The Society's views on the planning application are summarised below:-
We have concerns bout both the proposals and their implementation. However in resolving these there could be significant changes requiring a further application to be made. We hope that our comments will be taken as a positive contribution to achieving the aspirations of the project to achieve a ‘School of the 21st Century’ in accordance with the Scottish Executive Policies and Guidelines now that the choice of site has been made. We all want the best for Peebles.
Presentation.
We found the white model useful to see the building; however it would have if there were a series of photomontage views of the building and its placing on the site from various important viewpoints as part of a proper thorough landscape impact assessment; this is a serious deficiency and hardly serves to sell the proposals. We also find a number of inconsistencies between the architects’ and the landscape drawings in the placing of both the building and sports facilities. We assume that the larger scale drawings have precedence, but this needs to be confirmed.
Site Access. There are no proposals shown for the site access roads from the A72. We would have expected a planning application for such a development to fully address the works associated with the access to the site especially as early discussions on the project indicated the need for a turning lane to be introduced. Had this been a private development such information would have been required.
The Kingsland School Travel Plan states that there will be a road widening for a right turn safety lane into the public car park. This is not shown on the application drawing. It should be demonstrated how this is to be achieved bearing in mind the proximity of the Cemetery boundary wall and the closeness of the car part to the A72. The location and detail of the pedestrian crossing in relation to this entry needs to be detailed.
There is no reference in the ‘Travel Plan’ to a similar widening of the road for a right turning lane for the road entry to the school itself. Even without a road widening the sight lines for the entrance would need to be demonstrated.
The public car park has had lines marked for car parking but it is also used by lorries overnight and by busses to wait during the day. There is little provision for just setting off pupils at the west end of the car park which we consider to be inadequate, and no provision for school buses referred to in the PS Travel Plan. Also, there is no indication of a footpath around the outside of the parking bays for safe circulation clear of moving cars; this is especially critical on the south side close to the main road.
Site Layout.
The drawings have no site contours to show the existing ground form and the modelling of the ground to accommodate the building. We have therefore referred to a site contour plan in our possession in reviewing the design using the building levels given on the application drawings.
The proposed building has been quite well positioned in relation to the shape of the sloping site. A good use has been made providing ground level access to the rear classrooms.
However, we are pleased that the potentially highly engineered and visible playing field has been moved from the upper level, as this will preserve some of the landscape backdrop to the buildings.
We are concerned that the south-west end of the building comes so close (10m) to the road boundary and that the ground plate level here at the corner is some 3m above the present ground level. The classrooms here are very close to a source of noise from the road that is likely to be intrusive. We note that there will be tree planting to the west that we hope will screen this very obvious end gable and raised profile of the building.
The groundworks at this corner are a problem on account of the closeness of the building to the site boundary, the closeness of the contours here and the change in level from the single storey of the western pair of classrooms to the two storey part to the east. There are a number of problems that need to be resolved:
1.The wedge shaped ground form at the pupil entrance is most unsatisfactory and constricts access to the entrance. The steep ground slope here as shown on the drawings could become a safety hazard.
2.There will be a steep slope from the playground area to the site boundary fence of a 3m drop in 2m horizontal (1 in 0.66!) (see the SW elevation drawing – note that this drawing does not show the proximity to the A72, the hedge and the boundary fence)
3.The site 1/500 landscape drawing shows a ramped path around the school to reach the rear classrooms and western play area, yet the 1/200 building plan shows a series of steps. The change in level here would make a ramped path very difficult to achieve.
Achieving ground plates for the other parts of the project also proves to be a problem and results in prominent ground modelling such as the south-east corner of the nursery play area, at 2.6m above existing, and the cut and fill at each end of the grass playing pitch will be some 1.6m.
Due to the way that the buildings and sports pitches have been fitted onto the site there is little opportunity for future expansion, especially of outside sports facilities.
Sports Scotland Standards.
The original schools consultation document stated that “There is now a far greater emphasis on sports and games to encourage activity for children that will lead to healthier lifestyles as adults”, and Scottish Borders Council have stated that they will be working towards Sportscotland’s latest requirements. It would appear that these requirements have not been met and that the sports facilities have been seriously compromised as follows
1.Sportscotland require 2 PE teaching spaces for a 2-stream school – a 2-court gym hall (18mx18m minimum) plus a smaller secondary space with a lower ceiling. It also recommends against doubling up as a dining hall on account of environmental standards. This is also incompatible with the 21st Century Schools aim to make dining areas more welcoming. This part of the building is compromised and is severely underproviding facilities. There is no room on site to extend this part of the building now or in the future without considerable ground engineering works to dig into the hillside. Once built there is no flexibility for the future.
