Hackbridge & Beddington Corner Neighbourhood Development Group

www.hackbridgendg.com

Iain Williams 3 December 2018London Borough of Sutton24 Denmark RoadCarshaltonSurrey  SM5 2JG

Dear Mr Williams

Planning Application DM2018/00160LAND NORTH OF HACKBRIDGE TRAIN STATION

We note that the planning application was submitted on 2 February 2018, although not validated until November 2018. During this time, Sutton Council’s Local Plan 2031 was adopted on 26 February 2018. It should also be noted that the Hackbridge and Beddington Corner Neighbourhood Plan was recently approved at referendum and came into force on 30 November 2018.

The documentation refers to the old site allocation and policies, as well as the Hackbridge Draft Masterplan, which is not a statutory planning document and should not be considered with this application. Our comments below where applicable refer to the new Local and Neighbourhood Plans.

We are writing to OBJECT to this planning application for the reasons below:-

1.0 Housing and Built Environment 

Local residents have identified issues with the built environment of our local area, which are listed in the Hackbridge and Beddington Corner Neighbourhood Plan. These are;

● Existing housing estates are isolated from each other,● There is a lack of joined up ‘greeness’ across the neighbourhood,● Our housing needs are not being met,● Protect and conserve the suburban character of our neighbourhood,● Concern about poor design of new builds,● Lack of public places for people to interact.

The Hackbridge and Beddington Corner Neighbourhood Plan requires all new developments to address these issues and the proposed Hackbridge Gardens development should conform with the Built Environment policies as follows;

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1.1 H&BEP1: Local Character and Sense of Place

All developments shall make a positive contribution to the character of Hackbridge and Beddington Corner -

The development proposes for 10 no. mixed use residential/commercial buildings to be constructed on the 1.3 hectare site. The heights of the proposed buildings are as follows;

● 1 no. 11+ storeys● 1 no. 9+ storeys● 2 no. 8+ storeys● 1 no. 7+ storeys● 1 no. 6+ storeys● 1 no. 5 storeys● 3 no. 4 storeys

Six of the tallest buildings for the proposed Hackbridge Gardens development will be located on top of a podium, which accommodates car parking and refuse collection. The height of the podium level is greater than a standard residential storey, and therefore each of these blocks will feel taller that the equivalent number of residential storeys.

We acknowledge that the site is located within an area of taller building potential, as noted on Sutton Council’s site allocation S2, however this is for 7 to 10 storeys and it requires the proposed development to be exceptionally designed.

Therefore the proposed Hackbridge Gardens development does not conform with the requirements of the S2 site allocation nor H&BEP1 because;

● Five of the 10 no. buildings proposed for the site are taller than Saxon House, currently the tallest building in Hackbridge. This does not respect, in our opinion, the scale of the suburban setting of the local area,

● One of those buildings (Block A) incorporates ground level plus 10 storeys of residential units making it 11 storeys in total, exceeding the 10 storeys considered acceptable for a ‘tall’ building, made worse by the ground floor level being part of the extra tall podium level.

● The appearance of the development is similar to many other high density developments being built across London, and therefore not of exceptional quality. No aspect of the external facade is designed to connect the buildings to the local area, like the lavender motifs of the Felnex development or the colourful wind cowls of Bedzed, which have become iconic to the area.

● The proposed development is for 258 dwellings, which exceeds the indicative housing capacity for the site of 174 dwellings, as noted on the S2 site allocation.

● Positioning the tallest building on the southern side of the site does not maximise access to natural light to the shorter building behind, as required by H&BEP1.

● We have also noted that 39 of the flats, across a number of blocks, have single aspect, some of which are facing north which therefore limits access to light.

As a consequence of locating so many buildings on the site, the existing two storey parade of shops and Victorian cottages along London Road, will be severely overlooked. As will the flats located in Saxon House, houses on Furlong Close and the flats currently under construction on the Felnex site.

Roof gardens are located on Blocks H and I, at the fourth floor level and seem to incorporate outdoor gym equipment. Whilst the neighbourhood plan supports roof gardens, to increase the biodiversity of the site, these roof gardens are designed for groups of people to use and we are concerned that this will increase the sense of overlooking and nuisance from noise, to the existing buildings along London Road.

