The letter reproduced below was sent to the case officer for the Campion Development, Burnetta Van Stipriaan, after news was received that the Campion application would go to the Isleworth and Brentford Area Committee on 19th June. We wanted the officers to be clear about our views on the development and to be aware of the case that we would be putting to councillors. Also if the planners have further meetings or communications with the developer before that date, we wanted them to be aware of the case that we would be putting to them. Finally we invited the officers, as we have done on previous occasions, to be kind enough to inform us if we were wrong on any matters of fact since we have no interest in misleading either residents or councillors. On the contrary, we want the full facts of the application to be as widely known and understood as possible.
From: David Pavett
To: Burnetta Van Stipriaan
Sent: Thursday, May 22, 2008 11:58 AM
Subject: CCMG points on the Campion Application
Dear Ms Van Stipriaan,
The Campion Concerns Monitoring Group met recently to agree on the approach that it would make to both planning officers and councillors on IBAC and the SDC with respect to the current application to develop the Campion House site.
It is our view that there are good planning grounds for refusing the application.
1. The encroachment on open space is contrary to the clear purpose of planning guidelines at every level. Even if some or all of the land being made available for public access were, at some time in the future, to be designated as local open space the degree of encroachment would still be higher than in previous applications and would be of the order of 30%. As you know we have produced a paper to explain the basis for our case on this point. We believe that the application should be refused on this ground alone - even if there were no other problems with the application. We will do our best to convince councillors of our point of view. We are, of course, open to correction on any of our views on planning matters. In the absence of such correction we will put our case as strongly as we can.
2. Apart from the general case for protecting London's open space we believe that there are specific consequences of the encroachment that would be harmful to the area and more generally to the broader environment. There would be loss of soak-away area and a consequent diversion of surface water from the water table to the sewers. This is contrary to the aims of SUDS. The Planning Statement does not hide this fact. It is clear that despite attenuating peak surface water run-off there would be an overall increase in the discharge of surface water into the sewers of the order of at least 30%. This too, we believe, should be a sufficient ground for refusal.
3. The Hounslow SPG requires developers to produce detailed SUDS plans at an early stage of the development design. No such plans were drawn up in the early stages and none exist in the application.
4. (a) The density of the development is too high. While we understand that it is the consequences of density rather than density itself that constitutes grounds for refusal we think that those consequences are very clear. First, we believe that the indicative density range given in the Planning Statement is incorrect. We have produced detailed reasons for saying so and I have attached our document to this message. The number of habitable rooms is incorrectly stated to be in the 3.1-3.7 hr/u range in the Planning statement. We have counted the rooms and it seems very clear to us that the range should clearly be 3.8-4.6. This, coupled with the setting of the site and its PTAL rating means that the indicative density range for the site should be 35-65 dph and not 40-80 dph as asserted in the Planning Statement.
(b) The likely harm of exceeding the indicative density range for the site should have been a clear indication that there would be intractable problems on a site which, as the Inspector said, is in a sensitive location of the Spring Grove Conservation area.
(c) While accepting the general planning aim of increasing density we believe that special care should be taken to meet the provisos in the planning guidelines with regard to density. Given the sensitivity of the location in the conservation area it is important that the development blends with its surroundings. In the first place this means that the increase in density, which we accept will take place, should be gentle rather than sharp. The density of the housing on the opposite side of the road is about 30 dph and that of the immediately surrounding conservation area is about 40 dph. We suggest that a sensible policy would be to go for the mid-range of the indicative density namely 50 dph.
(d) Among the consequences of the over-dense proposals are that (1) the buildings along the frontage(with the exception of Block G) are too high. At four-storeys they would be far taller than the houses opposite and taller than surrounding developments. It would be fitting to follow the approach taken to the Linden Homes development in Osterley Road. There the proposal to go to four storeys was rejected and the main building is now three storeys. This is what we believe should happen to the housing along the Thornbury Road frontage. The original officers' assesment of this site said that buildings of three to four storeys would be appropriate. We believe that was a sensible judgement and that nothing has happened in the intervening period to make it less so. The development should not be allowed to creep up from 3/4 storeys to 4/5 storeys. There is no reason for such a change. The built environment hasn't changed. Neither has the need to respect the conservation area.
