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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/14/00944 5th June 2014

Dear Jerry planning application by Berkeley Homes I am writing to you on behalf of the Committee of the Pan Peninsula Leaseholders and Residents Association, of which I am Chairman. Pan Peninsula is by far the largest and most prestigious residential building in the : indeed one of the top residential buildings in Europe. Completed less than 5 years ago, it comprises some 760 privately owned flats held on 999 year leases in two connected towers, and is home to well over 1,000 residents. We are self-evidently the largest single group of local home owners and residents who would be materially and directly affected by the proposed South Quay Plaza development. In this letter I set out our objections to the South Quay Plaza application, and explain why. In case the Planning Committee is minded to grant consent despite our objections, I also set out conditions which we urge the Committee to attach to such consent or obtain guarantees in lieu, and again explain why. We are happy to provide supporting evidence should this be practicable and helpful. 1. Objection to the entire proposal We urge the Committee to reject the application outright for the following reasons: a. New Master Plan The Council is in the process of establishing a new Master Plan for the area. Although we appreciate that applications have to be processed during a new Master Plan’s development, such a major new development that would so radically impact the area should not be permitted until the new Master Plan has been finalised and adopted which, we understand, is expected by the end of this year. Otherwise the whole point of consulting on and establishing the new Master Plan could be pre-empted and undermined. Berkeley Homes were well aware of the new Master Plan process when they submitted their application, so they cannot blame anyone else for their having jumped the gun. We are only talking about a 6 month delay, after all. Page 2 of 11

b. Planning consistency The Pan Peninsula flats were sold to us at a significant premium, reflecting in particular the commanding views from the Pan Peninsula building, and in reliance on the Council’s published policy for the entire area which provided for buildings progressively stepping down in height from One . Specifically, the Council’s Core Strategy Development Plan 2025 vision for (which includes the relevant area), adopted as recently as September 2010, states: “Taller buildings in the north should step down to the south and west to create an area of transition from the higher-rise commercial area of and the low-rise predominantly residential area in the south.”1 The South Quay Plaza proposal for a building of about the same height as and considerably higher than all the buildings between them, flies in the face of that policy. If and insofar as this policy has been changed since most of us bought our flats, this will already have resulted in planning blight for all of us. If and when consent is given for huge new towers close to and overshadowing our building – bearing in mind that the South Quay Plaza proposal is just one of a number that would, if granted, surround us – the resultant reduction in value and enjoyment of our homes would patently be even greater. And that is before taking account of our reduced amenities from the extreme additional strain on already overstretched local infrastructure by not only the proposed South Quay Plaza development, but also the thousands of other homes in additional huge towers that are currently being proposed in our immediate vicinity. These other new towers include – but are by no means limited to – the 990 new homes in 7 towers of up to 50 storeys for which planning has just been applied at 2 Millharbour only about 20 metres to our west; and similar height towers with 1,500 new homes that Galliard is about to apply for, approximately the same distance to our west and south. Together with the South Quay Plaza proposal, these buildings alone would add approximately 3,500 new homes, closely surrounding and overshadowing us on three sides. Regardless of any specific rights we may have regarding planning blight, we are entitled to expect a consistent approach by the Council to such a major policy area that is, by its very nature, expressly intended to provide long term guidance and security in order to encourage investment, not least by individuals in their own homes. Allowing the South Quay Plaza application would be in direct contravention of the planning policy that was in place when most of us made our substantial personal investments in our flats, and chose to make our homes here. We did not therefore just assume there would be no massive new buildings surrounding us: the Council expressly stipulated that there would be none. The Committee should therefore reject such a huge contradiction to the Council’s policy statements in the interests of consistency and good government. c. Blocking light and overshadowing neighbouring buildings Although a major part of our reason for choosing to live in Pan Peninsula is our spectacular view of Canary Wharf, more concerning is the overshadowing of our building that the proposed development would create, blocking our light. There is absolutely no need for a tower as big as 73-storeys or anything like that. It should be proportionate in height to the buildings currently surrounding it, so as not to overshadow them and block their light. The proposal to build 947 new flats in one building is an attempt by Berkeley Homes to maximise the value of their site regardless of the adverse consequences on the local infrastructure and neighbouring buildings and residents.

