Pan Peninsula Leaseholders and Residents Association

Transcription

1 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 richard@horwood.org 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/ th 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 5 th 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

2 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 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 Transport Assessment by TPP for Docklands Centre, May 2014, Appendix L, Travel Plan, para 3.15

3 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 claim 6 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 3 rd 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 30 th January 2013) 10, the London Travel Demand Survey raw numbers 11, and LB Tower Hamlets own report on the Canary Wharf Ward Profile Transport Assessment by WSP for Berkeley Homes, submitted 8 th May 2014, section et seq 5 Transport Assessment by TPP for Docklands Centre, May 2014, Appendix L, Travel Plan, para Transport Assessment by TPP for Docklands Centre, May 2014, section 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 Transport Assessment by TPP for Docklands Centre, May 2014, Appendix I, page Transport Assessment by TPP for Docklands Centre, May 2014, Appendices, page LB Tower Hamlets Corporate Research Unit, Canary Wharf Ward Profile, May 2014

4 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 home 15, the 990 new homes at 2 Millharbour would give a population of 2,010 new residents. 34% of those would mean 683 extra people traveling to work using the tube or the DLR (not counting the additional trips by the many non-residents who would also be using the site). This straightforward calculation from public statistics is 2½ times TPP s assertion that 2 Millharbour s 990 new homes would generate only 268 extra outbound tube and DLR trips each morning rush hour. 16 The London Travel Demand Survey has 15,961 people in the Millharbour South area using the tube or DLR outbound between 7am and 9.59am daily. 2 Millharbour s extra 683 people traveling to work on the tube and DLR would alone increase outbound trips on the DLR and the Jubilee Line by some 4.3%. This increase would be doubled by the South Quay Plaza residents. This would plainly constitute a material impact on the existing DLR services. And even these large numbers of extra passengers would be added to by thousands more residential passengers if consent were given for the 1,550 new flats in the other large residential development in Millharbour Village (immediately adjacent to the 2 Millharbour site) that is now being proposed by Galliard; as well as the many more new flats already being built nearby such as at Lincoln Plaza; and others whose applications are imminent, such as LBS s Meridian Gate on Marsh Wall (just the other side of the South Quay 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 seek to use South Quay DLR station as it s their nearest station. Even were Heron Quays DLR station considered close enough to be an alternative for some of them (as 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. 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 enormous Westferry Printworks to the south of the site (at least around 1,000 new homes), and the Telford Homes site at 7 Limeharbour (167 new homes), whose residents may well pre-load the trains at Crossharbour DLR station leaving even less space on the trains at South Quay, let alone at Heron Quays. Perhaps the inaccurate and seriously misleading figures by TPP are what caused TfL s Assistant Surveyor, Rukaiya Umaru, to write to you with the extraordinary single sentence comment: Docklands Light Railway has no comments regarding this application. 17 We strongly urge you to check this alarming and casual response with senior responsible management at TfL in light of our analysis. 13 6,520 of the 19, year-old residents of the old Millwall Ward - Transport Assessment by TPP for Docklands Centre, May 2014, Appendix I, page % are of working age (cf. 74.1% for the Borough); and 69.1% in employment (cf. 57.6% for the Borough) - LB Tower Hamlets Corporate Research Unit, Canary Wharf Ward Profile, May 2014, pages 3 and 8 15 LB Tower Hamlets Corporate Research Unit, Canary Wharf Ward Profile, May 2014, page 5 16 TPP claim there would be only 118 extra outbound DLR trips extra outbound Jubilee Line trips = 268 extra trips 17 to you of 6 th June 2014

