Anita Anand chaired the forum meeting to discuss Richmond’s recovery, on Thursday 11th November 2021.
Anita Anand, Richmond Society Patron and author, broadcaster and host of the BBC’s Any Answers, moderated the discussion with:
Gaucho, which operates a restaurant with an outdoor area on the towpath near Richmond Bridge and the Richmond Hill conservation area, applied for planning permission to operate a seasonal restaurant on part of Richmond Landing Stage. The application envisaged Jumbrellas, an outdoor cinema and take-away service. The application was opposed by The Richmond Society and River Thames Society as well as several nearby residents, and Richmond Council’s Planning Committee rejected it in robust terms.
At the same time Gaucho applied for a licence to sell alcohol from the Landing Stage not only to diners there but also as a take-away. We opposed that too. Richmond Council’s Licensing Committee considered that there were no grounds to justify refusing the application and granted a licence (which excluded operating an outdoor cinema on the Landing Stage). Although this seems perverse, the Council’s Planning and Licensing committees operate under different statutory regimes.
You might therefore have been surprised to see that Gaucho is operating a restaurant on the Landing Stage. It is relying on the Government’s extension to permitted development rights which temporarily allows restaurants to operate for 56 days in circumstances which would otherwise require planning permission. As Gaucho now has a licence to sell alcohol on and from the Landing Stage it can operate its extended restaurant for 56 days even though it was refused planning permission.
Neighbours who opposed the planning application were concerned about additional noise and disturbance. In addition to these reasons The Richmond Society opposed it because of the encroachment on Metropolitan Open Land, the river and use of the river and increased congestion on an already crowded towpath with adverse effects which may result from greater light pollution.
For many years we have opposed extending commercial operations on the towpath, particularly that part of it which is upstream or south of Richmond Bridge. The rural and special setting must be protected, and creeping commercial encroachment will ultimately destroy that which residents and visitors alike come to enjoy. The photograph shows how the new operation on the Landing Stage impedes the view towards Richmond Bridge. The blue covers are instead of the Jumbrellas referred to in the planning application which would have been even more intrusive.
We understand that COVID has taken a significant financial toll on local businesses and that relaxing the regulations is intended to boost the hospitality sector of the economy. However this must be balanced against the detrimental effect on the local environment.
Robert Jenrick, Secretary of State for Housing, has just declined to call in the development plans for the Homebase site in Manor Road. This means that the Mayor of London’s decision in October to approve the application stands and that the development will proceed, subject to the developer Avanton agreeing s106 terms with Richmond Council and the GLA securing the affordable homes and other contributions to make the development acceptable in planning terms.
Richmond Council despite expressing “extreme disappointment” at Mr Jenrick’s decision, has apparently decided not to seek a judicial review of the Mayor’s decision so unless a third party does so the development will proceed.
The development approved by the Mayor is for 453 new residential units in five blocks ranging from four to eleven storeys. This contrasts with the scheme which Richmond Council rejected in July 2019 which proposed 385 homes with buildings of four to nine storeys. The Richmond Local Plan has a maximum of six storeys!
The pictures show the scale of the proposed buildings compared with the current setting.
Ironically the letter from the Ministry of Housing says: “The Government is committed to give more power to councils and communities to make their own decisions on planning issues, and believes planning decisions should be made at the local level wherever possible.”
The Mayor of London and the Government have ignored over 700 objections to the original plan rejected by Richmond Council. After the Mayor took over the role of planning authority in place of Richmond Council, the plans were further revised to increase density and height of the buildings. Thus the original objections which were principally about the effect on the immediate community, that the scale of development was over development of the site and would change the nature of the area and that the local amenities, especially transport, would be inadequate for the number of residential units applied even more to the revised plans but all were rejected. In addition the provisions of Richmond’s Local Plan have been overridden.
In this case local appears to mean regional!
A final point is that this development may set a precedent for other applications for buildings in excess of six storeys. Less “rus” in “urbe”.
Since our last update the Council met on Tuesday 26 January and passed the following resolution which was proposed by Cllr Fleming (South Richmond), seconded by Cllr Baldwin (North Richmond), and received unanimous approval from councillors:
“The Council expresses its disappointment that the Secretary of State has not called in the Homebase application which the Mayor has resolved to approve though it would damage the character of the area. It recognises the strong feelings of residents on the subject and will continue to explore with them and their Ward Councillors the implications of the application and the scope for amelioration or challenge.”
