Local developments

RPWBRA Comments to Merton - Motspur Park Gas Holders Planning Application

Application No: 25/P2859

My name and address:

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

129 Grand Drive,

London SW20 9LY

Application:

Demolition of existing gasholders and associated above ground structures and buildings. Phased redevelopment of site to provide 8 to 16 storey 5nos blocks with 586 residential units and ancillary residential facilities. etc.

Comments:

1, Introduction

1.1 We note that this planning application is for a site principally located in the Royal Borough of Kingston upon Thames (RBK). However, the northern of its existing two access points to the public road network in located in the London Borough of Merton (Merton). Additionally, the Applicant proposes opening a new pedestrian/cycle access from the application site to the end of Marina Avenue, which is in Merton.

1.2 The application is for 5 blocks of flats, up to 16 storeys high. Whilst these tall buildings would be located in RBK, their very proximity to the boundary with Merton, obviously means they would have a significant visual impact on Merton. The application site is also within an area of Metropolitan Open Land, which extends across the boundary between RBK and Merton.

1.3 We, the Raynes Park and West Barnes Residents’ Association (RPWBRA), have already submitted an objection to this application to RBK.

1.4 The following comments, therefore, focus on the adverse impacts that this Application would have on Merton:

· Conflict with Tall Buildings Policies

· Traffic & Highways Concerns

· Road Safety and Construction Traffic

· Conflict with Secured by Design – Marina Avenue

· Damage to Metropolitan Open Land

· Architectural Conflict with Neighbourhood Character

· Adverse Impact on Nature Conservation

· Adverse Impact on The Sir Joseph Hood Memorial Playing Fields

2. Conflict with Tall Buildings Policies

2.1 The Application Site is not located within those areas which are nominated within RBK’s Tall Building Policy, as being suitable for tall buildings. Due the site’s close proximity to Merton, and consequent visual impact, we consider that the Applicant should also comply with Merton’s Policy D 12.6 “Tall Buildings”. In particular, Section 3.b requires that “massing, bulk and height are appropriately sized” and ”demonstrate they take into account local character”.

2.2 The Applicant claims its proposed massing is designed tocreate a sense of openness within the development. However, the Applicant’s proposal to cram 586 dwellings onto the site results in the exact opposite to a “sense of openness”. In reality, the proposed massing is located in the middle of a large residential area consisting of 2 or 3 storey suburban “between-the-wars” houses.

2.3 Also, the Applicant has chosen to position the 5 blocks of flats such that the tallest (16 storeys) is located very close to the existing streets in the “KT3” (Motspur Park) area of Merton, i.e. Marina Avenue, Station Road and West Barnes Lane. It would thus be overbearing and loom over these nearby streets and homes.

2.4 The Application is also in conflict with the National Planning Policy Framework. This requires that developments will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development and are visually attractive, as a result of good architecture, layout and appropriate and effective landscaping. We consider that the Applicant’s proposals fail all these three tests.

3 Traffic & Highways Concerns

3.1 We consider that the Applicant’s traffic generation studies will not reflect the reality that will be faced by the occupants of the development.

3.2 The Application Site has a very low Public Transport Accessibility Level (PTAL) of between “Zero” and “1b”. The Applicant’s traffic analysis is flawed, as it has used as a basis of its traffic assessment, data derived from comparison developments with much higher PTAL scores.

3.3 Motspur Park is not an area that provides significant employment or services. Therefore, the residents from the proposed development will need to travel for work and to access schools, leisure, health and other services.

3.4 Despite the Applicant’s endeavours to limit the number of parking spaces, it is inevitable that, with such a low PTAL Score (Zero to 1b), the occupants of the proposed development will need to have daily access to private transport.

3.5 The proposed development is in conflict with the London Plan (Policy T6 Residential Car parking). This states that in town centres, which generally have good access to a range of services within walking distance, car-free lifestyles are a realistic option for many people living there. However, for sites with an extremely low PTAL score, (e.g. this Application Site), the Policy allows up to 1.5 parking spaces per home for new developments in PTAL 0-1 zones in outer London.

This Application thus ignores this Policy.

3.6 The Applicant’s suggestion that by only providing 86 car-parking spaces for 586 new homes will somehow promote the use of public transport, walking or cycling, at this location is plainly ludicrous. Somehow, the new residents will be forced to find somewhere to park their cars and work vehicles. This will affect neighbouring streets, not only in Kingston, but also in Merton.

4. Road Safety and Construction Traffic

4.1 The Applicant proposes using the existing vehicular access from West Barnes Lane for in-bound construction traffic. This is only a few metres away from the level-crossing gates at Motspur Park. In order to avoid the dangers of turning traffic causing queues across the level-crossing, the Applicant proposes to route all in-bound construction traffic from the north, along West Barnes Lane (i.e. using a left turn only, to access the site).

