Anti-Social Behaviour in Richmond

The Richmond Society is deeply concerned at anti-social behaviour and crime in the town and surrounding area as COVID-19 lockdown measures have eased. We intend to work closely with the Council, police and others to deliver improvements.

In the meantime we urge you strongly to tell the police about further incidents. You should register incidents online at www.met.police/uk. If you seek police attendance call 101 and the police will register the call and decide the priority. If you need support right away call 999.

The Society’s Trustee responsible for the town centre, licensing, anti-social behaviour and police liaison is Peter Willan. He writes:

Richmond has always been a magnet for visitors from all over London during the summer. Now it risks being the destination of choice for visitors who, under the influence of alcohol or drugs, cluster and create disorder and intimidate, threaten and scare residents and other visitors. They fight and brawl, and violence erupts.

Urination and defecation in open spaces and close to homes has reached crisis levels. Noise and music disturbance, sometimes to 3:00 am, has escalated. ASB, disorder and crime in Richmond’s evening economy have risen seriously.

A large virtual public meeting arranged by the Council Leader, Cllr Gareth Roberts, with a presentation by the Police Borough Commander, Chief Superintendent Sally Benatar, was attended by Society members. Members of the public, including two Trustees and other members, asked questions. A video recording of the conference can be viewed here.

Pro-active intervention and deterrence by the police and the Council’s Parkguard last weekend using dispersal and other powers reduced the number of more serious incidents and the edginess that pervaded the Green, the Riverside and the Terrace and Terrace Gardens on Richmond Hill.

The re-opening of pubs, bars and restaurants this coming Saturday and the Government’s easing of licensing laws could result in Richmond’s streets and open spaces becoming one large beer garden.

We are discussing with the authorities the lack of lavatories and the prevention of the more serious incidents of crime and disorder including drugs dealing. Disruptive people must be discouraged from coming to Richmond. The supermarket supply of alcohol to under-age drinkers is also a high priority for attention.

The Society seeks a much-needed update of the Council’s 2011 observational study of Richmond’s evening economy. We are also reviewing the application of legal powers of dispersion and Public Space Protection Orders. We are discussing with the authorities fixed and mobile CCTV coverage, and signage informing people of ASB laws and penalties.

We will continue to update you and welcome your observations about any part of the town and its surrounds that need attention. Please send any comments to us at www.richmondsociety.org.uk/contact.

Janet Locke: funeral service on 9th June

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.

Eulogy

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.

Life under Lockdown

Social distancing, self-isolating and the new normal

In the Richmond Society News of 23rd April, our chairman Barry May called for photos, short audio or video clips (less than one minute), or stories (less than 100 words), on what’s different in Richmond since social distancing and self-isolating became a thing and a new normal changed us. Here are some of the contributions.

A quiet day on Water Lane

Lamar Raine, one of The Richmond Society’s volunteers, has just completed a pen and ink and watercolour showing an all but deserted vista down to the river. She writes:

“My street, Water Lane, is now usually full of people walking to and from the river. As I watched the trees leaf up since my quarantine 27 February, having come back from Half Term in Italy, this painting shows the change. More birdlife than people and not a plane in the sky. A lovely change! However, it also shows our fabulous but now closed, new local, ‘The Waterman’s’. Indeed a sad change. Much work had gone into its ten month makeover with such a well received opening last November. Richmond Society members may know its great food, fabulous wine and warm hospitality – Karen Feeney generously hosted a ‘Thank You’ drinks for our supporters there 28 February. Let’s hope it can re-open again very soon!”.

Watercolour of the view down Water Lane, Richmond, painted by Lamar Raine

Tango by the Thames

Loic Verrall writes: “My Grandfather, Eric Ruggier, who is 88, and loves dancing Tango. Well, with the restrictions of social distancing, he has managed to work out how to continue dancing Tango, with his dancing partner, Jola, by using a broomstick!”

Enjoying the quiet

Lisa Perez writes: “There’s no boating allowed on the Thames during lockdown, but at least we can sit on the moored boat and enjoy the quiet”.

Photo of dog looking out from bow of boat on Thames

Safe Distancing

Our first contribution was from new member Sandra Thwaites:

By 7am I am walking at a prompt pace along the Thames path to avoid other path users that increase in numbers later in the morning.

