Dear Ms Mathews,
Re: Application BRW/281/2010 – Replacement GP Healthcare Surgery, Deal Tree Corner, Blackmore Road, Doddinghurst, Brentwood
Having studied the plans and supporting documents for the above planning application, and discussed the proposals with the Practice Manager at the existing surgery, and having taken note of the relevant points covered by the Brentwood Replacement Local Plan, I wish to raise a number of concerns regarding the proposed development. References in square brackets refer to policies in the Local Plan which I feel would be contravened by particular aspects of the proposed development.
- The development is in the Green Belt and therefore, as per policy GB1 of the Local Plan, the proposed change of use should not be permitted. I am not convinced that the circumstances of this application are exceptional/special enough to justify ignoring the green belt rules.
- The development would contravene GB2 by harming the openness of the Green Belt. The Green Belt is there for a reason – to stop the urbanisation of rural areas – and it needs to be protected and maintained.
- Section 8.5.5 of the Local Plan states that the Borough is already adequately provided with GP services and that the only area where there is a clear need for additional GP services is in Warley.
- The proposed development would see a large part of an existing arable field replaced by a large building and a car park. This represents an unacceptable detrimental impact on the visual amenity of the site and on the character and appearance of the surrounding area [see CP1 (i) of the Local Plan].
- The size and scale of the new building will dwarf the nearby properties and, as such, is not compatible with its location and the surrounding developments [CP1 (iii)].
- The new development, coupled with the additional traffic it would bring to the immediate area, would also give rise to an unacceptable detrimental impact on the general amenity of the occupiers of the nearby properties (in particular those directly opposite the development) by way of overlooking, lack of privacy, and general disturbance [CP1 (ii)].
- The noise in the proposed car park of traffic movement, car doors slamming, conversations taking place, car alarms going off, etc would have an unacceptable detrimental impact on the general amenity of the occupiers of the nearby properties (those directly opposite and adjacent to the development) by way of general disturbance [CP1 (ii)].
- It is stated in the application that the bus stop that is currently opposite Wayside Aquatics will be moved. But no mention is made of where the bus stop will be moved to. If it ends up being closer to the crossroads that would make the junction more dangerous. If the bus stop is moved closer to Kelvedon Hatch, then people will find themselves getting on/off the bus in or close to the stretch of road that is subject to a 60mph speed limit.
- The plans show that the vehicle entrance will be opposite the footpath that runs down the side of Wayside Aquatics. That means it is only a few car lengths from the crossroads at Deal Tree Corner. If people are driving from the Hook End direction and are waiting for a gap in the oncoming traffic to allow them to turn right into the new surgery then they will end up forming a queue of traffic which will stretch back to the crossroads, and hence have a negative impact on safety at the junction. [CP1 (iv) and (v)]
- The transport statement submitted as part of the application shows that at present 32% of people visiting the surgery come from Doddinghurst. At the moment these people arrive at the surgery by coming up Outings Lane and do not have to go through the crossroads at Deal Tree Corner. But if the surgery moves to the new location, all these people from Doddinghurst will now have to make a left turn from Outings Lane into Blackmore Road - hence there will be more traffic using the already busy crossroads. This will have a detrimental impact on highway safety[(CP1 (v)].
- Similarly the anticipated 20% increase in the number in journeys to/from the surgery that the transport statement refers to will also mean more traffic going through the crossroads in one direction or another. Despite what is claimed in 3.5.4 of the Transport Statement that accompanies this application, visibility at this crossroads is not good from all directions and therefore any increase in the number of vehicles using the junction will be detrimental to highway safety [CP1 (v)].
- It has been stated in the application, and confirmed by the Practice Manager, that the new surgery would offer additional services which are not currently provided (e.g. phlebotomy clinics). Extra services will lead to more people using the surgery. For example, people who currently travel to Brentwood Community Hospital or Queens Hospital for blood tests may now decide to come to Doddinghurst instead. This will put extra strain on the local road network and have a detrimental impact on highway safety [CP1 (v)] and create additional disturbance for local residents [CP1 (ii)].
