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Raynes Park and West Barnes Residents' Association
Serving the community since 1928

Planning Notes, June 2002

London Electricity Sportsground

As indicated in the April "Guide", revised plans for this site have now been submitted by Barratt Homes Ltd. The Planning Application number remains as before 00/P 2410. The plans are now available for the public to study at Merton Civic Centre, and should also be available in Morden Library and possibly also, unusually, in Raynes Park Library.

The main change is that the development, though still in the form of one- and two-bedroomed flats, would be in three blocks (instead of five), though largely occupying the same area of the site as before. However, the siting of the three blocks appears to be slightly different, with the centre block, shaped like an E on its side, taking up the major part of the development. The position of the three blocks indicates that the buildings would be very close to each other. The result is a situation in which, viewed from the remaining open space or from Blenheim Close, the impression would be a horrible example of "ribbon" development. In technical terms, the permeability (the see-through aspect) of the development would be close to negligible.

As an attempt to mitigate the adverse visual impact of the development, there is a proposal for a considerable amount of tree-planting, first in two clusters in the north-west and south-west corners of the LESSA field (in fact, well away from the new build), and secondly in an almost continuous line along the northern perimeter of the field and again along the front perimeter of the development on both sides of what would be the main access road.

Contrary to what I had hoped, the development would still be at four levels (ground floor and three storeys), but the number of flats at the top level seems to have been substantially reduced, and a number of the flats closest to Blenheim Close would be ground floor and first floor only. As far as one can judge from the drawings, the tiered effect created by different heights could lessen the intrusive visual impact, but the fact remains that the scale and mass of the development would be oppressive wherever you stood. Viewed from the properties in Greenway and Westway, the impression would be of a continuous line of building from west to east.

It is clear that the aim is to crowd in as many flats as possible on the part of the LESSA site above the 17m contour which is just outside the floodplain line. Indeed, it appears that the re-siting of the large centre block would bring the new build closer to the floodplain boundary. Car parking would be along the front of the buildings (the southern side) and, it would seem, either side of the access road. The centre of the existing field, which would become open park, would be ringed by a new pedestrian/cycle path with proposed access into Greenway and Westway alongside the existing electricity sub-stations.

Our objections to the revised plans remain the same, and just as valid as before. Let me remind you of the main points :

  1. The whole of the LESSA site is designated by Merton Council, under the emerging Unitary Development Plan (Policy L.6), as Urban Green Space. The stated policy is "to ensure the protection and retention" of such space, and there is no provision to permit even partial development on such land. There should be no building on LESSA other than essential structures in support of outdoor sport or recreation.
  2. Under Government guidance (Policy Planning Guidance Note 3, Housing), the Council is expected to permit housing development on "previously used land" before such development on greenfield sites. In technical terms, they are expected to apply a "sequential" test. In simple language this comes down to "Brownfield first, greenfield last". There are numerous brownfield type sites listed in the Unitary Development Plan (UDP) which are allocated for housing and other uses and which could and should be developed before LESSA is even considered for this type of use. The Council appears to be willing to ride roughshod over this policy guidance.
  3. The Council also appears to be treating LESSA as what is termed a "windfall" site, and they therefore conclude that it is not subject to the "sequential" test. This conclusion is incorrect. LESSA is an "unallocated greenfield site", and as such should not be used for housing, even partially, until all the available "brownfield" sites have been used and exhausted. That is what the "sequential" test means. This application is in clear conflict with central government guidance.
  4. There is further government guidance in the form of another Note, PPG17 - "Sport, Open Space and Recreation". This is still a consultation document, but the Council has accepted that it can be "material consideration" in dealing with planning applications. The guidance states that existing open space should not be developed for housing unless an assessment has been made that the land is surplus to requirements for sport or recreation. There is no evidence that such an assessment has been made, and so far the Council has failed to answer questions on this point (and, I might add, many others).
  5. You may recall that faced with objections from the Environment Agency, the applicant revised their original plans last October and restricted the proposed development to that part of the LESSA field which is just outside the floodplain of the Beverley Brook. The Agency then withdrew their objection to the revised plans, and the Council concluded that the issue of flood risk, either on site or "downstream", needed little if any further consideration. We believe this approach, if not irresponsible, leaves a lot to be desired. Government guidance on the subject of housing development in a floodplain area, or within the catchment of a river system which might be the cause of flooding, refers to a "precautionary principle" and yet another "sequential" test (similar in principle to PPG3). I am sorry about all the technical language, but the basis of the policy - which is no more than common sense - is that Local Planning Authorities should aim to permit housing development firstly (i.e. in sequence) in areas well away from the identified floodplain, and only allow housing in such areas where there are no alternative sites available. The fact that the Council has continued to consider a revised proposal since last October suggests that they have no intention of taking a precautionary approach in this instance, remembering that the proposed development is immediately adjacent to the boundary of the floodplain as currently drawn. Most of the sites allocated for housing development in the UDP are, by contrast, well away from the two floodplain areas in the Borough. I ask you, is this a responsible attitude ? I did ask the Council, but answer came there none.