With the weather so glorious the temptation to stare at anything other than four walls has never before been so precious. Whereas most people are considerate enough to maintain a safe distance on the river path there are unfortunately, as with any restrictions on human behaviour, the odd few who appear to be completely oblivious to me. In such situations I take responsibility for my own health and move out of the way.

Janet Locke 1928-2020

Photograph of Janet Locke at Trumpeters' House 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.

Richmond under Lockdown

How are you coping with life under lockdown? What has changed for you in these strange times of keeping your distance from others; shuttered shops, pubs and restaurants; controlled access to supermarkets; streets emptied of traffic and fewer people about?

Every cloud… Have you noticed the clearer, unpolluted skies enabling you to see farther and allowing birdsong to be heard in our gardens and open spaces?

Send us a photo, record a 1-minute audio or video clip, write a story (100 words max), on what’s different in Richmond since social distancing and self-isolating became a thing and a new normal changed us.

Photo of benches at Bridge House Gardens with Lockdown Richmond hashtag If you use social media – Facebook, Instagram or Twitter – go to the Richmond Society pages and use the hashtags #lockdownrichmond and #loverichmond

Links to help you get through Lockdown

The following links may help to get through confinement to your home during the current health emergency. If you know of others worth sharing, please tell us.

Cooking & Catering

Some local restaurants are providing an online ordering and delivery service. Go directly to their websites for details.

Keep Cooking & Carry On with Jamie Oliver

The Barefoot Contessa Recipes

Fitness

Coronavirus: Stay fit to fight the virus

NHS Get fit for free

NHS Vinyasa flow yoga

Government

You can sign up to the UK Government daily email updates on the coronavirus pandemic

Sarah Olney MP’s blog

Help

Coronavirus conditions: what to do if you think you are infected

Richmond Council, including how to seek help from the Community Hub

Cancellation of all Richmond Society events
until the end of June

Following Government advice for what we should all do about the coronavirus pandemic, we have decided to cancel all Richmond Society events until the end of June. This includes our talks, walks and Summer Party.

It is a big disappointment, not least because much effort goes into arranging the programme. However, we are certain that the Society’s 1,300 members will appreciate it is necessary to get us through these uncertain times safely.

We hope to resume our events in July and will keep you informed about that and other relevant developments as they occur. Speakers for those events that have been cancelled will be invited to talk to us next year.

The health, safety and well-being of members and guests who come to our events is of paramount importance. We are grateful for your support for our efforts to keep Richmond special.

We have several ways to keep in touch: in addition to this website www.richmondsociety.org.uk, we have our quarterly Newsletter, online messages such as this one and our periodic News Bulletin to which you can subscribe at https://richmondbulletin.org.uk. Past issues can be reached from the website, as can an archive of Newsletters. We also have a presence on Facebook, Instagram and Twitter.

Keep well, stay safe and take care. We hope our growing community of people who love Richmond will be spared the effects of this dreadful disease.

Meeting Cancellation, Thursday 19th March

The Richmond Society’s Executive Committee has decided that in view of the deteriorating public health situation the only responsible course of action is to cancel our speaker meeting planned for this coming Thursday 19 March. We are sorry it has not been possible to give more notice and hope you will not be inconvenienced.

We had hoped to go ahead but thought it only prudent to err on the side of caution by putting the health and safety of our members first.

We were looking forward to hearing from Tom Chesshyre about his walk along the length of the Thames from source to sea, so we will ask him to come at a later date.

We hope you will not be affected personally by this terrible pandemic.

Richmond Society requests urgent holding direction for Manor Road development approval

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.

BACKGROUND

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:

add to the overall quality of the area;
are visually attractive as a result of good architecture, layout and appropriate and effective landscaping;
are sympathetic to local character;
establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;
optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks; and
create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.

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!

TRANSPORT INFRASTRUCTURE

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.

HOUSING MIX

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.

HEIGHT AND MASS

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.

Vies showing the bulk of the proposed development in the context of the landscape overall 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.

DAY LIGHT / SUNLIGHT

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.

IN CONCLUSION

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

Response to LBRuT Active Travel Strategy Consultation January 2020

GENERAL OBSERVATIONS

The Society supports active travel modes for personal health benefits and the promotion of a better quality of life for the wider community by virtue of improvements to air quality, more reliable journey times and reduced congestion.

