Town
Planning
London
Borough of Bromley
Civic
Centre
Stockwell
Close
Bromley
BR1 3UH
For
the attention of Susanna Stevenson 7
April 2017
Dear
Sirs
REFERENCE: DC/17/01122/FINAL1 – 87
OAK TREE GARDENS, BROMLEY BR1 5BE
The Links Estate Residents’ Association (LERA) wishes to register an
objection to this planning application.
We are strongly opposed to this development for the following reasons:
- Road Safety
Residents are extremely
concerned about the effect the proposed development would have for road safety
and the increased risks of vehicle collisions and injury to pedestrians.
The inappropriateness
of the access arrangements and the risks to road safety were recognised as one
of the reasons for the Council’s refusal of the previous application for the
site (Reference: 16/04446/FINAL1):
“2. The layout of the estate roads and access
arrangements to the dwellings are inadequate to serve the proposal and as such
would be prejudicial to the free flow of traffic and conditions of general
safety within the development contrary to policy T18 of the Unitary Development
Plan 2006.”
We must emphasise most strongly that the corner where the
planned development site is located is extremely dangerous. The site in Oak Tree
Gardens lies at the junction with Portland Road on a very tight right angled
bend with very poor sightlines. The corner is already dangerous. The approach in both directions is
restricted. Both
roads have vehicles parked on both sides allowing only single lane traffic.
Traffic in both directions often travels at speed and there have been
collisions at the corner and more have been narrowly avoided, even when
vehicles have been travelling at moderate speed. For example, a serious accident occurred relatively
recently which necessitated police attendance and where one of the cars involved
carried young children.
Also, it is essential to recognise that since the
previous planning application, the dangers to traffic and pedestrians at the
corner have increased significantly as a result of increased parking due to more
houses in the area being used as multi-occupancy dwellings, as well as
households parking additional vehicles, including commercial vehicles. This has
resulted in very dense parking, worsening the sightlines even further. Only in the past few weeks, a further serious
accident involving police presence occurred which resulted in a car demolishing
the front bay of a house near the corner and the garden wall of the
neighbouring house.
This situation would
be inevitably exacerbated further by visitors to the proposed dwellings using
Portland Road and Oak Tree Gardens to park their vehicles which would have a
knock on effect in adjoining roads within the Estate.
Annexes
A1 and A2 illustrate the acute angle of the corner. Annexes B1 and B2 illustrate the sightlines
from the proposed access road.
We
must emphasise that the installation of an access road to the site creating a
3-way junction at the apex of the corner where Nos 89 and 91 are currently
located, would increase significantly the risks of such collisions,
particularly in view of the very poor sightlines when turning the corner from
each direction and from the access road.
2.
Inappropriate use of backland
development which is detrimental to the surrounding area
Residents
are very concerned about the effect that the proposed development would have on
the character of the Estate and the neighbouring properties.
The
Council recognised the adverse impact of such a development on the area in
refusing the previous application for the site to build 6 houses (Reference: 16/04446/FINAL1):
“1. The proposal, by reason of the height and siting of
the proposed dwellings, their elevated position and the proportion of the site
given over to buildings and hardsurfaces, would have a detrimental impact on
the character and appearance of the area, detrimental to its green and verdant
nature and thereby contrary to policies H7 and BE1 of the Unitary Development
Plan, policies 3.5 and 7.4 of the London Plan and the National Planning Policy Framework.”
The development now
proposed contravenes these policies. The
proposed adjustments to the overall height of the site and the proportion given
to hard surfaces do not alter this. The
siting and density of the development in existing back gardens at a site on a
sharp corner of 2 roads would significantly damage the layout and
sustainability of the area and the privacy of neighbouring houses. With no change to the density, layout and other
aspects, the adverse impact on the area will remain the same.
The proposed development would
constitute an unsatisfactory form of backland development and be seriously
detrimental to the amenities of neighbouring properties.
The
proposed development would constitute an unsatisfactory form of backland
development, out of character with the pattern of development, quality and
distinctiveness of the surrounding area and detrimental to the visual amenities
of the area.
Furthermore, approval
of the proposed development would contravene the following policy set out in
paragraph 3.34 of the London Plan 2016 –
“Directly and indirectly back gardens
play important roles in addressing many of these policy concerns, as well as
being a much cherished part of London townscape contributing to communities’
sense of place and quality of life.
