Booker Cash and Carry, Battersea Park Road

Booker and BMW Sites:  2022/1835

The Battersea Society objects strongly to this unneighbourly over-development of the site which fails to complement other buildings within the area; to the move from housing to student accommodation; and to the lack of concern for the environment in relation both to the removal of trees and to the low level of BREEAM  proposed.  We note that a number of these concerns were raised by the Design Review Panel (DRP) prior to the application being submitted and it is regrettable that little has been done to address these issues.

 Site Context and Shortcomings

 Overall the proposals do not give a strong understanding of how the development would sit alongside other new developments in this part of Nine Elms. In particular how it relates to the Sleaford Street development, the new primary school, and to Palmerston Court.

 The general layout of the blocks, public realm and access do not adequately reflect the impact heavy night traffic using the market access road will have on adjacent residential accommodation. This needs stronger acknowledgement both in the design of any buildings facing onto the access road and to its impact on servicing the development site as a whole. 

 We have concerns about the inclusion of a children's play area in the middle of a development of this type which, if a student complex is approved, will have few families with young children. We support the points made by the DRP in their April response. We would favour sitting out areas with grass or hard landscaping features which were interesting to children but not specifically a playground. In particular there seems to be confusion between providing a through route across the site and its use as a quieter play and sitting area. 

The student accommodation blocks provide quite limited communal cooking and eating areas. It is likely, therefore, that students will need to use local food outlets and convenience stores of which there are very few in the immediate vicinity of the site.  However the application says very little about the type of business likely to occupy the proposed ground floor commercial units. Is it envisaged that these would provide convenience goods and fast food outlets? If so they should be of a range that could serve both the student population and local residents. However If the commercial units are seen to be aimed at a different market, the submission should have included more detail of what fits the wider objectives for the site as a whole.

We are concerned that a large influx of students, alongside those in the Palmerston Court scheme, could mean that smaller independent outlets around Battersea Park Station are replaced in favour of the large fast food chains.   Every effort should be made to encourage small independents in this, as in other developments in the area, in order to generate a livelier locally based economy.

 Student Accommodation and move from housing.

 The approved proposal provided for 307 units of accommodation, the majority of which is now proposed as being replaced with student accommodation.  Given the need for housing and the amount of student housing already consented, this is not acceptable.

 The Planning Statement claims (6.24-6.26) that the development complies with the London Plan Policy H15.1 that it should contribute to a mixed and inclusive neighbourhood. But the calculations on which the claim is based fail to take account of the even larger development of student accommodation (868 units) currently being built 200 metres away at Palmerston Court, or of the large concentration of student accommodation at Vauxhall. And the proposal takes no aacount of the substantial number of studio and one-bedroom units already built or under construction in Nine Elms..

The Planning Statement also claims (6.31-6.32) that it meets the fast-track target set in the London Plan Policy H15.4 relating to affordable units. The target is 35% affordable student accommodation or 50% where the development is on public or industrial land. But the proposal will provide only 21.6% affordable student units. It then claims that if the 81 housing units are taken into account, the percentage rises to 39%. That higher percentage is still lower than the target of 50% for developments on public or industrial land; and the warehouse and former car service centre on the site clearly fall within that definition.

However the 39% claim derives from a calculation that includes all the rooms in the housing units, rather than the 81 units themselves. The true percentage is 29%. The claim that the development meets the fast track target is clearly false.

Lack of concern for the environment

The removal of 5 high quality mature trees with Tree Preservation Orders is of great concern and overall the proposals are unsatisfactory in terms of urban greening, biodiversity and climate change mitigation. While the London Plan recommends a target score of 0.4 for predominantly residential developments this proposal only achieves 0.38 and there appears to be no biodiversity net gain in spite of requirements under the 2021 Environment Act, for a Biodiversity Net Gain (BNG) of 10% as a condition for every planning permission granted.

 The development targets BREEAM Outstanding for the student residential provision but BREEAM Excellent only is expected for other parts and this falls short of Local Plan aspirations. The Daylight, Sunlight and Overshadowing Report acknowledges that methodology used is based on  Average Daylight Factor (ADF) instead of the new  target daylight factor (DTM) and  minimum target illuminance (ET) tests required by BS EN 17037. In both these areas there appear to be a number of further details to come without which it is hard to be sure that required standards will be met.

 To conclude, this application has major flaws and should be refused.