Summer Road Action Group Winter 2018 Existing street-scene looking north on Hampton Court Way Same as Viewpoint 9 in the HTVI (Note the illegal right turning red car) August 2019 SRAG Visualisation of Current Proposal (using the above image) SRAG OBJECTION TO APPLICATION 2019/2005 UNITS 1 & 2 HAMPTON COURT INDUSTRIAL ESTATE SUMMER ROAD, THAMES DITTON 1. SUMMARY This proposal is unacceptable to SRAG on the grounds that: - 1.1. Loss of employment use – The existing uses have not proved to be a bad neighbour to the local community; they provide local jobs that offer sustainable lifestyles; they should be relocated; and we see no community benefit to offset the loss, as required by adopted Local Plan policy; 1.2. Cumulative impact of proposed nearby residential sites – this site should be part of a comprehensive development of Units 1,2 & 3; the likely negative impact on the infrastructure and particularly on the highway network of residential development of this site, with Unit 3, plus the other nearby Housing Options sites at the north of Leaf Close and at 67 Summer Rd EM, and the current proposal at H C Station should be assessed as the commitment in the Housing Options Consultation documents and the proposal is premature until such time. 1.3. Excessive density – the proposal is for a density of 120+ dwelling unit/hectare which is excessive in comparison to the prevailing densities in the area that are likely to be around the borough average of 40 dwellings/hectare. Together with a commercial unit on the site which increases the true density, this indicates to us a significant harm to the character of the area. 1.4. Limited and unidentified affordable Housing – the offer of 10% affordable housing equating 8 units, has been made as an afterthought, whereas it should be provided at 40% to accord with policy and pre-app advice, and the location and size of each unit should be identified and subject to public consultation. The viability assessment and independent review is flawed as set out in our critique. If the development is unviable this application should not have been submitted; 1.5. An inappropriate site for a commercial use – the commercial unit, located at the entrance to the site, should be removed from any scheme for this site, as it creates internal urban design and vehicle movement conflicts, and a likely negative impact on the local highway network; 1 1.6. Negative impact of using the existing site access alone and lack of connectivity – the use of the existing access from Summer Road TD as the sole access to residential and commercial uses at Units 1,2 & 3 is unacceptable to SRAG by virtue of the likely negative highway impact on the level crossing and junction of the HC Way and Summer Road/s. A single access used by commercial, industrial or storage vehicles will bring serious safety and amenity hazards within the site for the residential occupiers. SRAG favours the new second access off the HC Way between Units 2 & 3 agreed by SCC CHA, associated with downgrading or closing the existing access, but unfortunately this does not form part of the application; 1.7. High probability of increased trip generation – the assertion that there will be no increase in trips generated from the existing uses operated Mon - Fri only is not based on actual survey information and likely to be flawed and unrealistic. The site currently has 40 car park spaces and following the development will have 85. Doubling the number of parking spaces and more than doubling the number of people on the site 7 days a week is bound to lead to an increase. The Elmbridge norm of between 47-63% of commuters travelling to work by car is likely to apply to this site, as the walking distances have not taken into consideration the distance travelled south before travelling north to the train and bus destinations. The future trip generation of Unit 3 is unknown and cannot be limited by planning legislation within the existing use rights. Unit 3 is likely to be redeveloped for residential, as established in the Housing Options report, which will further increase the trips generated from the existing access, and thus the proposal is premature until Unit 3 comes forward in a comprehensive development scheme.; 1.8. Highway safety concerns of increase trip generation – the HC Way/Summer Rds junction is currently congested and dangerous to use for all pedestrians and drivers, and the residents of Summer Road EM enclave are at risk on a daily basis as they must use this access. An increase in trips generated in the immediate vicinity will result in an increase in the prohibited movements at this junction, and an increase in the occurrence of tail backs onto the main carriageway when the level crossing is down, resulting in