The Battersea Society: Planning Committee submission The Battersea Society website 

Planning Committee Submission

Submission to Wandsworth Borough Council
Added on: 29 January 2016 at 16:15:11

Civil Works and Temporary Infrastructure in connection with 2016 Formula E Event 2015/7363

The Battersea Society object strongly to the continued use of Battersea Park for Formula E Races.

The current application in no way allays our previous view that such events are totally inappropriate for a much used local Heritage Park such as Battersea. All the issues we raised in relation to the initial application still stand, the conditions attached to the 2015 approval do not appear to have been fully met and the residents of Wandsworth are no clearer on what the financial benefits to the borough as a whole will be.

It is now the case that residents and others who use, love and wish to protect the Park are fully aware of the impact of the FE races. They have individually responded to the current application in very great numbers and we urge members of the PAC to give due weight to this enormous reaction against continuing use of the park for FE. We would also remind members of the PAC that DCLG NPPF guidance on Public Consultation states that consultee’s views are important because they offer 'particular insights or detailed information which is relevant to the consideration of the application.' In this case experience of Park users and local residents of the impact of FE provides just such insights.

This reflects the views of our members. In an online survey shortly after the 2015 races 69% of those responding felt that staging such a high profile event was not worth the disruption to the Park and 60% did not see any benefits at all in holding a Formula E event in Battersea Park. The Battersea Society has made two deputations to the Council opposing FE and objected to the 2014 planning application.

Our grounds for objection reflect experience from the 2015 event and cover

Breach of Policy and conditions applied to 2015 approval
Deficient application  - inadequate information for permanent approval of civil works
Cumulative impact of proposals inadequately assessed against DMO 1
Closure of park

a) Breach of Policy and breach of conditions applied to 2015 approval

The policy grounds for our objection remain. DMPD Policy DMO 1:  Protection and enhancement of open spaces in Wandsworth states that ‘… areas of open space … will be protected and enhanced and development will only be permitted where:

(i) it is linked to the functional use of the open space; and

(ii) it does not harm the character, appearance or function of the open space. 

Cumulative impacts of development will be taken into account in this assessment.

The impact of last year's race resulted in this policy being breached. One consequence of last year's approval is the extensive new areas of tarmac in the boules area and the Rosery Car Park. The Land Management Services September 2015 impact assessment (pages 49/50) confirms this ...'The realignment of areas of the Carriage Drives,...forms larger expanses of black tarmac which detract from the character of the Park and change the form and aesthetic impact of the physical structure of the Park. '

There has been no remediation treatment to these areas. We do not accept the Council's response in the OSC paper for 24 November 2015 where they state that remediation work is 'largely completed; it is accepted that not all remedial measures can be 'immediate' , but should be carried out in a reasonable period of time.' It is now 6 months since the event. We consider this is a reasonable period for reinstatement yet these tarmac areas remain. There is clearly no intention of restoring them. The Council should at least have provided some temporary planters with mature bushes, put in place at the FE promoter’s expense. 

Nor do we accept the applicant’s view in Paras 4.7 to 4.9 of the D and A statement that, as the development applied for is temporary, it is acceptable in respect of DMO1 (no reasoned justification is given for this assertion). The suggestion that no structures or works are proposed 'in park where there is not already development' is untrue. The permanent civil works applied for are clearly in former grassed or planted areas of the Park, hardly areas of  'development'. In subsequent paragraphs relating to Heritage Assets they admit there will be 'no substantial harm' i.e. there will be some harm but it outweighs unidentified benefits. Weasel words – if there was 'substantial' harm members would be obliged to reject the proposals.

b)  Deficient application – inadequate information for permanent civil works

Section 3.4. of the Design and Access Statement states: 'The civil works were granted temporary consent by planning permission 2014/6976 and this application seeks permanent consent for these works.'   There is a totally inadequate description of the works for which permanent approval is now being sought.There is no detailed information about their precise nature and location within the Park, nor any impression of what the finish and look would be. The Civil Works Area plans provided separately from the D and A consist of crude diagrams with trees as blobs and 'new' asphalt areas simply brushed out in purple. Both the broad description of the Works Areas in the D and A and the plans fail to indicate whether they are referring to what was left after last year's event, or whether further work is likely.

