This objection has already been submitted to the GLA. Feel free to paste / reword any of the text and email the Mayor of London and Peter Fortune, Penge’s GLA Member. We need at least 1000 emails to ensure success!
INTRODUCTION
This application is a gross overdevelopment which as the planning officer herself acknowledges in her report contains “a number of areas where the proposed development would transgress from planning policy requirements”
This proposal has several tall buildings, the tallest of which will be 16 storeys high.
London Fire Brigade has great concerns about safety which the developers have refused to take on board. Councillors on Bromley’s planning committee on all sides expressed concern about fire safety and the developers could not answer many of their questions on this (and other) issues. I urge you to read the LFB report.
The Bromley development committee passed this with the narrowest of margins (7 to 6 with 3 abstentions) ie. With less than 50 per cent support.
One of the reasons given for passing it was that – despite the development’s very many issues, it would help Bromley hit its housing target. However, as Cllr Kennedy-Brooks pointed out, the development would provide 30 per cent of the Borough’s housing target on one small site. This is indicative of the extent of the overdevelopment. It should be noted that the amount of affordable housing is minimal – around a third. It is of very poor quality.
As one (Conservative) Cllr on the development committee who opposed the development said – this wouldn’t be approved anywhere else in the borough.
The planning officer’s report was misleading in several respects. The summary is wrong to say the land is “under-utilised” – it is a site with a car park and shops on it. It is wrong to say “it will substantially improve the retail environment of Penge as a District Centre.” It will remove almost all the commercial parking, reduce the amount of commercial floor space and destroy the character and appeal of the high street in this tight-knit community. It will have devastating impact on heritage.
Here are just some reasons to reject this planning application:
- Totally inadequate social housing provision and poor quality homes
- Height and massing which even officers admitted were unacceptable;
- loss of commercial parking;
- loss of retail;
- fire safety;
- overdevelopment; detrimental to the high street;
- out of character;
- impact on heritage assets (did not meet London Plan or NPPF); impact on conservation areas;
- lack of amenity;
- loss of sunlight;
- privacy and overlooking (again officers deemed these unacceptable);
- breaches local plan (policy 47), London Plan (policy SD6), London Plan (Policy D9) and section 72 of the Planning Act.
OVERDEVELOPMENT
The revised proposal is to create 230 flats on 0.7 hectares of land, squeezed behind a high street. It would lead to an additional several hundred residents – in what is already a highly densely populated area. Penge is, as the Bromley Local Plan acknowledges at 1.2.22, one of the “more densely developed areas” of the Borough.
This is a gross overdevelopment which is out of keeping with the local area. It is a dramatic change of use from retail to high-density residential which is entirely inappropriate. It is noteworthy that the London Plan states that Penge has “incremental” residential growth potential. This proposal is NOT incremental.
TALL BUILDINGS – BREACH OF LONDON PLAN
It is self-evident that the proposal is an over-development which is out of character with the surrounding area. It is also contrary to policy 47 of the Local Plan which states:
“Proposals for tall and large buildings will be required to make a positive contribution to the townscape ensuring that their massing, scale and layout enhances the character of the surrounding area.”
It would also interfere with the view from Crystal Palace to Beckenham which the Council considers a view of local importance.
The London Plan says a high building should: “make a positive contribution to the existing and emerging skyline and not adversely affect local or strategic views ii mid-range views from the surrounding neighbourhood – particular attention should be paid to the form and proportions of the building. It should make a positive contribution to the local townscape in terms of legibility, proportions and materiality iii immediate views from the surrounding streets – attention should be paid to the base of the building. It should have a direct relationship with the street, maintaining the pedestrian scale, character and vitality of the street.”
The proposed redevelopment will not achieve the above – indeed, quite the reverse.
I also understand that tall buildings have a disproportionate impact on the environment. This is leaving aside the issue of embodied carbon.
COMMUNITY AND BUSINESS IMPACT
Penge has been largely neglected by the local council but the local independent shops have done their best to help the High Street thrive and have often put on small scale community events in Empire Square which are very well attended.
At 2.3.6 of the Bromley Local Plan, Bromley Council acknowledges Penge as an area of deprivation and an area for renewal but this proposed development will destroy the high street, local businesses and the local community.
Of the current stores on the site, I understand just one – Iceland – is due to return and with a reduced floor area (assuming it can survive an absence of circa three years while building happens). These practical shops act as anchor shops, attracting footfall to the other smaller shops, independent businesses and cafes.
The demolition of the multistory – the only public car park in Penge – will discourage people from coming to Penge to shop. They will simply drive through to Beckenham where there are several public car parks – or even Bromley.
The works will lead to prolonged disruption likely to push independent shops permanently out of business.
PARKING AND ACCESSIBIILTY ISSUES
The proposal will severely reduce the number of public car park spaces from 190 to 24. It is essential to the local shops that people have the option to visit them by car. This includes local residents. Many people who are not entitled to a disabled car park permit, nonetheless have mobility or other needs and require easier transportation access to the shops.
