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Hearing Session: report on discussions on Clapham Junction’s development framework

Author: Cyril Richert

An independent inspector has been conducting hearings in October regarding the Proposed Submission versions of the DMPD (Development Management Policies Document) and SSAD (Site Specific Allocation Document), which provide detailed policies to support the delivery of the Core Strategy [1].

On the afternoon of October 11th, Clapham Junction was subject of the meeting, and the list of topics was set in accordance to the objections raised by CJAG, including our criticism after the response to the consultation HERE. The meeting was organised in Room 123, Wandsworth Town Hall, with half a dozen Council officers, the inspector, the CJAG and the Battersea Society and a couple of people in the audience.

We have listed below the 4 topics with the arguments of CJAG.

Given that prospects for redevelopment of the adjacent land are uncertain, does the inclusion of reference to the re-alignment of Falcon Lane (proposal 4.1.1) introduce an unwarranted element of uncertainty?

Criticism (representation p7): The current vision will involve the move of the current Boots and the loss of Lidl and the car park. Although it could be envisaged in theory, there is no consideration on feasibility and cost (who is funding what): the land to the north will dramatically be reduced in size and value, rendering the scope of future investment there questionable at best.

In addition frontage and main residential windows of any development proposed will be forced to face north and directly looking upwards at a railway embankment.#

Contradiction with the Core Strategy encouraging the development of public realm and the provision of retail floorspace [Core Policies for Places: Policy PL 13 b) – page 77]. Although the public realm is proposed to be a square in front of Asda, it means a complete redevelopment involving Asda, Boots (Asda land ?), Liddl, and other adjoining properties.

OAK Trading (Hotel 155 Falcon Rd) objected and asked for amendment:

• Realignment will create an area of undeveloped land between their site and the hotel (1-p2)-> prejudicial impact on its interest. Comment 417 OAK TRADING:

it would reduce the size of the sites to the north and render redevelopment there less viable.
it could cause traffic difficulties by necessitating construction of a larger junction at Falcon Road.
it would still leave a relatively narrow strip between the realigned road and the rear of the gardens of the houses in Mossbury Road. The gardens of the houses on the north side of Mossbury Road are very short and any new residential development above ground floor level would surely need south facing windows which could harm the amenity of the houses in Mossbury Road.

• The Company has not been involved collaboratively with your Council over the future development strategy for Falcon Lane and environs (1-p3)

• Lidl (the land to the north of Falcon Lane is owned by retailer, Lidl GmbH Limited)has no interest in redeveloping its food store site to allow the realignment of Falcon Lane – and we would question the logic and deliverability of this SSAD policy. (1-p3)

Proposal: Is the south side of Falcon Lane a suitable site for future residential development? The rear gardens of the houses in Mossbury Road are already tiny. Any reasonable view will concede only 2 realistic solutions:

to offer extension of existing properties by land purchase (also supported by Oak Trading ID 418 suggest slight realignment and development Mossbury Rd)
to redevelop the open area with public space/square.

Tall buildings: The site is sloping down from Lavender Hill to Falcon road. The impact of a 5 storey building at the bottom won’t be the same as for a similar height at the top, where current buildings do not exceed 3-4 storeys.

Submission Statement of Consultation, p85 (3.222 Sites)

CJAG and Oak Trading Ltd consider that reference to the realignment of Falcon Lane has not considered feasibility and that costs and the impact of reducing the size of the ASDA/Boots/Lidl site on the deliverability of development have not been considered.[...] There has been no cost consideration applied to this approach and the intention is to flag up a potential improvement. The Council currently has no plans to realign the road. If a developer were to come forward it would be for them to undertake the necessary assessments of viability in the first instance. It is unclear as to the likelihood of such a scheme coming forward in the next 15 years with the existing economic uncertainties, however it is possible that one of the sites may come forward for development, and identification of the SSAD for a potential wider redevelopment is considered worthwhile.

This wishful dream (unrealistic, no cost, no viability study…) has not place in a document which should be used as guidelines for planning and future development.

Are the proposals for improvements to the Clapham Junction Station Approach (proposal 4.1.3) sufficiently definitive and positive?

• We acknowledge the mention of the site being sensitive to tall buildings.

• We agree on the justification providing that the site offers a real opportunity to provide the type of retail unit suited to the larger chain stores.

However the current presentation (as shown on graphics in previous versions of the SSAD) is actually re-using some of the planning of Delancey’s proposal without addressing the much needed issue of circulation between the two sides of the railway (Grant Road vs St John’s Hill).

It is using developer’s plans without any concerns for residents criticisms and resident suggestions!

The proposal map could be amended to present: Current map (#64) vs Proposed presentation, including open path and a much larger coverage of the railway allowing better retail usage.

Submission Statement of Consultation p86 (3.225) : CJAG acknowledge the mention of the Clapham Junction Station Approach site being sensitive to tall buildings and agree that the site provides a real opportunity to provide the type of retail unit suited to larger chain stores, however CJAG consider that the issue of circulation between the two sides of the railway still needs to be addressed. The Council acknowledge that this is a key issue facing Clapham Junction. [...] CJAG also consider that the ‘Land at Clapham Junction Station site’ should be allocated for mixed use development. As the site is outside the town centre it is more appropriately allocated for high density housing development.

Outside the town centre? Clapham Junction station?

As the officers wrote (Submission Statement of Consultation p85) “the Council considers that the relatively narrow site located between the railway lines is currently inaccessible and there are a number of obstacles to its development“.Any redevelopment of the Station Approach site will affect the station itself and therefore the town centre in general. It is currently a train depot and a business use could be retained.

In addition, latest discussion with the chair of the Transport Committee, Cllr Russel King, told us that a report was published showing London unable to sustain with growing demand for public transport within the next 5 years. There it is requested that all boroughs focus on developing business (instead of all residential accommodation) to relocate the demand.

It is therefore legitimate to consider CJ station as an appropriate site for mix-used/office development.

Should the land at Sendall Court (proposal 4.1.2) be allocated for open space rather than residential or mixed use?

Criticism (representation p8):

Visual representation: The visual representations provided by Berkeley first for their redevelopment of Lanner and Griffon House always presented an open space, used for public space, and balancing the very high density of their proposal.

In order to help visualise the impact, I presented the photos showed by the Developer (taken from its website) against a very quick montage assuming the impact of new constructions as it could happen in the space argued. Aren’t things less “appealing”?

In order to get approval, the developers of the site of Lanner and Griffon House submitted a documentation showing illustration with wide public spaces around their tall buildings. If it was showing that the Car park adjacent to Sendall Court could see another building increasing the already high density of the area, the public view and final decision of the committee might have changed.

During the Ram Brewery Enquiry (report of Colin Ball, the Inspector July, 4th 2010) a lot of consideration was made on the applicant images. It was said that the applicant’s AVRs must be taken as accurately representing what would be seen by the human eye. On the applicant image it is presented with a public square with grass and trees, which is not what the council is suggesting.

On the Submission Statement of Consultation, p12 (3.16 on Tall Buildings) it says “Clapham Junction Action Group request reference in this policy clause that the visual representations must accurately represent what would be seen by the human eye. This is accepted, but is considered more appropriate to be within the context to the policy.”

Public Space:

Submission Statement of Consultation p86 (3.224) : CJAG want the Car park adjacent to Sendall Court, Grant Road to be allocated entirely for public open space, in view of the consented developments at Lanner and Griffon House. This is not accepted as the site is not within an area of open space deficiency and is within 300m of York Gardens. Allocation of the site entirely for open space would therefore not be a priority use of the site.

SSAD p115 acknowledge that the site is located within an area of deficiency in access to nature

In addition, the Report of the Independent Review Neil Kinghan on Clapham Junction disorder (published a few days ago) made a recommendation that the Council should look at the actions it might take to reduce the influence of the gangs, for example in the design of its housing estates, the provision of more public areas such as the square on the Doddington Estate (report 6.16 p38).