It is heartening that this was a cross-party resolution reflecting the approach of Richmond Councillors and we look forward to working with them and local residents. It would seem that the Council has been advised that a successful judicial review of Mayor Khan’s decision is unlikely and that it would not be an appropriate use of resources to pursue one.
There remain issues about the weight the Mayor attached to the site’s good transport connectivity as part of his reasons for approving the development despite this not being so. For example, the hearing report claimed that North Sheen is served by 8 trains per hour to Waterloo despite 4 of them going away from Waterloo on the loop. Likewise, no account was taken of the changes announced by TfL in June 2020 reducing the bus services. Stephen Speak raised this point at the Council meeting and we hope the officers will consider the issue.
The Richmond Society and The Kew Society jointly submitted a statement of reasons objecting most strongly to the latest proposals to develop the Homebase site in Manor Road.
The two Societies’ joint submission in advance of a GLA hearing sched-uled for 1 October can be read by clicking the image or this link.
The Secretary of State for Housing, Communities and Local Government has issued a holding direction to the Mayor of London confirming that he will call in the application if the Mayor approves the application.
The Richmond Society has formally objected to the latest proposals for the Homebase site as part of the consultation closing on 3 September. After Richmond Council refused the application (to which the RS also objected) the Mayor of London exercised his powers to take over as the planning authority and indicated that more affordable housing was required. The current proposals are the second version submitted by the developer to meet that objective.
A public hearing is set for 1 October and the RS and Kew Society are proposing a joint submission given that we are likely to be allowed 5 minutes.
RS’s objections remain the same as originally expressed: over-development of the site because of density, excessive height and pressure on services which already cannot cope in the form of utilities (old gas and water pipes), a reduced bus service round Manor Circus resulting from TfL implementing its proposals to be done in December 2020 and an inadequate train station at North Sheen.Details of the current proposals are available in this press release on Richmond Council’s website. The public consultation runs from 6 August to 3 September 2020 and full details are available on this page on the GLA website.
Copies of the latest proposals are available to view on this page on the GLA website
The texts of the RS’s objections are set out below:
“I write on behalf of the Richmond Society with 1300 members to object to the latest revisions to the Application which are the subject of the current consultation. The proposed changes do nothing to alleviate our original concerns in our objection of 11 May 2019– indeed the problems are exacerbated by the increased height and density proposed with resulting pressure on local services.
The new proposals envisage increasing the number or residential units by 69 to 453 – even greater density.
One block will be 11 storeys, one 10 and two 8 each (compared with the original proposal of 3 blocks of nine storeys each) with additional unspecified height for plant. The new proposals would mean towers nearly double the maximum of six storeys envisaged under the Local Plan. The area surrounding the Homebase site comprises low rise buildings so the addition of the proposed four towers will change the character of the area significantly and result in the site being overdeveloped.
The increased density will put further pressure on local services and amenities just after TfL announced in June 2020 that it will implement changes on which it consulted. These will result in fewer buses in the Manor Road vicinity when the new plans envisage more than 1000 extra residents: surely a lack of a coherent plan. This is quite apart from the financial predicament of TfL and the uncertainty surrounding current rail franchises which threaten the current provision of services.
A development of this size will put additional pressure on the current infrastructure. Water supply here is in poor condition with many of our chalk streams being drained; there are inadequate sewage treatment facilities (the number of CSO spills is appalling); cold water mains, and old gas pipes are unable to cope with existing demands. Indeed in January a large part of central Richmond was without gas for several weeks when an old water pipe burst next to an old gas pipe.
