ondon borough of merton · 2 merton’s statement of consultation (sci) 2.1 merton’s statement of...

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1 Introduction 1.1 This document sets out how the London Borough of Merton complied with the consultation requirements of Merton’s Statement of

Community Involvement (2005) and the Regulations (The Town and Country Planning (Local Developments) (England) (Amended) Regulations 2012) by engaging, involving and consulting with local residents, local community groups/organisations, business, ethnic minority groups/organisations and local environmental groups/organisation.

1.2 Regulation 22 of the Town and Country Planning (Local Development) England) (Amended) Regulation 2012 requires local authorities to prepare a Statement of Consultation setting out:

i. Which bodies and persons the local planning authority were invited to make representations under Regulation ii. How those bodies and person were invited to make representations under either of those regulations iii. a summary of the main issues raised by the representations made iv. pursuant to either of those regulation, and v. how any representation made pursuant to either of those regulations have been taken into account

2 Merton’s Statement of Consultation (SCI) 2.1 Merton’s Statement of Community Involvement (SCI) was adopted in 2006 and describes how the community can be involved in the

preparation of planning development documents. The SCI is part of Merton’s Local Plan and sets out the council’s commitment to community involvement in planning. Its explains how Merton’s local community, residents groups/association/organisations, stakeholders, and other interested parties can be involved in development planning documents by informing the council what they think of a plan/strategy, provide additional information and suggest changes to the a plan/strategy.

2.2 Some of the engagement tools set out in the SCI has changed since its adoption in 2006. For example the council now has a Facebook and Twitter pages which is used as an additional method of alerting communities to new press releases on a range of topics including council’s consultations.

2.3 Furthermore the council no longer has a dedicated community engagement officer for planning matters. However in spite of not having a dedicated officer, all officers are now involved in plan making process actively take part in and conduct outreach engagements events with the local community, community groups and other interested parties. These changes are not considered to be significant changes to the principles of Merton’s SCI.

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2.4 This statement reports on the engagement methods used the shop front during 1st December 2016 and 27th January 2017 (this includes the 1 week extension) consultation, the feedback receive and council response following this feedback.

3 How we got here 3.1 During the last decade internet shopping has taken an increase market share in the UK, with online sale exceeding £116bn in 2015.

This has meant that many high street retailers are experiencing the implications of this shift in consumer buying practices.

3.2 We know from high street customers that the visual appearance of shops and the quality of the retail offer directly impact on their decision to shop local. The shop front is the identity of the shop irrespective of the line of trade it pursues. It is also the single most effective marketing tool for most high street business. A well ordered, tidy contextual and cared for appearance will almost always result in better business.

3.3 The guidance is designed to be a useful guide for shop owners, developers and building owners wanting to undertake work to shop front and signs. It also gives guidance for new built retail units.

4 How we consulted – consultation methods 4.1 During the consultation the council used different methods of public engagement to maximise public involvement and raise public

awareness of the consultation. A survey was conducted using Survey Monkey, the reason being it is a user friendly, recognisable and trusted consultation portal. As well as Survey Monkey other consultation methods used for this consultation were:

Postcard invites distributed across the borough for local community to take part in the consultation Paper copies and supporting documents e.g. Strategic Environmental Assessment screening statement made available in

Merton’s references libraries Posters and postcard invites displayed at Merton’s at libraries Dedicated webpage – with copies of the guidance and supporting documents Consultation details tweeted on Merton’s Twitter account and information on the council’s Facebook page by Merton’s

Communication team Formal written consultation letters and emails sent to local residents, businesses, residential groups/organisations,

environmental stake holders e.g. Historic England and other interested parties from Merton’s Local Plan consultation database

Targeted consultation letter to all businesses and shops in all Merton’s town centre and local centres

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Reminder emails and letters sent out –informing local communities there was still time to take part in the consultation.

5 Consultation responses 5.1 The following section gives a summary of the response received. All individual responses can be found on the council’s website at

www.merton.gov.uk/shopfrontspd . As mentioned earlier in this report a public consultation was carried out during December 2016 – January 2017, seeking views on the shop front guidance. A total of X was received, of which X were received via our online survey and X were on paper.