Density:

In the previous version, proposed submission, the SSAD document included a section 4.1.2 Lanner and Griffon House, Winstanley Road, SW11. Representations on Lanner and Griffon House were received from Clapham Junction Action Group, Battersea Society and St James Group. We highlighted that the whole area is currently under construction with 3 buildings/high density up to 11 storeys and – except considering that this investment has any chance to be knocked down within the next 15 years, the mention of tall building of more than 5 storeys being inappropriate shows deep contradiction within the Council’s policy.

REMEMBER: according to SSAD, this is an area inappropriate to tall buildings.

While this area is considered as inappropriate for tall building and the whole location is covered by tall buildings, it must be time to show respect on the visual impact of developments.

Proposal: It should be mentioned that any development of the area should reserve a larger part to a public space (at least 50%).

Is the incorporation of part of the Peabody Estate land (proposal 4.1.6) into the town centre justified by the evidence?

1st argument of Peabody’s developers: Public transport

On the CS examination Peabody Trust said: “The Peabody Trust support the broad locations identified on Map 15, which are considered to be appropriate locations for tall buildings. The Peabody Trust support draft Policy IS3 and consider that sites that are located close to public transport nodes and key town centre services and facilities are appropriate where regeneration benefits can be demonstrated through the use of higher density development.”

However that argument was refused by the inspector during the examination of the CS as shown in response to questions CJAG submitted Dec 8th 2010. The Council replied : In last year examination, the government Inspector ’s conclusion was that only sites within town centres, focal points of activity and Nine Elms near Vauxhall may be appropriate for tall building and this did not extend to all ‘areas with good public transport accessibility’.

Then 2nd argument: move the Boundaries

The first version of the SSAD (Preferred Option) 27/11/09 said:

Tall buildings: In accordance with Council’s Stage 2 Urban Design Study – Tall Buildings, applications for buildings of 5 or more storeys will be subject to the criteria of the tall buildings policy contained in the emerging DMPD. In accordance with Core Strategy policy IS3d, tall buildings in this location are likely to be inappropriate.

Peabody Trust criticised the wording and wrote on 05/02/10:

Peabody is concerned that the final sentence under the heading ‘Tall Buildings’ contradicts the analysis referred to above by stating: “In accordance with Core Strategy policy IS3(d), tall buildings in this location are likely to be inappropriate.”

You will note that Peabody based its analysis by stating that “Core Strategy policy IS3(d) clearly states that tall buildings may be appropriate in locations that are well served by public transport”

->The adopted version of the CS does not mention public transport in tall building justifications

The current SSAD submission version says:

Tall buildings: In accordance with Council’s Stage 2 Urban Design Study – Tall Buildings, applications for buildings of 5 or more storeys will be subject to the criteria of the tall buildings policy contained in DMPD Policy DMS4. The part of the site within the town centre is identified as being sensitive to tall buildings, whilst on the southern part of the site adjacent to Wandsworth Common they are likely to be inappropriate, in accordance with Core Strategy Policy IS5d

Everyone can see that after the previous inspector’s words, the Council could not justify the site suitable for tall buildings based on its PTAL (over-writing the inappropriate location). Therefore they changed the rules, deciding to extend the town centre to suit exactly the developers’ plan.

You will appreciate that the previous part that we highlighted in bold, stating that tall building in this location are likely to be inappropriate has been removed and replace with only a mention of the southern part of the site, the remaining becoming only “sensitive”.

We consider the boundary change in the DMPD to be an attempt to justify the inclusion of part of the estate in the “sensitive but not inappropriate to tall building” area for town centres, rather than the promotion of the St John’s Hill frontage.

This is actually acknowledged in by the council in DMPD Proposed submission page 145 saying: This change is proposed in order to promote active town centre uses along the St John’s Hill frontage, and to encourage regeneration of the Peabody Estate.

In addition Policy IS5d is related to the percentage of affordable housing and therefore is not appropriate regarding tall buildings. On the contrary, by linking the target for affordable housing with tall buildings, the Council is clearly sending a message of sympathy for tall buildings in order to comply with the very aggressive targets it decided to set out in CS IS5.

During the meeting, Council officers acknowledged the mistake and said it should read IS3d instead of IS5d.

History of tall building in Clapham Junction area

In 2008-2009, Delancey (which worked on it with the Council for 5 years) put forward a proposal for two 42-storey towers at Clapham Junction. The Council received petitions and individual letters (in total more than 1000) telling with numerous arguments that residents do not want tall building in the area.

Although the Core Strategy (which was adopted later) say in PL13 “Taller buildings could not only help deliver significant regeneration benefits but also give a visual focus to the town centre”, it was balanced by Stage 2 Urban Design Study: Tall Buildings-2.34 saying: “the centre has a rich historic heritage and as such is considered sensitive to tall building”.

DMPD – DMS4 says: b. Applications for tall buildings will be required to address the following criteria in order to demonstrate compliance with Core Strategy Policies IS3d and IS3e:

v. assess the impact on the existing historic environment through a conservation impact assessment identifying how the surrounding area’s character or appearance or the setting of a listed building will be preserved or enhanced.

To conclude, we can recall the Council officer’s report for Capstick in Putney saying the proposal is deficient in a number of policy areas (DMPD, SSAD…etc) but the benefits of regeneration is balancing the case. A change of boundaries was also made in this particularly case in order to suit the developer’s needs.

>>The council is setting up policies that will apply strongly to small development but is prepared to ignore them (and ignore the local residents) for big development (even arguing on “exceptional circumstances” while the word “exception” has been refused by the previous inspector).

>>The Council is setting plans in order to suit developers and in opposition to resident views, working hand to hand with developers and modifying rules and policy to remove valid objections of residents.

***

A report on the hearing session will be drafted for the next Transport Committee on November 14th.

Wandsworth Borough Council (WBC) should receive the report from the inspector early January 2012.

[1] The Clapham Junction Action Group has submitted a contribution that you can read HERE along with additional questions and comments THERE.

October 27, 2011 at 11:54 am Leave a comment

Planning Forum meeting October 2011: some feedback

Author: Cyril Richert

On Tuesday, October 18th, was organised the Planning Forum at Wandsworth Borough Town Hall. You will find below some comments and feedback. They do not intend to replace any minutes and are obviously my own views of the meeting (and comments in red).

Local development framework update

Development Management Policies Document & Site Specific Allocations Document

An independent inspector was conducting hearings regarding the Council’s planning documents at the beginning of October (the Clapham Junction Action Group was invited to attend on October 11th and we will report about this meeting here soon).

The main topics were: tall buildings, housing policy, town centre, Wandsworth delta, Nine Elms, with thorough discussions on Putney and Clapham Junction. Martin Howell (Group Planner – Policy & Information), thanked everyone for participating.

A report on the hearing session will be drafted for the next Transport Committee on November 14th.

Wandsworth Borough Council (WBC) should receive the report from the inspector early January 2012.

Although not clearly stated, the date is very important. The government is currently working on new regulations (localisms bill) allowing local authorities to ignore the inspector recommendation as long as the document is said to be sound. It seems that the Council is betting that the vote in parliament will come in December, thus making any recommendation from the report in January not binding and WBC could choose easily to ignore them.

As we received grateful messages from the Council officers on the opportunity to exchange with local groups and residents during those examinations, I inquired about the possibility to set regular meetings with Council officers but Martin Howell replied that he preferred to have invitation for public events organised by the amenity societies. Meeting will also happened next year on the review of the Core Strategy (already!).

Planning Obligations SPD

Section 106 can no longer be used to collect monies and it has been replaced by Community Infrastructure Levy (CIL). Nine Elms’s CIL are higher than for the rest of the borough.

Development management update

Pre-application charges

From now on boroughs can set their own fees. However there is no date yet for implementation, maybe April 2012.

In case WBS decides to to set pre-application fees, officers said it will need to be transparent and documents and reports of pre-app. meeting should be available.