For a major event such as this there must be a full civil engineering specification. These should be attached to the planning permission, as happens even with small domestic applications. Put simply, how can members of the PAC reach a decision on the basis of these computer diagrams  - they cannot. Without specification of the permanent civil works for which permission is sought it would be impossible to monitor any approval given.  We share the concerns of Historic England that no further tarmacking should take place but cannot be assured that this not the case, given the information provided.

c) Noise

The undertakings in the Noise management plan are weak and do not suggest a significant willingness to reduce noise nuisance. The application will therefore further detract from the peaceful character of the Park. Noise from the near continuous overflying of a helicopter at the 2015 event on both days caused very significant sound pollution to a wide area, including residents who had no interest or wish to attend the events. In addition there was significant nuisance outside the Park caused by music in the middle and end of the day. This in spite of reassurances to the Community Forum that there would be neither helicopters nor music.

The Noise management plan attached to the application does not allay fears that noise would again be a nuisance. There is a weak undertaking in para 6 of the Noise Management Plan that flying time will be reduced and the flight path reviewed. But what does the helicopter add? The tree cover means that virtually none of the racing can be seen from the air. Helicopter access over the park should be ruled out except for emergency use. Likewise the undertaking in relation to music is not comforting.  Para 5 of the Noise management plan states that music will be limited to the E village and spectator video boards. However the plan clearly indicates that the latter are scattered across the park. Music should be limited to the e-village alone and strict decibel levels set such that music cannot be heard outside the Park.

d) Cumulative impact of approving the application

The application does not meet the requirements of policy DMO1, i.e. that there will not be cumulative harm caused by the proposals. There are real concerns that repeated use of the Park for FE will have a long term deleterious impact on its quality as a heritage asset. Without very tight requirements to restore the civil works, and currently there appear to be none attached to this application, every opportunity will be taken for increased usage of the additional infrastructure. This will mean the peace and enjoyment of the Park will be further eroded. Additionally, the weather was kind in 2015 but wet conditions could severely damage the grass areas of the e village putting them out of use for an extended period and give rise to pressure for more all-weather surfaces.

We consider that, in the Rosery Car park and boules areas, there are already negative 'cumulative effects' as referred to in policy DMO1. Firstly the widening and resurfacing of these has provided more space for film crews and their 'village' of trailers which include catering kitchens, outside eating areas, changing rooms, water bowsers etc.  While occasional use of these areas for films set in the Park was acceptable, these areas were not designed for their now regular, often over weekends, use as a commercial parking lot, unrelated to the Park. This commercial use results in less parking space for visitors, park users having to negotiate round the vans and their outside catering areas, and having to face an ugly intrusive mass of vehicles on entering the Park from the south and west. There is intrusion from lights and activity late into the evening and waste food is not always removed from site immediately after the crews leave. This is commercial car park use and, given the listed status of the Park, should be subject to separate planning approval.

Another cumulative impact in the Rosery car park is the increased speed of cars using the area. No serious attempt has been made to restore the previous calming bumps or provide proper safety for pedestrians entering and leaving the Park through the Macduff Road gate. There are very small ridges and one pitiful small pedestrian warning sign, virtually on the crossing, far too close to temper speeds which have noticeably increased in the car park area since the widening of entrance and parking areas for the FE event. The comparative safety and calm of this part of the Park has unnecessarily been lost.

We fear these insidious creeping threats to the character of the Park, with its unique Heritage, will only increase if events such as FE are approved.

e) Closure of park and safety during build-up and de-rig

Finally the Battersea Society continues to condemn the effective closure of the Park for an extensive period in the height of the summer. We consider that the requirement of DMO1 (ii)  is not met, i.e that the proposal ‘does not harm the character, appearance or function of the open space'. The nuisance and intrusion to Park users caused by closure of sections of the Park during build-up, de-rig and the two days of racing clearly seriously disrupts the primary function of the Park. It cannot be justified in terms of the supposed benefit from the event itself.  Park users suffered extensively from construction noise, traffic, physical intrusion and potential danger during the event programme in 2015.The proposed timetable for 2016 could well mean longer hours of more intensive work, causing increased rather than less nuisance. Major events such as the fireworks and use of the exhibition site are managed effectively and offer visible and significant benefits.  No such benefits in support of further FE events have been demonstrated against the disruption and annoyance the event caused in 2015. The huge and well-reasoned public response to the application highlights this.

We consider that on planning policy grounds this latest application should be refused. Not only is FE counter to the Council's policy DMO1, the application is deficient in giving little detail of the permanent civil works and fails to justify the admitted harm it will cause. Without this detail, PAC members have insufficient information on which to base their decision on the application. It also means that monitoring of its implementation would be impossible. It should be refused.

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