2.There is an inconsistency between the landscape drawing at 1:1250 and 1:500. The 1:1250 shows an overall dimension for the grass pitch inside the ball fence of some 84x45m overall whilst the 1:500 drawing indicates a pitch of some 66x36m. Clarification is required. However, neither of these alternatives complies with Sportscotland standards, as a 2-stream school should have one Synthetic Grass Pitch 60m x 40m with 2m margins, or two grass pitches of the same size plus 3m margins and a 6m lateral strip to allow for the pitch to be moved to reduce wear. The proposed provision of a small tarmac play area at the extreme western end does not compensate for these deficiencies.
3.The site landscape plan shows the grass pitch with its ball stop fence 4.5m from the site boundary. Within this space there is shown a hedge. The existing silver birch trees are not shown so we assume that they are to be removed. Yet the large site elevation provided to show the new buildings in the site context and the site model have these existing trees shown remaining as a screen. We note that these trees have a 4m canopy within the site boundary. If these trees are removed the ball fence will be most visible, specially where the games pitch is raised some 1.6m above the present ground level at the east end. Equally the removal of these trees would expose floodlighting of the games pitch should this be provided now or in the future.
On-site Staff Parking
Whitbybird’s Transport Assessment estimates that there will be 40 staff cars, but there appears to be provision for only 25 within the site.
Building Design.
The building is intended to be a ‘landmark building’ by which we consider that it should be an outstanding example of good internal planning, respect for its surroundings and finely detailed with appropriate use of materials. In this location it should harmonise and not vie with its surroundings.
We like the layout in plan of main corridor, the administration and the clusters of classrooms. The main corridor with plenty of daylight will be most pleasing. However, by proposing ‘brise soleil’ screening to the deep recesses of the pupil entrances, any view out will be denied.
The pairs of classrooms fragment the building well but it is a pity that more advantage was not taken of the sloping site to layer the roof line in response to the immediate landscape setting. The classroom units set the scale of the building and introduce a horizontal element linking the classrooms to ground in a satisfactory way. The introduction of a masonry base to the building is good but its advantage is lost in the design of the administration and library section of the building.
The entrance, administration and library are referred to in the design statement as the ‘focal point’ of the school and to be the focus of ‘a public building on the edge of town’. Surely the whole school building as a unity should have this attribute in a suitably restrained form. The entrance itself is pleasant, open and inviting but we find the administration and library part most disappointing. The attempt to make a ‘barbican’ ‘ castle’ ‘fortress’ does not succeed, specially on this site in Peebles where there is a fine historic castle close-by. Is this really the best expression for this part of the building? Surely this part should also be welcoming, light and airy for both children and staff. Both the drawings and the model show that this part is totally out of scale with the rest of the building. We also find that the forcing of the fenestration into the ‘fortress’ idiom has compromised the use of the interior. The deep closely spaced vertical bars to the library window will obstruct the view out unless the viewer is standing actually at the window. The opportunity for the view out is referred to in the design statement. We would suggest a reappraisal of this part of the building.
The pupil entrances could benefit from having canopies to protect the entrances.
The separate Nursery School will be a most pleasant little building with its intimacy and light appearance. Why not clad this building in natural timber as the other classrooms.
Materials.
The use of timber and drystane is fine and appropriate to the site but we have reservations about the use of ‘off-white’ render.. The building should regress into the site and highlighting parts in white will be too harsh. The whiteness of the nursery building and part of the admin building will stand out too much in the landscape setting. Drawing attention to the service yard in this way is also unwarranted - why not continue with the natural timber of the upper part of the games hall. The type and finish of the timber is not given; we would like to see the timber and its finish [be] chosen to give and retain some colour, otherwise the building could become rather drab over time as it weathers. We would suggest that the range of walling materials is limited to the drystane, natural timber and grey aluminium windows to give a simple palette. The aluminium fascias of the east and west entrances could be livened by the introduction of some bold colour, possibly related top the colour scheme of the central corridor.
We are concerned about the use of grey profiled metal roofing as it will be shiny particularly on the south facing pitches facing onto the A72. Here is a good opportunity to use a ‘sedum’ roof to merge with the backdrop of the hillside behind. Such a roof will also be more sustainable as it will slow the storm water runoff. It will also reduce the noise intrusion of rain beating on a metal roof!
General
The inadequacies of the site layout and design as the south-western end, the all-important sports facilities, staff parking and pupil drop-off and collection are clearly consequences of the difficult sloping site.