Major developments

Springfield hospital: after WBC refused the application, the developers filled appeal. Hearings will be organised in November 2012.
Peabody: still confusing documents, and a meeting with officers should clarify the plans.
Clapham Junction Station: WBC is seeking to start new talks with Delancey on the site, especially in view of CP5 funding period (2014-19) for Network Rail where more money could be available.

Localism Bill

There is a 20 page document available to summarise the bill on the DCLG website.

There is currently the third hearing with the Lords’ Chamber and it is expected to be voted by the parliament in December 2011.

Issues are:

Predetermination: It should allow Councillors to make more comments prior to the vote before the planning committee.
Pre-application consultation: All major development will have to go through pre-application and a report will be published showing how it affected the application.
Neighbourhood planning: Council will be able to approve neighbourhood forums and will decide the level of implication in the process. However this is currently confusing and it is difficult to see how it will improve the community involvement. WBC officers said that they have already a great number of planning rules and documents.

Next meeting should be organised in January 2012.

October 26, 2011 at 5:18 pm Leave a comment

Hearing Session: discussion on Clapham Junction’s development framework

Author: Cyril Richert

Following the consultation on the Proposed Submission versions of the DMPD (Development Management Policies Document) and SSAD (Site Specific Allocation Document), which provide detailed policies to support the delivery of the Core Strategy [1], the final documents were submitted to the Secretary of States on May 27th. An independent inspector is currently conducting hearings regarding the documents.

Agenda for Hearing Session

Hearing Session 6 – 11 October 2011 – Afternoon

This Session opens at 14:15 and it is anticipated it will be completed by about 17:00.

The venue for the hearing sessions will be Room 123, Wandsworth Town Hall, Wandsworth High Street, London, SW18 2PU

SSAD

Clapham Junction

Given that prospects for redevelopment of the adjacent land are uncertain, does the inclusion of reference to the re-alignment of Falcon Lane (proposal 4.1.1) introduce an unwarranted element of uncertainty?
Should the land at Sendall Court (proposal 4.1.2) be allocated for open space rather than residential or mixed use?
Are the proposals for improvements to the Clapham Junction Station Approach (proposal 4.1.3) sufficiently definitive and positive?
Is the incorporation of part of the Peabody Estate land (proposal 4.1.6) into the town centre justified by the evidence?

The Clapham Junction Action Group (CJAG) has been invited to attend the hearing session along with the Battersea Society. You will notice that the list of topics covers all main concerns raised by CJAG, including our criticism after the response to the consultation HERE.

[1] The Clapham Junction Action Group has submitted a contribution that you can read HERE along with additional questions and comments THERE.

September 27, 2011 at 1:27 pm Leave a comment

Planning Forum meeting July 2011: some feedback

Author: Cyril Richert

On Thursday, July 12th, was organised the Planning Forum [1] at Wandsworth Borough Town Hall. You will find below some comments and feedback. They do not intend to replace any minutes and are obviously my own views of the meeting (and comments in red).

Local Development Framework

Since the last meeting, the Council officers have spent the beginning of the year working on analysing and commenting the responses to the consultation (both comments on the DMPD and on the SSAD). We have already published an article commenting the direct responses to the concerns raised by CJAG [2].

The documents were submitted to the Secretary of States on May 27th and are now under examination by an independent inspector until the end of the year. It is expected that the examination will take place at the end of September 2011.

The Council is planning to adopt the final policy by Spring 2012.

Enforcement

The amount of enforcement (complaints regarding planning procedure – or lack of planning) has significantly grown in the last years. Some of the most common cases include:

Building Work
Change of use
Untidy land
Work to listed buildings

etc.

The government owns advice is to negotiate. If it fails, the local authorities can consider taking enforcement action; however it considers also if it will achieve the purpose. In their address they will consider whether the matter is contrary to the planning policies adopted by the Council and the impact on the neighbourhood.

The officer reported however that enforcement were very costly and time consuming for (too) often a small consequence (a fine of £500) and therefore is never the preferred option. There are currently 4 enforcement officers in Wandsworth Borough Council.

Planning Web Pages

In view of the recurrent difficulties on the Council website last year, a lot of resources have been dedicated to the issue:

upgrade of the whole website
move to a new system
new search fields
new services: planning explorer, mapping (excellent service!)

During the meeting it was noted that comments were only available when you view the documents. Although it is voluntary, the officers will see how it is possible to display a warning message.

Several improvement were also listed for future upgrades:

It is currently difficult to make the difference between ongoing developments and alread done.
Need to scroll down completely to get the View related documents.
If the application is new, its boundary is not on the map and will appears only once the boundary is captured (and the consultation starts).

Central Government Legislation

The main concept of the Localism Bill is the neighbourhood planning (people can get together and write plans).

As I requested on behalf of the Clapham Junction Action Group, we should have a presentation of the Localism Bill (currently on progress with Parliament) at the next meeting.

The National Planning Policy Framework is summarizing 3 meters of documents into a simple 50 page national planning development guideline.

Next meeting: mid-October 2011

[1] I’m still wondering whether it is semi-annual or quarterly… or random

[2] Since our contribution criticising the change of town centre boundaries (see our contribution here and comment there) in a clear attempt to allow taller building in the location of the Peabody Estate (despite previous comments of the inspector) we heard that this was also highlighted by the Wandsworth Society, the Putney Society and the Labour group in the Council. Only the Clapham Junction Town Centre Partnership is supporting the recommendation as we discovered in their representation (that we did not received previously).

August 1, 2011 at 10:08 am Leave a comment

Planning consultation: the full answer from the Council

Author: Cyril Richert

Following the consultation on the Proposed Submission versions of the DMPD (Development Management Policies Document) and SSAD (Site Specific Allocation Document), which provide detailed policies to support the delivery of the Core Strategy [1], the Council officers have spent the beginning of the year working hard on analysing and commenting the 73 responses in total, made of 497 comments on the DMPD and 496 comments on the SSAD. Following the schedule they gave, they have presented their responses before the Committee this April.

First of all, and before any comment and disagreement we might write further down, we must admit that the Consultation report is fully detailed and – at least in the case of CJAG that we know – addressing all the comments that were made with details and proper responses.

We won’t go through the 144 pages of the report (you can download the PDF) but I will comment the direct responses to the concerns raised by CJAG (and where cited) and highlight in bold the key decisions.

page 5: A letter was sent to the Putney, Wandsworth, Battersea and Balham Socities, Clapham Junction Action Group and the Tooting Local History Group offering to meet with the groups and explain the DMPD and SSAD documents and process related to the consultation. Clapham Junction Action Group chose to send in a series of questions for the planning service to respond to, rather than attend a meeting.

You can read the outcome here.

p10: General development principles – Sustainable urban design and the quality of the environment (DMS1): Several minor wording changes were requested by residents and residents’ groups, which largely requested reversion to the preferred options wording (Patricia Poulter, Isabel Wooller, CR Atkins, Clapham Junction Action Group).

DMS1a: we questioned the definition of the potential of site (financial? density?). This policy criterion has been retained but further clarification has been provided in the context (para 2.3) to clarify that this needs to be appropriate to the local context and take into account the London Plan density matrix.

DMS1d: We questioned the removal of the “need to justify and mitigate any impact“. The officers acknowledged that the policy lacks the need to justify impacts where they do occur, but it is considered that only having to justify impacts, rather than seek to reduce them, does not go far enough either. Therefore, the Council has amended DMS1d to require any impacts on natural features, open spaces and strategic views to be avoided, remedied or mitigated. They submitted this amendment and required our feedback ; we supported the change.

p12: Tall Buildings: Clapham Junction Action Group request reference in this policy clause that the visual representations must accurately represent what would be seen by the human eye. This is accepted, but is considered more appropriate to be within the context to the policy.

