We wrote to ask Sarah Olney MP to object to the revised scheme. She has now written to the Mayor with her objections. Thank you to our MP for her support and for standing up for her constituents. Her reply to MBCG is here…
I am writing to let you know that I have just written to the Mayor of London, Sadiq Khan, with my objections to the revised planning application for the Former Stag Brewery.
Under the revised plans, the developer envisages expanding the development from 813 residential units to 1,250, increasing the square footage of flexible-use space and office space and raising the heights of most buildings, with ten storeys now the highest level. By expanding the height, scale and mass of the proposed development, I consider this application breaches the National Planning Policy Framework (NPPF), The London Plan and Richmond Council’s Local Plan and have explained how this is so to the Mayor and his planning officers as follows:
1. Section 12 of the NPPF, Achieving Well-Designed Places. This states “Permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions, taking into account any local design standards or style guides in plans or supplementary planning documents.” The proposed new heights for buildings are significantly higher than those recommended in the Council’s Local Plan Supplementary Planning Document/Planning Brief of July 2011, which states “New buildings should be less than the height of the Former (eight-storey) Maltings Building”. The developer has ignored this recommendation.
In addition, the application does not meet the goals of Section 12 of the NPPF, because it is neither sympathetic to Mortlake’s local character and history, nor visually attractive, and introduces central London levels of density, which is incongruous to the area.
2. Section 16 of the NPPF, Conserving and Enhancing the Historic Environment. Most buildings in the surrounding area are about two storeys, so the greater height of the proposed development’s structures will be overbearing, overwhelming and visually intrusive, more appropriate to an urban setting than a suburban district, and potentially harmful to the neighbouring Mortlake and Mortlake Conservation Areas, which is contrary to paragraphs 195 and 196 of Section 16 of the NPPF that seek to protect designated heritage assets.
Equally, Section 16 of the NPPF seeks to protect non-designated heritage assets. In paragraph 197, it emphasises the importance balancing a development’s benefits with its potential harmful effects on them. Owing to the excessive mass, height and scale of the development, it will have a detrimental impact on non-designated heritage assets in the same way as it does on the designated heritage assets mentioned above.
In addition, the application fails Section 16 of the NPPF, because it will not make a positive contribution to the area’s character, contrary to the stipulations of paragraph 192.
3. Section 9 of the NPPF, Promoting Sustainable Transport. Paragraph 109 states a “Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe”. Owing to the large growth in local population and road traffic resulting from the new development, there are serious health and safety concerns at two specific locations: Sheen Lane level crossing and the junction at Chalkers Corner. In addition, there is the application’s detrimental impact on the road network overall.
First, the Sheen Lane level crossing is already busy with waiting pedestrians, vehicles and cyclists at rush hour times, and even outside of those times, so it is not clear how more people waiting at the crossing for the gates to go up could be managed safely. Potential conflict between pedestrians, cyclists and vehicles will be high. I understand Network Rail has classified this crossing as 2 on a scale of 1 being highly hazardous and 13 being low. No significant mitigation can be made, because Sheen Lane level crossing is under the control of Network Rail and cannot be removed or have its waiting times altered. In addition, I am concerned that the station platforms will become significantly busier, with the safety implications that implies. Proposed Section 106 mitigation works appear to be insubstantial.
Second, Chalkers Corner would become a considerably worse choke point for vehicles, pedestrians and cyclists. However, the developer’s original proposal to widen the road, which was rejected by Richmond Council in January, is not sustainable. Widening the road will bring a polluted, busy thoroughfare closer to people’s homes, which runs contrary to the ambitions of the Mayor of London’s Healthy Streets initiative. Also, no firm assurances are available that the proposed semi-mature replacement trees outside Chertsey Court will remove carbon from the air to the same degree as the existing mature trees and that they’ll survive being planted there.
Third, the increased volume of vehicles on the roads arising from the development and the subsequent cumulative impacts on the road network would be severe. The developer envisages creating car parking spaces for 493 vehicles. These additional vehicles will add considerably to congested traffic conditions in the surrounding area, as will visiting vehicles.
4. Policy SI 1 of The London Plan, Improving Air Quality. This states “To tackle poor air quality, protect health and meet legal obligations…development proposals should not: (a) lead to further deterioration of existing poor air quality”. The developer justifies their proposals for road widening at Chalkers Corner on the basis that there will be more traffic as a result of the development, so surely this is an admission that the proposals fail this policy, because more traffic will result in more air pollution.
Also, during the construction phase, the Thames ought to be used for transporting waste and materials to and from the site, rather than using roads, so as not to worsen air pollution and traffic congestion further. This has become especially important in light of the ongoing problems with Hammersmith Bridge, where a final date for its final repair remains uncertain. If it is considered impossible to use the river in any meaningful way during the construction phase, then this would be an additional reason to refuse the application on the basis that it breaches The London Plan policies Policy SI 1, Improving Air Quality, and NPPF Section 9, Promoting Sustainable Transport, because not only does it not achieve either of those two goals, it significantly undermines them.
According to the NPPF, permission should be refused if the adverse impacts of a proposed development would ‘significantly and demonstrably’ outweigh its benefits. In this instance, the harm identified above clearly outweighs the benefits, so I have asked Mayor Khan to refuse this application.
I shall keep residents updated on this application’s progress.
Yours sincerely,
Sarah Olney
MP for Richmond Park
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