Joint Objections by the Greenwich Society, Westcombe Society and EGRA

Local societies unite in objecting to Knight Dragon's plans to build an extra 5000 units on the Peninsula over and above the Mayor's target of at least 13500 and the council's target of 14000 in the area. Knight Dragon want to take the total numbers of new dwellings in the Peninsula Opportunity Area to over 20,000. How will our already overstretched infrastructure, public transport and road network cope with such a massive increase?

kd

15/0716/O – land at Greenwich Peninsula to the south of the O2

Joint response by Greenwich Society, Westcombe Society and East Greenwich Residents Association to additional documents dated 15th July 2015

Quantum of development

No justification is produced for the excessive increase in units to 15720.

The applicant states,correctly, that the Mayor's plan calls for a minimum of 13,500 new units but ignores the fact that this target refers to the Greenwich Peninsula Opportunity Area which comprises not just the Masterplan zone but the entire area north of Trafalgar Road from Park Row in the west to the boundary of the Charlton OA in the east.

Similarly the RBG Core Strategy seeks 14,000 new units in the Peninsula defined as including Greenwich Millennium Village and the Enderby Wharf area.

15,720 units added to GMV(1746), Lovells(667), Alcatel/Enderby(1350) would provide a total of 19,483 units to which should be added the proposed 404 dwellings at Plot NO201 by the O2. Smaller schemes within the Opportunity Area such as the Peltons and the 200 serviced apartments at the hotel would bring the total number of dwelling to over 20,000, a massive overdevelopment far exceeding the targets set by the Mayor and RBG.

Density

Our objections regarding the density proposed remain unchanged. The use of the PTAL Density matrix table has been unwarrantably stretched to include all zones within the Central Area category (ie within 800 metres walking distance of an international, Metropolitan or Major town centre). The Urban category should apply to most, if not all, of the area and would suggest maximum density of 260 u/ha not the 345 u/ha proposed.

Furthermore the applicant has included all public open space in the density  calculations which we consider quite wrong. Central Park was provided as an amenity  for the general public, visitors to the entertainment zone and local workers and should not be used for density calculations purposes.

The effect of the applicant's approach is to support claims of "reasonable" densities in all zones, eg for Meridian Quays a density of 427u/ha whereas with public open space excluded the figure is 509 u/ha which vastly exceeds the GLA matrix maximum of 405 u/ha:; and for Brickfields North a density of 144 u/ha whereas with public open space excluded the figure is 300 u/ha, which again greatly  exceeds the GLA matrix maximum of 170 u/ha. We consider that the major areas of public open space should not be included in the density calculation figures.

Tall buildings

 

Excessive density leads to the demand for excessively tall buildings. Our concerns that tall buildings fronting the Central Park will reduce its amenity value and that tall buildings close to the Pilot P.H and Grade II Listed terrace, Nos. 70 to 84 River Way, would dwarf these heritage assets have not been addressed and therefore our objections  still stand.

Financial viability report

The BNP/Paribas report does no more than claim that a wholly private development would make an inadequate profit. Such a scheme is not proposed nor would it be approved. No attempt is made to model a realistic scheme including affordable housing nor any sensitivity testing based on cost and selling price variables. Sensitivity testing is essential for a scheme with  20 year build period and we would expect RBG's independent assessor to require a more thorough approach.

Affordable housing

We consider the applicant's approach to affordable housing inadequate. The Royal Borough must be given much greater assurance as to the quantum and percentage of affordable units to be provided and the timescale for provision. Their "offer" contingent on a September decision attempts to railroad a decision from the planning authority over a scheme of huge scale and major ramifications and in our view should be rejected- the 35%' if thought acceptable, should be subject to firm condition with no strings attached.

Family dwellings

A minimum of 20% family dwellings is insufficient to create sustainable communities. The original Planning Statement described studio units as forming up to 10% of the total: the Planning Addendum page 6 states the maximum would be 15% studios. Again such high numbers run counter to claims that sustainable communities will be created.

Inadequate Public Open Space

Under the approved 2004 Masterplan 10,010 units were to have access to 19.4 hectares of open space. The applicant proposes that 15,720 homes would only have access to 24ha of open space. On a pro-rata basis, around 30 hectares should be provided.

No justification is produced for this reduction in vital open space which would be exacerbated by 404 extra units at Plot NO201 beside the O2.

Road Network and Public Transport

 

In response to our objections, and those of others, that the increase from 10,010 to 15,720 contributes to extra load (9% more evening peak traffic in Trafalgar Rd) on the local road network which already lacks capacity and resilience and contributes to illegal levels of air pollution, the applicant states that “Future year and development modelling are in the process of being finalised such that the exact impact can be determined and subsequent mitigation measures provided if required.”

 In the light of community concern over air quality, it would be premature to determine the application without this information, especially mitigation.

Public transport is already overstrained and the response from the applicant to our concerns is “All these items require further investigation by means of revised modelling.  Once finalised the models can be used to determine the exact impact and subsequent mitigation if required.”

Again it would be premature to determine the application without this information being publicly available.

Cumulative effect

 

Finally, we would draw attention to the cumulative effect that all the various planning consents and applications  in the Greenwich area are having and will have on the road network, public transport and infrastructure generally. The impact of each  scheme has been considered in isolation to date.

Whatever the final size of the Peninsula scheme it will have a massive impact on all aspects of our community infrastructure and should surely prompt an overall review of the total impact of all the developments, completed, in the pipeline and proposed, so that the full picture can be assessed, understood and mitigation planned so that the community can have confidence that unprecedented levels of regeneration will be sustainable.

Richard Baglin                       Marilyn Little                        Dan Hayes

Chair                                     Chair                                    Chair

Greenwich Society                  Westcombe Society               EGRA