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Q1: Please provide us with any comments on Sections 8.1

I think future guidance is excellent Whilst the shop front is important, I think concentrating on the SERVICE provided to local shoppers is more important. Great news that Merton Council taking lots of effort. The guide is quite patronising and only offering a certain view of how shop fronts should be....victorian wood retro look shops. I have had a good look at the Draft Shop Front Guidance document visible on the Council's website. It makes interesting reading and is well produced, but is clearly aimed at shopkeepers rather than mere shop users like myself. Historic England welcomes the production of this well-illustrate and engaging document that should help support the management of local character in Merton’s town centres and assist shop and land owners make successful planning and listed building consent applications. It is difficult to understand who exactly this document is aimed at.

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Q2. Please provide us with any comments on Section 8.2

To achieve a pleasing effect to the town centre, some control needs to come from the top so the street looks attractive and coordinated. We are sick and tired of sheets of glass for 'fascias'. In WTC they are shattered one every two weeks. This is not just costly, it is dangerous and wasteful of resources. The installation of an awning (8.2.12) may require planning permission: or it may regarded as an advertisement (see PPG) and not require planning permission. 8.2.15 is wholly incorrect in law. A vast range of advertisements are either excepted from control or may be displayed with deemed consent. Document should include…a simple table showing where the applicant needs planning permission (and where not) listed building consent, advertisement consent, Building Regs approved within conservation areas and outside.

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Q3. Please provide us with any comments on the Planning Application Tool

I think future guidance is excellent but what is Merton doing to enforce the removal of illegal roller shutters which have been installed over the past fee years without planning approval. You need to share this with us!

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Q4. Have you tried using the Planning Application Tool? No

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Q5.If you have used the Planning Application Tool, please rate how useful the tool is from 1 not useful to 5 very useful

No responses

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Q6. Please provide us with any comments on shop front guidance for Wimbledon Town Centre I feel the shops in central Wimbledon such as on the bridge where Next is look attractive as they have been made to run smoothly into each other and look pleasing, modern and clean. Look across the road to the mess of little shops all with different style and that looks messy, run down and very seedy. Must fit within and enhance any Conservation Area or listed building nearby. Enforcement of badly maintained fascias must also happen.

Disappointing that there is zero mention of the parade of shops at North end of Haydons Road in section 8.3

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Q7. Please provide us with any comments on shop front guidance for Wimbledon Village Avoid shopping there, too pricey. The Village is the absolute heart of what is Brand Wimbledon. Each and every shop front must be attractive, clean and regularly painted. If not, the landlord or tenant must face enforcement action to rectify.

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Q8. Please provide us with any comments on shop front guidance for Arthur Road A bit tired, but generally a healthy, working high street. Shop fronts must enhance the road, not detract.

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Q9. Please provide us with any comments on shop front guidance for Colliers Wood Colliers wood shops have been ruined by poor planning and coordination between what should have been a well coordinated and lovely shopping area.

Definitely need lots of changes in Colliers Wood High street Some of the buildings looking very tired and could do with a facelift.

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Q10. Please provide us with any comments on shop front guidance for Mitcham Town Centre I like it the way it is at present.

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Q11. Please provide us with any comments on shop front guidance for North Mitcham Don't know much about this area

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Q12. Please provide us with any comments on shop front guidance for Morden Morden is a mess of little shops and feels very seedy. Disappointing that there is no mention of the characteristic art deco styles that could be a real design feature and selling point for Morden which could easily be marketed as Morden Village if a comprehensive smarten-up plan was undertaken.

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Q13. Please provide us with any comments on shop front guidance for Raynes Park Our general comment applies that Merton should be taking enforcement action against shutters without planning consent. A good set of shops which have improved over the years.

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Q14. Please provide us with any comments on shop front guidance for Motspur Park Don’t know it.

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Q15. Please provide us with any other comments on the Shop Front Guidance document It is very useful as a design tool but needs a proactive planning regime to make it effective. Planning Enforcement facility must be strengthened at Merton Council, or else all our high streets will continue to deteriorate. would like to see a grand plan for the North end of Haydons Road shopping parade that desperately needs regeneration we are astounded that a document which purports to give advice on advertisement displays does not even mention the Regulations or national planning policy and practice advice in the NPPF and PPG.

