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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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/14/00944 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 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 South Quay Plaza 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. Page 2 of 7 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 Millwall 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 Canary Wharf”. 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, 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.