Wimbledon Park Residents Association have submitted a detailed objection to Merton Council in relation to the planned house building and football ground scheme submitted by GRA Acquisitions Ltd. The letter reads:

Please find enclosed the objection of the Wimbledon Park Residents Association to the
planning application of AFC/Galliard Homes number 14/P4361. The objections on flooding and
transport have been prepared with the advice of one the UK’s leading planning consultants,
Wimbledon Park Ward in Merton is the ward most affected by this development and as a result
we request a meeting with the planners of Merton to discuss our objection and come to a
common understanding of how National Planning Guidance applies to this application.
The objection consists of five documents whose titles we list below together with some of their
main points. However, to properly understand our objection, the accompanying documents to
this letter, which contain many important technical details, should be read.
1. Flood Risk
The development does not satisfy National Planning Guidelines on flooding as:
{1.1} The National Planning Guidelines were revised in March 2014 and they make it very clear
that residential housing is not permitted in a 3b flood plain regardless of whether it is developed
or undeveloped land. This change supersedes an important part of the DM F1 policy in
Merton’s Sites and Policies document.
{1.2} The developers have not put forward a permitted flood storage plan as basements are not
permitted in a 3b flood plain.
{1.3} Even if we assume that the site is a 3a flood zone, which it is not, the developers have
not shown that their plans pass the sequential test as they have not applied this test to the
residential housing which the most vulnerable element. They also have proposed no reason of
substance why the development should pass the exception test.
{1.4} The flooding calculations of the developers are confusing and not given in sufficient detail.
As a result they have failed to convincingly demonstrate that their flood storage mechanism
increases the flood storage capacity on the site. They have made no attempt to show that
flooding will not increase off the site.
{1.5} The plans do not appear to have the agreement, or the support, of the Environment
From the Chairman, Iain C Simpson
56 Home Park Road
Wimbledon SW19 7HN
Tel: 020 8947 1301 Mob: 07836 361 782
E-mail: iainsimpson@imi-consulting.com
2. Transport
We list below some of the inadequacies of the developer’s Transport Assessment and as a
result we consider that the traffic and pedestrian impact has been grossly understated and that
its conclusions are inaccurate.
{2.1} Contrary to TFL’s Guidance, the Transport Assessment relies on traffic survey data
collected from the 12 July to the 18 July 2012. This was the period just prior to the 2012
London Olympics when some school holidays had begun. Therefore the data cannot be
considered representative of normal traffic conditions and consequently the transport modelling
is invalid.
{2.2} The Transport Assessment and Environmental Statement assumes that all supporters
arriving and departing by public transport will travel directly to and from the stadium rather than
visit local bars and restaurants during peak shopping/leisure times. As a result, the Applicants
have not correctly assessed the potential impact of 20,000 additional football supporters on
Wimbledon, Earlsfield and Tooting centres or local residential streets.
{2.3} The Planning Application does not provide any car parking for football supporters within
the development. Instead, it relies on 5,544 spaces which they claim to have identified on
residential streets within walking distance of the stadium. The existence of so many free
parking spaces does not agree with the common experience of many local residents. We
believe that the effect of supporters travelling around in search of these spaces will lead to
considerable inconvenience for local residents and businesses and will breach Merton’s policy
{2.4} The Applicants have not undertaken any survey, or provided any existing data, to identify
the current normal passenger numbers on local public transport infrastructure or pavements
serving the proposed development. Without this data, the Applicants have not identified the full
impact of the proposed development and whether the infrastructure needs to be upgraded to
cope with this additional demand placed on it by 20,000 supporters and 1,491 new residents.
{2.5} The Environment Statement and Transport Assessment have ignored the impact of
implementing their proposed 30 minute road closures. They also do not appear to have
undertaken their Traffic Modelling using appropriate software that takes account of factors such
as queuing across multiple junctions and pedestrian flows. Instead, their modelling assesses
individual junctions on a standalone basis which is unrealistic and ignores TFL’s advice
obtained at the scoping stage.
3. Heritage
{3.1}The Wimbledon Greyhound Stadium has had a long history of racing in Wimbledon, which
along with lawn tennis, is a key element of Wimbledon’s renowned sporting heritage at local,
regional, national and international levels.
{3.2}In terms of cultural heritage, the end of Greyhound racing in Wimbledon and in Greater
London would be a considerable loss, both to Wimbledon and the capital.
From the Chairman, Iain C Simpson
56 Home Park Road
Wimbledon SW19 7HN
Tel: 020 8947 1301 Mob: 07836 361 782
E-mail: iainsimpson@imi-consulting.com
{3.3} Wimbledon FC played on a separate site west of the current greyhound stadium, where a
housing development now stands. The new club, AFC Wimbledon, has never played in Merton.
{3.4} Only a minority of AFC Wimbledon supporters live in the Merton with the substantial
majority of supporters travelling into the proposed Plough Lane Stadium by train or car from
outside. The homes of the supporters would appear to be equally well clustered around AFC
Wimbledon’s current home at Kingsmeadow.
4. Community
{4.1} While AFC Wimbledon do carry out some activities that benefit the community there is no
reason to suppose that these would cease if they remained at their current home.
{4.2} Although the Applicants agree that their development would lead to additional demand for
GPs and school places, they do not wish to make provision for either.
{4.3} As detailed above, the developers proposal to make extensive use of local residential
streets for parking will cause considerable inconvenience to local residents and businesses.
{4.4} The community benefits of the development were assessed in the application and were
found to be only of minor benefit, except for the provision of residential housing, which is
forbidden on a 3b flood plain.
5. Consultation
{5.1} The developers have carried out minimal consultation and we are not aware of any aspect
of their plans that have changed as a result of our objections.
{5.2} The questions asked by the consultants ‘Your Shout’ were largely irrelevant to the
proposed development. The developers have ignored the results of the only statistically valid
survey which was carried out by the Wimbledon Park Residents Association.