Keston Village Residents’ Association with input from the

Friends of Keston Common !

Submission No.4 to the London Borough of

Bromley for Planning Application

!DC/14/03021/FULL1 !

Previously DC/13/01666/FULL1 Previously 12/03819/FULL1

!Keston CE Primary

School !!!!!!!

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!!!!Contents !!

Page !!

KVRA letter of conditional support to Russell Penn 3 to 5 !!Traffic including pedestrians and horse riders in Keston Village 6 to 13 !!KVRA letter to Nigel Davies 12th Dec ‘13 14 !Submission No. 3 DC/13/01666/FULL1 Enclosed (Russell Penn only) !!!

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! !4 Heritage Hill Keston Kent BR2 6AU !11th September 2014 !Dear Mr Penn, !Ref: Planning Application 14/03021/FULL1 Previously: DC/13/01666/FULL1 (originally Ref: 12/03819/FULL1) !This document is submitted as a formal response to the above consultation from Keston Village Residents Association (KVRA) on behalf of the Residents of Keston Village many of whom are opposed to any further expansion of Keston CE Primary School. !As you are the third Planning Officer this organisation has dealt with on the matter of extension of Keston C E School, please find below a summary of the submissions from KVRA which have been made in objection to the original two planning applications; !

1. 8th January 2013 – submission in response to public consultation & planning application Ref:12/03819/FULL1

2. 5th February 2013 – Letter to Mr Forrester objecting to planning application 12/03819/FULL1

3. 21st March 2013 – Letter to Plans Committee 3 Councillors 4. 16th April 2013 – Letter to 9 Councillors on Plans Committee 1 5. 1st July 2013 – Letter to Simon Greenwood and submission dated 16th

June 2013 to revised planning application DC/13/01666/FULL1 6. 2nd August 2013 – Letter to Simon Greenwood in response to YES

Transport survey and Memorandum from Kathryn Backhouse of 25th July 2013

7. 14th November 2013 – Letter to Simon Greenwood on Additional Information received comprising two documents added to the planning application

8. 10th January 2014 – Letter to Simon Greenwood in objection and highlighting the inaccuracies in the Footmark Transport Statement !

In the light of the new planning application for a single classroom, it is clear that certain of the residents concerns have been taken into consideration, which is welcomed. Residents have never wanted to disadvantage the children; however their requirements have centred on the following; to protect the local amenity, improve safety of the road and pavement infrastructure and reduce parking within the local roads. Therefore there are aspects of the above documents, which remain relevant and need to be considered by Officers and Councillors. !KVRA trust that LBB Officers will give weight to the residents’ previous submissions. This document represents the majority views of the 180 residents this residents’ association now represents. This response will concentrate on the new planning application 14/03021/FULL1. !!Page � of �3 14

