Local developments

19/P2387 - 265 Burlington Road

OBJECTIONS ON BEHALF OF THE ASSOCIATION 

Our committee member, David Freeman, has submitted the following on behalf of our Association.

 

Attention Case Officer . On behalf of Raynes Park and West Barnes Residents Association I submit the following comments. 

A ) Although not part of the Application I need to point out that the Newsletter distributed widely by Redrow Homes was highly misleading . This drew from the New London Plan ( a GLA document ) which sets out a target delivery in future years of 1,328 home pa. The Newsletter stated that Merton was “ expected to deliver “ this number of homes each year .

However the New London Plan is still in draft form and NOT an Adopted GLA Plan.

Merton’s housing target remains at 411 homes pa which derives from the existing London Plan of April 2016.

 

B ) SITE PROPOSAL

Site Proposal RP3 in Merton’s draft Local Plan October 2018, sets out LBM proposals for a comprehensive redevelopment of the WHOLE   of the Tesco site including the Store and Petrol Station. The Application in question is for a development on approx. one third of the site .

There is clear conflict here between Merton’ s Local Plan and the proposals in the Application.

 

C ) DESIGN

Planning Guidance : Policy 14 LDF Core Planning Strategy and Policy DM D 1 and DM D2 Sites and Policies Plan July 2014.

I submit that there is clear conflict with the guidance set out in the above Policies by failure of the proposals to “ relate positively and appropriately to the scale ,density,proportions, massing and height of the surrounding street patterns and by failure to protect existing development ( in nearby streets ) from visual intrusion .

 

D ) TALL BUILDINGS

Merton’s draft Local Plan provides a useful definition of a Tall Building . I quote .” a tall building is a building which is substantially taller than their surroundings “. 

The proposals submitted are for seven blocks of flats ( but NO houses !  ) ranging in height from 6 to 15 storey.

Starting from Merton’s LDF Tall Buildings Background Paper 2010 and Design Policy CS 14 Core Planning Strategy July 2011, reinforced by Strategic Policy LP D 5.1 Placemaking and Design in the draft Local Plan October 2018 from which I quote :

“ Proposals for tall buildings will be permitted only in Town Centres in Colliers Wood,Morden and Wimbledon.”

The Tesco car park site is not even close to Raynes Park which is a  LOCAL Centre and nowhere near Wimbledon Town Centre.

The proposal for “ tall buildings “ on the application Site is in FLAGRANT CONFLICT with the Planning Guidance quoted above .

Perhaps I should add - going back to the definition - that there can sometimes be doubt as to what “ substantially taller “ means . BUT NOT IN THIS CASE . The highest residential building ( under construction ) in the surrounding area is 5 storey.

A 15 STOREY BUILDING IS SUBSTANTIALY TALLER THAN A 5 STOREY BUILDING . Fact!

 

E ) HOUSING MIX

Planning Guidance : Sites and Policies Plan July 2014 Policy DM H 2 and draft Local Plan Policy H 4.3.

The proposal is to build 456 flats made up as follows ;

114 x one bed units =  25 %

290 x two bed units =  63.5 %

52  x  three bed units = 11.5 % 

The target mix set out in Merton’s Sites and Policy Plan is 33%, 32% and 35% but these have been slightly modified in the draft Local Plan to 33%, 33% and 34%.

The proposal to build almost two thirds of the flats as two bed units is way out of alignment with the policy . There would be too high a proportion of two bed flats and not enough ‘  family ‘ units. The proposals are in clear conflict with planning guidance.

 

F ) PUBLIC TRANSPORT ACCESIBILITY LEVEL ( PTAL ) AND TRANSPORT IMPACTS 

The Tesco car park site is beyond reasonable walking distance of both Raynes Park and Motspur Park Railway Stations and has limited bus service connections. In consequence it has a rather low PTAL rating between 2 and 3 ( out of 6 ).With an influx of probably more than 1,000 people and 220 car parking spaces it is obvious that the proposals would lead to a serious increase in traffic congestion in Burlington Road even greater than currently exists . 

The proposals are in conflict with Policy DM D 2 of the Sites and Policies Plan July 2014 in that there would be significant adverse impact on the existing transport infrastructure and local environment.

 

G ) FLOOD RISK

The Application Site is within fluvial ( river ) flood zones 2 and 3 and therefore at risk of surface water flooding. Such a location would be suitable for SOME types of development but not I suggest for high-density residential use.

