Following our previous work to support residents living near the old Mitcham Gasworks site, we submitted to the Council, on 13th May, our response to the latest planning application.
1. We find it extremely disappointing that the original vision for the site, as set out in the 2021 version of the Local Plan, has changed significantly since the applicant, in their previous version of the planning application, proposed 595 flats in six tower blocks rising to nine storeys. It seems highly convenient that despite the high number of objections to said application, the latest version of the Local Plan now supports the development of up to 650 homes in tower blocks rising to ten storeys. We had thought reasonable the suggestion of 200-400 homes and the statement that ‘[a] mixed-use redevelopment of the site could include taller buildings subject to consideration of impacts on existing character, heritage and townscape.’
Furthermore, it does not reflect well on the Council that the decision to increase the site allocation was made behind closed doors, as such behaviour flies in the face of the lengthy public consultation underpinning the initial recommendation.
2. We note that of the 579 flats proposed, the vast majority are one-bed or two-bed – respectively, 226 (39%) and 282 (49%) – meaning that the development will provide very few family-sized homes, specifically, only 65 three-beds (11%) and 6 four-beds (1%). We believe that this is not the right balance, and that what will address the housing crisis more effectively is a mixture of family-sized houses with private gardens, and one-bed and two-bed flats with communal green space.
3. We are deeply concerned that only 35% of the flats will be affordable, and that this will be split into 71% social rent and 29% intermediate rent. Firstly, this will have minimal impact on reducing the number of households on the Council’s Housing Register, which we have heard is closer to 11,000 than the 2019/20 figure provided on the Council’s website, namely, 9485. Secondly, it is not aligned with either the current Local Plan or the future Local Plan requirement, as policy CS8 in the former sets a target of least 40% affordable housing provision, and H11.1 in the latter increases this to 50%.
Indeed, the estimated cost of site remediation reveals that the project could run at a financial loss of between £4.2m and £19.9m, leading us to suspect that the applicant will argue, at a later date, that the project will be financially viable only if the number of flats for private sale is inflated and the number of affordable flats reduced.
4. We think that it is unacceptable that 21% of the flats will be single aspect, as the risk of overheating is high in this type of dwelling. We acknowledge the reduction from 35% in the previous version of the planning application, but would like to point out that, according to the London Plan and Merton’s Local Plan, single-aspect dwellings should be built as a last resort. The former states, in Policy D6, that development should ‘normally avoid the provision of single aspect dwellings’. The latter states, in Policy D12.3, that ‘single aspect homes are strongly discouraged’.
5. The applicant’s Daylight and Sunlight Report reveals that 12% of rooms will fall short on daylight standards, and that 35% of the flats will not meet BRE guidance to have a room which receives 1.5 hours of sunlight on 21 March. Allowing this would be irresponsible.
On a related note, we empathise with residents in Portland Road who are unhappy at the prospect of their gardens being overshadowed.
6. The applicant admits that the assessment of the site’s contamination is ‘preliminary’, and that ‘potential volatile contamination may be present and has not been fully investigated to date’. Likewise, it recognises that not only is previous clean-up work conducted on most of the site below the standard required for residential development, but also that the area of the recently demolished gasometer has not been cleaned up. We believe that this warrants further, rigorous investigation conducted by an independent, respected body. We are following the public health fallout in the wake of the applicant’s use of the former gasworks site in Southall.
7. The Urban Greening Factor in the planning application is 0.38, whereas the London Plan has a target of 0.4 for predominantly residential developments. We argue that this development should be able to achieve a higher figure than the target, as it is on a brownfield site.
8. It is obviously problematic that the estimated Biodiversity Net Gain stands at 9.14%, which is below the mandatory requirement of a minimum of 10%.
9. We would like details of how the applicant and the Council plan to address construction road traffic, as the air and noise pollution on Western Road is already excessive, and there is a climate emergency which the Council is seeking to address through its carbon reduction plans for the borough.
10. Although it is understood that it is not in the applicant’s gift to develop local public services – transport, healthcare, education, etc. – both the applicant and the Council need to appreciate that resources are already stretched and the addition of 579 households will exacerbate existing difficulties. The applicant will no doubt be keen to emphasise that the Community Infrastructure Levy will help in this regard. However, we are of the view that this underestimates the complexity and timescale of the changes that would be needed to ensure equity of access to high quality local public services.
11. Yet again, the applicant has failed to engage with local residents in a meaningful way. The number of visitors to the latest so-called consultation event bears this out, whilst the misleading artist’s impressions on display were tantamount to deliberate obfuscation. We feel strongly that this is a missed opportunity to work with a community who understand well the need for more social housing and are determined to do all that they can to ensure that it is provided and of a high standard.