Report Relating to Access Issues To The Proposed Ryde ... 5 Ryde School Planning P_01460_17.pdf ·...

Report

Relating to Access Issues

To

The Proposed Ryde School Boarding House

Planning Application

Ref: P/01460/17

Elspeth Grant Cert FRA TDipIT TripleAconsult 2 Quai Pasteur Chinon 37500

France

Tel: 07973 703309 E-mail: [email protected]

Website: www.tripleaconsult.co.uk

January 2018

Planning Reference: P/01460/17

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Table of Contents

1 Introduction .......................................................................................................................................... 3

2 Scope of report ..................................................................................................................................... 4

3 Credentials ............................................................................................................................................ 5

4 Access for emergency vehicles ............................................................................................................. 6

5 Access routes for students/staff ......................................................................................................... 11

6 Storage of motorised scooters and electric wheelchairs.................................................................... 16

7 Conclusion ........................................................................................................................................... 18

Appendix A Sport England Email re Removal of buggy path .................................................................. 20


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1 Introduction

1.1 Ryde School is a leading independent day and boarding school on the Isle of Wight. The school provides education to a diverse community of children aged 3 to 18 including international students. The school has the capability to provide non-discriminatory education for both non-disabled and disabled pupils and those who have special educational needs.

1.2 In March 2017, Ryde School submitted a planning application to the Isle of Wight Council for the construction of on-site boarding accommodation to be built at the lower edge of the site adjacent to the tennis/netball courts. The proposed three-storey accommodation would provide boarding for 68 pupils with four additional staff who would be re-located from the existing Bembridge boarding site. The proposed accommodation provision includes three accessible rooms for wheelchair users on the ground floor and cooking facilities.

1.3 The planning application was refused on 14th August 2017 on the grounds:

“ that it would fail to preserve and enhance the character of the Ryde Conservation Area and therefore would be contrary to the requirements of policies DM2 (Design Quality for New Development) and DM11 (Historic and Built Environment) of the Island Plan Core Strategy, the intentions of paragraphs 58, 60 and 61 of the National Planning Policy Framework, and the requirements of section 72(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 (as amended).”

1.4 A planning appeal was lodged 13th October 2017 with Interested Party Comments being required by 22 December 2017. A decision on this appeal has yet to be made.

1.5 In parallel with the appeal, a new planning application has been submitted on 15th December 2017 with supporting documentation.

1.6 A design and access statement has been submitted as part of this application however this statement makes no reference to accessibility issues for disabled people. The statement makes no reference as to how Ryde School intends to ensure equality of daily access between the proposed boarding house and the main school for wheelchair users, mobility and visually impaired pupils.

1.7 The General Arrangement Access/Highways Plan1 shows a compacted gravel buggy path running alongside the sports pitches to provide access between the boarding house and the main school facilities. Other plans submitted does not show the buggy path reaching all the way to the boarding house. It should be noted that Sport England (please refer to Appendix A) objected to the construction of an identical buggy path in the previous planning application2 which resulted in the plan for the path being withdrawn from the plans.

It is suggested that it is unlikely that students and staff would wish to travel this distance alone in a secluded location on a dark winter’s night or whether the parents of boarders would be satisfied with this arrangement.

1 Drawing Number 20548/5 2 Appeal Reference: APP/P2114/W/17/3186903


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2 Scope of report

2.1 This report has been commissioned by David Goodman & Co who are acting for the local residents group RABH (“Ryde Against The Boarding House”).

2.2 The report represents my professional views on the following issues:

Access for emergency vehicles;

Access for students between the boarding house and the main school buildings;

Storage and charging of motorised scooters and electric wheelchairs.

2.3 This report has been based on the information provided as part of the planning process, including the appellant’s amendments to the application, and information provided by D Goodman and Co.

2.4 The report therefore represents only my best judgement on the issues based on information provided by others. No liability whatsoever is accepted for the accuracy of such information.


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3 Credentials

3.1 With regard to my qualifications, training, and experience, I am a qualified fire risk assessor and an independent consultant advising clients in the areas of fire safety, access and egress for disabled people. For four years, I was the Secretary General of the Institute for Fire Managers (IFSM).