May 2019 objection: The Richmond Society supports the principle of a residential led mixed use scheme for this site and its contribution to the borough’s affordable housing stock. However, while we recognise the high quality architectural design, we are concerned that the density of development and its consequent height and mass results in the site being overdeveloped. In particular, three buildings of nine storeys (plus the extra unspecified height for plant) is significantly taller than the six storeys envisaged under the Local Plan as the maximum for this location. Furthermore, we understand that the Council has required a car free development for the site, but this suitability must be re-confirmed before a planning consent can be given because TfL’s plans to reduce bus services to Manor Circus. If the bus service cuts are implemented, then it would cause the site’s PTAL (Public Transport Accessibility Level) to fall below 5 – i.e. below the Council’s accepted threshold. Residents have also questioned whether the applicant’s parking stress survey is realistic and this should be verified by reference to the Council’s parking surveys commissioned by the Highways Department for CPZ proposals in 2015. Finally, there is conflicting information in the documentation regarding the site’s red line boundary and it is unclear whether the bus terminus requires s106 protection. That position should be explicitly confirmed noting that The Richmond Society supports improvements to the bus, rail and cycle facilities locally”
The Mayor of London is running a public consultation on the proposed development of the Homebase site at Manor Road in Richmond..
Last year, Richmond Council’s Planning Committee refused an application for the redevelopment of the Manor Road site currently occupied by Homebase. There had been 717 objections to the application.
The council’s refusal was based on several grounds, including:
The Mayor of London subsequently called in the planning application and is now running a public consultation with a view to a public hearing later in the year, provisionally scheduled for Thursday 1 October.
Details of the current proposals are available in this press release on Richmond Council’s website. The public consultation runs from 6 August to 3 September 2020 and full details are available on this page on the GLA website.
The Richmond Society will be submitting its comments on the latest amendments made to the application by the developers, Avanton. Copies of these documents are available to view on this page on the the GLA website. Comments should be sent by email to the Greater London Authority at ManorRoad@london.gov.uk by 3 September 2020.
Janet’s funeral was held on Tuesday 9th June at 3:30pm. Janet’s son, Chris Locke, presented the eulogy. The Order of Service is available at this link.
My mother was born in Leicester on May 16 1928, the only child of Monty and Nellie Furney. Janet’s father was a tailor, her mother a milliner and seamstress. By 1928 Monty had become a regional inspector for menswear chain Burton’s, which meant a series of moves around the country as his postings changed. This peripatetic existence, with her father often away, I think contributed greatly to my mother’s self-reliance and independence throughout her life.
Much of her early childhood was spent in Cambridge, but by the war the family had moved to Buckhurst Hill on the Essex fringes of London. Here her interest in architecture was sparked when a local builder won the pools and bought a plot of land to develop in the fields at the end of their road.
She was fascinated by the plans and resolved to become an architect, a rare career then for a woman, but she was determined. Monty went to see the headmistress, Miss Essame, of her boarding school, Queenswood near Hatfield, and was directed for advice to the head’s brother, who worked for the Royal Institute of British Architects.
She enrolled in the Bartlett School of Architecture at the end of the war, one of only five or six women in her academic year, developing that passion for beauty and against ugliness that animates William Blake’s Jerusalem, which we will sing later. In 1950 she was chosen by the Society for the Protection of Ancient Buildings as one of four Lethaby Scholars to study conservation work. At the SPAB building in Great Ormond Street she met Peter Locke, a fellow Scholar who had studied at Brixton School of Building. They were introduced by the SPAB’s secretary, Monica Dance, who when they fell in love and got engaged had to ride a storm of protest that she had turned the Scholarship into a matrimonial agency by admitting females.
They married in 1952, despite her parents’ disapproval who refused to attend. Typically my mother stuck to her guns and her parents were later won round. It was a long and happy marriage, lasting more than 60 years before Peter’s death in 2012. Both practised as architects, but Janet halted in 1957 for my birth in that year and that of Susan in 1959 (Sue died in 1993, leaving two grandchildren, Tom – who died in 2015 – and Katie, who were a great joy to Janet and Peter).
Janet’s early married life with Peter was in a garret in St John’s Wood, in a top-floor room shared with a hamster called Humphrey who tended to live in the sofa and next to a boiler they nicknamed Krakatoa. Poor as they were, they still would manage the occasional treat of a night at the theatre, including one night when they had battled through a pea-souper to their seats in the gods to find the inside of the theatre full of fog. Luckily a distant voice summoned them down to the front stalls to join the other dozen people who had made it as that night’s audience. Revues were a particular favourite, which is why we will hear both Flanders and Swann and Joyce Grenfell later.