Pressure for new housing means that they can be threatened by
inappropriate development and their loss can cause significant local concern. This Plan therefore supports plan-led
presumptions against development of back-gardens where locally justified by a
sound local evidence base ………”.
We
challenge the developer’s assertion at page 14 of the Planning Statement that
the proposed development is consistent with the “thrust” of Bromley’s strategy
and permissible by the Urban Development Plan 2006, Policies H1, H7 and BE1.
We contend that the
intention of the strategy is not to exploit existing cramped residential areas. Paragraph 4.9 (Local considerations) says:
“The Council takes the view that
meeting the housing requirements for the whole community can be achieved
without compromising its other primary aim of protecting the exceptional
environmental qualities of the Borough, particularly within existing
residential areas. ….”.
We also refute
the developer’s claim on page 8 of the Design and Access Statement that the
previous development in Leamington Close within the Links Estate provides a
precedent for the proposed development in Oak Tree Gardens. The site of the proposed development is quite
dissimilar to Leamington Close for the following reasons:
·
the site is located
directly at the junction of 2 roads that carry regular passing traffic. This was recognised by the Planning Inspector
in dismissing the appeal against the refusal of a previous application; and
· the
development would be closer to neighbouring houses, thereby having greater
detrimental impact on those properties and the environmental characteristics of
the surrounding area.
- Drainage and
Sewerage
Residents are very
concerned about the effect that the proposed development would have for the
increased risks of flooding of their properties and the surrounding area,
particularly as the existing systems are already overstretched. Residents in the area have had experience of
their properties being flooded.
Furthermore, residents in the area are on the Government’s flood warning
system and have routinely received telephone warnings advising of the imminent
increased risk of flooding, and properties have been flooded.
The London Borough of
Bromley’s (LBB) reports on previous planning applications for the site have
commented that the Environment Agency (EA) advised that “the application is assessed as having low environmental risk and
therefore there were no comments.”.
LERA disputes this assessment. We have previously obtained copies of the
original correspondence between LBB and EA and we contend that the risk
assessment that was quoted is incorrect.
Furthermore, we have obtained separately from EA confirmation that the
areas directly bordering and facing the site are assessed as HIGH and
MEDIUM/LOW risk respectively for river flooding. Also, LBB’s Strategic Flood Risk Assessment
map shows that the area is in a HIGH Probability risk zone (Level 3a). We have also obtained confirmation from LBB
that these areas are assessed at similar risk levels for surface water
flooding. This is consistent with the reality as
the area has been flooded during periods of heavy rainfall in recent years.
Both roads have a
river running along them through a culvert very close to the site which opens
into the adjacent Chinbrook Meadows. The drainage and sewerage systems serving
the roads are already struggling to cope with existing demands. These are already being put under further pressure
by the proliferation of extensions being built to existing houses with
additional bathrooms and lavatories, and houses being used increasingly for
multi-occupancy.
The drains cannot
cope even with normal rainfall and flooding frequently occurs. The risks of
flooding may be further exacerbated by the proposed diversion of drainage
channels in the area of the Meadows immediately behind the houses as part of a
scheme to remove pollution from the river Quaggy. Despite the sustainability
measures proposed and indicated in the
application, residents remain extremely
concerned about the effect the development would have on the already
overstretched system.
We contend that the proposed
extensive paving over of the site and proposed new access road would exacerbate
these flooding risks, particularly as the site is located on a slope, thus
allowing surface water to feed into the flooded roadways and surrounding
properties.
Houses in Portland
Road have frequently reported raw sewage
backing up in their lavatories and drains on their properties. The 4 (net) additional houses which would add
at least 14 lavatories, 14 washbasins and 14 baths/showers to the system would
only overload the sewers further and increase the risks of wider sewage back up
in the surrounding houses.
Householders have found they are unable to
obtain insurance against flooding and the
effects of the proposed development will
render further houses uninsurable in this respect.
Events relating to
flooding and climate change in parts of the country in recent years and the
resulting requirement to review the national flood prevention strategy
demonstrate the importance of ensuring that Local Planning Authority decisions
relating to potential flooding are taken very seriously.
LERA is strongly of
the view that the development should not proceed. For the reasons above, the strength of
opposition among residents to this development cannot be understated. We would ask the Planning Committee to take our
objections into serious consideration and reject the application.
This letter is being
copied to Councillors Peter Morgan, Michael Turner and Ellie Harmer.
Yours
sincerely
Stephen Hodges