1 LDF Tower Hamlets, Core Strategy Development Plan Document 2025, adopted September 2010, page 123 Page 3 of 11

While the taller 73-storey tower would patently block light and cast a shadow over the whole of Pan Peninsula and the surrounding area, the even closer 36-storey tower – fronting onto Marsh Wall and just a few metres away from our building – would substantially block light to most of the north facing flats in the Pan Peninsula East Tower, and all the north and east facing flats in our shorter . Well over a hundred of our flats would have their light blocked in this way. We therefore urge the Committee to reject the application. d. Privacy We understand the Council’s rule of thumb is that a minimum of 18 metres is required between large residential buildings. We cannot tell precisely from the submitted plans, but the proposed South Quay Plaza development could well come within that distance from Pan Peninsula. Even if a little more than 18 metres away – and we understand that the 18 metres figure is no more than a guide – it would still be very close, especially to our West Tower. As a result, the new building will have residential units looking straight into, and overlooked by, our north and north-east facing residential units, and at very close quarters. While it may be of modest concern to the developers, this surely cannot be acceptable either to ourselves or to the residents of the proposed new building. The plan to build so close to an existing large residential building is misconceived. We appreciate that Berkeley Homes have sought to reduce the effect of this by proposing to construct at a 45⁰ angle to Marsh Wall, and this is appreciated. However, while this helps to some extent our north facing East Tower flats, it in fact aims the new building directly at our north-east facing West Tower flats. Moreover, Berkeley Homes’ good intentions from building at a 45⁰ angle are largely undermined by their also proposing that the south facing corner windows of all the apartments are not only (i) floor to ceiling with no obstruction to looking straight into the Pan Peninsula flats, but also (ii) able to slide completely aside to allow the south facing corner of every flat to be an open balcony (so-called “amenity space”) staring straight into the Pan Peninsula bedrooms, bathrooms and living rooms. While the South Quay Plaza residents could choose only to open their south facing windows and balconies when suitably dressed etc, that option would not apply to the overlooked north and north-east facing Pan Peninsula residents. This invasion of our privacy would be a gross intrusion, and the application should be rejected for this reason. e. Impact on the environment The current use of the South Quay Plaza site is as a relatively modest 10-storey office building with a single storey retail mall in front of it. Changing the site into primarily an enormous residential building containing 947 flats fundamentally changes its character in terms of both privacy and the use of nearby infrastructure and services. i. As regards privacy, offices are generally used during the day and empty at night, and residential units are generally the reverse. It follows that there is far less intrusion into flat residents’ privacy from an office building across the road, even if it looks straight into the flats’ windows: and vice versa. If only for this reason, we urge the Committee to reject this application. ii. As regards the impact on services and infrastructure in the area, Berkeley Homes appear to have seriously understated the impact of creating 947 new flats where there were none before. We note they claim that some of the commercial jobs lost from the current office building would move to Harbour Page 4 of 11

Exchange just a few yards away, that others would move to the to-be- refurbished block on the adjacent site (SQP3), and that other retail and service jobs would be added2, so there could presumably also be a net increase in commercial workers in the area, as well as the many new residents in the 947 new flats. iii. Changing from a 10-storey office block into a 73-storey block of flats would plainly have a major impact on the transport infrastructure. We are not experts in transport planning, but Berkeley Homes’ assertion that “an assessment of the development proposals on the local DLR network shows that the effect of the development proposals would be insignificant”3 is incredible. In our view, the impact would plainly be severe, and paragraph 32 of the National Planning Policy Framework (March 2012) states that development should be “prevented or refused on transport grounds where the residual cumulative impacts of development are severe.” iv. Specifically, Berkeley Homes claim (in relation to the DLR) that there would only be “approximately six additional passengers per train for outbound trips during the AM peak hour, and three additional passengers per train for net inbound trips during the PM peak hour.” We find their use of the word “net” for one their figures and not the other confusing, and we wonder at their focus on only outbound trips in the morning and inbound trips in the evening. Be that as it may, this not only appears to be obfuscatory, but also conflicts with what Berkeley Homes’ transport consultant said publicly at their community consultation on 3rd February 2014 (which you chaired), which was that there would be up to 15 additional passengers per DLR train in the peak hours. Since there is a train approximately every 3 minutes in each direction during peak hours, that amounts to 40 trains x 15 extra passengers = 600 extra passengers per peak hour on the DLR, all getting on (or off in the evening) at South Quay DLR station. That is plainly not an “insignificant” effect on the DLR. And even Berkeley Homes’ newly reduced assertion of 6 extra outbound passengers per train in the morning peak hour leads to 240 extra passengers on the platform in that one hour. Also hardly “insignificant”. v. Moreover, the vast majority of those extra passengers will plainly be residential commuters leaving South Quay to work in London in the morning, and coming home from London to South Quay in the evening. In other words, those 600 extra people each rush hour will mostly be on one platform, trying to get on or off the 20 trains going their way. And as people don’t act ‘on average’, there are bound to be surges of perhaps hundreds of extra people at the same time cramming onto one of the raised and open South Quay DLR platforms, over and above those already packing the platforms in the rush hours today. vi. This would be exacerbated by thousands more additional and mainly residential passengers if consent were given for the approximately 2,500 new flats in the other large residential developments immediately adjacent to us that are now being proposed , as well as the many more already being built nearby – something that the new Master Plan would be bound to address. 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…”

