Here Are My Specific Comments to the New Documentation Submitted

I strongly object to the proposed plan to demolish 35 Maidstone Road and replace it with a purpose-built block of flats as per new submitted documentation within the existing consultation to which I had already previously objected. The new documents give no details or commentary on what has been changed from the documents previously submitted. The documentation supporting the application still seems sparse, vague and contradictory in many areas. In particular, the Design and Access Statement dated March 2016 (a date preceding the rejection of a previous application by the same applicant) has neither page nor paragraph numbers, making it difficult to refer to specific details. The table at the close of this document is so full of inaccuracies that it makes it impossible to understand what exactly is to be built. The company submitting the application (Gridline Architecture) is not registered either with the RIBA or the Architects Registration Board, and does not identify any individual associates who are registered architects. We would contend that the documentation supplied by the applicant is not of sufficient quality on which to base a decision, and that for that reason alone the application should be rejected. Here are my specific comments to the new documentation submitted:

1. Design & Access Statement Pg 1 – Introduction.  Refers to property being vacant. Incorrect as there are people living in at present (lights on and car in the drive) and so is a valuable local home.  Incorrectly refers to erection of 10 residential units. Pg 1 – The site and its surroundings  Refers to no evident street pattern. This is incorrect. Pattern is of individual building plots with large mature rear gardens.  Refers to greatly reduced need for a car. Evidence of the number of cars parked on street, and in front gardens of properties would dispute this. Pg 1 –Topography  Correctly recognises sloping terrain, but proposals still ignore it Pg 1 – Open space  Lists adjacent open spaces but for example the nearby Scout park is not a public park Pg 1 – Transport Connections  Arnos Grove, listed as a close walk away, is a 20 minutes walk. Pg2 – Streetscape  Comment on “no obvious architectural pattern” as above Pg2 – Design Proposal  Incorrect reference again to a ‘disused’ property.  Says proposal is for a two storey building when in reality it is four storey.  Makes reference to roofline of the proposed building being kept in line with its neighbours. Incorrect. It is in line with N0.33 but higher than No.37. It it follows the slope of Maidstone Road, and the street pattern, then it should halfway between the roofline on No.33 and No.37.  Refers to fenestration being reduced to be in keeping with neighbouring housing. Incorrect. Large areas of glazing and hence overlooking retained to the rear. This is incorrect. Glazing in this proposal to the rear and hence overlooking is increased in area over the January submission and there are a significant number of additional windows to the side walls. Pg3 – Our objective The proposals fail to meet three of the four listed.  To ensure that any development will not impede have any adverse effect neighbouring properties. Not achievable as the overlooking is increased. To create adequate external space (amenity space) in proportion to the habitable spaces internally. Not achievable as most of the flats are not provided with private amenity space  Scale & proportions has also been an important issue the design shows that all habitable spaces are of a good standard in size and they are well proportioned in relation to each other. No sizes given though some rooms have got smaller than the original proposals. Room areas should be shown.  Create a truly sustainable building. No detail or calculations provided to substantiate this. See also later comments. Pg4 – Spatial Organisation  Changes to the internal layouts including reducing some room sizes to add en-suites have been made. They therefore can no longer achieve the minimum room sizes as stated in the uncorrected D & A.  Combined floor occupancy areas should be shown on the drawings so they can be checked  No storage areas given or locations of hot water cylinders shown so cannot ascertain whether they meet the mandatory minimum storage requirements. Flats 1, 2 & 3 when scaled off plan do not meet the minimum storage requirements contrary to statement in the Design & access Statement and planning policy  No home office space shown despite reference to Code for Sustainable Homes Guidance in the Design & access statement. Flat 6 appears to have no space available in any event.  No wheelchair housing shown (Our normal calculation would be 10% i.e 0.6 rounded up to 1)

Pg4 – Amenity Space  Despite referring to compliance with the London Housing design guide they fail to provide private balconies to all dwellings and have even lost the roof terrace from the January application and where they do they are below the minimum standard. This is mandatory requirement of the London Housing design Guide. Therefore they fail to provide sufficient private amenity space for the dwellings. Pg 5 -Access–Car  Only one parking space provided Pg5 – Flexibility  Sweeping generalisation that the development provides a standard of housing that has a flexibility to adapt to future social and economic needs. How? Flats are two constrained by their irregular shaped floor plans to have flexibility. We challenge the architects to demonstrate this. Pg5 – Security and safety  Again reference to unused building. They currently rent the house out. There are already living spaces in the current house overlooking the road so current proposal does not improve security from this aspect. Pg6 – Code for Sustainable Homes.  Refers to minimum of Code Level 5, then in the Materials section refers to Code level 4. All very confusing as the Codes have been scrapped. Pg6- Green roofs  Makes reference to green roofs, but these have all now been omitted. Flat roofs now, out of keeping with surrounding vernacular will have a standard flat roof covering that will be visually intrusive. Pg6 – Renewable energy  Refers to photovoltaic cells, None shown on the drawings. They will only work on south facing roofs. There are now more roof lights proposed than January application and so there will be no room for them. Pg6- Bin storage  Only provides half the mandatory number of bin storage required. 