In the mid-Fifties they moved to Blackheath, to a rented flat where I and Sue appeared. This was the period when Peter had just begun working with Donald Insall as the two of them started their architectural practice specialising in the renovation they had first learned on the Lethaby Scholarship. For his work my father bought a succession of cheap ancient cars – I remember a Rover with a running board and a pre-war Austin Seven – underneath which he would spend most of the weekend doing repairs. No wonder Genevieve, the Fifties movie about the London to Brighton veteran car rally, was a film dear to them. We shall hear the theme from that later too.
Through all this, as we moved in 1962, buying a garden flat on the other side of Blackheath, my mother ran the household with endless cheer and resourcefulness. She was always ready, no matter how busy, to answer my childish questions. The only occasion she failed was when I held up a bottle of squash and asked whether “dilute to taste” meant delightful. Distracted by washing up she replied “Yes darling”. She was mortified when I recalled this years later.
Much more characteristic was when in 1967 I returned from primary school with the news that three of my class would be spectators as the Queen knighted Francis Chichester at the Royal Naval College. They would be chosen on a test of knowledge about his round-the-world voyage. I of course was hellbent on winning but knew nothing of Gipsy Moth IV and its solo skipper.
My mother must then have spent the whole of the next day in a public library because that night, the eve of the quiz, she coached me so thoroughly that I sailed through and was duly to be seen on TV sitting cross-legged in the front row of all the Greenwich tinies watching the investiture.
My mother returned to practice once we children were old enough, working for a local architect and then advising on planning applications for Lewisham council.
In 1978 they moved to Lewisham, buying and renovating a large mid-Victorian house there. It spoke to Peter’s regard for her as the better architect that he decided she should be in charge of the plans while he acted as general contractor.
In 1985 they moved to Richmond, first to a two-floor flat in Church Road and then in 1994 to a cottage in Albany Passage. They threw themselves into Richmond life, making many new friends and becoming stalwarts of the Richmond Society, of which my mother was vice-chair and served on the committees vetting planning applications and judging the annual building awards. They also fulfilled a lifelong love of travel as Peter eased into retirement.
After Peter’s death in 2012 Janet was determined to live an independent life, travelling solo abroad and continuing to absorb herself in matters cultural, historical and architectural. In 2017 however she decided, with typical practicality, that it was time to go into a care home, and the following year she moved into Lynde House in Twickenham, where she passed her remaining time amid great comfort and kindness.
I have received so many wonderful tributes, both from those in this room and those prevented from attending today. They recall Janet’s “architecturally perfect cakes, precise hairdos and her tinkling chandelier laugh”, “her unfailing kindness, generosity of spirit and interest in others”, her enthusiasm, hospitality and positivity and much, much more. Above all they concur, as the nurse who broke the news to me said, that she was “such a lovely woman”.
Go well, mother, and go with all our love.
A further short appreciation by Paul Velluet of Janet’s life and her work for The Richmond Society can be found here.
It was with great sadness that the Society learnt of the death last weekend of Janet Locke, who made a major contribution to the Society’s key role and work in protecting and enhancing the character and amenity of Richmond between 1986 and 2008.
Janet served on the Executive Committee from 1986 until the end of 2002 – including several years as the Society’s Vice-Chairman – and on the Conservation, Development and Planning Sub-Committee from 1986 to 2008.
Across those years, Janet led the Society’s important work in monitoring and commenting on development proposals located within the Society’s area of interest, involving careful scrutiny and consideration of many hundreds of planning applications affecting Richmond each year and drafting and submitting representations in collaboration with her committee colleagues on those specific proposals raising issues of concern to the Society. In addition and importantly, Janet also contributed significantly to the Society’s own conservation and improvement projects and in the assessment stages of its Annual Awards Scheme.
The Society owes an enormous debt of gratitude to Janet for her dedication, enthusiasm and wise advice across the years.
P.V. 26th May, 2020.
For details of Janet’s funeral service, please see here.
On 4th February, Stephen Speak on behalf of the Richmond Society wrote to the Planning Casework Unit requesting that the Secretary of State for Housing, Communities and Local Government issue an urgent holding direction to allow a call in of the Mayor of London’s expected consent of the proposed Manor Road development. Here’s his letter.