2 Berkeley Homes ‘Proposal’ document, submitted 23rd April 2014, section 5.1 3 Transport Assessment by WSP for Berkeley Homes, submitted 8th May 2014, section 18.1.3 Page 5 of 11

vii. This would clearly be dangerous, as well as overwhelming the DLR. Just increasing the frequency or length of the DLR trains – if possible – would not reduce the dangerous overloading on the South Quay DLR platform. The issue would be reduced were South Quay Plaza to remain a commercial site, even if replaced by a larger new office block, as then the extra commuters would at least be traveling against the already fast-growing residential tide. viii. TfL are now consulting on increasing the Northern Line capacity at Bank station, which will include passenger access and egress improvements to and from the existing DLR platforms, but apparently no other enhancements to the DLR.4 While this might allow for more frequent DLR trains – although increasing the frequency to an average of more than every 3 minutes in rush hours seems extremely ambitious given the complex architecture of the DLR and its imperfect signalling system, even if this does become part of TfL’s plans in the future – we note that TfL themselves do not expect a decision on the Bank station enhancements until 2016. They say: “To gain permission for compulsory purchase of land and buildings, to undertake construction work and to operate the new section of railway, TfL must apply to the Secretary of State for a Transport and Works Act Order. We plan to make our submission in Summer 2014. There may then be a public inquiry. If the Order is granted this is likely to be in early 2016.”5 Since TfL’s plan will involve major compulsory purchases and building development in a historically significant part of the Capital, there surely will be a public enquiry, and in any event there cannot now be certainty even of their currently proposed improvements for access and egress to and from the DLR platforms, let alone any other enhancements to the DLR. For this reason alone, it would be reckless to approve the building of yet another 947 new flats (particularly in the context of another 2,500 within just a few metres) that would be bound to dangerously overload the South Quay DLR station to which they would be adjacent, before the decision is made on the critical improvements to the Bank station DLR terminus in 2016. ix. We note that Berkeley Homes assert that Heron Quays and Canary Wharf DLR stations are alternatives to the South Quay DLR station, and their calculations regarding the extra loading at South Quay DLR appear to depend on this assertion.6 This is not correct. Unlike Berkeley Homes’ theoretical approach, as residents living adjacent to the South Quay DLR station (as the South Quay Plaza residents would be) we can assure the Committee that the other two stations are not practical alternatives for busy commuters (especially in inclement weather, and bearing in mind that the sole pedestrian bridge over South Dock to Heron Quays and Canary Wharf is already overloaded for residential pedestrian traffic according to TfL7). They would only be used by local residents if South Quay DLR station became dangerously overcrowded. Since dangerous overcrowding (especially of open and raised station platforms) is clearly to be avoided, Berkeley Homes’ argument is self-defeating. Moreover, very large new residential developments are being built – with more planned – close to Quays and Canary Wharf DLR stations (over and above the ones near South Quay station and along Marsh Wall), generating considerable increases in loading at those stations too, reducing even their theoretical use as an

