Local developments

208-212 Burlington Road, 22/P3479

January 2023   There is a new planning application, 22/P3479, that has been submitted to build a block of flats on the site of the car service and repair premises in Burlington Road, near Shannon Corner. It is very similar to the previous application made in 2020, albeit this time for 6 storeys high, rather than the previous seven. Our Association has submitted an objection, as follows:

Application reference number: 22/P3479

My name: Jerry Cuthbert on behalf of the Raynes Park and West Barnes Residents’ Association (RPWBRA)

RPWBRA address:  Residents’ Pavilion, 129 Grand Drive, SW20 9LY

Planning application description: 208 - 212 Burlington Road New Malden KT3 4NP

Demolition of existing buildings and construction of part four and part six storey building to create 16 new homes with ground floor commercial unit (use class e), together with parking, refuse storage, landscaping and associated works.

Our comments:

On behalf of the Committee of Raynes Park and West Barnes Residents Association (RPWBRA), I submit this OBJECTION to the above Planning application. 


At present, the Application Site is an Auto Repair and MOT facility, set back from the Burlington Road frontage. All the buildings on site would be demolished. 

The basic scheme is to construct a block of flats, stepping from four up to six storeys in height, with a commercial unit, together with interior car parking and other utility spaces at ground floor level.  The location is described by Merton Council as a “scattered employment site” and is mainly a mix of light industrial and some retail use. Whatever the need for more homes, the application site is not one which could be deemed desirable for residential development. 

The southern end of Burlington Road is NOT a normal residential area. A new six story building would hardly fit the local scene which is mainly of 2 or 3 storeys. The location is well known to have very poor air quality, with heavy traffic crawling along, often queuing all the way to the level crossing at West Barnes Lane. Also, the site is in a Flood Zone and Shannon Corner nearby suffers from flash flooding. 

The location is not well served by public transport and the two railway stations are well beyond convenient walking distance. 

The area is supposed to be an employment location. Whilst the applicant has incorporated commercial space at ground floor level, it is not clear what this might be. We observe that, with the decline of the high street, there are many similar spaces in the Merton that are unoccupied. It is highly likely therefore that current employment numbers would be retained. 

Additionally, there is a large electricity Sub Station next-door and the A3, with its noise and air pollution is close by. 

Taking into consideration all the above we object to the proposals based on conflict with the relevant Planning Guidance as quoted.

Merton Sites and Policies Plan, July 2014 (SPP) and

Merton LDF Core Planning Strategy July 2011 (CPS) 


The building would fail to relate positively and appropriately to the scale, density, proportions and height to development in the nearby area and would fail to protect nearby resident (in particular, in Barnard Gardens) from visual intrusion in conflict with Policies DM D 1 and DM D 2

SPP and Policy 14 CPS. 

This is illustrated in the Applicant’s Design and Access Statement, on pages 50 and 51. 

Additionally, some nearby buildings will suffer significant loss of daylight. In particular, the Applicant’s Daylight Report shows that 214 Burlington Road would suffer average loss of 22% in Vertical Sky Component (VSC) and, similarly, 32 Barnard Gardens a 10% loss. (Applicant’s Daylight Report, page 16) 


The application site is within the fluvial flood zone and therefore at risk of flooding. The whole of the area around Shannon Corner is one of the lowest points of West Barnes Ward in terms of height above sea level. Shannon Corner suffered flash flooding as recently as 25 July 2021. 

As a scheme for residential use, under the Planning Guidance regulations, there is a requirement for the applicant to apply a Sequential Test (to find an alternative site NOT in a flood zone) There is no evidence of this having been done. 

We submit that the site is clearly unsuitable for housing development and, consequently, is in conflict with Policy CS 16 CPS and Policy DM F   SPP. 


In terms of land use designation, the site is classified as a Scattered Employment Location.  The applicant has suggested that the ground floor of the block would be a commercial unit. However, there is no evidence of what type of shop this would be or whether (as seems very probable) employment numbers would be protected let alone increased. 

We submit that the proposal  would conflict with Policy DM E 3 SPP.  


The site is not well served by the local bus network and is beyond reasonable walking distance of both Raynes Park and Motspur Park Railway Stations. In consequence the site is deemed as having a low Public Transport Accessibility Level (PTAL) rating of between 2 and 3, on a scale from 1 the poorest to 6 b at the best. 

We submit that the scheme would be in conflict with Policy DM D 2 SPP. 


The London Borough of Merton has declared a climate change emergency and has published its Climate Strategy and Action Plan. It is therefore very disappointing to note that the applicant is unable to come up with a carbon neutral design. We note that the applicant proposes 30-year carbon emissions totalling 342 tonnes of CO2. This it seeks to offset by means of a £35,302 payment, in recognition of its failure to achieve a carbon neutral design. 


In the light of earlier applications in the area it has been clearly established that the application site has very poor air quality. This arises from the heavy traffic on the A3, around Shannon Corner and along Burlington Road. We submit that this is not a suitable location for families to live and the proposals conflict with the broad aims of Policy DM D 2 of the Sites and Policies Plan. 


This policy states that “All development s need to be designed in order to respect, reinforce and enhance the local character of  the area in which it is located. 

We submit this application fails this test. 

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

Jerry Cuthbert, Committee Member,

On behalf of Raynes Park and West Barnes Residents’ Association



Join us on:


Share this page: