Reselton, the developer for the Former Stag Brewery site, has submitted further documents to the GLA which are now out for public consultation. Responses must be in by 8th March.
To recap on how we got to this point:
- February 2020: Richmond Council approved a scheme for 813 homes and for a secondary school (but turned down proposals to widen Chalker’s Corner)
- Summer 2020: the GLA ‘called in’ the scheme, took over as the planning authority and held discussions with the developer
- September 2020: the GLA consulted on the developer’s enlarged and amended scheme for 1250 homes and for a secondary school
Many concerns were raised in the autumn about the new enlarged scheme and its Transport Assessment including the facts that:
- the developer’s submissions did not take into account the Hammersmith Bridge closure
- the cumulative impact of other developments on the local road system was ignored and
- the proposed mitigation measures were not conclusive and instead involved a series of options which still included the full Chalker’s Corner junction works, works that had been denied planning permission in January 2020.
So, in an attempt to address those concerns, the GLA are now seeking your views on their response to the Autumn 2020 consultation and on the developer’s next set of transport proposals.
The latest documents are:
- Technical Note TN039- Implications of Hammersmith Bridge Closure
- New Highway Mitigation Plans showing options for the Lower Richmond Road and for Chalker’s Corner (Option1) – a widening of the left turn from Lower Richmond Road (LRR) into Chalker’s Corner (CC), and – (Option 2) – the left turn lane plus a bus lane along the end of the west bound LRR leading to CC, with the loss of 36 car parking spaces currently outside domestic properties.
- Technical Note TN041- VISSIM Modelling Summary
- Technical Note TN040- Consultation Response
These documents can be accessed on the GLA website using the following link: Former Stag Brewery public hearing I London City Hall
Take action now!
The MBCG have studied these documents and together with our specialist transport advisor have put together a detailed response which we will be submitting by the deadline. The summary of the key points is outlined below and we trust this is helpful in assisting your own personal representation response to the GLA’s consultations.
You can use our template email (link) to object to latest plans.
Emails should be sent to the GLA at the formerstagbrewery@london.gov.uk by 8th March.
Summary of MBCG’s view
We urge the GLA to reject these transport proposals and to go back to the drawing board to reduce the density of the development for the following reasons:
Wholly inadequate transport proposals given the increased density of the scheme: In the original scheme of 2019/20, the developer argued that major road works were needed at Chalker’s Corner; consultation respondents said then that the proposal would not deal in any way with the traffic impact of the scheme. The road works were rejected. Now, in 2021, we are being asked to accept an even smaller traffic mitigation proposal for a much bigger development that contains 40% (437) more residences; that makes absolutely no sense and is completely counter-intuitive.
Flawed assumptions: The assumptions about the traffic impact of the completed development are flawed and misleading. Some reduced residential parking on the development will not automatically result in fewer traffic movements into and out of the site. On the contrary the demand for deliveries and uber rides alone will add to traffic entering and exiting the site 24/7 and will be an obvious component of increased traffic in the surrounding area.
Permanent, slow crawling traffic on the Lower Richmond Road impacting child and adult health: This is the inevitable consequence of these proposals, with air quality and pollution deterioration and profound consequences on the lives of children living on the Lower Richmond Road and at Chertsey Court. The proposals take no account of these consequences.
Gross underestimate of current and future impact of Hammersmith Bridge closure: Existing traffic levels on the Lower Richmond Road and Chalker’s Corner are underestimated by the developer; the data is inadequate, flawed and misleading. It does not reflect the daily slow crawling traffic and long queues on the Lower Richmond Road or the congestion at Chalker’s Corner.
Unsubstantiated assumptions are made about the likelihood of repairs to Hammersmith Bridge being funded and the Bridge re-opened to buses and vehicles. Currently there is no funding, no repair plans and no clarity about the type of vehicle that will be able to use the Bridge in future.
