Author: Cyril Richert

In accordance with the Town and Country Planning (Local Planning) (England) Regulations 2012, Wandsworth Council was (again!) seeking representations between 17 May 2013 and 28 June 2013 on Proposed Submission versions of its Local Plan documents which it is intending to submit to the Secretary of State for independent Examination.

Last review was conducted (and concluded) by a government inspector hearing in October 2011. Following the hearing session (where CJAG presented its view on Clapham Junction) the inspector concluded in its report on a global soundness of the plan. The documents were definitely adopted in early 2012 and became official policy. However, as since then the London Plan was published, Wandsworth Council has to amend its plan to seek conformity with the global rules.

You can download and read our full submission HERE.

The local plan is made by several documents, the three most important being:

1. Core Strategy (this sets out the spatial vision, strategic objectives including strategic policies, for the borough of Wandsworth over the next 15 years and beyond).
2. Development Management Policies Document (this sets out detailed policies for managing development in the borough).
3. Site Specific Allocations Document (this sets out the main sites where development or other change is anticipated in the borough, or where the Council has particular objectives, together with policies for individual sites and details about the allocation of waste sites and detailed maps relating to the tall buildings policy).

Find below our main comments (for details, see in our representation) and criticism on the different documents:

Core Strategy

The wording of the policy is an open door to all understanding and misuse by the Council to justify any planning development. We have already numerous examples where factual breach of policies is balanced with subjective “overall benefit” in Wandsworth planning reports. Those statements have no place in the document and must be removed for the policy to become effective.

Development Management Policies Document

Although the policy seems to be specific enough, in reality many resident associations, groups and even councillors have recently criticized the lack of rigour to which those policy have been applied and often ignored by Wandsworth Council. Within the last years, Wandsworth Borough Council has passed a series of applications often making a very wide interpretation, dismissing or even ignoring existing policies. Therefore, they are not effective and need to be reinforced.

Site Specific Allocations Document

Some statements relate to hypothetical views that are not justified by any existing or even suggested possibility. Therefore it cannot be taken seriously and undermine the document as guideline for the sites. A major site (the territorial Army site) is missing.

The policies are currently often ignored or put aside by the Council

Our general point is 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.

We want to believe that this time it will be different and this new review of the local plan will give opportunities to address the concern of the local residents, including the lack of rigour of the use made of the current policy guidelines.

If you need only one example of the consideration given to the policy by  planning officer, you can read the conclusion of the planning report for Capsticks site (77-83 Upper Richmond Road – 2011/0054):

“The proposal is deficient in a number of policy areas including levels of affordable housing, office re-provision, children’s play space and sustainability measures. The proposal does however provide a wider regenerative package […].

On balance, the overall benefits to regenerating this site, is considered to provide a sufficient exception for not achieving full policy objectives and could not be precedential in the consideration of future schemes in this area.”

Yep, but Wandsworth Council does not care about affordable housing, children’s space, sustainability and office space (we’re just becoming a dormitory borough and an investment place for rich foreigners!).

Similar comments have been made by other groups.

The residents of Ernshaw Place said:

“It continues to surprise and dismay local residents that they have played no part in devising these plans and have seen no shift of position by WBC after commenting and engaging with the consultation process since 2010. This is in itself against the letter and spirit of the NPPF.

Whilst local and national planning policies have evolved, the participative role of local residents and local amenity groups in forming a strategy for their local environment has consistently been dismissed under the premise that existing policies would protect them from harmful and inappropriate development. This may be the theory but has not been the reality.

We would challenge that all the planning applications approved on the Upper Richmond Road using the current policies have failed to meet significant DMPD and Core Strategy along with SSAD policies. This reflects badly on the consultation process and dismissal of objections to individual planning applications suggests that Wandsworth Council just pays lip service to the consultation process.

The policies must be strengthened and more importantly applied at planning application stage to have any validity in the eyes of those unpaid residents who have for 2 years been engaged and have fought for redevelopment on a human scale in their neighbourhood.”