We trust that these observations are useful and can be considered further as part of the design development to produce a building to the standard that we would all wish to be achieved. We would be willing to meet to discuss the issues that we raise should this be of assistance to you.
The following is the correspondence between the Society and the Council in May 2007:-
Mr David Hume Chief Executive Scottish Borders Council Council Headquarters Newtown St Boswells MELROSE TD6 OSA
22 May 2007
Dear Mr Hume
REPORT BY THE DIRECTOR OF EDUCATION AND LIFELONG LEARNING -OPTION APPRAISAL TO DETERMINE THE BEST VALUE SITE FOR THE NEW KINGSLAND PRIMARY SCHOOL
We refer to your letter of 17.04.07 saying that you had asked the Director of Education to respond to our letter of 13.04.07. We have now received a letter from the Director, and enclose a copy of our response.
We believe it must be difficult for the Director of Education to deal with our representations, which are largely questioning his established view. That is why we wrote to you originally, in the hope of obtaining an independent and objective consideration. We still hope that that might be possible, and look forward to hearing from you.
We are not trying to change the Council's decision. That would be unrealistic. We do, however, believe that the best Value Report was flawed and, in particular, that the timing of its presentation for decision was premature. To submit the report in favour of the Neidpath Grazings site before the precise location of the building and its associated facilities on that site had been determined, and with little opportunity for consultation and challenge, was, in our view, misleading and therefore wrong. That is demonstrated by the shortcomings of the site in respect of sports facilities and parking that have now been revealed by the planning application, but which were entirely absent from the Best Value Report. Those shortcomings have always been inherent in the site, but apparently ignored by DELL. The timing would appear to have been dictated by the determination to obtain the desired decision rather than the need to present a comprehensive, objective and balanced report to the Council.
We believe such practice by the Council to be unacceptable, and should not be repeated. We would be happy to meet with you to discuss.
Yours/$incerely I/
Peter Norris Copies to: Director of Education and Lifelong Learning
Chairman Tweeddale East and Tweeddale West Councillors
Peebles and District Community Council
~
Mr Glenn Rodger
Director of Education and Lifelong Learning
Scottish Borders Council
Council Headquarters
Newtown St Boswells
MELROSE
TD6 OSA
22 May 2007
Dear Mr Rodger
REPORT BY THE DIRECTOR OF EDUCATION AND LIFELONG LEARNING -OPTION APPRAISAL TO DETERMINE THE BEST VALUE SITE FOR THE NEW KINGSLAND PRIMARY SCHOOL
Thank you for your reply dated 25.04.07 (received 03.05.07) to our letter of 13.04.07. Our letter i) sought a response to our original observations (04.03.07) on your Best Value
Report (presented on 06.03.07); and
ii) drew attention to misleading aspects of the report which have now been revealed
by the planning application for the Neidpath Grazings site.
We have tried to deal fully with your reply in the addendum attached herewith. In summary, however, we continue to be particularly concerned about the following matters. In the hope that Tweeddale members of Scottish Borders Council will pursue these concerns with you, we have copied the letter and addendum to them
1. The provision of outdoor and indoor sports facilities.
Whilst the Best Value Report stated that these would meet the latest guidelines from sportscotland, the facilities shown in the planning application, both outdoor and indoor, fall far short of those guidelines - despite your assertions to the contrary. Full details are provided under 'A' in the addendum.
2. Community use
Whilst community use is a stated requirement, the natural grass playing field of less than sportscotland's recommended dimensions will offer very limited, if any, opportunity for community use (with or without floodlighting?); and, without a standard two-badminton-court hall, there will be even less opportunity for indoor community sports activity. (See Addendum, A)
3. Car parking, drop-off/pick-up
Whilst the Best Value Report claimed that the town would benefit from the ability to use the school's parking facilities, completely the opposite will be the case. The subsequent need to locate the playing field where the school's parking facilities were to have been, and consequently to use the existing public car park for the school's purposes, will deprive the public. And, in view of the town's serious shortage of public car parks, your revelation that it is the Council's intention to move the existing bus and lorry parking from this site to some other so-far-unspecified site is not reassuring. (See Addendum, B 4.2)
___________________
4. Traffic control
Whilst the original proposals were for traffic control and roadway alterations on the A72 to be at the entrance to the school, it would seem that such measures would now need to be at the entrance to the "public" car park - but no details have been provided. (See Addendum, B 4.2)
5. Future expansion of the school
You say that you have identified an area at the western end of the school to provide up to 120 extra pupil places. However, no drawings have been provided. Any such expansion would be technically difficult, and could have adverse visual implications. Full details should be provided with the current planning application. Furthermore, in view of the space constraints imposed by the sloping site, it seems unlikely that the associated extra indoor and outdoor facilities for such a large increase in pupil numbers could be provided. (See Addendum, A 8)
We believe that these shortcomings of the Neidpath Grazings site have now clearly emerged, but have been disregarded. Our urgent hope is that they will be addressed before the final detailed planning application for the new school is submitted.