3.2 Since 2003, I have delivered solutions for complex workplace legislative issues such as fire safety and equality & diversity, including advising architects/designers on social housing major renovation programmes. I have designed strategic plans for means of escape for disabled people from complex environments such as high rise social housing assisted living accommodation and major public access environments for the past ten years.

3.3 I regularly present as an expert speaker to forums such as the NASHiCS Forum for Safety and Health Conferences, Firex, Fire Protection Association, British Standards Institute, Total Workplace Management at Olympia, Boards of Directors on issues such as access and egress issues.

3.4 I am an experienced trainer with a Teacher’s Diploma who has delivered training courses to public and private clients including Fire and Rescue authorities on the subject of disabled evacuation strategies. I have also managed large scale training programmes including Equality & Diversity for 3,500 public sector employees delivered by a team of disabled trainers.

3.5 The table below details my qualifications and professional membership:

2012-2014 Secretary General of The Institute of Fire Safety Managers (IFSM)

2011-2014 Member of the Council of The Institute of Fire Safety Managers (IFSM)

2011 Inclusion in the Institute of Fire Risk Managers Fire Risk Assessors Register

2011 Principles and Practise of Evacuation Modelling, University of Greenwich

2011- 2014 Member of the Institute of Fire Safety Managers after Associate Membership

2009 ABBE NVQ Diploma Fire Risk Assessor (Cert FRA)

2007- 2014 Associate Member of British Institute of Facilities Management (BIFM)

2007 IOSH Managing Safely Cert No 626,580

2005 – 2011 Specialist Knowledge Member of Guildford Borough Access Group

2004 – to date

Member of and Associate Trainer for Workplace Law

2003 Qualified as an Access/Egress Assessor


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4 Access for emergency vehicles

4.1 The most common causes of fire within student accommodation are cigarettes, candles, appliances left on and over use of extension leads. Students are likely to be filling plug banks with numerous electrical devices (laptops, phone chargers, and televisions) and potentially smoking whilst under the influence of alcohol. This increases the likely risk of a major fire incident.

4.2 Access to the location of the proposed three-storey sleeping accommodation for 68 students and four members of staff is via a narrow, single lane, dead-end and unmade track leading from Spencer Road.

4.3 The proposed location of the boarding house is approximately 135 metres from Spencer Road and therefore emergency vehicles will need to utilise this track in an emergency.

4.4 The nearest Fire Station is currently 1.7 miles away. This service is currently under review. It is not known whether the fire station will retain a high reach appliance capable of providing emergency fire-fighting/evacuation for a three storey building.

4.5 The access route does not currently meet the requirements of Building Regulations3 as an access route and there is a stream running beside the early section. The angled access from Spencer Road would not currently permit a fire appliance to access the track however there are plans to widen a small section of the initial track. The track is flanked on both sides by residential houses and there are tree root protection issues relating to the first sections of the track.

4.6 Island Roads have recognised the widening of the entrance to the access track for maintenance vehicles. It should be noted that currently there is no requirement for such vehicles to enter the site. Island Roads have not addressed the issue of emergency vehicles being able to pass each other at the pinch points between the residential properties lining the track.

4.7 A fire appliance needs access to within 45m of every point within a dwelling and, importantly, the access road to this site should not require fire appliances to reverse more than 20m in order to access, or leave, the scene of an incident.

4.8 Legislative requirements and guidance which are relevant to the above fire safety issues include but are not limited to the following statements:

“Traffic routes should be determined and can be classified as either access/through routes to site for deliveries, shuttle routes between buildings for on-site activities, or emergency access routes for fire engines, ambulances etc4.”

“The suitability of access arrangements for the Fire and Rescue Service and ambulance service can be an important consideration in the layout and design of development, particularly in relation to backland development or sites with restricted access. Designers should therefore consider the needs of the emergency services early in the

3 Building Regulations 2010 B5

4 HSE Roadways / site traffic control / immobilisation of vehicles


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design process and may be required to submit information to accompany their proposals indicating how the matter has been addressed5.”

“The typical fire and rescue service vehicle access route specification 3.7 metres minimum width of road between kerbs with a clearance of height of 4.0 metres for a high-reach vehicle6 .”

