The Council list outstanding reports and raise concerns in April yet the reports are still unavailable

Marble Hill Park, Twickenham

LB Richmond References: 17/1094/FUL & 17/1096/LBC

Site: Marble Hill Park, Richmond Road, Twickenham TW1 2NL

28 April 2017

Proposal: Comprehensive redevelopment, including Marble Hill House renovation and alteration; Stable Building extension (to form 140 cover café) and service yard access; park landscaping and drainage; sports building alterations; sports pitch and play area improvements; and associated works (including to walls), installations and services.



1. Redacted

2. Trees (and Landscape)

(a) Introduction / Overview &
BS5837: 2012: ‘Trees in relation to design, demolition and construction’

The scale of tree removal on this site is such that a commitment to re-planting is required to mitigate for the loss of amenity. Currently the detailed planting plans are to be developed in consultation with park users as part of a long term strategy. Policy DM DC4 states that there will be a presumption against schemes that result in a significant loss of trees, unless replacements are proposed. The removal of trees is recognised in Policy DM DC4 as part of a historic restoration scheme but without a commitment to replacement trees, this proposal is not currently acceptable.

The applicant’s confirmation of their intentions in this regard is required in accordance with the BS 5837, as summarised under the following headings:-

  1. (b)  Woodland Quadrant Plans / DetailsA detailed plan is required for each woodland quadrant that clearly shows the quantity, scale, species and size of trees due for removal and/or coppice.

    Reasons / background: In order to facilitate the re-landscape elements for each woodland quadrant garden a significant number of trees will need to be removed and/or coppiced (G8, G9, G10 and G7). Within in each woodland quadrant it is unclear which trees are designated for removal, and/or coppicing and which has been categorised as a ‘specimen tree’ for retention. The drawing number CBA10677.04 is unclear on the trees advised for removal (red circle) and those being retained.

  2. (c)  Quadrant Demolition / Construction WorksA detailed plan is required that clearly shows the implications and effects, within each woodland quadrant, for specific demolition/construction works. This should include larger scale drawing details (superimposing Streetwise Tree Removal Plan on the Illustrative Landscape Plan) of the following areas:
    1. The four Quadrants;
    2. The West Grove line;
    3. The Line of the Proposed Tree works extending westwards, along the river, at the south end of the East Grove.
      4(d)  Smaller Landscape Works DetailThe smaller landscape works need to be specifically detailed, including:

      • ninepin alley;
      • gravel paths
      • marquee (bases? and anchor points)* (See covering email)[Details, such as benches in the play area, waterproof buggy store may be Conditioned.]

        It is currently unclear what impact these will have on the trees and where exactly some of these will be sited.

        5. (e)  Play Area : No-Dig Footpath (or ‘minimal dig’ Detail)Revised drawings confirming a no-dig footpath should be provided; or details of the proposed ‘minimal dig’ footpath should be provided.

        Reason: The proposed new play area is shown within the middle of a group of mature trees a category A Red Oak (T27), category C Common Lime (T18) and a category B (T17) Lime with the main play area outside of the RPA’s of the trees.

There is no objection to this element of the proposal although details relating to the minimal dig footpath are lacking.

(f) Stables: Proposed Extension & Service Yard

Details are required in respect of the proposed removal of T12, including the requisite arboricultural justification.

[The café and service yard will require the removal of a category B mature Horse chestnut (T12) within the service yard.]

Details are required of proposed service arrangements. [However, while it may be prudent for the applicant’s interest to identify these at planning application stage; in the event that the Council should be minded to approve, this matter may be deferred by a Condition.]

  1. (g)  Montpelier House (Garden)Details are required, in respect of:
    • the proposed foundations which are within close proximity to the site boundary with the Montpelier House Root Protection Area (RPA); and
    • the effects of the proposed foundations upon the Montpellier HouseRPAs and trees; and
    • the trial holes dug nearby.Reason: The proposed café would sit within the root protection area (RPA) of trees T53, T54 and T55 three early mature Hornbeams and T52 (Sycamore) and T51 (Yew) in the rear garden of Montpelier House. The incursion into the RPA’s of these trees has not been detailed; and the results of trial holes dug nearby have not been provided.

      [Details of services / routing will be required (tree effects). While these could be Conditioned, the applicant may consider it prudent to investigate / propose these at application stage.]

      8 (h)  Wetland: Existing Vs Proposed?Improved clarity is required in respect of the existing and proposed wetland areas.

      The main flooding area is directly in the view from the main house to the River Thames seen by the lush green vegetation and amounts of stinging nettles and docks that grow there. However, the Illustrative Management Plan (581_PL_L_01 C) shows improved wetland areas to the east of the site, with no reference to the extant wetland area. Clarity is required in respect of the principles of the works proposed to the extant wetland area; and in respect of the proposed wetland area.

3. Ecology

The Park is a site of local nature importance, where biodiversity and opportunities to create new habitats is encouraged [LDF Core Strategy 2009]. The Council’s Ecologist has recommended refusal, following concerns in respect of the absence of

details of appropriate protected species surveys and the proposal (e.g. details for woodland landscaping). These issues, together with actions for productions, have been summarised below.

(a) Bats [European Protected Species and a UK Priority Species]

  1. Omitted Baseline Survey Data – London Bat GroupThe requisite information should be obtained from the London Bat Group, in respect of the holistic activity across the site, to provide the full complement of baseline information to inform a revised Bat Survey and Report.

