Southwark Green Party submitted today its objections to the Canada Water Masterplan.  Despite further changes made by the developers in response to mounting local opposition, the vast majority of our serious concerns remain unaddressed, and we continue to support the wider community campaign opposing the planning application.

See our detailed feedback, and email response template:

https://www.southwarkgreenparty.org.uk/cwmp

Just 8 days after the Council elections, British Land submitted its planning application for the Canada Water Masterplan – handily ensuring there was no opportunity to debate it during the election campaign.

Only three sites are set out in detail. Yet as the developer has submitted a “hybrid” planning application, British Land will not require any further planning applications provided they stay within these (very broad) outline plans.

Southwark Green Party has repeatedly raised serious concerns over the Canada Water Masterplan proposals, which have not been addressed.  We are now supporting the wider community campaign opposing the planning application.

See our detailed feedback, and email response template:

https://www.southwarkgreenparty.org.uk/cwmp

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.

Our response

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:

1. Summary Response
2. Overall Development Objectives
3. Building Height, Density and Usage
4. Right to Light Impacts
5. Transport Impacts
6. Other infrastructure Impacts
7. Social and Heritage Impacts
8. Environmental Impacts
9. Leeway to change plans going forward
10. Cumulative impacts

Final Response

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.

Dear Sir

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.

Plot A1

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.

Plot A2

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.

Plot K1

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.

Transport Impacts

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.

Plot A1 

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.

Plot K1

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.

Environmental Impacts

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.

Cumulative Impacts

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.

Regards

Build more council housing - not unaffordable luxury flats

Temporary tenants need to be able to obtain secure tenancies rather than being shuffled about from one address to another, and so relieving Southwark Council from providing secure tenancies. Secure tenants need to be able to retain their secure tenancies, rather than losing them by being forced to change to a housing association lease.

Leaseholders demand like-for-like replacements for their flats, in the local area – so they can remain with their community, and have no increase in commute to work. They reject any invasion of their privacy with financial assessments, and financial restrictions like the £16k rule. They demand the right to transfer any mortgages at the same repayment level. They should be able to pass on their homes to their children, make alterations, and let out the property if they so wish.

Labour claim they have built 535 new council homes, while on the Heygate Estate they have already destroyed 941 council homes and they are in the process of destroying 778 council homes on the Aylesbury Estate – a total loss of 1,719 council homes. Architect Liam Hennessy says: “When it comes to social housing Southwark Labour is a total loss. The right to return’ on the Aylesbury cannot be taken seriously because the number of council homes to be demolished is 778 greater than being provided on the ‘regenerated’ estate.”

According to the most recent independent monitoring of Southwark Labour Council’s record on council homes, they built a grand total of 13 council homes in the three years 2014, 2015, 2016! (London Plan Annual Monitoring Report 2015-2016, pages 108-109)

Southwark Labour claim they will build 11,000 new council homes by 2043. At the rate of 4.33 council homes per year – from the most recent independent audit of new council homes - it will take Southwark Labour 2,540 years to build their target of 11,000 council homes!

Left out in the cold by Southwark Council

Homes on the D’Eynsford Estate in Camberwell were left without any heating for days in freezing weather earlier this year. What really upset residents was that no one answered the emergency helpline at Southwark Council. One resident reported that it was only when they took to Twitter that they got a response from councillors - and then from Southwark Council. A heater was produced for them - but nothing for those who weren't so active on social media. The council demonstrated little care for the many elderly people living on the D'Eynsford on their own.

Reassurance, information about the repair schedule, and practical action like the loan of a portable heater is the minimum tenants should expect. The council’s communication with Southwark residents must improve.

Betiel Mehari is a single mother who became a housing activist to try to save her own home.

Betiel works in retail on a zero-hours contract. She lived on the Loughborough Park Estate in Brixton for 11 years, until her family lost their home when the estate was completely demolished by housing association Guinness Partnership in a £75m "regeneration" scheme. She was forced to leave Brixton, losing her much valued local community, with huge disruption to her family. ("That's what regeneration does," she says.) Rehoused in a smaller flat in Newington with no balcony, her two children (aged 11 and 10) are now commuting the lengthy distance from Newington to Brixton in order to maintain their educational stability and friends.

Furthermore, Guinness whacked up the rent in the family's new flat, from a "social rent" of £109 per week to a so-called "affordable rent" of £265 per week. Although Betiel had been a Guinness tenant for 11 years, Guinness claimed that demolishing her flat and rehousing her had created "a new tenancy".

Betiel says: "'Affordable' rent is a con. You'd assume it's based on wages, but it's not. It's set at 80% of market rents, not according to any measure of actual affordability. With two kids it requires an income of £35,000, which is higher than the national average. This measure puts us at the mercy of the housing market - it's absolute madness."

Members of the Wells Way Triangle Residents Association have organised informal workshops to help local people look at the plans for redevelopment of Burgess Business Park on Parkhouse Street. The proposal, dubbed 'Camberwell Union' by the developers, would create 505 residential units. The developers claim that with target profit margins of of 17.5% for private residential, 16.67% on commercial, and 6.0% on affordable units - agreed as 'reasonable' by the council's 'viability consultant' - they would not be able to provide 35% affordable housing.

After the 2014 local elections, Southwark's Labour-run council promised they would build 1,500 new council homes by the end of 2018. Now Councillor Mark Williams, lead for regeneration and new homes, has admitted "we will not be meeting this target".

Only 400 new homes will have been built - less than one-third of the local Labour promise. Southwark Labour's 2014 manifesto had promised 11,000 new homes, but it didn't say how long they would need to meet this pledge. It has since emerged that the Labour-dominated Council's official homebuilding targets stretch to the year 2043 - 25 years away from now.

In December, property developers Delancey put in an application to demolish Elephant & Castle Shopping Centre and London College of Communication. Councillors on Southwark Council’s Planning Committee refused to approve the plan, yet accommodated an eleventh-hour promise from Delancey to make an improved offer. This means the committee will hear the proposal again this month.

Meanwhile, the Shopping Centre is being run down, conveniently bolstering the claimed 'need' for demolition. Certain entrances are now being closed during trading hours (right). Empty units are no longer available for re-let, enhancing a 'ghost town' feel. Escalators have been left broken for long periods. Pedestrian access has been unsatisfactory since removal of subways. Yet the building is structurally sound and could be imaginatively refurbished, re-landscaped and re-clad. This would avoid nine years of environmental destruction, intense construction noise, degraded local shopping and leisure facilities, and enormous disruption to nearby residents' home delivery access.