Complete disregard for the impact on traffic of the Sheen Lane Mortlake Station Level Crossing: The mitigation proposals ignore the impact on traffic level build up and slow crawling traffic caused by closure of Mortlake Station Level Crossing up 48 minutes in every hour at peak times. The risks of crowds of pedestrians massing at the closed level crossing barriers are not treated seriously.
Vague and insufficient mitigations on traffic and parking expose existing residential streets to being overwhelmed by traffic, by rat-running; by vehicles trying to reach the development and by parking demands of development residents, visitors and suppliers.
In conclusion you may wish to highlight in your response to the GLA the following Policy D2 in the new London Plan, published by the Mayor at the end of 2020:
“Where additional required infrastructure cannot be delivered, the scale of the development should be considered to reflect the capacity of the current supporting infrastructure’’
This new enlarged scheme of 1250 units, associated commercial space, and super-sized new secondary school is simply too large and too dense given the immutable geographical river-side and railway constrained characteristics of the site, the compressed local transport infrastructure, and the character of the immediate sub-urban riverside environment. These new transport proposals do nothing meaningful to address the scale of future congestion and air pollution – indeed they only add to both. Therefore, we urge that proposals from the developer be rejected and the scale of the development re-sized to reflect the capacity of the current supporting infrastructure.
Detailed analysis of consultation documents
The MBCG have studied these documents and together with our specialist transport advisor have put together a detailed response based on the analysis below.
Implications of Hammersmith Bridge Closure TN039
The Technical Note states that presently, the total traffic increase through Chalker’s Corner, following the Bridge closure, is just 1.4% and 1.3% in the AM and PM peaks respectively. It also states that Transport for London’s ATP traffic counters on Chiswick Bridge show significantly higher figures of 3% to 6% respectively.
The Technical Note purports that traffic from the completed development predicted to use Hammersmith Bridge is minimal in both peak periods; that the new proposals accompanying this technical note for Chalker’s Corner in any case provide adequate mitigation for the fully constructed development; and that the Bridge is likely to be open before the development is fully operational if funding for repairs are agreed before May 2022.
MBCG Response
This Technical Note gives conflicting survey results about existing traffic levels undermining any confidence we could have in assumptions then included in the developer’s models.
Furthermore, other relevant changes in traffic patterns, for example at the nearest bridge at Putney, are not considered, meaning that the true impacts on the area are not being analysed or presented to decision makers.
The Technical Note does not reflect local peoples’ experience of the intense, daily additional congestion on the South Circular and Lower Richmond Road, from the date of Bridge closure in April 2019 until the first lockdown in March 2020.
Also, currently there is neither funding nor repair plans for Hammersmith Bridge; no agreed timetable for repair and no clarity about the type or volumes of vehicle that will be able to use the Bridge in future.
Highway Mitigation Plans and VISSIM Modelling Summary TN041
The Technical Note indicates that the new Highway Mitigation options for Chalker’s Corner have been tested using the VISSIM model and have been found to bring significant benefits.
MBCG Response
MBCG calls for an independent review of the traffic model used by the developer. MBCG’s forecasts, prepared by our transport adviser, for traffic generated by the new enlarged development and school are significantly higher than those more aspirational forecasts supplied by the developer and apparently agreed with TfL.
We strongly dispute that the latest much larger scheme (2020) will generate much less traffic than the previous applications (A&B) put to London Borough of Richmond (2019/20); if the developer is so confident of these assessments they should be willing to subject them to an independent review.
The evidence suggesting that the secondary school will be far less car dependent when compared to other schools in the area is simply conjectural.
The developer’s forecasting has considered the recent Homebase scheme but fails to take account of the very substantial new and committed developments in nearby areas, including for example the A4 Brentford corridor, which will add to pressures on Kew Bridge, the South Circular / Chalker’s Corner and the Lower Richmond Road. Only generic growth assumptions over a wider area appear to have been modelled and this is wholly inadequate for a scheme of this size.