5 Page 5 of 11 Moreover, even TPP s patently understated numbers expect the ratio of flow to capacity ie. how packed a train can theoretically get to increase to 89.9% on northbound services towards Heron Quays once 2 Millharbour is opened. 18 This maximum loading percentage is based not only on their understated numbers of residential passengers from 2 Millharbour, but also on their assertion that each DLR carriage can satisfactorily hold 162 people. As each carriage has only 56 seats, it is hard to imagine commuting in a DLR train with over 100 people standing crammed together in a single carriage around the lucky 56 seated. Even if it were technically possible, this huge percentage loading of the DLR platforms and trains in the morning rush hour surely cannot be allowed. It would not only be extremely uncomfortable for the passengers, but also dangerous, especially on the open platforms, and is as we have explained seriously understated anyway. This is clearly something that the new Master Plan would be bound to address. Moreover, 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 We note that TPP state that there are no current plans to further improve capacity of the DLR. 19 In view of the enormous extra loading of the DLR that is bound to follow the building of thousands more homes in this increasingly densely packed area, it would surely be negligent to grant consent unless and until substantial extra DLR capacity has been guaranteed. TPP go on to suggest there is in the future, should demand require it, the ability to increase the frequency of trains on the line. 20 This assertion is unsupported in their report, and seems somewhat cavalier. In the rush hours, DLR trains already run every 3 minutes on average in each direction. The architecture of the service requires the trains to switch tracks and cross over in front of other trains at several critical junction points. This already frequently overstretches the signalling and maintenance systems. Significantly increasing the frequency of the trains therefore seems ambitious, to say the least. We are aware that 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. 21 Even if this did allow for more frequent DLR trains though as stated above, increasing the frequency to an average of more than every 3 minutes in rush hours seems extremely ambitious, 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 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 There may then be a public inquiry. If the Order is granted this is likely to be in early 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 18 Transport Assessment by TPP for Docklands Centre, May 2014, section Transport Assessment by TPP for Docklands Centre, May 2014, section Ibid

6 Page 6 of 11 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 service. So, even if the proposed works at Bank station could help increase the frequency of the DLR trains, it would be reckless to approve the building of yet another 990 new flats (particularly in the context of thousands more 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 We note that TPP assert that Crossrail will be an alternative to using the South Quay DLR station. 23 This is an heroic assumption. Unlike TPP s theoretical approach, as residents living adjacent to the South Quay DLR station (as the 2 Millharbour residents would be) we can assure the Planning Committee that stations in Canary Wharf are not necessarily practical alternatives for busy commuters (especially in inclement weather), bearing in mind that the sole pedestrian bridge over South Dock to Canary Wharf is already overloaded for residential pedestrian traffic according to TfL 24. Local residents would only walk to the Crossrail station on the north side of Canary Wharf if South Quay DLR station became dangerously overcrowded. Since dangerous overcrowding (especially of open and raised station platforms) is clearly to be avoided, TPP s argument is self-defeating. Moreover, very large new residential developments are being built with more planned close to the Crossrail station, and indeed to the Heron Quays and Canary Wharf stations (over and above the ones near the South Quay and Crossharbour DLR stations), generating considerable increases in loading at those stations too, reducing even their theoretical use as an alternative to the South Quay DLR station. Dangerous overcrowding on DLR platforms must be avoided, and Docklands Centre s application should therefore be rejected, at least unless and until TfL is able to guarantee major increases in the DLR s capacity. Other infrastructure would also be stretched through the addition of residents in 990 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 (as can be seen from the photograph on the next page, taken on the evening of Friday 27 th June 2014, of typical, virtually stationary evening traffic bumper to bumper all along Marsh Wall); 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 and commercial use is also proposed for the site (and the other proposed sites nearby), which will mean even more deliveries. The 760 Pan Peninsula flats generate around 22, vehicle movements annually, despite relatively few residents keeping cars here and using mainly the DLR or tube instead. 2 Millharbour s 990 new flats could therefore be expected to generate around 29, Transport Assessment by TPP for Docklands Centre, May 2014, section Transport Assessment by WSP for Berkeley Homes, submitted 8 th May 2014, section et seq. 25 According to Ballymore Asset Management, Pan Peninsula s Managing Agents

7 Page 7 of 11 additional vehicle movements, all of which will have to turn onto or off Marsh Wall, in addition to the substantial extra retail and commercial traffic that the development will generate. 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 Docklands Centre, even before considering all the other proposed developments in the pipeline. Over and above the 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 no objection to the previously approved office building on the 2 MIllharbour site in terms of the infrastructure issues, we strongly urge the Committee to reject Docklands Centre s proposed residential development.