!Transport Statement (TS) The TS, which forms a part of the latest planning application, is the original document of July 2013 updated to July 2014 and with several notable deletions and additions. The most obvious deletion is the reference to the bulge class of 30 pupils introduced in September 2012. The tables and data from Intelligent Data Collection Limited (IDC) include Parking Beat Data with a date of survey of 28.01.2013. The July 2014 TS records in Section 7 Summary and Conclusions point ‘e’ that “The results of the Parking Survey indicate that on average 150 unrestricted parking bays are available within the vicinity of the school. This demonstrates that there are plenty of on-street parking spaces available”. This is inaccurate and not substantiated. The IDC data contained within this latest TS includes ‘old’ 28.01.2013 data showing an unrestricted capacity of 214. KVRA have already carried out a physical parking survey as reported in our document dated 09.01.14 copy enclosed. A quote from this document is shown below; !Residents of each of the four roads used the principles of the Lambeth Parking Methodology and carried out their own practical test of car parking spaces on Sunday 5th January 2014. Enlarged copies of the YES plan were provided to residents for this work. The results have been substantiated with numerous photographs and descriptions included in this document. The YES plan shows car spaces located in contravention of both the Highway Code and The Lambeth Methodology. !A number of the spaces shown on the YES plan may be technically compliant but from the KVRA physical check they are wholly impractical as viable parking spaces especially in Windmill Drive and Keston Gardens. Parking in these narrow roads using the YES plan locations would completely restrict residents’ access by blocking manoeuvering space for private drives and exit routes for cars already parked further into either road. !Parental parking patterns have not changed for years and evidence shows most opt to follow the one-way system and hope to get as near to the school as possible. Any additional pupils will also be brought to and collected from school in the same way, thereby exacerbating the already intolerable situation. It can be argued that hypothetical parking spaces in these circumstances are irrelevant. !TS July 2014 Section 7 Summary and Conclusions b Noted c It is noted and welcomed that “all car parking is contained within the school rather than on the neighbouring roads”. d Whilst 7% of pupils and 86% of staff wish to travel to school by care, the fact is that as reported by the school in November 2012 of the 239 children surveyed, 117 (49%) actually travelled to school by car. e This statement is incorrect and misleading as detailed above. h is incorrect and a dangerous assumption. As residents have pointed out on numerous occasions, the junction of Keston Avenue with Heathfield Road has poor sight lines and in therefore potentially dangerous. !The volume and speed of traffic in Keston Village You may not be aware that there is under consideration (LBB Report No. ES13094) a proposed roundabout to be located at the junction of Heathfield Road and Westerham Road. KVRA and the Friends of Keston Common (FoKC) are vehemently against this proposal. These two groups have worked together with residents input to develop a set of comprehensive and strategic

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proposals, which address the fundamental issues for the long term. These are enclosed so that as you consider this latest application you are aware of the local concerns and the steps residents consider are necessary to improve the safety of vehicles and pedestrians in the village. The safety steps proposed will protect the pupils, parents and teachers of Keston CE School. !Please use your report to Councillors to recommend this latest planning application is permitted only on condition of;

1) A maximum for the number of Pupils permitted at Keston C E School is set at 240 (7 x 30 + 1 x 30)

2) The local authority transport department is required to carry out road and pedestrian traffic improvements in consultation with the local residents who are represented by KVRA and the FoKC. !

Yours sincerely !!!!!David Clapham Chairman Keston Village Residents’ Association !!!Enc: Copy of submission No. 3 dated 09.01.2014 (Russell Penn only) Copy of Safety of ‘Traffic and Pedestrians in Keston Village’ document !!Cc: Councillors; Ruth Bennett, Stephen Carr, Alexa Michael, Colin Smith KVRA and FoKC Members !!!Mr Russell Penn London Borough of Bromley Planning Department Civic Centre, Stockwell Close, Bromley, BR1 3UH !

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!!TRAFFIC, INCLUDING PEDESTRIANS AND HORSE RIDERS IN KESTON VILLAGE !Background !A document (REPORT ES13094) was produced by LBB for Pre-Scrutiny by the Environment PDS Committee on 1st October 2013 with the Title: CONGESTION RELIEF SCHEME: HEATHFIELD ROAD / WESTERHAM ROAD, PROPOSED ROUNDABOUT. !KVRA discussed this scheme and it was considered that a new road layout would potentially increase the already disproportionately high volume of traffic using the B265 Heathfield Road, rather than the less busy A233 Westerham Road. It is recognised that at this junction the proportion of drivers travelling North are choosing the B265 due in part to the inadequacy of the Keston Mark junction of the A233 Westerham Road with the A232 Croydon Road. !The narrow width of Heathfield Road, vehicles emerging from junctions, some of which are blind with a high volume of cars emerging daily and driveways, 1

car doors opening when people stop at the shops and Post Office, pedestrians crossing, the Keston C E School pedestrians and 4,000 vehicles each way every day all contribute to creating a very busy village centre. Through traffic regularly exceeds the 40mph then 30mph speed limits travelling north and south causing potentially dangerous situations. !Overtaking at speed and other near miss situations occur daily. Recently many residents have voiced their concern about the numerous heavy lorries transporting spoil from sites in and out of the Borough to Cherry Lodge Golf Club. The volume of traffic, already heavy, has increased significantly since the survey for the LBB report during the 1st to 7th July 2013. Keston Village Residents’ Association (KVRA) and the Friends of Keston Common (FoKC) 2 3

