Section 1: Introduction
Below are additional reasons for my formal request that the Mayor either rejects outright or calls in Planning Reference 23/00178/FULL1.
Quite simply, while everyone is sympathetic to the fact that London needs more housing, this should not mean that every planning application which involves housing should be automatically approved: Some applications are so grossly inappropriate and damaging to the local community and to London as a whole that they should be rejected.
In this case, Bromley Council and the Hadley Property Group are planning to cram 230 ‘rabbit hutch’ homes into a tiny 0.7ha site, which will be an eyesore, damage local businesses, and destroy the light and outlook for the surrounding conservation area and neighbouring homes.
The proposed homes only barely conform to size standards, do not comply with fire safety protocols and are acknowledged to be noisy and unpleasent to live in. In addition, only 36 socially rented homes will be provided, which is completely inadequate.
Additional reasons to reject the proposals are set out below, mostly summarised and copied from previous objections.
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Section 2: Summary of objections
2.1 These towers are not green. They are not clean. They fulfil neither the spirit nor the
letter of Bromley Local Plan and its vision for the people and places of the Borough.
2.2 If the Planning Committee approves this application there would no longer be any
purpose for the planning process – nobody in Bromley would have protection from any
outrageous project proposed by a developer.
2.3 As for the fire hazard, this is crazy irresponsible. Anyone can see that a cramped space
like this, for the height and width of these buildings, has inadequate access for fire
appliances. Fires break out more and more frequently due to the hazards of rechargeable
batteries – as everyone is aware. Most of the criticisms raised by London Fire Brigade and
knowledgeable residents have not been corrected in the revised application.
2.4 I object to this planning application because it is a gross over-development. It is not an
investment into Penge, but extracts from it, removing wealth, jobs, amenities, facilities,
and wellbeing. It is energy intensive and harms or destroys existing wildlife.
It does not “complement its surroundings, respecting the existing scale and layout” (ref
Bromley Local Plan para 1.3.12). There would be a drastic change in the skyline.
It would create, not regeneration, but degeneration: urban blight, poverty, poor health, and
unhappiness.
2.5 The site is too small and far too close to homes and the high street. There is substantial
risk of damage to surrounding buildings: cracks, structural instability, and risk of flood
from displacement of underground water. Local owners and tenants are at
high risk of enormous mental stress and financial costs. Local basements already fill up with water from underground rivers, and for example Penge Congregational Church in 2023 suffered high costs from basement water damage and the need to install pumps. None
of these very real risks to other people are addressed by the applicant.
2.6 Pile driving and construction noise will create terrible noise right beside people’s
homes and businesses, and continue for years. This is particularly relevant to the many
cafes, and to solicitors, the two music shops, hair and beauty services, the craft
store, and the many places where the ability to hear is important.
2.7 Demolition and construction creates huge amounts of dust and dirt. This will settle on
food (including fresh meat, fish, fruit and vegetables on open display) and other goods in
shops and cause further damage to businesses. The planning committee should
consider how the many shops in the immediate vicinity of the site can continue in business under these circumstances.
2.8 It threatens the high street business community as well as the vibrant and supportive
social community of Penge. Loss of retail would badly impact the community and create
more need to travel.
2.9 This proposed development is incompatible with the needs of Penge in terms of:
- High existing population density;
- Already inadequate transport, health services, and car parking;
- Well-being of the residents;
- Local architecture;
- Visual amenity of Penge, both locally and from a distance;
- Dark and cold at street level and people’s homes, with strong winds blowing dust and litter
- around pavement cafes;
- The local business community and district town centre;
- Local wildlife;
- The high carbon impact of tall buildings and increased pollution.
- The open through routes and oppressive feel designs crime “in” not “out” (as is required
- under planning policies).
2.10 It does not improve Penge. It is not a positive plan. Social wellbeing will decline.
Deprivation would increase. Health would further decline. Employment would decline.
Economic activity would decline. Penge cannot thrive with this.
The proposal is in direct opposition to Council Policies 12, 13 and 14 which refer
specifically to Penge as one of the Borough’s most deprived areas. It does not fulfil any
aspect of Policy 37 (General Design of Development).