The Wandsworth Society said:

“We think to make the Core Strategy effective it needs to strengthen policies that will help keep the borough a mixed live/work community and not a dormitory town. Sadly the council itself has undermined the strategy by selling for residential development many of the small-workshop sites essential to support the needs of local people, and allowing others not to include small workshop areas in large development sites. […]

Whilst we recognise that subjectivity is inevitable in planning decisions, Policy DMS4 [Tall Buildings] is unsound because, as currently interpreted, it is completely ineffectual in judging either the harm or the benefits of tall buildings. A coach and horses can be driven through the various policy guidelines.”

We have not received the Putney Society’s representation nor the Battersea Society’s comments, but you can bet they all say the same as above!

Filed under: Planning strategy

Author: Cyril Richert

At the last Planning Forum meeting organised at Wandsworth Town Hall, I asked planning officers whether images using a wide angle camera were acceptable.

As we demonstrated in 2012, it seems that developers are still providing wide angle images of their proposals despite the current policy.

The Development Management Policies Document states, para 2.49 page 23:

“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. The 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 be acceptable”.

Two years ago, following the Ram Brewery inquiry, the government inspector rejected the plan and wrote in his report (p7):

“Guidance on how to prepare AVRs consistently indicates that images should ideally be made within a 40° field of view (FOV); beyond that, the perceived shapes of surrounding buildings may be distorted […]  the use of a wide angle lens has the effect of distorting perspective and distance, and thus the spatial relationship between foreground and background. Existing buildings, and therefore the new ones, appear further away or smaller than they are or would be in reality, This was particularly apparent to me when I compared the AVRs to the actual views from the same viewpoints and is also demonstrated in the Wandsworth Society’s comparable 40º AVRs.

[…] the applicant’s AVRs cannot be taken as accurately representing what would be seen by the human eye.“

What is a wide angle photograph?

In photography, a wide-angle lens refers to a lens whose focal length is substantially smaller than the focal length of a normal lens for a given film plane. This type of lens allows more of the scene to be included in the photograph, where the photographer may not be able to move farther from the scene to photograph it. Another use is where the photographer wishes to emphasise the difference in size or distance between objects in the foreground and the background; nearby objects appear very large and objects at a moderate distance appear small and far away.

Photo with a 48 mm lens.

Photo taken with a 34 mm lens (wide-angle). The tower disappears nearly completely behind the house. The camera was moved closer in the second picture in order to keep the same dimensions for the foreground (the house); it’s the only way to compare properly the impact foreground vs background.

The most commonly used normal lens is 50 mm, but focal lengths between about 40 and 58 mm are also considered normal. By custom, a lens of focal length 35 mm or less is considered wide-angle. Common wide-angle and ultra wide-angle lenses are 35, 28, 24, 21, 20, 18 and 14 mm.

In the case of Peabody’s proposal, lenses used were 24mm or 35mm. For the current Ram Brewery scheme, they have also used lenses of 24mm and 35mm as stated in their Accurate Visual Representation methodology. They are definitely wide-angle lenses.

Wandsworth planning officers say images are correct

So then I tried to understand how representations using a wide-angle camera could be seen as accurate to what would see a human eye.

Wording is important in policy

As I quoted the policy DMPD (above), I was told by officers that the exact words used were: “The use of wide-angle lenses, for example, can distort perspective and distance […] and this will not be acceptable”. Therefore, when it does not, this is acceptable. As I was told “there are times when images using a wide angle camera reflect what will be seen by human eye“.

So then I asked a photographer with more than 10 years experience: “When does it not distort perspective and distance?” The answer is:

“When you only take a photo of a plane surface, for example a wall or a sheet of paper. In all other cases when you have a foreground and background. it does distort perspective“.

As demonstrated, wide-angle images are not close to what the naked eye would see when the development is complete. Rather the opposite as you can see above. Their purpose is to give other information, such as number of buildings, location…etc. This is explained by Miller Hare, a company specialised in those images, saying: “it is logical to use a wide angle lens in order to include additional context in the print“.

It seems therefore that the Wandsworth planning officers dispute the fact that using a wide angle camera to illustrate buildings in a proposed scheme will always impact perspective and distance and that buildings, and therefore the new ones, appear further away or smaller than they are or would be in reality. Tim Cronin said: “the images used are the closest representation to what the naked human eye would see once the development is complete“.

