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.  You can find more detail on the planning application, and our work to develop a detailed 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.

Draft 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.  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.

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).

Proportions of different types of residence 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

Left to right: Barbara Pattinson (SE5 Forum), Eleanor Margolies (Southwark Green Party), Magda Devas (Women's Equality Party, Lambeth), Becca Thackray (Green councillor, Herne Hill ward, Lambeth), Jemima Hartshorn (Mums for Lungs)

Eleanor Margolies and Phil Vabulas from Southwark Green Party were delighted to join a study trip to Walthamstow - to walk around the streets that have been transformed by reducing through motor traffic. The walking tour was led by Paul Gasson of Walthamstow Village Residents' Association, and Dan Kelly, a parent and school governor.

The walk took in streets alongside a primary school where children are now able to walk, scoot and play without fear of constant passing traffic, the largest street market in Europe, new squares for community use and thriving parades of small shops.

One of five newly elected Green councillors in Lambeth, Becca Thackray said the visit was: 'A breath of fresh air to see just what can be achieved, in terms of traffic calming, pollution-lowering, urban greening and improving physical, mental and community health'.

We support the Liveable London campaign and are pleased to see the London Cycling Campaign and Living Streets working together, showing that we have common interests as people who want safer, more pleasant streets, whether on foot or on cycle.

If elected as councillors, we will do everything we can to implement policies to make it easier and safer to walk and cycle.

Southwark Greens have been working for more action on air pollution in Southwark since 2011. Our actions include:
• triggering the first full council debate on air pollution
• putting up nitrogen dioxide pollution monitors near schools in Peckham, Camberwell and Dulwich
• taking a 500+ signature petition to the Mayor for cleaner buses through our area
• running a free Travel Clinic at Brunswick Park summer fete to help people work out how much they could save by giving up a private car
• planting a pollution screen round Goose Green Primary school playground

More details here.

Southwark Greens have opposed Southwark Council’s plans to demolish Peckham Arch and asked the Mayor to look at how these plans fail to take into account TfL’s identification of a high potential for walking and cycling in Peckham.

We support CS4 - a cycle route going between Tower Bridge and Greenwich - and would like Southwark Council and TfL to work together to fill in the missing pieces. We support the idea of a new bridge across the river for pedestrians and cyclists - the Brunel Bridge. 

Why do councillors ignore residents' views?

Last year, Southwark Council ran a consultation on its proposed 'Southwark Spine' cycle route. Local people and road safety experts said the designs would make cycling more dangerous, especially around Bellenden Road. In fact, 63% of people who replied opposed it.

But just before the election was called, one of the Labour councillors for this area, Ian Wingfield, signed off the scheme.

Eleanor Margolies says: "This makes a mockery of the idea of consultation. The Southwark Spine was meant to make cycling safe for all ages, from 8-80. Hundreds of people took the time to write in with their concerns. I can’t believe Cllr Wingfield has ignored us all. I will listen to residents and fight for a better scheme that reduces motor traffic and is safer for everyone."

We asked Southwark Greens what they've been up to to keep the streets tidy...

What do you do when you see a bike rusting away on the street or on a council estate?
Eleanor: It's sad to see an unloved bike! I do a quick check that it really is abandoned. Rusty chains and missing wheels are a good clue. Then I report abandoned bikes on the Southwark Council website. The council cleaning team puts a note on the bike, giving a week or two for it to be claimed by its owner.

What happens next?
Eleanor: After a further month in storage to allow owners to get in touch, unclaimed bikes are passed on to local charities like the brilliant Bike Project on Champion Hill. They refurbish old bikes and donate them to refugees. Someone gets a bike of their own and the freedom to get around locally. A bike parking space is freed up for other people who need to use it. And we all get rid of a trip hazard and eyesore. It’s win-win-win!

Our stations are dangerously overcrowded

Local people are increasingly worried about overcrowding at Denmark Hill and Peckham Rye stations. Susie Wheeldon, who lives in Peckham, says: "It’s scary to see platforms and entrances jam-packed at rush hour. And it’s unbelievable that there’s still no step-free access at Peckham Rye!"

Rail fares rose by 3.4% on 1 January — up to £150 extra per year. Fares have risen twice as much as pay in the last eight years. Shareholders made billions of pounds in profits last year, while passengers saw services delayed, disrupted and cancelled. This has to change.

We’re calling for a new exit at Denmark Hill and for lifts to be installed at Peckham Rye as a matter of urgency.

Southwark Council has received funds from Transport for London to create Quietway 7 from Elephant and Castle to Dulwich. The Quietways are designed to be safe and pleasant for people aged 8-80, of all abilities, for trips to school, work and shops. No lycra required! The changes will also improve the streets for people on foot, including new crossings along the route, and wider pavements outside Brunswick Park on Benhill Road.

But contractors working for Notting Hill Housing on Edmund Street put in two new humps along the Quietway route – and made them the wrong shape!

Southwark Greens support the cross-party local campaign for a tube station at the Bricklayers' Arms.

At a well-supported demonstration on Saturday 4 November, Peter Wright from Living Streets demolished the claim that it would be ‘too close’ to other tube stations – it’s farther to any of the nearby stations than the average distance on the Bakerloo line. Simon Hughes pointed out that the original plans for the Jubilee line didn’t include a stop at Southwark – now a very busy station. Caroline Pidgeon pointed out that major investment and disruption are already proposed for the construction of a ventilation shaft - constructing a station would be a relatively small additional cost. And a tube station need not be a large building, since most of the business happens below ground – Bermondsey tube station is a good example of this.

Eleanor Margolies from Southwark Green Party affirmed the local party’s support for a station at Bricklayers' Arms and asked for it to be set in the context of local travel needs.

Southwark Council is consulting on the status of Camberwell Grove. The road goes over the railway via a bridge, just south of the junction with McNeil Road. This bridge has been closed to all motor traffic since October 2016, due to structural failure.

The council website says: 'Repairs to the bridge will soon be completed by Network Rail, which will allow it to be reopened for small motor vehicles (under 3 tonne) with traffic lights allowing alternate one-way flows to cater for both north and south-bound traffic'. The council wants to hear your views before taking a final decision on reopening the bridge. The consultation page is here (closing Monday 30 October).

We encourage Southwark residents to respond. Read on for our comments.