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
