Arising from the discussions held at our most recent Open Meeting in Decmber 2014, the following email has been submitted to Merton's Planning Department on 20/01/2015:
This email is submitted on behalf of the Raynes Park and West Barnes Residents’ Association (RPWBRA)
by Jerry Cuthbert, Committee Member, as follows:
Application reference numbers: 14/P4287 and 14/P4288.
Name: Jerry Cuthbert for the Raynes Park and West Barnes Residents’ Association.
Address: address supplied
Planning application description:
Redevelopment of the Rainbow Industrial Estate, Approach Road Grand Drive, SW20 OJY (14/P4287)
“Kiss & Ride” at Rainbow Industrial Estate, Approach Road, Grand Drive, SW20 OJY (14/P4288)
The Raynes Park and West Barnes Residents’ Association objects to the Planning Application for Redevelopment of the Rainbow Industrial Estate (14/P4287) on the following grounds:
Note: This document refers to Merton’s Local Development Framework (LDF), its supporting documents, including its Core Strategies (CS), its planning policies and its “Planning Brief for the Rainbow Industrial Estate” (the Planning Brief).
1. EXECUTIVE SUMMARY
The origins of the proposals stem from the decisions reached at the Examination-in-Public ( EIP ) for the Core Planning Strategy, in March 2011. At these hearings, the Inspector noted that the designation for the site was - and still remains – as a Locally Significant Industrial Site; the permitted uses of which are mainly Industry and Storage. At the hearing, Workspace Group’s representatives made the claim that, in order to redevelop the site, they were seeking a broader range of uses. The Inspector accepted that a wider range of uses "may be considered " for the site " where these uses contributed to the site delivering the aims of Policy CS12 ( Economic Development in the Core Strategy ) and meet the terms of other Policies in Merton s Development Plan". The Inspector specified that a Planning Brief would need to be Adopted which set out proposals for the whole site and she specified that the proposals " must be employment led and may incorporate a greater mix of uses " other than Industry and Storage. The Inspector did NOT indicate what the "greater mix " could include.
Conflict with Planning Policies
We submit that the proposals fail to meet the requirements of Policy CS 12 and other Policies in Merton ' s Sites and Policies DPD for reasons set out below but in particular we believe the proposals are NOT "employment led ". The huge quantum of proposed residential development in comparison to the very modest amount of additional business-type development clearly demonstrates that in overall terms the proposals are in reality residential led and therefore in significant conflict with adopted Planning Guidance, including the conditions imposed by the Inspectorate.
Unsuitable Location for Residential Development
We further submit that the proposals are in conflict with Policies in the Sites and Policies DPD in that the site is a highly unsuitable LOCATION for any residential use due to the proximity to the Railway Station and Railway lines due to noise, dust, vibration, station announcements, etc and equally unsuitable due to the limitations and potential risk factors of the single entrance with no prospect of securing a second means of access.
Long Term Considerations
We further believe that if longer term considerations were taken into consideration, the site should be retained for its current restricted uses, in case the site was deemed essential to provide more important uses; possibly in connection with the proposals for Crossrail 2. If the proposals were implemented it would render it almost impossible to use the site for such needs and in that sense we submit that the proposals fail to represent Sustainable Development and are therefore in conflct with the National Policy Planning Framework.
The following paragraphs set out our concerns in greater detail:
· The need to safeguard the Kiss & Ride facility,
· Loss of employment land.
· Overbearing massing.
· Noise, pollution and vibration from the railway
· Lack of affordable housing.
· Omission of sustainable urban drainage
· Severe access limitations
We therefore urge Refusal of this Application.
2. THE NEED FOR SAFEGUARDING THE “KISS AND RIDE” FOR THE COMMUNITY.
It is noted that the proposed “Kiss and Ride” facility on the south side of Raynes Park Station has been submitted as a separate application (14/P4288). The RPWBRA supports this methodology, on the basis that the “Rainbow Application” (14/P4287) may not be approved or may be subject to subsequent amendments or delays. It is important that the “Kiss and Ride” facility is delivered for the local community, irrespective of the outcome of the “Rainbow Application”.
The Planning Brief, Site Proposals, Section 6.4, states that the Kiss and Ride is a requirement. It is thus implicit in the Site Planning Brief that the “Kiss and Ride” facility is a crucial part of the Brief and thus enabled by the “Rainbow Application” (14/P4287).