agree that if action to channel vehicles along more appropriate routes is not taken promptly, the volume using the B265 is likely to completely overwhelm the pinch-point alongside the shops and adjacent to Lakes Road. This 4

junction and that of Keston Avenue with Heathfield Road witnesses the school traffic twice daily. Most school traffic turns left into Lakes Road and right out of Keston Avenue where it joins fast moving traffic. The twice daily school traffic along with the associated safety issues is naturally dangerous. During term

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School traffic in volumes of over 200 per day exit Keston Avenue onto Heathfield 1

Road

KVRA Membership 15 residents form the committee and email contact with a 2

further 170 residents plus an AGM. www.kvra.org.uk

FoKC Membership 30 individuals; see http://3

www.friendsofkestoncommon.btck.co.uk for more information.

Pavement width alongside Post Office 3’ (910mm). Carriageway north 4

9’6” (2900mm). Carriageway south 10’3” (3130mm).

time the junction of Lakes Road with Heathfield Road is already at capacity during both morning and evening school drop-off and collection times. !KVRA submitted an objection letter to Nigel Davies Executive Director of Environment and Community Services for LBB dated 12th December 2013 . 5

This was acknowledged by e-mail on 18th December promising that our comments would be taken into consideration and that KVRA would be kept informed of any developments. !Subsequently the KVRA AGM circular reported this to residents and following this the two groups convened to discuss and agree the response to the forthcoming consultation. !Objectives were agreed as follows; KVRA 1. To create a safer environment through a reduction in the speed and

volume of traffic overall and in particular heavy lorries travelling through Keston Village

FoKC 1. Improve the safety of horse riders at the junction of Heathfield Road and

Westerham Road 2. Reduce the volume of traffic using Fishponds Road and exiting right onto 6

Westerham Road in order to avoid the queue travelling South !London Borough of Bromley The LBB Report ES13094 state that the reasons for the suggested roundabout is …” to assist traffic flow through this busy junction , in 7

particular vehicles travelling south from Heathfield Road to Westerham Road.” The report also suggests that the proposed roundabout “would be likely to have a positive impact on vehicle speeds at this location”. The paper refers to the excessive speeds and accident levels along ‘chicken farm bends’. KVRA and the FoKC propose that with carefully constructed and sustainable alterations to this junction configuration concerned together with speed and weight restrictions and appropriate signage alterations at the key interchanges leading to Keston Village all these objectives can be met. !For reference purposes, the Heathfield Road junction with Westerham Road is shown below. There is a bus stop and bus shelter located alongside the junction. There are no continuous pavements in this area are and no safe crossing points.

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See Appendix 15

Fishponds Road runs through the middle of Keston Common which is designated by Natural 6

England as a Site of Special Scientific Interest (SSSI). As such, it is a protected area and qualifies for Higher Level Stewardship.

LBB Report ES13094 quotes 14,400 drivers pass through this location on average daily.7

T

This photo demonstrates the ease for traffic travelling north to turn left from Westerham Road A233 onto Heathfield Road B265. The north bound carriageway is very wide (much wider than the Westerham Road equivalent at this point) and follows a gentle left turn. A recent check confirmed that many cars speed past the bus stop. Beyond this junction the B265 inclines downwards towards Keston Village. The speed limits see-saw from an ‘advisory’ 30mph around chicken farm bends to 40mph reducing to 30mph on Heathfield Road. Both of these limits are regularly exceeded. The LBB data in report ES13094 demonstrates that the volume of traffic using the B road is 27% greater than that using the A road. This volume as well as the speeds are unacceptable. !During peak evening periods most traffic heads south and hence queues are formed at the junction shown. These back up as far as the Village Hall. Cars seeking to avoid this queue divert, sometimes exceeding the 30mph speed limit, through Fishponds Road and turn right onto Westerham Road. This

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junction has poor sight lines and traffic on the A233 routinely exceeds the 40mph speed limit at this point. The junction is shown below.

