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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 October 2014

Dear Jerry

South Quay Plaza planning application by Berkeley Homes

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 development. This letter is supplementary to, and should be read in conjunction with, our related letter of 5th June 2014. As such, we will not expressly repeat here the points made in our earlier letter, but those points are strongly reaffirmed. We also repeat our request that I be allowed to speak at the Strategic Planning Committee hearing at which this application is considered. 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 South Quay Plaza application. 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 Berkeley Homes, we have heard absolutely nothing from them. Instead they have just buried in the many documents supplied to you a dismissive response to the major issues we raised. We mention this to highlight the inappropriately arrogant approach of Berkeley Homes to the real and extreme adverse impact their proposed development would have on our neighbourhood and the quality of life for the local residents.

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This application must be considered in context Berkeley Homes have taken the same dismissive approach with regard to the critical work you and your colleagues, along with the GLA, are doing on the South Quay Masterplan. For example, the GLA’s response to the proposed development1 stated that “GLA officers are currently working in partnership with the Council in the delivery of its Supplementary Planning Document for the South Quay area, which is seeking to identify the social and physical infrastructure requirements triggered by the quantum of emerging development, as well as addressing the issues surrounding place making. GLA officers will work with the Council and applicant to determine whether the density proposed can be successfully integrated into a wider plan, and what measures may be required from the applicant. Further discussions are therefore required before the proposal can be considered acceptable with regards to density.” (emphasis added) Berkeley Homes’ representatives dismissively replied that “the Borough already has an adopted policy context that is sufficient to provide a framework for the determination of this application.” That statement is patently incorrect. The very fact that 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, demonstrates how inappropriate Berkeley Homes’ response is. Moreover, the South Quay Masterplan has in fact 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. We can only draw the conclusion that Berkeley Homes – 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. Berkeley Homes themselves refer to the 2010 LBTH Core Strategy identifying the area as “capable of accommodating more than 3,501 homes up to 2025”2. That entire potential would be used up by just this proposal and the two adjacent Millharbour Village proposals from Fidelity and Galliard surrounding Pan Peninsula, and the whole of the rest of Millwall would therefore have to be left undeveloped. Our view is clearly shared by the GLA and the Mayor of London. In a statement issued in the last few days, 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.” He added that the Masterplan “would enable a coordinated approach to planning, with development contributing to the sustainability of the area, directly to the south of ”. 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, , etc); have recently been approved (e.g. City Pride, , etc); are currently awaiting consent (e.g. Quay House, 2 Millharbour,

1 http://planreg.towerhamlets.gov.uk/WAM/doc/Correspondence- 909670.pdf?extension=.pdf&id=909670&appid=&location=VOLUME5&contentType=application/pdf&pageCou nt=1 2 Neighbour Response, 11th September 2014 Page 3 of 7

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 Berkeley Homes’ 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.

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. We noted in our earlier letter that Berkeley Homes claimed (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 that the effect on the DLR of their proposals would be “insignificant”.3 They now acknowledge in their revised transport assessment4 that the nominal 6% reduction in the number of units in their revised proposals (from 947 to 890 units) will make no noticeable difference to the extra loading of the DLR, and continue to maintain – contrary to common sense – that “the effect of the development proposals [on the DLR] is negligible”. We also noted in our earlier letter that their written figures conflict 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’ 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 from just this one development. Also hardly “insignificant”. We also pointed out in our earlier letter that virtually all those extra morning rush hour DLR passengers will be residential commuters leaving South Quay to work in central London in the morning, who will all be on the platform going their way (just 20 DLR trains in that direction in the morning rush hour). 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. This would patently be dangerous.