For many parts of the neighbourhood the visual impact of the proposed Hackbridge Gardens development will be major. The Townscape and Visual Appraisal Report submitted with the planning application assesses six viewpoints across the local area, as noted on page 39. However these are located either north of the site, or south. No views are provided from the east or west, therefore we do not know, from the images provided, how the proposed development will look when standing within the Beddington Farmlands, looking back towards Hackbridge Station, or from standing on Hackbridge

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Green. Drawing no. LA.08-2 indicates that you will be able to see most or part of the proposed development from these locations.

We would also like to know how the development would look from Furlong Close and Foxglove Way. These are residential streets located directly north of the site and from drawing no. LA.08-2, it appears that you will be able to see the development from these streets. It concerns us that the northern view chosen for the Townscape and Visual Appraisal Report, was from further along London road, near Bedzed, where a row of mature trees obscure the view to the development. We would like to know more about what the visual impact of the development will be from within the Flowers Estate.

In general insufficient information has been provided to be able to fully understand the full visual impact of the proposed development across our neighbourhood. Nine cross sections of the site were provided and NONE of them included the two storey Victorian cottages along London Road. Therefore we cannot accurately ascertain the scale of the proposed development against the existing adjacent buildings.

1.2 H&BEP2: Sustainable Design for Sustainable Living

Where feasible and practical, residential development proposals should provide cycle storage that;● at least meets the minimum cycle standards set out in the Sutton Local Plan,● should be located adjacent to the main entrance in flatted developments.

On drawing 273-CDA-Z1-00-DR-05-A-0100 Rev 03, submitted with the planning application, it appears that only Blocks A, C, D and E have dedicated cycle parking providing a total of 176 cycle parking spaces, as noted in the Movement section below. This is insufficient and not in conformity with the Sutton Local Plan. In addition, since not all Blocks have dedicated cycle parking, residents will have to go through the car park to access the cycle parking across the site. The areas where the cycle parking is located also appears to be open and not secured. Having the cycle parking located away from the main entrances to the residential blocks, will make it feel less secure and discourage cycling. How will if feel for a family with young children, or a person on their own, to have to traverse through a carpark to access their bicycles, which are in an open area that is tucked away in a corner?

H&BEP2 also requires for outdoor drying to be considered. As part of the drive to help reduce the energy consumption of the residents, outdoor spaces such as balconies could incorporate screening to provide private spaces for locating a drying rack. This would help to reduce dependence on electric clothes dryers, or clothes being draped over radiators - this causes issues with indoor moisture content. The balustrades to each balcony of the proposed development, have open metal uprights only and do not provide any privacy for outdoor drying.

Therefore the proposed Hackbridge Gardens development does not conform with the requirements of H&BEP2 for cycle storage and outdoor drying.

In addition we cannot find any information confirming what the strategy is for dealing with waste. We do not know if segregated under bench bins will be provided within the kitchens of each dwelling, to help residents manage their waste to ensure the maximum amount is recycled or composted. It is better to do this at the point of use, rather than try to separate it later when taken to communal bins.

1.3 H&BEP3: Design for Sociability

All development proposals shall demonstrate that sufficient consideration has been given to ensuring that the design will encourage sociability and community interaction -

We note that a number of green spaces are provided within the proposed development, which we welcome.

However further detail is required in relation to the following, to ensure that these green spaces provide benefit beyond the boundary of the site and help interaction with the wider community;

● No details are provided to show how the roads and footpaths through the site connect to Mile Road and the bridge beyond. Policy EP1 below, requires all development proposals to

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develop or provide access to Beddington Farmlands. It identifies Mile Road as a point of access to the Farmlands.

● We note that a series of very wide steps and ramps have been designed to the edge of the podium, to provide more direct access between street level and the podium. We are concerned that some of the visuals do lot show any handrails and therefore may not accurately represent what will actually get built, unlike the photograph of a built example on page 84 of the Design and Access Statement, which shows numerous handrails and balustrades.