!!!!Roundabout Proposal (Report ES13094) The proposal for a roundabout at the junction of the Heathfield Road and the Westerham Road is REJECTED in favour of the following proposals. !!KVRA & FoKC Proposals !1. To redesign the Heathfield Road/Westerham Road junction to;

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• Include bus lanes and width restricted lanes for vehicles travelling 8

both north and south . 9

• Incorporate a crossing point for pedestrians and horse riders over all carriageways.

• The left turn for vehicles travelling north must be as sharp as possible off Westerham Road (90 degrees) to require a deliberate left turn manoeuvre, thus slowing traffic considerably.

• Improve signage at this junction to articulate clearly that the left turn is for 'Keston Village traffic only' with Bromley, Beckenham and all other routes using the A rated Westerham Road.

• At the junctions of; Commonside, Baston Road, West Common Road and Baston Manor Road with the Croydon Road, warn south bound drivers of the width restriction and additionally restrict the size (width & weight) of vehicles permitted through Keston Village.

2. Restrict vehicle speeds on the B265 from its junction with the A232 Croydon Road to its junction with the A233 Westerham Road to 30mph. 10

Additionally impose a further 20mph restriction along the full length of the Keston Village Conservation Area; from the Flint Institute in the south to The Fox and into Commonside as far as the Croydon Road junction in the north. Restrict vehicle speed to 20mph along Fishponds Road.

3. Install a pedestrian crossing on Heathfield Road, in particular to make safer access for Keston CE School pupils and their parents. Improve the footpath on Commonside from St Audrey’s to Oakfield Lane.

4. Create a traffic-calming measure - indentation/extension of the pavement into the road on both north and south carriageways of Heathfield Road to emphasise the change in speed limits at both points. See; http://www.rospa.com/roadsafety/conferences/congress2005/info/kennedy.pdf and page 51 of Highway Code; photo below. Incorporate central white diagonal stripes along the whole of the 20mph section. Improve pavement configuration at junction with Keston Avenue.

5. Restrict the east bound traffic along Fishponds Road to left turn only, making the junction with the Westerham Road 'No Right Turn’. Consider Fishponds Road for one-way designation, which would be safer for all and along with shaped kerbs would enforce the no right turn.

6. Create a strong visual feature within the verge areas either side of the Bridleway 'cross-over' point on Westerham Road. Combine this with road surface cross hatching and appropriate signage to warn drivers of the possibility of horse riders crossing the road at this point.

7. Improve the sequencing and dwell-time/priority allocated within the traffic light system to pedestrians at the Croydon Road junction with Westerham Road at the Mark. Improve the right turn facilities particularly for traffic turning right and towards the south using Westerham Road. !

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Highway Code Rule 1418

Large delivery vehicles, removal vans etc would need to enter and leave the village 9

from the Croydon Road.

Currently there are two stretches of the B265 with 40mph speed limits. 10

!!!!!!!!!!!!!!!As an example of the width restriction configuration recommended, a similar scheme has been in place along the A2213 Kidbrooke Park Road for many years.The photo shown above demonstrates a width restriction of 7 feet and

bus lane in close proximity and in both directions of the A2213. Please note in particular that the schemes for each carriageway, whilst not juxtaposed are within 30 meters of each other and close to the incoming road T junction with Weigal Road.

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!!The photo below shows the bus lane and width restrictors close to the A2 end of the A2213.

