How To Comment on Planning Applications

Windmill Road Action Group Creates Comprehensive Advice

Further to last week's article about the proposed development at Reynard Mills and the wider implication of continued planning developments in Brentford, the Windmill Road Action Group have written a clear crib sheet explaining how to complain, which applies both to Reynard Mills in particular but also to many applications. In order to gain a wider audience it is reproduced below.

There are two sections:  

• Firstly, a description of some of the key planning matters you may wish to include in your email or letter to the Hounslow planner who is reviewing the application.

It’s vital that you use ‘planning arguments’ in your objection, and the more the better.

• Secondly, the administrative aspects of submitting a response.  Who to send it to, the deadline, and copying the councillors.

SECTION ONE  -  WHAT TO COMMENT ON

It is vital to comment on planning matters.  The more planning matters each objection contains the better.

We’ve looked through the application and noted some of the key concerns.  These are described below and may assist you with drafting your response.

Transport and parking are a major worry for many surrounding residents.  The extent of these pressures is directly related to the number of housing units that are approved for Reynard Mills, and the resulting number of car drivers. 

So, it is vital that as many residents as possible comment on the planning issues of:

• low rise and low density character of the surrounding area,
• height of the proposed development,
• unacceptable massing of the proposed development ,
• that the development is out of scale for the location,
• excessive density of the proposed development . 

If we can get the planners to recommend rejection for these and related reasons, the developer will have to respond with a more modest application, which would mean fewer cars.

CHARACTER AND APPEARANCE OF SURROUNDING AREA
The proposed tower blocks and town housing fail to respect and reflect the character of the local area.  

This is particularly unfortunate as recent developments at the edge of the site have striven to reflect the low rise and vernacular style of the surrounding Edwardian housing. 

Particular examples include: Boston Lodge of two storeys constructed in London stock brick on Windmill Road at the northeast corner of the site and Mill Cross Court of four storeys, again clad in London stock brick, on Windmill Road to the south of St Faith’s. 

Along the western side of the site, recent housing has been low rise.  This includes the two storey housing at no’s 82 to 105 Manor Vale and the courtyard development of two and three storey housing at no’s 1 to 20 Manor House.

The 1930’s Art Deco three storey development of Manor Vale, set in carefully designed grounds and amenity space, will be adversely affected both by the design and the height of the tower blocks that will be some two and a half times taller and located close to the Reynards Mills site boundary.

In summary, the character of the proposed development is incongruous, and fails to reflect and enhance the carefully nurtured character of the housing surrounding the development site.

HEIGHT
At seven storeys, and built on raised ground, the proposed towers will be three times taller than the neighbouring buildings.

It is important to point out to the planners the heights of the proposed towers and how they compare to the much lower residential buildings that surround the Reynard Mills site.

On the Boston Manor side: 

• Our Lady and St John’s primary school is only two storeys high,
• The 1970/80’s housing in Manor Vale, next to the school, is also two storeys high,
• The 1930’s flats in Manor Vale are three storeys high,
• The 1970/80’s housing in Manor House is a mix of two and three storeys.

The northern side of the site where it adjoins Gunnersbury Secondary School is open.  The recently built Boston Lodge at the junction with Windmill Road is only two storeys high.

Along the eastern side, the Edwardian terrace facing Windmill Road is only two storeys high.

The highest neighbouring buildings are beside the southwest corner of the site, behind St Faith’s, where the recently built student housing is only four storeys high.

The developer is claiming that the height of the more distant GSK and TVU towers makes their proposed tower blocks on the Reynard Mills site OK.  This is a flawed argument that needs to be refuted to the Hounslow planners.  The buildings nearest Reynard Mills are much lower at between two an three storeys high and these lower heights should set the precedent for the height of any the replacement buildings on the Reynard Mills site.

It is also worth pointing out that the existing warehouse buildings on the Reynard Mills site are mainly two storeys high with ridge roofs.  The same is true of the recently constructed brick-clad office building used by Guided Ultrasonics Ltd at the southwest corner of the site next to St Faith’s.

MASSING
Much of the site will be dominated by the substantial footprint of the elongated tower blocks, some of which will extend for almost the whole width of the site. 

When viewed from most angles, these blocks will appear as a continuous mass and dominate both the sky line and the surrounding low rise housing.

SCALE
The proposed tower blocks are excessive and out of scale with the surrounding low rise residential housing to the west and east of the site. 

They will also dominate the downhill views, across the open air sports facilities of Gunnersbury Secondary School, from residential housing in The Ride to the north.

OVERLOOKING RESIDENTS OF SURROUNDING HOUSING
The height and mass of the proposed tower blocks will result in a significant loss of amenity, privacy and outlook for the surrounding residents.

Many of the nearest properties will be overlooked and suffer from a loss of natural light and direct sunlight.

DESIGN
The external appearance of the proposed flats and houses is incongruous and dominant.  It fails to respect the character, finish and scale of the suburban housing that surrounds and borders the Reynard Mills site.

The east-west axis of the proposed tower blocks means that many rooms will be north facing.  Some flats will be single aspect with only north facing windows.  The height of the towers means that some residents will be denied adequate natural light, especially in winter months.

DENSITY
The density of units on the proposed development significantly exceeds that of the surrounding residential housing.

A high density on this site is particularly inappropriate in view of its distance from public open space due to both of its entrances facing onto Windmill Road.  Residents, especially those with young children, will need to circumvent a lengthy route along busy roads if they wish to access either Boston Manor or Blondin Parks. 

In these circumstances a far greater proportion of the site should be reserved for open amenity space, as is the case in Manor Vale, and the density of housing units reduced.

