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.
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