After the Ram Brewery Inquiry, the Inspector wrote: “the use of a wide angle lens has the effect of distorting perspective and distance, and thus the spatial relationship between foreground and background. Existing buildings, and therefore the new ones, appear further away or smaller than they are or would be in reality. This was particularly apparent to me when I compared the AVRs to the actual views from the same viewpoints and is also demonstrated in the Wandsworth Society’s comparable 40º AVRs”. We are pleased that the Council officers are acknowledging our point and accept the consideration.

p13: Clapham Junction Action Group question why the requirement to respond positively to any characteristic alignment and setback of surrounding buildings was removed between Preferred Options and Proposed DMPD & SSAD Proposed Submission Statement of Consultation Submission stage. It is accepted that this was an important part of the policy that should have been retained, and has been reinstated in the Submission version.

YES!

p14: The Stage 2 Urban Design Study describes storeys as an average of 3m. [...] The 3m assumption has now been referenced in the context to DMS4, along with a requirement for planning applications to express the height of their buildings in storeys and metres. Clarification has also been provided that the ground floor is counted as a storey.

p83: In relation to building heights, CJAG queried why heights are expressed in storeys rather than metres. The Council responded that [...] this assumes an average storey height of 3m [...]. This has now been included in the context to DMS4 for clarity, along with a requirement for developers to express their building heights in storeys as well as metres in planning applications

Always better to specify clearly. Better for the developers. Better for the public.

p54: The Clapham Junction town centre boundary change is supported by the Clapham Junction Town Centre Partnership, but opposed by the Wandsworth Society on the basis that this has been done to allow tall buildings in this location. The change has been made to encourage integration of the site into the town centre, by allowing town centre uses along the St John’s Hill frontage. The site has been identified as ‘sensitive’ to tall buildings, with buildings being considered tall at 5 storeys and above.

p86: CJAG consider that the inclusion of part of the Peabody site within the town centre has been carried out to ease the passage to consent for tall buildings, and not the promotion of the St John’s Hill frontage. This is not accepted. Part of the site has been included in the town centre to promote active town centre uses along the St John’s Hill frontage allowing better integration into the town centre. The part of the site within the town centre is sensitive to tall buildings, and the part outside the town centre is inappropriate for tall buildings. The height at which a building is considered tall in both locations is 5 storeys.

As far as we know it is also contested by the Putney Society. The fact that the Council cannot ignore is that Peabody Trust is working on the possible redevelopment of the estate, including knocking down the existing buildings and replacing them by high density constructions including a 21-storey tower, along with a 13-storey and 10-storey buildings.

The re-wording seems an attempt to address the arguments raised by developers to ease their planning: in the new version, their taller buildings will be located in the sensitive but no longer inappropriate location! It is noticeable that the paragraph does not mention anymore the Core Strategy IS3 talking about the impact on the surrounding area. Located at the top of the hill, a 11 storey building will appear to be about 28 storeys when viewed from Arding and Hobbs and will nearly double the size of the estate in Grant Road.

Therefore we consider the boundary change in the DMPD to be an attempt to justify the inclusion of part of the estate in the “sensitive but not inappropriate to tall building” area for town centres, rather than the promotion of the St John’s Hill frontage.

As the council officers do not see the difference between “sensitive” and “inappropriate” this is definitely an issue that we will seek to resolve before the inspector. In a previous hearing, the inspector already rejected the argument made by the Council that the Peabody site is appropriate for tall buildings because of its high PTAL (page 33 of the DMPD and SSAD preferred options statement of consultation) and is likely to see the boundary dispute as an attempt to bypass her previous decision.

p85: CJAG and Oak Trading Ltd consider that reference to the realignment of Falcon Lane has not considered feasibility and that costs and the impact of reducing the size of the ASDA/Boots/Lidl site on the deliverability of development have not been considered.[...] There has been no cost consideration applied to this approach and the intention is to flag up a potential improvement. The Council currently has no plans to realign the road. If a developer were to come forward it would be for them to undertake the necessary assessments of viability in the first instance. It is unclear as to the likelihood of such a scheme coming forward in the next 15 years with the existing economic uncertainties, however it is possible that one of the sites may come forward for development, and identification of the SSAD for a potential wider redevelopment is considered worthwhile.

At least it has the merit of clarity: it is just a wishful idea, with no serious thought whatsoever.

p85: Representations on Lanner and Griffon House were received from Clapham
Junction Action Group, Battersea Society and St James Group. As construction has
started on the site for student accommodation (2009/2279) it has been removed from
the Site Specific Allocations Document.

That is what we said, considering that the whole area is currently under construction with 3 buildings/high density up to 11 storeys and therefore Lanner and Griffon Houses do no longer exist as such.

p86: CJAG want the Car park adjacent to Sendall Court, Grant Road to be allocated entirely for public open space, in view of the consented developments at Lanner and Griffon House. This is not accepted as the site is not within an area of open space deficiency and is within 300m of York Gardens. Allocation of the site entirely for open space would therefore not be a priority use of the site.

It is indeed close to a public space. However, considering that it is separated by buildings up to 11 storeys exceeding the 5-6 storeys that the Council recommends in its policy documents, the open public space should balance that impact.

As we were talking above about the necessity of appropriate visual representation we must consider the images that were submitted. In order to get approval, the developers of the site of Lanner and Griffon House submitted a documentation showing illustration with wide public spaces around their tall buildings. If it was showing that the Car park adjacent to Sendall Court could see another building increasing the already high density of the area, the public view and final decision of the committee might have changed.

As we cannot consider that the Council approved the consultation and the planning proposal based on visual representation that it knew being inaccurate, we think that the Council should consider the space adjacent to Sendall Court, Grant Road with the greatest circumspection.

Current representation:

Montage on planning policy impact:

p86: CJAG acknowledge the mention of the Clapham Junction Station Approach site being sensitive to tall buildings and agree that the site provides a real opportunity to provide the type of retail unit suited to larger chain stores, however CJAG consider that the issue of circulation between the two sides of the railway still needs to be addressed. The Council acknowledge that this is a key issue facing Clapham Junction. [...] CJAG also consider that the ‘Land at Clapham Junction Station site’ should be allocated for mixed use development. As the site is outside the town centre it is more appropriately allocated for high density housing development.

Outside the town centre? Clapham Junction station? Indeed if you read the artificial limits following existing developments. As the officers wrote (p85) “the Council considers that the relatively narrow site located between the railway lines is currently inaccessible and there are a number of obstacles to its development“. Any redevelopment of the Station Approach site will affect the station itself and therefore the town centre in general. It is currently a train depot and a business use could be retained.

[1] The Clapham Junction Action Group has submitted a contribution that you can read HERE along with additional questions and comments THERE.

May 24, 2011 at 5:36 pm Leave a comment

Planning Forum meeting January 2011: some feedback

Author: Cyril Richert

On Wednesday, January 19th [1], was organised the semi-annual Planning Forum at Wandsworth Borough Town Hall. You will find below some comments and feedback. They do not intend to replace any minutes and are obviously my own views of the meeting.

Local Development Framework

The Proposed Submission versions of the DMPD (Development Management Policies Document) and SSAD (Site Specific Allocation Document), which provide detailed policies to support the delivery of the Core Strategy, were under public consultation until the 10th December 2010.

The Clapham Junction Action Group has submitted a contribution that you can read HERE. We also raised specific point, received some responses and made comments HERE.

Martin Howell presented the purpose of the Local Development Framework documents with slides.

The current schedule is such as:

April 2011: Submission version to the committee.
May-Dec 2011: Examination by the independent inspector
April 2012: Adoption

In last year’s consultation, they received 73 responses in total, made of 497 comments on the DMPD and 496 comments on the SSAD.

The planning officers made several changes, including the removal of upper limits for the size of the buildings (the Council saw that applicants were testing the policy constantly by submitting all applications at the minimum of the upper limit), mix-housing percentages, clarification on industrial areas, and the removal of the gipsy area proposals (subject to London plan).

