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Pan Peninsula Leaseholders and Residents Association c/o Richard Horwood, Flat 4203, 3 Square, South Quay, E14 9HR Email: [email protected]

Jerry Bell Applications (Team Leader) Development & Renewal, Town Planning London Borough of Tower Hamlets Town Hall Mulberry Place 5 Clove Crescent London E14 2BG Application Number: PA/14/01246

13th October 2014

Dear Jerry

2 Millharbour planning application

I am writing to you on behalf of the Pan Peninsula Leaseholders and Residents Association, of which I am Chairman. Pan Peninsula is the largest residential building in the , comprising some 760 privately owned flats and home to well over 1,000 residents. We are the largest single group of local home owners and residents who would be materially and directly affected by the proposed 2 Millharbour development. This letter is supplementary to, and should be read in conjunction with, our related letter of 30th June 2014. As such, we will not expressly repeat here the points made in our earlier letter, but those points are strongly reaffirmed. We note that the applicant’s own advisers refer to their changes to the proposed scheme as “minor”.1 We are not in the least opposed to further residential development on the Isle of Dogs. Indeed we strongly support it as long as it is in proportion to the infrastructure needed and available to sustain it, and does not detract from the quality of life for those of us already living here or the value of our homes. We hope this position is shared by everyone, and we urge you and the Committee to use it as the litmus test for any related recommendations and decisions. It is on this basis that we reiterate our objection to the 2 Millharbour application. We repeat our request that I be allowed to speak at the Strategic Planning Committee hearing at which this application is considered. Despite our having set out many important and carefully considered issues in our earlier letter and expressly asking you to pass it on with our details to Docklands Centre/Fidelity, we have heard absolutely nothing from them. We have not even been able to find in the many documents supplied to you any specific response to the major issues we raised.

1 TPP Transport Assessment Addendum, September 2014, p6. Page 2 of 7

This application must be considered in context A new Masterplan has been deemed critically necessary by the Council and other responsible public bodies to set an up-to-date policy context against which to assess proposed developments such as this one. The South Quay Masterplan has been in development for some time and is currently the subject of public consultation, with further detailed consultation due in just 2 months’ time, and adoption thereafter. It is common sense that planning for huge developments such as this one must be judged in the context of the carefully considered Masterplan for the area, rather than be allowed to pre-empt it. We can only draw the conclusion that Docklands Centre/Fidelity – and others with applications for large developments in the area – are eager to get their proposals approved before the Masterplan has been adopted, expecting it to restrict the density of developments across the whole area. Such a restriction will be necessary to avoid (i) overwhelming the surrounding infrastructure, and (ii) a first-come-first-served approach, which would condemn many other sites to wasteland status as the total acceptable density for the entire area is reached by a few enormous, but relatively small footprint, towers. Our view is clearly shared by the GLA and the Mayor of London. In a statement issued in on 3rd October, Sir Edward Lister, Deputy London Mayor for Planning, said: “South Quay is enjoying unprecedented interest from developers all of whom want to bring forward their own plans. While we want to see the comprehensive regeneration of the area, what we cannot allow is a situation where planning is granted on a first-come-first- served basis with no overall strategy, as this could eat up valuable space, have a negative impact on the public realm and potentially cause other schemes to collapse. “This Masterplan will allow us to take a coordinated approach so that this growth is managed in a sensible way with developers coordinating their proposals. It will allow us to maximise the area’s huge potential while ensuring that all development contributes directly to the sustainability of the area. The Mayor firmly believes that tall buildings play a valuable role in addressing some of our housing needs but it is essential that the right buildings are built in the right places. “By working with the council, the Mayor hopes that the Masterplan will be brought forward more speedily so that there is clarity for developers about what schemes are suitable. This will ensure that the key planning objectives for this key growth area can be met. “The Masterplan will also ensure that the social and physical infrastructure required to realise and support this unprecedented growth is delivered in a managed way.” The Committee is well aware of the many thousands of new homes in very dense developments that are already being built (e.g. Lincoln Plaza, Baltimore Tower, etc); have recently been approved (e.g. City Pride, , etc); are currently awaiting consent (e.g. Quay House, , Meridian Gate, etc); or are imminent (e.g. Millharbour Village, Westferry Printworks, etc). These examples are far from exhaustive. We therefore strongly urge the Committee to recognise that, regardless of other issues, it is essential only to consider the Docklands Centre/Fidelity proposal – and those from other developers with large scale proposals in the area – in the context of a new, up-to-date and carefully constructed framework for the area. For this reason alone, the Committee should reject this application. Moreover, we remind the Committee that The National Planning Practice Guidance (March 2014) provides that “local planning authorities should take into account…the cumulative impacts of multiple developments within a particular area…”. The Committee is therefore obliged to take account of the impact of all current and prospective developments when considering each one – especially such a large one as this. Page 3 of 7

