Stag brewery, mortlake brewery plan April 2018
Article

HAVE YOUR SAY BY 13th May!


Richmond Council has now validated the planning application submitted by Reselton Properties for the Stag Brewery site.  You can see information on the Council’s website here:

http://www2.richmond.gov.uk/PlanData2/Planning_MajorDevelopments.aspx


Update to this post:

If you didn’t send your comments in by the 13th May, you can still do so.  Your comments will be read but the case officer may not respond or include them in her case report. See Have Your say for where to send them.


Are you worried about the impact of these proposals on Mortlake and the surrounding area? If so, have your say!

Please note there are thee applications submitted, outline planning application for the whole site (A); one for the erection of a three storey school (B) and finally the application to widen Chalker’s Corner (C)

The MBCG will be submitting a detailed response to these planning applications.  But it is important that there are also as many individual responses as possible.

You can respond by directly commenting on the website or you can write to or email the Council directly. We urge you to also copy in your local ward councillors, The Leader of the Council and our local MP, Zac Goldsmith.

To help you put your response together, we have produced a short summary of our concerns drawn together by our expert local group of architects, planners, environmentalists and community activists.  We hope you find this information useful when submitting your own comments.

The council have listed all the issues you need to consider when making an objection to any planning application. http://www.richmond.gov.uk/services/planning/comment_on_a_planning_application/what_is_a_valid_objection_to_a_planning_application

 

Our Initial Assessment of the Planning Applications

The development of the brewery site is welcomed by the MBCG and while there are some positive aspects, based on our initial assessment of the plans, we are still very concerned about what is being proposed.

Design and Density

  • The cumulative density of the scheme is overbearing:
    • 817 residential units including potentially 150 care units, plus a nursing home for 80, plus 1200 pupil secondary school and 7,008 sq of office/retail uses;
    • Increase in residential units represents a 40% increase in population of Mortlake
    • The school and its all-weather pitch are too large for the plot;
    • The eastern half of the site is extremely dense in layout, creating issues of overshadowing and overlooking
    • The proposals still exceed the height constraints in the Council’s own Planning Brief for the site in 2011, the north-western area of the site exceeding the planning brief heights by between one to three levels and resulting in a material loss of light to adjacent residential properties;
    • The proposed minimum of landscaped open space falls below the Planning Brief
  • The proposals are more urban in character and design than the predominantly sub-urban nature of Mortlake

Click here for more information on Design and Density concerns.

Traffic and Transport

  • A substantial increase in residential cars (611), the school (15), commercial uses and visitors (77) to the site (total 703, all at basement level except for those at the school and at the 24 town houses) will further add congestion on an already very busy local network. It is not clear if there is a more strategic plan between the council, developer and Transport for London (TFL) to address the wider traffic concerns
  • There are safety issues and further congestion at Mortlake Level Crossings – there is no concrete plan to address this between the interested parties (Developer, Council, Network Rail)
  • The developer’s plans include major road works at Chalker’s Corner, aimed they claim, at improving traffic movements at peak hours. This is far from conclusive and may indeed simply attract further through traffic. However even more significantly it severely impacts the quality of life of Chertsey Court and adjacent residents (See Chertsey Court Section)
  • No evidence of an integrated public transport strategy or improvements to these services

Click here for more information on Traffic and Transport concerns.

Green Spaces

  • Mortlake, while in a green borough, has only a small amount of open green space of which the brewery’s playing fields represent 53%. The playing fields have protection under the classification of ‘Other Open Land of Townscape Importance’ (OOLTI).
  • Some OOLTI land is lost on both the Brewery site and at Chertsey Court and has not been adequately re-provided
  • Two grass playing fields are replaced by one artificial surface playing field with lights, reducing the areas available for sports use and are detrimental to the environment. An alternative would be use of “reinforced grass” which would allow greater play (than grass) and would not impact the environment to same degree and would not require flood lighting
  • Building on green assets, rather than wholly on the brownfield area of the site, runs contrary to the London Plan, draft London Plan, draft Local Plan, Adopted Development Master Plan, National Planning Policy Framework, Village Plan for Mortlake and the Planning Brief for the site
  • An area on the green playing fields has been “reserved” for a potential bus turn-around I the need arises in the future. If enacted upon, this would further reduce green space.

Click here for more information on Green concerns.