Now all area specified in the SSAD documents have been defined with 3 colours where buildings are:

inappropriates,
sensitive,
appropriates (only in the Nine Elms/Vauxhall area with a cluster of tall buildings).

Size of buildings to be considered tall is generally more than 5 storeys (with 5/6 in the Putney area).

Following the last round of consultation this autumn, the Council received 84 representations on the SSAD (made of 295 comments) and 48 for DMPD (244). The reduction is partly explained by the removal of the gipsy locations which generated a lot of comments previously.

The policy team is currently preparing a consultation report addressing the different representation with the Council’s responses. Although it should be addressing each single comments, the whole document should be much more detailed than the previous report which was only summarizing a few comments.

The officers explained that no fundamental change will be made to the current documents (otherwise it would require another consultation). However the inspector will look at all the representations and will even request more details/explanation from the individuals if necessary before making recommendations.

Localism Bill

The localism bill is at its early stages and it is expected to go through a very long and extended process and controversy in Parliament. In a nutshell it aims to give more power to local authorities.

Amongst the list of changes proposed, I noted that the Council would be no longer required to make changes regarding inspector’s recommendations (which is currently binding). As Philip from the Wandsworth Society commented that it will be removing some weight to the planning consultation, the officers commented that actually some changes will still be mandatory (or so I understood).

Another point was the introduction of a £50 per sqm levy on behalf of the Mayor of London on all infrastructure. The Council seems concerned that it would take money out of their current funding.

Major Development

The planning application for the Battersea Power Station has been approved.

Application for Springsfield hospital (Balham) has been refused.

The new application for the Ram Brewery is moving very slowly (apparently mainly due to the proximity with the gas holder, which was a major concerned in the inspector’s decision to refuse).

Website

Following the numerous problems which affected the Council’s website, it looks like recent improvement (including the change of provider) made the number of complains to drop. There are still issues such as the search within the application database and the automatic email sent for major planning applications with broken links, and the Council encourages people to report all problems.

Next meeting: Tuesday 7th June 2011

[1] Previously planned quarterly for December, it was then postponed to January at the last minute to happen after the end of the planning consultation on DMPD and SSAD documents

January 31, 2011 at 5:15 pm Leave a comment

The Wandsworth Society society is commenting on planning policy

Author: Cyril Richert

The Wandsworth Society submitted its comments on the Proposed Submission versions of the DMPD (Development Management Policies Document) and SSAD (Site Specific Allocation Document), which provide detailed policies to support the delivery of the Core Strategy. You can download the 6-pages HERE. The Clapham Junction Action Group has submitted a contribution that you can read HERE.

Their main concerns relate to specific applications of the tall buildings policy and to the justification given for some site-specific allocation proposals.

They highlighted that the majority of respondees to the initial consultation do not want to see tall buildings in the borough (and hoped therefore that the views of actual residents will be paramount in this latest round of consultation). They criticized the link made in the S2UDS (2.6) between the status of the town centres and tall buildings. Although this is now a Core Strategy policy statement, there is no sound or logical reason why tall buildings should be associated with commercial success or with regeneration.

As we did in our representation, they criticized the change of the Clapham Junction boundaries to include some of the Peabody estate, with a very similar statement to ours:

“1.3 [...] The extension of the Clapham Junction town centre boundary, to make tall buildings acceptable along the St John’s Hill boundary of the Peabody Estate, is equally untenable. Particularly since this was done to overcome the verdict of the Inspector at the Core Strategy Examination who refused to sanction tall buildings here.“

And they also recommend to specify clearly the height of a storey:

“1.5. Although the S2UDS (2.17) states that storey height is assumed to be 3m, this is not stated in the DMPD. As the DMPD will be the general reference point it should be made clear here too. If tall-building policy IS3 is to be effective, it is particularly important that the actual height of buildings is not disguised by spurious storey heights.“

The Council officers seem to agree, according to the response they made to our latest exchange:

“This is based on a middle ground between average residential floor to ceiling heights which are generally 2.5m and average commercial floor to ceiling heights which are generally 3-4m. We will be including reference to this in the context of policy DMS4 in the submission version.“

The Council should be working on analysing all contributions as the public consultation closed on December, 10th. Results should come by February/March but we should be able to get some update at the next Planning Forum on January 19th.

January 12, 2011 at 9:14 pm Leave a comment

Planning consultation: some progress and a responsive Council

Author: Cyril Richert

The Proposed Submission versions of the DMPD (Development Management Policies Document) and SSAD (Site Specific Allocation Document), which provide detailed policies to support the delivery of the Core Strategy, are still under public consultation up to the 10th December 2010.

The Clapham Junction Action Group has submitted a contribution that you can read HERE.

We must say that we have been impressed by the effort made by the Council officers in charge of the consultation, and Martin Howell and his team have been particularly responsive, participating to several meetings organised by societies and partnerships.

The meeting organised by the Putney Society at the end of November was well attended (~65 people) and Martin Howell outlined the changes and reasons behind the changes and was confronted by local residents over the appropriateness of high rises in Putney in particular. He confirmed that applications would be scrutinised against the policies contained in the DMPD. He also mentioned that these were based on the vision outlined and already approved.

In addition, the team agreed to answer questions sent by the Clapham Junction Action Group (special thank to Kristen McGavock). You will find below the questions in bold, answers and some comments in dark red when appropriate.

Questions regarding the consultation on the Development Management Policies Document and the Site Specific Allocation Document – 30th November 2010

Development Management Policies Document

Question 1: DMS 1 a: “use a design-led approach to optimise the potential of sites”> What is the definition of the potential of site. Is it a potential in term of profit? In term of density? Or is it in term of public realm?

Reference to optimising the potential of sites relates to making the maximum use of previously developed land in terms of density. This is in accordance with Core Strategy Policy IS1 and Planning Policy Statement 3 – Housing. However, we acknowledge that this could be further clarified in the context and potentially in the policy, to ensure that it is clear what we mean.

Question 2: DMS 1 d: “aim to minimise any impact on natural features”> Those words have replaced the previous “need to justify and mitigate any impact”. Why is there no longer a need to justify an impact?

Preferred options versions of policy DMS1h and i were seen to have a degree of duplication as they both related to impacts on natural features/landscape features. These policies were merged into proposed submission version of policy DMS1d. It is acknowledged that the policy now lacks the need to justify impacts where they do occur, but we feel that only having to justify impacts, and not attempt to minimise them, was not good enough either. We suggest the following change and would welcome your feedback “are sympathetic to local landscape characteristics and avoid, remedy or mitigate any impact on natural features, open spaces and strategic views.”

Yes, the proposal including “avoid, remedy or mitigate any impact” is much stronger than the current “minimise” and can imply a strong justification for any proposal with even the smallest impact as it should avoid it.

Question 3: DMS 4: Tall buildings v. :“that the proposal will have an acceptable visual impact on surrounding areas”> What is the definition of acceptable? Could it be acceptable to have a negative impact on surrounding while a positive contribution could compensate in the same area?

The preferred options version of this clause only required applicants to “show, through a detailed design analysis, how the proposal visually affects surrounding areas”. The implied purpose of providing this design analysis was to enable officers, members and local residents to be able to make an informed assessment on the acceptability of the visual impact of a proposal. We felt that the way the policy was written did not make it explicit that this was the reason for providing the information, and that one could argue that to simply provide the information would satisfy the criteria. We have amended this in the proposed submission version to require applicants to “show, through a detailed design analysis, that the proposal will have an acceptable visual impact on surrounding areas.” We acknowledge that this criteria, like many planning policies, results in a degree of subjectivity, requiring value judgements to be made about whether something is acceptable or not. It would not be possible to write a policy to explain what is ‘acceptable’ in every case. A decision has to be taken about whether the visual impact of a proposal is acceptable, weighing up pros and cons and different people’s views. This criteria should not be read in isolation, as an assessment of the schemes acceptability needs to be made in terms of all of the criteria in policy DMS4.

