Matt and I bought a property last year in Woolwich. We love our new home …however, the area is being rapidly, inappropriately, and distastefully developed by Berkeley Homes (a massive property developer in the UK). I have been really disappointed in how planning applications for the area have been dealt with, by both the developer and the local council. Feelings of injustice moved Matt and I to mobilise the community around our common concerns. We set up a Facebook group and have been coordinating community engagement with local plans since May. Despite the frustrations and lack of power I felt throughout this process, I have been really motivated and proud of my community for coming out in such large numbers to have our voices heard. Over 100 residents submitted letters of objections to the planning application (you can see ours below – fascinating read I assure you), and more than 20 of us spoke at the recent planning board meeting. We even managed to get some media coverage ahead of the meeting (see youtube clip above).
The board meeting last Tuesday resulted in a bit of a win for us. Board members decided to hold off on approving the application until they had more information – particularly around alternative service delivery routes. I am glad this happened, as it was very clear that the planning officers on the case working for the council were not well informed on the issues. They failed to offer answers to many of the board members questions and concerns… and in some cases, even provided inaccurate information. This is very concerning considering the planning officers had mad a recommendation for the board to accept the planning application ahead of the meeting.
Despite this little win there is still loads of work to be done. The board members seemed to be interested in mainly safety issues around the service delivery route proposed (fair, definitely an important issue), however, the communities concerns of breach of national and local policy concerning listed buildings, conservation areas, privacy, overlooking, amenity, open spaces for community use, etc. were largely ignored. So now what?? To be honest I don’t know. I’m slightly exhausted and feel defeated. I don’t know if it is possible to stick it to the man. The power imbalance between communities and corporates…heck even communities and governments these days…is massive. I feel like giving up – but I don’t think I can. If I do, I am accepting that the current power imbalance is inevitable, unchangeable, and ok. But it isn’t. And for that reason I feel this is only the start of my journey towards a life of uphill battles and perseverance. I can only hope that I continue to meet amazing people to join me along the way. There is power in numbers after all.
~ Robyn (Nov. 29, 2016)
COPY OF OUR LETTER OF OBJECTION IN RELATION TO THIS PLANNING APPLICATION
We are writing in reference to planning application 16/2807/F. Please note that we object to this planning application.
This is our second letter of objection in relation to this application. Despite amends made by the applicant, all our original objections (Submitted September, 22, 2016) remain pertinent.
Might I also express our disappointment with the process of community “consultation” throughout this planning application. Firstly, I have just viewed the Planning Board Summary document in relation to this application and noticed two rounds of consultation and respondent rates quoted. Upon receiving a subsequent notice associated with this application in October, many members of our community approached the council to seek information as to why a second notice was delivered, and whether or not they needed to resubmit their initial comments in order for them to be considered. The council advised that interested community parties did not need to resubmit comments. While indeed this was technically true, it is now clear that having resubmitted and / or elaborated on our comments would have been beneficial to strengthening our community response. The council failed to disclose this information and the community was not made aware that the notification of the planning application delivered in October was for the purpose of conducting a second round of “consultation” post minimal amendments made by the applicant. In addition to this, the summary document reveals that the council has made a recommendation that the planning board accept this planning application, which means this recommendation was made ahead of the close of the community consultation period. This demonstrates a disregard for considering community responses in the making of your recommendation.
I would also like to lodge my grievance with the council regarding the release of formal invitations to the planning board meeting. The community only received invitations exactly one week ahead of the meeting. Furthermore, given that the closing date for submitting comments associated with the October notification is November 16th, community members that commented on the notification received in October would not have been invited to the planning board meeting. This overtly excludes interested members of the community from attending the board meeting, where they are supposed to have the opportunity to address the board.