 

And Finally let me say that Raynes Park and West Barnes Residents Association ( RP&WBRA ) is NOT opposed to any new housing in the Borough . We are supportive of Merton ‘delivering 400 plus new homes pa hopefully a MIX of houses and flats . A high proportion of these schemes are in ‘ backland ‘ areas on so called ‘ windfall ‘ sites.

We support this type of development where - in terms of numbers - the new residents can be assimilated into the local network without causing strains , on the local social services, for BOTH them AND the existing populace.

 

However let me indulge in a Compare and Contrast exercise.

I suggest Redrow Homes proposals could well be a ‘ natural fit ‘in the centre of a New Town  like Milton Keynes for example. There are in fact large blocks of flats in MK within the Town Centre and within a short walk to the main Transport Hub. The residents look down on to a wide shopping parade with housing development only in the very far distance. Many of the residents are either single or couples and many do not have a car - very limited on site parking. They use the Car Club. 

Would this type of development be a ‘ natural fit ‘ on the Tesco car park in West Barns .Hardly . 

The site is NOT a Town Centre location.

It is nowhere near a main Transport Hub.

Most of the new residents would insist of having a car but only about half of them would have a nearby parking space. And where would they find school places for their children, a GP Surgery, a NHS Dentist a Local Park . The list could go on.

They would be locked in between the A3 and the Railway lines breathing in the fumes from vehicles standing still for 15 minutes or more in Burlington Road waiting to get over the level crossing .

WHAT SORT OF QUALITYOF LIFE WOULD THAT BE FOR ANYBODY?

 Also in terms of Design the tower blocks would - by contrast with the local scene - stand out like huge monoliths bearing down on the residents of Seaforth Avenue and the roads beyond. Should they have to live with that sort of intrusion. 

I pose this question . Would these proposals meet the requirements of a key piece of Merton Planning Guidance - Core Planning Strategy  Policy CS 14 ? I quote :

“All development needs to be designed in order to respect, reinforce and enhance the local character of the area in which it is located “.Think about each of the three components.

I submit that set against this test alone the Redrow scheme would be a total failure.

 

On behalf of the RP&WBRA for all the reasons outlined above I urge the Planning Applications Committee to REFUSE this application . Thank you for your time. 

David Freeman

TESCO SITE DEVELOPMENT

Link to further information - Tesco Site - 265 Burlington Road

Tesco Site Development - Public Meeting

Tesco Site - 265 Burlington Road

UPDATE JULY 2019 - The Planning Application for this development has now been submitted (19/P2387)

Anyone who wishes to raise objections or make comments (called "representations") to the Planning Authority about this proposed development, is advised to do so by the revised date of 30 August 2019. This can be done using Merton's Planning Portal at:

https://planning.merton.gov.uk/Northgate/PlanningExplorerAA/GeneralSearch.aspx

The application number is 19/P2387

For our members to have an idea how large this development will be when viewed from our local roads, we are preparing some images, which may be viewed on this link: Images for 19/P2387

The application details may be downloaded from the Planning Explorer website.

Please note that the deadline for comments from the public (called "representations") has been extended to 30 August 2019

However, even if you miss the 30 August deadline, please still make your submissions.

Due to the very tight timescale for representations, Councillor Eloise Bailey has sought some clarification about dates from the Planning Dept, with the following response;

 “Dear Councillor Bailey, 

 

Thank you for your email. The statutory time period for notification for a planning application is 21 days. Therefore, for this application the representation date is currently shown as 14th August 2019. To unilaterally alter this statutory period would be seen as unreasonable behaviour on behalf of the Local Planning Authority and would not be consistent with how planning applications are processed. 

That being said, whilst the formal representation period could not reasonably be altered, representations will continue to be taken into account until such time as the application is determined. Therefore, comments received after the 14th August [This has since been revised to 30 August - Ed] will still be considered, up until the point of the committee meeting, which is likely to be September or even October. 

In addition, I note that the newspaper advert for this application has not yet been published, it is due to be published today, which would mean that the representation date would need to be 16th august at the very earliest. [This has since been revised to 30 August - Ed]

I hope that provides some assurance that comments will be taken into account throughout the process. Merton has carried out a wide ranging consultation exercise on this application, well in excess of the statutory requirements (i.e. we have consulted a wide area around the site). 