- The Transport Statement (3.8.8) acknowledges that provision of sufficient parking is essential. However, I am concerned that the proposed 38 spaces will not be sufficient [CP1 (iv)] at peak times – especially if additional medical services are now to be offered at the surgery. The problem will be even worse if extra GPs/nurses join the practice. At the current surgery, when there are not enough car parking spaces available, people choose to park in the road or on the pavement nearby in Outings Lane. If the car park at the proposed new surgery were to become full, then people would no doubt do the same thing and would park along Blackmore Road. That will be far more dangerous than the current situation because traffic on Blackmore Road is considerably faster moving than it is on Outings Lane and there is a greater volume of traffic on Blackmore Road than there is on Outings Lane. Again, this would represent a detrimental impact on highway safety [CP1 (v)].
- I am not aware of any proposals to attempt to reduce the number of people travelling to the surgery by car as referred to in policy T1 of the Local Plan. In fact, the increase in the number of parking spaces from the current 11 to the proposed 38 may encourage people who currently walk to the surgery under sufferance to drive instead – because they will believe it will now be easier to park when they get there.
- Section 4.3.1 of the Transport Statement says that the proposals for the development support the policies of the Local Plan to encourage sustainable travel and reduce the need to travel. The justification that is given for this is the fact that the new surgery would have bicycle parking spaces. I very much doubt that we will see an increase in the number of people cycling to the surgery. Further, I do not see how the proposals will reduce the need to travel. If anything, the provision of additional services referred to earlier will result in more travel to/from the surgery.
- Having additional services at the surgery could result in more delivery vehicles using the nearby roads, and hence greater general disturbance and noise/air pollution for residents [CP1 (ii) and (vii)].
- At both Deal Tree Farm (next door to the proposed surgery) and at Ashwells Lodge (opposite the proposed surgery and adjacent to the proposed pedestrian crossing) there are at least four guard dogs – Alsatians and Rottweilers. It is already the case that if a pedestrian walks anywhere near the boundary of either of these two properties, the dogs bark very loudly and vociferously. The increase in pedestrian traffic which the new surgery would cause would mean these two sets of dogs would be barking almost non-stop during the hours the surgery was open. This would cause an unacceptable detrimental impact on the environment and amenity by virtue of the resultant noise pollution [CP1 (vii)].
- The provision of the new pedestrian crossing would lead to extra queues of traffic along Blackmore Road and extra acceleration/deceleration of vehicles, which would have an unacceptable detrimental impact on the general amenity of the occupiers of the nearby properties by way of general disturbance and pollution from vehicle fumes [CP1 (ii) and (vii)].
- By causing queues back towards the Deal Tree corner crossroads, the pedestrian crossing would have a negative impact on highway safety [CP1 (v)].
- The lighting at the crossing (both the Belisha beacons and any “white” lighting provided to illuminate the crossing at night) would have an unacceptable detrimental impact on the general amenity of the occupiers of the bungalows and cottages immediately adjacent to the crossing by way of general disturbance [CP1 (ii)].
- The crossing would have a detrimental impact on the visual amenity, character and appearance of the surrounding area [CP1 (i)].
- Under policy LT12 in the Local Plan it states that changes of use to healthcare use will be permitted only where the property is located somewhere which is accessible by public transport, walking and cycling. The proposed development is not served by any cycle routes and many of the local roads are not particularly safe for cyclists to use. Similarly, many of the nearby roads have no pavements and so the property cannot be said to be easily accessible on foot. Apart from a very limited bus service there are no public transport links at all.
Whilst I can see that there are some benefits to be gained from having a new surgery, I do not feel that the proposed site is suitable and I feel that the application overlooks a number of pertinent issues.
I would therefore be grateful if the above observations, especially those regarding the destruction of the Green Belt and the traffic problems that would be caused by (a) the location of the vehicle access road and (b) the plans to offer additional services, could please be taken into account by those responsible for deciding whether or not to approve this application.
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