“Vehicle access to the exterior of a building is needed to enable high reach appliances, such as turntable ladders and hydraulic platforms, to be used and to enable pumping appliances to supply water and equipment for fire-fighting, search and rescue activities7.”

4.9 To meet the requirements, the access route will need to be raised and strengthened to carry at least 12 tonnes with a clearance of 4 metres8. It is difficult to see how this could be achieved in the initial section of the access route given the tree root protection issues for the access track which is within the Isle of Wight Ryde Conservation Area.

4.10 In order to address the above issues, Ryde School have submitted proposals to include the provision of:

A hard-surface, single access route to the proposed tennis, netball court;

Widening of the initial section of the access lane to allow the minimum requirement of 3.7 metres clearance for emergency fire appliance access9;

Turning facilities on the proposed new tennis/netball courts.

4.11 No plans have been submitted by Ryde School to:

Provide access to the rear of the building for fire appliances where there is an elevation of 40.2510 metres above ground level;

5 PPS 3: Access, Movement and Parking Policy AMP 2 5.12

6 Building Regulations 2010 B5 Table 20

7 Approved Document B section 11.1

8 Isle of Wight Building Control Guidance Access for Fire Service

9 Building Regulations 2010 B5 Table 20

10 P/01460/17 Ryde School Planning Application Site and Floor Levels PL130


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Widen the access route sufficiently to permit passing of emergency vehicles such as fire appliances, police or ambulances entering or leaving the site which is at the dead end of the access route;

Ensure sufficient clearance is available to enable suitable fire appliances to enter the site once the track hard-surface has been constructed.

4.12 No Arboricultural Impact Assessment has been submitted with this planning application. It should be noted however that the impact assessment submitted on 13/3/17 by Wayne Isaacson as part of the planning appeal makes the following statements:

Para 3.3 Root protection area (RPA) incursions by hard surfacing: Nine trees will be affected by the reconstruction of the access road. The impact of this work will be kept to a minimum by the use of a three- dimensional cellular confinement system for the road sub base, detailed in the design. The route of the gravel path (existing) is also to be improved. Where this path crosses the RPAs of retained trees, it is proposed to remove the compacted surface and, again, replace with three- dimensional cellular confinement system. This will improve the rooting environment in these areas, so will have a positive effect on these trees. If an arboricultural method statement is produced for this by a competent arboriculturist and adhered to, then the impact of path and access road construction will be minor.

Para 3.4 Service trenching: The plans that I have seen do not detail service or drainage routing. Any trenching within RPAs has the potential to cause severe damage to the respective tree and should be avoided. Where conventional trenching within RPAs cannot be avoided a detailed arboricultural method statement must be produced and adhered to.

Para 3.7 Treework: The access road will be required to accommodate high vehicles, plant and machinery. Trees No 1-12 line the northern section of this roadway. Low branches will interfere with traffic so facilitation pruning will be needed. From my survey, the amount of pruning required to provide 5m clearance over the road will be well within the trees’ tolerance to pruning. The long-term impact of this level of pruning will be minor.

4.13 It should therefore be noted that it is not be possible to further increase the width of the initial sections of the track further due to the adjacent properties on Spencer Street. Any attempt to widen this section of track further would require the removal of all the adjacent trees.

4.14 The photo, access route plan and table below shows the maximum widths of the access route.


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Photo looking south, trees either side mark narrowest point

Figure 1: Access route plan

4.15 The maximum access track width boundaries from Nos 39 to the boundary of Nos 41 are marked on Figure 1 however it must be noted that this will require the removal of all the adjacent trees which has not been agreed as an approach:

1. 8.2 metres

2. 7.5 metres

3. 9.77 metres from corner of Nos 41 fence.

4.16 The maximum access track width boundaries taking measurements from the boundary of Nos 39 westwards to stream bank:

1. 5.4 metres


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2. 4.1 metres

3. 6.0 metres

4.17 The maximum possible width of the access track between the boundaries of the adjacent properties has pinch points reducing the width to 4.1 metres. Emergency vehicles will have no choice but to wait for approaching traffic to clear the access route with the possibility of having to reverse over distances which are more than 20 metres.

