Mount Clare planning appeal - core documents

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Application documents
Appellant’s appeal statement of case documents
Appellant’s further documents (provided 8 October 2025)
LPA’s appeal statement of case documents
Third party representations (including consultees)
Statements of common ground
Appellant’s proofs of evidence
LPA’s proofs of evidence
Policy documents
Authorities
Additional documents
Conditions and S106 agreement
Inquiry documents

Application documents

Item	Document
A1	Application for Planning Permission Form – 10 January 2025
A2	Application Covering Letter from NTA Planning – 10 January 2025
A3	Air Quality Assessment – December 2024
A4	Arboricultural Report – 29 October 2024
A5	BNG Calculations – published 20 March 2025
A6	Community Infrastructure Levy (CIL) - Form 1: CIL Additional Information – 6 December 2024
A7	Design and Access Statement – November 2024
A8	Ecological Report – December 2024
A9	Planning Statement – January 2025
A10	Transport Statement – December 2024
A11	Tree Schedule – published 11 January 2025
A12	Site Notice
A13	Existing Site Plan
A14	Proposed Site Plan
A15	Existing Site Location Plan
A16	Existing Floor Plan – Block A – Ground Floor Existing Floor Plan – Block A – First Floor Existing Floor Plan – Block B – Ground Floor Existing Floor Plan – Block B – First Floor Existing Floor Plan – Block C – Ground Floor Existing Floor Plan – Block C – First Floor Existing Floor Plan – Block D – Ground Floor Existing Floor Plan – Block D – First Floor Existing Floor Plan – Block E – Ground Floor Existing Floor Plan – Block E – First Floor
A17	Proposed Plan – Typical Ground Floor – Block A Proposed Plan – Typical Ground Floor – Block B Proposed Plan – Typical Ground Floor – Block C Proposed Plan – Typical Ground Floor – Block D Proposed Plan – Typical Ground Floor – Block E Proposed Plan – Typical First Floor – Block A Proposed Plan – Typical First Floor – Block B Proposed Plan – Typical First Floor – Block C Proposed Plan – Typical First Floor – Block D Proposed Plan – Typical First Floor – Block E
A18	Typical Ground Floor Block A-E Typical First Floor Block A-E
A19	Existing Floor Plan – Basement (Picasso House) Existing Floor Plan – Ground Floor (Picasso House) Existing Floor Plan – First Floor (Picasso House)
A20	Proposed Floor Plan – First Floor (Picasso House)
A21	Proposed Bungalow Ground Floor Plan
A22	Landscape Plan
A23	Proposed First Floor Site Plan
A24	Tree Constraints Plan
A25	AMENDED Proposed Floor Plan – Basement (Picasso House) AMENDED Proposed Floor Plan – Ground Floor (Picasso House)
A26	AMENDED Accommodation Summary Schedule

Appellant’s appeal statement of case documents

Item	Document
B1	Appeal Form – 25 August 2025
B2	Appeal Statement of Case – August 2025
B3	Appendices to Appeal Statement of Case: Correspondence with LBW Wandsworth Validation Letter dated 23 April 2025 (ref. 2025/0074) Email correspondence dated 8th August 2025 Email correspondence dated 20th August 2025 PINS Decision Notice 3358768 Alton Estate Deemed Permission (ref: 740/575/3) dated 13 August 1952 Legal Challenge ref AC-2025-LON-002743 Letter from Spring4 dated 22 July 2025 Letter of Representation – UoR dated 21 August 2025
B4	Proof of Evidence of David Gwyn Lewis – April 2025
B5	Application for an award of appeal costs – 22 August 2025
B6	Draft Statement of Common Ground
B7	List of all plans and drawings (stating drawing numbers) submitted but not previously seen by the LPA
B8	List of all plans, drawings and documents (stating drawing numbers) which did not form part of the original application
B9	List of all plans, drawings and documents (stating drawing numbers) submitted with the application to the LPA

Appellant’s further documents (provided 8 October 2025)