● No details are provided showing if there is a footpath in front of Block K, facing onto the Hackbridge Station car park. Traffic into the Station car park and new traffic to the proposed development, will pose a risk to any pedestrians walking past Block K, to access Hackbridge Station or the new retail units of the proposed development. We do not think that it is ok to show the proposed building positioned up against the site boundary and not take into account how pedestrians will get safely past this point.

Without further details regarding the above, then we are not satisfied that pedestrian movement across the site and to the wider community beyond, has been sufficiently considered to ensure good community interaction.

1.4 H&BEP4: Housing Needs for Hackbridge Residents

All residential development proposals will be expected to give priority to meeting local needs -

The Accommodation Schedule, submitted with the planning application, lists which flats are ‘affordable’. Page 102 of the Design and Access Statement confirms that 35% of the dwellings will be affordable.

However no details are provided which confirms the tenure for the affordable housing, so it cannot be ascertained how the affordable housing provided by the proposed development will meet local needs.

This is not ok, because we have already observed that the prices of the newly constructed housing are already pushing up housing prices of the existing housing. We need to know if the affordable housing types, to be provided by the Hackbridge Gardens development, will helps residents on varying household incomes.

2.0 Local Economy

Local residents have identified issues with the economy of our local area, which are listed in the Hackbridge and Beddington Corner Neighbourhood Plan. These are;

● Retain employment land as currently designated,● Need to promote local employment,● Support the role of the local centre,● Foster new business and trade within Hackbridge,● Promote community-run shops and other local social enterprises and other local supply

chains.

The Hackbridge and Beddington Corner Neighbourhood Plan requires all new developments to address these issues and the proposed Hackbridge Gardens development should conform with the Local Economy policies as follows;

2.1 LEP2: Employment opportunities in Hackbridge

Policy LEP2 requires all employment proposals to consider business opportunities that cater for recreational visitors to the Wandle Valley Regional Park (‘WVRP’) and flexible spaces for new start up enterprises, opportunities for training and apprenticeships.

The location of the site beside Hackbridge Station, means that the commercial aspect of the proposed development could provide for business opportunities such as cycle hire / repair shop, information centre that would help attract and support visitors to the WVRP.

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However little detail has been provided about the commercial space, or the route from the train station through the site to Mile Road (the main access point to the Beddington Farmlands and the WVRP beyond) that would enable us to determine if these opportunities have been considered.

3.0 Environment 

3.1 EP1: Access to the Wandle Valley Regional Park EP2: Local Green Space Designation● Policy 40 of the Local Plan sets out considerations for the development of the site, including

that the design should ‘respect the open character of the adjacent Wandle Valley Regional Park’.

● The objectives to Policy EP1 are to develop Hackbridge as a major gateway to the WVRP.

● The proposals do not highlight how their development will respect this character or enhance access to Beddington Farmlands and beyond. In fact what should be a destination arrival point at Hackbridge to access the largest area of green space in the Regional Park, 3 times the size of Hyde Park is greeted by a wall of flats and an 11+ storey ‘landmark’ building.

● The view below highlights the dense and overbearing design that will tower over the railway track to greet arriving visitors.

● Access to Beddington Farmlands needs to be managed so that it is sensitive to the local wildlife. As previously mentioned, the proposed plan neglects any details about how Mile Road Bridge joins the development and whether the rest of the access across the bridge will be improved.

3.2 EP3: Trees● Syntegra Consulting’s Ecology report states where possible there should be no net loss of

trees.

● Policy EP3 requires that where appropriate trees need to be commensurate to the development and large canopied trees will be looked upon more favourably.

● Page 81 of the Design and Access Statement does not provide a full landscape layout. The key is confusing and you cannot tell where there are shrubs or the difference in tree sizes.

● Trees are required by the Wind Analysis Report to mitigate wind channelling from the design of tall buildings at both podium and roof garden levels. Whilst planting plans are often part of a planning condition that are provided later after approval, full details are needed upfront to ascertain whether the position of trees (and shrubs) will satisfactorily mitigate this.

● We would be interested to know Network Rail’s comments on the provision of new trees so close the the railway track and whether this would be an issue.

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3.3 EP4: Management of Current Public Green Spaces

● Whilst this area does not include a public green space, investigations have taken place and Japanese Knotweed is present on site. A management plan is needed for the full eradication of this.

