Author: Cyril Richert

Impact of the Ram Brewery development as granted by the Council

With 230 new towers planned, London is going to become “Gotham City”, claims last week article in the Evening Standard.

In a statement in the Observer at the end of March, signatories from sculptor Sir Antony Gormley to philosopher Alain de Botton, author Alan Bennett, Stirling prize-winning architect Alison Brooks, and London mayoral hopefuls Dame Tessa Jowell and MP David Lammy warn: “The skyline of London is out of control.”

More than 200 towers of at least 20 storeys are under construction or being planned, of which three-quarters will provide luxury residential flats, according to New London Architecture (NLA), a discussion and education forum.

The Skyline campaign, organised jointly by the Architects’ Journal magazine and the Observer newspaper, demands a new mayoral Skyline Commission “to review and enable well-designed development” as well as a new policy for tall buildings that “ensures high-quality architecture.”

In their statement, more than 70 signatories, including societies and associations, write:

“Over 200 tall buildings, from 20 storeys to much greater heights, are currently consented or proposed. Many of them are hugely prominent and grossly insensitive to their immediate context and appearance on the skyline.

This fundamental transformation is taking place with a shocking lack of public awareness, consultation or debate.

Planning and political systems are proving inadequate to protect the valued qualities of London, or provide a coherent and positive vision for the future skyline. The official policy is that tall buildings should be ‘well designed and in the right place’, yet implementation of policy is fragmented and weak.

Too many of these towers are of mediocre architectural quality and badly sited. Many show little consideration for scale and setting, make minimal contribution to public realm or street-level experience and are designed without concern for their cumulative effect and impact. Their generic designs, typical of fast-growing cities around the world, threaten London’s unique character and identity.”

The Observer’s architecture critic Rowan Moore said:

“Nobody could go to the places already being shaped by towers – Elephant and Castle, Vauxhall or Stratford High Street, a discus-throw from the Olympic Park – and say that these are great places to linger, or that the tall buildings now rising there enhance the experience. Images of these places in the future, when further skyscrapers will jostle for attention, suggest more of the same. New urban zones are being created with no overall idea of how the parts contribute to the whole, of the places that are being made at their base.”

Back in 2005, the St George Tower, in Vauxhall, was granted on appeal by John Prescott, despite advice from his advisers that it “could set a precedent for the indiscriminate scattering of very tall buildings across London“. Here we are: either the Labour deputy PM was completely blinded or full of cynicism, but 10 years later the warning of the advisers becomes a reality:

How the view along the Thames from Vauxhall/Nine Elms might look. – photo from the Evening Standard 14/04/2014

There is a very good series of animation “before/after” where you can view the dramatic impact of the new skyline in a few years by clicking and sliding on the images:

• How is London’s skyline going to change? An interactive guide

All this campaign echoes our criticisms on Wandsworth Council’s attitude, making frequent decisions in breach of local and national policies, and blatantly ignoring local community outcry.

• David Cameron is told that Wandsworth Council’s planning procedures and ‘localism’ practice have failed

Filed under: Planning strategy

Author: Cyril Richert

To the question: “If the adopted Local and National Planning Policies are only treated as loose guidelines which can be ignored at will, then Wandsworth Council should state that such is the case” the leader of Wandsworth Council, Cllr Govindia, answered: “Yes, the keyword is ‘guidelines’“.

On Thursday 10th April, the Wandsworth Society organised a local election hustings with the representatives of the Conservatives, the Labour, the Libdems, UKIP and the Greens.

Following the comment, Battersea Society Secretary Harvey Heath said:

“This is full admission that the Council considers that Policies are just rules that can be bended and ignored“.

Local policies are statutory Development Plan for the borough and must comply with a long list of requirements and must be submitted to the Secretary of State for Examination and reviewed by an independent Planning Inspector and subject to the changes identified in the Inspector’s Examination report. Policies say clearly (DMPD p13): “Planning permission will be granted for developments which comply with the following criteria…“

Policies are NOT guidelines (and Cllr Govindia, as former Chairman of the Planning Committee for a decade, knows that very well indeed).