Chertsey Court

  • The proposals to change the junction at Chalker’s Corner will have a devastating impact on Chertsey Court residents:
    • Increased poor air quality and pollution due to increased traffic generation; it already exceeds EU pollution limits
    • Increased noise and disturbance
    • Loss of ‘Other Open Land of Townscape Importance’ (OOLTI) protected land contravenes planning policy
    • Loss of mature trees

Click here for more information on Chertsey Court concerns.

Health Facilities

  • With a substantial increase in residents, we would expect to see more primary NHS care facilities provided; there are none currently in Mortlake. Existing services will come under even more pressure to deliver.
  • The borough, Richmond Clinical Commissioning Group and the developer need to be encouraged to work together to deliver this.

Click here for more information on Health concerns.

school

  • The school site will provide a sub-optimal experience for pupils in that there is limited space to play and circulate. If a school is to be built on this site then it needs to have a smaller capacity. The proposed 6 form entry plus 6th form may be the most viable in terms of the range of curriculum offered but it poses a huge risk if the capacity is not filled
  • A school of half the size, i.e. 3-form entry, would be worth exploring
  • Alternatively some of the existing secondary schools in the area could be further expanded and the site could instead be used for a primary school, as originally indicated in the Planning Brief, and would be ideal for the new Thomson House School, currently located unsatisfactorily in two buildings, one of which is dangerously sited next to the Sheen Lane level crossing

affordable housing

  • The proposed housing is in two phases, vis. 443 units east of Ship Lane in Phase 1 and 224 units plus potentially 150 care units west of Ship Lane in Phase 2. The developer has indicated an affordable element of 20% but not until Phase 2.  This is not acceptable as there is the risk that it may never be provided
  • The GLA is likely to ask for 35%. The developer has indicated that this is not possible

Establishing a New Heart in Mortlake

  • While the design does provide a link between the river and Mortlake, there is an opportunity for further improvements:
    • The scheme does not sufficiently exploit the frontage to Mortlake High St
    • An all-weather pitch will be accompanied by flood lights which will have damaging impact on environment and noise for existing residents
    • The Ground Floor active uses are dispersed and would be better focused around the Green Link and Maltings Plaza.
    • There is some doubt about the viability of so much commercial space and impact on other retail outlets in Sheen
  • The composition of the residential elements is not known; there needs to be a good mix of tenure and sizes of units with a high social and affordable provision. Affordable housing is low, proposed as 20% of residential units.
  • No evidence of any over-arching sustainability strategy
  • The school site will provide a sub-optimal experience for pupils there is limited space to play and circulate. If a school is to be built on this site then it needs to have a smaller capacity.

Click here for more information on Mortlake Heart concerns.

Positive Components of the Planning Application

  • The scheme provides a mix of new homes and new employment opportunities
  • It does create the opportunity to establish a new village ‘heart’ for Mortlake around the Green Link and the Maltings Plaza
  • The scheme does generally open up the brewery land to Mortlake, linking the riverside and the High St.
  • The Green Link positively connects Mortlake Green with the Thames riverside and towpath.
  • The design retains the existing historic buildings – The Maltings and the Former Hotel/Bottling Building.
  • A much needed new community centre is included in the Maltings
  • The secondary school has been repositioned, partly on brownfield land, and the residential block is removed from the existing OOLTI playing fields
  • The layout is not ‘gated’ and incorporates a number of public spaces

