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1.

Traffic on Fortune Green Road


After reviewing the submitted Transport Assessment (Supporting Documents-3222075 FINAL TRANSPORT ASSESSMENT.pdf), we are highly concerned with its inaccuracies and how it deliberately understates the potential impact on traffic on Fortune Green Road. The report contains a number of assumptions which understate both the number of cars travelling to the site and impact they would have on traffic. These are discussed in Appendix 1. As per paragraph 7.10.1 in the Transport Assessment, the school site is open from 8 am with a start time/registration of 8:45 am. This means that in less than 45 minutes all parents dropping off children need to enter the site. Per table 7.4.8 in the report 38 pupils will use individual cars and 16 will car-share, totalling 44 car trips each morning and each afternoon (see Appendix 2) This means that average one car every minute needs to be entering the site at the bottleneck at the gates (where it is difficult for standard size cars to pass each other), swing around into the courtyard, stopping for the car in front, once the traffic light turns green needs to dive down the single lane ramp (avoiding children being walked across the mouth of the ramp in order to get to the Southern classrooms), turn 180 degrees at the bottom of the ramp, manoeuvre past cars waiting to come up, dodge children already in the car park being walked to the exit (there are no pedestrian walkways children will be walking in the path of vehicles), park up, unload their children, and then join the queue to leave the car park, then once up and out, join the queue to turn right out of the site and onto Fortune Green Road. This is absolutely unworkable. In the likely situation that there are queues to exit the site leading to a backup, chaos would ensue. There would be nowhere to go. The ramp would be blocked, leaving cars stranded in the car park and the entrance to the site full, leading to tailbacks on Fortune Green Road. This is using the calculated trip numbers as assumed in report, which is based on a school extremely close to a tube station, unlike Fortune Green. Using the trip profile of Abercorn School itself produces 62 cars each morning from parents (Appendix 2). Add to this the increased distance from homes increasing the probability of cars being used as well as the car usage by residents and the staff member and the numbers are unsupportable. As explained in Appendix 3 the Daily car trip rates and car trip generation profile of trips to and from the site during the day can be ignored as it is nonsense.

The following is from 7.9.3 of the report:


Assuming 100% occupancy at the school and all pupils arrived within a single hour, in the AM peak, there would be a maximum of 50 inbound car trips (45 for the school plus 5 for residents) compared to 19 in the permission. The TRICS analysis in 7.[11] (Authors note: the report incorrectly refers to table 7.10 rather than 7.11) indicates that in reality car trip generation in the peak hours would be less than this.

We have shown why the 45 inbound trips (44 student cars and 1 teachers car) are very likely to be an underestimation. We have shown that the TRICS analysis in nonsensical and common sense tells us that all trips will be between the opening time of 8 a.m. and registration time of 8:45 a.m. Therefore the inbound car trips exceeds the maximum of 19 as per the permission in Table 7.2 Consented Use Vehicle Trip Generation from the Colin Buchanan TA 2003.

2. Plans to Use the Underground Car Park at Alfred/Joan Court


The entrance, courtyard and car park at the site are not designed to cope with heavy levels of traffic nor pedestrians. The entrance to the site is narrow; when the gates are open they swing inwards, and they naturally reduce the width of the road, and two family-size vehicles going in opposite directions would have difficulty passing each other at this point. The application fails to make explicit and prominent the fact that the ramp to the car park is a single-lane only. This significantly restricts efficiency of movement. The car park itself is cramped. Two of the proposed parking spaces for the school are said to be unusable due to the angles of entry required. There are no designated pathways for pedestrians. Children walking from the designated parking up to the other side of the car park to their designated exit will be walking into oncoming traffic. The impact of this additional traffic and exhaust fumes in the car park has not been assessed at all and obviously could have a negative impact on the health of the students, residents and especially the school staff who will have to spend extended periods of time in the car park. The intention is also that students are brought from the car park up into the north unit and those that are based in the south units will be walked across the courtyard, across the path of cars entering and exiting the car park. This is considered to be a very dangerous proposal, especially as exiting drivers will be able to see pedestrians only once they are directly in the path of the car!

Figure 1: View up the ramp from the car park

Figure 2: View from half way up the ramp. The fire exits in the wall opposite are the proposed entrance to the southern units. Note the wall on the left which completely obscures the view of any pedestrians looking to cross in front of the path of traffic and into the doors.

Figure 3: This is where the walkway from the north unit exits into the courtyard. Note that directly in front of it is a parking space for service vehicles, which according to the Transport Assessment would also be used for deliveries to the school. Note also there is no pathway and no space to install one.

Figure 4: Path of children across the mouth of the ramp and into the fire exit.

Figure 5: The photo is taken from the area of the school's proposed parking spaces. The arrow shows the direction of traffic coming from the ramp. In the distance the door to be used to exit the car park is highlighted. Children will have to be walked from cars to the door along the roadway. There are no walkways so they will be walking in the path of traffic.

A major concern of residents is the fact that this is an accident waiting to happen; mixing children and traffic in a confined space will eventually lead to a child being injured or worse.