Most people fail to register that EVERY journey begins and ends with an element of walking (even if only to walk to or from a parked bicycle or bus stop) and, while it may not constitute the main component of their journey it is integral element of all journeys.

The Mayor’s Heathy Street indicators are a fine aspiration, but they often lump walking with cycling and therefore fail to make a proper distinction between their differing needs and priorities. This reads across into the council’s active travel plans and targets with walking too often appearing to be the poor relation.

In considering some of the Healthy Street indicators for example:

PEOPLE FEEL RELAXED / PEOPLE FEEL SAFE – Pedestrians cannot relax when walking through shared cycling space, or crossing a cycle lane, because they must remain alert to faster moving cyclists. The increased risk of a collision, most especially for less mobile and visually impaired pedestrians, makes these areas feel less safe and less attractive for those on foot. In the Richmond specific context these considerations gain extra relevance when the enjoyment of a walk along the towpath is regularly disrupted by demands from cyclists travelling fast and sometimes aggressively;
PEOPLE FEEL SAFE / EASY TO CROSS – One-way streets with a contra flow lane for cyclists adds risk to pedestrians crossing such roads. Cyclists coming from the opposite direction of travel to motor vehicles will be close to the kerb and that leaves little opportunity for either party to take evasive action. Cycle lanes along the length of a pavement (such as along the A316) require added caution when using pedestrian crossings or alighting from buses;
EASY TO CROSS – High levels of kerb side cycle parking can make roads harder to cross by reducing the free space that is available at the edge of the road.

The council’s 2024 target for number of Healthy Streets completed (page 24) therefore does not indicate whether the council will prioritise its investment towards addressing pedestrian or cyclist needs. Given that this Healthy Streets numerical target is immediately followed by the number of cycle parking places installed and kilometres of cycleway completed, it suggests that pedestrians will not be the primary beneficiary.

However, we also note from the data presented on page 12 that more pedestrians were fatally injured than cyclists both in absolute terms and as a proportion of total injuries for these modes. The safety imperative for pedestrians should therefore receive high levels of attention.

The following points respond to specific headings in the strategy.

WALKING INFRASTRUCTURE (Page 10)

The council correctly notes the problems for walkers that arise from tree roots and trunk girth, but the strategy does not offer a plan for addressing these. We are aware of residents in wheelchairs, or parents with buggies, who must leave the footpath and compete with vehicles on the road to get past street trees.

The active management of the Borough’s street trees to reduce this impediment to active travel could legitimately be included as a strategic objective.

STRATEGIC CYCLE CONNECTIONS (page 11 and page 23)

In the context of the Richmond Society’s area of benefit it is unclear why the A316 cycleway that connects the town and Chiswick Bridge appears to have been omitted from the borough’s strategic network map. This segregated facility already exists and, because TfL has long promised improvements for this section, its omission from the map becomes a curiosity! It also gives an impression that the local cycle network is less well connected than the situation on the ground.

We are already discussing various cycle route options thorough Richmond Town with officers, but additionally note from this consultation that the council has started design work to make A307 (Kew Road) a strategic cycle route by 2024. A cycle lane already exists along both sides of this road for much of its length, but the narrow road and pavement widths between Kew Gardens Road and Mortlake Terrace and around Kew Green (when it becomes the South Circular) will make it a challenge to build a continuous segregated facility along the full length of the road and link with CS9. It’s unclear how the council can overcome this constraint but would question if the absence of a cycle lane through the more dangerous part of Kew Road may negate any benefit from upgrading the rest of this route. Furthermore, parking is currently allowed in the north bound cycle lane from 10am between Lion Gate Gardens and Kew Gardens Road. This part time parking is very well used and the arrangement seems to work well balancing the use of the cycle lane for Brentford bound commuters in the morning peak against the parking need later in the day of an increasing numbers of visitors to the Royal Botanic Gardens at Kew (including those that arrive by coaches). The council must carefully evaluate the repercussions for RBG Kew visitor numbers and the consequences of displaced visitor parking for many residents in North Richmond and Kew if the current volume of on street parking cannot be reprovisioned acceptably elsewhere.

