Objecting to Formula E Planning application (2015/7363)
A planning application has now been made by Formula E on 29 December for
the 2016 event to be held on 2nd & 3rd of July.
The application appears to have two purposes. Firstly, the main aim of
obtaining temporary consent for the event in 2016 and secondly, seeking a
permanent consent for the additional areas of temporary tarmacking created
for the event in March 2015. If granted, this will mean Formula E will not as
previously intended be required to reinstate any of these areas when the event
no longer takes place in the park.
We feel that it is wrong that the Formula E application should include
permanent changes in a public park to form a circuit and that these are then
left behind as their legacy. Why should a here today, gone tomorrow,
organisation be released from its original obligation to reinstate areas where
these have resulted in lost grass and planting?
This is wrong and where these have an adverse effect on landscaping they must
be reinstated. Where wider car parks have been created and unbroken wide
areas of tarmac has been laid these must be broken up as before with narrower
linking road sections. This must be decided on a location by location basis not
now but when Formula E is discontinued. This should not be wrapped into this
application but treated as a separate issue when appropriate and these should
remain temporary modifications.
The relevant planning application is 2015/7363 and can be viewed using the
link below which also gives access to all relevant associated documentation
required to be submitted as part of Formula E’s application.
http://is.gd/fe2016
The way to object to the planning application is to write to the Planning
Department, either by post or by e-mail.
On-line follow the link above and then click on:Comment on application and add your details and the basis of your objection
make very sure you tick the box object to the proposal not the default which
is ‘make an observation’.
If sending a letter please quote the planning application number shown above
and send to the case officer:Chris Grace
Planning Department
The Town Hall,
Wandsworth High Street,
London, SW18 2PU
Basis of Objections
In terms of objections, these need to made individually and not in a standard
format but we hope these guidance notes will help you through this process:The Council has requested objections/comments within a set time limit of 21
days and so all objections must be made by 26 January
Your objections need to be made on planning grounds although there is no limit
within reason as to what you can say but please keep in mind they should
generally be planning related and be reasoned as to why you think consent
should not be given. You can concentrate on those aspects that most concern
you or, be more wide ranging in your objection, whatever suits you.
When making your planning objection you need to concentrate on those aspects
of the event/development which you feel are unacceptable such as possible
noise and disturbance, visual impact, the likely effect on the amenity value
and use of the park on residents and park users. Such areas as impact on
park facilities, normal use of the park and out of hours working and general
noise are therefore all relevant areas, (refer to the ‘Noise Management Plan’
document for detailed proposals that cover these issues including working
hours which are unclear).
With regard to the additional tarmacking that Formula E now have applied to
be made permanent, details are included in the document ‘Civil Works’ and
reference is then contained within the ‘Design and Access Statement’
document (Page 6, Sections 3.4 to 3.10). We feel that these areas have in many
cases purely been created to facilitate the design of the circuit and not for the
benefit of the public and their use of the park. Permanently establishing
these areas of tarmac which replace grass and planting is wholly against the
ethos of the park. The Formula E Venue Use Agreement requires reinstatement
when Formula E finally leaves the park and this we feel must be enforced not
avoided by a sneaky bureaucratic abuse of the planning system.
The park is a Conservation area and Grade II* listed open space and therefore
tighter restrictions apply including protecting and conserving the park. The
park houses a Local Nature Reserve and again protection of this asset and the
park wildlife is very important. Nesting birds, wildfowl, bats and other
wildlife as well as flora including trees all need to be protected from what
many view as a wholly inappropriate use.
Councils are under a legal duty to have particular regard to the desirability of
preserving or enhancing the character and appearance of a Conservation Area
and an open space with listed status
Concerns over Health & Safety during set up and de-rig are not planning issues
but the experience of last year may be worth mentioning in passing.
Last year’s planning consent for Formula E contained a number of planning
conditions. This year, if granted, we feel more stringent planning conditions
should be applied. The 2015 planning consent can be viewed at
http://is.gd/FE2015consent
If you have time, please review the 2015 conditions as clearly in many cases
the Council failed to enforce them or they need beefing up.
From last year’s planning consent the conditions we feel were flouted were
as follows:Condition 3 – An inadequate noise Management plan.
Condition 4 – (a) No pruning of trees and shrubs without prior written approval.
(c) No tree protection in place during construction
(d) Aboricultural site supervision inadequate
Condition 6 – Car & HGV management plan poor and ill-conceived
Condition 11 – Insufficient consideration given to a local nature reserve.
Ecological Report not fit for purpose proper consideration required of nesting
birds, wildfowl and protected bats (full bat survey not undertaken which should
have been made an essential requirement of Formula E) as well as other
wildlife and flora.
Planning Policies
Planners and Planning Committees are required by law to determine
applications by reference to National and local policy guidance and this is
contained within a document called the LOCAL PLAN. Your objections can
where necessary reference the relevant section of the Local Plan document
as this should be their guide on any application.