In terms of a change of date on the website, I am not aware of this and I can’t think why it would have said 24thAugust, as that is well over 21 days away. I will ask the leader of the admin team, Matthew Davidson, if he can provide any insight into this matter. 

 

Please do not hesitate to contact me should you wish to discuss the matter further or any other aspect of the application.”

 

FURTHER BACKGROUND INFORMATION

Redevelopment of 265 Burlington Road and Tesco Extra car park  

In the October 2018, we set out the basic details of a proposed large residential development scheme on a part of the Tesco car park site alongside Burlington Road. This was based on information provided at a Consultation Exhibition on 18th September mounted by BECG (Built Environment Communications Group) who are acting as agents for the housebuilder Redrow Homes PLC. (Follow this link to see Redrow's summary of their proposals https://burlingtonroad.com/proposals/ ) 

BECG held a second consultation, again at the Holy Cross Church hall, Motspur Park, on 13th November last year but this time with slightly amended proposals.  

The Scheme 

As at early December 2018, the outline proposals envisage using the Eastern side of the Tesco car park (1.21 Hectares) which would be just under one quarter of the whole Tesco site area.  

We therefore anticipate that the Planning Application from Redrow, when submitted, will aim to provide 446 flats in seven blocks ranging from 14 storey on the side furthest from Burlington Road down to 7 storey on the side closer to Burlington Road.  

  • The units would be made up as follows:
  • 90 one bed flats (approx. 20% of the total);
  • 290 two bed flats (64 %); and 66 three bed flats (16 %)  

"Affordable " Housing  

Taken overall it is claimed that 35% of the flats would pass the test of being regarded as "affordable" i.e. they would be social or subsidised housing either for sale or rental at no more than 80% of the prevailing market-rate costs and prices.  

It is quite often the case that developers tend (for obvious reasons) to offer the cheaper (mainly one bed) units to meet the social proportion. Currently, we are not aware how this will work out in practice, but the Planning Application will probably clarify this point.  

Car Parking  

The proposals include up to 220 car parking spaces and the current thinking is that these would be at the base of the flats i.e. as an ' undercroft ' scheme. It is claimed that 575 car spaces will remain available for the Tesco store shoppers.  

Site Access  

One change to the original proposals is to provide up to 475 sq. meters. of commercial space at ground floor level in the blocks fronting Burlington Road.  What type of business would be housed in these units is not known at present, but presumably Tesco would NOT want any competition quite so near their store!  

Also, the earlier proposal was that the existing short access road leading from Burlington Road to the Tesco store would become THE vehicular access road for the residents of the new flats, but no longer for vehicle access to the Tesco store, although pedestrian access from Burlington Road was to be maintained.  

This idea appears to have changed so that vehicle access from Burlington Road would be available for BOTH the new residents and shoppers going to Tesco. In short for Tesco shoppers no change to the present (unofficial) arrangement. At first sight this strikes us as far from being an ideal arrangement, given the single proposed vehicle access, the volume of traffic in Burlington Road even now, and the proximity of the level crossing, Surely the congestion would become even worse? However, it is still ‘early days.  

High Rise Development  

Anybody familiar with this part of West Barnes will know that it is characterised by inter-war mostly two-storey suburban housing, apart from Raynes Park High School to the North. We leave you to contemplate what it would be like for those residents having to live in the shadow of blocks of flats up to 14-storeys in height.  

There is currently great concern about possible flats at this sort of height along Wimbledon Broadway; but is at least that area has a Town Centre designation. Tesco car park certainly has not!  

The Local Plan 

 Merton Council now has a New Local Plan out for consultation. This may be seen here.  At present, this document is only a draft, and it is hoped that this will replace two other Planning Guidance documents sometime during 2020. Within this bulky document are Site Proposals for many areas of the borough including several for Raynes Park.  

One of these is site RP3 (page 158) named as Burlington Road -Tesco. The map provided (which is intended to show the area potentially suitable for development) shows the ENTIRE Tesco site, store, car parking, petrol station, redundant offices in the NE corner: all 5.2 hectares of it.  However, the proposals from Redrow relate only to a quarter of the site alongside Burlington Road.  

On the face of it, there is an anomaly here. The Council preference appears to be redevelopment of the whole of the site. but the proposals from Redrow - so far – are for only a part of it.  

