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Planning Submission


Submission to Wandsworth Borough Council
Added on: 17 January 2015 at 12:47:01

Formula E Racing in Battersea Park: 2014/6976

The Battersea Society strongly objects to this application for FE racing in Battersea Park.  The application is for activity which is directly contrary to the purpose of the park and the enjoyment and use local people make of it. 

Policies in relation to Metropolitan Open Land

Approval for staging the event would run counter to the policy relating to Metropolitan Open Land in Policy 7.17 of the London Plan, and to policy DMO 1: Protection and enhancement of open spaces in the Borough’s Development Management Policies Document. 

The London Plan policy 7.17 Metropolitan Open Land (MOL) requires that planning decisions should give MOL the strongest protection and inappropriate development refused – within which category a major racing event such as this clearly falls.  In addition, even appropriate uses will only be acceptable where they do not have an adverse effect on the openness of MOL.

In the Wandsworth DMPD Policy DMO 1:  Protection and enhancement of open spaces in Wandsworth it states that ‘… areas of open space … will be protected and enhanced and development will only be permitted where: 

(i) it is linked to the functional use of the open space; and

(ii) it does not harm the character, appearance or function of the open space. 

Cumulative impacts of development will be taken into account in this assessment.
 

We consider this application fails to make the case that those exceptions can be regarded as applying in this instance. 



We are also concerned that the protection and restoration of the Park during and after the proposed operations will apparently be left in the hands of a company which has not demonstrated any experience or expertise in that field or (so far as we are aware) provided any guarantees against insolvency risks. 

Lack of Essential Information 

The application is deficient in that it does not provide sufficient information on which to give planning approval for the event, for example in relation to traffic planning, hours of working and other aspects potentially causing harm to users of the park and to residents.  It is deficient in not providing any detailed transport traffic plan.  The thin references to adequate public transport in section 5 of the Design and Access (D&A) statement are naïve given the number and type of attendees for the events. The Thames Water objection highlights these concerns.  It is essential, therefore, that the promoter provides further detailed information on these issues in order that the Council can fully assess the application and consider the consequent measures required to monitor the promoters’ work. 

Financial Benefit to the Borough 

This lack of operational information is compounded by the lack of transparency about the financial benefits to the borough and the extent to which the Park and its management would benefit from this, if at all.

No cogent case is made in terms of balancing the clearly detrimental impact of the staging of the event against any financial or other benefit.  We totally disagree with the bland statement by the promoters in section 4.23 of the D&A statement that short term disbenefits are outweighed by long term advantages.  While the promoters repeatedly emphasise that the events are a temporary use of the Park, what is not recognised is that the necessary infrastructure will cause permanent changes to planting and hard landscape in the Park.

 In addition, should it go ahead it would represent a significant shift in the type of use associated with the Park and provide a precedent for further large scale events, to the detriment of the long term sustainability of the Park’s heritage and its green and calm character. 

We consider, therefore, that it should be refused planning approval.  Further justification for our conclusion and our detailed concerns are set below 



Further Note of Objections  (submitted earlier) 

Our concerns focus on five areas: 



1 Inappropriate use for a listed grade 2 heritage park




  • international FE racing on this scale is an inappropriate use under adopted planning policies both at London and borough level i.e. London Plan policy 7.17 Metropolitan Open Land and Wandsworth DMPD Policy DMO 1: Protection and enhancement of open spaces

  • local closure for four days plus major disruption over extended period during  build up and break down runs counter to the role of such a park as a universally accessible peaceful haven and summer oasis in a high density urban area where many, especially lower income groups, have little access to private open space

  • the event would set an unfortunate precedent for the park becoming seen as a prime venue location for major events rather than a public local park (as  has happened to other parks in London e.g. Victoria Park post Olympics)

  • the event will have a significant impact on the hard landscaping features of the Victorian Park notably carriageways, avenues, vistas and street furniture all recently restored with a major grant from the Heritage Lottery Fund grant



2: Impact on trees, planting and soft landscaping




  • potential  loss  and damage of trees, planting, grassed areas at time of year when use of Park at its peak; suggestions for mitigation are weak and in hands of promoters

  • 30,000 visitors per day will inevitably cause damage and trampling to shrubs, grass areas etc as a result of the racing, which could take months to restore at a time of year when the Park is most used

  • we consider dismissal of the Heritage Lottery Fund's requirement for full time conservation officer by the borough is misjudged.  Inspection before and after is inadequate on its own to deal with issues which arise during construction and reinstatement



3: Extended period of Construction and break-down




  • extended period of disruption to park  - it appears that commencing physical works as soon as possible after grant of planning permission in February  i.e. 4 months before the event. This runs counter to policy of allowing residents full use and enjoyment of the park

  • scale of plant needed to construct barriers, lighting etc presents major risk to Park gates, roads and hard landscape as well as damage to trees, grass, kerbs

  •  works taking place in summer when many using park, including young children raising potential danger and conflict between users and works traffic;

  • unclear what routes construction traffic would take: would add to already congested roads due to Nine Elms sites – turn off Queenstown Road at Chelsea Gate should be from north as lorries too big to make turn from south without risk to the gates

  • deadlines attempting to shorten build up and breakdown are a double-edged sword as could lead to pressure for completion and give rise to reckless work and damage – oversight difficult and suggested mitigation/restoration an inadequate recompense



4 Nuisance to residents, access, parking  noise etc




  • an event attracting potentially 30,000 visitors each day for two days in the height of summer presents a major local nuisance for local residents especially over a weekend when they expect a quieter environment and are at home during the day;

  • lack of local parking - drop off on adjacent roads could cause major traffic congestion and raise safety issues e.g. on Queenstown Road, Albert Bridge Road and Prince of Wales Drive; there is a need for local parking controls (which do not normally operate at weekends) to protect local resident parking during event and no consideration of this is included in the application

  • public transport is already overloaded 

  • no transport plan or suggested controls on working access to site are included with this application; the thin references to adequate public transport in section 5 of the D and A statement are totally adequate



5 Insufficient Information about actual financial benefit to the park




  • impossible for councillors to reassure Wandsworth residents  without greater transparency on income and how it would off-set costs be ring-fenced in support of Park maintenance etc

  • unclear what type of break clause built in or whether any review and full assessment  after one year before approval for further four years

  • unclear what position is if promoting companty ceases trading given it and FE's short history


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