2.11 The change in use of the plot would create an imbalance in the local community, with
too many people and cars for the amount of essential services and facilities.
Section 3: Detailed objection as regards environmental considerations
“The proposed development is neither green nor clean”, as follows:
3.1 Greening and biodiversity calculations
The local estates including Burham Close, Greatstone House and Strood House are
surprisingly good environments for wildlife. There are mature gardens, bushes, trees, and
substantial areas of flower-rich meadows supporting an array of insects. Local residents
report routine sighting of many bats.
The reports included as part of the planning application claim an increase in biodiversity.
This is based upon calculations of the amount of planting included in the development.
However it ignores the fact that much of this planting simply replaces existing
biodiversity. The losses are not taken into account and so these figures are meaningless.
Losses are as follows:
(A) Mature plane trees will be lost
(B) Bat colonies will be lost
( C) Flower-rich meadows will be damaged by reduction in size and by loss of daylight
with associated wind, dryness and cold.
(D) Associated insect colonies within the flower-rich meadows will be damaged
(E) Associated birds that feed on the seeds and insects in the flower rich meadows will also
be damaged.
3.2 Loss of mature plane trees
The reports fail to draw attention to the removal of these trees. Only by closely examining
the diagrams in the report “Landscape Strategy 3.0″ can you see that the five mature
existing trees are no longer there.
Elsewhere the planning application attempts to justify removal on the basis of mower
damage to roots. This is a false justification, as these are healthy trees in good condition,
with trivial foot passage scuffing on one exposed root . Trees obviously are unaffected
by this. All of the trees are self-supporting and none of them are ‘leaning’ as claimed in the
application. Two of the smaller trees are growing at an angle (not vertically) but have
never been assessed as unsafe and look sound and in good condition.
In my earlier objection (which is still valid) I provided a set of photographs to prove these points.
Lovely big trees are important for mental health and wellbeing. Large trees obviously are
more effective than small trees in terms of air quality and carbon reduction as they: Put on
more growth each year; Produce more leaves (and bark) which collect and safely
process
pollution; Transpire more which cleans the air of pollutants especially volatile organic
compounds.
3.3 Bats
The Bat Conservation Trust advises that trees are the natural habitat for bats, which use
different parts of the tree at different times of the day and times of the year. Trees with
rough and uneven bark provide the necessary crevices for bats to hook onto:
mature plane
trees do exactly that. Local residents of the Blenheim/Arpley estate advise that large
numbers of bats are seen roosting in these trees.
The Bat Conservation Trust further advises that removal of bat roosts is a criminal act.
This is fully recognised by “Bromley biodiversity species action plan: bats”.
The action plan goes on to state:
“Threats to bats in London Borough of Bromley:
- Loss of maternity roost sites in buildings and/or trees
- Loss of and disturbance to other roost sites [etc]
- Loss of insects due to inappropriate management of insect-rich feeding habitats such as
grassland, woodland and wetland. - Disturbance to commuting routes – may be due to loss of or inappropriate management
of flightline features such as trees, hedges, river corridors
All bats present in Bromley are London and Bromley Priority Species.”
All these threats will occur if this application is allowed: loss of roosts, loss of insects,
disturbance of commuting routes – and also the dust, dry air, pressure changes, and noise of
demolition and construction are injurious to bats. It is unlikely that
any local bats will
survive.
The provision of bat boxes in the towers as described in the planning application would do
nothing to mitigate these effects.
From the planning application I quote:
6.9.5
‘A survey was undertaken in July 2022: - a detailed systematic daytime external inspection noted LOW POTENTIAL value for
roosting bats in the warehouse building on site. No internal roof voids were present in the
building and so internal inspection was not considered necessary - emergency surveys undertaken confirmed the likely absence of roosting bats in the
building - no foraging or commuting bats were recorded at the time of the survey’
This casual and superficial survey is inadequate and unacceptable. It does not conform to
UK law and a full survey is required to determine what species are present.
The number of blocks needs to be reduced and the trees allowed to stand, incorporated into
the design rather than removed from it. This would enhance the space for wildlife and also
for the people who live there.