Photo of cycle channel showing some of the problems mentioned in the text Retrofitting “wheel rails” (or alternatively cycle channels/gullies) over pedestrian bridges does enhance cyclist facilities and improves network connectivity but, in many cases, this comes at the expense of a degraded pedestrian experience. Although a cycle channel is not being used most of the time their constant presence reduces the useable width on the steps which can be a problem on busier and/or narrower bridges for opposing pedestrian flows. They also make it harder for anyone unsteady on their feet to use the handrail and, because some bridges are poorly lit, the cycle channels are often difficult to see in the dark creating a hazard that can trip, graze or otherwise injure an unwary pedestrian. Cleaning under the cycle channel is generally desultory which results in an accumulation of decaying leaves, moss and litter. Cycle channels do offer a solution for cyclists unable to carry their bike, but we urge the council firstly to consider the other options (that may also offer a better cyclist experience) before retrofitting a cycle channel to a footbridge that has been designed for pedestrians.

LOW TRAFFIC NEIGHBOURHOODS (Page 21)

The Society will support interventions that reduce rat running, enhance safety and make neighbourhoods more liveable provided that they are not manifestly unfair to other residents and have predictable consequences. The council’s recent experience with the East Sheen LTN tends to suggest that it may be a mistake under this strategy to expect to start “most schemes” with experimental traffic orders followed by formal consultation. We would be concerned that sequencing schemes in this order may cause avoidable neighbourhood angst with the potential for wasting more money resolving and possibly reversing an implementation. We therefore suggest that LTNs are not imposed on unwilling residents and that there should be a buy in through a consultation process once the ramifications are broadly understood by those most affected.

OFF ROAD WALKING AND CYCLING

We have already noted that in a few places aggressive cycling is harming the enjoyment of walking off road. For this reason, it will often not be appropriate to remove existing gates and bollards so that cycling is made easier, most especially those installed specifically to slow down cyclists! At some locations the worthy aim of facilitating better wheelchair access by widening restrictive gaps would also facilitate faster cycling and possibly more use of such paths by powered two wheelers. With misuse in mind, the council should recall that many gates and bollards were installed at the request of the police or community to ensure that some paths do remain “off road”.

Cycling on the footpath where not permitted is illegal and, because this is a growing concern in and around Richmond town, the Society would support the council enforcing this rule with the same rigour as is applied to a moving traffic violation.

LINKING TO PUBLIC TRANSPORT (Page 26)

We support the council’s aims in the section, particularly in the context of improved wayfinding and cycle parking at Richmond Station, but note that this should not run counter to the long-standing objective of reducing the street clutter in Richmond town.

SUPPORTING OTHER TYPES OF ACTIVE TRAVEL (Page 27)

We absolutely support and encourage the council to pursue a policy of “no loose tiles” in the footpath, but also to extend this policy to cover the timely elimination of trip hazards caused when slabs lift.

Furthermore, there should be more enforcement against vehicles parking on pavements illegally. Not only does this block the footpath, but heavy vehicles often damage paving slabs. Photographic evidence from residents should be accepted whenever possible and particularly when the council can make a claim against a land owner for damage caused by construction traffic.

We feel that the strategy is weak in this section because it does not give enough consideration to pavement condition. This is a particular concern when many Richmond residents are older people who do not want to fall and find that uneven pavements are a major impediment to being able to leave their home independently. Similarly clearing streets of leaf litter before it turns to mulch and makes pavements slippery is vitally important. The council might therefore consider adapting the autumn leaf sweeping frequency at specific locations where leaves from certain tree species turn to mulch under the weight of pedestrian footfall faster than they are cleared.

These are public health considerations for older residents that may justify using a share of this budget for pavement improvements.

We note also that a number of roads and pavements around Richmond are increasingly prone to flood. This is a particular problem for pedestrians who need to leap over puddles and/or risk being soaked by a passing vehicle. The essential ongoing maintenance that ensures the continued delivery of a good pedestrian experience should also be an integral requirement of the Active Travel Strategy.

CONCLUSION

There is much to support in the Active Travel Strategy and we welcome this effort and opportunity to respond. We do however feel that the strategy gives cycling too much emphasis and a disproportionate amount of time and money relative to the more modest improvements that could enhance the walking experience for more residents.