The new proposals for Chalker’s Corner (Option 2 is singled out as preferred by the developer in the documents), show little difference in their impacts on journey times; and there is a very strong focus of attention given to journey time changes which are forecast on the Lower Richmond Road whereas traffic flows, noise and air quality/pollution are not, or are barely mentioned.
The plans contain no mention of the timing and sequencing of the various traffic mitigation works themselves, which if they were to go ahead, would need to be carried out at the same time as very substantial demolition works, basement parking excavations and construction of the school and 1250 residential units.
TN040 Consultation Response (and other matters not mentioned above)
The applicant’s Technical Note indicates that the reduction of parking spaces on the Stag site from 679 to 493 will lessen the impact of the development on the surrounding roads. The note also states that the loss of 36 parking spaces on the Lower Richmond Road, displaced by the new bus lane, can be accommodated in the surrounding roads.
New signalised and non-signalised pedestrian crossings are proposed for the Lower Richmond Road and Mortlake High Street, and some limited changes are proposed at the Sheen Lane level crossing.
MBCG Response
The reduction in car parking on the developed site and new post-Covid trends/ behavioural patterns are likely to/ or already have increased home delivery vehicles, and the use of taxis/uber and Zipcar type hire etc. Self-evidently a reduction in residential car parking spaces cannot be equated with an automatic reduction in vehicle movements into and out of the site. People who do not have cars have deliveries and use hire vehicles – at the moment none of that is included in the traffic movement models.
The reported parking surveys were undertaken during partial ‘lockdown’ and are clearly unrepresentative of normal conditions. We note that the closest streets where alternative parking is suggested to replace the spaces lost due to the new bus lane are already filled to capacity. (i.e.: Kingsway and Shalstone Road) and there is already a dawn to dusk CPZ on those residential streets. Hanson Close and Rosemary Terrace are both private roads, and Thames Bank is flooded very regularly.
The enlarged scheme with 1250 new residential units increases the population of Mortlake by 90% concentrated into a small area. Over 1100 more pedestrians are forecast to cross the Lower Richmond Road in the AM rush hour peak and this road is set to become permanently busier with the extra lane into Chalker’s Corner. This massive increase in pedestrian and cycle movement when considered with four new/remodeled crossings over Mortlake High Street / Lower Richmond Road will cause considerable delays to traffic at those crossings, especially with the concentrated AM use adjacent the 1150 pupil secondary school. All this on a road already heavily congested with long tail backs.
The Mortlake Rail/Sheen Lane level crossing is predicted by the developer to handle at least an additional 900 pedestrians and 70 cyclists crossing through it in the AM rush hour alone. These huge increases are conservative estimates. If the developer’s own assessment of the likely increased use of train services is taken seriously the number of pedestrians around the level crossing would be significantly larger than these suggested numbers.
This increase will only add to the already dangerous conditions as crowds build up either side of the crossing during barrier down time. Once the barriers lift for a few minutes, the massed pedestrians will vie with frustrated drivers for space to traverse the crossing. Especially risky will be arrival/departure times of infant school children and parents for Thomson House Primary School. Only minor ‘cosmetic’ mitigation measures are proposed at the crossing. Network Rail recognise that there is no practical way of reducing the dangers and risks without a radical solution but no such solution is forthcoming. The developer’s proposals in effect ‘wash their hands’ of this problem, and knowingly add to the risks surrounding what is already stated by Network Rail to be one of the riskiest level crossings on the south western network.
Although additional bus services are mentioned there is no agreed public transport strategy and it is impossible therefore to rely on any mitigation provided by the financial commitments to TfL.
The Technical Notes repeatedly state that further modelling, surveys and design are required, and changes to traffic light sequencing may also need to be adjusted. We would contend that no amount of modelling and adjustments will change the clear and certain facts about the increase in traffic and pedestrian movements linked to the density of the development. This hardly provides the level of certainty required to justify such significant development proposals within Applications A&B and we therefore urge that both applications are refused.