Objection to planning application 10/00406/FULL

From:

…………………………………….
…………………………………….
…………………………………….
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Director of City Development
Dundee City Council
Floor 15
Tayside House
Dundee
DD1 3RB.
Date …………………………………….

Dear Sir/Madam,

I wish to object to planning application 10/00406/FULL: Construction of a new 2 x 1 stream primary

school and nursery school at the former Harris Academy Annexe Blackness Road Dundee DD2 1SF
on the following valid planning grounds:

I believe that the application should be rendered invalid at the present time and the correct
procedure should be followed as regards the land ownership of the site. It is my understanding
that the Council does not own the site. It would seem that the site is subject to an agreement
to transfer the land; however, this is different to ownership. The correct land ownership
should be acknowledged on the land ownership certificate as part of a new application.

Appearance (layout, design, materials etc) / Effect on setting and character of Conservation
Area.

The proposal will not respect the character and appearance of the wider area. The proposal
represents a building of poor contemporary homogeneous design. It has been designed
merely to accommodate its internal uses, with no respect for the massing, scale, design and
materials of the buildings in the surrounding area.

The proposal will not relate well to the materials used in the construction of the historic buildings
in the surrounding area, which form the identity of this part of Dundee. It will adversely
impact on the character and appearance of the historic Blackness Road area and particularly
on the adjacent Logie conservation area which has been designated as outstanding by Historic
Scotland. The design statement quite openly exalts the buildings inability to reflect the
materials used in the construction of buildings found in the surrounding area.

The design of the building has had no external validation. As a major application, should it not
have been subject to consultation with Architecture and Design Scotland?

By virtue of design, scale, massing, finishing materials and landscaping the proposed school will
have a significant impact upon the level of environmental quality afforded to neighbouring
properties. The proposals are therefore considered not to comply with the requirements of
Policy 1 of the adopted Local Plan.

It has not been demonstrated that the Whole Life Costing of the building was carried out at the pre-
application stage or has been carried out at this the planning application stage. This
information is vital to demonstrate that a Whole Life Cost model has been developed early in
the design process to influence the fundamental decisions regarding the building strategy
(such as lightweight vs heavyweight construction, passive cooling vs mechanical air

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conditioning etc.)

The materials used in the construction of the building will have a short life span. The whole life
cost of the building has not been demonstrated. As such it has not been demonstrated that the
building is sustainable in this respect or that it represents a value for money investment for the
Dundee tax payer.

It is my understanding that no consultation or explanation was provided which demonstrated the

need for a new school on this site. It was presented as the only option which is not a choice.
The decision to locate the school on this site was undertaken before consultation regarding a
new school was undertaken.

No information seems to have been submitted to allow for an assessment of the impact of the
building on the health and well being of the children who will be using the school.
Considerations such as:

· At least 80% of occupied spaces will be adequately and evenly daylit with an
average daylight factor exceeding 2%
· For music accommodation (or multi purpose halls in primary schools with no
music accommodation) where there is a commitment to achieve airborne sound
insulation values that are at least 5dB higher, and impact sound insulation values that
are at least 5dB lower, than the performance standards

In my view the pre-application consultation carried out was not conducted in accordance with good
practice, particularly with the pre-application exhibition of the nearly final proposal
conducted on a bank holiday weekend which was prohibitive to many attending.

The report complied by Scottish and Southern Electricity found that the site is not currently
affected by electro magnetic fields. However, is it not the case that electro magnetic fields can
be attracted and thus the danger here is that the building itself will encompass electrical
equipment and this will in turn attract the electro magnetic fields from the nearby substation
and even amplify them within the building which itself will act as a huge attraction and
amplification device through the use of exterior metal cladding? It is most notable that points
B and C on the survey relate to the proposed nursery and the closest point to the electrical
substation.

That there exists no guideline levels for a school end use where contaminants have been found in
the soil. Because of the limitations of the Phase Two Intrusive Environmental site
investigations, it would appear that the construction of a school on the site proposed would
represent an experiment and the end users of the school the children and staff would be
guinea pigs to determine whether they become contaminated by the pollutants present on the
site. The survey itself acknowledges that the assessment carried out is in no way definitive,
due to the large number of assumptions made. This is most likely the reason the site has not
been developed up to this point as the previous or present owners had a survey carried out
also and it is acknowledged that there are unknowns with respect to the remediation work
such as the cost and consequences. I would suggest that a condition to deal with remediation
is insufficient. It will not address the issue. Cost of remediation is unknown; the success of
any remediation is unknown. We need to know in advance what the levels of contamination
are and if remediation will be successful before an expensive mistake is propagated.
Sufficient information is a must.