The overall process for community “consultation” is inaccessible and lacks transparency. Each planning notification that gets slipped through our door is illegible (half of the front page is covered in numbers and application references that have little meaning), and lacks a clear message as to what the letter and associated planning application is concerning. Further to this, members of the community are unable to discern the scale of the various planning applications they receive. The council frequently sends the same looking notification for a diversity of issues, which not only overwhelms, but confuses residents as to what is important and affects them, and what is merely a change of use to an existing space. Despite these challenges, if a member of the community proceeds to make an objection, numerous hurdles around accessing documents associated with the application, contacting the council, and understanding the process of review emerge. It is clear (or at least widely perceived by the community) that the council goes out of it’s way to make it difficult for community members to engage with planning applications.
ORIGINAL OBJECTIONS STILL RELEVANT:
In particular, we object to the negative impact to the conservation area, historic buildings and surrounding area, and local residents and community from the cumulative designs of the proposed taxi interchange, service-delivery route, extension to building 11, and residential development on top of building 10.
In their Planning Statement and supporting materials, the Applicant has failed to include all relevant information required for the Council to make an adequately informed decision. We bring additional information and relevant policy to your attention.
With regards to the proposed Taxi interchange, Berkley Homes states: “Within Royal Carriage Square and integrated into the landscaping proposal, a taxi turning point is proposed. This would support the operation of the adjacent Woolwich Crossrail Station, maximizing the Site’s accessibility and facilitating easier connections to elsewhere within the Borough.” (5.46); and “It is understood that previous studies relating to the Crossrail development and through liaison with TfL and Crossrail determined that there was a requirement for a formal taxi rank within sight of the station entrance and which had sufficient capacity to accommodate up to 50 taxis during the peak hour. It is estimated that this equates to a taxi rank with capacity for up to eight waiting taxis. On this basis a facility satisfying this demand and accommodating eight taxis has been provided within Royal Carriage Square.” (5.47)
We challenge these claims. The Applicant provides no evidence that a taxi interchange in the proposed location is a requirement of the Crossrail. On the contrary, ‘TfL Station public realm design guidance’ dated August 2015 (‘Station Guidance’), doesn’t require a taxi interchange to be within “site of the station entrance”, as the Applicant asserts, but states that “walking distance should be minimal” for taxi and private hire vehicles. In terms of further clarity for acceptable distances, the Station Guidance provides, “while interchange distance should generally be kept under 100 meters, designers should consider transport destinations that are within 200 meters (about a three-minute walk of the main station).” Further to this, Section 3.2 of the Station Guidance states, “we should consider the access points of other transport near the station and look to make the most of these connections for passengers using the interchange area.”
The Applicants proposed location for a taxi interchange does not follow Tfl guidance. Instead of considering access points to other transport near the station and using existing transport destinations, the planning application under review segregates the Crossrail station from the wider Woolwich community and proposes to introduce traffic to what is currently a pedal area. If efforts were being made to keep the Crossrail station accessible to the wider Woolwich community, the use of existing transportation destinations along Plumstead Road, which connects bus routes and the DLR with the Crossrail station, would be considered.
In addition to this, the Royal Arsenal Development itself offers a solution that would preserve the attractiveness of the proposed public square associated with this application. A planning application that introduces vehicle traffic beside an “attractive” public square is contradictory. There is ample space within 200m away, for example on Arsenal Way, along Plumstead Road or within Woolwich Town Centre that could accommodate up to 8 Taxis, and which utilizes existing roads and traffic routes.
Interestingly, in reference to “the initial 2013 public realm scheme proposed taxi drop off and interchange at Major Draper Street”, Berkeley Homes refuted the introduction of a taxi interchange to the space on the following grounds, which still hold true:
“3.19 During this time it was understood that the 2018 opening of the Crossrail Station, allied with the massive increase in pedestrian numbers and the requirements to change to other modes of transport (including taxis, private pick up and drop off, and cycles in a Zone 4 station such as Woolwich) would put immense pressure on an already pressurised space to the north east of Dial Arch Square besides Building 11 at the head of Major Draper Street. In addition it was noted that there would be:
– Conflict with significant pedestrian flows and service/delivery vehicles;
– Insufficient road width to provide taxi rank with adequate capacity;
– Insufficient space for taxis to turnaround without making three-point turns;
– Long and convoluted route for taxis to and from Plumstead Road; and
– A poor relation with residential uses along Major Draper Street and incompatible with aspiration to pedestrianise the Street.”