The current car park allows direct access by lift to the Blenheim shops greatly increasing accessibility for everyone, especially those with mobility or other needs.
This is our town centre and – like every town centre – it needs and deserves a public car park to allow it to flourish and indeed, to survive.
No car park spaces have been allocated for the proposed 230 flats. This is unrealistic and will only lead to increased car park pressures in the surrounding streets. It will also mean that any self employed person who needs a vehicle for their business will not be able to live in these flats.
I understand that the applicant has recognised there is a parking shortfall against the London Plan l in its “updated travel plan” which admits that the London Plan requires an addition 7% of the units to be given parking spaces “which could not be accommodated within the public realm dues to the constrained nature of the site and the severe adverse impact it would have on the proposed pedestrian/circulation space and landscaping in the public realm.”
I understand that the PTAL rating has been described as 5 when in fact much of the area falls within PTAL 4 and that as such there should be provision of parking for the proposed residential flats of around 100 spaces.
Since the proposal was put in, there has been a severe reduction in two train lines into London.
Apparently there will be space for 400 bikes but as the Councillors noted at the planning meeting, there are no cycle lanes in Penge and already pedestrian have to dodge the very many delivery bikes. 400 bikes is a pie-in-the-sky figure.
OUT OF KEEPING WITH THE LOCAL AREA; CONSERVATION IMPACT HERITAGE
Historic England has objected to the applications (see attachments). Likewise the Victorian Society.
Penge is an outer London suburb mainly with low rise buildings of Victorian and Edwardian character. It is NOT an urban area.
Penge High Street forms the Penge High Street Conservation Area and is close to the conservation areas of Alexandra Cottages and the Alms houses at Waterman Square.
The Bromley Local Plan states at 1.3.15 that its objective include “Continue to conserve and enhance locally and nationally significant heritage assets. Ensure development complements. and responds to local character, and the significance of heritage assets, including their settings. Encourage greater accessibility of heritage assets.”
Policy 42 of the Bromley Local Plan says “A development proposal adjacent to a conservation area will be expected to preserve or enhance its setting and not detract from views into or out of the area. “
The Local Plan also refers to Policy 4 Housing Design which states:
“All new housing developments will need to achieve a high standard of design and layout whilst enhancing the quality of local places. Housing schemes will also need to respect local character, spatial standards, physical context and density”
Policy 37 of the Local Housing Plan states new developments “should complement the scale, proportion, form, layout and materials of adjacent buildings and areas”.
The Local Plan also states: “Policies 3.5 and 7.4 of the London Plan emphasise the importance of new developments taking account of physical context, local character and a design approach that has an understanding of place.”
And at 2.1.54 it states: “The Council’s primary objective is to ensure a high standard of residential environment. Redevelopment should be of a design that is sympathetic to and complements the surrounding residential area but not necessarily a reproduction of the established form and pattern of development.”
The London Plan states at 3.3.8: “Buildings should be of high quality and enhance, activate and appropriately frame the public realm. Their massing, scale and layout should help make public spaces coherent and should complement the existing streetscape and surrounding area.”
The proposed development is contrary to all of the above.
LOSS OF LIGHT
There will be a huge overshadowing effect, not just on neighbouring houses which have a right to light, but also on the High Street itself. This is the heart of Penge and a place where people often spend time not just shopping but chatting with neighbours. It would no longer be a desirable place to spend any time in the shadows of a massive tower block plus several other high rise buildings..
People will be much less likely as a result to visit Penge High Street or spend time there.
This is contrary to Policy 37 of the Bromley Local Plan which states that “-The relationship with existing buildings should allow for adequate daylight and sunlight to penetrate in and between buildings.”
Policy D6 of the London Plan states that a development should “ensure that appropriate shade, shelter, seating and, where possible, areas of direct sunlight are provided, with other microclimatic considerations, including temperature and wind, taken into account in order to encourage people to spend time in a place.”
No one is going to want to spend time in the shadow of a tower block.
LOW QUALITY HOUSING
The proposed flats are mainly studio, one and two bed apartments, with about 6 per cent three beds. They are not designed to attract families. There is no private outside space. They are cramped and no private outside space has been provided – only a small pocket park. It is striking that the original plan only allow for one lift and was only amended to include two lifts after a local resident commented on social media about the inadequate lift provision which would be a safety risk.
AMENITIES
The proposed development will remove local amenities in the form of reduced shops. The pocket park is inadequate as a leisure area or a means of improving the public realm. The proposed development does not include any community amenities for example a cinema, or a low-cost community centre.
TRAFFIC AND ACCESS
This is a tiny space and access will be very difficult both for the residents and emergency vehicles. The high street already attracts traffic not only for the shops it has but because it is a route to Beckenham. This development will make the situation much worse.
CONCLUSION
The above objections are only some of the gross inadequacies of this application which in contrary to many policy objectives and planning considerations. It would devastate the economy, community and heritage of Penge and bring no benefit to its businesses and residents.