Item	Document
C1	Proposed Bungalow Elevations & Plan
C2	Proposed Bungalow Plan
C3	Proposed Bungalow Roof Plan
C4	Energy Statement – 3 October 2025

LPA’s appeal statement of case documents

Item	Document
D1	Statement of Case of the London Borough of Wandsworth
D2	Appendix A – Officer Report
D3	Appendix B – Schedule of Planning Conditions
D4	Appendix C – The Lawful Use of the Appeal Site

Third party representations (including consultees)

Item	Document
E1	Letter from London Parks & Gardens – 23 April 2025
E2	Objection to the proposal – Mr Stephen Lang – 25 April 2025
E3	Objection to the proposal – Ms Edyta S – published 11 June 2025
E4	Objection to the proposal – Miss Susan Marks – published 1 July 2025
E5	Further objection to the proposal – Miss Susan Marks – published 1 July 2025
E6	Objection to the proposal – Ms. Lila Palmer, Charcot House Residents Association – published 5 July 2025
E7	Objection to the proposal – Anne Kearns – 6 July 2025
E8	Objection to the proposal – Mr George Mills – published 7 July 2025
E9	Support for the proposal – Letter from the University of Roehampton – 21 August 2025
E10	Transport comments of Will Marshall, Principal Transport Planner, London Borough of Wandsworth – 10 October 2025
E11	Letter from The Gardens Trust – Undated
E12	Letter from The Gardens Trust – 15 October 2025
E13	Further objection to the proposal – Miss Susan Marks – 24 October 2025
E14	Objection to the proposal – MR J P – published 26 October 2025

Statements of common ground

Item	Document
F1	Statement of Common Ground – 27 October 2025
F2	Heritage Statement of Common Ground – 9 December 2025
F3	Baseline Use Statement of Common Ground – 23 January 2026

Appellant’s proofs of evidence

Item	Document
G1	Proof of Evidence – Mandip Sahota (Planning)
G2	Appendices to Proof of Evidence (Mandip Sahota): Draft outline management plan University of Roehampton letter dated 21 august 2025 Correspondence dated 16 October 2023 – extract from FOI WBC-FOI-05788 Correspondence between appellant and Mr Worth (2024) Meeting notes – 8 July 2024 Email correspondence 18 December 2025 Appellants (Feb 2024) pre-app advice submission extracts Cabinet paper – 14 July 2025 Floorplan – application 2025/0453 Redloft letter Correspondence with GLA – November 2025
G3	Proof of Evidence Anna Cooley (Temporary Accommodation Standards and Need)
G4	Proof of Evidence Daniel Curtin (Design)
G5	Proof of Evidence David Lewis (Transport)
G6	Proof of Evidence Charles Rose (Heritage)
G7	Witness Statement – Christopher Aquilina (Observed Use)
G8	Appendices to Witness Statement (Christopher Aquilina): Title Plan View - TGL47292 - Mount Clare Title Plan View - TGL160764 - Mount Clare House and Temple 2002.02.12 Lease - Mount Clare House 2003.06.17 Lease - Dining Block 2008.07.30 Surrender and Lease - Dining Block - Signed by Roehampton University 2008.07.30 Surrender and Lease - Mount Clare House - Signed by Roehampton University 2019.09.18 Underlease - CAB - Picasso House - Signed by Roehampton University