Images shown to the public do not need to be correct

I pointed out the fact that images available on the Council website (for the public to consult) were not acceptable representations. I was told that the process is to put on the website all documents sent by the developers, whether they are acceptable or not and therefore it does not imply that it was validated by Wandsworth planning department. CJAG received a letter from Tim Cronin, planning officer, saying that: “This does not mean the plans or supporting documents are accurate at this stage, just that they have submitted the information required“.

This is the public to guess probably…

In addition, in order to distribute the information as soon as possible whenever a major scheme is due to consultation, the Planning News leaflets distributed to the public by the Council may not include accurate images, but are considered better than drawings and, as Tim Cronin said, “serve the purpose at that stage adequately“.

Wandsworth policy in a nutshell

In order to summarize:

1. This is a fact that images of buildings taken with wide angle lenses always distort perspectives; even architect experts say that their purpose is to provide other information than what the naked eye would see. However Wandsworth planning department disagree.
2. Validity is made by ticking boxes on a list of required documents. This does not mean that those docs (and images) published on the Council’s website have to be accurate.
3. They may publish and distribute to the residents architect’s photos which do not represent what the naked human eye would see once the development is complete, as long it is certified by experts.

Filed under: Planning strategy

Author: Cyril Richert

On Tuesday, June 4th, was organised the Planning Forum at Wandsworth Borough Town Hall. You will find below some comments and feedback. As usual, they do not intend to replace any minutes (that we usually receive only a few days before next meeting anyway… ).

MINUTES OF PREVIOUS MEETING

Argh! 45 minutes spent on that… it says it all!

a) It started with a lengthy discussion raised by one of us on the legislation about offices converted and residential blocks redeveloped. In a nutshell the issue of the vacancies for a very long period of time of premises (shops). If all developers are asked mix-used developments, is it going to be viable? Martin Howell (officer, planning policy) replied that policy is that in town centre they wish mixed used, it does not mean shops only (it can be community, etc) but it means active frontage.

b) Nick Evans (Friends of Putney Common – FoPC) asked about the progress that was made on resolving issues with the formatting of the planning portal. Martin Howell said that the company they use  has changed their customer manager a few time, thus the delay in addressing anything. However:

1. they promised the formatting online comment will be introduced in V4 (September 2013 release)
2. they said that adding people name (when they fill online comment) was more difficult (i.e. they try to find excuses to not do it!) but the planning department is pushing on that.

c) Nick Evans found also that the minutes were not clear about the policy on wide angle (and the point I raised last time). Tim Cronin showed a little bit of irritation to have to deal with that again and said the certified AVR by the company working with the developer are “the closest images that you can get by naked eye” (although probably not recorded in the minutes we will have to remember that).

d) When I took over about the minutes Cllr Cuff started to be annoyed that we get again other the things that were discussed last time. A couple of things should have been recorded in the minutes, including Cllr King agreeing that at least an acknowledgement should be sent in response to letters received by the planning department. Other quotes were completely absent regarding statements on wide-angle images but Cllr Cuff had enough and after saying that no, he was not authorising access to the tape recorded of last meeting, he added that those are just minutes, that is not really important!

So, 45 minutes later…

LOCAL PLAN

Martin Howell repeated what he said last time on the consultation:

• policy maps are shown in the plans.
• changes and updates appear clearly with colours (accommodation, retail surface, new town centre at Nine Elms…etc)

He said it doesn’t stop commenting to things that have not been changed, but encourages to comment on things that have been changed.

COMMITTEE  PLANNING DEVELOPMENT RIGHTS

1. New rights for residentials since 30 May 2013: outside conservation no need for planning permission to extend 3-6m and 4-8m (if detached). Wandsworth Borough Council will send a notice solely to the neighbours to the boundaries of the property. Objections will have to be made within the 21 calendar day period.
2. Change of use from office to residential: non of the Council bids were successful but the Mayor of London managed to have exemption for central London , which includes up to Nine Elms.

ENTERPRISE AND REGULATORY REFORM

Duplication (to apply for conservation area consent for the demolition) is removed. It will be covered by the planning application.

