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

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Pan Peninsula Leaseholders and Residents Association C/O Richard Horwood, Flat 4203, 3 Pan Peninsula Square, South Quay, London E14 9HR Email: Richard@Horwood.Org Page 1 of 7 Pan Peninsula Leaseholders and Residents Association c/o Richard Horwood, Flat 4203, 3 Pan Peninsula Square, South Quay, London 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 Isle of Dogs, 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, Wood Wharf, etc); are currently awaiting consent (e.g. Quay House, South Quay Plaza, 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 Millwall 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, Canary Wharf 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.
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