Traffic, parking or access problems

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The school will not benefit from adequate car parking space and the traffic assessment is
inadequate. It notes the number of spaces available in the surrounding area, but does not
counter the main concern, that the spaces currently available are oversubscribed (to a degree
that a permit scheme has been muted by the Council) and that the spaces available can not
possibly absorb the parking proposed by a new school of this scale.

The access road will offer limited access. It is a singular road, offing one access point which will be
prone to congestion at peak times.

There has not been sufficient dropping off facilities offered as part of the proposal. The existing St
Joseph’s school site has been the subject of numerous complaints and this school proposal
provides fewer opportunities than at the existing at the current St Joseph’s site.

The school if approved, it will be located on a busy section of Blackness Road which is subject to
regular bus traffic. Blackness Road is a main arterial route into the city centre and at present,
it is already congested. The introduction of a school at this point of the road will be severely
detrimental to free traffic flow. A travel plan will not address this issue and it can not be
mitigated by any measures at the disposal of the Council.

A school travel plan (STP) will not be an appropriate solution to the traffic problems which will be
experienced by the introduction of a school of this size and nature. STPs are successful where
they relate to the local characteristics of the area and relate to schools with a small catchment
area. The proposed schools will be out of character with this mainly residential area and they
will have a large catchment area; thus these issues make it impossible to implement a
successful STP.

The plans make provision for dropping children off within the school grounds, however, this is
totally inadequate and human nature dictates that people will drop children off on Blackness
Road and Glenagnes Road no matter what arrangements are put in place on the school
grounds.

Residential amenity (overshadowing, overlooking, noise, odour, etc)

At the pre-application stage, it was indicated that a biomass boiler would possibly be installed at
the school. However, no details of boiler type have been included in the application. This is
an important issue which should be addressed at the planning application stage. The type of
boiler proposed will have a huge impact on the amenity of neighbouring residents. I would
strongly object to the introduction of a biomass boiler. Many biomass boilers are maintenance
heavy and are often backed up by gas fired boilers. Whilst a biomass boiler may be the
cheapest option in terms of capital cost and is the easiest way to get additional funding
available for low carbon fuels, it represents a false economy and other routes are more cost
effective in terms of life cycle costs. Where will the pellets come from and will the source be
local. As we have seen in the case of the boiler proposed at the Waterfront, the pellets would
be shipped in from abroad which is neither sustainable or a low carbon option. Biomass
boilers have proved to be a significant issue in Edinburgh which discourages the use of
Biomass boilers due to concerns relating to potential health risks and their impact on local air
quality (Edinburgh Council’s policy on biomass boilers Nov 2009). The boilers require a lot
of long term maintenance which is expensive and will cost the Dundee taxpayer a substantial
amount in the long term and achieve little if any in the way of carbon saving.

In the report on mechanical services plant noise, section 3.2 states that noise levels due to the
kitchen supply, kitchen canopy and toilet extract fans were found to be, respectively, NR44,
NR43 and NR40. However, section 3.4 sates that noise inside the flat was found to be NR28,
NR27 and NR25 respectively and that these noise levels are within the limit of NR35 which

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would normally apply to this kind of noise. However in permission 09/00786/FULM a

condition ‘[a]ll noise from mechanical and electronic plant shall not exceed NR35 when
measured 1m external to the facade of neighbouring residential properties’ was applied. Why
is this development different? The development would not appear to be able to satisfy this
condition. The condition seems to have been applied to many developments all around
Dundee. Why is this development different to the many instances where it has been applied
all around Dundee? If it is not different, why is this development being treated differently?
An explanation of this point will be of interest to the many developers in Dundee who have
spent time and money complying with the condition or have had their development refused as
result of this condition.

Loss of trees and landscaping issues

Scotland’s education establishment is gearing up for the introduction of the curriculum for
excellence, however, the grounds of the proposed new school building do not seem to provide
a learning resource that can be used to facilitate development of environmental issues within
the school curriculum.

The proposal does not appear to include a survey of the application site at the pre-application stage
or any subsequent stage with regard to bio-diversity. There does not seem to be information
which demonstrates that a suitably qualified ecologist has confirmed in writing that all
relevant UK and EU legislation relating to protection and enhancement of ecology has been,
or will be, complied with during the design and construction process.

I ask that my views are properly taken into account and given due consideration in the determination
of this planning application. Please confirm receipt of this letter and keep me apprised of any
developments in relation to this application.

Yours faithfully,

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