Comments submitted by councillors Eloise Bailey, Hina Bokhari and Carl Quilliam:
Tesco Site, 265 Burlington Road New Malden Surrey KT3 4NE
19/P2387 DEMOLITION OF THE EXISTING BUILDINGS AND ERECTION OF TWO BLOCKS OF DEVELOPMENT RANGING IN HEIGHT BETWEEN SEVEN AND 15 STOREYS AND COMPRISING 456 NEW HOMES, OF WHICH 114 WILL BE ONE BEDS, 290 WILL BE TWO BEDS AND 52 WILL BE THREE BEDS. 499SQM OF B1(A) OFFICE SPACE WILL BE ACCOMMODATED AT GROUND FLOOR LEVEL ALONG WITH 220 CAR PARKING SPACES, 830 CYCLE PARKING SPACES, A REALIGNED JUNCTION ONTO BURLINGTON ROAD, HARD AND SOFT LANDSCAPING AND ASSOCIATED RESIDENTIAL FACILITIES. THE APPLICATION ALSO INCLUDES MINOR CHANGES TO THE LAYOUT AND CONFIGURATION OF THE RETAINED TESCO CAR PARK
We are writing as councillors for West Barnes Ward in connection with the above Planning Application. In addition, we would like to express an interest in speaking at the PAC on this application.
A number of concerns have been raised about the application that we feel should be addressed before any approval is given: the height of the proposed blocks, the affordable housing element, parking, transport and road access, flooding concerns, and the use of any section 106 agreement or CIL contribution.
Need for housing
There is significant need for local housing. As per DM H2 of the Sites and Policies Plan:
“Research in London and in Merton shows that there is an overwhelming need in London and in Merton for all types and sizes of new homes, which must be balanced against the need for supporting infrastructure. Assessment of historical provision in the borough indicates a disproportionately greater delivery of smaller homes compared to larger homes”.
Fundamentally, it might be preferable for the Council to adopt a formal planning brief relating to the development of this site/the remainder of this site, and this could include a needs analysis on the capability of local schools, GP surgeries and other services to cater for the increase in population that results from significant further residential development.
Heights/massing/closeness to existing properties
Para 127 of the National Planning Policy Framework requires that developments:
- “add to the overall quality of the area”
- “are sympathetic to local character and history”
Furthermore, there are 3 elements of DM D2 of the Sites and Policies Plan that seem particularly relevant to this development:
As per DM D2(A)(i), developments are expected to “Relate positively and appropriately to the siting, rhythm, scale, density, proportions, height, materials and massing of surrounding buildings and existing street patterns, historic context, urban layout and landscape features of the surrounding area”.
Under (A)(v) thereof, developments must “Ensure provision of appropriate levels of sunlight and daylight, quality of living conditions, amenity space and privacy, to both proposed and adjoining buildings and gardens”.
And by virtue of (A)(vi) they must “Protect new and existing development from visual intrusion, noise, vibrations or pollution so that the living conditions of existing and future occupiers are not unduly diminished”
The proposed development would, by reason of its design, building heights, bulk and massing be out of scale and character with nearby properties and would be a visually intrusive form of development, detrimental to the character and appearance of this area and therefore contrary to the policies outlined above.
Merton Council’s figures show that it is significantly failing in meeting its own target in Core Strategy CS8 of 40% affordable housing units in new developments over 10 units. Para 62 of the National Planning Policy Framework expects affordable housing elements to be met on site, unless financial contribution can be “robustly justified”.
Whilst it is pleasing that this development currently has 35% affordable housing proposed, it would only take 25 more units to bring this to 40%. The developer raise both viability issues and unit mix – rather than space or design issues. As such, we hope that Merton will examine this in detail, given the scale of the development, and insist on sticking to CS8.
Parking, transport & road access
Policy CS 20 (d) and (g) require that “developers to demonstrate that their development will not adversely affect pedestrian and cycle movements, safety, the convenience of local residents or the quality of bus movement and/or facilities; on-street parking and traffic management.… Supporting permit-free developments in areas within CPZs benefiting from good access to public transport (PTAL 4-6), with good access to facilities and services and/or in a town centre location”.
In addition, DM T3 of the Sites and Policies Plan states that “development will be approved where the council is satisfied that this will not have an adverse effect on the level of on-street parking, road safety or local amenity”.
Burlington road is already extremely congested, especially when the level crossing is down. The additional residents who will naturally have cars will only exacerbate this. The parking provision is 0.7 spaces per home with the idea that people will not have cars. However we have concerns people will still have cars, and the parking will spill into neighbouring roads. For example, in Linkway and D Avenue where residents already have difficulty parking. Related to this there are also significant concerns about guest parking for the new development, it would only take a very small number of visitors to create significant parking issues in the surrounding area at any one time.
Residents have raised concerns about the risk of flooding in the area for the proposed site.
The Pyl Brook (a tributary of Beverley Brook, open at this point but going into a culvert under the railway and the next part of West Barnes Lane) divides the Tesco site from Raynes Park High School.
In 2016, Tesco car park was deeply flooded. According to the London Borough of Merton, Policy N3.4, Raynes Park Local Plan (undated but a map is captioned 2018):
“3.4.8. The Strategic Flood Risk Assessment identified the potential for flooding over parts of Raynes Park Local Centre and more so to the south around Shannon Corner/Beverley Way. . . Flooding at Shannon Corner/Beverley Way is attributed to fluvial flooding of Beverley Brook. Development in these areas should comply with most recent Environment Agency advice and flood risk management policies and should incorporate sustainable drainage solutions to help manage surface water flood risk.”
The above document also refers to flooding in other parts of Raynes Park and Motspur Park.
Raynes Park and West Barnes Residents’ Association has an archived website showing historic flooding of local streets. See: http://oldweb.rpwbresidents.org.uk/campaign/floods2.htm
As such, we are concerned that the consideration of flood risk has not been assessed in full.
Section 106 agreement/CIL contribution
We believe that any such agreements negotiated or monies contributed should be used to ensure local school, early years/nursery and GP provision within the vicinity are expanded to help mitigate the impact of the development on the surrounding area. Feedback from residents is that they are very concerned that services locally are stretched. Any money not used for these purposes should be invested in further local transport infrastructure, including in ways to promote sustainable forms of transport.
Cllrs Bailey, Bokhari and Quilliam
Werst Barnes Ward