During the Ram Brewery Inquiry, a lot of time was spent on the Applicant Visual Representations of the scheme. In his final report the Inspector wrote: “the use of a wide angle lens has the effect of distorting perspective and distance, and thus the spatial relationship between foreground and background. Existing buildings, and therefore the new ones, appear further away or smaller than they are or would be in reality, This was particularly apparent to me when I compared the AVRs to the actual views from the same viewpoints and is also demonstrated in the Wandsworth Society’s comparable 40º AVRs”. Therefore, regarding the visual impact, it should be clarified.

We suggest (change in bold) that DMS4 should require applicants to “show, through a detailed design analysis, that the proposal will have an acceptable visual impact on surrounding areas. The applicant’s Applicant Visual Representations must accurately represent what would be seen by the human eye.“

Question 4: DMS 4: Tall buildings xii: What is the justification for the removal of “Applications must describe how the proposal responds positively to any characteristic alignment and setbacks of the surrounding buildings”? (this has not been justified as a “duplication” anywhere else in the DMPD. In several parts of the borough the setbacks are important and a characteristic of many streets)

We take the point that this should have been retained – will be included in
submission version.

Site Specific Allocation Document

Question 5: How do you explain the contradiction between CS-PL13 “Taller buildings could not only help deliver significant regeneration benefits but also give a visual focus to the town centre” and S2UDS-2.34: “the centre has a rich historic heritage and as such is considered sensitive to tall building”.

The Core Strategy identified broad areas where tall buildings ‘may be appropriate,’ but acknowledged that some sites within these areas will be sensitive to, or inappropriate for, tall buildings. Further work has now been carried out in the Council’s Stage 2 Urban Design Assessment which looks at these broad areas to identify their appropriateness for tall buildings. The work that has been carried out in relation to Clapham Junction has concluded that the entire town centre is sensitive to tall buildings, and any applications for tall buildings will therefore have to be well justified in terms of policy DMS4.

Question 5b: In view of this contradiction between the CS and the S2UDS, what consideration was given to the government inspector demand [1] “to amend policies relating to the locations where tall buildings may be acceptable (Policies IS 3, PL 11, PL 12, PL 13, PL 14) to reflect the Council’s Stage 1 Urban Design Statement and to acknowledge the ongoing work in the Stage 2 Urban Design Statement and lower level DPDs.”

[1] Report to the London Borough of Wandsworth by Linda Wride Dip TP MRTPI – 14 June 2010

The changes required by the Inspector in order to make the plan sound were set out in a schedule of changes in Annex A of the Inspectors report. Change IC15 directed the changes to be made to Core Strategy Policy PL13b, and these were made in the adopted version of the Core Strategy.

Question 6: Height of buildings: how do you justify the choice of number of floors rather the height expressed in meters to measure the size of buildings (for example the PCS building in Clapham Junction is 5 storeys high but the hotel proposal granted on the over-side,155 Falcon Road, is 8 storeys for a similar size).

The Stage 2 Urban Design Study describes in para 2.1 that the heights are expressed in metres and this assumes an average storey height of 3 metres. This is based on a middle ground between average residential floor to ceiling heights which are generally 2.5m and average commercial floor to ceiling heights which are generally 3-4m. We will be including reference to this in the context of policy DMS4 in the submission version. Expressing building height in storeys rather than metres is preferable as people relate more to storeys than
metres.

Storeys may be preferable for the general public, but meters are certainly more accurate for architects and developers.

Question 7: Re-SSAD 4.1.1 Asda, Lidl, Boots and 155 Falcon Lane, SW11 – page 110
Can you explain the consideration given to the proposal regarding the loss of green space and the loss of value due to the reduction of land on the current Boots and Lidl location? What was the cost consideration and what is the feasibility within the next 15 years? (duration of the proposed LDF)

The proposal to realign Falcon Lane to the south of its current alignment would allow an active frontage to be provided on both sides of Falcon Lane. At present it is a two way road providing access and egress to three retail units that are directed at least in part to car-borne customers and carrying a variable level of through traffic. Falcon Lane has a relatively small pedestrian movement along it and in fact has only a footway on its northern side. On the southern side it has a narrow strip of green space. It is considered that a realignment of Falcon lane would permit the active frontage on the Southside. Within any realignment tree planting could be considered to mitigate against the loss of the existing trees on the green space. The realignment would clearly need to be undertaken in conjunction with the owners of the Boots and Lidl sites and the resultant scheme would need to be of a scale to achieve an appropriate economic viability. There has been no cost consideration applied to this proposal and the intention is to flag up a potential improvement. The Council currently has no plans to realign Falcon Lane. If a developer where to come forward it would be for them to undertake the necessary assessments of viability in the first instance. It is unclear as to the likelihood of such a scheme coming forward in the next 15 years with the existing economic
uncertainties. However, it is possible that one of the sites may come forward for development and identification in the SSAD of a potential wider redevelopment is considered worthwhile.

Question 8: Re-SSAD 4.1.2 Lanner and Griffon House, Winstanley Road, SW11 – page 112
How do you explain the contradiction between the current explanation and recommendation (including tall building seen as inappropriate) and the current developments of buildings up to 11 storeys? Is there an assumption that those development are temporary?

The application for the higher element in this location (2010/2279) was received at a time when the Proposed Submission version of the Core Strategy was a material consideration. At that time, the Core Strategy identified that tall buildings may be appropriate in locations which are well served by public transport, such as the town centres and Nine Elms near Vauxhall, or at other defined focal points of activity, providing they can justify themselves in terms of the benefits they bring for regeneration, townscape and public realm. As the site has excellent public transport accessibility, consideration of a tall building in this location was not contrary to policy at that time. As you know, the policy was amended by the Inspector to firm up that it is only the sites within town centres, focal points, and Nine Elms near Vauxhall that may be appropriate for tall buildings, and the reference to ‘locations which are well served by public transport’ has been removed. The Stage 2 Urban Design Study and the SSAD were updated after the change to the Core Strategy policy was made, and as this site is outside the town centre, it is identified as inappropriate for tall buildings. The more recent application for a lower building (2010/2853) was considered to be appropriate in its context.

Question 9: Re-SSAD 4.1.7 Peabody Estate, St Johns Hill, SW11 – page 118
Changes have been made within the town centre boundary to include the south of Peabody Estate. Therefore, as confirmed with the amended SSAD, this site is not anymore inappropriate for tall building but only sensitive. The Council cannot ignore that Peabody estate has been working for more than a year on a proposal including a 21, 13 and 10-storey tower (the tallest tower will be seen as 28 storey high from the bottom of the hill where it should be located).
Does this amendment mean to facilitate the redevelopment of Peabody estate by allowing tall building? What safe-lines have been considered to prevent the erection of tall buildings in this area in future. Why is there no mention of the government inspector’s recommendation that the site is not suitable for tall buildings?[2]

[2] The argument that the Peabody site is appropriate for tall buildings because of its high PTAL was rejected by the Core Strategy Inspector

Part of the site has been included in the town centre to promote active town centre uses along the St John’s Hill frontage allowing better integration into the town centre. The Inspector’s conclusion was that only sites within town centres, focal points of activity and Nine Elms near Vauxhall may be appropriate for tall building and this did not extend to all ‘areas with good public transport accessibility’. The Inspector did not conclude that the Peabody site is inappropriate for tall buildings. You will see that the SSAD identifies that buildings of five storeys and above will be regarded as tall buildings and this does not represent a change in the level at which the criteria in policy DMS4 will apply.

This answer is a bit twisting the argument. On page 33 of the DMPD and SSAD preferred options statement of consultation it says that “The argument that the Peabody site is appropriate for tall buildings because of its high PTAL was rejected by the Core Strategy Inspector“; many people will consider that the Council is trying to find another way of allowing tall building by including the site in the town centre boundaries. Therefore it should also be clarified as the change as strong implications in view of the current potential redevelopment of the site (“inappropriate” to tall building being currently changed to read “sensitive”).