● Being situated next to Beddington Farmlands, a site especially important to birds, removal of any shrubs and trees should only be undertaken outside the bird nesting season (March to end of August).

3.4 EP5: Management of New Public Green Space

There are several green spaces, proposed for the Hackbridge Gardens development. The most significant being the landscaped podium, on which 5 of the residential blocks will be built.

We were unable to find a plan that confirms the details for the landscape design of these green spaces.

Without this information we are unable to ascertain the quality of these spaces.

The Daylight, Sunlight and Overshadowing report includes Suncast images, which seem to indicate significant overshadowing of the green spaces located on the podium, amongst the taller building - see image below. We are concerned about whether or not these spaces will be pleasant to use, if there is too much shade and wind, as a result of the height of the buildings bounding these spaces.

The Design and Access Statement mentions fruit trees being planted. Where will these be located and how will the residents be encouraged to join in with any communal gardening?

3.5 EP6: Green Infrastructure

All developments shall be required, where appropriate to extend the biodiversity and amenity value of surrounding open spaces through the neighbourhood via new and enhanced green infrastructure linkages.

● As highlighted under Policy MP1, an important green link is access to Beddington Farmlands and the rest of the Wandle Valley Regional Park via Mile Road Bridge. There are no details how the development site will access Mile Road as a thoroughfare and whether improvements to the rest of the road will be made. There is concern that this important entrance will be completely overshadowed by the proposed development.

● There is no mention whether bird or bat boxes will be provided or other amenities to encourage wildlife.

● There is not enough detail whether the overshadowing and light pollution of the tall buildings will have a detrimental effect on existing wildlife and their habitat.

● There is insufficient detail to assess whether the development is complying with Policy EP6.

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3.6 EP7: Urban Greening

Development proposals where appropriate should use soft landscaping in an innovative way to combat climate change

● The proposal of 10 residential blocks of flats between the heights of 4 and 11+ storeys create their own micro-climate. The Wind Analysis report has highlighted windier than desired conditions, requiring mitigation measures along the following proposed areas:-

○ Entrances into Building F along the western façade. Mitigation measures required if any seating areas are proposed to be located here;

○ Ground level amenity space between Buildings A and J and to the west of Building F;○ Podium terrace amenity spaces are one to two categories windier than required for

standing and strolling, predicted to the north of Buildings B and C and around Buildings D, E and F.

○ We welcome roof gardens, but all of the roof terrace amenity spaces are expected to have windier than desired conditions due to their elevation and resulting exposure to the prevailing winds, with Building A anticipated to have standing wind conditions throughout.

○ The corner balconies of the proposed development highlighted below have windier than desired conditions due to exposure to the prevailing winds. All other balconies would also benefit from shelter.

● Mitigation suggestion for the above is proposed by soft landscaping. A full landscaping plan has not been submitted and therefore we are unable to be satisfied that the developer can comply with Policy EP7.

● We acknowledge the proposal of fruit trees, but there is not enough information provided if there is sufficient space for community gardening and food growing.

3.7 EP8 & EP9: Water Efficiency and Water Efficient Landscape Design

Insufficient information has been submitted with this planning application to determine if the proposed development conforms with EP8 and EP9. We note that the Design and Accesses Statement mentions rainwater harvesting, but no further details are provided.

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4.0 Energy Waste and Water

4.1 EW&WP1: Better Buildings for the Future

We note in the Energy Strategy Report that the proposed Hackbridge Gardens development aims to achieve a greater carbon reduction than required by the London Plan. This is to be achieved through better thermal efficiency of the building envelope, efficient electric heating system, natural ventilation to wet areas and low energy lighting. However we note that many flats are not orientated in a southern direction and at least 15% are single aspect, some only facing north. Therefore solar gains are not being utilised to achieve maximum thermal gains, particularly useful in winter to reduce heating requirements. Also having the tallest building located on the southern part of the site will not help this. A development of smaller scale and less dwellings would be able to better position dwellings to achieve better solar orientation, such as Bedzed and reduce even further its heating requirements.