Impact on the DLR While we will refrain from repeating all the points made in our earlier letter, we wish to emphasise and expand on our concerns about the likely, and indeed dangerous effect of the proposals on the DLR. Our view is confirmed by the Council’s own Highways Department, who have stated2: “Given the proximity of South Quay station to the development, it is expected that all of this additional demand will access the DLR from this station. This increase will place additional pressure on the already heavily congested northbound DLR platform at South Quay in the AM peak.” We note that the applicant agrees that “the proposed development DLR trips will originate and end at South Quay station”3. However, these worrying conclusions contrast with the applicant’s dismissive assertions that “the impact of the proposed development DLR trips would be low”,4 and that “the Proposed Development would have a negligible effect on local public transport”.5 Neither of these statements is credible, and we reiterate that the applicant’s transport consultant’s calculations are flawed, as set out in our letter of 30th June. Specifically, based on there now being 909 homes6 proposed in this development, 2.03 people per home on average in this area7, and 34% of the residents of the old Ward traveling to work using the tube or the DLR8 (and even discounting the fact that a much higher than average proportion of South Quay residents are of working age and in employment than the 34% average implies),9 that gives 627 extra morning rush hour DLR or tube passengers coming from just 2 Millharbour, mostly trying to get onto the DLR at the single central-London bound South Quay DLR station platform. That’s some 6x the number the applicant’s self-serving analysis suggests, and on which their dismissive statements rely.10 And even these large numbers of extra passengers would be added to by thousands more residential passengers if consent were given for the c. 2,500 new flats in the South Quay Plaza and Millharbour Village developments that are now being proposed by Berkeley Homes and Galliard within just a few metres of 2 Millharbour, and which are also adjacent to the South Quay DLR station; as well as the many more new flats already being built nearby such as at Lincoln Plaza; and others whose applications are pending or imminent, such as LBS’s Meridian Gate on Marsh Wall (just the other side of the South Quay DLR station) and Daejan’s proposals for 54 Marsh Wall (just west of the 2 Millharbour site); and numerous other nearby developments. As the applicant and the Highways Department will surely acknowledge (given their acceptance of the fact in relation to 2 Millharbour), the thousands of residents of all these new homes would also naturally prefer to use South Quay DLR station to go to work in central London, as it’s their nearest station too.

2 LBTH Highways Department in July 2014, reported in TPP’s response in August 2014, p3 3 TPP’s response to LBTH, August 2014, p4 4 TPP’s response to LBTH, August 2014, p4 5 BWB Environmental Statement Addendum, September 2014, para 105 6 8% (81) less than originally proposed. 7 LB Tower Hamlets Corporate Research Unit, Ward Profile, May 2014, page 5 8 6,520 of the 19,191 16-74 year-old residents of the old Millwall Ward - Transport Assessment by TPP for Docklands Centre, May 2014, Appendix I, page 105 9 80.8% are of working age (cf. 74.1% for the Borough); and 69.1% in employment (cf. 57.6% for the Borough) - LB Tower Hamlets Corporate Research Unit, Canary Wharf Ward Profile, May 2014, pages 3 and 8 10 108 outbound AM Peak DLR trips. TPP’s Transport Assessment Addendum, September 2014, p3 Page 4 of 7