Design and Density Concerns

  • The combined density of the scheme remains a major concern with 817 residential units (including potentially 150 care units), the 1200 pupil secondary school and 4,664 sq m. of commercial uses (retail, restaurants, cafes, cinema, offices etc.)
  • The brewery site represents about 15% (9 hectares), of the area of Mortlake. The proposals represent an increase of some 40% in residents and dwellings in Mortlake
  • The eastern half of the site is extremely dense in layout and character far exceeding the GLA’s existing London Plan guidelines on development density – units/hectare. The scheme illustrates around 211 units/hectare east of Ship Lane, whilst the existing average density for Mortlake is circa 70 units/hectare
  • Some of the spaces between blocks have been increased since earlier designs. However, the compressed layout, particularly in the eastern half of the site, where individual residential blocks are very close to one another, especially the higher blocks, creates issues of overlooking between dwellings, and significant shadowing of open spaces in the public realm. Any detrimental effect on existing properties, particularly in the north west of the site, will need to be further assessed
  • The proposals still exceed the height constraints in the Council’s Planning Brief for the site published in 2011, especially in the north west of the site where blocks are proposed from 3 up to 5 storeys. The Planning Brief envisaged only low-level buildings in this sensitive part of the site near existing residences and listed buildings. (The Brief included a primary school – single storey, and a mix of heights to 3 storeys maximum)
  • The north west of the site forms part of an Outline Planning Application only. Further detail is required to allow evaluation of design, scale, size and height aspects of the proposals
  • The Planning Brief also proposed a reduction in height at the perimeter of the site and along the riverside. Some of the blocks remain very high overlooking the river and potentially over-powering the historic Maltings building
  • There is a concern that some of the open courtyards, particularly those near the towpath and pedestrian routes, although intended to be public, may gradually become ‘privatised’ by residents – conditions should apply to prevent ‘privatisation’ and a gated environment
  • The Cinema Building appears very alien in nature and character compared to the other new and existing buildings
  • The composition of the residential elements – east and west – is still not known. The proposals should incorporate a good mix of tenure and sizes of units with a high social and affordable provision. Any such units should be sensitively incorporated into and across the phased development (east and west). We are strongly against a ‘rich ghetto’ and units for overseas investment.

Putting the Heart into Mortlake

  • The proposals are more urban in character and design than the predominantly sub-urban nature and grain of the immediate context in Mortlake, largely an existing 2/3 storey terraced residential street-pattern
  • The layout is very dense compared to the surrounding local context
  • The ‘Mansion Block’ and ‘Warehouse’ styles adopted in the design are more urban in character and examples are located generally in more central London areas
  • The 2011 Planning Brief included a ‘base level’ of landscaped open space of circa 28% of the site, (sports fields and the Green Link), with additional green open space and public realm envisaged between and adjacent the new buildings. The proposals provide less than the base 28%
  • Although the school is now re-located more satisfactorily, positioned in part on the site of existing large brewery buildings it is still very large and creates one, long, bulky form, out of character with Mortlake. The siting of the school still involves the loss of part of the protected OOLTI sports fields.
  • The school and its all-weather pitch are shoe-horned into the western half of the site with limited space for pupils’ recreation areas whilst the MUGA (all-weather Multi Use Games Area), is in use.
  • The MUGA is clearly capable of greater use than the existing grass pitches but this requires the pitch to be fenced and floodlit. This combined with the sheer scale of the school will increase nuisance and disturbance to existing residents in Williams Lane, Wadham Mews and Watney Road
  • An access ramp to basement car parking is still included in the scheme. This faces directly onto Mortlake High St. with a new sub-station immediately alongside the ramp. These adjacent features of the design are visually intrusive and do not comply with the spirit of the 2011 Planning Brief which encourages active uses of the High St
  • The Ground Floor active uses (cafes, restaurants, retail etc.) are dispersed around the site and would be best focused around the Green Link and Maltings Plaza to create a vibrant ‘heart’.
  • There is some doubt about the viability of so much commercial space including the cinema. Is the cinema viable with other offers in Barnes, Richmond, Putney and Kingston?
  • No evidence of adequate health facilities for the growth of the Mortlake community
  • Community Space is proposed in the lower levels of the Maltings but this is still very inflexible space and poor use of this unique building. The design appears driven more to suit access to the residential space above rather than create useful, flexible community space
  • No evidence as yet of any over-arching sustainability strategy which would be expected in any major regeneration development of this nature and scale

Traffic and Transport Concerns

The streets of Mortlake and Sheen area are notoriously and regularly gridlocked as they struggle vainly to take the traffic loads thrust on them by the two strategic routes – the orbital South Circular Road and the radial Great Chertsey Road. Combined with the very real constraints of the River Thames and the railway level crossings, congestion on our local roads is at a critical level with harmful impacts now affecting all road “users” including bus passengers, pedestrians and of course people living by them.

Public transport in the area is extremely weak compared with surrounding parts of London. There is no prospect of more trains ever stopping at Mortlake and now, even the 209 Route is under threat of a reduced service under the proposals to extend the 485 bus service.  Little mention is made of the 190 bus service from Richmond over Chiswick Bridge to Hammersmith and the opportunity of increasing its frequency.