As if all the above is not enough to cause concern, there are other issues which the Council seem unwilling to consider. These include traffic density and the twice-daily "gridlock" in Grand Drive, which could only get worse with probably well over 100 cars on the site. Residents living around the field will also be much concerned about security, given that a large part of the field would become public open space. The planning application itself was silent on the questions of security.

We have been led to believe that, with these revised plans, there would be a further round of consultation, which should mean that if you had a letter from the Council informing you about the application, you should now receive another letter. This provides a further opportunity to look at the revised scheme and make fresh objections if you wish. There are ample grounds on which to do so.

Raynes Park Library

This is back on the agenda again, but don't get too excited - at least, not yet. The selected developer "pulled" their planning application last September, for reasons which have never been made entirely clear. We learn that the Council recently went ahead with a re-tendering exercise, with a closing date of 26 April, and I can confirm that Michael Shanly Homes have submitted a new offer. We have no further details at present, and bear in mind this could be another long haul. We will keep in touch with our friends in the Apostles Residents' Association, who "lead" on this subject. We are pleased that the Council has re-opened the tendering process, and hope for better results this time round. There were many people who were unhappy last time that the area allocated for the library and the meeting room were not much larger than at present. Let us see what the new bids produce.

175 Burlington Road - Proposed New B & Q

I mentioned briefly in the April "Guide" that a planning application has been submitted to develop a new store on this site. The Association has made an objection to this application, firstly on the grounds that the site is designated for industrial use, not retail, and secondly that the new building could result in loss of privacy and create visual intrusion to the residents in Rookwood Avenue because of the proposed height and scale of the new structure.

This might be mitigated, to some extent, by a proposal to establish a "woodland band" between Rookwood Gardens and the proposed garden centre. However, it is unclear just how effective this would be. It would also take many years before this screen of trees achieved its objective.

We also expressed concern about the proposed large underground car park, remembering that the site is within the floodplain of the Beverley Brook. Government guidance on development in a floodplain area, other than for residential purposes, is lacking in clarity, but any development or re-development in such an area clearly needs to be treated with caution. We have urged the Council to take advice from the Environment Agency regarding this aspect of the scheme. It may be quite a while before we see any movement on this application.

129 Seaforth Avenue (Jack Riley House)

Two planning applications were submitted in March on the site of this unusual house at the junction of Seaforth and Adela Avenues. The first was to convert the ground floor office and first floor flat into a guest house/hotel, with a new rear extension to provide most of the bedroom accommodation, and the second to convert two more flats.

The Association opposed both these applications for a variety of reasons, not least that the extensions would have been a massive overdevelopment of the site and were likely to impact on the privacy and amenity of neighbouring properties. Both applications were seeking a change of use, because the ground floor is designated for office use (though I believe it is currently unused). Many local residents living around the area made objections to the Council in respect of both applications. There was a lot of concern about the unsuitability of the location as a hotel in the midst of a residential area which already has difficult parking problems. We learn that both applications have been refused by Merton Council.

Raynes Park "Interchange" proposals

The "improvements" around Raynes Park station were due to have been completed by the end of March, but have continued for several weeks thereafter. Some of the changes do not seem to be quote what we had expected. We will have to see how all the changes work out. It looks as though the re-located bus stop has helped to free the flow of westbound traffic through the centre, at least. At the moment, I am left in some doubt as to how cyclists and pedestrians are supposed to conveniently avoid each other at certain points of the system. May I once again make a plea to cyclists using the Cattle Arch to exercise care and consideration towards those on foot.

David J. Freeman
Planning Officer, RP&WBRA