4.18 It is sometimes suggested that potential delays in the arrival of emergency services due to access routes can be resolved by the installation of a water-based fire suppression system and dry fire main. It is important note that there is no Building Regulation maintenance requirement on such systems resulting in Fire and Rescue Service being reluctant to rely on these particularly in high risk sleeping accommodation.

4.19 Inevitably, the access route would therefore contravene Requirement B5 of Part B to Schedule 1 to the Building Regulations 2010. As a result, the access would not be such as to enable development of the access route to be passed by the Local Authority Building Control department.

4.20 The access route to the proposed development is single lane and the initial section of the access route is restricted by flanking houses either side which prevents widening of the route irrespective of any conditions set.

4.21 It is my professional opinion that the access route physical restrictions will result in unacceptable difficulties for operational fire-fighting which cannot be resolved through conditions set.

4.22 It recognised that in normal circumstances, the above issues would be dealt with during building control negotiations. However, given the extreme restrictions in access to the site my professional opinion is that these must be considered as part of the planning application rather than through the setting of a condition. This is due to the fact that it is not possible to widen the access route for emergency vehicles to allow for passing traffic.


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5 Access routes for students/staff

5.1 The proposed boarding accommodation makes provision for three wheelchair accessible rooms. It is therefore reasonable to expect that the school presumes that there will be students and/or members of staff who are mobility impaired and/or wheelchair users. It is also assumed that in addition there would be a number of pupils who will have temporary mobility impairment through sports injuries/accidents etc.

5.2 The planned boarding house is situated at a distance of approximately 126 meters between the proposed entrance to the new building and the hard surface car park adjacent to the main building of the school. This in itself will present difficulties for mobility or visually impaired students and staff who will be slow moving.

5.3 It is planned that all current services such as educational, catering and recreational facilities would remain within the main school buildings located adjacent to Queens Road. It would therefore be necessary for all boarding pupils to travel between the proposed boarding house and the main school buildings several times a day in all weathers.

5.4 A basic buggy path had been presented as part of the original planning application however when Sport England objected this was shelved in their Appeal Application11 (please refer to Appendix A).

5.5 It is understood that attempts by Ryde School were made previously to re-route the path however this then presented issues regarding the roots of trees. It is therefore surprising that Ryde School have re-presented the buggy path as part of this planning application particularly as it fails to meet access and equality requirements for disabled people.

5.6 The General Arrangement Access/Highways Plan12 shows a compacted gravel buggy path between the proposed boarding house and the main school facilities. This plan 20548/5 does indeed mark a “2.5m wide compacted gravel “buggy” track” however this is inconsistent with other plans which seem to show the track stopping short of the school building.

5.7 Legislative requirements which are relevant to disabled people include but are not limited to the following statements:

“All are equal before the law and are entitled without any discrimination to equal protection of the law. All are entitled to equal protection against any discrimination in violation of this Declaration and against any incitement to such discrimination13.”

“To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and

11 Appeal Reference: APP/P2114/W/17/3186903

12 Drawing Number 20548/5 13

The Universal Declaration of Human Rights Article 7


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communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas14.”

“These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia:

a) Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces;

b) Information, communications and other services, including electronic services and emergency services15.”

“Discrimination occurs when a disabled person is treated less favourably than someone else because of their disability, unless there is a good reason.”

“Direct discrimination occurs where, because of disability, a person receives worse treatment than someone who does not have a disability. This provision is intended to stop people being denied a service, or receiving a worse service, because of prejudice16.”

“Building regulations contain the framework for architects, designers and building managers to refer to, when implementing a new workplace or changing an existing one. Part M sets minimum standards for access and use of buildings by all building users, including disabled people17.”

5.8 Building Regulations Part M is supported by ‘Approved Documents’ (ADM) and British Standards which give practical guidance with respect to the regulations18.

Approved Document M (ADM) of the Building Regulations (Access to and use of buildings) provides guidance which is based on and complementary to BS 8300. But, it is incorrect to assume compliance with Part M or BS 8300 alone will meet the requirements of the Equality Act. Also, it should be noted that the requirements of Part M and BS 8300 are ‘minimum standards’.

