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

Page 1 of 11 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 30th June 2014 Dear Jerry Enterprise Business Park, 2 Millharbour Planning application by Docklands Centre Ltd (a wholly owned subsidiary of Fidelity Investments) I am writing to you on behalf of the Committee of the Pan Peninsula Leaseholders and Residents Association, of which I am Chairman. This submission should be read in conjunction with our submission of 5th June 2014 relating to the South Quay Plaza planning application by Berkeley Homes. The two sites are close to each other and both applications propose a similar density of new homes, and therefore raise some of the same issues, compounded. Pan Peninsula is by far the largest residential building in the Isle of Dogs. 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.1 We are self-evidently the largest single group of local home owners and residents who would be materially and directly affected by the proposed development. In this letter I set out our objections to the 2 Millharbour 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, yet another massive 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, 1 1,543 residents based on the average household size in Canary Wharf of 2.03 people – LB Tower Hamlets Corporate Research Unit, May 2014 Page 2 of 11 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. The applicants in this case were of course 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 relatively short delay, after all. b. Impact on the environment The site was formerly a print works, now long demolished, and is currently empty. In 2003, planning consent was granted for a 10-20 storey office building. That consent was extended in 2006 and again in 2009, but has now lapsed. We would have no objection to such an office development on the site, as it would complement and balance the large residential developments around it in terms of its impact on the local environment. However, building an enormous residential development on the site with 990 new homes would plainly put a major further strain on nearby infrastructure and services. It would not only add to existing residential loading, but also cumulatively exacerbate the loading from neighbouring large developments that are already under construction (such as Lincoln Plaza immediately opposite the site on Lighterman’s Road); or which already have planning consent (eg. City Pride to the west of the site on Marsh Wall); let alone many others for which planning is now being sought or known to be imminent, such as Berkeley Homes’ South Quay Plaza just across Marsh Wall, and Galliard’s Millharbour Village immediately adjacent to the 2 Millharbour site. In particular, building 990 new flats would clearly have a major adverse impact on the transport infrastructure, especially the DLR. The assertion by Docklands Centre’s transport consultants, Transport Planning Practice (TPP), that “the forecast DLR trips would not present any material impact on the existing DLR services at South Quay station”2 is palpable nonsense. The impact would inevitably 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.” Other assertions in TPP’s report underline their lack of actual local knowledge, causing their report to be seriously misleading. For example, they wholly inaccurately say: “The nearest Docklands Light Railway (DLR) station is South Quay which is located approximately 350m (a 3 to 5 minute walk) of the site. The nearest London Underground Line (LUL) Station is Canary Wharf on the Jubilee Line, 380m from the site via the South Quay footbridge and through 40 Bank Street.”3 This is completely wrong. This map clearly shows that South Quay DLR station is just moments away from the 2 Millharbour site, whereas the Canary Wharf Jubilee Line station is a great deal further 2 Transport Assessment by TPP for Docklands Centre, May 2014, section 12.9 3 Transport Assessment by TPP for Docklands Centre, May 2014, Appendix L, Travel Plan, para 3.15 Page 3 of 11 away – not just another 30m as TPP claim – and therefore inevitably less attractive in terms of accessibility. Moreover, TPP casually assert that residents and their visitors can use the footbridge over South Dock to access the Jubilee Line. They fail to mention, however, that this narrow, exposed and windy bridge is already operating at pedestrian traffic levels worse than TfL considers suitable for residential use.4 (They also appear unaware of the inadequate nature of the footbridge when they say that the Canary Wharf retail and leisure facilities “are easily accessed via the South Quay footbridge”.5) Another example of the unreliability of TPP’s report (at least in relation to the DLR) is that their estimates of the extra morning rush hour DLR passengers from 2 Millharbour’s proposed 990 new homes are less than a quarter of even those initially admitted by WSP (Berkeley Homes’ traffic consultant on the nearby South Quay Plaza development, which would add 947 new homes). Specifically, TPP claim6 that the 990 new homes at 2 Millharbour would only generate an extra 133 total DLR trips in the morning rush hour, whereas WSP publicly told us at the South Quay Plaza community consultation on 3rd February 2014 (which you chaired) that there would be up to 600 extra passengers per peak hour on the DLR from the 947 new homes planned for the South Quay Plaza site, which is just a few metres away.7 If we apply WSP’s initial figures pro rata to 2 Millharbour’s 990 new homes, that gives 627 additional passengers in the morning rush hour from 2 Millharbour to add to South Quay Plaza’s 600, totalling 1,227 extra rush hour passengers surging onto the already packed South Quay DLR platforms as they scramble to work between 8am and 9am.8 We note that TPP expressly acknowledge that virtually all the peak hour passengers from the 990 new homes at 2 Millharbour would be travelling in the same direction,9 which is logical as residents living in the Isle of Dogs are most likely to be travelling towards central London in the mornings, and back in the evenings. This means well over a thousand extra people trying to squeeze onto a single open and high level platform at South Quay station from just these two developments. Another common sense way of demonstrating the inaccuracy of TPP’s assertion that “the forecast DLR trips would not present any material impact on the existing DLR services at South Quay station”, is to combine the ONS Travel to Work 2011 Census data (last updated 30th January 2013)10, the London Travel Demand Survey 2006-2009 raw numbers11, and LB Tower Hamlets’ own report on the Canary Wharf Ward Profile12. 4 Transport Assessment by WSP for Berkeley Homes, submitted 8th May 2014, section 4.2.11 et seq 5 Transport Assessment by TPP for Docklands Centre, May 2014, Appendix L, Travel Plan, para 3.4 6 Transport Assessment by TPP for Docklands Centre, May 2014, section 12.1 7 They said they expected an average of 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 600 figure was inexplicably reduced to 240 extra peak hour passengers when WSP made their written submission, but even that is still nearly double the TPP assertion. 8 Even WSP’s later reduced figure implies 257 extra rush hour passengers from 2 Millharbour to add to South Quay Plaza’s 240, totalling nearly 500 extra people surging onto the South Quay DLR platform. 9 Transport Assessment by TPP for Docklands Centre, May 2014, section 12.1 10 Transport Assessment by TPP for Docklands Centre, May 2014, Appendix I, page 105 11 Transport Assessment by TPP for Docklands Centre, May 2014, Appendices, page 120 12 LB Tower Hamlets Corporate Research Unit, Canary Wharf Ward Profile, May 2014 Page 4 of 11 34% of the residents of the old Millwall Ward travel to work using the tube or the DLR.13 (Given that LB Tower Hamlets’ latest data shows that a much higher proportion than average of the new Canary Wharf Ward’s residents are of working age and in employment, this is surely a conservative estimate.14) If we take the Canary Wharf Ward average of just 2.03 people per home15, the 990 new homes at 2 Millharbour would give a population of 2,010 new residents.

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