While we welcome a higher degree of carbon reduction, as the proposed development aims to do, we would like to know the overall environmental impact of the proposed development. This is why policy EW&WP1 requires all new developments, where feasible, to do a One Planet Action Plan, so that information about its energy consumption, water consumption and more, are located in one document that is easy to access by the general public. Many residents are concerned about the environmental impact of all new developments in our area. For a development of this scale, it is an imperative that we understand just how much energy and water it will consume, as well as how much waste it will produce, so that we not only understand it’s environmental impact, but also the impact it will have on local resources and infrastructures.

We note that a One Planet Action Plan has not been submitted with the planning application for the proposed Hackbridge Gardens development.

5.0 Movement

The development has a PTAL rating of 3 and proposes 118 parking spaces (equates to 0.46 per dwelling) and 176 cycle spaces for 88 1-bedroom, 132 2-bedroom, 33 3-bedroom and 5 4-bedroom units and 392sqm of flexible commercial floor space. There is no dedicated parking for commercial buildings.

5.1 MP1: Pedestrian and Cycle Networks

Connect existing networks and provide linkages in particular to the River Wandle and Wandle Valley Regional Park, encouraging alternative modes of transport to reduce emissions

● We note that principal access to the site is outside the applicant’s boundary. Has there been negotiations with Network Rail that access can be used for the development? What improvements will be made to this access road for increased vehicle movement and the safety of residents crossing to the train station, apart from the new junction on the London Road?

● Policy MP1 expects the implementation of developments to connect to existing networks and to provide pedestrian and cycle linkages between schemes and surrounding roads.

● We welcome access through the site for existing residents to be able to walk through to the train station from Mile Road, avoiding the narrow footpath along London Road and heavy traffic fumes.

● There are no details how this connection will work, whether the existing pocket park will be lost or what improvements will be made to the major access route to the unfolding Wandle Valley Regional Park.

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Cycling Provision & Networks● The London Plan and Local Plan requires a provision of 1 space per studio/1-bedroom unit

and 2 spaces for all others.● The submitted Transport Assessment refers to to the requirement of 424 spaces to be in

compliant with these policies. However, this is based on 256 dwellings, not the 258 dwellings as per the planning application.

● The amended planning application form states only 176 spaces will be provided, which is the equivalent of approximately 41% of the required provision of 428 spaces. There is confusion between submitted documents what the actual number should be as page 42 of the Design and Access Statement states 368 spaces and page 44 shows approximately 222 spaces.

● The provision throughout the site is inconsistent with only Blocks A, C, D & E having dedicated spaces and Block E having 55% of the whole provision.

● As noted in the Housing and Built Environment Section, this provision (whether 176 or 222 cycling spaces) and storage is not in conformity with our Policies H&BEP2 and MP1.

● The application does not demonstrate how its development will connect to existing cycle networks or to the WVRP..

● If the overall transport strategy for the proposed development is to reduce car use and increase cycling and public transport use, then the cycling provision needs to be of an excellent standard, easy to use and safe. The current cycling provision is none of these.

5.2 MP2: Transport

Where appropriate, development proposals should demonstrate how they would integrate with existing transport infrastructure ie public transport provision, cycling, walking and car parking -

● Page 9 of the Transport Report concludes that the proposed site is allocated in an accessible location which will encourage the use of sustainable travel choices and reduce reliance on the private car and encourage reduced levels of car ownership.

● The application does not demonstration how they will provide improvements to public transport provision or cycling.

● Whilst we encourage sustainable travel choices, the reality is very different. Improvements are needed to the local infrastructure and transport connections. Hackbridge Station has a short platform, meaning at least 3 carriages are inaccessible by commuters.

● The train service from Hackbridge is currently unreliable, and the number of services has been cut. Whilst the new developments in Hackbridge are promoting fast connection to London, the impact of these developments have not been fully realised with over 1,000 dwellings being built using an already overcrowded public transport service.

● Sutton Council are currently undertaking a parking strategy. Hackbridge suffers from commuter parking, as well as over-spill from new developments, including Saxon House and Felnex.

● The provision of parking spaces for the Felnex development was based on the same rationale of being an accessible location and so minimal parking provided, but this has not stopped new residents coming with cars.

● Improvements need to be made to the design, quality and environmental standards of the scheme to encourage the type of residents who would not need a car. Along with public transport improvements, then the parking rationale would be acceptable.

