What is this Planning Application?
The Canada Water Masterplan covers approx. 53 acres comprising the Surrey Quays Shopping Centre, the Printworks and Surrey Quays Leisure Park sites, former Dock Offices Courtyard, the former Rotherhithe Police Station and the site at Roberts Close.
The planning application can be found at this link. It's made up of 212 documents, which makes it very difficult for a non-expert to have the time or specialist knowledge to tackle.
Southwark Green Party has worked with the Southwark Law Centre and Southwark Community Action Network (CAN) to identify the legitimate grounds on which planning applications can be successfully challenged. Fundamentally, there has to be "material considerations" relative to the planning policy framework for the area covered by this application.
We have structured our response as follows:
- Summary Response
- Overall Development Objectives
- Building Height, Density and Usage
- Right to Light Impacts
- Transport Impacts
- Other infrastructure Impacts
- Social and Heritage Impacts
- Environmental Impacts
- Leeway to change plans going forward
- Cumulative impacts
Please see our final response here.
What you can do
It's very important that Southwark Council's Planning Committee receives as many comments on the Canada Water Masterplan planning application as possible so that councillors understand the depth and range of local residents' concerns.
We, therefore, suggest you might want to use the following as the basis for your response - just highlight it, copy it, paste it into the feedback box below, amend it as you see fit, and then submit it. Your contact details will automatically be added and we will send you a copy of your response.
I am writing regarding Planning Application 18/AP/1604. While I support the principle that the area should be redeveloped, I oppose this planning application for the following reasons.
Building Heights, Density and Usage
The New London Plan Policy D6 requires development proposals to be developed "at the optimum density". Particular consideration should be given to transport connectivity and the capacity of surrounding infrastructure. The Policy goes on to state that proposed residential development that does not demonstrably optimise the housing density of the site in accordance with this policy should be refused.
It is clear from the developer's own evidence that the developer has sought to maximise (not optimise) density, notably
- In Planning Statement paragraph 7.4.44 where it admits that the Canada Water Area Action Plan (CWAAP) maximum densities are exceeded.
- With regard to retail floorspace, the target of up to 88,568 sq m is excessive given the CWAAP target of 35,000 sq m
- With regard to office floorspace, the target of up to 320,588 sq m is very excessive given the CWAAP target of 12,000 sq m
Together this results in far too densely packed development, especially given the density and character of the immediate area. Even after taking account of the welcome reductions in the maximum heights of some of the zone in the October 2018 update, this also results in building heights that are excessive, and that do not integrate well with the surrounding area.
The escalation from less than 30m to 129m is too extreme.
The other tall buildings in that cluster are a maximum of 87m tall. Given this and the scaling issue, this building should be <=87m in height.
Planning Statement paragraph 7.4.35 states that "To address overlooking issues, the massing of the rear building has evolved to create a series of stepped inaccessible planted terraces to help prevent overlooking of adjacent residences...and the planting will be secured in the form of a Landscaping Management Plan.”
The developer is admitting that they have not fully addressed local community concerns, and that even this solution is not fully “built-in”, but is dependent on ongoing maintenance of the planted terraces. It is not clear that the adjustments made in the October 2018 update are sufficient to alleviate this concern.
The excessive housing density in this plot is achieved by building up to mainly six storeys. This is too high for its location on the edge of Russia Dock Woodland. The height needs to be lowered by at least one storey, both to reduce the density and to respect the Woodland.
Right to Light and Privacy Impacts
The tall buildings will create significant shadowing impacts on multiple residencies, and on the Canada Water basin which will impact wildlife and plant life.
- Plot A1 breaks BRE Guidance on light requirements for residents in Orchard House and Columbia Point, and threatens to put half of Columbia Point into 2.5 hours extra darkness a day. This will impact on local amenities and wildlife. The shadow studies suggest it will impact the Canada Water Basin, encouraging algae growth and kill wildlife in the basin.
- Plot K1 will specifically overshadow and overlook two local schools.
Fundamentally, the developer is claiming that despite there being adverse impacts, that these are somehow not material. For example, their modelling is said to indicate that tube journeys to Canada Water and Surrey Quays stations will increase during the morning peak. It is suggested however that this pressure may be relieved by an interchange at New Cross Gate with the Bakerloo Line extension (not even a committed project!) and (much further away) an interchange at Tottenham Court Road with Crossrail.