Peter Norris Chairman Civic Society
Copies to: Chief Executive
Tweeddale East and Tweeddale West Councillors Peebles and District Community Council
ADDENDUM to letter of 22.05.07 to Director of Education and Lifelong Learning re:
REPORT BY THE DIRECTOR OF EDUCATION AND LIFELONG LEARNING -OPTION APPRAISAL TO DETERMINE THE BEST VALUE SITE FOR THE NEW KINGSLAND PRIMARY SCHOOL
A. Re Director's letter of 25.04.07
1. Thank you for corifirming that you are providing a 'multi use pitch' of 66x36m and a
'synthetic pitch' of 36x18m. These are the dimensions within the ball stop fences shown on the
1:500 scale drawing, Kingsland - Landscape Layout, submitted with the planning application
07/00479/SBC. We note, therefore, that the 1:1250 scale drawing also submitted with that
application and showing different dimensions is incorrect, presumably because of an incorrect
scale. We also note from the planning application that the 66x36m pitch will be grass, and that
the 36x18m pitch will be tarmac.
2. You say that you are providing close to 1 hectare of playing fields. Could you let us have
a scale drawing, please, showing where they are? The 66x36m grass sports pitch is 0.2376ha,
and the 36x18 tarmac play area is 0.0648ha, totalling only 0.3024ha - ie somewhat less in fact
than the Q.4ha statutory requirement. If you are including informal access areas and the sloping
rough grass area to the north of the proposed building, we think you should qualify the statement
by describing their nature, conformation and purpose. Although beneficial, we very much doubt
that they are acceptable as part of the statutory requirement for playing fields.
3. You said in your Best Value Report to the Council dated 06.03.07:
"6.2.2 Sports facilities on either site would meet the latest guidelines from sportscotland (our underlining) that includes a multi use games area (with a synthetic surface), a grass area for athletics/games, separate games hall and informal fixed play equipment around the school to encourage a wide variety of physical activity."
4.1 Concerning outdoor facilities, the latest guidance from sportscotland, School Playing Fields - Planning & Design Guidance, is:
"page 24: sportscotland considers mat a synthetic grass 'sevens' pitch is the optimum
provision for primary schools........... Whilst a synthetic grass sevens pitch is recommended, if
none is provided men a grass sevens pitch will be required for each stream at a school."
pages 36/37: To meet both curricular and extra-curricular needs, a primary school should have access to:
• hard surface areas for play, informal social purposes, assembly and physical
education and sport;
• informal social areas;
• landscape and habitat areas; and
• playing fields.
sportscotland's recommended unit of provision is a small multi-purpose SGP (synthetic grass pitch). A pitch of around 60x40m (plus safety margins of 2m on all sides) will be suitable for PE, small-sided sports and informal activity. If only grass playing fields are provided, a similarly sized pitch will be required for each stream at a school, with safety margins increased to 3m and the provision of a 6m wide lateral strip to allow the pitch to be moved to reduce wear and tear.
As with secondary schools, the School Premises Regulations apply. Local authorities should ensure that their playing field provision is compliant. (This is elaborated on page 27.)"
4.2 Clearly, therefore, what you are providing does not meet the latest guidelines from sportscotland and, therefore, does not comply with the undertaking in your Best Value Report, as set out below. We fail to understand how you can claim that the facilities that you are providing are "well within the guidelines", when clearly they fall far short of those guidelines.
4.2.1 In sportscotland's guidelines, playing fields are a separate category and requirement from
hard surface play areas, informal social areas and landscape and habitat areas.
4.2.2 To meet the guidelines, grass pitch size needs to be 'around' 66x52m within the ball stop
fences, including safety margins and lateral strip - and your 66x36m is substantially less than
that. Even without a lateral strip to reduce wear and tear, the actual playing width will be only
30m instead of the recommended 40m.
4.2.3 If you are not providing a synthetic grass pitch, two grass pitches are required, not one.
4.2.4 If a smaller, 18x36m, 'synthetic' pitch is considered to be a reasonable substitute for the
second grass pitch, a tarmac surface as specified in the planning application (whether dense or
porous macadam) hardly seems to be appropriate as it does not provide 'playing field' conditions.