3. Inadequate consultation and notice


The Statement of Community Involvement states that The applicants have undertaken a comprehensive consultation programme with local residents and stakeholders While some consultation has occurred we note: a) Joan Court residents have from the start made clear their concerns re safety and nothing we have said appears to have been taken into account in this planning application. The consultation appears to have been an exercise in going through the motions rather than a real attempt to address valid and widely held concerns.

b) As owners (defined as is a person with a freehold interest or leasehold interest with at least 7 years left to run) of part of the land or building to which this application relates, our members do not understand why we have not received notices of application for planning permission under article 11 of the Town and Country Planning (Development Management Procedure) (England) Order 2010 and question whether this invalidates the application.

4. Noise Pollution
Contained within Design and Access Statement-3225840.pdf is the Acoustic Consultants Report. This report contains pages and pages of analyses of sound levels, construction materials etc, however, once again, there is a fundamental flaw. A key part of the application is the intention is to use the playground facilities and sports pitch (MUGA in the report) of Fortune Green Play Centre located directly west of the site and overlooked by residents, run by an organisation called PACE, PACE operates an afterschool club during term-time and an all-day holiday club during school holidays. In evenings the sports pitch is regularly used by members of the local community to playing football until 10 p.m. using floodlights. The residents strongly support PACEs use of the playground facilities and encourages local children to play together in a safe and welcoming environment. During these sessions, groups of approximately 20 children use the playground to have a great time, including screaming, shouting and, hopefully more often than not, laughing raucously. This can be clearly heard by residents overlooking the playground, especially as all these flats have balconies, however we have no complaint whatsoever in this regard.

Something which is completely ignored in the report is the plan for these playgrounds to be used by 180 children for their morning and lunch time breaks. The manager of PACE has told us that he estimates the capacity of the outside areas to be in the region of 50 to 70 children. This means that break-times will have to be staggered, with 3 to 4 different session for both the morning and lunchtime breaks, and as such the much increased noise levels will be occurring for sustained periods throughout the day.

Figure 6: View from a balcony of Joan Court directly overlooking the playground and sports pitch

This is not to say that residents would oppose a school using the playgrounds in such a way, especially if it was for the benefit of local children as there is a distinct problem of lack of school places for families living in the area. However as no assessment has been made of the impact on noise levels the pupils would have, and it is of course likely to be substantial, the application should be rejected. As per policy DP28 of the Camden Local Development Framework adopted in 2010 The Council will seek to ensure that noise and vibration is controlled and managed and will not grant planning permission for: a) development likely to generate noise pollution;

Appendix 1: How the Transport Assessment Underestimates Increased Traffic


In section 7.4.7 of the above it assumed that all students who currently live within walking distance of the existing school sites (37%) will use the school bus. This is extremely optimistic and takes no account of the much earlier start time required for such families. In section 7.4.9 it is anticipated that the catchment of the school will become more local to Fortune Green and therefore an increase in the walking and public transport mode share is anticipated. This ignores the fact that the feeder primary schools remain outside of the borough, so a large proportion of pupils progressing through the schools will continue to be based in the Marylebone area. In section 7.5.2 it is assumed that only one of the 25 staff will drive to work. Again this appears to be very unrealistic with the increased distance from the existing schools and the fact that the SHHS travel plan predicts 4. In reality in addition to increasing traffic, we expect staff cars to add to the parking problems on neighbouring roads. Figure 8.1 of the report on page 45 shows the peak period for southbound traffic on Fortune Green Road is between 8 a.m. and 9 a.m., with 732 vehicles. The report then goes on to discuss total average weekday traffic flows, which is irrelevant, and concludes vehicle activity at the school would have little impact on the amount of peak hour traffic travelling along Fortune Green Road. The number of additional student car trips extrapolated from Table 7.6 of the report is 44. Note that no matter the direction of approach to the site, whether from the North or South, every car will leave the site to return home in the opposite direction they came, therefore every car will add to the southbound traffic in the peak hour. An additional 44 cars represents an increase of 6% to the current southbound traffic of 732 cars. Given that southbound traffic can sometimes be at a standstill, an additional 6% would be considered to have a very significant impact especially with cars pulling into and out of the site magnifying the problem.

Appendix 2: Student Car Trips

As per the Transport Assessment, it has been assumed that car shares contain 3 students.

Appendix 3: Analysis of the Transport Assessments Daily car trip rates and car trip generation
Table 7.11 on page 41 which analyses the trips in and out of the car park during the day is nonsensical and underlines the way the report uses selective data to brush aside obvious facts. The number of parking spaces available to parents is 12 (ignoring the fact that 2 of these spaces are unusable due to the cramped conditions and the angle of entry required). A simple review of this data shows that it is completely illogical; for 6 periods the number of parents cars in the car park exceeds the capacity of 12, and 3 cars will apparently be staying overnight! In reality all morning car trips will be between the time the school opens at 8 a.m. and the time school registration begins at 8:45 a.m.