The denser the development is on the brewery site the more total trips are generated in cars, vans, buses, trains on bikes and on foot. Logically then, the converse is that lower densities and a smaller school would generate fewer trips.

The obvious added congestion points are going to be Sheen Lane – particularly around the level crossing, Mortlake High Street and the Lower Richmond Road.  But to focus on increasing the capacity of the lower Richmond Road to and from Chalker’s Corner seems an expensive, damaging and pointless intervention.

The specific concerns are:


Substantial traffic increase from residential (too many parking spaces and other commercial uses).

  • There are too many parking spaces planned. The planning and highway officers have agreed in principle to a parking provision of 0.75 spaces/unit for 643 residential apartments (i.e. 479 spaces) and 1 space for each of the 24 townhouses units for sale/affordable homes, making 503 residential spaces in all. Add to this the 77 spaces for the 150 care units, the 31 spaces for the nursing home, the 15 for the school and the 77 non-residential spaces, the total comes to 703 parking spaces, of which 664 would be at basement level and 39 at ground level
  • 1,200 pupil school will generate a significant increase in traffic and movements at morning peak hours, particularly by public transport and bicycle
  • Commercial uses, visitors and deliveries will substantially add further traffic pressure onto the already congested Lower Richmond Road and Mortlake High Street.


Chalker’s Corner changes will not resolve the issue of increased traffic.

  • The developer’s plans include major road works at Chalker’s Corner, aimed they claim, at improving traffic movements at peak hours. This is far from conclusive and may indeed simply attract further through traffic.
  • However even more significantly it will involve moving the junction closer to residents in Chertsey Court and potentially increasing pollution and traffic noise and disturbance to all nearby local residents, whilst necessitating the removal of protected landscape space and mature trees.
  • There is no strategic approach to resolving traffic congestion in the area which needs to be a combined effort with TFL and the Council


There is no plan to address the issues at the Sheen Lane Crossing which is already operating at capacity.

  • Network Rail is likewise deeply concerned about the scale of the development and resultant traffic, increased pedestrian and cycle movements, and thus further pressures on the level crossing at Mortlake Station which is already at ‘High Risk’.
  • Our forecast of overall vehicle generation is, with justification in or view, higher than that revealed by the developer as is the proportion of total traffic likely to use Sheen Lane. The “headline” increases in demand above the 2017 measured flows around the level crossing between 8am and 9am are forecast as follows:
    • Pedestrians crossing the tracks at ground level and via the station footbridge – over 50% increase
    • Cyclists crossing the tracks at ground level and via the station footbridge – over 65% increase
    • Vehicles crossing the tracks – over 33% increase


The proposals alarmingly do not include any overall strategy for public transport

  • If approached more intelligently could support extension of the 22 bus service from Putney to Barnes and improvements and extension of both the 209 and 419 services and increased frequency of the 190 from Hammersmith

The cumulative scale and sheer density of the current proposals will lead to the traffic between Barnes and Richmond grinding to a halt and make life intolerable for the community living in Barnes, Mortlake and East Sheen.

Health Facility Concerns

The development will bring a 40% increase in local residents and one thing we should all expect to see are NHS GP and primary care facilities on the site.

It is positive to see that the plans include a Residential Care Home and a supported housing scheme.   However, the care provided in both will be largely private, will not include any NHS care and will be specifically for the people who live in these two places.    Furthermore, these particular residents will have higher than usual needs for NHS primary and community care.

  • WHERE ARE THE ADDITIONAL NHS SERVICES? Lack of any NHS facility could be a major concern; the developer recently suggested the minimal four clinical rooms  may be dropped owing to lack of interest from local GPs – this is not acceptable
  • EXISTING SERVICES BARELY COPING. Unless plans for additional services are made clear, current local residents will therefore have to wait even longer to get a GP appointment.
  • EXTRA JOURNEYS TO GP, to OUTPATIENTS AND HOSPITAL lack of any additional facilities will only add to journeys, many of which will be by car (or by ambulance for the residents of the care home and the supported housing).
  • NOT DOWN TO THE DEVELOPER ALONE the Richmond Clinical Commissioning Group has an important role to play but we should press the Council, through the planning process, to explain what the plans are for the much needed increase in NHS primary and community care services to match the needs of the additional population.