5.1 There are several other references in sportscotland's guidelines that have some bearing.
"page 2: School playing fields can also be a valuable resource for community sport. (See
also 6.1 below.)
page 19: The maximum number of pupils that the school is likely to accommodate in its
lifetime should be considered in planning for school playing fields.
page 36: Locating pitches close to boundary fences can be dangerous if balls can stray onto
roads, footpaths ........
page 37: Where pitches are to be located adjacent to roads ......... larger clearances may be
required.
If any facility is to be floodlit, care needs to be taken to ensure that light spill does not cause a hazard or inconvenience to neighbouring properties.
page 44: In order to obtain the full benefits from the increased capacity of SGPs and Multi-
use games areas, floodlighting for evening and winter play is essential
5.2. In these respects, also, what you will provide falls short of the recommendations in sportscotland's guidelines, as follows.
5.2.1 The Best Value Report (10.1) refers to community use; and the September 2005
consultation document refers (page 11) to the provision of playing fields for community use; as
does Scottish Executive guidance. A grass pitch of reduced size and without scope for lateral
movement to reduce wear will have less availability for community use.
5.2.2 Whilst your intentions are substantially less than sportscotland's guidelines even for the
current development of a two stream primary school, you nevertheless say that expansion could
provide up to a further 120 places. Clearly, therefore, you are not meeting sportscotland's
playing field guidelines to provide for the future capacity of the school - and it is clear from the
current limitations of the site that mere will be no opportunity to do so in the future.
5.2.3 As no details have been included in the planning application, it is not clear whether the
ball stop fence will prevent balls from going onto the adjacent A72 but, as it would appear from
the planning application that the existing trees along the roadside boundary are to be removed,
this must be an issue of some concern.
5.2.4 Although floodlighting is not referred to in the current planning application, the
sportscotland guidelines recognise it as an essential for full, including community, utilisation. It
is doubtful that it would be acceptable so close to the A72 entrance to the town, again curtailing
community use.
6.1 Concerning indoor facilities, the latest guidance from sportscotland, Primary School Sports Facilities, is:
"page 2: sportscotland urges all local authorities to consider the potential contribution new
and refurbished primary schools can make to meeting the sporting needs of local communities. The provision of new school facilities should be planned as part of a wider strategy for all sports facilities in the area.
page 3: sportscotland considers a two-badminton-court hall to be the starting point from
which to plan the provision of PE facilities in a primary school. This space should be a minimum of 18mxl8m, with a minimum height above the playing area of 6.7m.
Even a two-court hall can only accommodate a limited number of sports. A three-
court hall would in fact allow for a significantly greater range of activities............. If significant
levels of community use are expected, serious consideration should be given to providing a three-court hall or larger.
page 5: the 28 hours of activity time required for two-stream schools means two PE
teaching spaces are required. The principal space should be a two-court hall, and this will be used principally for PE. The secondary space should be smaller and more suited to PE by younger children, and to movement and dance-based activities. This space will have a lower ceiling height man the main hall and should be designed to provide an intimate, comforting environment for younger children. It should be noted that in a two-stream school this space will by no means be required for PE at all times and therefore should be designed as a dual-purpose space.
page 7: sportscotland recommends that school dining does not take place in the same
space as PE. The time taken to set up and then remove tables and chairs encroaches significantly on the time available for PE, and regular moving of equipment or furniture is likely to quickly damage or degrade the floor. Even after removing the chairs, the floor must be cleaned and dried before subsequent use, both taking up time and presenting a safety risk if not done thoroughly. Also, the serving hatches and other design features required for a school dining area are not appropriate for a sports facility, particularly one available for wider community use. A dining area will also need to be at a higher temperature than a PE teaching space, and heating/cooling of the space will take some time. Finally, schools should aim to create a welcoming and pleasant dining environment, to encourage healthy eating habits in pupils. A sports hall with dining tables is unlikely to provide such an environment. Only in very small rural schools with limited requirements for PE may the same space be suitable for dining."
6.2.1 Clearly, therefore, in not providing a separate sports hall, the undertaking to do so
and the undertaking to meet the latest guidelines from sportscotland, both given in the Best
Value Report, are not being fulfilled - and in view of the spatial constraints imposed by the
sloping site it will be very difficult to do so in the future to provide for an expanded roll. Again,
we fail to understand how you can claim that the facilities that you are providing are "well within
the guidelines", when clearly they fall far short of those guidelines.
6.2.2 Also, community use is not being provided for. Apart from sportscotland's guidelines,
the Scottish Executive state under School Estate Related Policies in their document, The 21st
Century School:
"page 43: Ensuring mat school-based sports facilities both in primary school and secondary school are available for community use is essential not only in best value terms but also for the benefits to pupils and schools through forging links with local sports clubs."