BS 8300 is the code of practice that helps disabled people make the most of their surroundings through architectural design in the built environment. It looks at the provision of aids and the use of features such as access routes. The code is officially known as BS 8300:2009+A1: 2010 (Design of buildings and their approaches to meet the needs of disabled people – Code of practice).

5.9 Any future proposal for access between the two buildings must meet UK Design Standards and Guidance which support international, European and national law:

“Reasonable provision shall be made for people to gain access to and use the building and its facilities’. This does not apply to any part of a building that is used solely to enable the building or any service or fitting within the building to be inspected, repaired or maintained19. An accessible environment is one which a disabled person

14 UN Convention on the Rights of Persons with Disabilities Article 9 - Accessibility

15UN Convention on the Rights of Persons with Disabilities Article 9 - Accessibility

16 Equality Act 2010 17

Building Regulations2010 Part M and supporting British Standards, BS8300:2009 18

Approved Document M and supporting British Standards, BS8300:2009 + A1:2010 19

BS 8300, Design of buildings and their approaches to meet the needs of disabled people – Code of practice


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can enter and make use of independently or with help from a partner or assistant….20.”

“Purpose-built student living accommodation, including that in the form of flats ….. should be treated as hotel/motel accommodation in respect of space requirements and internal facilities21.”

“It is advisable for the recommendations given in this standard to be applied at the earliest possible stage in the design process22.”

“Uneven surfaces, surfaces of loose materials (e.g. bonded gravel) and large gaps between paving materials cause problems for wheelchair users, blind and partially sighted people and people who are, generally unsteady on their feet”23.”

“To be accessible the minimum surface width of an access route (ie between walls, kerbs or path edging) should be at least 1 800 mm for general routes or at least 1 500 mm if passing places are provided24.”

“An access route should either be level along its length or (where the topography of the land prevents this) should be gently sloping or incorporate a ramp or ramps25.”

“A ramp should have the lowest practical gradient within the range 1:20 to 1:1226.”

“An access route should have a firm, slip-resistant and reasonably smooth surface. Surface materials should be slip-resistant when wet.27.”

5.10 The Design and Access Statement states in para 6.7 "If this application is approved, parents dropping off their children will use the existing Queens Road access, and any disabled children will be transported to the boarding house”. The inference being that this is a once only journey when in fact this journey will take place several times a day.

5.11 It is unclear how Ryde School intends to transport disabled students and/or members of staff between the boarding house and main school facilities. It is difficult to understand how the school intends to ensure that their mobility scooters/wheelchairs would be available in different locations.

5.12 Disabled students and/or members of staff would not be able to travel independently between the buildings in the same manner as their peers. It is clear however that they would be put at a greater disadvantage than their non-disabled peers who would be able to move freely between the two locations without waiting for assistance.

5.13 In order to provide a non-discriminative environment where disabled students and staff can move between the facilities independently, a suitable access pathway that meets the requirement must be proposed.

20

BS 8300:2009+A1:2010 Introduction 21

Approved Document M Access To and Use of Buildings para 0.16 22

BS 8300:2009+A1:2010 Introduction 23

BS 8300:2009+A1:2010 section 5 24 BS 8300:2009+A1:2010 section 5.2 and 5.3 25

BS 8300:2009+A1:2010 section 5.4 26

BS 8300:2009+A1:2010 section 5.8.2 27

BS 8300:2009+A1:2010 section 5.5.1 & 5.8.7.


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5.14 The site plan below shows that in some areas the slope of the proposed buggy route between the proposed boarding house and the main school facilities greatly exceeds the Approved Document M and BS8300 gradient guidelines.

5.15 It should be noted that Approved Document M states that if site constrains necessitate an approach of 1:20 or steeper, an approach incorporating ramped access should be provided. Gradients should be as shallow as practicable, as steep gradients create difficulties for some wheelchair users and those with mobility impairment that lack the strength to propel themselves up a slope or have difficulty in slowing down or stopping when descending28.