Even were Heron Quays DLR station considered close enough to be an alternative for some of them (as casually asserted by the developers’ consultants), they would of course in practice avoid it as the trains would already be packed before reaching Heron Quays by the huge numbers of passengers getting on at South Quay or earlier. They would also be competing to get on trains in Canary Wharf with residents from the 3,600 new homes at the recently approved Wood Wharf development, as well as the thousands more from other residential developments in and around Canary Wharf. Added to all these new homes are Galliard’s Baltimore Tower now being built on Limeharbour, and proposals for thousands more homes at sites like LRP’s Westferry Printworks to the south of the site (around 800 new homes), the Telford Homes site at 7 Limeharbour (167 new homes), and the large ‘Asda’ site, all of whose commuting residents will pre-load the central London-bound trains at Crossharbour DLR station, leaving even less space on the trains at South Quay, let alone at Heron Quays. It is therefore self-evident that the DLR would not be able to absorb anything like the additional commuter traffic that would be generated if these proposals were approved. And it is not just a question of the trains becoming overloaded, as commuters struggling to get on the trains will increasingly pack the platforms. In case the Committee is unfamiliar with South Quay DLR station, the platforms are unmanned, exposed to the track, suspended at high level, and reached primarily via an escalator, from the bottom of which it is impossible to see how busy the platform is. People already on the platforms are therefore inevitably and inexorably pushed forwards as more commuters are constantly carried up the escalator. If the platform is already packed, those at the front will be pushed onto the tracks in a ghastly echo of the Hillsborough tragedy. It follows that, rather than adopting an unacceptable first-come-first-served approach, no more large developments should be approved unless and until substantial extra DLR capacity is identified and guaranteed. It also follows that, to avoid leaving large areas of the Isle of Dogs undeveloped and to promote effective community building, further housing should be spread much more widely and at much lower densities.

New pedestrian bridge The only practical route for South Quay and other Millwall residents to an alternative DLR station (or to the and ) is over the narrow pedestrian bridge over the dock which, as we explained in our earlier letter, is already operating beyond acceptable levels according to TfL. As the Council itself said in response to the applicant’s proposals:11 “A second South Dock crossing is critical to mitigate the impacts of the development… The applicant suggests in the TA that Crossrail is expected to reduce use of the DLR and Jubilee Line in the area. The pedestrian route from the site to these services includes the footbridge over South Dock. The Pedestrian Comfort Level (PCL) audit submitted as part of the South Quay Plaza application shows that based on existing flows, this bridge would need to be widened substantially to provide an acceptable PCL and that the congestion will worsen as a result of the additional trips generated by committed development in the area. “Delivery of a second South Dock footbridge would help relieve overcrowding on the existing footbridge by providing an alternative crossing and additional capacity. It would also alleviate the severe congestion at South Quay station by enabling redistribution of flows generated by the development (and other committed and likely development in the vicinity) to services at Heron Quays (DRL), Canary Wharf (LUL and Crossrail) and Poplar (DLR).”

11 TPP’s response to LBTH, August 2014, p3 Page 5 of 7

We have already explained why it is very unlikely that morning commuters would seek to get on the DLR at ‘downstream’ stations as the trains will already have been pre-packed; and we dispute that Poplar station is close enough to be a realistic alternative for most people (as is obvious from the map below). But those seeking to use the Jubilee Line or Crossrail will undoubtedly need a second bridge. We understand that the Canal & River Trust continues to resist allowing a second bridge to be built over the dock at South Quay, if at all. We stress that, were large developments such as 2 Millharbour to be approved close to and east or south of South Quay DLR station, it would be wholly inadequate to position a second bridge further to the west.

This is not only because of the much greater walking distance west to such a bridge, and then back east to the Canary Wharf Jubilee Line station and retail facilities, but also because the riverside walkway would become seriously congested with the City Pride and other planned developments to the west of South Quay also generating large numbers of ‘competing’ pedestrians in the morning rush hour converging on the same spot. If anything, a third bridge would be required. We understand that the issue of new bridges is already considered a critical part of the new South Quay Masterplan. Unless and until adequate new bridges are guaranteed, the Committee cannot safely approve major new residential developments dependent on them. This is another reason why the Committee must reject this precipitate application. Moreover in the case of the 2 Millharbour proposal, public safety and the interests of current and future local residents must take precedence over the narrow commercial interests of the Canal & River Trust and their aspirations for docking exceptionally large ships at South Quay. We suggest that, had the Canal & River Trust been seriously concerned about docking very large ships in the dock, they would not have acceded to Wood Wharf reclaiming a very large section of the Page 6 of 7

