Comment Keep Osterley Green Metropolitan Open Land Planning

Appendix 1 Consultation responses: Comment Keep Osterley Green Metropolitan Open Land Planning restrictions on MOL have not been properly considered. The constant erosion of open space is unsustainable, irreversible and contrary to the NPPF, London Plan and Hounslow Local Plan. The application site has not been designated for development in the Hounslow Local Plan. The site is not currently used for education and as such the expansion or provision of new education facilities into open space would be contrary to Policy GB3. The justification for development in MOL, based on ‘very special circumstances’ rests entirely on the claim that there are no alternative sites within Hounslow. The proposal would result in a precedent of permitting inappropriate development in MOL. Sequential site assessment This analysis is deeply flawed and alternative sites are available which do not impact on MOL. The application site was not shortlisted as an educational site following the Borough’s site sequential assessment carried out by Cundall in 2014 and was highlighted as a non-preferred site in the Local Plan Sustainability Appraisal. The Nishkam School Trust had already chosen the site before the sequential assessment was undertaken. The initial parameters (e.g. site size, building height, requirement for a nursery) were inflexible and ruled out a wide range of other possibilities. The assessment does not follow an objective, non-arbitrary approach against defined criteria and scoring measures. A number of sites were included, such as Osterley Park, Syon Park, West Middlesex University Hospital, Mogden Sewage Treatment Works, the Treaty Centre, etc. that were entirely inappropriate and should not have even been considered. The assessment states that sites were only rejected once a clear statement of non-availability had been received, yet a large number of sites were ruled out on the basis that no response was received, so non-availability was assumed. Other sites were excluded based on their PTAL rating, even though the application site has the lowest PTAL rating. Other alternative sites are available, e.g. Sutton Lane, Gillette Buildings, Feltham Arenas, all of which are advertised on the Invest Hounslow website. Catchment area problems The school will do little to serve the area in which it would be built. The application site falls within the Brentford Priority Admissions Area – however 2011 census data indicates that there are not many Sikhs in Osterley (11.8%), Isleworth (2.4%) and Brentford (1.4%). This is reflected in the admissions data for the temporary Nishkam School on Wood Lane, which shows that under 16% of the intake come from Osterley, Isleworth & Brentford. The Nishkam Travel Plan shows that more than 45% of their current pupils live between 3 and 6km from the proposed site, and a further 10% live more than 6km away. This does not comply with statutory guidelines on school admissions (Academies Act 2010). The Nishkam admissions policy is for allocating up to 50% of the places to practising Sikhs over other faiths, the remaining 50% of spaces are assigned by random selection, with no regard to the distance of the pupil’s home from the school. Will the school really help address the shortage of school places within the Brentford PAA and consequently are they demonstrating ‘very special circumstances’ for a school to be based within the Brentford PAA. It is wildly inappropriate to place a primary school for 700 children in an area which is far from most of their homes. The greater than normal distances children would travel, plus poor public transport service, would mean an unsustainable increase in private car use. Traffic analysis The Transport Assessment lacks rigour and seriously downplays the severe impact that will arise in an existing traffic black spot that has the lowest PTAL rating. The traffic analysis is incomplete, grossly underestimated and based upon irrelevant baseline data. A more likely number of round trip car journeys is an additional 1500 plus at least 75 coach/mini bus journeys. Based on 113 responses from pupils in the current Nishkam School on Wood Lane, car travel accounts for 23% compared to 16% average for Hounslow primary schools. Total car transport is 52%, if this is extrapolated to the proposed primary school, this would result in 364 car journeys just for the primary school. The untenable impact of on-street parking is excluded from the assessment, there is no detailed data relating to the existing minimal on-street parking availability or the existing levels of on-street parking demand. Currently, all free off- street parking is taken by employees of BskyB around the Syon Lane area and Wood Lane is too narrow for on-street parking. The Wood Lane/A4 junction will be widely used but it is already one of the worst junctions in terms of delays in Hounslow. No consideration has been given to parents dropping children off, often illegally, close to the school. There is insufficient detail in the TA in terms of pedestrian