Cllr Rex Osborn, leader of the Labour, proposes that the public should be able to make representation at the Planning Application Committee meetings (this is currently forbidden by Wandsworth Council – the only borough in London not allowing such representation) and that Community Societies/groups should be involved in planning discussions with the planning department (maybe represented at the PAC?).

All the other local election candidates said yesterday that policies are not only guidelines and therefore should be applied at a much tougher level than currently.

Cllr Govindia also said that all decisions can always be challenged in court with a judicial review. However this process is way above the financial possibilities of most of individuals, community groups and even Societies. The only recent case known is when the Friends of Putney Common managed to quashed a Council’s planning decision, after spending £12,000 in solicitor and lawyer’s fees.

Filed under: Planning strategy

Author: Cyril Richert

Following our letter to the Prime Minister on Wandsworth Council’s planning procedures and ‘localism’ practice failures, the Council said we were all NIMBYies who “hurl false and groundless allegations around“.

According to the local media PutneySW15.com, a council spokesman said:

“Planning decisions are made by ordinary local people who have been elected to represent the wider community. They make hundreds of decisions each year having weighed up all the available evidence, including all the arguments in favour of permission and also all those against. 

Their difficult task is to balance competing interests for the benefit of the whole community – to improve the borough’s built environment and to provide new homes, offices, schools, shops and other economic benefits like jobs. The council has worked in partnership with organisations like the Putney and Wandsworth Societies for many years with the shared aim of creating a better borough for people to live and work in and we are proud of our record. 

Unfortunately this letter and the evidence presented alongside it is based on a skewed and wholly selective picture of the local planning system. All our decisions are based on planning legislation and we scrupulously follow out own local guidelines where these do not conflict with national planning rules. It is always regrettable therefore that some people have a more NIMBYist approach and choose to hurl false and groundless allegations around when they don’t get their own way.” 

On Monday 7th April, Amenity Societies and Community Groups in the Borough of Wandsworth have teamed up to publish an ‘Open Letter’ to David Cameron showing major failures in its planning procedures, and calling for an urgent independent review into its planning processes.

Beside the bold comment made by the Council’s spokesperson, we look forward to receiving a  response from Cllr Ravi Govindia, leader of the Council, to our letter’s detailed criticisms and a reply from the Prime Minister about our call for an independent review. It’s easy to be rude, less easy to give detailed explanations to the detailed criticisms set out in the letter’s Summary/Appendix.

You can find reports and articles about the initiative in the following websites.

On participants’ websites:

• Putney Society
• Wandsworth Society
• Clapham Junction Action Group
• Friends of Putney Common

Putney SW15.com: Local residents’ groups write open letter to David Cameron (with forum discussion HERE).

Wandsworth SW18.com: Call Made for Urgent Review of Planning in Wandsworth (with forum discussion HERE).

Streetlife: Forum posts

Thanks for the many messages of support such as:

“Thanks to those who put this together.  Living in a small community being swamped by gross, ugly developments around Wandsworth Bridge roundabout, I repeatedly wonder whether any of this would be allowed anywhere near where the councillors live.  Perhaps if there are councillors reading this they can site cases.”

Filed under: Planning strategy

Author: Cyril Richert

Wandsworth London Borough Council is named in an ‘Open Letter’ to David Cameron showing major failures in its planning procedures, and calling for the Prime Minister to set up an urgent independent review.

The Putney Society, Wandsworth Society, the Clapham Junction Action Group and Friends of Putney Common community group have all written to the Prime Minister to express their concerns at the way Wandsworth Council has dealt with a number of important planning applications, in the context of published planning policy documents and guidelines.

“The issues which concern us all are the fairness and legitimacy of Wandsworth Council’s planning procedures. Planning decisions frequently breach local and national policies and guidelines and, in recent years, there have been too many examples of bad practice for this to be ignored.”

Many residents have lost faith in the fairness and impartiality of the planning procedures used by Wandsworth Council. We have attempted to engage with the Council to get them to follow their own local and also national policies, but to no avail. Our analysis of recent planning decisions makes damning reading. We hope that the Prime Minister, who has always supported Localism personally and as Prime Minister, will respond to our appeal for an urgent review of what is going wrong in Wandsworth.