LPA’s proofs of evidence

Item	Document
H1	Planning Proof of Evidence - Nik Smith
H2	Housing Appendices to the Proof of Evidence (Nik Smith) Extract from 2004 Housing Act relating to HMO’s Homes for Londoners SPG 2017 BPS Report, December 2025 Marked-up typical floorplan showing measurements Note relating to consultation draft NPPF
H3	Housing Proof of Evidence – Dave Worth
H4	Appendices to the Proof of Evidence (Dave Worth) Homelessness advice - Shelter England PowerPoint presentation on temporary accommodation occupancy
H5	Heritage Proof of Evidence – Barry Sellers
H6	Appendices to the Proof of Evidence (Barry Sellers) Heritage at Risk Register – Temple in the grounds of Mount Clare Email from Gilly King, University of Roehampton – 2 July 2024 Official list entry- Landscaping to the Alton West Estate Conservation Area Consent Decision Notice- 18 April 2002 Urban Design Study prepared by Arup- December 2020 Scope of Works for the Temple prepared by Martin Ashley Architects- January 2022 Summary Proofs of Evidence]Historic England- conservation Principles, Policies and Guidance
H7	Baseline Use Proof of Evidence - Siri Thafvelin
H8	Appendices to the Proof of Evidence (Siri Thafvelin) Inspector’s Decision in the Certificate of Lawfulness Appeal – 11 July 2025 Appendix A to Proof of Evidence – Siri Thafvelin – 22 April 2025 Order of David Elvin KC sitting as a Deputy High Court Judge – 28 November 2025 Inspector’s Note of Certificate of Lawfulness Appeal Inquiry (with pagination added) Proof of Evidence – Siri Thafvelin – 22 April 2025
H9	Summary Proof of Evidence - Barry Sellers
H10	Summary Proof of Evidence - Dave Worth
H11	Summary Proof of Evidence - Nik Smith
H12	Summary Proof of Evidence - Siri Thafvelin

Policy documents

Item	Document
I1	National Policy Planning Framework
I2	London Plan 2021
I3	Wandsworth Local Plan 2023 to 2038
I4	Historic England – List descriptions of Heritage Assets
I5	Historic England – List descriptions of Registered Parks and Gardens
I6	Historic England – Setting of Heritage Assets
I7	Historic England – Heritage at Risk Register 2025
I8	Historic England – Designation and Managing a Conservation area
I9	Historic England – Conservation Area Appraisal, Designation and Management
I10	Historic England – Conservation Principles, Policies and Guidance
I11	Historic England – Managing Significance in Decision – Taking in the Historic Environment
I12	GLA – Planning Practice Note: Heritage Impact Assessments and the Setting of Heritage Assets
I13	Alton Conservation Area Appraisal
I14	Heritage Fund – Management and Maintenance Plan Good Practice Guidance
I15	Extract from Country Life Magazine 26 January 1935
I16	Setting the Standard – Standards and Guidance Note for StS Inspection Officers and Local Authorities – September 2022
I17	London Borough of Wandsworth Minimum Amenities Standards For Houses In Multiple Occupation
I18	Wandsworth Borough Council - Roehampton SPD 2015

Authorities

Item	Document
J1	F W Grabbitas v SSE and Newham LBC (1985)
J2	Mansell v Tonbridge and Malling Borough Council (2017)

