SWLEN believes that the proposed development represents inappropriate development on Metropolitan Open Land (MOL), and is contrary to policies relating to the Green Belt/MOL at national, London and local levels. The ‘very special circumstances’ which might justify such development do not appear to be present in relation to this development.  The National Planning Policy Framework does not list building an entire new school as an exception to the general rule that building on MOL is inappropriate development.  The Sequential Site Assessment Report examines a number of other sites but dismisses them on the basis that they are MOL so it is not clear why a different rule should apply to this site. 

The site has considerable biodiversity interest and potential although records of species directly on the site are currently limited as it has not been open to the public.  The site is close to Hounslow Heath and the River Crane corridor and adjacent to the railway and gardens which form a wildlife corridor from Hounslow Heath to the site.  There have been many bat sightings to the north of the site and the Preliminary Ecological Appraisal (PLA) states (para 4.3) that “it may be possible that bats forage along the trees that line the borders of the site”, a conclusion that we endorse.  The fact that the site is currently largely unlit will contribute to its biodiversity value and we are concerned that placing a large building and floodlit multi-use games areas (MUGAs) close to the northern boundary will interfere with the dark corridor.  We agree with the PLA’s recommendation that there is a need for additional bat roost surveys (November-March) and emergence and re-entry surveys (May-August).  The impact of lighting must be kept to a minimum following guidance.  We also agree with the need for further surveys looking for evidence of badgers, nesting birds and hedgehogs and a further botanical survey, plus consultation with the LB Richmond Ecology Officer. 

Heathfield Recreation Ground

The impact on Heathfield Recreation Ground of opening a pedestrian entrance leading across the park to the school also needs to be carefully considered.  This park has recently had some improvements to make it a “friendly park” where the elderly, particularly those with dementia, and those with mental health problems can feel safe.  It is also used extensively by younger children particularly those from Heathfield Infant and Junior Schools.  The impact of a large number of secondary school children using the park after school needs to be considered and we suggest that supervision arrangements might need to be put in place by the school to ensure that more vulnerable park users do not feel intimidated and that standards of behaviour are good.   Should the Council be minded to grant this application we ask that some CIL money is allocated to improvements to Heathfield Recreation Ground to be chosen in consultation with the Parks Department, Friends’ group and local residents. 

We agree with the comments by many others about the dangerous access to the site, lack of safe cycling infrastructure in the area, particularly considering that many students would need to cycle from the Fulwell and West Twickenham area, the limited public transport to this site and the potential for further traffic to be generated leading to further air pollution in an area which already suffers from air pollution. 

Should the Council be minded to grant this application we suggest that the proposed size of the school and therefore the size of the impact on MOL cannot be justified. The increased intake appears to be excessive considering that Twickenham School is not full. There should be scope for sharing sports facilities with other local schools reducing the need for MUGAs and associated floodlighting which will have an impact on biodiversity.  We also suggest that there does not appear to be sufficient demand for such a large sixth form considering Twickenham School closed its sixth form because there was so little demand and Teddington School’s sixth form is only half full.  Therefore, if a school sixth form is needed in this area, we suggest that Turing House’s sixth form could be provided jointly with Twickenham School at the Twickenham School site.