Chertsey Court Concerns

  • Poor Air Quality and pollution due to increased traffic generation. Chertsey Court is situated at Chalker’s Corner which has already been identified as an Air Quality Management Area and air quality monitoring in Chertsey Court grounds has shown levels of NO2 above legal limits. The developer’s plan to widen the road junction at Chalker’s Corner will increase traffic congestion, increase air pollution levels and directly affect the health and wellbeing of Chertsey Court residents.
  • Noise and disturbance. The increase in traffic along the Lower Richmond Road and at the Chalker’s Corner/A316 junction means that residents will be badly affected by increased noise and light levels as street lighting, vehicles, pedestrians and cyclists will all be brought closer to the flats day and night.
  • Loss of ‘Other Open Land of Townscape Importance’ (OOLTI) protected Land contravenes planning policy. Mortlake is relatively poor in green open spaces compared with other areas of the borough. The Council recognised this some years ago and gave the grounds at Chertsey Court the protection of OOLTI status. The developer’s plans to widen the junction by cutting through Chertsey Court’s gardens are therefore against the Council’s published policy.
  • Loss of Trees. Many mature trees within Chertsey Court’s grounds, along the adjacent verges of the A316 and the Lower Richmond Road will be lost to the junction widening scheme. These trees help reduce air-borne pollution and reduce some noise. They also provide a valuable foraging resource for bats and nesting site for birds as part of a wider, local green network. Chertsey Court residents also enjoy them for their beauty. The developer’s plan to replace them with semi-mature specimens is unacceptable as they become effective against pollution and noise.

Green Space Concerns

There is a wide body of planning law that seeks to protect exactly this type of space.  Some at high-level, and some very specific to the site, including (i) the 2011 planning brief for the site (APB); and (ii) the Council’s ‘Adopted Development Master Plan’ – and its proposed replacement Local Plan which is in the process of being adopted.  This latter covers the Council’s ‘Other Open Land of Townscape Importance’ (OOLTI) designations which have been afforded to the playing fields/sports ground at the south west of the site and some of the land at Chertsey Court.

The Sports Fields

  • In the Plans, the existing grass playing fields (containing two football pitches) are replaced by:
    • just one ‘full-size’ artificial pitch (known as ‘third generation Astroturf’, 3G);
    • a large part of the secondary school building (c. 30 to 40 per cent.) and private or restricted access grounds;
    • a hard ‘multi-use games area’;
    • a pocket park to the south – see further below;
    • as part of that park, at the south west corner of the fields, an area which the developer has, we understand, been asked by the Council to reserve for a bus turnaround (incorporating a three-bus stand); and
    • New trees around the perimeter;
    • There may also be the introduction of perimeter fencing around the fields, the 3G pitch (potentially to include netting) and the school;
  • The area available for playing community sports has accordingly been reduced by approximately 45 to 60 per cent.
  • If this land were properly safeguarded in line with the Council’s planning brief of 2011 requirements, two ‘youth-sized’ pitches could be retained, with an option for cricket in the summer – doubling the number of potential users at any one time.
  • Regarding the replacement of grass fields with, in part, a plastic 3G surface, the developer’s stated case is that this is a requirement of the Education Schools Funding Agency and Sport England for new schools, who wish to encourage maximum usage. However, as we have existing grass fields that would have to be destroyed to make way for a 3G pitch.
  • The ‘use case’ for 3G is also prefaced significantly on use outside of daylight hours. This will require extensive floodlighting. The potential impact of obtrusive light on local residents could be significant if not mitigated to the fullest extent possible.  Floodlighting can also be an eye-sore detracting from what is presently an open, natural space. The Council must therefore resist the introduction of floodlighting to this site. To the extent it was to be required, extensive mitigation measures must be imposed to reduce light spill upwards and beyond the perimeter of the fence to zero.
  • In practice, grass fields achieve much more than just amenity space on which the 3G use case is founded: they:
    • host numerous species of wildlife which also visit neighbouring ecosystems at the riverside, Mortlake Green and beyond.  These sports fields provide a vital link in this wider green chain.
    • act as a flood defence in a flood risk zone by virtue of their drainage properties;
    • provide a surface suitable for activities that cannot properly be carried out on a hard surface;
    • Represent a key part of the natural fabric that makes Mortlake, and Richmond Borough, special – indeed, it is one of the Borough’s defining characteristics.
    • In addition, these sports fields have never been built on.
  • Building on green assets, rather than wholly on the brownfield area of the site, runs contrary to the London Plan, draft London Plan, draft Local Plan, Adopted Development Master Plan, National Planning Policy Framework, Village Plan for Mortlake and the Planning Brief for the site.
  • The playing fields – including the sport-related buildings – also benefit from ‘OOLTI’ designation to provide protection from development. That protection is not absolute – OOLTI land can be developed upon in certain limited circumstances, where certain criteria are met. However, it is far from clear from the Plans how the developer will meet the criteria which allows development to occur, which are based around the ‘quantum, quality and openness’ of the land being removed which having to be re-provided on the site:
    • that the quantity of land – which should be in addition to what the developer would ordinarily need to provide in such a scheme – removed has not been adequately re-provided elsewhere on the site;
    • critically, that the quality of such land is deficient: as noted above, the new land does not support ecosystems and flood prevention in an equivalent manner, nor by being parcelled off does it allow two games of football or a game of cricket simultaneously to take place as is the case at present; and
    • That the openness – which must also be assessed by reference to the views afforded to neighbouring users – will be prejudiced by the introduction of new fences, netting and other barriers.
  • This is particularly the case in relation to the portion of the OOLTI land occupied by the school and ear-marked for a bus turn-around in case required at a later stage: re-provision will need to be addressed.
  • The Council should be strongly encouraged to examine this in detail to ensure we are not losing our valuable, OOLTI-protected assets. If the land is not to be properly re-provided, it must be protected.
  • The MBCG submitted an application on February 2017 to have the fields designated as Local Green Space (LGS), a higher classification of protection akin to Green Belt. We continue to await a formal response from the Council on this.  However, we understand from comments made during the Local Plan process that the Council intends to reject our LGS application.  This being on the basis that the land is earmarked for development. This is contradictory, given the planning application has only been validated, and that the Council’s specific existing planning brief for the site – expressly provides for the fields to be retained and enhanced