Additionally, that as a result of this "increased inbound movement" passengers previously travelling to Canada Water and Surrey Quays stations "will seek alternative routes that avoid the area.", yet tens of thousands of additional passengers will simultaneously need to travel into the area for the up to 30,000 proposed new jobs.
Cycle parking is proposed to be provided in line with the minimum London Plan requirements. This is insufficient - cycle parking should be provided based on the standards in the draft New London Plan. The street network should also meet the "Healthy Streets" standards.
Overall, the feedback from Transport for London that "... there will be implications for the transport network from increased demand, and that mitigation is required to deliver transport improvements and, in particular, more capacity on public transport." needs to be addressed before this planning application can proceed.
Other infrastructure Impacts
The development will put extra pressure on other local infrastructure such as schools and health centres, but without any plans on how to increase them. As with transport, these services are already operating at or near full capacity.
Social and Heritage Impacts
Although the Masterplan is supposed to be an example of regeneration it offers no improvements for local residents and no improvement in quality of life. Any changes proposed that are being marketed as improvements (e.g. new leisure centre) are just re-building of what already exists (e.g. we already have a leisure centre in Rotherhithe which this replaces).
Even given the welcome improvements in ratios in the October 2018 update, the proportions of different types of residence still seem to be too biased towards studio and 1-bed flats, with too few 3-beds or larger. Given the lack of sufficient numbers of larger residences in the immediate area, this will prevent people establishing families and will force them to move out of the area, making the community increasingly transitory.
A specific number of affordable housing units by type should be stated and not dependent on grant funding, or at the very least the dependency etc. must be defined. The approach to determining “affordable” should also be stated.
The developer states that there is insufficient amenity space, and the proposed justifications are not acceptable – e.g. the reliance on existing, over-stretched space such as Southwark Park.
Making Plot K1 wholly "social and intermediate affordable housing" is not acceptable in terms of community cohesion and is incompatible with Planning Statement paragraph 7.3.90. This segregation is made worse by the physical distance of the site from the main nodes of the development.
The main energy objective of the draft New London Plan is for London to become a zero-carbon city by 2050. For this reason, the zero-carbon target that the 2016 version set for major residential developments is extended to include major non-residential development upon publication of the document which is expected in 2019. The developer does not even claim to meet the New London Plan requirements, nor is it clear that it meets the existing London Plan Policies. This is further evidenced by the failure to commit to achieving specific targets, and for the lack of ambition in the aspirational goals.
The development will reduce the per capita open space in the area, and put more pressure on other open space in the area, notably Southwark Park, Russia Dock Woodland and Stave Hill Ecology Park.
The Southwark Biodiversity Action Plan 2013 - 2019 states: "All major and minor developments should incorporate nesting or roosting sites for relevant species of birds and bats. Preference should always be given to 'built-in' features such as roosting bricks, bat tubes and bat bricks". The current design does not accommodate these features.
A minimum of 20% of parking spaces is proposed to be equipped with electric vehicle charging facilities with a further 20% with passive provision. This is insufficient - good practice would be for more parking spaces to be equipped initially, and all parking spaces to at least have passive provision.
Leeway to change plans going forward
The application seeks to reserve all matters for the Outline Proposals. It then states that "the Development comprises a true mix of uses which will be built out over a prolonged period of time and will encounter market fluctuations, full economic cycles and demand pressures. The need for flexibility is therefore paramount to allow the Development to respond to changing needs and patterns as future phases come forward for development.”
The degree of flexibility requested is far too great to allow any reasonable judgement on the merits of anything except the detailed proposals for plots A1, A2 and K1. The application should therefore not be allowed to reserve all matters for the Outline Proposals. Due consideration, in consultation with the community, the council and other relevant parties (such as TfL), of these “…market fluctuations, full economic cycles and demand pressures” should take place through submission of future detailed planning applications for specific sites.
The developer undertakes little consideration of the numerous other recent or planned developments that will have a cumulative impact on the viability of their proposal. The Convoys Wharf, New Bermondsey, Timberyard, and Biscuity Factory Bermondsey all have the potential to significantly impact the viability of this development - especially with regard to transportation, but also with regard to the balance of usage types (office vs. leisure vs. residential). This further undermines confidence in the sustainability of this development.