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

Letter of objection to the proposed LESSA development

Copy of a letter sent to Merton Council's Director of Environmental Services by the Residents' Association in January 2001

Richard Rawes Esq.
Director of Environmental Services
London Borough of Merton
Civic Centre
London Road
MORDEN, Surrey

14th January 2001

Dear Sir,

Re : Planning Application Nos. 00/P2410 and 00/P2413
Redevelopment of LESSA Sports Ground, SW20

The Raynes Park and West Barnes Residents' Association strongly objects to the above applications in all respects for the reasons given below.

Firstly, and most importantly:

  1. the proposal to redevelop a major part of the site will result in the loss of a large area of Recreational Open Space, which is contrary to UDP Policy L8.
  2. The proposed development is either on or adjacent to the flood plain of the Pyl Brook. Such a residential development would expose new and existing residents within the flood plain area to the risk of flooding. We submit that the proposals would seriously contravene Policy PE6.

We set out below our detailed case objecting to these proposals. All references to UDP Policies relate to the 2nd Deposit Draft, dated October 2000.

Policy PE6 – Flooding

Policy PE6 states that "New Development….will not be permitted in the areas at risk from flooding where they would increase the risk of flooding within this area or elsewhere", or "reduce the capacity of the flood plain to store water". Although not included within the Policy – as recommended by the Environment Agency (EA), the Justification also adds developments that "increase the number of people or properties at risk from significant adverse effects of flooding should not normally be permitted".

The Proposals Map issued with the 1st Deposit Draft UDP (September 1999) shows the Beverley Brook flood plain as covering the SW corner of the site. However, the EA maps of this area show that much the greater part of the site is now within the flood plain. We believe that development to the extent envisaged would seriously violate policy PE 6, in that the housing, car parking and access roads would both impede the flow of water and reduce the capacity of the site to store water. This would result in increased run-off water from the site to the lower ground to the west and would, thereby, "increase the number of people or properties at risk" of flooding.

The residents of Westway, whose gardens face the site, have already experienced flooding, and in 1981, Westway itself was flooded and looked like a canal. We believe that if the development went ahead, the new houses on the flood plain would be at serious risk of flooding and that ALL the housing to the west of the development – already within the flood plain – would be exposed to much greater risks.

Given that in a relatively short time frame the flood plain boundary has extended across the major part of the site, it is very likely that within the next decade, the whole of the LESSA site will be within the flood plain area. Against a background of:

we believe that any residential development on this site would be extremely unwise in the short term, and potentially disastrous for many people in the longer term.

The House of Commons Select Committee on the Environment, recently taking evidence from the EA and DETR, recommended Government change the policy on development within flood plains to a presumption against such development. Moreover, the Committee recommended adoption of a sequential approach to selecting sites for development, particularly residential, under which all potential development sites would be categorised, ranging from high (flooding) risk to no risk. In giving evidence the DETR Minister said that Her Majesty's Government would adopt the sequential approach.

Under this policy most of the LESSA site would be classified as high risk and the remainder as medium risk. The conclusion - bearing in mind that there are many sites in the borough identified for housing that are well away from flood plains - must be that the LESSA site is entirely unsuitable for extensive development, particularly residential, not only for the potential new occupants, but also because of the increased risk to thousands of existing residents.

We would add that the EA flood plain map of the area is still based on the 'one flood in a hundred years' scenario. However, the risk factor measurement may be amended to the 'one in 200 years' risk. Under this regime it is probable that the whole of the LESSA site would fall within the Pyl Brook flood plain.

We urge that serious consideration be given to these views and the advice from the EA submitted in their letter to Mr. Duyile of 4th January 2001.

Policy L8 – Private recreational open space

As a privately owned site used exclusively for recreational purposes, LESSA falls within Policy L8 as well as Policy L6.

The intention of Policy L8 is that such Open Space should be protected and retained for recreational purposes. There is scope within the policy to permit development of "a small part of the site", however, it is clear that the prime purpose of such redevelopment should be that "sports and recreation facilities can best be retained and enhanced" and "that alternative provision of at least equivalent community value is made available". This Association submits that the loss of some 45% of the LESSA site would be a serious violation of this Policy, regardless of whatever alternative provision was said to be available. In considering possible redevelopment, full consideration is supposed to be given to several factors, not least the impact that "the loss of sports pitches would have on the Borough's position in providing strategically important outdoor sports facilities in SW London". The Justification points out that in Merton there is "an overall shortage of quality facilities" for modern players. It goes on to say "It is important to maintain existing facilities where possible". Merton has long had a role in providing outdoor sports pitches for Inner London Boroughs who are deficient in this area. The Policy is all the more important in view of the possible loss to the public of a substantial part of the nearby Prince George's Playing Fields. The loss of close to half of a Private Recreational Open Space is clearly contrary to Policy L8, whatever alternative provision might be available.

Policy ST12 – Housing provision

Policy ST12 states that housing opportunities will follow a sequential approach, i.e. there should be a presumption that previously developed sites should be used before green field sites. This development proposal is clearly contrary to the intentions of this Policy.

Policy ST20 – Natural environment

Policy ST20 states that "the Council will safeguard and enhance MOL, open spaces and sports pitches" etc. Implementation of this development proposal would be contrary to the intentions of Policy ST20.