We suggest the following change (in bold): “…applications for buildings of 5 or more storeys will be subject to the criteria of the tall buildings policy contained in DMPD Policy DMS4. In accordance with Core Strategy policy IS3d tall buildings in this location are likely to be inappropriate. The level of affordable housing will be set in accordance with Core Strategy IS5d.“

Policy IS5d is related to the percentage of affordable housing and therefore is not appropriate regarding tall buildings. On the contrary the reading of target for affordable housing can be seen as an incentive to build tall, in order to comply with the rules set out in CS IS5.

December 7, 2010 at 9:01 am 1 comment

Public Consultation on planning strategy document (SSAD)

Author: Cyril Richert

The planning inspectorate has now confirmed that the WBC planning strategy is sound and can go ahead with a number of amendments. Most of the changes were discussed at the public hearings in February 2010 and you can read our comment on the Inspector’s approval here. The Council has officially adopted the final version of the Core Strategy in its meeting in October.

The Proposed Submission versions of the DMPD (Development Management Policies Document) and SSAD (Site Specific Allocation Document), which provide detailed policies to support the delivery of the Core Strategy, are now proposed for public consultation up to the 10th December 2010.

We have already submitted comments in the previous consultation on the Site Specific Allocation Document in February 2010 (download in full HERE and article HERE). We are concerned that, with the length, volume and complexity of the documents it is very difficult, if not impossible for the general public to make a fair participation to the consultation. As highlighted also by other amenities societies, the Council should explain the changes made in the documents and why some suggestions for amendments were not implemented.

Below is an extract of the full submission, concentrating on comments on the Clapham Junction area. You can download the full submission HERE (pdf).

Proposed amendments regarding Clapham Junction SW11 (p109-118 of the SSAD):

For clarity we kept the same numbers for sections as in the SSAD document and highlighted our proposed changes in grey background.

4.1 Planning Policy Content: the case for tall buildings – page 109

The Core Strategy was amended to remove some of the specific references to tall building in Clapham Junction area, following the Inspector’s concerns that the current policy did not include specific reference to account being taken of the historic context when assessing applications for tall buildings.

Thus, PL13 clause b) was amended to add (amendment in bold):

Taller buildings could not only help deliver significant regeneration benefits but also give a visual focus to the town centre, subject to the qualifications set out in Policy IS3 and the criteria based policy on tall buildings to be included in the Development Management Policies Document.

Clause e) was also changed to remove (amendment in bold):

Taller buildings in this location could be justified due to the proximity of Clapham Junction station and its accessibility to high frequency public transport.

But the Council decided to keep the wording:

Taller buildings could not only help deliver significant regeneration benefits but also give a visual focus to the town centre, subject to qualifications set out in Policy IS3 and the criteria based policy on tall buildings to be included in the Development Management Policies Document.

However, in the main conclusions of her report , the government inspector wrote clearly:

1.7 My overall conclusion is that the London Borough of Wandsworth Core Strategy DPD is sound, provided it is changed in the ways specified in Annex A. The principal changes required are, in summary:

[…]

d) To amend policies relating to the locations where tall buildings may be acceptable (Policies IS 3, PL 11, PL 12, PL 13, PL 14) to reflect the Council’s Stage 1 Urban Design Statement and to acknowledge the ongoing work in the Stage 2 Urban Design Statement and lower level DPDs.

We look at the Council’s Urban Design Statement (S2UDS) and we can read page 26 (we put in bold):

2.34 [...] Accordingly any building of five storeys and above would be noticeable above the prevailing height within the town centre. Because of the need to protect the essential character of the buildings that define the main shopping streets, applications for development of 5 storeys and above will be subject to the criteria of the tall buildings policy contained in this document.

In a similar way we open the DMPD document and we can read page 22:

2.44 [...] The Core Strategy also acknowledged that there will be some sites within these locations that are sensitive to, or inappropriate for tall buildings, and that outside these areas tall buildings are likely to be inappropriate.

We are a bit surprised to see that there is no amendment to the Core Strategy Policy PL13 , although Policy IS3 states that c) tall buildings should not harm the character of the surrounding area and d) some locations within these areas will be sensitive to, or inappropriate for, tall buildings.

On page 109 of the SSAD there is mention of the Core Strategy Policy PL13 with the comment above. The meaning of this sentence is still nothing less than an encouragement to develop taller building in Clapham Junction area, while this has already been the subject of lengthy discussion during the Local Development Framework consultations.

Although there is a reference to the UDS and the DMPD, there is no clear mention of the sensitivity of the site in this global presentation (page 109). This is especially misleading when put in perspective with statements in the following pages 110-118) stating either:

the site is sensitive to tall buildings, and the height at which a development in this location will be considered to be tall is 5 storeys.
tall buildings in this location are likely to be inappropriate

Therefore the page should be amended to clearly state (in accordance to the Inspector’s requirement) that :

The centre has a rich historic heritage and as such is considered sensitive to tall buildings (see map below).
Because of the need to protect the essential character of the buildings that define the main shopping streets, applications for development of 5 storeys and above will be subject to the criteria of the tall buildings policy contained in this document.

In addition, we consider strongly that to measure the height of buildings by storey heights is unsound as these can vary considerably (8 storey approved for Falcon Road is the same size as PCS 4-storey building). Actual heights (meters) should be stated in all the document.

All pages should be amended to read, for example:

the site is sensitive to tall buildings, and the height at which a development in this location will be considered to be tall is 15 meters.

4.1.1 Asda, Lidl, Boots and 155 Falcon Lane, SW11 – page 110

Streets: A specific attention has been made to the piece of land between the residential houses (Mossbury road) and Falcon Road.

Pages 106 of the SSAD document it says:

Given the restricted nature of land on the south side of Falcon lane it is suggested that it could be re-aligned slightly to the north to allow frontage mixed use development with retail provision to the ground floor.

It doesn’t really seem to have considered some of the fundamental issues or the effects on existing properties either side of it.

As presented, the project is in complete contradiction with the Core Strategy encouraging the development of public realm and the provision of retail floorspace .

The current vision will involve the move of the current Boots and the loss of Lidl and the car park. Although it could be envisaged in theory, there is no consideration on feasibility and cost (who is funding what): the land to the north will dramatically be reduced in size and value, rendering the scope of future investment there questionable at best.

In addition frontage and main residential windows of any development proposed will be forced to face north and directly looking upwards at a railway embankment.

Is the south side of Falcon Lane a suitable site for future residential development? The rear gardens of the houses in Mossbury Road are already tiny. Any reasonable view will concede only two realistic solutions:

to offer extension of existing properties by land purchase
to redevelop the open area with public space/square.

4.1.2 Lanner and Griffon House, Winstanley Road, SW11 – page 112

Tall Building: Here it is worth quoting the full paragraph:

In accordance with Core Strategy Policy IS3d, tall buildings in this location are likely to be inappropriate. In accordance with DMPD Policy DMS4, the height at which a development in this location will be considered to be tall is 5 storeys.

Readers should appreciate that this policy is already in contradiction with the approval by the Council of the redevelopment of the site along Grant Road (Griffon House & Lanner House 6 Grant Road SW11) involving demolition of existing buildings and construction of two new buildings up to 11 storeys (without reference to the DMPD policies on tall buildings) to provide 452 self-contained studio rooms for use as student accommodation. In addition it was reinforced in September 2010 with a new application granted for an additional 6 storey building to provide 114 self-contained studio rooms.

Therefore the whole area is currently under construction with 3 buildings/high density up to 11 storeys and – except considering that this investment has any chance to be knocked down within the next 15 years – a full rewriting of the page in view of the current situation needs to be carried out, including changing the title of the section as Lanner and Griffon Houses do no longer exist.

4.1.3 Car park adjacent to Sendall Court, Grant Road, SW11 – page 113

Site Allocation: the document says:

Entirely residential, or a mixed use development with commercial use on the ground floor and residential accommodation to upper floors.