facilities (crossing points and footways) in the immediate area. Consultation Only one “consultation” event was ever organised for the application; an exhibition held in the Osterley Park Hotel on the 20th and 23rd of May. It was in no way a consultation with residents about any problems they may have with the proposals. Residents have been informed about it and no more and even that, only weeks before making the submission. This is contrary to the Council’s Statement of Community Involvement. The only consultation that has been run by the Council is where residents are given a few weeks to respond to 1,400 pages of documentation prepared by the EFA/NST and their consultants. Design/character The proposal is out of character with the surrounding area, not respecting mass, height, design etc. Council for the Protection of Rural England: The proposed use would not appear to fulfil the requirement in the National Planning Policy Framework for very special circumstances to clearly outweigh the ‘substantial weight’ to be given in decision making to harm to the Green Belt or Metropolitan Open Land. The proposed development by virtue of its scale and character would unacceptably and unnecessarily harm the open, green character of the site and its nature conservation and historical interest. Inadequate justification has been given that this site should be developed before available brownfield sites. The proposal is likely to create a major increase in traffic, detrimental to the open, green character and tranquillity of the area. The proposed development by virtue of its scale would be likely to exacerbate flood risk. Heston Residents’ Association: Opposed to the use of open space for the proposed development. Open space must be preserved. The proposal to introduce a right turn to enable easier vehicular access to the school site and also the proposed park and stride concept and use of "buses" and marshals together with the proposed Parent's Charter are well noted. However I feel that despite these initiatives the additional vehicular movements associated with a 1400 pupil school, not only in Syon Lane and Windmill Lane, but in other nearby residential roads, such as Jersey Road and further afield will exacerbate the already present heavy traffic problems, particularly during peak periods, both am and pm The narrowness of Syon Lane, particularly near the proposed school entrance is such that inevitably and despite the proposals acknowledged above, there will be hold-ups particularly during peak traffic movement periods. This applies both south and north bound together with traffic relating to Tesco customers and Sky employees etc. The pavement adjacent to the proposed school site is particularly narrow and totally unsuitable for the potential use of even some of the estimated 1400 pupils, particularly during inclement weather. The residential roads opposite the proposed site would remain vulnerable to the set down/pick-up of pupils even with the intended provision of marshals. The proposed use of Tesco and the Wyevale Garden Centre as drop-off / pick-up points will inevitably introduce traffic problems on both Syon and Windmill Lanes, again during peak times. A particular pinch point is the mini-roundabout at the junction of Jersey Road and Syon / Windmill Lanes. The ever present possibility of traffic incidents affecting traffic flow on the Great West Road, particularly at Gillette's Corner, cannot be ignored when considering the overall impact of additional vehicular movements in the area. The proposed right turn to enable improved entry to the site raises concerns relating to potential accidents on such a busy and narrow highway with associated delays. The need to introduce a speed limit must be considered. Isleworth Society: The application proposes building on Metropolitan Open Lane (MOL); the London Plan and Hounslow’s emerging Local Plan emphasise the need to protect and enhance MOL and existing open spaces; Planning guidance requires that where in special circumstance building is permitted on MOL, alternative land must be provided to maintain the status quo; no alternative MOL is being provided; Transport facilities are inadequate. Of existing pupils of the Nishkam School for which this site is proposed as an alternative, only 16% come from the Isleworth/Osterley/Brentford area. Public Transport Accessibility Level for the location is 1 a/b, the very lowest, thus rendering it unsustainable as a place for a primary school; The proposed three storey glass and concrete structure is wholly out of character with the surrounding residential area. Oaklands Avenue Residents’ Association: 'All through' school could exclude Hounslow children: lf there is low application for the primary stage from local children when they wish to move to a secondary school the proposed Nishkam school will not be an available choice for them. We would suggest that if the Committee is minded to grant the application that there be mitigation applied to reduce the potential for exclusion.

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