ANY OTHER BUSINESS

• Northern Line extension consultation: representation must be addressed to the SoS for Transport.
• Consultation on Cross Rail2: Metro vs Regional proposal. Regional includes the Metro routes but extends to join the national rail network. In Ragional plan tunnels are bigger, trains bigger and longer. The Metro plan is similar to the Tube.
• Nick Evans said that the minutes and new agend was snet with a very short notice (Friday 31st for meeting on Tuesday 4th). He asked that WBC considers the possibility of deputation before the PAC.
• Cllr Nick Cuff said that they are thinking about merging the agents forum (planning matters discussed with architects, developers, planners) which is rather unattended with the planning forum.

Next date TBD (when decision is made about the merge).

Filed under: Planning strategy

Author: Cyril Richert

There has been various interesting discussions recently in the newspaper about the impact of tall building (very very tall buildings I mean!) on London skyline.

In early March, Rowan Moore, the Observer’s architecture critic, organised a panel discussion about the pros and cons of London’s increasing number of tall buildings.

Despite the recession, London is in the grip of a tall building frenzy. Driven by foreign money, ego and the pressure to build homes and offices, towers are being approved and constructed at a staggering rate. London Bridge is already home to Europe’s tallest and soon the South Bank and Vauxhall will be rivaling the City as serious high rise hubs.

Is our planning system working? [A question that many are currently wondering in Wandsworth!] Are tall buildings blighting London’s skyline? According to the Guardian’s article, most of the audience didn’t think so at the beginning; more did by the end.

A handy graphic showing how London’s skyline is changing

The Journalist wrote (words in bold are my own highlight):

“No one had a good word for the towers now planned and in some cases rising on the south bank of the Thames, mostly containing flats sold to overseas speculators, many of which will no doubt remain empty.

For me the architectural point is that tall buildings are more visible than others and therefore should reach higher standards of design, which is not happening. There is also a political point, as the current spate of tower proposals represents the triumph of financial speculation over most environmental considerations. Is this really what we want?“

The Walkie Talkie building view from St Katherine’s docks, and it’s impact on Ten Trinity Square (a building dated 1922 which played host to the inaugural meeting of the General Assembly of the United Nations in 1946). The Walkie-Talkie tower has upset Unesco and been called ‘brutally dominant’ by English Heritage

I read an article about the Walkie Talkie from Rafael Viñoly. It says:

“Viñoly is indifferent to the criticism, though, seeming to enjoy the controversy his project has created. […] He is untroubled by the extent of Rees’s [note: chief planner of London, who has presided over its bold, vertical evolution since 1985] powers: “You can say it’s a form of absolutism, but at least you have someone to blame, for the good and the bad. If Louis XIV hadn’t been the king, then Paris wouldn’t have happened – right?””

I really hope that Mr Viñoly has not the same knowledge in history as he’s got in architecture. Paris was not built by Louis XIV (rather the opposite, he decided to avoid that city and set up in Versailles) and part of Paris architecture has been transformed in the 19th century by Baron Haussmann under Napoleon III.

And regarding heritage buildings Mr Viñoly couldn’t less care saying:

“The view from the Tower is already ruined – would it be logical to demolish all of the visible modern buildings?”

When things are bad, there is no need to seek to improve them.

A view that is shared by Wandsworth planning as the Assistant Director for Planning said last autumn (regarding 102-104 High Street, p.a. 2012/3666) that the existing building sets a precedent for height and bulk, which seems to imply that an application for a new building is acceptable if it is no worse than that presently there.

Coming soon also the “Cheesegrater” (Leadenhall building) although the current video does not show that it will be half blighted by the then fully erected Walkie Talkie!

See also a series of photos from the Daily Mail showing how the skyline of London has changed within the last 2 years.

Filed under: Planning strategy

Author: Cyril Richert

Where is the vision for London’s skyline is wondering Simon Jenkins in his article in the Evening Standard on April 30th?

First, Simon Jenkins is right to remember the broken promise of Boris Johnson at at time when was running for Mayor of London in 2008. In November 2008 it was actually one of our first article on this website: Mr Johnson had warned he will not approve skyscrapers if residents are opposed to them, confirmed he will redraw the planned skyline as a matter of priority and called Ken Livingston’s plans’ “phallocratic towers”.