2. Application Form Section 10 Vehicle Parking  Table has been filled out incorrectly and is misleading. In the total proposed column the I space is double accounted, appearing in both the Cars and Disability spaces rows. Currently there are three parking spaces on site (one in the garage and two on the drive). Section 14 – Existing use  House is not vacant Section 15 – Trees and Hedges  Applicant incorrectly states that there are no trees or hedges on the development site and that therefore is nothing that could influence the development.

3. Drawings Site Plan 531-PL-01 Resubmitted as part of the amended set but is in fact the same as the January submission and incorrectly shows the garden stores a lot smaller than that proposed.

Proposed footprint justification 532- PL-02 (NEW DRAWING)  Drawing is misleading as the footprint includes the single storey side and rear extensions so overstates the size/volume of the building currently on site. The two storey volume is less than that of No. 33 and No.37 currently. Proposed building of total 4 storeys fills larger footprint so destroying the defining and important character of detached buildings on this part of Maidstone Road.  Larger volume will seriously impact on the level of daylight amenity currently enjoyed by the flank windows of the adjacent properties. We would expect the applicant to submit an independently commissioned Daylight and Sunlight analysis to test that the daylight still meets the BRE standards. Similarly the analysis should demonstrate that sufficient daylight is provided in the proposed new apartments. Proposed Site Plan 532- PL-02 (NEW DRAWING)  Duplicates drawing number of the Proposed footprint justification drawing above. True volume and footprint of the building can be seen here and is much larger than the other houses on the street. It is also a single rectangular block without the irregularities and architectural interest on plan of its neighbours. Site Plan 531-PL-02  Completely out of scale stores most apparent on this drawing. Lower Ground Floor 532-PL-03  Boundary treatment not clear to side fences as the new drawings are not annotated to say what the treatments are (January drawings had annotation of 1.2m fence) Footpath from flat 2 to garden would directly overlook garden to No.33.  New windows to flank walls facing No.33  Non-compliance with priority 1 standards of the London Housing design Guide. o 3.2.3 – No natural light to circulation areas o 4.2.1 – Inadequate space to demonstrate that two single beds fit in at least one of the bedrooms. o 4.6.2 – None of the flats provide accessible WC with possible future shower installation at entry level. Ground Floor Plan 532-PL-04  Not clear which is the disabled flat but presumably flat 2 or 3 as they are at ‘ground floor” level? Neither comply with required wheelchair design standards and of insufficient overall area.  Flat 2 has no balcony therefore does not provide private amenity space which is a mandatory, priority 1, requirement of the London Housing Design Guide.  Non-compliance with priority 1 standards of the London Housing design Guide. o 3.2.4 – Paths and corridors not minimum 1.2m o 4.2.1 – Inadequate space to demonstrate that two single beds fit in at least one of the bedrooms. o 4.6.2 – None of the flats provide accessible WC with possible future shower installation at entry level. First Floor Plan 532-PL-05  Non-compliance with priority 1 standards of the London Housing design Guide. o 3.2.4 – Corridors not minimum 1.2m o 4.2.1 – Inadequate space to demonstrate that two single beds fit in at least one of the bedrooms. o 4.6.2 – None of the flats provide accessible WC with possible future shower installation at entry level. o 4.10.1/4.10.3 – No private outdoor space to flats 4 7 5 which is a mandatory, priority 1, requirement of the London Housing Design Guide. Second Floor plan - 532–PL-06  Non-compliance with priority 1 standards of the London Housing design Guide. o 3.2.4 – Corridors not minimum 1.2m o 4.2.1 – Inadequate space to demonstrate that two single beds fit in at least one of the bedrooms. o 4.6.2 – None of the flats provide accessible WC with possible future shower installation at entry level. o 4.10.1/4.10.3 – No private outdoor space to flat 6 Proposed Front Elevation and Street view 532-PL-07  Ridge of proposed building should naturally step down below that of No.33 to follow street gradient. Shown as level with No.33 thus taller than current building. Height however is inadequate to provide required headroom for habitable rooms proposed, see below, hence building`s overall height would need to increase.  Ridge of N.39 drawn incorrectly as higher than that of No.37 giving misleading impression that building heights go up and down rather than what accurately happens and they follow the street gradient.  Needs to show basement elevations as the original submission drawings to allow for fair comparison.  Needs to show the balustrade treatment to the basement terrace. Proposed Front Elevation and Rear Section 531-PL-08 (Incorrect drawing number as presumably should be 532-Pl-08?  There are now many more windows and more larger windows than the original application. Rear windows are not obscured glass and so overlooking to gardens of No.33 and 37 has increased from that of current house and the original proposals. Proposed Long Section 532-PL-09  Rooflight to front of property does not work as half to it is shown in the roof void so daylight levels to bedroom and living/dining room appear to be inadequate. As a minimum the daylight levels should be calculated to assess whether they meet the BRE minimum standards.  Non-compliance with priority 1 standards of the London Housing design Guide. o 5.4.1 – Floor to ceiling heights not minimum 2.5m requiring overall building height to increase. o Inadequate headroom to loft within roof space. Height of room where partition joins underside of the roof scales as 1.4m clear.