While this SPD chapter will go a long way to helping support good design in town centres the Council could consider, for example, allocating CIL revenues to public realm works including shopfront enhancement schemes.

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Q16. How would you describe yourself? Shop owner Building owner Merton Resident

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ID

number

Format

Company / Resident Group / Community Organisation

Description

Summarised Comment (Shop front content)

Merton Council response

SFSPD1 Letter British Sign and Graphics Association (BSGA)

Industry representative

- Concern about the shop front guide placing further considerations upon advertisements than already apply within The National Planning Policy Framework, Planning Practice Guidance and the Town and Country Planning (Control of Advertisements) (England) Regulations 2007 - Concern regarding the reference to advertisements and signs throughout guidance. - Guidance does not reference Regulations or national planning policy in the NPPF and PPG - Concern regarding the style and pitch in which the guide is written 'it reads more as advice from a style guru or retail expert' - Concern regarding the level of control the guidance exerts on shop display and advertising within buildings - Concerns regarding external shop signs which are deemed consent. - Concerns regarding control of colour, fonts, materials in relation to deemed consent. - Guidance has no detailed reference to general permissions granted by law. - Make reference to the DCLG advice booklet ' Outdoor Advertisements and

- The response raises some factual omissions and errors, which are addressed by the addition of a planning permission checklist added to 8.2 Design, Consent, Implement on page 45 and referenced at para. 8.2.15 thus: “Advertisement Consent The display of adverts is controlled by the Town & Country Planning (Control of Advertisements) Regulations 2007 (SI 783). The Department for Communities and Local Government (DCLG) has also published relevant guidance: Outdoor Advertisements & Signs: a guide for advertisers, June 2007. A range of advertising does not require consent and these documents should be referred to, to establish whether consent is needed. The table opposite gives further guidance on what type of work requires planning permission or advertisement consent. If you are still unsure please contact the Council or consult the detailed regulations.." The remainder of comments are largely subjective opinion based on an apparent misunderstanding of what the guide is and what it is

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ID

number

Format


Description



Signs - a Guide for Advertisers' - Concerns regarding the emphasis of the document, feels it should be redrafted. - Concerns regarding maintenance advice. - Removal of design and retail advice.

legitimate for a local authority to provide guidance on. In short, the response here is that the general design guidance in the SPD is guidance, not regulations, and it is aimed at encouraging shop owners to consider a range of design options in order to create good quality shop-fronts that enhance the appearance of the townscape and are good for business.

SFSPD2 Email Historic England Statutory Consultee

- Historic England welcomes the production of high quality document which should help to support preservation of local character in Merton's town centre. - Council could consider allocating CIL revenues to public realm works including shop front enhancement schemes. - Outlines concerns regarding Wimbledon town centre conservation areas and risks in relation to Crossrail 2 with regards to shopfront investment. Outlines grant offers that can be used to enhance shop fronts.

Noted

SFSPD3

Email N/A Merton Resident -Well produced document. - Document aimed at shopkeepers rather than shop users. - Felt online survey was not appropriate for shopper.

Noted

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ID

number

Format


Description



- Greater emphasis should be placed on house numbers.

SFSPD4 Letter The Wimbledon Society Residents Association

-Difficulty in understanding who document is aimed at. - Concerns that document is too long for target audience of shop owners and development control. - Concerns regarding emphasis of design assumptions, focuses on details rather than basic design principles, favours a 'traditional' approach. - Text should be reviewed to provide more clarity and practical usefulness. - Should include a basic checklist on single sheet of A4 to demonstrate basis design principles. On the reverse provide the basic advertisement design and illumination principles for listed buildings, conservation areas etc. - Provide simple table showing where the applicant needs planning permission (and where not), listed building consent, advertisement consent, Building Regs approval. Please refer to similar checklists produced by The Society.

-Expansion of introduction to clarify layout and identify clearly the target audience and status of the document. References to relevant planning documents and policies made. Text added to introduction below: “Who is the guide for The guide is aimed primarily at people who own their own shops and will be themselves responsible for its repair and economic success. As such the guidance covers a wide range of subject areas and is intended to aid owners find the most appropriate and cost effective way of keeping a good quality shopfront and successful business. Shop-fronts requiring specialist architectural work or shops owned by companies with multiple outlets are less likely to require some of the guidance, however much of it will remain relevant.