7.1 Whereas your Best Value Report said that the sports facilities (both outdoor and
indoor) at both Violet bank and Neidpath Grazings would meet the latest guidelines from
sportscotland, the position seems to be that whilst it would be perfectly possible to meet
them at Violet Bank it is impossible to do so at Neidpath Grazings. An early drawing for
Violet Bank showed a 70x45m 'football pitch' and a 50x30m 'all weather pitch' with ample
space on all sides, and there would have been fewer spatial building constraints upon provision of
the indoor facilities.
7.2 The Best Value Report says:
" Option 1 - Neidpath Grazings
6.2.4 Concern has been expressed in relation to the position of the pitches with regard to the proximity of the adjacent golf club. Following discussions with the project's engineers, further work is being undertaken to move the pitches to a lower position on the site."
This statement studiously avoids any indication of the difficulty of meeting sportscotland's guidelines at a lower position on the site, and therefore of meeting them anywhere on the difficult sloping site at Neidpath Grazings. In view of the importance that you have always attributed to
playing fields (page 6 of the September 2005 consultation document) and the wider policy of community use, this must be a serious issue
8. You say that you have identified an area for expansion at the western end of the school to provide up to 120 extra places. It is not clear whether this includes, or is additional to, the 60 extra places indicated on the planning application drawings. In any event we believe that doing so will be far from straightforward and could be unacceptable visually. To enlarge the classroom capacity by more than 25% must significantly increase all the associated indoor and outdoor requirements - and we do not believe that that can be achieved. In our view, planning applications for developments such as this by local authorities should show all anticipated extensions, in order to ensure that they are future-proofed and sustainable, and that they will remain acceptable when enlarged.
B. Re Schedule with Director's letter of 25.04.07 Rel.
A detailed design for Violet Bank is not included in the scoring for Project Delivery, and therefore the reference to it in your reply would seem to be something of a red herring. The main components of Project Delivery are planning, acquisition and ground conditions, and we maintain our view that you neglected all three in respect of Violet Bank and that therefore its low scoring on project delivery was not justified. As the remediation and use of contaminated land is a local authority responsibility, there would seem to be no excuse for this aspect at Violet Bank not being vigorously pursued as soon as the site was identified in the draft Local Plan, if not before.
Re 2/2.1
Our point here is that elected members were not suitably advised of the difficulties associated with the unresolved issues. This is our central criticism of the Best Value Report.
Re 2.2
You fail to confirm that the intention is still to provide a "landmark building" at Neidpath Grazings - ie a building with a greater sense of place than might be required for a less sensitive site.
We have a copy of the letter of 16.03.07 from Architecture+Design Scotland with their report on a planning application for the relocation of Kingsland at Neidpath Grazings. Unless you have had further consultations with A+DS, your statement pointing out their "favourable view on design" would seem to be misleading. The consultation was a panel assessment of planning applications for Kingsland, Clovenford and Lauder primary schools, and concluded that "We are generally supportive of the designs", but expressed some concern with the selection of the site for Kingsland, called for more detailed layouts of the classroom spaces and development of the edge conditions between the existing and designed landscapes. Somewhat puzzling, however, is the fact that this consultation was on 27.02.07 - ie before the presentation of the Best Value Report on 06.03.07. Therefore, either A+DS were not considering the current proposals, or the current proposals were known before the Best Value Report and witli-held
Re 3
We note your generalised response and expression of your subjective view without supporting evidence. We also have a wider view than the letters in the Peeblesshire News, including comments from members of the public and other community groups. We believe, therefore, that the points we have made against your equal scoring of Violet Bank and Neidpath Grazings in terms of Community Support are correct, and that Neidpath grazings should have been shown less favourably.
Re 4.1
Concerning site contamination at Violet Bank, we do not wish to split hairs but we did not say that there was not an issue to be resolved - we quoted the consultants' conclusion that further limited surface soil sampling and assessment is considered to be necessary to demonstrate that this zone is suitable for its potential proposed use as a school development. We said that (in view of that) it is difficult to see that there is (likely to be) a problem (of the magnitude stated in the Best Value Report).
Re 4.2
Whilst you say that you do not agree with any of our conclusions, you fail to address the fact that Neidpath Grazings will generate 18% more car travel than Violet Bank, and that the Best Value Report (9Ac) describes this as being "too similar to provide a meaningful differentiation"!