With regard to the proposed public square associated with this application, similar concerns emerge. Within the Royal Greenwhich Local Plan: Core Strategy with Detailed Policies, open space is emphasized as integral to cohesive and healthy communities. Given the high population density within the development, the community is currently in dire need of more open and green public spaces. This is particularly important in order to reduce the increasing stress on the existing open space in front of Dial Arch.
However, within the application under consideration, the prospects for creating an enjoyable and attractive open space for community use are slim. First of all, it would be better to describe what Berkeley Homes proposes as a “public square” as a “concrete rectangle with a few trees”, as introduction of a taxi interchange, the extension to building 11, and service delivery route, leaves little space for a public square, whilst introducing risks associated with the introduction of vehicles. Designs and mock-ups throughout Berkeley Homes planning application lack accuracy and scale, and do not reflect this reality. Furthermore, combined, all developments within the planning application close off space rather than open up space. Little physical space for a public square, coupled with the introduction of an 11 story development on top of building 10, creates a feeling of enclosure from the ground. Both physical and air space are relevant for creating “open spaces”, yet both are compromised in the planning application.
In addition to a lack of square footage available and creating a feeling of enclosure within the proposed “public square”, the proposed taxi interchange associated with this application negatively impacts the conservation and community enjoyment of the “public square”. More specifically, the proposal to introduce traffic into the area negatively impacts the community in the following ways:
- Introduction of pollution, both noise from new traffic, but also fumes from cars.
- Presents danger of traffic in a highly pedestrianized area. This is particularly relevant to children and elderly in the area (note that Bentham house bordering the proposed traffic route is a retirement home where many residents have accessibility needs).
- Negatively impacts existing and future commercial/hospitality space around the square, as the area would not be a desirable location for the local community to enjoy and spend time and money.
It must be noted that buildings 10 and 11 under consideration in this application are Grade II listed heritage assets located within a conservation area. Paragraph 127 of the National Planning Policy Framework (‘NPPF’) provides, “when considering the designation of conservation areas, local planning authorities should ensure that an area justifies such status because of its special architectural or historic interest, and that the concept of conservation is not devalued through the designation of areas that lack special interest.” Paragraph 132 of the NPPF provides that “when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.” And paragraph 137 of the MPPF – provides that “Local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites and within the setting of heritage assets to enhance or better reveal their significance.”
The planning application and proposals for both building 10 and 11 significantly compromise the integrity of, and detract from, these heritage assets – which is particularly damaging as there are opportunities to enhance and better reveal their significance. In the proposed extension and structural alteration to building 11, merely the façade of the heritage building will be retained on one side of the building, while an 11 story development on top of building 10 would greatly detract from it’s significance within the space. Overall, the development proposals for building 11 and 10 are not in keeping with the character of their heritage or the distinctiveness of the wider Royal Arsenal development.
The justifications that Berkeley Homes has provided for significantly altering these heritage assets is cost and time. They make reference to a viability assessment (that has not been made public and brings the transparency associated with this planning application into question) claiming that this over development of the area is necessary in order to finance the “saving” of building 11. This corporate enterprise is not hard done by when their 2016 profits were £479.9 million after tax. Their viability assessment should not be taken seriously and does not justify a lack of respect for the people, environment, and heritage assets that reside in this conservation area. In reference to time, Berkeley Homes pressures the council to make a decision quickly by stating that development must be completed before the Crossrail station is open. We see this as a method of bullying and manipulative use of strategically timing their planning application to leverage their position for maximizing profits within the development.
In addition to this planning application affecting two Grade II listed buildings and a registered conservation area, also note that this planning application is for an area where particularly vulnerable populations within the Royal Arsenal development reside. I do hope the council carefully considers the planning application under review.
To conclude, we request that the current planning application is rejected and encourage the Application to consider a redesign that reflects the collective concerns of the community.
Please keep us informed as to when this will be taken to the planning committee for consideration. We request an opportunity to speak at the planning authority committee at which the application is decided.
Robyn & Matt