We the undersigned residents of Haringey, petition Haringey Planners to refuse the application HGY/2020/1345 for prior approval for Change of Use of Morriss House to a Class DI Registered Nursey on the grounds of noise and traffic disruption.  Planners should instead require the applicant to make a full planning application, so that all the details of the proposal can be properly scrutinised at a time when all the necessary relevant data on noise and traffic disruption can be collected and evaluated.

We deplore the Applicant’s strategy to again try to exploit the current lockdown to slide through this prior approval application when residents have greater priorities than responding to this, the fourth application on Morriss House, and the second in just three months.

The Applicant’s Expert Study on existing noise levels in adjoining properties is deeply flawed in methodology – they have surveyed relatively high noise levels purporting to reflect those in neighbouring gardens by siting their monitoring equipment less than ten feet from the informal patio at the rear of their own Annexe building where the twenty house-bound tenants of Morriss House, (who are there illegally, given that Morriss House is not designated for residential use) regularly congregated for sunbathing, barbecues, socialising and singing during lockdown, in the hot sunny weather when the Applicant’s Sound Study was carried out. 

In simple terms, the Applicant has collected these relatively high noise levels from their own noisy residents partying in their own garden(!) and are attempting to attribute these to the adjoining properties to enable them to argue that a nursery would make little difference!  It is hard to believe such a gross flaw in methodology was anything other than intentional.

The owner of 21 Coolhurst Road consequently commissioned their own Expert Sound Study by Hann Tucker Associates which shows existing sound levels very substantially lower, despite this new Survey being carried out when the wind was on average 40% stronger than during the Applicant’s study.  Moreover, the Hann Tucker Report, unlike the Applicant’s Study, simultaneously collected data on the sources of the noise and found these to be very predominantly those of nature – (strong) wind in the trees and birdsong, with some local traffic noise.  This is in keeping with the Coolhurst Road Character Assessment which describes long, tranquil back gardens (and an extremely congested Coolhurst Road)

The Applicant claims the level of playground noise at the boundary of nurseries will typically be in the region of 70 decibels. This is 22Db higher than the existing 'real' noise levels in adjoining properties on Coolhurst Road and anything above a 10Db increase is classified as severe noise pollution.  Moreover, the nature of this playground noise will be entirely intrusive, in contrast to the existing sounds of birds and wind in the trees. In any case, this 70 decibel figure is just an estimate – it is not real data because it has not been collected from properties adjoining the very large N-Family Nurseries. 

Such data will be readily obtainable when these Nurseries are again operating normally.  Similarly, the Applicant claims, without any substantiation, there have been no complaints by neighbours about noise from existing N-Family nurseries, but, in the current lockdown, it is impossible to test this assertion.  By requiring a full planning application, it will be possible to test this claim by surveying the neighbours of properties immediately adjacent to N-Family Nurseries when these are again operating normally and making contact with those neighbours will again be possible.

The Applicant clearly implies that the other N-Family Nurseries are located in similar (deeply) residential locations, and that they have suffered no noise complaints from their residential neighbours.  A simple Google Earth survey shows the locations of the other N-Family Nurseries to be predominantly in commercial locations, or sited next to busy main roads, where the additional noise levels of a nursery would be far less intrusive.  Certainly none of the N-Family Nurseries appear to be sited in Conservation Areas, as would be the case with this application. 

Similarly the Applicant’s submission on potential traffic disruption, which suggests that only 8.7% of parents will use cars for pick-up and drop-off relies entirely on N-Family’s own ‘survey', the data and methodology for which is not provided  As N-Family are an interested party, this data must be discounted by planners until it can be validated by independent survey at such time when these Nurseries are again operating normally and proper survey data can be commissioned.  Coolhurst Road is a narrow street, heavily congested with parking both sides and is entirely unsuitable for any large-scale set-down and pick-up of children throughout the day.  This proposed Nursery is extremely large, catering for 138 children, and will be operating between 7am and 7:30pm for 51 weeks of the year.

We understand that the Manager of Bright Horizons Nursery on Crouch Hill volunteered the information that 66% of her children were delivered and picked up by car – more than 8 times the level claimed by this Applicant.

We remind planners that by simply relying on ‘expert’ data supplied by an applicant to approve a planning application, they risk their decision being overturned at judicial review if that expert data is shown to be flawed or biased.

In summary, we believe the only logical course of action is for Haringey to refuse prior approval and to require a full planning application be submitted at a time when the N-Family Nurseries are operating normally and genuine data on noise levels from their playgrounds, the opinions of their immediately adjacent neighbours and the levels of car use and traffic disruption can be collected and properly considered.

Requiring a full planning application will have the added benefit of allowing Haringey to examine all aspects of this proposal, including fire safety, before considering approval.  The Haringey Fire Commissioners have already stated they are not happy with the Annexe being used for residential purposes because of inaccessibility in the case of fire.  These risks are further magnified in the event of needing to evacuate 138 children, 40 of which are babies, with just 33 staff, from both the Annexe and from the main building, which will have children spread over three floors and only one staircase for means of escape.

It will also allow Haringey to scrutinise the proposed Nursery's plans for tree removal before granting approval.  Their other Nurseries are characterised by artificial playgrounds without trees, (as pictured).   The plans submitted in this pre-application show none of the many mature trees in the garden still in place, and the green space in general has been replaced by artificial surfaces, entirely inappropriate to the principles of a Conservation Area.  If they succeed in this pre-appplication the site will, de facto, have become a Nursery, and they will be able to justify large-scale tree removal and artificial surfaces on the grounds of safety for their children.