Additional documents

Item	Document
K1	Start Letter – 22 September 2025 (Appellant) Start Letter – 22 September 2025 (LPA)
K2	Appeal Questionnaire – 29 September 2025
K3	CMC Agenda – Mount Clare Campus
K4	Inspector’s Pre-Conference Note – 4 November 2025
K5	Inspector’s Case Management Conference Summary – 11 November 2025
K6	LPA’s response to the Inspector’s Case Management Conference Summary – 17 November 2025
K7	S106 Agreement Heads of Terms – 17 November 2025
K8	REVISED Energy Statement – 19 November 2025
K9	Appellant’s Heritage Impact Assessment – November 2025
K10	Appellant’s Structural Report on Lodge/Bungalow – 26 November 2025
K11	Appellant’s correspondence to the Inspector (amended/amplifying plans for the Lodge and the clarification of room numbers) – 28 November 2025
K12	LPA’s Structural Report on Lodge/Bungalow – 2 December 2025
K13	LPA’s Submissions on Appellant’s Structural Report and Lawful Use – 5 December 2025
K14	LPA and Appellant Correspondence regarding Lawful Use – 26 November to 5 December 2025
K15	Appellant’s Submissions on the Lodge and Lawful Use – 9 December 2025
K16	LPA’s Further Submissions on the Lodge and Lawful Use – 10 December 2025
K17	Correspondence from the Inspector (description of development, plans, and baseline use) – 11 December 2025
K18	Draft Site Notice – 11 December 2025
K19	LPA’s Response to the Inspector (baseline use) –12 December 2025
K20	Appellant’s Response to the Inspector (baseline use) – 12 December 2025
K21	LPA Correspondence to the Inspector (lawful use, housing need, energy reason for refusal and affordable housing) - 16 December 2026
K22	Appellant’s Correspondence (revised application documents) – 22 December 2025
K23	Appellant’s Revised Landscape Plan – provided 22 December 2025
K24	Appellant’s Revised Planning Statement – provided 22 December 2025
K25	Appellant’s Revised Design and Access Statement – provided 22 December 2025
K26	Appellant’s Revised Accommodation Schedule – provided 22 December 2025
K27	Appellant’s Proposed Ground Floor Site Plan – provided 22 December 2025
K28	Appellant’s Proposed Bungalow Plan – provided 22 December 2025
K29	Correspondence from the Inspector (baseline position) – 22 December 2025
K30	Appellant’s Correspondence (further revised application documents) – 23 December 2025
K31	Appellant’s Revised Accommodation Schedule – provided 23 December 2025
K32	Appellant’s Revised Design and Access Statement – provided 23 December 2025
K33	Appellant’s Revised Planning Statement – provided 23 December 2025
K34	Inquiry Site Visit Route Map
K35	Appellant’s correspondence to the Inspector (baseline) – 12 January 2026
K36	Correspondence from the Inspector (examination of baseline) – 13 January 2026
K37	CIL Compliance Statement
K38	LPA’s correspondence to the Inspector (baseline and approach to evidence) – 14 January 2026
K39	Correspondence from the Inspector (suppling inquiry timetable, queries regarding baseline) – 15 January 2026
K40	DRAFT Inquiry Time Schedule A – 15 January 2026
K41	LPA’s Correspondence (baseline and Barry Sellers’ proof of evidence) – 15 January 2026
K42	Appellant’s Correspondence with the Inspector (baseline) – 15 January 2026
K43	Appellant’s Correspondence to the LPA (providing 8 January 2026 letter from Redloft) – 14 January 2026
K44	Letter from Redloft – 8 January 2026
K45	LPA’s response to 8 January 2026 letter from Redloft – 19 January 2026
K46	Wandsworth Borough Council – Tenancy and Rent Strategy – December 2022
K47	Appellant and LPA Correspondence (plan clarifications) – 16 January 2026
K48	Inspector’s Correspondence (inquiry timetable revision) – 16 January 2026
K49	Further Inspector Correspondence (issuing revised inquiry timetable)
K50	Draft Inquiry Time Schedule B – 16 January 2026
K51	LPA Correspondence (querying details of erection of fence) – 16 January 2026
K52	National Plan to End Homelessness (MHCLG) – December 2025
K53	Wandsworth Homelessness Health Needs Assessment 2023 (Public Health Wandsworth)
K54	Local Government Association – Local government out of area placements guidance – 23 January 2023
K55	Tooting scheme (ref. 2025/0453) floorplans
K56	Temporary accommodation – London Borough of Wandsworth website

Conditions and S106 agreement

Item	Document
L1	Draft without prejudice planning conditions – 2 December 2025
L2	Inspector’s comments on without prejudice planning conditions – 23 December 2025
L3	Draft Conditions – 19 January 2026 (to be agreed)
L4	S106 Agreement - 9 February 2026

Inquiry documents

Item	Document
M1	Appellant's Revised Floor Plans
M2	Appellant's Opening Submission
M3	Council's Opening Submission
M4	Third Party Statement - Councillor Matthew Tiller
M5	LPA's Note on Environmental Impacts
M6	GP Capacity with Screenshots
M7	NHS Letter to Council
M8	LPA's Comments on the Appellant's Unilateral Undertaking
M9	Third Party Statement - MP Fleur Anderson
M10	Appellant's closing submissions
M11	LPA's closing submissions

Up to Mount Clare planning appeal

Updated: 11/02/2026