3.4 Importance for residents
The trees and wildlife greatly enhance the quality of life of local residents.
Many of these residents live deprived lives of financial hardship and disablement. Their
lives will be harmed by loss of sunlight & warmth, overlooking, harms to the gardens,
damage to wildlife, cold winds, loss of trees and loss of views of the sky.
3.5 Local Green Space
Under Bromley Local Plan, a Green Space is “demonstrably special to the local
community and holds a particular local significance for example because of its beauty,
historic importance, recreational value, tranquillity or richness of its wildlife. Local Green
Space must be local in character and not cover extensive tracts of land. Its special qualities
are described in Statements of Significance. The level of protection afforded to Local
Green Space is commensurate with that of the Greenbelt in that harm to special
qualities will only be allowed in very special circumstances.”
The trees and wild flower meadows amply fulfil the definition of Local Green Space and
should be protected by the planning process.
3.6 Carbon use
The renewed planning application recognisees that construction uses huge amounts of
carbon.
Reference Whole Life Carbon RIBA Stage 2 loaded 26 Jan
“The key action with largest carbon emission reduction is the redesign of the building with
fewer floors.
….new buildings, while potentially more energy efficient,
typically use more construction products and therefore often have higher upfront
construction carbon emissions compared with refurbishment….”
New buildings may sometimes be more energy efficient – but it is known that tall buildings
are not energy efficient. This is because of the short lifespan (only 60 years); Energy
intensive operation and maintenance, with lifts using a lot of electricity; Much
higher heating costs due to cold air at height.“
When a lifetime assessment of the environmental impact is made, tower blocks come out
very badly. This is well-known, and is described and referenced in an important letter from
Andrew Boff AM, Chair of the Planning and Regeneration Committee, dated 2nd
September
2021, headed “Housing typologies investigation findings”.
The likely damage to surrounding properties carries an additional carbon cost.
3.7 Congestion, journeys, and air pollution
The demolition and construction will create very substantial amounts of dust which will
affect people with lung conditions, and harm wildlife especially bats.
By contrast the planning application claims that it will reduce air pollution by preventing
new residents from owning cars – in reality impossible, and the reverse will happen. There
will be many more cars with nowhere to park, resulting in cars trawling round
local streets
until they can find a kerbside space.
Also there will be less retail and this too will increase the need for journeys as people have
to travel to shop, instead of walk as at present.
3.8 Noise pollution
The proposed site is immediately adjacent to many homes and businesses. Demolition and
construction work is very noisy and this further harms wildlife, residents and business and
cultural activities.
The noise will go on day after day for years, right beside existing homes. This is just a
terrible thing to do to people.
Section 4. Bromley Local Plan – Contraventions
The revised planning application is still in indirect contravention of most of Bromley Local
Plan.
4.1 Paragraph 2.9 of Bromley Local Plan states: “Within the Town Centre boundary,
development proposals will be encouraged and expected to contribute positively to the
vitality and viability of the Town Centre.”
This proposal would do the exact opposite. There are no measures that mitigate the years
of noise and disruption, the loss of daylight and of attractiveness to visitors, and loss of
parking. Short-stay parking will become impossible – due to loss of multi-storey
car park, introduction of parking permits, and the many additional vehicles needing to find roadside
parking.
Many cultural, creative, and social activities will suffer for the same reasons.
4.2 It is specifically against policies 13, 14 and 15 which apply directly to Penge.
Policy 13 Renewal Areas
The Council will seek to maximise opportunities for enhancement and improvement within
the Renewal Areas. Proposals should provide demonstrable economic, social and
environmental benefits and address identified issues and opportunities.
For example, proposals will be expected to maximise opportunities to:
a-deliver high quality environments, which complement and enhance existing development
and ’assets’, including built heritage and other environmental assets,
b – support health and wellbeing ….
e – make a positive contribution to the vitality of local centres having regard for their
importance as providers both of local facilities and local employment…
Policy 14 Development Affecting Renewal Areas
The Council will require development in, or close, to Renewal Areas to demonstrate that
they maximise their contribution to economic, social and environmental improvements…
Policy 15 Crystal Palace, Penge & Anerley Renewal Area
Proposals within the Crystal Palace, Penge & Anerley Renewal Area will be expected to
take advantage of opportunities:
a – to enhance Crystal Palace Park …
b – which create benefit to the wider area …
c – to support renewal in Penge Town Centre.
