St Georges East Planning Response

Application Reference number 26/FULL/1099: 1 St George's Road, SW19 4DR

We write as ward councillors for Wimbledon Town and Dundonald and Hillside Wards in relation to the above application.

REDEVELOPMENT OF ST GEORGE'S HOUSE EAST FOR A MIX OF COMMERCIAL (CLASS E), SOCIAL RENTED AFFORDABLE HOUSING (C3) AND SHARED LIVING (SUI GENERIS), ALONGSIDE ENHANCED PUBLIC REALM, NEW AMENITY SPACE, PARKING AND SERVICING ARRANGEMENTS.

St George's House East is a key strategic site in Wimbledon. Because of its location in the heart of Wimbledon town centre and proximity to Wimbledon Station, any re-development of this site must seriously consider any impact on its surroundings, particularly any visual and economic impacts.

Compliance with Merton's Local Plan and Future Wimbledon SDP with regards to heights and massing

 Merton's Local Plan Policy N9.1 Wimbledon provides:

1. To ensure that Wimbledon continues to be a thriving destination for businesses, residents and visitors.
2. We will do this by

- Supporting tall buildings within Wimbledon Town Centre in accordance with the details in the Strategic Heights Diagram for Wimbledon Town Centre and the requirements in Policy D12.6 Tall Buildings.

- Respecting views from Wimbledon Hill through the Town Centre and beyond, with taller developments at St George's Road, away from the historic core, located around the station

Merton's Strategic Heights Diagram for Wimbledon town centre provides that the site is part within

• The area where 40m heights "could be appropriate"
• The area where 48m heights "could be appropriate"

This is supported by the Future Wimbledon SPD building height guidance map which shows the site is part within a 'stepped site':

• Up to 6 storeys (21-24m)
• Up to 8 storeys (28-32m)
• Up to 12 storeys (42-48m)

Paragraph 12.6.3 sets out indicative building heights based on residential and commercial uses – suggesting a building of around 10 storeys would be somewhere between 32m and 40m high.

Paragraph 12.6.11 of the Local Plan provides: "This policy requires exemplary design for proposals containing tall buildings. To demonstrate this, Design Guides and/or Design Codes should be prepared for these sites, either by applicants or the council".

Information provided by the developers shows a building rising to 15 storeys and 73.8m AOD. According to information again provided by the developer the ground at different parts of the site is around 22.6m AOD to 23.8m AOD, making the building over 50m high (from the ground) at its tallest.

We submit the proposed height materially exceeds the indicative height parameters shown in both the Strategic Heights Diagram and the Future Wimbledon SPD. The applicant therefore carries a particularly high burden to demonstrate that the additional height and massing are justified through exemplary design and that the proposal would not cause unacceptable impacts on townscape, strategic views or the setting of heritage assets.

We further urge the Council to set out a detailed tall buildings policy alongside the existing diagram to ensure that local planning policy is clear to developers.

Local Liberal Democrat councillors have always been clear that appropriate heights for tall buildings should have been set upfront by the Council and in its planning rules.

 In March 2021, in our Stage 2a consultation response to the Merton Local Plan, we said:

 "Building heights are hugely controversial, and the most contentious element of the Future Wimbledon SPD (that ultimately will need to be supported by the Local Plan, and as such the Local Plan must be consistent with the already adopted SPD). As such, we would expect to see Policy N3.6 and para 3.6.7 set out guidance on heights consistent with those in the SPD." 

In March 2024, in our post-hearings consultation response, we said: 

 "We think it is important that the Design Guides / Codes called for in site allocations that point to tall buildings are produced as soon as possible; equally we think there is a strong argument for a new Supplementary Planning Document on tall buildings. These documents should be ready for adoption at the same time as the New Local Plan for effective master planning". 

In November 2024, we tabled a Recommendation at the Development and Planning Applications Committee calling on the Council to produce a Supplementary Planning Document (SPD) on tall buildings.

This Recommendation was voted down by administration councillors and our consultation responses were ignored. As a result, the administration has failed to put in place these essential planning tools ahead of the adoption of the Merton Local Plan (2024) – and has still not done so.

Design and Appearance

This application has given little attention to the character and context of Wimbledon Town Centre. Wimbledon is a high footfall town centre, particularly during the Championships, and importantly Wimbledon Station is the point at which tourists first enter and experience Wimbledon.

Merton's Local Plan D.12.6 Tall Buildings provides:

1. The council will support tall buildings in those locations set out in part 3 of this policy where they meet all of the following criteria:

b. Their massing, bulk and height are appropriately sized and located, and demonstrate they

take into account local character and Heritage Assets and their settings through townscape analysis of short, mid and long views i. Where appropriate, they provide a mix of tenure and home sizes in accordance with policies on Housing

 Given the scale, height and bulk of the proposal, we are not yet persuaded that the applicant has demonstrated compliance with Policy D12.6. In particular, further justification is required regarding:

• its relationship with Wimbledon Station as a principal gateway to the town centre;
• its effect on the wider skyline;
• its visibility in strategic views from Wimbledon Hill;
• its contribution to the character of St George's Road;
• its cumulative impact alongside other consented tall buildings;
• whether its visual dominance is proportionate in this location; and
• how it provides an appropriate transition between the historic town centre and the taller commercial quarter around the station.

Particular attention should be given to long-distance views from Wimbledon Hill and to demonstrating compliance with Local Plan Policy N9.1(f), which seeks to respect views through the town centre while concentrating greater height around the station.

In broad terms we support developments that improve the landscaping of the "East Slope" area.

Co-Living and affordable housing

Merton Council does not currently have its own policy on Large-Scale Purpose-Built Shared Living (LSPBSL), unlike other authorities including Westminster, Lambeth and Barnet. As a result, the Council has less ability to shape development in these circumstances. Developers instead look to London Plan Guidance which fails to take account of specific local factors.

If Merton developed their own policy on LSPBSL, the Council could have greater control over the circumstances in which these developments would be permitted and how they might be managed. Lambeth and Barnet both have borough-specific requirements, for example to include a clear management plan.

In the absence of borough-specific policy, careful use of planning conditions and obligations becomes particularly important.

Separately, we support the intention to provide larger affordable housing units.

Construction

Should planning officers be minded to recommend the application for approval, we request that neighbouring residents' amenity as well as that of people using the town centre be protected during the build itself, as far as it can possibly be done.

Under Local Plan Policy 12.3 (p), development must "Ensure that the traffic and construction activity do not adversely impact or cause significant inconvenience in the day to day lives of those living and working nearby, and do not harm road safety or significantly increase traffic congestion"

To meet this, we would expect strict controls on noise, dust and dirt, hours of operation and site-traffic movements.

We appreciate most of these matters would be dealt with via a construction management / construction logistics plan approved via discharge of conditions application, but we would encourage there to be greater consultation and engagement about these matters and the development of these plans. As such we request that rather than just a condition that these plans be provided, thought is put into whether the conditions could be stronger and set out some of these factors.

Given the location of the site and the pedestrian and traffic movements in the town centre, we ask that if the application is granted a condition be applied that "There shall also be no noisy works undertaken at weekends or Bank Holidays" as has been applied to other sites in this area.

Resident liaison

We presume that the developer will provide liaison and emergency contact details.

Councillors Anthony Fairclough, Samantha MacArthur and Sarah Golby