You may be aware that Barratt Homes have now submitted to Merton Council a revised outline planning application for the LESSA site. Although this is an outline planning application, we should treat this as if it was a full planning application.
The new application provides for 98 flats (one- and two-bed) in five blocks of two, three and four storeys. The proposed development, with parking and access roads, would take up 2.7 acres out of a total area of 11 acres, about 25% of the site. The proposed build is located in the north-eastern section of the site by Blenheim Close and Grand Drive, lying just above the designated flood plain as defined by the Environment Agency (EA). Barratts say that some eight acres of the site would remain as "public open space", but no details are provided about ownership, upkeep or usage, etc.
The Residents' Association strongly objects to these proposals on a number of grounds, and will be submitting a formal letter of objection to this outline planning application. The outcome of this application may influence the future of the Royal and Sun Alliance sports field as well. Both sites remain under threat of development. WE STRONGLY URGE ALL RESIDENTS WHO SHARE OUR CONCERNS TO SUBMIT INDIVIDUAL OBJECTIONS TO THE COUNCIL.
Some of the main issues on which you may wish to base your own objection are outlined below.
The greater part of the site, about 75%, is within the Beverley Brook floodplain as defined by the EA. However, the revised application seeks to limit the new building, including parking and access roads, to the remainder of the site just above the designated floodplain. This does NOT mean that the application is acceptable in planning terms. Central Government guidance on this subject is contained mainly in three Planning Policy Guidance documents : PPG 25 – Development and Flood Risk, PPG 3 – Housing and PPG17 – Sport, Open Space and Recreation, as well as several policies in Merton's Unitary Development Plan (UDP), particularly Policy PE6 – Risk of Flooding and Policy L6 – Urban Green Space.
Under the guidance provided by PPG25 and UDP Policy PE6, Merton Council is expected to apply a precautionary principle to the issue of flood risk, and adopt a risk-based search sequence in considering sites for new development, in particular for housing, whereby new development should be directed away from areas at high risk of flooding to areas at lower risk. UDP Policy PE6 states that "New development will not be permitted in areas at risk from flooding where they would (a) increase the risk of flooding within this area or downstream, (b) reduce the capacity of the floodplain to store water", and continues "development that increases the risk of flooding or increases the number of people or properties at risk from significant adverse effects of flooding SHOULD NOT BE PERMITTED".
The proposed development would be sited immediately above the flood plain, which is an area defined by the EA as having the highest level of inland flooding risk. One of the biggest environmental threats in our area is that of flooding. Climate change is expected to significantly increase rainfall in the future, together with a greater frequency and severity of flooding. The proposed development would increase the risk of flooding to properties on the floodplain through the rapid run-off of rainfall from the new buildings and hard standings. The residents of Westway, Greenway, Blenheim Road, Blenheim Close, Brook Close, Linkway and Westway Close in particular could be exposed to a much greater degree of risk of flooding. Moreover, given the effects of climate change and the forecast of more extreme flood events by the EA, this greater risk could extend beyond these roads in the future, and well within the lifetime of the new buildings the floodplain could extend to the whole of the LESSA site. This could have serious consequences for residents, not only from flooding itself, but from the difficulty in securing insurance and in obtaining mortgages. The risk of flooding would be further increased by the new buildings, car parking and access roads having a significant adverse impact on reducing the capacity of the site to store water.
There can be no doubt that this proposal is in total conflict with Government guidance and Merton Council policy with regard to the avoidance of increasing flood risk. To allow the scheme to be approved would also be a flagrant breach of the precautionary principle and the requirement to apply the risk-based search sequence test. Due and proper application of the test would show that the whole of the LESSA site is inappropriate and unsuitable for housing development given that there are ample sites for housing in the Borough well away from the dangers of the floodplain. The EA has identified thousands of homes and other properties on the flood plain that are at risk of flooding, and that the Beverley Brook and its tributaries are unlikely to be able to cope with exceptional flows similar to those which have occurred in the past. This flood risk has been caused by excessive development over many years and by diverting water courses underground through lengthy culverts. The proposed development would increase flood risk even further. The only prudent and precautionary approach to this application is that IT SHOULD BE REJECTED OUTRIGHT.
Under the guidance covered by PPG3, Merton Council is required to adopt (as with PPG 25) a sequential approach to selecting sites for housing whereby previously developed land should be used first, well before greenfield sites. Council has identified sites for housing in Merton, including many brownfield sites, which are available for housing and other uses now, most of which are safely away from the floodplain. In support of this Government guidance, there are a string of policies in the Council's UDP which require the Council to protect and enhance open space for sport and recreation use and not to use it for housing. This proposal is in serious conflict with Government and Merton Council policy.
The guidance in the Government document PPG17 is particularly relevant to this application. Under this, the Council is expected to provide the strongest possible protection for open space that is, or has the potential to be, of value to the community, and to resist development which could diminish recreational provision. This Association strongly believes that the loss of a significant part of the LESSA site for housing, and the risks posed by the total uncertainty over the future of the rest of the site, would be a major breach of Government and Council policy.
The Council has identified LESSA as Urban Green Space. Policy L6 of the Second draft of the UDP dated October 2000 states that "The Council will seek to ensure the protection and retention of the Borough's resource of urban green space" and goes on to say "the Council is concerned that these be protected regardless of ownership". The proposed development would cover nearly a quarter of the LESSA site, and would therefore be in direct conflict with the stated policy.
Other issues of concern relate to the height of the proposed buildings of up to four storeys, which would be out of character in an area of predominately two-storey dwellings. The proposed density of the development significantly exceeds the guidelines set out in UDP Policy HP6.
The revised application refers to what would be the undeveloped part of LESSA as "public open space". There is no information about who would own and maintain the land, what it would be used for and by whom. This raises very important issues about security, such as a rising incidence of crime, vandalism and other anti-social behaviour, if most of the LESSA site were to become "public open space".
This revised application includes provision for no fewer than 112 parking spaces. Being realistic, there would probably be far more than this number of cars using the site. We believe this could have serious consequences for traffic congestion in Grand Drive, already bad enough, and also raises concerns about a further deterioration in air quality.
It would be worth drawing attention to one important point. Merton Council seem to consider each planning application in isolation of what has gone before. It is the CUMULATIVE IMPACT of development over the last 70 to 80 years which has intensified the flooding risk and caused flood damage. We have suffered from flooding already. WE MUST AVOID INCREASING FLOOD RISK BY RESISTING INAPPROPRIATE DEVELOPMENT AND FIGHT TO RETAIN AND ENHANCE ALL OF OUR LOCAL GREENFIELD SITES FOR THE BENEFIT OF GENERATIONS TO COME. A thought to ponder over – one brick in a puddle will hardly make the water move - but add brick after brick and see what happens!
Merton's Development Plan supports the need for sustainable development. This is "development which meets the needs of the present without compromising the ability of future generations to meet their own needs" (Bruntland Commission). Future generations will look upon us with contempt if we fail to heed this advice.
Against a background of flooding and the need to protect and enhance Urban Green Spaces, and considering the weight of planning evidence above, this Association believes this proposal is totally unsound and should be rejected outright.
Letters of objection should be headed:
Re: Outline Planning Application 00/P2410and sent by 12th November 2001, or as soon as possible, to : The Environmental Services Department
LESSA Sports Ground, Grand Drive
Residents' Association contact : Martin Mitchell