4.3 The London Plan is not fulfilled: London Plan paragraph 2.63A states “the overriding
objective of the Mayor’s regeneration programmes is to drive and shape growth in
London’s town and economic centres and high streets. A focus on these renewal areas can
contribute to a reduction in health inequalities, improve links to employment opportunities
and improve the overall ‘well-being’ of the area.”
Instead the exact opposite will happen.
4.4 the amenity value of Penge and Crystal Palace Park (from where it will be visible and
intrusive) is reduced. An amenity is defined as “Element of a location or neighbourhood
that helps to make it attractive or enjoyable for residents and visitors” (London
Plan 2016).
4.5 the Environment Agency’s requirements as laid out in their report have not been
fulfilled.
4.6 Bromley’s policies for tall and large buildings, and for respecting local architecture and
the character of local places are not fulfilled. The impact on local character, the local
heritage assets, the wider historic environment and on important views would
be strongly negative and harmful.
Policies that are not respected include:
Policy 47 Tall & Large Buildings
“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. Proposals for tall buildings will be
required to follow the current Historic England Guidance.”
Paragraph 5.1.20 “Tall buildings are those that exceed the general height of their
surroundings and cause a significant change to the skyline. Much of the Borough is not
considered appropriate for tall buildings due to the established suburban character of
the Borough. However, potential may exist for such development to be considered in town
centre locations which benefit from good public transport, exhibit an existing local built
character that would allow for taller buildings, and where no harm would be caused
to heritage assets, the wider historic environment or important views.”
Paragraph 5.1.22 “Views of local importance:
From Addington Hills of panorama across Crystal Palace, Penge, Beckenham and
Greenwich towards Shooters Hill, Isle of Dogs and Blackwall Reach
From Crystal Palace Park of Bromley, Beckenham and West Wickham” [an area that
obviously covers Penge itself].
4.7 Numerous national and local policies cover the need for natural light, and describe the
negative effects on people’s wellbeing of being overlooked. The application shows that
local people and the highstreet would be badly affected.
Businesses, homes and visitors would have their natural light cut significantly by a 16-
storey block complex. This includes the following roads: Penge High Street, Croydon
Road, Maple Road, Evelina Road, Pawleyne Close, Franklin Road, Burham Close & Frant
Close.
All these roads are densely populated meaning that many people will be
significantly affected. Loss of the sun’s heat means more energy costs keeping residences
warm. Psychologically, prolonged deep shadow has been shown to adversely affect wellbeing.
4.8 The reduction in retail increases the need for travel which also is in direct
contravention of all modern planning policies.
4.9 Modern Sustainability policies are not fulfilled.
From the letter from Andrew Boff AM, Chair of the Planning and Regeneration
Committee, 2nd September 2021, headed “Housing typologies investigation findings” I
quote: “Energy use is higher in tall buildings, with electricity use twice as high due to increased
solar gain. The taller the building, the higher the amount of embodied energy required per
useable square metre as low-carbon materials such as timber are not viable.
Tall buildings also suffer more from heat loss for the same amount of insulation as lower buildings
because of the higher wind speeds, as well as other conditions prevalent at higher altitudes,
including more wind and colder temperatures.
The Committee finds there is a growing evidence base demonstrating that tall buildings are
less sustainable than those which provide a similar quantum of development in other
configurations.”
The letter is fully referenced and should be referred to for further information.
The London Plan describes sustainable communities as ones where people and live and
work and access their needs without need for travel. This proposal does the opposite, by
increasing the number of people – but decreasing employment and access to essential
facilities.
4.10 To carry out this development is contrary to Bromley’s vision statement “The
Council, local people, organisations and businesses work together to ensure that we all
enjoy a good quality of life, living healthy, full, independent and rewarding lives.”.