In a hard-hitting letter addressed personally to David Cameron the group of Wandsworth amenity societies and community groups have combined to call for a review of planning procedures in the Borough of Wandsworth.

We cite the issues which concern them as representatives of the residents of Wandsworth which stretches from Battersea in the East to Putney in the West and which is the largest Borough in London. We say that planning decisions made by the Council and its officers frequently breach local and national policies and guidelines, and that recently there have been far too many examples of bad practice to be ignored, as shown in our detailed report to the Prime Minister included with our letter.

The report sets out numerous examples of policies agreed in the Local Plan which have been blatantly circumvented or swept aside. What is more, they show that in many cases objections made by many individual local residents are just undervalued and discounted.

Wandsworth Council has been guilty of ignoring policies and guidelines related to key planning concerns: General Development Principles, Managing the Historic Environment, Tall Buildings, Methods of Visual Representation, Supplementary Planning as it relates to Housing, Affordable Housing, Conservation and Heritage matters, Residential Properties, Transport and Offices, and Consultation.

The letter goes on to point out that however impressive the Local Plan related to planning and development might seem on paper, the guidelines and policies enshrined in that document are useless if they are consistently ignored by the Council. The adopted Local and Planning Policies are only treated as loose guidelines which can be ignored at will, as the case studies described in the report sent to the Prime Minster clearly demonstrate.

In calling for the Prime Minister to set up an urgent independent review the letter says:

“Your government has rightly placed localism at the heart of the agenda for reforming local government practices, and indeed you have said you are a “confirmed localist”. When launching your party’s local government campaign in Nuneaton last year you rightly criticised the “top down, target-driven, big bossy, bureaucratic, we know best arrogance” of some local authorities and declared that this had been “turned upside down.” The detailed information provided with this letter unfortunately shows clearly that Wandsworth Borough Council is falling far short in putting localism into practice in its planning procedures. It has failed to listen to its residents and the groups that represent them, on numerous occasions.

We are therefore requesting that an independent review into Wandsworth’s planning arrangements is set up urgently to trigger the necessary change. “

• [ You can download the full report HERE]

Filed under: Planning strategy

Author: Cyril Richert

The Council has now published its report on the Consultation on changes for its Local Plan (item 9 – Paper 14-141). In total 34 respondents made representations relating to the different planning documents (Core Strategy, DMPD, SSAD, …).

CJAG contributed to this consultation last July 2013. Our general point was that most of the comments made by the residents, groups and societies have been rejected or ignored in previous consultations on planning policy; it questions the purpose of the full process, other than ticking the right box at the right time.

As you see below, this time again, all our comments regarding the meaning of the policy (wording, strengthening) have been rejected, to the exception of our comment on acceptable images (which shows have we say all along that there is a real problem). Our accepted comments relate to factual corrections on dates and updating information on sites already developed.

You will find below the relevant parts on CJAG’s comments through the 40 pages. We have quickly highlighted in green when our comments have been accepted, and in red when they have been rejected.

Comments on the plan as a whole/general principles

4.1 […] Whilst a number of the general comments indicated that the Plan was not sound these did not relate to the overall approach adopted by the Council. Some comments, e.g from the Wandsworth Society and Ernshaw Place Residents’ Association (EPRA) related to how the policies applied to the assessment of planning applications, and how residents views were taken into account in assessing planning applications.

4.2 The Council does not agree with EPRA’s assertion that “residents have played part in devising these plans“. The Council has undertaken its statutory duties in consulting the public and other bodies throughout the development of the Local Plan and the Local Development Framework documents on which they are based. As reflected in this document, the Council has carefully reviewed all the comments received at every stage in the production of the documents, and agreed numerous amendments in response to the comments received.

Comments on the Core Strategy & DMPD

4.3 This section sets out comments on Chapters 1 – 3 of the Core Strategy (Introduction; Issues problems and challenges; and A spatial vision and strategic objectives for Wandsworth) and Chapter 1 of the Development Management Policies Document ((DMPD) Introduction).

4.4 The date of consultation on the topics to be included in the review in paragraph 1.4 of the Core Strategy has been corrected as identified by Clapham Junction Action Group (CJAG) and EPRA.

