Mill Hill Preservation Society
...making change worthwhile


Evidence put before the Inspector at the Examination in Pubic for the Mill Hill East Area Action Plan proposals winter 2007

These pages give the bullet points used by John Turtle in his presentation of evidence at the hearing - evidence prepared by John Living.

Mill Hill East Development – Session 1 – Density proposals

1. The site is SUBURBAN not URBAN – see AAP Doc. ‘Foreword’ by Cllr Melvin Cohen and many other locations.

2. The Grimley evidence claims that the site is defined as URBAN by reference to the London Plan clause 3.23 – whereas we feel it is best described as SUBURBAN from the same clause.

3. The Density levels put forward at the consultation in February 2007 were noted as too high by the participants – but these comments were not taken into account. This refers to LBB evidence point 3.14

4. The LBB evidence claims the average density required is 85 dwellings per hectare. The site is 48 hectares. To accommodate 2,660 units the average density needs to be only in the region of 55 dwellings per hectare.

5. The PTAL calculations appear to have been done as for a flat site and not one with significant hills. This would reduce the PTAL values.

6. The PTAL range is from 2 in the south to 1 in the north – see AAP pages 29 and 45. The evidence put by Grimley notes them as higher than this.

7. The lower PTAL values and the SUBURBAN setting when applied to the London Plan 2008 Table 3A.2 – give significantly lower density figures as shown in the MHPS submission.

Mill Hill East Development – Session 2 – Implications of the wider highway network properly provided for: Also paragraphs 5.18.14 in the AAP 2008 submission doc

1. MHPS feel strongly that no additional traffic should be diverted onto Partingdale Lane – a rural setting. (Not urban or suburban.)

2. Generally, if the provision of 2000+ units is the maximum the road network will take – (as explained in session 1) then the larger target of 3,500 units in the ‘extended site area’ will overload the network. As the 2000+ units will saturate the road network can we have an assurance today that there will be no other density increases in the surrounding area?

3. In respect of clause 5.18.14 - as the road proposals are shown in the AAP document and on the diagrams then MHPS believe that it is right for the proposals be considered now. However the proposals (such as they are) have been dealt with inadequately in the consultation process. This is the thrust of our formal submission. For instance it was never mentioned in the Stakeholders Consultation meeting in Feb 2007 nor in the first public consultation. It’s flawed.

4. A. F. Macdonald estimates that without an east-west cross route the mini roundabout at the end of Frith Lane will become clogged up and not work – it will still be under pressure even with a new cross route - hence the need to extend the cross route through Sanders Lane to relieve the traffic. MHPS believe that the option to have the cross route located further North on the site - so that it can link with Engel Park - has not been adequately explored.

5. Again the question of the way the PTAL figures have been worked out comes into question due to the gradients – and this feeds back to the Density issues discussed in session 1. If the traffic issues are so difficult to resolve then this clearly indicates the proposed site density is too high in this suburban setting.

Mill Hill East Development – Session 3 – Landscape and Wildlife assets appropriately protected etc

nb: Originally MHPS did not submit on wildlife and left it to others like the London Wildlife Trust. We concentrated on landscape and the allocation of open space (to be discussed in session 5).

1. MHPS feel that there is not sufficient provision for Wildlife corridors through the site: linking one green space to another green space on the site and to those round the site is not proposed.

3. Similarly MHPS would have preferred a scheme that linked green spaces together to give the maximum chance for established footpaths to continue through the site within green areas.

4. MHPS have surveyed the existing trees and compared their location with the proposed development. We note that the majority of the mature trees will have to be cut down to facilitate the density and location of construction that is proposed especially in the zones labelled Central Slopes and Southern Hub. In spite of what the AAP plan states about the retention of trees and hedgerows – the exact opposite is going to happen based on what is proposed.

5. A characteristic of our local landscaping is wide swathes of grass between buildings and alongside footpaths and roads - linking with other footpaths and larger open spaces – with a proliferation of trees and ancient hedgerows. This characteristic is not embodied in the proposed layout which talks of ‘Public Squares’ and ‘Boulevards’ which are not features of this suburb.

6. Phase 1 has already lost some ancient hedgerows and we fear that the remaining hedgerows round the site - in key locations - will be lost for ever. Already there is evidence that fine mature trees have been cut down for no apparent reason. This is not acceptable.

7. Loosing mature trees, hedgerows and so much open space goes back to density: the AAP shows a suburban area being turned it into an urban one – which we consider totally inappropriate.

Mill Hill East Development – Session 5 – Open Spaces

1. We have argued about the provision of open space being inadequate in relation to the UDP and the National Playing Fields Association standards (NPFA) – over 10 hectares required. The LBB is using other ‘non statutory’ criteria to measure the requirement. Even based on EDAW’s own model the requirement is 6.2 hectares and the scheme provides for 5.5. The site is overdeveloped to such an extent that public open space has had to suffer. Back to Density again.

2. The AAP argues that the surrounding green spaces contribute and so less needs to be provided. Examine those surrounding spaces:
The ‘Scouts’ land will be inaccessible to the normal public.
Finchley Golf Course is privately run.
Hendon Cemetery hardly a fun space.
Copthall is some distance away – as are such spaces as Arrandene etc.
The Green belt only really provides areas for walking. - and -
Bittacy Hill Park already caters for the open space needs of a considerable body of existing housing nearby. Once allocated to those houses can it be reallocated as open space for a new development?

3. Turn the tables on them: If this is to be an Urban Settlement it should be treated as such and given the required standards of open space as recommended by the UDP and the National Playing Fields Association. As far as open space goes they are pretending it is a suburban development where private gardens can ameliorate somewhat for the lack of public open space. The development will be so dense that there will be few private gardens - and no doubt they will be miniscule where they do occur. Back to Urban v. Suburban!

4. On a sarcastic note you might add that Panoramic Park will be so built up round it that there will be few ‘panoramic views’ to enjoy – unless you happen to be in the penthouse suite!

Mill Hill East Development – Session 6 – Heritage Assets – are they sufficiently protected?

1. The Mess is Locally Listed under UDP policies HC14 and HC15. (No good for Listed Building Approval due to UVPC windows.) Has attractive garden and lawns. The plan is to enhance its setting.

2. The uses proposed for the mess are important:
Original uses suggested as Community, Commercial, Residential or other appropriate use a possibility.

Now uses proposed as Community, Commercial, Part Residential or other suitable uses with the ground floor ideally having public access.
One suggestion for the Officers Mess is a Public House or Restaurant.

(Other uses I have heard are Community hall, Regimental or Local History Museum, or Hotel.)

3. MHPS feel that the selection of an appropriate use for the building is vital to its successful incorporation into the overall scheme.

4. The War Memorial is proposed to go to the Ridgeway opposite St Pauls Church. MHPS would welcome this.