Planning Department

Telford & Wrekin Council

Civic Offices

Coach Central

Telford

TF3 4HD

18 April 2012

Dear Sirs:

Planning application: TWC/2012/0261

I would like to raise the following points in objection to Planning Application TWC/2012/0261 Donkey Field Community Project.  More information than is available in the covering letter for the application and the Design and Access Statement needs to be obtained before the proposed development is approved.

1.  I first should state that I have an interest in the outcome of the application as I am a homeowner from whose property the Donkey Field is clearly visible.  I also am a frequent user of Wrekin Course and the Little Wenlock road both as a driver and a walker. 

Access points

2.  The planned access is NOT safe.  Cars using the specified exit point will not be able to see traffic coming from the west because the road bends just to the west of the exit.  They also will not be able to see traffic approaching the brow of the hill from the east.  Cars using the specified entrance will not be able to see traffic coming from the west because of the bend and brow of the hill to the west of the entrance point.  I can say that this is the case as I have been using this stretch of Wrekin Course for over 32 years.  The application should not be approved before traffic safety officers have been consulted about the siting of the entrance and exit points.

3.  The assertion in the Statement that Wrekin Course “is straight” is misleading. It is a straight road along the base of the Wrekin UNTIL it reaches the bend just to the west of the proposed entrance and exit from the car park.  It is only if one ignores that bend  (and the rise in the road to the east of the exit point) that it can be said the road “provides good sight lines” at the proposed access points.

4.  It is incorrect to say, as the Statement asserts, that Wrekin Course “carries little traffic”. Again, from the vantage point of our house, I have observed for over thirty years that Wrekin Course is a road which receives a lot of use.  The use of the road also has steadily increased over the years.  A full, formal, survey of traffic on Wrekin Course  should be carried out before the application is decided on.

5.  It also should be noted that Wrekin Course is not a wide road.  Because of the poor condition of the road and verges it is often necessary for one car to pull over so that another car coming from the opposite direction can pass.  This is especially the case at the western approach to the bend where the forest comes down to the road, which is close to the proposed exit from the car park; and at the brow of the rise which is near the proposed entrance to the car park.  Any increase in traffic on Wrekin Course would not be recommended.  Again: a full formal traffic survey needs to be carried out before a decision is made on the application,

6.  The Statement says that “it is intended” that responsibility for locking the entrance and exit gates will be assumed by the operator of the catering van.  It is not clear what that will mean in practice.  Presumably the car park gates will only be unlocked at times when the catering van is manned.  What provision has been made for the hours of operation of the catering van?  Will those hours accommodate people who wish to use the car park early in the morning or in the late afternoon/evening.  Will the catering van operate daily on a year round basis?  The application should not be decided on without that information.

On-site catering

7.  No provision for dealing with the litter and other forms of waste inevitably arising from on-site catering and the provision of picnic facilities is mentioned in the Statement.  What guarantees are there that the operator of the catering van will responsibly deal with litter and waste?  If no firm provision is made there is a risk that an eyesore will be created.

8.  There is no mention of  sanitation facilities in the Statement.  The application covering letter refers in its 2^nd paragraph to “the possible provision of allotment gardens for local residents and the provision of toilets serviced by the catering providers”.  This wording does not amount to a commitment to providing either allotments or toilets.

9.  If there is catering planned, should there not also be a definite commitment to the provision of sanitation facilities from the beginning of the site's operation?  Is there any legal/planning requirement that such facilities have to accompany the provision of a fixed catering site? How will the cost of keeping the site clean and sanitary be met if there is to be free parking?  It is unrealistic to assert that 'volunteers' will be responsible for the long-term ongoing work of cleaning the site as frequently and thoroughly as will be necessary.  The application should not be approved until there is a detailed statement of how the recurrent costs of keeping the site clean and sanitary has been received from the applicant.

10.If sanitation facilities are provided what arrangement will be made to protect those facilities from the sort of vandalism and misuse that eventually led to the demolition of the toilets sited at the entrance to the main path up the Wrekin?  Approval should not be granted until details are given as to how the recurrent cost of maintaining the site's security will be met.

11.At various points in the Statement, the catering facility is referred to as the “cafe”.  Does this imply that there will be development of the catering from a 'mobile' van to a building?

12.All of these points about the proposed catering operation should be clarified before approval is given to the application.

Free parking

13.The Statement says the car park would be “free to use”.  It is stated that the owner of the field has agreed to a 3-year rent free period for use of the land. After that a “market rate” rent will be required for its use.  As the application covering letter says, this is a generous offer to the community.  However, what funding arrangements are in place to continue free use of the car park after 3 years?  Or will it become a fee payable car park from that point on in order to meet the cost of rent and other recurrent costs?  In the light of proposals in the Statement that “means of discouraging roadside parking employed such as 'no parking' notices” will be required – indicating that people will be forced into using the car park - no approval of the application should be given without clarification of what means, other than charging users for parking , will be used to secure the payment of the rent and recurrent costs required from year 4 onward of the car park's operation.

14.If roadside parking is to be made unlawful, a question of enforcement arises. Have the local police been consulted about the proposal to ban parking on the roadside, particularly in respect of how extensive the ban would be?

Traffic and visitor numbers

15.The underlying assumption in the application is that most visitors to the Wrekin will continue to make their way there by car.  This runs counter to the increasing attraction of providing some form of public transport from Wellington (where there is plenty of parking) to the Wrekin.  Providing public transport of some sort has both an ecological and environmental rationale.  If it was possible to do this in the 19^th and early 20^th century it should not be beyond devising in the 21^st century.