5.16 A suitable access route between the two areas will therefore require major construction as any proposed access routes between the facilities must comply with all of the following29:

The gradient is between 1:20 and 1:15;

Flights to have a minimum clear width of 1200 mm;

Top and bottom landings to be provided to every flight;

An intermediate landing to be provided between individual flights and at any change of direction;

Have a firm, slip-resistant and reasonably smooth surface30;

28 Approved Document M sections 1.19 – 1.39

29 Approved Document M section 3.10

30 BS8300 Sections 3.9 & 5.5


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Be illuminated by fully diffused lighting activated automatically by dusk to dawn timer or by detecting motion;

Seating furniture to enable those who are slow moving to rest at suitable intervals.

5.17 Sport England has already objected to the buggy path in the previous application causing it to be withdrawn. It is my professional opinion that Sport England will inevitably object to the type of major construction necessary for the implementation of a suitable access route for disabled people in order to meet the legislative requirements irrespective of any conditions set.


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6 Storage of motorised scooters and electric wheelchairs

6.1 Ryde School is offering accessible rooms as part of their student accommodation in the proposed boarding house. It can therefore be expected that at any time there maybe one or more wheelchair users occupying that accommodation. There will therefore be a requirement for the storage and charging of their mobility scooters. However, the ground floor plans do not show any facilities for the safe storage and charging of students and/or staff mobility scooters.

6.2 Mobility Scooters are defined as an “Invalid Carriage” under the Use of Invalid Carriages on the Highways Regulations 1988 and have three categories:

Class 1 Vehicles Manually operated wheelchairs that are not electrically powered.

Class 2 Vehicles Powered Wheelchairs and mobility scooters for pedestrian routes and indoor use, that are limited to a maximum speed of 4mph and do not exceed an unladen weight of 113.4 kg.

Class 2 vehicles are not allowed on the public highway and are not required to be registered with the Driver and Vehicle Licensing Agency (DVLA).

Class 3 Vehicles Powered vehicles and mobility scooters that are designed to:

Travel up to 8mph and are used on roads/highways and;

Fitted with a device to restrict travel to a maximum speed of 4mph on pedestrian routes and for indoor use.

Class 3 Vehicles must not exceed an unladen weight of 150 kg.

Class 3 vehicles are not classed as motor vehicles but they are required to be licensed with the DVLA for road use and cannot be operated by anyone below the age of 14.

6.3 For the avoidance of doubt, the definition of an Invalid Carriage is:

“a vehicle, whether mechanically propelled or not, constructed or adapted for use for the carriage of one person, being a person suffering from some physical defect or disability.31”

6.4 The legislative requirement is as follows:

The Regulatory Reform (Fire Safety) Order 2005 applies and covers general precautions and fire safety duties which are required to protect people in case of a fire in common areas in and around buildings. The Order requires that risks should be assessed and actions taken to reduce risks to the extent that is reasonable and practical.

6.5 The Isle of Wight Fire and Rescue Services make the following statement regarding the storage of mobility scooters within residential care homes. However, it is logical that the same principle is applied in all residential accommodation:

“Mobility scooters are often stored and left to charge in areas such as corridors and staircases which are classed as sterile areas and should be free from combustible materials and ignition sources. This sterile area often makes up the means of escape for other residents within the living accommodation. This could be in a block of flats, sheltered accommodation, residential care home or other similar communal living accommodation.

31

Motor Scooter Guidance NSHFSGS working group


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The practice of storing mobility scooters in sterile areas places an unacceptable risk to other occupiers and must be discouraged.

Mobility scooters offer an increased fire loading and potential source of ignition. If involved in fire they can release large amounts of highly toxic smoke and gases. If stored in protected corridors, staircases or common areas (sterile areas), a fire involving a mobility scooter could affect the means of escape and place an unacceptable risk to all occupiers within the building.”

6.6 Mobility scooter temperature can reach 375 Centigrade within 3 minutes and 556 Centigrade within 8.5 minutes. With the speed that the temperature rises and the volume of the products of combustion, occupants would need to make their escape very quickly. A mobility scooter fire that is being stored within common areas of egress routes of premises would render circulation corridors untenable in less than 3 minutes.

6.7 It is evident that a fire involving mobility scooters, within an escape corridor or stairwell, will create a substantial risk to occupants since the smoke and heat will make such routes impassable and put occupants at risk32.