4.2 However, due to width restrictions in the West Barnes area, this proposed route would have to approach the site from the A3, via the following route:

· Exit the A3 at Shannon Corner,

· Turn northeast along Burlington Road (540 m),

· Turn southeast to join West Barnes Lane, across the level-crossing

· Continue along West Barnes Lane to Motspur Park, turning southwest at the junction with Crossway. (1.2 km)

4.3 This route passes close to two schools, Sacred Heart Primary School and Blossom House School, and passes through residential streets. Therefore, in the event that the Application were approved by RBK, restrictions on the hours of access for the site (both for removal of the gasholders and for construction) should be imposed for reasons of public safety and tranquillity.

5. The Proposals conflict with Secured by Design – Marina Avenue

5.1 The Applicant proposes to open the end of Marina Avenue to allow pedestrian and cycle access to Marina Avenue and adjoining residential streets. Marina Avenue is an existing cul-de-sac, with no access (pedestrian or otherwise) from its far end. This proposal is in conflict with the design principles recommended by “Secured by Design” (SBD). This is a UK police initiative that aims to reduce crime by improving the security of buildings and their surroundings, through design principles and security standards.

5.2 Section 8 of the SBD Residential (Homes) Guide 2025, states that the security benefit of a cul-de-sac can be compromised if it backs onto (inter alia) railway lines and long footpaths. This is an exact description of the proposed link to Marina Avenue.

5.3 Additionally, the Guide states that cul-de-sacs that connect footpaths to other parts of a development experience the higher levels of crime when compared to crime levels within a cul-de-sac (i.e. 110% higher) and therefore should be avoided.

5.4 This is thus irrefutable evidence that the Applicant’s proposal to open up access into Marina Avenue will probably lead to an increase in crime, which must be avoided.

6. Damage to Metropolitan Open Land

6.1 The Application Site is within of an area of designated Metropolitan Open Land (MOL), which is part of an almost contiguous area of 300 acres. This large single area of MOL extends into the boundaries of three boroughs, Kingston, Merton and Sutton. It is one single area, apart from the narrow space taken by the railway lines.

6.2 The London Plan Policy G3 states that any alterations to the boundary of MOL should be undertaken through the Local Plan process, in consultation with the Mayor and adjoining boroughs. MOL boundaries should only be changed in exceptional circumstances.

6.3 This is further enforced by Merton’s policy O 15.2, which places a high value on green infrastructure and strives to protect and enhance Metropolitan Open Land. Clearly, this Application conflicts with these policies, as it would destroy MOL. Consequently, it would also degrade the openness and environmental value of the wider Metropolitan Open Land, including that part which is within Merton.

7. Architectural Conflict with Neighbourhood Character

7.1 Again, whilst the Application Site is located in RBK, it is within an extensive area of 2 or 3 storey suburban mid-twentieth century houses. It would be highly visible from within this part of Merton and we therefore aver that the Application should comply with Merton’s Policy D 12.2 “Urban Design”.

7.2 This Policy requires that proposals should (inter alia):

· Have an appropriate street level presence and roofscape,

· Ensure that scale, height, mass, bulk and form is appropriate and assessed for visual impact, including long distance views,

· Consider the enhancement of views and settings.

7.3 We therefore aver that the applicant’s proposals, being in direct conflict with the existing local architectural character, are in breach of Policy D 12.2.

8. Adverse Impact on Nature Conservation

8.1 Nature’s reach is not constrained by local government boundaries and neither do wild fauna and flora confine themselves to a particular borough. Therefore, development proposals such as this, so close to Merton’s boundary, must have an impact on Merton’s biodiversity and residents’ access to nature.

8.2 We also aver that the Application is in conflict with the London Plan Policy G6, which mandates that biodiversity impacts be addressed from the outset and that priority species and habitats be protected and enhanced.

8.3 Currently, the site supports a rich and interconnected ecological network, including common and soprano pipistrelle bats, slow worms and numerous breeding bird species. The proposed development would lead to a degradation of the various habitats that support these species.

8.4 Merton’s Policy O 15.3 “Biodiversity and Access to Nature”, Section 1e, requires developments to follow the following mitigation hierarchy:

· Avoid damaging ecological features

· Minimise spatial impact and mitigate it.

· Delivery of off-site compensation of better biodiversity

8.5 We therefore aver that the Application does not comply with this requirement, due to its inevitable impact on biodiversity.

9 Adverse Impact on The Sir Joseph Hood Memorial Playing Fields

9.1 The London Plan and local planning guidance require that new developments:

· Respect the scale, massing, and character of their surroundings

· Avoid visual dominance or townscape disruption

· Provide accurate and honest visual representations to inform decision-making

9.2 We consider the Applicant’s assessments of visual impact of the proposed development as being misleading for the following reasons:

· Key viewpoints are obstructed by trees, bushes, or wide-angle distortion, making the towers appear hidden or more distant than as seen by the human eye.

· Images are taken from distant viewpoints, failing to show how overbearing the development will be.

· The applicant has conveniently used summer-time imagery, when trees are in full leaf, to mask the true visual impact of the towers.

9.3 In reality, the proposed development will loom over the Sir Joseph Hood Memorial Playing Field, damaging the open aspect of the public park, which is enjoyed by the residents in Old Malden and Motspur Park and visitors from further afield.

10. Conclusion

For the above reasons the Raynes Park and West Barnes Residents’ Association urges the Planning Committee of the London Borough of Merton to refuse this application.