16.There also is an assumption in the application that there is a constant 'overflow'  of parked cars from the existing parking at the former Forest Glen site and on the roadside alongside the reservoir.  I have been told by people who regularly use both these existing parking areas that it is not the case that they are insufficient to meet the demand for parking at most times.  It is at weekends and on bank holidays – provided the weather is fine – that the existing formal and informal parking facilities come under pressure.  It surely makes more sense to improve the existing roadside and Forest Glen parking rather than to create a completely new parking area.

17.The Statement refers to one purpose of the application being “replacing the unsafe and visually intrusive roadside parking with attractive off-road parking”.  It is worth noting that there have been no recorded incidents of injury to people walking along the roadside toward or from the main path.  In fact there are no recorded vehicular accidents between cars parking on or leaving the roadside and cars making their way up or down the Little Wenlock road or Wrekin Course.

18.It is clearly the case that if the roadside parking were supplemented by a designated pedestrian way beside the road, the likelihood of an accident would decrease.  It also would be a major improvement to the use of roadside parking if it were clearly signed before entering the area where such parking occurs that drivers should be alert to cars or pedestrians coming into the road.  The fixing of a low speed limit for the approaches to the Wrekin would also help to prevent accidents..  All of these of these measures could be carried out without the need for the Donkey Field development.

19.An underlying but unspoken idea in the application seems to be as much to attract more visitors to the Wrekin as to make parking easier for the present visitor load. That will generate more traffic on the already congested Little Wenlock Road and certainly will add to the traffic on Wrekin Course.  In fact it may be the case that the provision of 40 additional off road parking spaces will prove to be inadequate to remove all of the roadside parking, putting those who do park on the roadside, rather than giving up their plan to visit the Wrekin, at risk of a fine for doing so.   Since this situation is most likely to arise at weekends and on bank holidays, the police view about enforcing a roadside parking ban (and how extensive such a ban should be) seems to be an essential element of the basket of factors to be weighed for and against the proposal. 

    Other points

20.There is long-standing concern about the impact of increasing numbers of visitors on the Wrekin.  Increased numbers may have an impact on the whole of the ecology of the Wrekin.  Any degradation of the flora and fauna associated with the Wrekin would be a serious loss to its standing as an ANOB.  The environmental survey carried out for the applicant is careful to note in its conclusion that, within the “limitations” of this survey there would be no direct risk to designated habitats or to protected and valued species from the proposed work on the site “provided that care is taken to avoid risks to roosting bats and disturbance of badgers, hedgehogs, nesting birds, reptiles and common  amphibians. Any work to the over mature tree that is in the site will need careful planning to avoid risks to bats and birds. Work to hedgerows will also need careful planning and management to avoid impacts on nesting birds.” (my emphasis).  Any approval of the application should be delayed until specific commitments about the way the works on the site will be carried out have been provided and are seen to satisfy the concern expressed in the above quotation.

21.The promotion of Wellington as one of the national “Walkers are Welcome” destinations would not be assisted by making more provision for visitors who arrive at the Wrekin without any contact with Wellington other than driving through it.  This would be to the disadvantage of those merchants who presently or might in future obtain trade from visitors who use Wellington as the base for setting out to visit the Wrekin.  Has any effort been made to appraise the opinion of Wellington merchants about the proposed development?

22.One of the proposals in the application is that some part of the Donkey Field could be developed as a site for allotments.  If this were the case, what reduction in the use of the 40 parking places provided as an alternative to roadside parking for people walking on the Wrekin would occur?  Would this be seen as an opening to increase the number of parking places on the Field?  If it is not seen as realistic to expect walkers to come out from Wellington by foot to use the Wrekin how realistic is it to assume that “local resident” allotment gardeners would do so?  Is there any evidence of demand for allotments which would support the idea of creating them on the Donkey Field?

23.The Statement refers to  the possible extension of car parking onto “overflow space” if the 40 spaces initially provided are regularly not enough.  Given that the present planned use amounts to only 16% of the area of the Donkey Field it is possible to envisage the development of a very large car park on the Field.  It would be inappropriate for approval to be given to this application without some strong provision in that approval requiring, further detailed enquiry into the existing usage and cost/benefit of the 40 space car park, before any extension of the parking area would be approved.

24.It is certainly misleading to say that a car park on the Donkey Field would be less visually intrusive than the present roadside parking.  The Donkey Field can be seen clearly as one approaches the Wrekin from Wellington or the M54 up the Little Wenlock road.  In fact almost the first view of the Wrekin along the Little Wenlock road is of the Donkey Field.  Is a car park for 40 cars (or its extension later on) the first thing visitors to the Wrekin should be confronted with?

25.The visual aspect of the roadside parking also could be improved if the area being used for parking were re-surfaced and marked out to provide more formal parking spaces.  The present ad hoc use of the roadside for parking could be reduced without the need to create a new space in the Donkey Field.

26. In the covering letter for the application it is stated that this is a “community (volunteer) led project”.  Community involvement in the care and maintenance of the Wrekin, which is, after all, the most important physical amenity in East Shropshire, is to be welcomed, as is the support of the Huntington Lane Mining Community Trust.  However, as is the case here, where there are proposals which involve recurrent cash costs, it is essential that the means of defraying those costs that are not likely to be met by 'volunteer' work over the mid-to-long term are spelled out. 

I hope that the points raised above will be helpful to you in reaching your decision to approve the application as it stands or not.  Please feel free to contact me if you wish to have clarification of any of the points made.

Yours sincerely,

Jim Clevenger

# Posted by Steve Hooker at 19/4/12; 6:36:24 PM
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26 objections to the donkey field car park