The Local Plan is the strategic planning document that provides general
guidance and policy upon which planning decisions need to be taken. The final
Wandsworth Local Plan is not as yet agreed as it has needed to go through
public consultation but is at an advanced stage and due weight needs to be
given by the committee to the policies in this emerging plan.
The document in its entirety can be found at:-
http://is.gd/localplan
In terms of the park the relevant sections of the plan in full are as follows:Local Plan Review - Core Strategy (2nd Proposed Submission Version 2014)
Open space and the natural environment
4.33 Open spaces and the green chains that connect many of the borough’s
open spaces fulfil a variety of environmental functions, provide visual relief in
built up areas and are important for both formal and informal recreation,
physical activity, sport and play, providing playing fields, walking and
cycling routes. They play an important part in addressing health
inequalities in the borough: the most deprived areas have a higher
incidence of health problems and/or lower life expectancy. They also
play an important role in the delivery of broad government objectives
of urban renaissance, social inclusion and community cohesion, health
and well being, and in promoting more sustainable development. They are
important in addressing climate change: the retention of soft landscaping,
such as front gardens, can reduce the risk of flooding from run-off, as well as
providing opportunities for biodiversity.
Open spaces also provide “green lungs” in the borough, important to
improving air quality. Private residential gardens also represent a
valuable open space resource which should, where appropriate be
protected from development. Trees are important as a visual amenity,
contributing to historic landscapes, and in adapting to climate change.
The Council has an adopted Tree Strategy providing a policy framework
for the management of trees. The Sustainable Community Strategy Council
aims to provide healthy environments by promoting wise stewardship
of natural resources, encouraging access to high quality and safe
parks, commons and other open spaces to improve people's physical and
mental well being. New and improved facilities will be supported, including
increasing public use of private facilities, using planning obligations where
necessary to deliver improvements in targeted areas of need.
.
4.36 Wandsworth is well served by all types of open space, including
Metropolitan Open Land which contributes to London's network of strategically
important open spaces. However, both public and private open spaces are under
pressure from development and Government guidance makes it clear that
developing more housing should not mean building on urban green spaces.
Moreover, the projected significant increases in the borough's
population will create additional demand for accessible open space,
sport and play facilities. The Council commissioned consultants to carry out
an Open Space Study in 2006, which undertook a quantitative and qualitative
audit of open spaces and an assessment of current and future needs, including
evaluating the strategic role of the borough’s open spaces. Given the limited
potential for urban areas such as Wandsworth to provide new open
spaces, the study assessed the potential for improvements and
increased access to existing open spaces to better meet the needs of
users.
4.38 Within the borough are large areas of European, metropolitan and local
ecological importance: and there is a Local Nature Reserve in Battersea
Park. There are also several other important sites for biodiversity identified in
the borough and the Council has a biodiversity action plan which
details opportunities to enhance or increase the biodiversity value of
these sites.
Core Policies for Places: Policy PL 4
Open space and the natural environment
a. The Council will protect and improve public and private open space
and Green Infrastructure in the borough, including Metropolitan Open
Land, such as the major commons, parks, allotments, trees and playing
fields as well as the smaller spaces, including play spaces, as identified in the
Open Space Study and Play Strategy.
c. Playing fields will be protected and opportunities for participation in sport,
recreation and children's play will be promoted. Where there is no future demand
for playing fields or other outdoor sports use, other open space uses will be
sought.
e. The borough's green chains and the open spaces along them will be
protected and enhanced.
f. The biodiversity value of the borough will be protected and enhanced
including that of the River Thames, River Wandle and Beverley Brook and
species and habitats identified in the London Biodiversity Action Plan
and through Local Nature Partnerships.
g. New development should avoid causing ecological damage and
propose full mitigation and compensation measures for ecological
impacts which do occur.
Other Policy considerations relate to National guidance within the
document below:National Planning Policy Framework (the NPPF), published in March 2012
Section 117. To minimise impacts on biodiversity and geodiversity, planning
policies should:

Promote the preservation, restoration and re-creation of priority
habitats, ecological networks and the protection and recovery of
priority species populations, linked to national and local targets, and
identify suitable indicators for monitoring biodiversity in the plan;
Section 132. When considering the impact of a proposed development on the
significance of a designated heritage asset, great weight should be given to the
asset’s conservation. Significance can be harmed or lost through alteration or
destruction of the heritage asset or development within its setting. As heritage
assets are irreplaceable, any harm or loss should require clear and convincing
justification. Substantial harm to or loss of a grade II listed building, park or
garden should be exceptional. Substantial harm to or loss of designated
heritage assets of the highest significance, notably scheduled monuments,
protected wreck sites, battlefields, grade I and II* listed buildings, Grade I and
II* registered parks and gardens, and World Heritage Sites, should be wholly
exceptional.
We hope this helps you in making your objection and good luck!!