5.3 MP3: Air Quality

● Air quality is a major concern for the local residents of Hackbridge and Beddington Corner with the recent build of the Beddington Incinerator and the ongoing building works of the Felnex Development.

● The air quality report does not include either of these sites in their report and recommendation of this proposal should not be looked at until this information has been provided.

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5.4 MP4: Car Clubs & Electric Cars

● Whilst we welcome a car club onsite, unless improvements are made to the current infrastructure and public transport, using this as a basis to reduce car parking provision is unrealistic and will lead to more on-street parking.

6.0 Community Infrastructure 

6.1 CIP1: Local Infrastructure

● The Hackbridge and Beddington Corner Neighbourhood Development Group expects CIL monies from this development to be used in accordance with paragraph 5.128 of the Hackbridge and Beddington Corner Neighbourhood Plan.

● Policy CIP1 intends to conserve and where possible enhance heritage assets and areas of special local character. The image below shows the visual impact of the development on the majority of open space in the Wandle Valley Regional Park. We believe the proposals will lead to great change in areas of high sensitivity in both Beddington Farmlands and Mitcham Common and be unacceptable on grounds of visual impact.

Proposed visability of the majority of the site seen over 2000m away

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Proposed view from Beddington Park

Proposed view from Mitcham Common

7.0 Other Observations

A public exhibition, about this proposed development, was held on the 19 January 2017. That was almost two years ago and there have been many changes made to the design since then.

The Hackbridge and Beddington Corner NDG encourages developers to do more direct consultation with the local residents. It is their chance to answer questions and possibly provide more information where needed. On past major planning applications in the area, we have found that closely consulting with local residents has led to designed schemes that better consider the needs of the local area.

Paragraph 128 of the National Planning Policy Framework states - “Applicants should work closely with those affected by their proposals to evolve designs that take account of the views of the community. Applications that can demonstrate early, proactive and effective engagement with the community should be looked on more favourably than those that cannot.”

Conclusion

Many residents have communicated to the Hackbridge and Beddington Corner NDG about how concerned they are regarding the proposed Hackbridge Garden development. They think it is too big, too overbearing and unattractive and they are most worried about how the existing infrastructure will cope.

Hackbridge is going through great change at present and the many developments that are currently under construction, will add more than 1000 new dwellings to the area. We do not yet know how the existing infrastructure will cope when these new houses are completed, before we can truly understand the impact of the additional dwellings proposed for the Hackbridge Gardens site.

Section 4.4.6 of the Townscape and Visual Appraisal report mentions that the local area has some recent and modern residential development and then only lists Bedzed and the Felnex Trading Estate. It fails to mention development on the following locations, all currently under construction;

● Corbet Close,● Wandle Valley Trading Estate,● Mill Green,● Vulcan House,● or the new Hackbridge School.

It concerns us greatly that insufficient information has been submitted with this application to be able to correctly understand what impact the proposed development will have on the surrounding area.

For a development of this scale, density and height and located so close to the Victorian terraces and parade of shops along London Road, the design must be of an exceptional design standard to be considered acceptable - see Sutton Site allocation S2.

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Given that the design of the proposed Hackbridge Gardens development;

● does not meet the requirements of many of the policies in the Hackbridge and Beddington Corner Neighbourhood Plan,

● is identikit in appearance to many high density developments elsewhere in London,● the number of proposed dwellings exceed the indicative housing capacity for the site of 174

dwellings, as noted on the S2 site allocation,● conflicting information has been submitted regarding exact numbers of cycle parking that the

proposed scheme will provide, however the 176 spaces listed on the amended planning application form does not meet the requirements of the Sutton Local Plan,

● insufficient information has been submitted about the details of the new green spaces and how the development will contribute to improving access to Beddington Farmlands,

● there has been insufficient consultation with local residents,● and it is overbearing in scale;

then the proposed development does not meet the requirement to be exceptionally designed, to make up for any negative impact it will have on the surrounding community. It does not make Hackbridge but undermines it.

Paragraph 130 of the National Planning Policy Framework states - “permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions”.

We ask you to please refuse this planning application.

Yours sincerely

JArmstrong

Julia ArmstrongChair

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