TRAFFIC
Traffic is a major concern for residents, especially those who live on the Windmill Road side of the site.

With 315 flats and houses, a high level of car ownership can be expected.  Also, as the location is poorly served by public transport many visitors may wish to arrive by car.

The only ways of accessing the site will be by the existing entrances onto Windmill Road.  Congestion and accidents at these junctions are a possibility.

Both of the entry/exit roads to the site are narrow and are unlikely to be able to cope with a large volume of vehicles leaving and entering the site at busy periods.

Windmill Road isn’t wide enough for ‘holding zone’ traffic islands to be constructed along its centre at each of the Reynard Mills entrances. 

Southbound vehicles waiting to enter Reynard Mills will block all southbound movement in Windmill Road until it’s safe for them to cross in front of the northbound traffic. 

Southbound vehicles wishing to leave Reynard Mills will have to wait for a gap in both the northbound and southbound traffic in Windmill Lane, or risk moving out into the traffic causing congestion and possibly accidents.

Installing traffic lights at the Reynard Mills entrances will slow down through traffic, causing it to divert to the ‘rat runs’ leading to Junction Road. 

Any increase in congestion in Windmill Road will divert vehicles onto the residential side streets and ‘rat- runs’.

Please alert the Hounslow planners to any concerns you may have about increased congestion in Windmill Road and the problems it will cause.  It would be helpful if you could refer to any problems you have witnessed and make the point that those arose before the Reynard Mills residents arrive and exacerbate today’s problems.

PARKING
The developer is only proposing to provide 298 car parking spaces for the 315 flats and houses. 

As many households will wish to run two cars, there is a very real risk that some of the Reynard Mills residents, and their visitors, will be unable to park at Reynard Mills and will therefore park in the nearby residential side streets.

The number of flats and houses at Reynard Mills will determine the number of cars and the resulting parking pressures on the surrounding residential side streets.

In addition to commenting on the parking issues, you may wish to advise the Hounslow planners of any difficulties you already have parking near your home, as a means of evidencing the current problems before there’s a massive increase in residents.

FAMILY ACCOMMODATION
There is an acknowledged shortage of family accommodation in the local area.  You may wish to comment on the fact that the developer is proposing that only a quarter of the flats and houses will have three bedrooms.

SEWAGE
A number of residents have commented on problems with waste water and sewage flooding nearby properties. 

Please refer to this in your objection if you have experienced it, as there is likely to be insufficient capacity in the sewers to accommodate the additional 315 flats and houses.

SCHOOL PLACES
Many residents have expressed concerns over the current shortage of primary and secondary school places.  Please refer to any difficulties your family has experienced, and comment on the implications of constructing an additional 315 flats and houses.

MEDICAL PROVISION
Many residents have expressed concerns over the current shortage of GP’s and Dentists.  Please refer to any difficulties your family has experienced, and comment on the implications of constructing an additional 315 flats and houses.

SECTION TWO  -  ADMINISTRATIVE INFORMATION

DEADLINE FOR COMMENTS
The formal deadline for commenting on the application is Wed 13th July. 

(This has been confirmed by the council based on the 2nd phase of consultation letters dated 22nd June)

Please send in your response, even if you miss this date, as the planners will consider and count all responses received up to the moment they finalise their report.

WHO TO OBJECT TO
As the Reynard Mills site is just inside the Hounslow boundary, the planning application and public consultation is being administered by Hounslow’s planning department. 

All objections, including those from Ealing residents, must be sent to the Hounslow planners. 

Email objections should be sent to: Nikolas.Smith@hounslow.gov.uk

Postal objections should be addressed to:
Nikolas Smith
Development Control
London Borough of Hounslow
The Civic Centre
Lampton Road
Hounslow  TW3 4DN

Please quote:
Reynard Mills Planning Application  -  Reference P/2011/1516
on your submission.

WHERE TO LOOK AT THE PLANNING APPLICATION
The application documents can be found on the planning pages on the Hounslow Council website at:  www.hounslow.gov.uk/planning  and then follow the Search Planning Applications links to application reference:  P/2011/1516.

The documents are listed over two pages on the website.  You may find it helpful to begin by looking at:

• Design and Access Statement,
• Planning Statement,
• Transport Assessment (on the  second web page).

A reference set of the plans are available for inspection at Brentford Library. 

The library is open on Mondays, Tuesdays, Thursdays and Saturdays.  Its phone number is 020 8560 8801.

SUPPLEMENTARY OBJECTIONS
Please submit a supplementary objection if you’ve already commented on the application and would like to add to your original response.

COPY THE BRENTFORD COUNCILLORS
The planning application will be decided by the Hounslow councillors.

It’s vital the councillors are aware of the scale of resident concerns.

Please copy your objection to each of the local Brentford Ward councillors.  Their email addresses are:
Ruth Cadbury:       ruth.cadbury@hounslow.gov.uk
Melvin Collins:       Mel.Collins@hounslow.gov.uk
Matthew Harmer:  matt.harmer@hounslow.gov.uk

While the councillors are not allowed to express an opinion on a planning matter before the committee meeting at which it will be decided, they have a duty to listen to residents concerns.

If you’ve already submitted your objection, and don’t have a copy, please send an email setting out your concerns to each of the Brentford Ward councillors.  They need to be made aware that a very large number of residents are concerned about what is proposed.

Ealing residents should email the Brentford Ward councillors, as they will be making the planning decision. 

They could also email the Ealing Northfield Ward councillors who are: 
David Millican:       david.millican@ealing.gov.uk
Mark Reen:           mark.reen@ealing.gov.uk
Phil Taylor:            philip.taylor@ealing.gov.uk

March 31, 2013