The Battersea Society: Planning Committee submission The Battersea Society website 

Planning Committee Submission

Submission to Wandsworth Borough Council
Added on: 1 September 2017 at 11:07:00

198 York Road, 2017/4380

 The Battersea Society objects to this application on the grounds of:
1. Height, bulk and density
2.Paucity of affordable housing
3. Added pressure on transport facilities, the roadway and the lack of car parking.

The application appears to be being fast-tracked. At a pre-application meeting with officers on May 15 “the scope and context of the application was agreed”.  The application was registered on 8 August, closing date for comments 6 September, Planning Applications Committee 20 September.  We note that the Leader had a lunch meeting with Peter Bingle of Terrapin Communications on 5 May 2017. 

Other concerns relate to the manner in which this developer has, in parallel with this application, put in some 15 applications relating to the existing plan; the manner in which the Design and Access Statement is presented on the planning website; and the gloss put on the public comments made at the exhibition. 

1. Height, Bulk and Density 

i.  Height:  This application “builds upon the extant planning permission by reflecting the height and massing changes within the surrounding context since the first approval of the scheme”.   In other words, many excessively tall buildings have been approved so 20 storeys, subsequently raised to 21, is no longer tall enough. 

This stretch of the river and York Road is being turned into an unplanned version of Nine Elms with little clarity, for ourselves or for councillors, of the cumulative impact of the schemes which are reviewed and approved piecemeal.  The Site Specific Allocations Document (SSAD) adopted in March 2016 confirms that this is seen as an area where tall buildings are appropriate. This site is ‘sensitive to tall buildings’ and ‘the height at which a development in this location will be considered to be tall is 9 storeys’.  By March 2016 a revised building height for this site of 21 storeys had already been approved and a number of other buildings, considerably in excess of 9 storeys, had been approved along York and Lombard Roads. 

The Design and Access Statement (D&A part 4 para. 2.5) shows some of these schemes.  There are plans for tall buildings along the south side of York Road on part of York Gardens.  These together with plans for Plantation Wharf will turn York Road, York Place and Gartons Way into deep-sided canyons. The visual showing a sight line from York Gardens to the scheme is misleading and irrelevant. 

Nine Elms benefits from coherent open space in the form of the Linear Park and along the riverside; and by the setting back from the roadway of some developments.  No similar thought has been given to the public realm and open space in the Lombard Road/York Road Riverside Focal Point Area.  We, and the Design Review Panel, have already expressed considerable concern about Plantation Wharf proposals (2016/5644), presumably approved in March this year.  It is hard to avoid the conclusion that this whole area is set to become an incoherent and dispiriting mess which this proposal will only make worse. 

ii. Bulk:  It is not clear from the paperwork but it appears that the footprint of the building is to be increased.  D&A pt. 27 shows a cgi  image suggesting the taller building will be quite close to the road.  The image is at night but we assume the red lines are from traffic on the roadway.  D&A  pt. 40 para 7.61 refers to an extension of the proposed building footprint . 

iii.  Density 

The proposed density is significantly higher than that proposed in the London Plan.  The London Plan also indicates that where there are public transport pressures, as is the case here, density should be at the lower end of the desired ranges.  This would imply that the proposed density is over three times the recommended level without any justification for this intensification given.  This density is made more unattractive by the lack of space around the buildings and the surrounding tall buildings.  Planning Statement para 4.17 refers. 

2.  Paucity of Affordable Housing. 

The current scheme is to provide 15% affordable housing.  While no statement is provided, this being confidential until the PAC report is published on 13 September, one of the two parts of the DAS numbered 24 gives a schedule of accommodation proposing 41 intermediate rented units from the total of 299 - 13.71%.  The majority are 1 bed x 2 (presumably co-habiting) persons and 13 are 2 bed x 3 persons.  The schedule of accommodation for application 2017/3886 relating to the permitted scheme also shows 41 intermediate rented – 14.91% 

The majority of the private units (150) are 2 bed x 4 persons.   Only 17 are 3 bed apartments. 

We are sending a copy of these comments to the Mayor so that his expert panel can offer the PAC their views of the viability report before 20 September. 

3.  Transport, Roadway and Car Parking 

i.  Public Transport

Clapham Junction and Wandsworth Town stations are dangerously over-crowded during peak times and all bus routes are already considerably over-stretched.  This at a time when most of the new buildings here, in Wandsworth Town and on the Winstanley are not yet built.  

We are at a loss to understand why neither the Council nor TfL can see the urgent need for action to quantify the added passenger numbers and set down some feasible plan to address this.  Table 5.5 of the Transport Statement for this scheme shows the extra trips likely to be generated.  It would be a relatively simple task for similar tables to be extracted for all the approved and proposed plans to give an estimate of the cumulative impact. 

We fear that it will take a significant accident resulting from overcrowding at one of the stations before the serious nature of these pressures is properly appreciated. 

ii.  Roadway Size 

It is noticeable that traffic from Nine Elms through to York Road is already increasing congestion west of Queenstown Road.   Lombard and Gwynne Roads are narrow and heavily trafficked.    There is a low railway bridge impeding traffic flow in Lombard Road.  Wandsworth Road and Lavender Hill have been heavily congested at peak times for many years.  Battersea overall and Wandsworth Town Centre are set for gridlock. 

This will, of course, further increase pollution levels, especially given the heights of the planned developments on both sides of York Road. 

iii.  Car Parking 

Proposals are inadequate.  There should be provision for parking for RAD, for delivery and service vehicles visiting residents and more than one Car Club space, particularly as we note that all occupants of the 299 units are being offered a one-year free car club membership.  We are observing increased traffic and congestion as on-line shopping increases. 

Other Concerns 

i. Revisions to existing scheme 

We cannot understand why the developer has not waited to see whether this scheme will be approved or refused before putting forward 15 detailed applications in relation to the existing scheme.  One, 2017/3886, has some 46 reports and many drawings.  It is hard to understand why this has been done.  The effect is to add to the workload of WBC planning officers.  In the case of the Battersea Society we have not, during the holiday period, been able to review the revisions in any detail and we trust that the consultation period for 2017/3886 will be extended. 

ii.  Design and Access Statement 

This document has been posted on the application web site in 45 sections of which: 

  • 18 are just one page long, 11 are 2 pages.

  • 5 are 3 pages, 4 are 4 pages.

  • Only 7 consist of 5 pages or more. 

It is only because this is so important an application that we have undertaken the laborious task of reviewing the D&A in full – and even then we have not had time to look in any detail at the landscaping proposals and may have overlooked some important aspect of the plans. 

iii.  Community Involvement 

It is a nonsense to quote an 88% approval for the scheme in percentages based on 18 or19 people. Only 18 of the 64 people who attended the exhibition filled in a feedback form so this represents 15 or 16 people at most.  To date at least 45 objections have been posted. 

The Battersea Society is cited as having been informed and having turned down a meeting.  It does not mention that we were only contacted after the exhibition had closed and so had no chance to attend the exhibition nor alert our members.  This despite our being well known to Dave Clark at Terrapin Communications, both during his time at WBC and during his current employment. 

This is a thoroughly unsatisfactory application and we trust it will be refused. 

To see full details of this application and other comments, or to make your own views known please click here