Policy ST23 - Leisure and recreation, arts and culture

Policy ST23 states that Council "will seek to improve the quality and range of leisure, recreation and sports facilities…and will protect existing facilities". The Justification also points out that Merton has a strategic role in providing playing fields for people from the wider SW London area. The proposal from Barratts would run contrary to this Policy.

Policy HP1 – Housing target

Under Policy HP1, Merton has a housing target – taken from RPG3 – to provide some 5,000 new units between 1992 and 2006, representing an annual target of 333 Dwelling Units (DU) per annum. The Housing Strategy Paper (released with the Ex. Committee Agenda of 12th July 2000) recorded that, against this target, between 1992 and 1998 an average of 457 DU's per annum were completed. This is well in excess of the target figure. Policy HP1 also says, "there is no justification to require release of other land uses protected by other Plan policies". The development proposal is therefore wholly contrary to the UDP Policy intentions.

Policy HP4 – Land identified for housing and Schedule 1 site proposals

Policy HP4 identifies some 37 sites across the borough for housing and other uses, suggesting that there is ample land already available for residential development. In addition, the Housing Strategy Paper lists 30 sites for potential housing and mixed use to a total of some 75 acres. A large share of this land would be for housing. Also, as recorded elsewhere in the UDP, the majority of sites for housing come forward as 'windfalls'. There is clearly no priority need for housing development on the LESSA site.

Policy HP6 – Density of development

Policy HP6 sets the range of Habitable Rooms (HR) per hectare for residential development depending on several factors. Given "the scale and general character of the surrounding area" and the distance from "good public transport facilities" the site would be unsuitable for high-density development (Ref: Fig 3.1 of the UDP). This Association believes that a density of no more than 150 HR per hectare would be appropriate, if the site was otherwise suitable. The proposed density of 225 HR per Hectare contravenes Policy HP6.

Policy HN1 – Affordable housing

We understand the need for a proportion of new dwelling units across the borough to be provided as affordable housing, but this particular site is in an area of high and still rising house prices, both for sale and rental. We do not believe that Policy HN1 is a viable concept on this site and feel that affordable housing would be better secured where land and property prices are markedly lower. Moreover, if the site is developed, there is no doubt that substantial and expensive drainage and flood mitigation measures would be required, thus inflating the property prices and working against the aims of providing lower cost housing.

Policy HN2 – Provision of affordable housing from other sources

Policy HN2 offers scope to encourage affordable housing development on sites of less than 15 dwelling units. We feel that making use of such sites where the economics of the site are favourable would be a more practical method of achieving the target rate of 30% across the borough as a whole, rather than on every site over 15DU.

Policy BE22 – New buildings and extensions ; loss of privacy

Policy BE22 states that it "will require development to protect adjoining properties… from loss of privacy and from visual intrusion". From the layout plan of the proposed development, it is clear that the housing on the north and west of the site would conflict with this Policy.

Policy PE8 – Capacity of water systems

The Justification draws attention to the "limited capacity in existing sewers in Merton" and says "rates of surface water run-off from hard surfaces are increasing in London…as a result of built developments and an increase in land covered by hard surfaces". Paragraph 4.122 adds, "this has an impact on the capacity of the systems which ARE ALREADY UNDER STRESS and can therefore lead to AN INCREASE IN FLOOD RISK. Heavy rainfall on hard surfaces can also lead to localised flooding". We could hardly agree more! As noted by Policy PE8, these development proposals would intensify the risks, which are already there.

Policy L1 – Informal recreation

The main thrust of this policy is the Council's desire to encourage the opening up of private open land "for public access and informal recreation". The proposal to take almost half of the LESSA land out of use for recreational purposes would contravene this Policy.

Policy L6 - Urban green space

The LESSA site is listed under Schedule 2 of the 2nd Deposit UDP as Urban Green Space. The Policy states clearly that the Council "will seek to ensure the protection and retention" of such space and the Justification adds that the "Council is concerned that such space be protected regardless of ownership". Permitting development of a large part of this site would be wholly against the spirit of Policy L6.

Policy L9 – Open space deficiencies

This policy (see Fig. 4.2 of the 2nd Deposit UDP) highlights the fact that large areas of the borough, including much of the residential area surrounding LESSA, are deficient in terms of proximity to local recreation facilities. Policy L9 underlines the need to preserve and open up green space, not to use it for housing.

Policy L14 – Increasing participation in leisure and recreation activities

Policy L14 is to "encourage increased participation in leisure and recreation activities". Implementing the development proposals would, in overall terms, be contrary to this Policy.

Policy L15 – Outdoor sport and recreation

Part of the underlying aim of this Policy is to foster the pursuit of sports and games within the borough and the Justification points to the need "to maintain an adequate supply of playing pitch provision". These proposals would reduce both the playing pitch provision and the area available for informal games.

Policy LU2 – Public transport accessibility

Policy LU2 is to permit large-scale development only "at or near public transport hubs" as shown in Fig. 6.5. Barratts proposal is large scale and is well away from a town centre. It is an unsuitable location for a large residential development given the low level of public transport accessibility.

For all the reasons stated above, this Association believes that these two Planning Applications are ill founded and should be rejected. Above all, the matter of concern is the deeply worrying issue of the increased risk of flooding – both on the site itself – and to those already living nearby.

In the light of the known history of flooding in the area and the increased risk of flooding through climate change, and taking into account professional advice from the Environment Agency, this Association feels that there is an overwhelming case to reject these applications.

Yours faithfully,

Prof. G. Hunt