MILL HILL EAST ACTION PLAN
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
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
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
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
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.