3 Transport Assessment by WSP for Berkeley Homes, submitted 8th May 2014, section 18.1.3 4 Revised Transport Assessment, Part 1, para 13.2.8 Page 4 of 7

Our view is confirmed by the Council’s own Highways Department, who have stated that the development proposals would “place additional pressure on the already heavily congested northbound DLR platform at South Quay in the AM peak.”5 As stated above, Berkeley Homes’ assertion that the impact would be insignificant defies common sense. This can be demonstrated by simply multiplying Berkeley Homes’ calculation6 of 1,637 residents in the proposed development by the 49% who Berkeley Homes say travel to work using the tube or DLR7, giving a total of 802 extra South Quay Plaza residents trying to get on the already heavily congested DLR or tube going towards central London in the morning rush hour. And if we take the Canary Wharf average population per flat8 of 2.03 for the 890 proposed new flats, that would yield 1,807 residents and therefore 885 extra morning rush hour commuters on the DLR or tube from just this one development. These figures tend to support what Berkeley Homes’ transport consultant candidly admitted at the meeting last February before their more self-serving assertions were devised. 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 2 Millharbour and Millharbour Village developments that are now being proposed by Fidelity and Galliard just across the road from South Quay Plaza, 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). The thousands of residents of all these new homes would naturally prefer to use South Quay DLR station to go to work in central London, as it’s their nearest station. Even were Heron Quays DLR station considered close enough to be an alternative for some of them (as naively suggested 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 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. 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 at much lower densities.

5 http://planreg.towerhamlets.gov.uk/WAM/doc/Correspondence- 909671.pdf?extension=.pdf&id=909671&appid=&location=VOLUME5&contentType=application/pdf&pageCou nt=1 6 Ibid. Berkeley Homes’ response to the LBTH Communities, Localities and Culture comments of 9th June 2014 7 Revised Transport Assessment, Part 1, para 6.2.1 8 LB Tower Hamlets Corporate Research Unit, Canary Wharf Ward Profile, May 2014 Page 5 of 7

New pedestrian bridge The only practical route for South Quay and other Millwall residents to an alternative DLR station (or to the Jubilee Line 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 GLA said in their comments on Berkeley Homes’ proposals: “A key infrastructure barrier to development capacity within the South Quay area is the lack of bridge provision across the dock linking key development sites to essential transport facilities at Canary Wharf.” 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 South Quay Plaza 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 stations 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 South Quay Plaza 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 alongside the site. 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 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 South Quay Plaza, 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 South Quay Plaza 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 assertions made by Berkeley Homes. Specifically, the Highways Department’s response of 1st July 2014 to the South Quay Plaza proposals states: “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 is almost double the upper limit of the London Plan density matrix for a ‘central’ site with a high PTAL rating.” Page 6 of 7

The Highways Department’s point about current peak time congestion on Marsh Wall is illustrated by this photograph taken in June this year from Pan Peninsula of virtually stationary evening peak time traffic on Marsh Wall at South Quay. In keeping with their inappropriate and generally dismissive attitude, Berkeley Homes replied to the Highways Department’s serious concerns as follows: “The effect of the development on the local highway network is considered to be negligible.”9

Overshadowing neighbouring properties In our earlier letter, we explained how the proposed development would in fact be very close to and overshadow especially the Pan Peninsula ; and that, while its 45⁰ angle to Marsh Wall does help reduce its impact on our east tower, it actually aims the new development directly at the north east facing flats in our west tower (see diagram). We note that the revised proposals for the South Quay Plaza dockside tower are for a still enormous 68 storeys instead of the initially proposed 73, but the tower that would be just a few metres away from the Pan Peninsula west tower remains at the original 36 storeys, and Berkeley Homes have proposed nothing of substance to address our issues in relation to that. Our serious concerns regarding the invasion of privacy, as well as overshadowing and reduction of light, therefore remain.

9 Letter from GVA for Berkeley Homes, 9th September 2014 Page 7 of 7

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. 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. Moreover, Berkeley Homes’ over-ambitious plan for a 68-storey skyscraper that would overshadow every other development in its vicinity is unwanted and unnecessary, and would be damaging to the local community. Please share this letter with all interested parties. Yours sincerely

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