4.7 The CJAG and the EPRA commented on changes to the Council’s Strategic Priorities set out in Core Strategy paragraph 1.20. The change to paragraph 1.20 reflects the priorities identified in the Council’s latest Corporate Business Plan.

4.11 Paragraph 4.1 has been amended to reflect the latest population projections and revised housing targets. The changes do not reflect “a major goal to transform Wandsworth into a dormitory borough” as suggested by CJAG.

Sustainability

4.12 The Putney and Wandsworth Societies, Clapham Junction Action Group (CJAG) Ernshaw Place Residents Association (EPRA) and Wandsworth Clinical Commissioning Group (WCCG) made various comments on the wording of Policy SD1. No changes are proposed as the policy uses standard wording provided by the Planning Inspectorate to reflect the principles in the National Planning Policy Framework. The Policy was supported by Barratt London Ltd and the St James Group.

Housing – The provision of new homes

4.28 The Putney Society, Ernshaw Place Residents Association (EPRA) and Clapham Junction Action Group (CJAG) commented that the wording of CS paragraph 4.46. As is stated in the paragraph and in DMPD Policy DMTS13b. A balance has to be reached between different objectives in the plan, particularly in relation to the development of sites in East Putney. This balancing of different policy objectives is taken into full account in the assessment of planning applications when each application is considered on its merits. No changes are therefore proposed to this policy.

4.44 The Clapham Junction Action Group (CJAG) considered that the guidelines as to what is considered inappropriate development in back gardens lacked clarity and contend that neighbouring properties and any conservation area should also be taken into account. This objection is not accepted as further guidance is provided in the Council’s Housing SPD which is referenced in both the contextual paragraphs referred to and in the policy. The DMPD also contains a policy and further guidance for proposed development in conservation  areas (Policy DMS2). The CJAG and the Ernshaw Place Residents’ Association considered that there should be a stronger approach to protecting spaces between buildings and considered that spaces between buildings should be no less important outside conservation areas than within them. This is not accepted as, whilst Policy DMS1b seeks to ensure that new development contributes positively to local character, conservation areas are covered by separate legislation, and form part of the borough’s Historic Assets. As such, the requirements for managing development in conservation areas have been set out separately in DMPD Policy DMS2.

Business, industry and waste

4.90 + 4.99 Clapham Junction Action Group (CJAG) commented on an apparent contradiction in figures for projected employment growth quoted in paragraphs 4.1 and 4.49. The difference is due to the different time periods quoted. The reference to the London Office Market Review has been corrected.

Design – Tall Buildings

4.118 The Wandsworth Society and the CJAG suggested that more exact policy guidelines on acceptable images would be helpful and that DMPD paragraph 2.53 should be moved or referenced elsewhere as it should relate to more than just tall buildings. The Council accepts this representation and proposes alteration of the wording to paragraph 2.53 with respect to wide-angle lens images and an additional reference to visual assessments in paragraph 2.7.

• The new proposed wording is (underlined): 2.53 Detailed visual assessments submitted with applications in order to demonstrate compliance with this policy will be required to accurately represent what would be seen by the human eye. As, tThe use of wide angle lenses, for example, can distort perspective and distance, and thus the relationship between the foreground and background, and this will not normally be acceptable. However, in exceptional circumstances where a wider context is required, alternative visual assessments, such as the use of wide angled lenses, may be submitted in addition. >>> Although the addition of the last sentence can be seen as an improvement, the refusal to remove the misleading word “can” will still lead to the same issues as we highlighted. The new wording is even more confusing that before!

4.120 The WCCG supported Policy DMS4 Criteria to determine inclusion and environmental health whilst suggesting points planning applications should address. The Wandsworth Society and the CJAG commented that DMS4 needs strengthening, with added definition and also that it needs to be applied with more rigour. Kinley Financial Inc suggested that any assessment of tall buildings should be undertaken in the context of wider objectives and that DMS4 was too restrictive. The Council considers the policy wording and intent to be clear and no changes are proposed to the adopted DMS4 policy.

Clapham Junction

4.184 The Clapham Junction Action Group request that the Territorial Army centre site should be added as a new site in the SSAD. Whilst acknowledging that the TA centre is of a size (approx 0.4ha) that would warrant consideration of inclusion as a separate site within the SSAD it was never brought to the Council’s attention in the early stages of the plan preparation period. As there wouldn’t be any consultation on this potential new site there would be no opportunity for public comment and therefore it is considered too late in the plan process to add a further site.