8 Page 8 of 11 c. Housing needs vs. more luxury flats Of the proposed 990 new homes, only 197 would be so-called affordable homes (plus another 94 deemed intermediate ). 26 The Council should be encouraging developers to build large numbers of affordable homes on available land, rather than pandering to high value developers producing mainly 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 Docklands Centre s 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 Docklands Centre and/or other relevant bodies, or attach conditions to the consent as the case may be, to address the following issues: a. DLR capacity and safety Before the consent can be implemented, the Council should receive absolute guarantees from the relevant bodies that, before the new 2 Millharbour buildings are open to any residents, substantially increased capacity will have been created on the DLR (including the proposed enhanced terminus at Bank see 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. b. Marsh Wall pedestrian crossing In view of the considerable increase in pedestrian traffic across Marsh Wall that is bound to be generated by the 2 Millharbour development, 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 South Quay Plaza 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 2 Millharbour development is allowed to commence, and completed before the 2 Millharbour development is opened. And again, if no such guarantees are obtained, then the application should be rejected. c. 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. As noted above, the existing narrow pedestrian bridge is already operating at pedestrian traffic levels worse than TfL considers suitable for residential use, and only at the margin of acceptability for office and retail use. 26 Affordable Housing Statement, DS2 LLP for Docklands Centre Ltd, May 2014, para 3.5

9 Page 9 of 11 Moreover, as illustrated in the above map, when the existing footbridge is blocked or unavailable, it is a long 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. The footbridge can be closed not only for maintenance at weekends, but also on weekdays to let boats through. For example, in addition to maintenance closures we understand it was closed to lets boats pass three times in May 2014 alone, for up to half an hour each time. So for these reasons, as well as to encourage people to walk into Canary Wharf to use the Jubilee line or Crossrail 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 new covered bridge will be built and operational before the proposed 2 Millharbour 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 Berkeley Homes as the owner of the South Quay Plaza landing site, 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 Docklands Centre and the other developers applying for consent to build major new residential buildings in this small area, it is right that planning consent for all such developments should be contingent on the new bridge being built; and that the developers who are the only parties to benefit financially from the granting of consent are motivated in this way to achieve such a commitment from all necessary parties before they are allowed to commence their building work.

10 Page 10 of 11 d. 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 a large project as this would be bound to cause large amounts of disruption. It is therefore incumbent on Docklands Centre 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. All site personnel controlled by Docklands Centre 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. ii. 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. We are aware that longer permitted hours are normally allowed, but we ask the Committee to recognise the exceptional scale and duration of the proposed works, coupled with the site s extremely close proximity to thousands of homes. iii. Heavy piling work should be restricted to between the hours of 10am and 4pm Monday to Friday only. iv. The use of explosives should not be permitted under any circumstances. v. Hammer drilling equipment, power tools, heavy machinery or pneumatic drilling equipment should not be used where the noise or vibration levels would be felt (or audible at unacceptable levels) in neighbouring properties. vi. If the Committee were to permit building work on Saturday mornings despite our objection, then hammer drilling equipment, power tools, heavy machinery or pneumatic drilling equipment should only be permitted to be used after at least one hour later than on weekdays. vii. Docklands Centre 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. viii. 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 2 Millharbour building works should attract compensation from Docklands Centre to all affected parties at a rate of (we suggest) 50 per affected dwelling and per affected utility service, per day of disruption. ix. In view of the long period of construction and the close proximity of other residential buildings, Docklands Centre should pay for the procurement and

11 Page 11 of 11 installation of external privacy shielding on the site and, where feasible, to all 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 2 Millharbour 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 Docklands Centre s 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, including TfL. We also invite you to pass on our details to Docklands Centre 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 Docklands Centre application for 2 Millharbour. 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