!!!!!Page � of �12 14

Local width restrictions Already in use at Hayes Lane where the restriction is 7’ and on Red Lodge Road, West Wickham where the restriction is also 7’. !Conservation Area Much of the central area of Keston Village is a designated Conservation Area. The boundary stretches from the Flint Institute (Previously Keston C of E School) in the south along Heathfield Road and Commonside as far as Oakfield Lane in the north. The Conservation Area incorporates the historic village centre and Keston Windmill, a Grade 1 listed Postmill built in 1716. KVRA and the FoKC consider that LBB have a responsibility to support residents in their efforts to maintain the special character of the area for the enjoyment of all. Signage, such as can be seen in Wickham Road, Beckenham can inform people of the areas status as a Conservation Area. The ROSPA Traffic Calming work confirms "Physical traffic calming measures........have been shown to generate substantial reductions of vehicle speeds and accidents”. !Unintended Consequences Such comprehensive proposals may have unintended consequences. In the event of all proposals being implemented, thought has been given to what these may include; • Increased volume of wide and heavy vehicles using local lanes; Solution;

reduced speed limits and improved signage and width restriction. • Commonside and Fox Lane may become busier as these two could provide

a through route if the Croydon Road junction with Westerham Road remains such a poor major cross road with resulting east bound queues along the A232. Solution; improve traffic light phasing

• Vehicles travelling north and avoiding the width restrictors may turn left off Westerham Road into Fishponds Road to then turn right into Heathfield Road to travel through Keston Village. Solution; make Fishponds Road one way and hence 'No Entry' from Westerham Road. This would potentially also improve the awkward bend alongside the entrance to Holwood in Westerham Road, which has resulted in fatal accidents.

• The junction at the Mark will theoretically be busier. !!Conclusion The proposals have been agreed by both KVRA and FoKC and have been widely circulated with a great deal of support from Keston residents. !Keston Village residents are determined to protect the Village and the Conservation Area in a sustainable way from the problems of ever increasing traffic levels. Residents, visitors, School pupils and business people will all benefit from the strategic approach taken by KVRA and FoKC in constructing the proposals contained above. We are confident that when implemented these will provide a much safer environment for all. !!Page � of �13 14

!Appendix 1 !Mr Nigel Davies Executive Director of Environment and Community Services London Borough of Bromley Civic Centre Stockwell Close Bromley Kent BR1 3UH !12th December 2013 !Dear Mr Davies !Ref: Speed and quantity of vehicles through Keston Village !Keston Village Residents’ Association (KVRA) discussed the proposed roundabout to be located at the junction of Heathfield Road and Westerham Road at their recent meeting. !KVRA write to you to express their concern about this proposal and the significant volume and excessive speed of traffic passing through the village using Heathfied Road. !Roundabout The residents are exercised that this proposal involves unnecessary expenditure of £37,000 during constrained financial times. Locals consider that the roundabout will increase traffic using Heathfield Road. KVRA request that this organisation is formally consulted on the proposal. In addition, consultation must include the residents of all the Village roads, which join Heathfield Road. These residents suffer the daily inconvenience and dangers accessing the main road. !Heathfield Road – volume and speed of traffic The report reference number ES13094 quantifies the volume of traffic using Heathfield Road in the table on page 157. The data records that between 7am and 7pm on average every day 8042 (70 + 3996 + 117 + 3859 = 8042) vehicles pass through the Westerham Road/Heathfield Road junction using Heathfield Road. This is the volume using the B classified Heathfield Road and travelling through Keston Village each day. This compares with the 6325 (3338 + 2987 = 6325) vehicles using the A classified Westerham Road. The statistics in this report clearly demonstrates that the number of vehicles using the B265 Heathfield Road is 27% greater than the A233. Residents living on Heathfield Road constantly witness vehicles travelling at illegal and excessive speeds on this road. KVRA has been trying to obtain speed monitoring equipment to tackle this danger. !KVRA suggest that every LBB effort should be concentrated on encouraging the use of the main Westerham Road A233 and restricting traffic using the narrow and congested B265 through Keston Village rather than incurring significant expenditure simply to ease a minor inconvenience to south bound traffic each evening. Width restrictions at this junction, which allow routine car and bus movement as in place on Kidbrooke Park Road on A2213 between the A20 and the A2 would be a constructive start. Yours sincerely !David Clapham Chairman Keston Village Residents’ Association !!Cc: KVRA Committee, Councillors; R Bennett, S Carr and A Michael

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