water in the dock, making it much harder for their desired large ships to manoeuvre or tie up on the north side of the dock. We therefore urge the Committee to take the view that a guaranteed new pedestrian bridge located at South Quay is an essential minimum requirement before being able to grant consent to any major new developments in the area including 2 Millharbour, regardless of any contrary arguments from the Canal & River Trust.

Serious road congestion We said in our earlier letter that further large developments such as 2 Millharbour would plainly have a serious adverse effect on Marsh Wall traffic, the only road on and off the Isle of Dogs via Westferry to the west and Preston’s Road to the east. We note that the Council’s Highways Department shares this view, in stark contrast to the casual assertions made by Docklands Centre/Fidelity. Specifically, the Highways Department’s response to the 2 Millharbour proposals states:12 “The majority of vehicle trips generated by the development would be expected to use one of the two highway access points to the Isle of Dogs (Westferry and Preston’s Road roundabout). Both of these junctions currently experience peak time congestion and this is forecasted to worsen as a result of the high level of development on the Island. The level of parking proposed would generate vehicle trips that will undoubtedly compound the stress at these already congested junctions. “Furthermore, there is an inconsistent approach between the applicant’s argument for the proposed development density and on-site car parking. The proposed density considerably exceeds the upper limit of the London Plan density matrix for a ‘central’ site with a high PTAL13 rating.” The Highways Department’s point about current peak time congestion on Marsh Wall is illustrated by this photograph taken in June this year of virtually stationary evening peak time traffic on Marsh Wall at South Quay, queuing across the entire width of the Isle of Dogs between Westferry in the west and Preston’s Road in the east.

12 TPP’s response to LBTH, August 2014, p1 13 Public Transport Accessibility Level Page 7 of 7

In keeping with their dismissive attitude to this issue, the applicant replied to the Highways Department’s serious concerns as follows: “In respect of the Council’s comment about the traffic impact of the proposed development, the net impact from the additional 55 and 42 vehicle movements in the AM and PM peak hours would be negligible once disbursed from the site access on the local highway network in the eastbound and westbound direction.”14 They also casually assert that “additional car trips can be accommodated on the local highway network”.15 Either the Highways Department is right, or the applicant is. They cannot both be. We are also concerned that the additional road traffic generated by the proposed development – not just residents’ own cars, but also their visitors, taxis and deliveries, as well as the vehicles serving and visiting the proposed retail, social and commercial aspects of the site – will cause additional congestion on the roads surrounding 2 Millharbour and at their junctions with Marsh Wall. Moreover we agree with the Highways Department’s concerns about vehicles queuing up to access the site and, as a result, causing congestion on the surrounding roads and blocking access to other properties including Pan Peninsula.16 Road traffic congestion, particularly when considered in the context of the many other large scale developments currently being proposed, is therefore another reason to reject this application.

Conclusion As we have said, we strongly support proportionate development of the Isle of Dogs. But it is clear that the numerous huge residential towers that are now being proposed are neither desirable nor sustainable. It is also clear that it would be wrong to approve some extremely dense developments on a first- come-first-served basis, as that would inevitably blight the rest of the island as its capacity to absorb new residential developments is rapidly reached. Far better would be to spread desperately needed family homes across the whole area, enhancing the community and diluting the load on the already overstretched South Quay infrastructure, rather than approving another 909 small and densely-packed high rise flats at South Quay itself. At the very least, no new large developments should be approved until a sustainable and up-to-date Masterplan has been adopted for the area, and the attempts by some developers to pre-empt this should be rejected. Please share this letter with all interested parties. Yours sincerely

Richard Horwood For and on behalf of the Pan Peninsula Leaseholders and Residents Association

14 TPP’s response to LBTH, August 2014, p2 15 BWB Environmental Statement Addendum, September 2014, para 106 16 TPP’s response to LBTH, August 2014, p2