4 https://consultations.tfl.gov.uk/tube/bank-consultation?cid=fs162. 5 https://consultations.tfl.gov.uk/tube/bank-consultation/user_uploads/15_timeline.pdf-1. 6 Transport Assessment by WSP for Berkeley Homes, submitted 8th May 2014, section 4.5.4 7 Transport Assessment by WSP for Berkeley Homes, submitted 8th May 2014, section 4.2.11 et seq. Page 6 of 11

alternative to the South Quay DLR station. Dangerous overcrowding on DLR platforms must be avoided, and Berkeley Homes’ application should therefore be rejected unless and until TfL is able to guarantee major increases in the DLR’s capacity. x. Other infrastructure would also be stretched through the addition of residents in 947 new flats in one spot, let alone the thousands more homes also being built and proposed close by. In particular, Marsh Wall – a two-lane road easily blocked by a stationary vehicle – is the only road across the Isle of Dogs, other than driving all the way around the bottom which is not a realistic substitute. It already gets seriously backed up in rush hours, and whenever the road bridge at the West India Dock Entrance Lock is opened to let boats in and out, which can take half an hour or more for large boats. We appreciate that residents are unable to keep many cars here under current policy guidelines, but that does not mean they do not generate many vehicular trips – such as taxis, visitors, and deliveries. Extra retail is also proposed for the site (and the other proposed sites nearby), which will mean even more deliveries. The increased traffic on Marsh Wall would also cause problems for the hugely increased number of pedestrians crossing the road, where there have already been serious accidents. The road infrastructure, as well as the DLR, would therefore be severely overloaded were permission granted to Berkeley Homes, even before considering all the other proposed developments in the pipeline. xi. Over and above the privacy and transport implications of allowing such a major residential development on this site, there would also be considerable strain on schools, surgeries and other local infrastructure from allowing so many new residents to be crammed into such a small space. Support infrastructure needs to be increased before it is overwhelmed: not afterwards. So for all these reasons, while we would have much less objection to even a tall office building on the South Quay Plaza site in terms of the privacy and infrastructure issues, we strongly urge the Committee to reject Berkeley Homes’ proposed residential development. f. Reflected DLR noise Around the South Quay DLR station, apart from Pan Peninsula there are only relatively low rise buildings and a lot of open space including large docks. As a result, the noise of the DLR – which passes close alongside our building – is largely dissipated away from our homes. If a large building is erected just the other side of the DLR from us, the noise will be reflected back into our windows. This would also be a problem for the proposed South Quay Plaza development, and is another reason for it to be rejected. g. Wind tunnelling The docklands area has in the past suffered from unpredictable problems with wind tunnelling, despite expert studies and modelling having been undertaken in advance. For example, before the rest of Canada Square was built, the drop off area for One Canada Square was originally located on the North Colonnade alongside the building. After incidents including car doors being ripped off their hinges by the wind, it was urgently moved to the east side of the building where the Park Pavilion now stands. It is quite possible that such a huge new building, directly opposite Pan Peninsula, could create dangerous wind tunnelling on Marsh Wall, directly through which DLR trains have to travel as well as pedestrians and high sided vehicles; and dangerous gusts on the already wind-swept exposed South Quay DLR station platforms. Page 7 of 11

We do not believe that any amount of theoretical expert advice and modelling can provide complete assurance that this will not happen, and therefore the application for such a big building directly across the road from another existing big building in this windy location should be rejected. h. Housing needs vs. more luxury flats Berkeley Homes refer8 to the 2011 London Plan which calls for additional homes especially in East London as a priority. The vast majority of the proposed 947 new flats are not what the Plan is calling for, and the relatively small number of so-called ‘affordable’ homes that will presumably be required as a condition of planning will be a drop in the ocean. The Council should instead be encouraging developers to build large numbers of affordable homes on available land, rather than pandering to high value developers producing expensive flats in ever greater numbers for which there is little need, as there are already plenty of expensive properties in London. This is another reason why the application should be rejected.