Dear Sir/Madam,
I write on behalf of The Richmond Society to ask the Secretary of State to place an urgent holding order, with a view to calling in the Mayor of London’s expected consent of a planning application by Avanton Richmond to build 433 residential units at 84 Manor Road, Richmond, TW9 1YB (currently a Homebase and Pets At Home stores).
The Richmond Society is a civic amenity group with over 1,300 members across an area of benefit that incorporates the site.
The original proposal for 385 units was refused by London Borough of Richmond (“LBRUT”) in July 2019 under their reference 19/0510 which cited failings under the NPPF, the London Plan and the Local Plan. Subsequently the Mayor of London used his powers to call in that decision and has taken over the duties of the Local Planning Authority.
On 22 November 2019 the developer submitted new proposals directly to the Mayor which are significantly different from, and materially worse than, those previously refused by LBRUT. Despite the 12% uplift in total units, increases in the heights of several blocks, a different community provision and the addition of a new block the Mayor is treating these plans simply as an amendment. There has been no further consultation between the developer and residents regarding the new proposals while administrative errors by the Mayor’s office has meant that previous objectors were informed late about the changes (or in some cases have not been advised at all).
As highlighted below we are concerned that, in the effort, to reach his affordable housing targets for London the Mayor has taken a pre-determined position over this development. His intervention is inhibiting proper scrutiny of these significantly amended proposals, ignoring multiple planning breaches and facilitating the unsustainable overdevelopment of the site. Details of the amended proposals are on the GLA website and can be accessed through this link: https://www.london.gov.uk/what-we-do/planning/planning-applications-and-decisions/public-hearings/homebase-manor-road-public-hearing (or as a shortened version here: https://bit.ly/2RVE0qU).
A public hearing is not expected before February 17, but we are aware that the Mayor has given his planning consent very quickly after call-in hearings having previously agreed the s106 contributions with developers. An urgent holding order from the Secretary of State would appear to be the only way of ensuring that the developer’s amended plans are sustainable and can meet the NPPF’s economic and social objectives.
The key economic concerns relate to weaknesses in the transport infrastructure at this location while the social objective failings pertain to the negative local impact of the design’s height and mass. The principle of building homes on this brownfield site is accepted, although the loss of two major retail outlets is regrettable.
The NPPF expects planning decisions to ensure that developments:
In refusing the original proposals LBRUT planning officers found failings under all these criteria and the revised proposals are worse.
The Building Better Building Beautiful Commission was appointed under the late Sir Roger Scruton to advise the government. Its report issued on January 30, 2020 recommends interalia:
Stewardship: Quick profits should not be taken at the cost of beauty and community: “Hence places, not units […], not faceless architecture that could be anywhere.”
Neighbourhoods: create places not just houses. “Too much of what we build is […] overly dense ‘small flats in big blocks’ (on brownfield sites)”.
The amended development proposals are exemplars of exactly the failings that the Commission is urging the government to avoid!
Census data shows that residents of the local area are already heavily reliant on public transport for travel to work (at 47%).
Network Rail objected to the original application due to concerns over the anticipated levels of rail trip generation. They also expressed concerns that the uplift in rail users and pedestrians will significantly impact on the safe and efficient operation of the level crossing on Manor Road immediately next to the southern boundary of the site. We understood that the expected provision of CIL funds did not overcome the harms identified and it remains unclear whether the developer will adjust this through s106 funding for the new proposals.
The Draft London Plan calls for car free parking provision in all areas of PTAL 5-6. The site currently has a Public Transport Accessibility Level rating of 5 (“excellent”). However, this rating is entirely dependent upon bus services to Manor Circus (just north of the site) being maintained. In December 2018 the Mayor, though Transport for London, issued proposals for cutting certain bus services which, if implemented, would result in the site’s PTAL falling one notch. At PTAL 4 the site would no longer meet the car free standard and the proposed housing density is unsustainable. The Mayor should therefore be required to give a formal undertaking to retain a range of frequent bus services sufficient to ensure that the site’s PTAL 5 rating can be maintained in perpetuity.