4.185 Royal Mail Group made a representation relating to the ASDA, LIDL and Boots site (4.1.1) on Falcon Lane, requesting clarification regarding the retention of the Royal Mail Delivery Office. The council supports the retention of the post office use which includes the delivery office facility. The text has been amended to make this clear. The  Clapham Junction Action Group also made comments relating to parts of this site that have since been developed. References to the part of the site excluded by the re-drawn SSAD boundary have been updated to reflect this.

4.186 The Clapham Junction Action Group made a representation on the Clapham Junction Station Approach site (4.1.3) relating the the new access facilities that have been developed at Brighton Yard and disputing that enhanced retail provision here could relieve any pressure from Northcote Road. The text has been updated to reflect the part of the station site that has since been improved. They also suggested that the Peabody site should be deleted following the grant of permission for redevelopment. As the site is not yet substantially completed it is not proposed to remove it from the document.

Filed under: Planning strategy

Author: Cyril Richert

The Council has now published its report on the Consultation on changes for its Local Plan (item 9 – Paper 14-141). In total 34 respondents made representations relating to the different planning documents (Core Strategy, DMPD, SSAD, …).

CJAG contributed to this consultation last July 2013. Our general point was that most of the comments made by the residents, groups and societies have been rejected or ignored in previous consultations on planning policy; it questions the purpose of the full process, other than ticking the right box at the right time.

As you see below, this time again, all our comments regarding the meaning of the policy (wording, strengthening) have been rejected, to the exception of our comment on acceptable images (which shows have we say all along that there is a real problem). Our accepted comments relate to factual corrections on dates and updating information on sites already developed.

You will find below the relevant parts on CJAG’s comments through the 40 pages. We have quickly highlighted in green when our comments have been accepted, and in red when they have been rejected.

Comments on the plan as a whole/general principles

4.1 […] Whilst a number of the general comments indicated that the Plan was not sound these did not relate to the overall approach adopted by the Council. Some comments, e.g from the Wandsworth Society and Ernshaw Place Residents’ Association (EPRA) related to how the policies applied to the assessment of planning applications, and how residents views were taken into account in assessing planning applications.

4.2 The Council does not agree with EPRA’s assertion that “residents have played part in devising these plans“. The Council has undertaken its statutory duties in consulting the public and other bodies throughout the development of the Local Plan and the Local Development Framework documents on which they are based. As reflected in this document, the Council has carefully reviewed all the comments received at every stage in the production of the documents, and agreed numerous amendments in response to the comments received.

Comments on the Core Strategy & DMPD

4.3 This section sets out comments on Chapters 1 – 3 of the Core Strategy (Introduction; Issues problems and challenges; and A spatial vision and strategic objectives for Wandsworth) and Chapter 1 of the Development Management Policies Document ((DMPD) Introduction).

4.4 The date of consultation on the topics to be included in the review in paragraph 1.4 of the Core Strategy has been corrected as identified by Clapham Junction Action Group (CJAG) and EPRA.

4.7 The CJAG and the EPRA commented on changes to the Council’s Strategic Priorities set out in Core Strategy paragraph 1.20. The change to paragraph 1.20 reflects the priorities identified in the Council’s latest Corporate Business Plan.

4.11 Paragraph 4.1 has been amended to reflect the latest population projections and revised housing targets. The changes do not reflect “a major goal to transform Wandsworth into a dormitory borough” as suggested by CJAG.

Sustainability

4.12 The Putney and Wandsworth Societies, Clapham Junction Action Group (CJAG) Ernshaw Place Residents Association (EPRA) and Wandsworth Clinical Commissioning Group (WCCG) made various comments on the wording of Policy SD1. No changes are proposed as the policy uses standard wording provided by the Planning Inspectorate to reflect the principles in the National Planning Policy Framework. The Policy was supported by Barratt London Ltd and the St James Group.