Chertsey Court

  • The Plans provide for a triangular area – including a number of mature trees – to be removed from Chertsey Court to accommodate the road junction works.
  • This land and these trees provide vital respite from the emissions of noxious gases known at times to exceed legal levels – an annual mean concentration of 57μgm-3. Indeed, we understand that Chalker’s Corner forms part of the Borough’s Air Quality Management Area and its related Air Quality Action Plan. Human health is at risk in the event this area and these trees are removed.
  • Furthermore, certain of the land at Chertsey Court is also designated ‘Other Open Land of Townscape Importance (OOLTI). The developer’s proposal to re-distribute any such land is presently unclear. The indication is that a pocket of land will be made available on the other side of the Lower Mortlake Road. Again, we would call on the Council to examine this in detail.  If the land is not to be properly re-provided, it must be protected.

Mortlake Green

  • It is unclear whether the Plans require any of the landscaping and mature trees at the northern perimeter of Mortlake Green to be removed to allow access to the new road crossings and/or ‘Green Link. The developer’s materials appear to indicate that planning permission is being sought for an area which includes a section of Mortlake Green opposite the proposed cinema and Green Link.
  • To the extent the proposal is for the trees and hedges at Mortlake Green, for the reasons stated in paragraph 8 (Sports Field) which apply equally here, this must be carefully examined.

Towpath

Under the Plans, the River Thames towpath will remain untouched and access to the river will be vastly improved. Concerns remain, however, that the proposed access routes from the site to the towpath might negatively impact the towpath and/or pose flood prevention risks.

Trees on remainder of site

Whilst many trees – including those the subject of tree preservation orders – are to be retained under the Plans, a significant number of trees and shrubs – mainly those falling within the part of the site not presently visible to the public, but also to the east and south east of the playing fields – will be removed to make way for construction of the school and new residential units. This should be resisted wherever feasible.

Conclusion

The protection and enhancement of Mortlake’s green and open spaces is of paramount importance to the community as a whole, and the planning framework supports this.  These objectives have not in our view been adequately achieved in the Plans, especially as regards the loss of the two grass playing fields which the Council previously indicated it would require to be retained and which are OOLTI. This will prejudice users (one pitch instead of two), neighbours (through floodlighting and traffic), and our ecosystems and may negatively impact flood water protection. It also fails to respect the natural beauty of Mortlake, and the introduction of fences and barriers will impair the current open aspect of the site.