6.8 It is my professional opinion is that the Ryde School plans should include a secure, internal area with a sprinkler system fitted with charging points for the storage and charging of mobility scooters.

32

Motor Scooter Guidance NSHFSGS working group


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7 Conclusion

7.1 My professional opinion is that the access route restrictions have the potential to result in difficulties for operational fire-fighting which cannot be resolved by developing the access route. Although the fire station is relatively close, the reduced access route would have the potential to delay the arrival of fire-fighters and their equipment to the proposed boarding and create a bottle-neck for emergency vehicles.

7.2 There is the additional risk that the restricted access route would result in a delay in the emergency vehicles leaving the site after any incident. This delay would have the result of delaying the availability of fire appliance/s and other emergency vehicles for other emergencies elsewhere.

7.3 It is also my professional opinion that the access route cannot be developed to provide adequate access for the emergency services in the event of a major incident and would therefore contravene Requirement B5 of Part B to Schedule 1 to the Building Regulations 2010. As a result, the access would not be such as to enable plans to be passed by the Local Authority Building Control Department.

7.4 These opinions are based on the following rational:

The proposed development is located in the far corner of the sports fields at the bottom of a terraced/sloping site and isolated from the main school building.

The planning application relates to sleeping accommodation for 72 people, 68 of these will be less than 18 years old. As such, this type of accommodation can be considered as a higher risk of fire.

Fire incidents at this type of accommodation would involve all the emergency services resulting in a combination of emergency vehicles from the fire, police and ambulance services needing to access and exit the site;

The access route is single lane and the initial section of the access route is restricted by flanking houses either side which prevents widening of the route. It is not possible to develop the access route as part of the setting of conditions to enable two way traffic;

The length of the proposed lane together with the restricted width in the initial section will provide inadequate access for the Fire and Rescue Service. The width of the lane is inadequate to permit effective operations by the Fire and Rescue Service in the event of a major incident;

7.5 As regards to the issue of access for students and staff to and from the boarding house and main buildings.

7.6 It is my professional opinion that the proposal by Ryde School to transport disabled students and/or members of staff between the main school facilities and the new boarding house breaches:

The Universal Declaration of Human Rights Article 7

UN Convention on the Rights of Persons with Disabilities Article 9 – Accessibility

Equality Act 2010

Building Regulations 2010 Part M


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7.7 Furthermore, it is also my professional opinion that if the Council were to approve the current plans with respect to the access route between the main school facilities and the boarding house that, as a State Party, they would also be in breach of the above legislation.

7.8 In order to meet the legislative requirements for disabled people, it will be necessary for Ryde School to construct a pathway that fully meets Building Regulations Part M. My professional opinion is that the construction of a suitable access route to provide a non-discriminative environment for disabled students/staff is a major construction project in itself.

7.9 The construction of a pathway which meets Building Regulations will result in a major incursion into the sports areas. Sport England has already objected to the buggy path in the previous applications causing the plans to be withdrawn. It is my opinion that Sport England will inevitably object to the implementation of a suitable access route for disabled people irrespective of any conditions set.

7.10 As part of my rational, I have considered the following:

International and national legislation relating to disabled people;

The distance between the proposed entrance to the new building and the hard surface car park;

The gradients of the sloping site would require the construction of a number of ramps and landings;

That Sport England has already objected to the original plans for a simple buggy path. It can therefore be presumed that they would object to the construction of a hard surface pathway of the type necessary to provide a non-discriminative access route for wheelchair user, mobility or visually impaired students and staff;

7.11 It is highly unlikely, irrespective of conditions set as part of planning permission, that it would be possible to construct a path to provide a non-discriminatory route for disabled and non-disabled people which will be acceptable to Sport England. My professional opinion is that this would apply to any school building in this location.

7.12 The issue of safe storage and charging of mobility scooters for students and/or staff should be addressed. It is recognised that this could be provided externally after completion of the build however this would involve additional difficulties for disabled people. It is my professional opinion that the ground floor plan needs modification to incorporate a suitable facility internally.

7.13 The evidence which I have prepared and provided for this planning application P/01460/17 is true and I confirm that the opinions expressed are my true and professional opinions.


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Appendix A Sport England Email re Removal of buggy path

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