Concerning the use of the public car park for pupil drop-off and pick-up, you say that it is the Council's intention to relocate the existing bus and lorry parking to elsewhere in the town. We are at a loss to know how to regard this revelation. Where will it be relocated to? The town is already seriously short of car parks, without the Council being able to offer any solution, and therefore it would seem that any relocation must reduce the public parking potential. The Best Value Report misleadingly said:
"10.1 Community benefits Option 1 - Neidpath Grazings
d. In addition the town will benefit from the ability to use the school's parking facilities to provide additional parking for events at Hay Lodge Park."
In fact, however, quite the opposite will be the case. Now mat the playing field is to be located where the school car parking and pick-up/drop-off areas were to have been, the relocation of the school's requirements to the public car park will be to the disadvantage of the town - maybe particularly to the disadvantage of visitors to the Hay Lodge Health Centre.
Details of the crucial design requirements for access into this area from the A72, and use of it as a combined public car park and school drop-off and pick-up location, have not yet been made available.
Re 4.3
You fail to comment on our point here that the Neidpath Grazings option ignores national and local policies relating to remediation and use of contaminated land and the reduction of car travel. The Best Value Report does not even acknowledge these policies and seek to justify setting them aside. It would appear that the Council do not consider that such policies apply to their own activities - even though that is particularly difficult to believe in respect of contaminated land.
Re 5.
We do not ask you to rehash the points you have already made in the Best Value Report. Whilst it does deal with roll projections (our 5.3), it does not deal with the matter of larger schools and larger catchment areas (5.1), nor the matter of a Catholic-faith school with a 75% non-Catholic roll being an integral part of the secular provision (5.2), nor with the possibility of improving traffic flow generally in the areas by providing a bridge at Dalatho (5.4). We believe that these matters should have been clearly set out in the report so that councillors were fully aware of the implications of the proposal.
Also, you have not responded to our view (5.4) that 6.1.14 of the report would seem to be totally unfounded. It says that Violet Bank would cap Halyrude at a lower level reducing capacity by at least 100 places. This is particularly important as it is used as a key factor in the costing conclusions, claiming that the loss of the 100 places would incur a f 3.5m cost penalty (7.2.h.b). Unless it can be substantiated, it must be regarded as seriously misleading.
Re 6.
We note what you say about Project Costs. As far as Neidpath Grazings is concerned, the actual costs will of course become apparent in due course. We can only hope that higher than expected ground work costs will not demand economies in the quality of build.
Re 6.1
Your response re the lease does not seem to recognise the important distinction between the Council and the Common Good; and the very limited draft terms of the lease which have so far been revealed seem to reflect the same attitude. Terms relating to procedure and responsibilities at the end of the lease are an essential part of any lease and, as far as we are aware, have not been defined in this case.
Re 6.2
You appear to be assuming that Glen Craig is not Common Good but, so far as we are aware, that has not yet been established. If it is Common Good, it needs to be valued as development land.
Re 6.3
We note that you say that the previous estimate for the replacement of the Glen Craig Nursery included the cottage which is now being retained. Whilst the September 2005 consultation
document (page 14) says "including greenhouses and tunnels", it makes no mention of the cottage.
Re 6.4
Yes, it remains our view that the costs for the Neidpath Grazings building will prove to be grossly underestimated. Whilst we do not seek to criticise the work of professional cost consultants, who will have prepared preliminary cost estimates on the basis of available information, we believe that, because of the difficulties of the site and the technical design matters still to be resolved, costs could not be estimated sufficiently accurately until the precise position and design had been decided - and therefore should not have been. This view is supported by the fact that the location and layout now being proposed are substantially different from those presented, and presumably used for estimating costs, at the time of the Best Value Report. We also believe that the comparative costs for Violet Bank were misrepresented in the Best Value Report, in favour of Neidpath Grazings.
Re 6.5
Yes, we accept that there is a cost difference between remediation for informal recreation and for a school building, but we question whether or not the Council's remediation obligations and the possibility of Scottish Executive grant were taken fully into account - as well as the possibility of placing the school building on the additional land and the playing fields on the Council-owned land.
Re 6.6
On the basis of the drawings submitted with the planning application for the refurbishment of Kingsland for Halyrude, we suspect that it will be necessary to extend Kingsland to provide School of the Future accommodation for 200 children. You say (in your letter, not in the schedule) that there are 2 "bays" which will provide additional classroom spaces as the school grows. If these two bays are the 2 former classrooms that are to be used initially as shared 'wet' areas, they would seem to be essential as such to supplement the small classrooms - and their loss would be a retrograde step which, presumably, would be unacceptable. The cost saving, previously suggested by us, of having a smaller capacity Halyrude at Kingsland, would be achieved in not having to extend Kingsland.