His U-turn will be his legacy to London. You can vote him out, but a long time after he’s left you will still see the Walkie Talkie, the Helter Skelter, the Razor (the Strata tower, named ugliest building of the year in 2010) or the Cheesegrater in the sky of London!

Simon Jenkins wrote:

“Johnson wants towers everywhere. He wants them looming over Victoria, Euston and Waterloo. He wants them over North Kensington, Brentford and Battersea. Above all, he wants them along the banks of the Thames, not so much a row of pepper-pots as an entire table-top of condiments. […]

Though the Mayor is supposedly responsible for high buildings, he appears to have allowed the planning ministers, Eric Pickles and Nick Boles, to upstage him. The developments have been pushed through after lobbying by the developers, on the grounds that Lambeth councillors are in favour. These poverty-stricken south London councils are approving everything that comes their way as a result of so-called “section 106” deals.

These deals involve developers offering token numbers of “affordable homes” in their towers or, more usually, giving the councils cash to spend elsewhere. Southwark has garnered £70?million in such payments for allowing unlimited towers further downstream. Because the Government will not pay for social housing in the normal way, it encourages such bribes to distort normal planning considerations. […]

In most great world cities there is someone in an office somewhere — such as a planner employed by the Mayor — who has a vision for the city skyline that he can share with the world. It embraces how renewal should take place and where, what views should be guarded, where highly visible structures should go and not go. On that basis people can debate, argue and forge a compromise.

In London there is no such person and no such vision. The Mayor has none. “

Although the section 106 has mostly been replaced by the CIL (Community Infrastructure Levy, read at the bottom HERE), the purpose is similar.

You can read our article: Section 106 dictating our landscape

Filed under: Planning strategy

Authors: Jacqui Bowers & Cyril Richert

On Tuesday, April 16th, was organised the Planning Forum at Wandsworth Borough Town Hall. You will find below some comments and feedback. As usual, they do not intend to replace any minutes.

Pubs Protection Policy

The topic was added to the agenda by Dale Ingram, CAMRA‘s member, representing the local resident group which campaigned against the proposal to redevelop the site of the current Castle Pub in Battersea High Street.

Wandsworth Borough Council (WBC) policy is that there is no need to protect/maintain pubs when already one other exist with 400m (considered as walking distance). The Castle Pub Campaign group said that central government is currently moving to protect pubs (making a difference within the A3/A4 categories). Someone said that it must depend on density instead.

Assistant director for planning, Ms Manshanda, explained that at the end of the day it was a question of economic viability. When there is a demand, a pub will stay. But Dale Ingram said this is not true as everyone knows that the issue is the cost of renting premises and the cost pubs are buying beers etc…

Councillor King (who was chairing the meeting in the absence of Cllr Cuff) questioned whether Wandsworth Council should be promoting alcoholic drinking in the light of recent surveys. The problem raised by CAMRA was cheap alcohol being sold as lost leaders in supermarkets.

Nick Evans from Friends of Putney Common (FoPC) asked if it was possible to have a list of the pubs that must be protected in the Borough and Ms Manshanda said that they can provide a list of A3/A4 premises (not very helpful, there are 1000s!)

Register of Community Assets

The Castle pub is the first (and only, currently) registration as as an Asset of Community Value under the Localism Act in WBC.

Regarding the Castle pub, Ms Manshanda confirmed that there are rumours that they don’t want to sell (therefore the astronomic price tag of £2.25m, having paid sellers Young’s Brewery just £1.1m in 2011). And in addition the developers have just appealed (a few days ago) against the decision to refuse them the 5 storey building.

Local Plan

The revised Local Plan was due to go before the Overview of strategic and Transportation committee on April 23rd.

After the adoption of the London plan, WBC is meant to review and amend its current local plan. Consultation period for residents is 17th May – 28th June. Any objection requires evidence based. Martin Howell and his team will be available from 17th May if Societies/large groups want to organise meetings for them to explain the changes.

On of the main change is on targets for affordable housing (targets set by London); but there was also the occasion to update the current documents with changes in the Borough (in term of new developments) that have happened since 2009.

There are track changes on the website: new parts are in red, removed parts are with strikes through.

