Stag Brewery Planning Inquiry: Final Submissions: Richmond Council

Readers will also wish to note that the Government has today published a new National Planning Policy Framework. The Inspector will direct, provisionally, that further submissions in the the light of that Guidance should be served as soon as possible and in any event by 10 January 2025.

In conclusion on the need for the school it was argued

There is an unconditional development plan imperative for the delivery of a
secondary school at the site. Imperative is a matter for the Inspector


There is support from government at local, regional and national levels.

And substantial local opposition

All of the current indicators of need point to a suppressed and sizeable level of
latent pent up and unmet need.
If there is the evidence is not obvious. More to the point is that the proposed school could not possibly be available over the next four years, and then only on the basis of one form a year.

The statistical year 7 predictions undertaken by both the Council and objectors
show a shortfall in provision over the next 4 years.

The objector’s only expert assessment, read with due regard to potential yields, is
agreed to show a need for a secondary school within the period to 2040.

No alternative site for a secondary school is suggested to exist.

This ignores the argument that Thomson House School could move to the site and would not need to be of the same size as proposed in the current scheme.

There is no established capacity for expansion of existing schools.

There is no evidence that any overprovision of education facilities will harm any
existing school.

Res ipsa loquitur?

There is clear evidence that the under-provision of facilities within the borough
will have the potential to harm the education of pupils.

It would have the potential if it were true.

The development of a school will be in accordance with the development plan.

In his overall conclusion Counsel for Richmond argued:

The benefits of this scheme are myriad, as the Appellant has highlighted. Ultimately, the
Council has taken into account the effects of the scheme and the benefits it delivers. It
recognises the contribution that the scheme will make to market housing, affordable
housing, employment opportunities, townscape, education, heritage and design and
transportation, all on brownfield land. The Council has concluded that the scheme is in
accordance with the development plan and that there are no material considerations which
would warrant dismissing either appeal; no party has suggested that the Council was not able
to rationally conclude that the development is in accordance with the development plan, nor
was Ms. Thatcher criticised …. for that conclusion. Therefore, it is respectfully requested
that the appeals are allowed subject to conditions and s. 106 provisions.


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About Richard AH White

Retired Solicitor specialising in child law and former Tribunal Judge hearing cases on special educational needs and welfare benefits.
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