However on the previous page, Lanner and Griffon House, Winstanley Road, SW11 – page 112, the Nature Conservation statement says that the site is located within an area of deficiency in access to nature.

In addition, the visual representations provided by Berkeley first for their redevelopment of Lanner and Griffon House always presented an open space, used for public space, and balancing the very high density of their proposal.

In view of the adjacent developments already authorised and in excess of the guidelines provided in this same document, the site allocation should be reserved for public realm use only, such a square and public space.

4.1.4 Clapham Junction Station Approach, SW11 – page 114

We acknowledge the mention of the site being sensitive to tall buildings.

We agree on the justification providing that the site offers a real opportunity to provide the type of retail unit suited to the larger chain stores.

However the current presentation (including page 109) is actually re-using some of the planning of Delancey’s proposal without addressing the much needed issue of circulation between the two sides of the railway (Grant Road vs St John’s Hill).

The proposal map could be amended to present:

Current map (#64) vs Proposed presentation, including open path and a much larger coverage of the railway allowing better retail usage.

4.1.6 Land at Clapham Junction station, SW11 – page 117

The site allocation is for residential and safeguarding for transport use (Core Strategy an London Plan requirement). However we suggest that this paragraph should be amended to read:

Mixed use development to capitalise on the existing excellent rail connections into and out of London which will be improved even further by the East London Line extension and encourage one or more major employers to base themselves in this Town Centre; other appropriate uses include business, hotel, cultural, leisure and entertainment. Transport use should be safeguarded (Core Strategy Policy PL3).

4.1.7 Peabody Estate, St Johns Hill, SW11 – page 118

There is a small change in the guidelines for tall building between the SSAD published on the 27 Nov 2009 and the current proposed submission.

The SSAD 27/11/09 said:

Tall buildings: In accordance with Council’s Stage 2 Urban Design Study – Tall Buildings, applications for buildings of 5 or more storeys will be subject to the criteria of the tall buildings policy contained in the emerging DMPD. In accordance with Core Strategy policy IS3d, tall buildings in this location are likely to be inappropriate.

The current proposed SSAD says:

Tall buildings: In accordance with Council’s Stage 2 Urban Design Study – Tall Buildings, applications for buildings of 5 or more storeys will be subject to the criteria of the tall buildings policy contained in DMPD Policy DMS4. The part of the site within the town centre is identified as being sensitive to tall buildings, whilst on the southern part of the site adjacent to Wandsworth Common they are likely to be inappropriate, in accordance with Core Strategy Policy IS5d

You will appreciate that the previous part that we highlighted in bold, stating that tall building in this location are likely to be inappropriate (CS IS3d) has been removed and replace with only a mention of the southern part of the site, the remaining becoming only “sensitive”.

The fact that the Council cannot ignore is that Peabody Trust is currently working on the possible redevelopment of the estate, including knocking down the existing buildings and replacing them by high density constructions including a 21-storey tower, along with a 13-storey and 10-storey buildings.

The re-wording seems an attempt to address the arguments raised by developers to ease their planning: in the new version, their taller buildings will be located in the sensitive but no longer inappropriate location! It is noticeable that the paragraph does not mention anymore the Core Strategy IS3 talking about the impact on the surrounding area. Located at the top of the hill, a 21 storey building will appear to be about 28 storeys when viewed from Arding and Hobbs and will nearly double the size of the estate in Grant Road.

Therefore the tall building criteria should be changed to:

Tall buildings: In accordance with Core Strategy policy IS3c&d, tall buildings in this location are likely to be inappropriate.

The Clapham Junction Action Group wishes to participate at the oral examination

It is important the arguments set out above are presented and developed during discussion of policy on Site Specific Allocation.

Current map (#64)

Proposed presentation, including open path and a much larger coverage of the railway allowing better retail usage.

November 16, 2010 at 8:56 am Leave a comment

Analysis of the proposed DMPD – planning policy document

The Proposed Submission versions of the DMPD (Development Management Policies Document) and SSAD (Site Specific Allocation Document), which provide detailed policies to support the delivery of the Core Strategy, are now proposed for public consultation up to the 11th December 2010.

Patricia Poulter (a member of the Putney Society) sent us her analysis of the proposed DMPD document and highlighted changes that should be implemented. We have highlighted in bold green the comments that are also made in the submission from the Clapham Junction Action Group.

Author: Patricia Poulter

Response to the consultation on DMPD and SSAD proposed version 2

Consultation:

As experienced in the previous submission, the consultation documents are extremely lengthy and whilst a great deal of effort has gone into making them more comprehensible to the general public their sheer volume and complexity will deter a lot of residents from participating.

Changes made:

A number of changes have been made to the DMPD and SSAD versions compared to the earlier submission. These changes have not been explained within the documents as responding to any comment or request from either the Inspector, the residents, developers or amenities groups. It would have been very useful to know the reasons behind the alterations. It is stated that some amendments were made to avoid repetitions. The changes highlighted in the attached document do not fall in that category.

Tall buildings:

It is generally perceived that it would benefit all interested parties if the definition of “storeys” was also qualified in meters on planning applications leaving no room for misunderstandings. It is also thought that planning applications subject to tall buildings policies should clearly display the height in meters of adjoining buildings in their design and access statements as well as their plans.

The removal of the “buildings beyond x storeys will be unacceptable”( referred to by residents as maximum heights) has now been replaced by alternate wording that implies that intensive high rise development is acceptable. This is disappointing.

It is also clear, based on current applications coming through on the Upper Richmond Road, that the maximum heights quoted in the earlier submissions have been viewed by developers as acceptable heights. This is confirmed by the current applications for Tileman site and Tote.

The damage has been done! Applications are coming through seeking to double the heights of existing buildings. This is contrary to the Council Leader’s pre election pledge that buildings on the Upper Richmond Road should be replaced with buildings similar in scale to the existing ones.

Crime and disorder:

The issue of law and order in the proposed private public realms still has not been addressed in depth in this new version of the DMPD and is of serious concern to all residents.

Financial contributions from developers:

There seems to a tendency to seek contributions from developers for infrastructure and transport enhancements. This needs a great deal more transparency. Whilst it is probable that a substantial amount of the monies collected will go to improve the infrastructure where these developments will take place, it is important that these contributions are detailed at application stage and more visible to the public.

The Council must be seen to make realistic requests from developers for projects that have a clear implementation date and over which they have complete control. Collecting contributions from developers for improved train capacity for example is not within the developer’s nor the Council’s control.

Local distinctiveness:

The emphasis on local distinctiveness prominent in the previous submission has been removed from this new version, including the adherence to setbacks typical of the area where developments are proposed. This is a retrograde step.

Town Centres:

The changes that seek to reduce the percentage of A1 retail in secondary shopping frontages will result in loss of amenity for communities. Residents require to retain in their vicinity shops that serve the needs of the local community.

The Town Centre boundary change on the Capsticks site is based on the disingenuous statement that it is only a small part of the site. It actually represents more than two thirds of the site. This is unacceptable. It is the slippery slope to creating shopping frontages in residential streets. It is difficult enough the main core shopping parades fully occupied, it seems ill advised to encroach on residential boundaries. This should not be allowed.

Treatment of neighbours:

It is disappointing that neighbours of sites identified in the SSAD are treated unequally.

There is already sufficient bias towards residents in conservation areas who are well protected by conservation regulations.

There is however an inherent unequal treatment of neighbours of sites outside conservation areas. This is undemocratic, unjustified and assumes there are various classes of citizens. All residents deserve equal protection from harmful development.

You can download the full analysis DPMD HERE.

November 15, 2010 at 8:53 am Leave a comment

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Clapham Junction Action Group

Posts filed under ‘Planning strategy’

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Analysis of the proposed DMPD – planning policy document

Response to the consultation on DMPD and SSAD proposed version 2

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