    The Survey report also recommended that the LBG bat data was requested as this data is not included within data provide by GiGL. However, there does not appear to be any reference to this.

  2. Holistic Survey of Bat ActivityThe Survey needs to be extended to a more holistic survey (i.e. how the bats use the whole site), as prescribed in the Preliminary Ecological Appraisal (PEA).

    The FAO Bat Survey is limited to a Roost Survey. It needs to be extended to an expanded holistic study. The PEA recommended having a bat survey carried out to understand how bats use the whole site.

  3. Incomplete Bat Surveys: Stables, Service Yard and Sports Building (and pagoda/ticket shed and disused toilet block)All the bat surveys should be completed, as prescribed in the FOA Ecology report, for the following remaining areas: Stables, Service Yard and Sports Building, pagoda/ticket shed and former WC block. These need to be provided seasonally / urgently Reason: The FOA Ecology Bat Report identified further bat surveys for a number of areas which have not been provided. Therefore, the bat surveys are incomplete. These omitted studies cannot be addressed by Conditions of a PP; and one cannot apply for a protected species licence ‘just in case’ there may be harm to the species.
  4. Inconsistency / Incompatibility of Illustrative Masterplan and Tree Removal PlanAll documents / drawings submitted should be reviewed to ensure that they provide unambiguous details of the proposal definition and are mutually compatible. This will include, for example, addressing the issue of consistency of the Illustrative Masterplan and Tree Removal Plan:-

i. The Site Wide Tree Removal Plan (581_PL_L10) shows only the understory yew and holly to be coppiced; with seven specifically identified trees. However, the Illustrative Masterplan (581_PL_L_01 C) shows amenity grassland paths running through the woodland [which would surely require more extensive permanent tree removal (rather than simply coppicing)]. This should be appropriately reflected in the Tree Removal Plan [i.e. creating these formal/direct path-lines will involve more than ‘Coppicing (e.g. the removal of a mature holm oak on the east side)].

ii. The Illustrative Management Plan (581_PL_L_01 C) also proposes the removal of mature trees that have been identified by the PEA as being high value trees, which is contradictory and those trees will be important trees for bats to use.

  1. West Grove: Tree Corridor ProtectionThe landscape scheme needs to be revised to address the importance of the wildlife corridor that is established along the area of the proposed West Grove.

    The proposal involves removal of a number of mature trees (the crack willows etc) along the West Grove that will potentially sever the tree corridor that the bats use to get to the river to feed which would be detrimental (e.g. tree cover provides protection from light/predators, insect feeding grounds). Severing the effectiveness of this wildlife corridor will potentially impact bats moving around the site and travelling to / from feeding sites.

  2. Ground Level Roost Assessment (Trees to be Felled)A report on a daytime ground level roost assessment, of all trees to be felled, should be submitted, as recommended in the FOA Bat Report.

4. Transport

A revised transport assessment is required, based on more accurate baseline details and which addresses the issues summarised below. This should inform the submission of a revised Transport Statement (TS).

a. Erroneous Baseline
There are basic deficiencies in the TS e.g.

  • Richmond Road (adjacent to Marble Hill Park) is not 20mph, as stated in the TS. It is a 30mph road.
  • There is no way to check that pedestrian visitors to the park have driven but parked on street with a residents permit.
  • Incomparable Base Cases of Primrose Hill and Greenwich Park-Greenwich Park sits adjacent to two CPZ’s one is operational Mon-Sat 9am-5pm and Sundays 9am-6pm and the other is operational Mon-Sun 9am-6.30pm. There are also many other destinations locally such as Maritime Museum, Royal Observatory, Naval College, Cutty Sark – that would generate joint trips rather than specific trips just for Greenwich Park. Also the university campus opposite would generate student visitors to the park due Coach Parking to its proximity. Visitors to this park would be well in excess to those that may attend Marble Hill Park.

Primrose Hill is also within a CPZ that operates 8.30am-6pm Mon- Fri. It has no parking availability in its own right, only the car park that is available opposite in Regent’s Park. Again, it could attract people from Regents Park for the protected views.

Additionally: The information for both Greenwich and Primrose Hill Parks is from 2008, so nearly 10 years old.

  •   There has been no submitted data used from these two parks.
  •   As Marble Hill House visitors are currently restricted to weekends, the TS needs to clearly explain how the projected visits proposed for week days (and weekends)

Coach parking in the location proposed would result in the loss of resident parking which would not be acceptable. Parking a coach within the area of the double yellow lines would also not be acceptable as it would be too close to the Montpellier Row junction and sightlines for exiting drivers from Montpellier Row would be compromised.

c. Proposed Café (140 Covers)

The TS has failed to demonstrate that the area retained for servicing of the proposed café is sufficient. Such details should include manoeuvring tracks for servicing vehicles.

d. Sports Pitches (Intensification of Use) Further clarification is required in respect of:

  • the impact of the intensification of use of the sports pitches.
  • in the calculation presented in the TS, it has only increased the figures forcurrent usage levels.

The revise TS will also need to demonstrate, with specific sports pitch usage:

  • The current and possible increased future use of the pitches, that users can be accommodated on site if driving and will not cause on street parking issues after CPZ operation times have finished (particularly in the summer months with longer daylight hours).

5. External Consultee Responses a. Sport England

This Holding Objection has been the subject of further productions from your agent, which are currently with SE for review.

d lamont (28.4.17)


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