a probability of increased traffic incidents; 1.9. Parking overspill outside the site – the car parking space allocation plan has not been illustrated even though it is a requirement of EBC and SCC. Flats that have 2 or more cars will be forced to park offsite competing with local residents and creating a potential danger to highway movements. Two visitors parking spaces for 78 flats is an under provision. This is not such a sustainable location that car ownership levels will be low; 2 1.10. Lack of understanding of the townscape character of the area – the documents demonstrate a misunderstanding and misrepresentation of the character of the immediate area. It is important that the strength of the surrounding mature landscape is retained to separate the two adjoining villages and maintain the Green Corridor policy, as the existing warehouses achieve, and are not dominated by new built form. The visualisations of the proposal are limited, unrealistic, often inaccurate, based on summer tree cover prior to recent felling, and do not fool the local community; 1.11. Excessive heights and massing – the 3 apartment slab blocks have huge footprints compared to the scale of nearby built forms, and are predominantly four full storeys at 15.24m high, in an area where the buildings are predominantly 2 storey and between 8-8.6m high. The building line is brought nearer the HC Way which will increase the visual impact through and above the tree canopy; 1.12. Weak and unsympathetic built forms – the design includes a clumsy entrance block comprising the commercial unit that does not create an inviting sense of arrival; the roof forms are top heavy and create an extended continuous domineering roofscape; the ground floors elevations and internal layouts are soulless and comprise poor design endangering personal safety and anti-social activity; all to the detriment of the visual and functional character of the area 1.13. Lack of understanding of the landscape character of the area and site – there is an exaggerated and unrealistic emphasis on the capacity of the dry ditch tree strip to provide a solid screen to obscure the impact of these vast built forms. The tree planting within the site at the boundaries does not include indigenous species, and trees and structures on the two flat roofs will be visually jarring to the character of the area; 1.14. Unacceptable increase in pollutants in an areas of poor air quality - the site is adjacent to a designated AQMA which exceeds current limits, a railway line and a level crossing making the pollution levels a high risk to the occupants of new dwellings, plus the residential and commercial users will generate vehicle movements to worsen the existing pollutant levels to the detriment of the surrounding residents. If this development is approved a condition and a S106 agreement should secure an extension to the existing AQMA. 3 2. BACKGROUND 2.1. SRAG stands for Summer Road Action Group which was set up in March 2019 following receipt of the community consultation. We represent 100 plus houses in Summer Road, Summer Gardens and Summer Avenue, East Molesey and comprise a formal committee of 8; 2.2. Our pre-app submission, made to the applicant, setting out SRAG concerns 23rd April 2019, attached in Appendix 1 2.3. One meeting held with the applicant’s developer’s team on 15th May 2019. Agreed Minutes of meeting in Appendix 2; 2.4. A meeting scheduled for 23rd July cancelled by developer’s team; 2.5. Ongoing email communication has set out our serious highway concerns in detail; 2.6. SRAG members has a long-term concern with the highway network and specifically the Summer Roads/Hampton Court Way (HCW) junction layout and has made representations to SCC Highway Authority who have agreed modifications to road signage and markings based on the existing traffic conditions, subject to funding availability; 2.7. A meeting with the applicant’s team to solely discuss highway issues has been requested; 2.8. A meeting with SCC to discuss highway issues has been requested but has been refused; 2.9. Abbreviations used in this report are: - SRAG Summer Road Action Group (Committee & our members) CHA – County Highway Authority HCW – Hampton Court Way SCC - Surrey County Council HRP – Historic Royal Palaces EM – East Molesey TA – Transport Assessment TD – Thames Ditton KGS – Kingston Grammar School AQMA – Air Quality Monitoring Area 4 3. LOSS OF EXISTING BUILDINGS & EMPLOYMENT USES 3.1. No objection to the loss of the built fabric on the site which is considered neutral in its contribution to the local character. However, we are mindful of the townscape contribution of the existing building which should set the context for replacement building (see Sections 14-16 below); 3.2.