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Description



Status of guidance This guidance applies to all shop fronts not just those in the main centres in the borough. This guidance should be read in conjunction with Merton’s Borough Character study, Conservation Area Appraisals as well as planning policy documents. Planning permission is required to install and in some cases to alter a shopfront. However we recommend that this guidance should be used whether planning permission or relevant consents are or are not required. This will help to ensure that development is respectful of the surrounding area and of a high quality design. It is worth considering employing an architect to achieve the most attractive and effective shopfront. This Shopfront Design SPD takes account of current national and regional planning policies and guidance on town centres; as well as recognised design practices. This Shopfront Design SPD takes account of current national and

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Description



regional planning policies and guidance on town centres; as well as recognised design practices” - The document is aimed at shop-owners who own their own shop and may not be able to afford the expense of designers, architects etc. It therefore includes a range of guidance to help owners make the best of what they have, and to promote high streets, better business and local readers. A brief document is not considered useful to the target audience. However, the Introduction would benefit from sub-headings and an expansion of the paragraph stating who the guidance is for. Basic shop-front design principles are shown on p11. They set out the basic proportions and elements of a shop-front and can be applied to both traditional or contemporary designs. The sub-title 'typical Victorian shop front elements' on pg.11 is misleading and it is suggested it is replaced with "Key elements of a traditional shop-front”. These elements can

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also be applied, in whole or in part, to more contemporary styles and designs. The suggested planning permission checklist is a useful idea. An updated version of this has be added to 8.2 Design, Consent, Implement on page 45 and referenced at para. 8.2.15 thus:

"The table opposite gives further guidance on what type of work requires planning permission or advertisement consent. If you are still unsure please contact the Council or consult the detailed regulations."

SFSPD5 Survey monkey

PLACE Design & Planning Ltd Building Owner - Considers guidance to be excellent. - Concerns regarding enforcing the removal illegal roller shutter. - Need for effective planning regime to enforce. - Concern regarding the cost for small businesses of implementing guidance.

Noted


Not provided Not provided - Raised the issue of providing good customer service as a means to improve business. - Need to for control to achieve cohesive street design.

Noted

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- Some specific comments on the appearance of Merton Town Centres.


Not provided Not provided - Need for cohesive design of shopfronts to enhance parades / streetscape. - Concern regarding the use of glass as fascia material. - Not aware of planning application tool. - Need for enforcement to ensure shop fronts are well maintained. - Some specific comments regarding the appearance of shop fronts in town centres.

Noted


Not provided Shop Owner Pleased with the guidance and plans to improve Colliers Wood. Lots of change needed in Colliers Wood.

Noted


Not provided Shop Owner - Concerns regarding the emphasis the guide puts on Victorian shop fronts. - Concerns regarding the maintenance of shop fronts. - Guidance is too prescriptive. - Concerns regarding the poor examples of shop front conversions particularly in South Wimbledon. - Guidance is unrealistic and does not take into account small budgets.

Basic shop-front design principles are shown on p11. They set out the basic proportions and elements of a shop-front and can be applied to both traditional or contemporary designs. The sub-title 'typical Victorian shop front elements' on pg.11 is misleading and it is suggested it is replaced with "Key elements of a traditional shop-front. These elements can also be applied, in whole or in part, to more contemporary styles and designs. The document is aimed at shop-

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ID

number

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Description



owners who own their own shop and may not be able to afford the expense of designers, architects etc. It therefore includes a range of guidance to help owners make the best of what they have, and to promote high streets, better business and local readers. A brief document is not considered useful to the target audience. However, the Introduction would benefit from sub-headings and an expansion of the paragraph stating who the guidance is for. Conversion of shop fronts is largely due to prior approval. Addition of section 8.5 Conversions to residential which provides design guidance on the conversion of shop front to residential use.

SFSPD10 Survey

monkey Haydons Road North Community

Merton resident Specific comments regarding the appearance of Haydons Road and Morden town centre.

Noted


Merton resident Specific comments about the appearance of Colliers Wood town centre

Noted

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