LBRUT’s Transport Officer raised concerns over the validity and findings of the developer’s parking survey which was not undertaken in accordance with recommended methodology. Local parking stress was therefore understated and, despite the car free and CPZ proposals associated with the development the reasonable parking needs of its visitors, carers, trades people and similar is simply not available in the wider area.
The draft New London Plan, as amended by the inspectors, sets a 10 year housing target for Richmond borough of 4,110 units. This site on its own would therefore be contributing more than a year’s housing requirement for the whole borough. This intense level of development, plus the recently approved proposals for the nearby Stag Brewery development on the other side of the South Circular Road, plus the nearby sites identified in the Local Plan, is adding cumulative pressure onto a community and physical infrastructure already struggling to cope.
The developer’s revisions mean that the plans now provide for 40% affordable housing and qualify for fast track determination by the Mayor without providing viability information. It is unclear to what extent Mayoral grant is supplementing the developer’s profit at the expense of the community.
Of the 40% affordable homes, 50% are intermediate (split between shared ownership and London Living Rent) with 50% social (affordable rent) broken down by units as follows:
| Affordable Housing Mix | Studio | 1 bed 2 person |
2 bed 3 person |
2 bed 4 person |
3 bed 5 person |
3 bed 6 person |
Total Units / Hab Rooms |
| Affordable Rent | 0 | 12 | 21 | 15 | 19 | 8 | 75 |
| Shared Ownership | 0 | 23 | 12 | 23 | 0 | 0 | 58 |
| London Living Rent | 0 | 22 | 10 | 6 | 0 | 0 | 38 |
| Total | 0 | 57 | 43 | 44 | 19 | 8 | 171 / 483 |
The developer’s statement goes on to state that gross annual income requirements for the Shared Ownership and London Living Rent are as follows:
| Unit Type | London Living Rent | Shared Ownership 2019/2020 |
| One Bedroom | £50,614 | £62,765 |
| Two Bedroom | £56,271 | £80,072 |
Richmond has met its housing targets under the London Plan and, while more genuinely affordable housing is welcome, the majority of the provision from this development requires that occupants earn salaries out of reach for many in local housing need. The plans are not providing enough of the social rent housing that the borough requires. With so many units directed towards high earners they will (of necessity) need to commute to the better paid jobs in central London. This will load incremental demand onto the already over stretched train network that is accessible from the station nearest to the development at North Sheen.
The developer engaged with Richmond’s Design Review Panel which reported in February 8, 2019 “that the development as a whole represents a jump in scale from the surrounding suburban context. The Panel feels that the proposed height of the scheme density is still overly ambitious.”
Against NPPF and local planning expectations the Panel’s comments appear to have been ignored by the developer and by the GLA. The amended plans have increased the height of three blocks which further emphasises the jump in scale to make the development proposals even more incongruous in the context of the surrounding area.
The unrelenting scale and mass is more commonly found in an urban context and is inappropriate for this suburban location. The nearby conservation areas will always restrict the maximum allowable height of surrounding buildings and cause this development to appear in perpetuity as a monolithic mass.
In their planning statement the developer asserts that “mature trees within the Royal Botanic Gardens World Heritage Site at Kew will prevent the amended proposals from being seen.” And “the uppermost parts of the development will be visible from the top of the Grade I listed Pagoda in Kew Gardens.” The picture above shows the view towards the site from the top of the Pagoda. The development will be clearly visible in this panorama as a clustered mass behind and to the left of the Towers. Three of the buildings in the development are equivalent in height to the Towers and so it is apparent that significantly more than just the uppermost parts will in fact be visible. Furthermore, many of the mature trees that the developer expects to block the view from Kew Gardens will lose their leaves over winter. We therefore disagree with the developer’s opinion that the visitor experience and significance of the Royal Botanic Gardens would be unaltered.
While not a locally designated view, the vista from Manor Circus to the greenery of Richmond Park is important and incorporates the spire of St. Mathias church on the horizon as a reference. This view will be blocked due to the height of the development.
Many of the objections raised by LBRUT to the original development are unaddressed by the developer’s amended proposals and have been made worse. In particular we highlight the following comments made by professional planning officers relating to height and mass: (paragraph numbers refer to the LBRUT officer’s report provided to the Planning Committee):
107. The site is not located within an area identified for tall or taller buildings and, overall, it is considered that the scheme fails to demonstrate a thorough understanding of the character and built form context of the immediate area, which the site forms a part.