(e) The massing of blocks C and D is excessive in the context. They would present a form of much greater bulk than Thornbury House. This impression of bulk is increased by the use of flat roofs which have been adopted to get as many units in without exceeding the height of Campion House. In addition to bulk blocks C and D make an unpleasant contrast to the rest of the development and to the surrounding housing. The side of block C most visible to the street looks rather flat and like standard hotel architecture.
(f) The J blocks are too close to the ICG astroturf. We believe that the light and noise from the astroturf would be a constant source of friction between residents and the club. This would harm community relations and this should be avoided at all costs. Despite having drawn attention to this problem from the beginning of the consultation exercise we are unaware of any attempt being made to evaluate the acceptability or otherwise of the light and noise levels from the astroturf.
(g) Prima facie it should be evident that stepping density up to something like double that of the surrounding housing in a sensitive spot in a conservation area is inappropriate.
Beyond these fundamental issues there are plenty of others which we think should be treated as problems requiring a solution before approval is given.
(5) The only acceptable feature of the previous application was block A. Then it was in a "villa" style and consisted of 6 flats. Now, with the predicted demise of the "doctors' surgery" plan it has become a block of 9 flats. Not only that but it has moved closer to No.114 so that the gap has been reduced from 5m to about 2.7m. If this block is to be retained - many think that it should go altogether - then it should revert to the former villa approach with 6 flats. It should also be moved away from No114.
(6) The requirement to produce a clear play strategy in line with the latest requirements of the London Plan has not been met. We will produce a note on this for councillors.
(7) We do not believe that the housing mix matches those of the Council's HIPS statement. We have only just got the latest figures and will examine them closely. If, as we suspect there is a disparity between need and provision we will point this out to councillors. We were not happy with the Housing Officer's views on the last application and will consider that matter in more detail this time.
(8) The lack of 3-D images in the Design and Access Statement is a serious shortcoming. (The only ones we have are the ones I lifted and enlarged from the JTP Newsletter.) There are several other respects in which the CABE guidelines have not been followed. Every effort should be made to help members to understand what the development would look like in context. This is generally not possible for the lay person when only 2-D images are provided. That is why CABE gives its advice. We asked for such 3-D images at an earlier stage. You, in turn asked, JTP/Linden to provide such images. We can only speculate as to the reason why they have not been provided. We were told that a sophisticated computer model had been produced for the development. It cannot, therefore, be all that difficult to generate the required images. We are concerned that members, as well as residents, should be provided with what they need to make a judgement on the design aspects of the application. Without 3-D images this is unnecessarily difficult.
(9) The water tank on block D, rising above the fifth level, is an eyesore. Would tanks not be required on the top of all four-storey blocks - as a result of local pressure conditions (any unit above 10m will necessitate a pumping unit and a storage tank)? We will examine that before IBAC meets.
(10) The claim in the Planning Statement that local schools are within walking distance is highly misleading. The only primary school within walking distance is full.
This application would have been a reasonable starting point since one naturally expects developers to push the limits to their own advantage. The previous two applications were simply outrageous and this was confirmed by the strong judgement of the Inspector.
The consultation process has not been a farce as it was with Green Issues. We recognise that JTP have listened to residents. Our view is, however, that they have been obviously constrained from the outset by the Linden Homes' objectives of the number of units they want on the site - contrary to Government and CABE advice concerning Design and Access Statements (design should come first and not as a way of fitting in a preconceived number of units).
A clear indication of the Linden preconceptions which JTP had to work to is the issue of open space. From the beginning they asked us individually and collectively if we would find a certain amount of encroachment acceptable if other objectives were met. From the outset we all told them that encroachment should not be regarded as a prize for good design. In fact managing to meet housing objectives while protecting open space should, itself, be regarded as key element of good design.
We are convinced that in order for the application to be acceptable it would be necessary to remove or significantly reduce some of the blocks both in terms of height and massing.
I hope this helps to make clear the views of the Campion Concerns Monitoring Group. As you know we have a website and we are trying to keep it up to date. More of our materials will appear on it over the next week or so.
Yours sincerely
David Pavett
(Campion Concerns)
101 Thornbury Road
Isleworth
Middlesex
TW7 4NL