Housing – The provision of new homes

4.28 The Putney Society, Ernshaw Place Residents Association (EPRA) and Clapham Junction Action Group (CJAG) commented that the wording of CS paragraph 4.46. As is stated in the paragraph and in DMPD Policy DMTS13b. A balance has to be reached between different objectives in the plan, particularly in relation to the development of sites in East Putney. This balancing of different policy objectives is taken into full account in the assessment of planning applications when each application is considered on its merits. No changes are therefore proposed to this policy.

4.44 The Clapham Junction Action Group (CJAG) considered that the guidelines as to what is considered inappropriate development in back gardens lacked clarity and contend that neighbouring properties and any conservation area should also be taken into account. This objection is not accepted as further guidance is provided in the Council’s Housing SPD which is referenced in both the contextual paragraphs referred to and in the policy. The DMPD also contains a policy and further guidance for proposed development in conservation  areas (Policy DMS2). The CJAG and the Ernshaw Place Residents’ Association considered that there should be a stronger approach to protecting spaces between buildings and considered that spaces between buildings should be no less important outside conservation areas than within them. This is not accepted as, whilst Policy DMS1b seeks to ensure that new development contributes positively to local character, conservation areas are covered by separate legislation, and form part of the borough’s Historic Assets. As such, the requirements for managing development in conservation areas have been set out separately in DMPD Policy DMS2.

Business, industry and waste

4.90 + 4.99 Clapham Junction Action Group (CJAG) commented on an apparent contradiction in figures for projected employment growth quoted in paragraphs 4.1 and 4.49. The difference is due to the different time periods quoted. The reference to the London Office Market Review has been corrected.

Design – Tall Buildings

4.118 The Wandsworth Society and the CJAG suggested that more exact policy guidelines on acceptable images would be helpful and that DMPD paragraph 2.53 should be moved or referenced elsewhere as it should relate to more than just tall buildings. The Council accepts this representation and proposes alteration of the wording to paragraph 2.53 with respect to wide-angle lens images and an additional reference to visual assessments in paragraph 2.7.

• NB: we haven’t seen the proposed wording. We said: “The guidelines as expressed in DMPD 2.53 are clearly misleading if not wrong and create un-necessary confusion on the permitted documents. We strongly suggest that this is changed with a correct guideline and that the incorrect word “can” is removed such as: “The use of wide angle lenses, for example, can distorts perspective and distance, and thus the relationship between the foreground and background, and this will not be acceptable.”

4.120 The WCCG supported Policy DMS4 Criteria to determine inclusion and environmental health whilst suggesting points planning applications should address. The Wandsworth Society and the CJAG commented that DMS4 needs strengthening, with added definition and also that it needs to be applied with more rigour. Kinley Financial Inc suggested that any assessment of tall buildings should be undertaken in the context of wider objectives and that DMS4 was too restrictive. The Council considers the policy wording and intent to be clear and no changes are proposed to the adopted DMS4 policy.

Clapham Junction

4.184 The Clapham Junction Action Group request that the Territorial Army centre site should be added as a new site in the SSAD. Whilst acknowledging that the TA centre is of a size (approx 0.4ha) that would warrant consideration of inclusion as a separate site within the SSAD it was never brought to the Council’s attention in the early stages of the plan preparation period. As there wouldn’t be any consultation on this potential new site there would be no opportunity for public comment and therefore it is considered too late in the plan process to add a further site.

4.185 Royal Mail Group made a representation relating to the ASDA, LIDL and Boots site (4.1.1) on Falcon Lane, requesting clarification regarding the retention of the Royal Mail Delivery Office. The council supports the retention of the post office use which includes the delivery office facility. The text has been amended to make this clear. The  Clapham Junction Action Group also made comments relating to parts of this site that have since been developed. References to the part of the site excluded by the re-drawn SSAD boundary have been updated to reflect this.

4.186 The Clapham Junction Action Group made a representation on the Clapham Junction Station Approach site (4.1.3) relating the the new access facilities that have been developed at Brighton Yard and disputing that enhanced retail provision here could relieve any pressure from Northcote Road. The text has been updated to reflect the part of the station site that has since been improved. They also suggested that the Peabody site should be deleted following the grant of permission for redevelopment. As the site is not yet substantially completed it is not proposed to remove it from the document.

Filed under: Planning strategy