108. The proposed height across the site is significantly taller than the predominant building height in the area. In particular, the 9 storey buildings in the centre of the site are wholly excessive in height, which will be dominant, overwhelming, unrelenting and visually intrusive, and will result in a looming impression, in particular from Manor Grove, Manor Road, Trinity Road and Dee Road. Nor is it deemed the townscape appraisal and visual assessments provide design justification to warrant such height. [The height as amended is increased to 10 storeys with plant on the roof]
115. The site is within close proximity to designated (Sheendale Road Conservation Area) and non-designated (BTMs on Manor Road, Trinity Road) heritage assets and the height, scale, mass and uniform design of the development would result in an imposing presence and a harmful visual impact on these heritage assets, ultimately resulting in harm to their setting in conflict with the NPPF and LP 3, LP 4 of the Local Plan.
158. The applicant’s Planning Statement identifies the need to protect neighbourhood amenity but does not adequately address considerations regarding the visual impact on surrounding properties. These concerns were expressed to the applicant throughout the course of this application and earlier pre-application process. The applicant has elected not to modify the proposal.
The officer’s conclusion in paragraph 158 rather reflects the developer’s disdain for the local planning process and for affected local residents. The developer has instead made clear from an early stage that they have preferred to work with GLA officers knowing that the plans would ultimately be subject to Mayoral approval. The GLA’s written advice to the developer to build taller in contravention of local policies is suggestive of Mayoral pre-determination for a political aim which would be an abuse of process.
The developer dismisses much of the Daylight/Sunlight impact on surrounding buildings (especially those to the north) because they consider the local VSC component to be atypical for an “urban setting” due to the underdeveloped nature of the site. This disregards the actual situation as experienced by residents and also the fact that it is a suburban site and should be treated as such.
Of great concern to existing residents is that the increased heights and addition of Block E will cause even greater harm especially to nearby properties in the area known as the “Trinity Triangle” to the northwest of the site. The developer’s own reports show their amended development proposals would reduce the proportion of windows in surrounding properties that comply with strict BRE Guidelines (VSC loss of under 20%) from 84% to 79%. Furthermore, residents’ analysis of these reports has highlighted that windows in some affected properties have been excluded – which understates the impact.
The amended proposals remain in conflict with the NPPF, the New London Plan and numerous policies in LBRUT’s Local Plan.
Paper based Mayoral affordable housing targets are being used to justify the site’s overdevelopment with unsustainable repercussions for the community. The affordable housing contribution does not include enough social rent housing and that should not overrule NPPF expectations for sustainable developments that are subject to proper scrutiny and comply with adopted planning rules.
We request that the Secretary of State issue an urgent holding notice to the Mayor concerning these amended proposals while he considers whether, or not, they should be called in for further scrutiny. We will of course provide further assistance and evidence as required.
Yours faithfully,
Stephen Speak
Trustee
Deadline 20 December 2019
In July, Richmond Council, on the recommendation of officers, resolved to refuse a planning application for this site by owners Avanton Richmond Ltd on a number of grounds including: an under-provision of affordable housing; design (siting/layout/height/scale/bulk, etc); visual impact on neighbouring residents; living standards of future residents of the scheme; energy efficiency.
Later that month, the Mayor of London declared that he would become the Local Authority for the purposes of determining the planning application, and has been in “pre-app” discussions with the owners since that time.
This has recently resulted in an amended set of proposals including a higher provision of affordable units, up from 134 (35%) to 171 (40%) through an increase in the total number of units from 385 to 433 including a new block above the bus layover.
The next steps are a public consultation, which runs to Friday 20 December, followed by a public hearing, the date of which has not yet been advised.
In the meantime you can access the details of this revised application through:
You can also view them by going along to City Hall, The Queen’s Walk, London SE1 2AA from 9 am to 5 pm weekdays.
If you intend to make representations to support or object to the revisions these should be submitted by email or in writing to the following addresses by 20 December 2019:
The Richmond Society will be considering the proposals too and will be commenting in due course.