Greater London Authority - Office of the Mayor 

We should just mention that because of the large number of housing units involved, the Planning Application - when it is submitted - will have to be considered by the Mayor of London in the first instance. The Mayor and his planning staff have the option either to a) approve or refuse the application or b) leave the determination process entirely to Merton Council. This added layer can sometimes hold up the process of considering the application.  

The Local Press 

 It is possible - but not certain - that by early January a Planning Application will have been submitted. At that stage there is a strong chance Redrow will seek some publicity in the local press, quite apart from a notice in a local newspaper, under a heading, such as, “Merton Council Town and Country Planning Act.”  Once the application has been formally submitted to Merton’s Planners, the Association, and most importantly, individual members of the community can make their comments to the Planning Officers and Ward Councillors regarding these proposals.  

DAVID FREEMAN, December 2018

 

Rainbow Ind Est - June 2018

Members may recall that a few years ago Workspace 12 Ltd. the owners of the greater part of the Rainbow site – which sits just to the south of Raynes Park Station – submitted two planning applications. 

The first of these 14/P4287 was for the demolition of the existing industrial buildings and the construction of more than 200 flats and 9 terraced houses.  

The other application, 14/P4288, was to provide a so-called ‘Kiss and Ride’ facility, incorporating a roundabout, near the entrance.   In simple words, this is an arrangement for cars to come off Approach Road and either drop off or collect people from the station.  It was never intended to provide actual parking spaces within the entrance, only a very short-term waiting bay. 

Given that Rainbow has been in industrial use for some decades, it is almost certain that there will be some – quite possibly quite a lot – of contamination in the soil.   Consequently, approval of the first application was accompanied by two important Conditions amongst quite a long list of others. 

These were, in short, to investigate the degree of contamination and submit an ‘action plan’ for dealing with this problem. 

Conditions

I should explain that Conditions, which in the main are of two types, are normally attached to large applications in order either to take whatever action is required to bring the ‘application site’ up to a condition suitable for development (highly relevant in this case), or to ‘mitigate’ (reduce the severity) of the downside consequences of the new development.  For example, if a housing development resulted in the total loss of a piece of land (whether open space or whatever) which had been in regular use as a play area for local children, there would probably be a Condition which required the developer to provide a suitable replacement within the new housing scheme. 

Rolfe Judd, the Agent acting for Workspace has submitted an application 18/P0997 with a proposed ‘Outline Remediation Strategy’ for dealing with the contamination issue.  In the main, this appears to be reports prepared by two specialist companies (Cundalls and Entec UK Ltd.) in November 2016.  To be frank, this is hardly a leap forward to redevelopment of this site, but it is a start.   Merton Council’s Planning Department will consider whether they can ‘Discharge’ Conditions 13 and 14, meaning whether the requirements of the Condition have been adequately satisfied. 

David Freeman

Housing and Planning Guidance

We draw attention to the speech by the Prime Minister on 6th March regarding the “housing crises” and the provision of “affordable “housing. The Government is concerned about both the shortage and cost of housing. It appears that developers are permitted to aim for a “suitable return “(i.e. profit) of 20% but often claim that they cannot achieve this AND at the same time deliver the proportion of social subsidised housing - either for sale or rent - which Councils want. 

The Government is suggesting that the ‘viability assessment ‘(through which developers can submit that they can only achieve a 20% profit on a scheme by reducing the proportion of social housing required by Councils) should be made public except in exceptional circumstances. Also, there is a proposal to urge developers to aim for a profit margin of about 6% when building social housing with the aim that this would guarantee an ‘end-sale ‘at a known value. It appears that the Government is keen to increase housing supply by encouraging developers to build more blocks of flats and convert and build on top of existing shops and offices provided that the final scheme is not higher than buildings in the immediate vicinity. In short, to build upwards. 

The ‘permitted development ‘provisions (which originated in 2013 and currently extend to 2019) may also be amended to permit ‘upwards ‘extensions provided the extension is “consistent with the prevailing height and form of neighbouring properties”. 

The Mayor of London (the Greater London Authority) is currently consulting on revisions to the London Plan (the GLA Planning Guidance document). One of the recommendations is that London Councils should seek an “affordable” housing contribution of at least 35% but for large schemes, e.g. on former industrial sites, they should aim for a 50% contribution. Such a high figure would probably meet with strong opposition by developers who would argue that they could not make a reasonable profit AND provide half the housing for ‘social’ needs. 

David Freeman - May 2018

 

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