Therefore, assuming that redevelopment of the Rainbow Estate may eventually be approved in whatever form, the delivery of the “Kiss and Ride” facility (14/P4288) should be made the subject of a S106 Agreement or similar Condition attached to the main application (14/P4287). This would guarantee the provision of this key requirement of the Planning Brief for the community. Additionally, the S106 Agreement or condition should fix a suitable point for completion of the “Kiss & Ride” within the construction programme for the re-development of the Rainbow Industrial Estate.
Neglecting to incorporate this safeguard could result in the delay or non-delivery of the “Kiss and Ride”, particularly in view of the complexities of ownership of this part of the site close to the railway station. The potential for failure of this part of Merton’s LDF is significant and should not be overlooked.
3. THE APPLICATION IS NOT EMPLOYMENT LED AND REPRESENTS A LOSS OF LAND AVAILABLE FOR EMPLOYMENT, CONTRARY TO THE PLANNING BRIEF AND LDF.
The Planning Brief, states:
· in the Objectives, Section 5.4 (b), that Merton will resist the loss of employment uses within Raynes Park.
· in the Site Proposals, Section 6.1, that the site delivers employment-led regeneration, and
· in Section 6.2, that there will be a minimum 3,400 or more of employment floor space.·
Merton’s LDF, Core planning Strategy, Policy CS12, Economic Development, includes:
- Item a, the requirement for increased provision in jobs in the Borough;
- Item c, the protection of the supply of sites for employment use.
- Section 20.12 requires an increase in employment opportunities,
- Section 20.13 sets a restrictive approach to the transfer of industrial sites to non-employment uses, and
- Section. 20.16 specifically requires that the Rainbow Industrial Estate must be employment led and meet the terms of Policy CS12.
The applicant states that the Commercial Gross External Floor Area (GEA) will be 3,758 m2,. This is very similar to the current amount of enclosed commercial available on the site. By concentrating this into only part of the site, the application proposes to convert 2/3 of the site to residential use, thereby leaving only one third of the land currently remaining available for employment uses.
Additionally, the application states that the Residential GEA will be a massive 24,336 m2. Thus only 13% of the developable space will be given to employment uses and that 87% of the floor space would be allocated to residential use.
Effectively, the application removes any opportunity for increasing employment opportunities on the site and represents the loss of approximately 13,000m2(1.3 hectares) of land designated for employment use.
The application therefore fails to deliver the requirements of the Brief:
- It represents a loss of employment uses within Raynes Park.
- It is not employment-led regeneration.
The application also fails to comply with the LDF, Policy CS12, for the following reasons:
· It does not provide an increased provision of jobs.
- It represents the loss of land available for employment.
· It does not deliver an increase in employment opportunities.
· It transfers land from employment to residential use.
· It is not an employment led development.
4. THE OVERBEARING MASSING OF THE BUILDINGS IS CONTRARY TO THE PLANNING BRIEF AND LDF.
The Planning Brief, Site Proposals, Section 3.43, Design Principle, requires that the development be limited to 4-5 storeys in height, with the upper storeys set back.
Merton’s Sites and Policies, DM D2, Design,. Policy a) i) , “requires that new developments relate positively to the … height … massing of surrounding buildings”
Additionally, the LDF Policy CS14, Design, Item c, states that tall buildings may only be appropriate in certain specified locations. These locations do not include Raynes Park.
However, in this application the following building heights are proposed:
Block A 6 Storeys plus plantroom
Block B 7 Storeys (no stepping back of upper floors)
Block C 6 Storeys (no stepping back of upper floors)
Block D 5 Storeys
Block E 6 Storeys (with extra height top storey and no stepping back of upper floors)
Block F 6 Storeys (no stepping back of upper floors)
The massing is therefore overbearing and out of keeping with the urban landscape in Raynes Park, which is principally comprised of 2 storey houses. The design is even several storeys higher than other blocks in the vicinity such a “Waitrose” and “Bushey Court”.
This visual impact of the overbearing massing can be seen in the applicant’s Design and Access Statement, Section 3.5, Views of the Site.
The applicant has therefore failed to meet the requirements of the Planning Brief and LDF Design Policies, in that:
- The development is not limited to 4-5 storeys, with the upper storeys stepped back.
- The massing does not relate to the height and massing of the surrounding buildings.
- It introduces tall buildings into Raynes Park.