2. Conditions to be attached to any planning consent that may be granted, or guarantees in lieu As we have stated, we ask the Committee to reject Berkeley Homes’ application outright for the above reasons. If, in the event, the Committee is minded to grant consent, we urge the Committee to obtain binding undertakings from Berkeley Homes and/or other relevant bodies, or attach conditions to the consent as the case may be, to address the following issues: a. Privacy Pan Peninsula flats would be directly overlooked at close quarters by the residents in the proposed new building. To minimise this: i. The south-facing corner units should not be permitted balcony areas (the so- called “amenity space”) allowing people to stand in the open looking directly into the Pan Peninsula flats. ii. The south facing windows should not be glazed floor to ceiling, or be able to slide wide open. iii. A treatment should be applied to the affected windows of both the proposed South Quay Plaza building and Pan Peninsula as required to enable people to look out transparently, but not in. Standard blinds or curtains are not the solution, as much of the value and enjoyment of the Pan Peninsula flats and the proposed new South Quay Plaza building is in the views from their windows, even if ours would be blocked to some degree by the new development. People neither want others to see into their homes, nor do they want to see into others’ homes, so this would benefit both sets of residents. If the privacy of the residents in only one of the buildings can be achieved in practice, then the Pan Peninsula residents’ privacy should be protected. The purchasers of the South Quay Plaza flats will be purchasing in the knowledge of their windows being overlooked, and will therefore have taken that into account, whereas the Pan Peninsula leaseholders and residents will have had no such choice. As the problem will have been created by Berkeley Homes, the remedy should be at their expense in any event.

8 Berkeley Homes ‘Wider Site Context’ document, submitted 23rd April 2014, section 2.10 Page 8 of 11

b. DLR capacity and safety Before the consent can be implemented, the Council should receive absolute guarantees from the relevant bodies that, before the new South Quay Plaza building is open to any residents, substantially increased capacity will have been created on the DLR (including the proposed enhanced terminus at Bank – see para 1 (e) (viii) above); and sufficient additional capacity and safety arrangements will be available on the South Quay DLR platforms to avoid dangerous overcrowding. If no such guarantees are obtained, then the application should be rejected. c. DLR noise The Council should receive absolute guarantees from the relevant bodies that noise protection will be erected on the DLR for the benefit of all the adjacent buildings before the consent can be implemented. Since there are proposals for new buildings along Marsh Wall from Heron Quays (in the west) to the South Quay station (in the east), the noise shielding should be erected along the whole stretch. Care should be taken to prevent noise not only to the sides of the track, but also above it, given the close proximity to the DLR of the existing and proposed tall residential buildings. Again, if no such guarantees are obtained, then the application should be rejected. d. Marsh Wall pedestrian crossing In view of the considerable increase in pedestrian traffic across Marsh Wall that is bound to be generated by the South Quay Plaza development (if only to and from the South Quay DLR station on the south side of Marsh Wall), and especially in light of the other large residential developments nearby (both under construction and proposed) which would further exacerbate the problem, traffic calming and a substantial pedestrian crossing should be built across Marsh Wall between the South Quay Plaza development and South Quay DLR station. As the South Quay DLR station already has step-free access to its upper level, subject to our overcrowding concerns we suggest this could provide an appropriate landing for the south side of a new pedestrian footbridge over the road. Improved pedestrian crossing arrangements should be guaranteed before building of the South Quay Plaza development is allowed to commence, and completed before the South Quay Plaza development is opened. And again, if no such guarantees are obtained, then the application should be rejected. e. New covered bridge over South Dock to Canary Wharf In the original plans for this area, a covered pedestrian bridge was planned from the South Quay Plaza site to Canary Wharf, as a second pedestrian bridge. It needs to be covered, as the open bridge further along the dock can be almost impassable in bad weather. We also note that even Berkeley Homes’ own transport study9 says that the existing pedestrian bridge is already operating at pedestrian traffic levels worse than TfL considers suitable for residential use – although they fail to highlight that point, despite some 10,000 new homes planned for the Isle of Dogs, including nearly 1,000 in the South Quay Plaza development alone – and only at the margin of acceptability for office and retail use. They also very misleadingly assert the following: “Notably for travel to the northern side of the South Dock on foot, where Canary Wharf and Herons Quay are located, is not reliant on the use of South Quay footbridge; Marsh Wall (westbound) to Herons Quay Road provides

9 Transport Assessment by WSP for Berkeley Homes, submitted 8th May 2014, section 4.2.11 et seq. Page 9 of 11

an alternative route. Without routing via the footbridge the journey time is approximately an additional 6 minutes.”10 This is not correct. As illustrated below, it in fact takes a good deal more than 6 minutes to walk from near the South Quay landing area of the bridge to near its Canary Wharf landing area; and the walk would be very hard indeed if, say, carrying shopping from the main supermarket in Canary Wharf (Waitrose) which is significantly east of the bridge.