New documents to be reviewed can be downloaded here (item 7. on the page).

Protected views in the borough

There will also be a consultation on local views (see our previous article in December 2012). The document has been re-drafted with a shorter list of views and more explanations have been added on what need to be protected in the pictures.

Neighbourhood Planning

It seems to really only apply to rural areas. Putney/Diador Road residents have looked at the requirements but came to the conclusion that it was not appropriate. Surrey Lane and Winstanley groups asked WBC to become a Neighbourhood forum. They were both refused as they did not meet the requirement: they first need to apply to be registered as a neighbourhood area before to apply for a forum (according to Martin Howell, the procedure is clearly described on the website).

Ms Manshanda confirmed her previous comments that in her view it benefits more to rural area than to urban area. A Neighbourhood Plan will have to show at least the same housing target as WBC,(i.e. 1145/year for the next 5 years) and those target are very high (set by London).

Major Infrastructure Schemes

Northern Line: the possibility to extend to CJ has been protected but there is no budget/consideration currently.

Changes in Planning Legislation – permitted development

Property extensions: WBC raised concerns and would have objected. But the House of Common voted against Opt Out possibilities yesterday (as reported by BBC said T Cronin) so not possible. The Secretary of States for Community, Mr Pickles, is going to try to find a compromise between Lord/Common houses.

A.O.B.

Ram Brewery (asked by someone from the WandSoc)

Ms Manshanda said they received a lot of representations from residents. She added that it looks unlikely to be presented before the Planning Application Committee before July 2013.

She made 2 noticeable comments:

1- The Design review panel has been consulted at the pre-application level and there is no plan to consult further. Facing the protest from Monica Tross (Battersea Society) she said that it will be up to Cllr Cuff to decide whether there is another review (Cllr King confirmed that it will be up to Cllr Cuff with the advice of the planners – who are against it apparently!).

2- Regarding the Wandsworth Conservation Area Advisory Committee (WCAAC) meeting, Ms Mashanda said the WCAAC had mixed views and a minority was in favour of the scheme! That’s seeing a very positive outcome of a meeting where only 3 out of 8 people talked in favour of the scheme, and that the vote decided that the WCAAC was going to object against the development!

State of consultation

Nick from FoPC complained about the poor condition in the Planning Application Committee room. Ms Manshanda said new microphones have been ordered.

Julia Macham said that the comments left using the facilities of the comment box on the website are very poor (all displayed on 1 line, no name on the list). Martin Howell said he will look at it and that should be corrected.

Are the letter sent to planning officers to be responded? Tim Cronin said that they always answer the first letter. When another response come saying they disagree, they have nothing to say more but that they disagree too so do not answer. Cllr King agreed that at least an acknowledgement should be sent.

Community Infrastructure Levy (CIL)

The question was: “Why minor domestic applications, for dormer windows for example, required to be accompanied by a CIL form which is not relevant to minor works such as extension dormers, etc?”

And the answer: Because otherwise an officer needs to check. It is time consuming for them, they have limited resources. If not necessary it is not forwarded to the CIL team. Cyril asked if a simple check box “not necessary” or such thing wouldn’t be more efficient for both parties. Answers was: well it’s not that hard to fill the form and save time for us as it is.

Are images using a wide angle camera acceptable?

Basically it gives a good idea of what will be the defence of the Council (we summarise the outcome of the decision, that was not discussed specifically in this order):

1. When they receive an application they put everything on the website (i.e.e they accept all materials). Then they check and if they think some images are not correct they ask the developers to provide others.
2. They used the images provided by the developers – whether correct or incorrect – in the planning publicity form, because they want the consultation to start asap and the public needs to have a view of what is proposed.
3. In the policy they use the word can, which means that they consider that some wide lens view can be accurate to what a human eye will see, so therefore acceptable.
4. For the Ram Brewery they received a set of verified views
5. Ms Manshanda CERTIFIED that views for the RB have been verified and accurate to human eye.

CJAG has therefore written to Ms Manshanda asking confirmation of the policy and to arrange a meeting to be able to check the certified view as soon as possible (see the letter HERE).

Next meeting: 4th June 2013

Filed under: Planning strategy