Professional Critique of English Heritage’s current plans

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.

 

LB RICHMOND’s LIST OF REQUIRED OUTSTANDING PRODUCTIONS

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 8.1.4.2]. 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)

 

English Heritage’s Tree Removal Scheme

Below, is an unedited email from Kate Pitt, Audience Development Manager and Head of Landscape and Gardens, English Heritage, received 22nd September 2017.

‘There are 1837 trees in Marble Hill Park. We are proposing to remove 347, of which 326 come from the woodland quarters. The 347 tree removals equate to 18.9% of the tree stock. We will be planting 401 new trees, this is a 2.2% increase in the number of trees on site. It is estimated that after all the proposed tree removals and the proposed re-planting programme is completed, tree cover will extend by 0.5 ha to 42% of the site.

The tree survey exercise has focused on the proposed areas of park improvements and identified 66 (sixty six) individual specimen trees and 24 (twenty four) groups of trees. Within these groups, 234 (two hundred and thirty four) trees were considered worthy of note. The development works focus on three areas of the park; improving the existing café facilities within the stable block area; improving the play facilities adjacent to the stable block and reinstating the landscaping around Marble Hill House and down to the River Thames.

Improvements to the café facilities at the stable block will require the removal of 3 (three) trees, an additional group of 9 (nine)trees to the right of the café , and 1 (one) low grade tree to the south of the café  will be removed to improve the growing conditions for the remaining trees within the group.  Next to the house 3 (three) trees are proposed for removal and amongst the Western avenue towards the Thames a further 4 (four) trees are proposed for removal.

There are 609 trees within the four woodland quarters south of the house of these 326 are proposed for removal to reduce the significant overcrowding and enable the remaining and newly planted trees to grow under better light conditions and the generation of a ground flora which will improve biodiversity.

Improvements to the play area adjacent to the stable block do not require any trees to be removed as a direct result of the works. One poor quality tree (Sambucus nigra) will be removed due to its condition. The proposed play equipment is to be positioned to avoid tree protection zones.

The landscape reinstatement works to the four quarters around Marble Hill House and part of the grounds down towards the River Thames will require the management of these areas through the removal of a number of trees, the coppicing of trees, the retention of trees and the replanting of trees.

The south-east quadrant (Group 7) will require the removal of 88 (eighty eight) trees, the retention of 73 (seventy three) trees and the coppicing of 44 (forty four) trees.

The north-east quadrant (Group 8) will require the removal of 74 (seventy four) trees, the retention of 21 (twenty one) trees and the coppicing of 7 (seven) trees. (One tree has been removed since the original survey).

The north-west quadrant (Group 9) will require the removal of 86 (eighty six) trees, the retention of 55 (fifty five) trees and the coppicing of 15 (fifteen) trees. (One tree has been removed since the original survey and one was a duplicate tree).

The south-west quadrant (Group 10) will require the removal of 83 (eight three) trees, the retention of 32 (thirty two) trees and the coppicing of 31 (thirty one) trees.

Five trees are recommended for removal for reasons of sound arboricultural management regardless of any development proposals. Therefore the removal of these poor quality trees should not have a bearing on this development proposal.’

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Description: Description: cid:image005.png@01D33167.96225020

The Truth about Trees

Please find a breakdown of the tree removal scheme for Marble Hill Park from English Heritage’s Head of Landscape Gardens.

September 22nd 2017

Kate Pitt, Audience Development Manager, English Heritage says, ‘The map will be available soon on Richmond Planning Portal – I’m just trying to get clarity of when this will be.’

Head of Landscape Gardens for English Heritage:

‘There are 1837 trees in Marble Hill Park. We are proposing to remove 347, of which 326 come from the woodland quarters. The 347 tree removals equate to 18.9% of the tree stock.

Improvements to the café facilities at the stable block will require the removal of 3 (three) trees, an additional group of 9 (nine ) trees to the right of the café , and 1 (one) low grade tree to the south of the café  will be removed to improve the growing conditions for the remaining trees within the group.  Next to the house 3 (three) trees are proposed for removal and amongst the Western avenue towards the Thames a further 4 (four) trees are proposed for removal.

There are 609 trees within the four woodland quarters south of the house of these 326 are proposed for removal.

The south-east quadrant (Group 7) will require the removal of 88 (eighty eight) trees, the retention of 73 (seventy three) trees and the coppicing of 44 (forty four) trees.

The north-east quadrant (Group 8) will require the removal of 74 (seventy four) trees, the retention of 21 (twenty one) trees and the coppicing of 7 (seven) trees. (One tree has been removed since the original survey).

The north-west quadrant (Group 9) will require the removal of 86 (eighty six) trees, the retention of 55 (fifty five) trees and the coppicing of 15 (fifteen) trees. (One tree has been removed since the original survey and one was a duplicate tree).

The south-west quadrant (Group 10) will require the removal of 83 (eight three) trees, the retention of 32 (thirty two) trees and the coppicing of 31 (thirty one) trees.’

Our campaign acknowledges that English Heritage has a proposed replanting scheme for the 347 trees it plans to remove plus the 97 that will be coppiced. However, we are concerned that once the woodlands are removed our park’s wildlife will suffer. English Heritage hasn’t adequately acknowledged the importance the wooded areas for The Park’s badgers, song-thrush, stag beetles, bats (all protected species) and other wildlife.

Much of The Park’s wildlife relies heavily on the tree canopy for foraging and habitat and it serves an important job on the ground too by creating ideal conditions for insects, an important part of The Park’s food chain. We have not seen English Heritage’s replanting scheme and worry that small specimens and ornamental gardens will not adequately replace what is already there. The woodlands or copses play an instrumental part of our park’s biodiversity and once gone they’ll impossible to replace.

The story so far…

 

English Heritage has been awarded millions from the Heritage Lottery Fund for Marble Hill Revived. A project centred on renovating Marble Hill House, the construction of a large cafe, a new adventure playground, the updating of certain park facilities and newly landscaped gardens.

At first glance the plans sounds wonderful but scratch beneath the surface a little and certain elements seem at odds with our current semi-rural green space.

Not least plans to fell over 50 per cent of the woodland quadrants where certain species of The Park’s wildlife currently thrive. Of the 609 trees that make up the copses 326 will be felled and a further 97 coppiced, a method whereby trees are repeatedly cut down near ground level. Only 186 trees from within the quadrants will be left untouched.

The idea behind this is so that English Heritage would then have an area for its landscaped gardens and a home for the 200 person wedding marquee. It argues that the woodlands are bereft of wildlife and unimportant.

Our own expert from the Badger Trust found during his field visit obvious signs of badger activity within the woodlands and said the prolific badger setts had been there for perhaps 30 years yet when alerted to our findings English Heritage said it was unaware of the badgers until September this year and as a result is currently doing its own badger survey. It’s concerning that a protected species had gone unnoticed for so long especially after sustained scrub clearance over the last three years and archeological digs in the immediate locality.

Whilst the bat survey acknowledges that bats are active just one minute after sunset in The Park which indicates they live within The Park the report fails to establish roosts. As well as soprano and common pipistrelle bats, Nathusius’ pipistrelle, Nyctalus species (noctule or Leisler’s), probable Leisler’s and also a long-eared bat has been detected.

We know this area is of vital importance to bats thanks to The Thames Landscape Strategy and trees that make up the bats’ foraging lines are essential to their survival. And so the idea that the woodlands within The Park will be destroyed is of real concern.

 

 

 

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