So for these reasons, as well as to encourage people to walk into Canary Wharf to use the or instead of the DLR to help address the DLR’s capacity and station safety issues – or at least to walk into Canary Wharf to get on the DLR there on their way to work in the morning instead of at South Quay – before the consent can be implemented the Council should obtain guarantees that the covered bridge will be built and operational before the proposed South Quay Plaza development is opened. And again, if no such guarantees are obtained, then the application should be rejected. We understand that the bridge requires agreement and cooperation from not only Berkeley Homes as the owner of the South Quay Plaza landing site, but also from Canary Wharf as the owner of the other landing site, and from the Canal & River Trust which controls the dock. However, as the need for the bridge will have been created by Berkeley Homes, it is right that planning consent for their development is contingent on the new bridge being built; and that Berkeley Homes – who are the only party to benefit financially from the granting of

10 Transport Assessment by WSP for Berkeley Homes, submitted 8th May 2014, section 4.2.17. Their incorrect spelling of Heron Quays suggests their lack of actual local knowledge. Page 10 of 11

consent – are motivated in this way to achieve such a commitment from all necessary parties before they are allowed to commence the South Quay Plaza development. f. Disruption during construction It is inevitable that any large construction project will cause disruption to its neighbourhood, and it is always important for this to be minimised. Such an unusually large and challenging project as this, taking some 5 years to build, would be bound to cause unusually large amounts of disruption. It is therefore incumbent on Berkeley Homes and the Planning Committee to take extra measures to find ways to minimise disruption in this case. While this is desirable in any event, it is even more essential in view of the considerable amount of other large developments already under construction or being proposed nearby over the same period. We are not experts in drafting building work conditions, but we propose the following conditions (which are not intended to be exhaustive) be attached to any consent that may be granted if and insofar as standard regulations do not apply: i. Since the site has a long water frontage onto the dock, all building materials and equipment should be delivered via the water, especially in view of the many other imminent developments nearby that would not be able to mitigate their disruption in this way, so the Committee should take advantage of this particular characteristic of the South Quay Plaza site. ii. There should be no increase in road traffic or use of existing road infrastructure. All site personnel controlled by Berkeley Homes should be required to travel to the site using public transport and no use of on-street parking should be permitted at any time. The use of aerial drones and helicopters should be prohibited. Crane operations should not overshadow or impinge existing rights of way or impede access to existing routes. iii. In view of the very close proximity to many residential units, building work should only be carried out between the hours of 9am and 6pm Monday to Friday. No work on site should be allowed on weekends, bank holidays, nor on any day between 6pm and 9am. Breach of this condition should result in substantial and uncapped fines. iv. The use of explosives should not be permitted and hammer drilling equipment or pneumatic drilling equipment may not be used where the noise or vibration levels would be felt (or audible at unacceptable levels) in neighbouring properties. v. Berkeley Homes should pay for additional cleaning of external building surfaces of neighbouring residential properties close to the site to compensate for added dust and particle pollution raised by the building works, to be carried out by the affected building's existing contractors at their contracted applicable rates. vi. Any loss of utilities (including without limitation water, gas, electricity, heating/cooling services and internet and telephony network operation) at nearby residential properties attributable to the South Quay Plaza building works should attract compensation from Berkeley Homes to all affected parties at a rate of (we suggest) £50 per affected dwelling and per affected utility service, per day of disruption. vii. In view of the very long period of construction and the close proximity of other residential buildings, Berkeley Homes should pay for the procurement and installation of external privacy shielding on the site and, where feasible, to all Page 11 of 11

neighbouring residential properties in line of sight of the new development. Such shielding should comply with the aesthetics of the existing buildings and be of an equivalent quality. As the 760 flats in Pan Peninsula are home to most of the closest local residents and home owners to the South Quay Plaza site, and therefore have the best actual (as opposed to theoretical) local knowledge and insights into how local amenities and the local environment are used and the likely effect of Berkeley Homes’ proposals on the site’s residential neighbours, we formally ask that we are invited to help brief any independent experts the Council approaches to consider relevant issues. We also invite you to pass on our details to Berkeley Homes and to other affected residents’ associations if they would like to discuss these issues with us. We hope the above is helpful to you in assessing the Berkeley Homes application for South Quay Plaza. Please do not hesitate to contact me for further information. Yours sincerely

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