In summary, we wish to record that we find your reply inadequate. In particular, we consider that what you say about the sports facilities meeting the latest guidelines from sportscotland is incorrect.
We are making this detailed addendum available to our Tweeddale councillors in the hope that they will pursue our concerns with you before the final detailed planning application for the Neidpath Grazings school is submitted.
Peter Norris will pursue our concerns with you before the final detailed planning application for the Neidpath Grazings school is submitted
.
Peter Norris Copies to: Chief Executive
Chairman Tweeddale East and Tweeddale West Councillors
Peebles and District Community Council
Mr Ian Lindley
Director of Planning and Economic Development
Scottish Borders Council
Newtown St Boswells
MELROSE
TD6 0SA
19 October 2007
Dear Mr Lindley
SCOTTISH BORDERS LOCAL PLAN
REPORT INTO OBJECTIONS TO THE FINALISED LOCAL PLAN
Objection 1821/1/1 by Scottish Borders Council
Neidpath Road School Site
We refer to this objection by Scottish Borders Council to its own Finalised Local Plan, and to the Reporters’ recommendation in response that there should be no change to the local plan – ie that the objection be rejected. Accordingly, the Reporters’ recommendation is that the development boundary should remain as proposed in the Finalised Local Plan to include the Glen Craig Nursery Site but to exclude the Neidpath Grazings land, and that the combined area, referred to as the Neidpath Road Site, should not be allocated for a primary school development.
We see, however, from Appendix A to your report, which is to be submitted to the Council on 25.10.2007, that, nevertheless, you recommend that the combined area should be allocated for a school site and that the development boundary should be adjusted accordingly.
We note the considerations that you list in support of that recommendation, and do not believe that they justify it.
- You say: “The detailed planning consent reviewed by the Scottish Executive shows very significant variations from the initial designs discussed at the Local Plan Inquiry.” Whilst that is correct, those changes relating to relocation of the playing field and consequential relocation of staff parking and pupil drop-off and pick-up etc could have been equally unacceptable to the Reporters.
- You refer to the Option Appraisal (Best Value Report) that has been produced in favour of the Neidpath Road site. As that report did not reveal the significant changes referred to above, we have previously questioned the validity of its approval by the Council.
- The school travel plan and the further transport assessment referred to by you, together with the major changes referred to above, can be seen as attempts by the Council to minimise the inherent disadvantages of the site.
The Reporters’ reasons for rejecting the proposal are comprehensive and wide ranging in the context of the town as a whole, whereas the planning applications and consents were site specific and, as such, more limited.
The Reporters’ recommendation, which you are accepting, that sites at Venlaw and Violet Bank should be allocated to provide a further 85 houses in the northern part of the town, increases the unsuitability of the Neidpath Road site. And this is endorsed by the Reporters’ observations about the proposed use of a denominational school in the most northerly part of the town to meet non-denominational needs.
The following statement by the Reporters is also worthy of note:
“… this is an unusual procedural situation, in that the Council is seeking to promote a departure from its own finalised local plan through an objection lodged on behalf of one of the Council’s own departments. The development which it seeks to accommodate is already provided for in an explicit land use proposal in the local plan (zSS4), which the Council does not seek to withdraw.”
The planning system, as the Reporters themselves emphasise, is intended to be plan led. Therefore, it is difficult to understand how, in such a matter of long-term importance to the town, the Council could be so determined to secure its own preference as to seek planning consent and Best Value endorsement so shortly before completion of the relevant Local Plan.
In connection with the Reporters’ conclusions and recommendations which differ from the Council position, we note your statements that:
“it is accepted that these have emerged from a thorough, comprehensive and independent process”;
and:
“In this context it is recommended that the Council accepts the recommendations from the Reporters except in a very limited number of particular circumstances predominantly where decisions have been taken on individual planning applications in the intervening period.”
We can see the reasonableness of this for planning consents given to private developers, especially where work on site has already begun. We do not, however, believe that the same reasoning can be applied to the Council’s own proposals where work on site has not yet begun – especially as, in this particular case, the local councillors had always undertaken to ensure that preparatory work in respect of the alternative site at Violet Bank would proceed in parallel with that at Neidpath Road to facilitate the development of Violet Bank if adopted.
Accordingly, we ask you to change your recommendation and to accept the recommendation of the Reporters that there should be no change to the Local Plan. We believe that anything other than this would be fundamentally contrary to established government policy, which is that development provision and control should be plan led.
Yours sincerely
Peter Norris
Chairman
Copies to: Mr D Hume, Chief Executive
Tweeddale Councillors
Peebles and District Community Council