5. THE APPLICATION HARDLY PROVIDES FOR ANY AFFORDABLE HOUSING
The Planning Brief, Policy Context, Development Plan Policies, Housing, refers to the requirement for 40% affordable housing. This is now incorporated into Merton’s Core Planning Strategy policy CS8, Housing Choice, section (d)..
The applicant’s Planning Statement says that 16 affordable homes will be provided out of a total of 229 (i.e. a mere 7%).
This is woefully short of Merton’s Core Strategy CS8 and the Planning Brief.
6. THE RESIDENTS WILL BE EXPOSED TO NOISE, VIBRATION AND POLLUTION FROM THE RAILWAY
The RPWBRA Association avers that the Rainbow Industrial Estate is completely unsuitable for residential development. One reason, as many, is that the site is completely surrounded by busy railway lines and is close to Raynes Park Station.
There is a significant amount of noise associated with proximity to the railway;
· Noise from passing trains.
· Wheel squeal as the trains passing through tight bends in the track.
· Brake noise from stopping trains.
· Platform announcements on the public address system.
· Night-time engineering works.
There is also vibration from passing trains and pollution caused by brake dust.
Merton’s Sites and Policies, D2, Design, Policy a) vi), requires that developments are protected from “… noise, vibration and pollution.”
The applicant’s Design & Access Statement and Noise and Vibration Statement correctly identify the railway lines that surround the site as being a source of noise, and vibration.
Whilst some mitigation measures are proposed for noise, it is noted that no measures are propose to combat vibration. Also, the applicant’s documents put emphasis on the outdoor amenities to be provided, for children and adults, but completely overlook the proximity of busy railway lines, with the concomitant noise and vibration.
The application is therefore only partially addresses the requirements of Merton’s Sites and Policies, D2, Design.
7. OMISSION OF SUSTAINABLE URBAN DRAINAGE (SUDS)
The Planning Brief, Policy Contact, Flooding, requires the development to utilise sustainable urban drainage unless there are practical reasons for not doing so.
Merton’s Sites and Policies, DM F2, Flooding and Drainage, incorporates the following requirements for new developments:
Item i - A sustainable design approach to drainage,
Item iii - A demonstration of maintenance and long term management,
Item vi - Demonstrate the local network has adequate capacity.
The applicant’s Below Ground Drainage Statement proposes that surface water drainage is collected into underground storage facilities, before being discharged into an existing culvert. Additionally, it is proposed that pumps will be necessary due to the lack of sufficient slopes.
Whilst the Statement explores the possibility SUDS at some length, the proposed solution is NOT a SUDS scheme. The Statement fails to consider:
a) Whether, if the development were less dense, that there would be less run-off and also more space and opportunity to incorporate SUDS.
b) Any proposals for maintenance and long term management
c) Whether the local network has adequate capacity.
Therefore, by proposing an inappropriately dense development, the applicant claims that SUDS are not viable, contrary to the Planning Brief.
The application also fails to meet requirements of Policy DM F2 on the several matters as listed above under Items i, iii & vi.
8. THE SEVERELY LIMITED ACCESS IN INAPPROPRIATE FOR THE PROPOSED DEVELOPMENT.
The RPWBRA avers that the applicant’s Transport Assessment shows many symptoms of the site being inappropriate for a dense residential development, as follows:
a. Applicant’s Appendix L
In order to provide safe pedestrian access under the railway bridge, the access road will be reduced to a single lane at this pinch-point, controlled by traffic lights. However, no consideration is given to the likelihood of queues backing up into the K&R area.
b. Applicant’s Appendix M
It is proposed that there will only be a single lane access road to blocks D, E and F, with a small single vehicle turning area at the end. This is likely to lead to queuing and traffic conflicts and grid-lock, as soon as more than one vehicle needs access to these blocks. Attendance by the emergency services and refuse collection are all likely to experience problems.
c. Single Point of Access
The only access to the whole site is through the railway arch. The RPWBRA avers that, in an emergency, this is an unsafe arrangement, as it totally depends on the railway arch not being blocked; for example, by a broken down vehicle, a vehicle fire in the K&R area or traffic congestion on the south side of Raynes Park Station. In such circumstances, all the residents would be trapped on the site.
We therefore urge Refusal of this Application.
J R Cuthbert
on behalf of the Committee for the Raynes Park and West Barnes Residents’ Association.