PLANNING CONSULTATION DEADLINE Midnight on Monday 8 August 2022
See application details and impacts here !
Wyndham Redcar Proposal
A planning application has been submitted for a new housing complex behind Clarendon Terrace on Camberwell New Road. This would create a new public road in Camberwell, for the first time since the early 20th Century. It would remove Pedestrian Priority from Miah Close, forcing residents & traders (including the elderly, and sheltered housing tenants) onto one narrow strip of footway, which will only run along one side of the road.
The deadline for comment or is Midnight on Monday 8 August 2022.
The details of the application can be found here (Application Number 22/AP/1095):
Email to Object: email@example.com
Objection Reasons[edit | edit source]
Unprecedented Creation of A New Public Road Behind Buildings on an Arterial[edit | edit source]
- There is no precedent for creating a public loop road directly behind buildings, including a shopping parade, on an arterial main road, part of the TLRN. Architects, officers and councillors were invited to offer an example of a precedent, and could not do so
- Best practice in similar developments is to create an estate road with a barrier that remains private, therefore only for the explicit purpose of accessing the development
- The decision to create a new road appears to be a reaction to the insistence by many locals and planning guidance that the new development should be car free. The idea appears to be to expand the available public road space for parking, to enable local car ownership to grow with the development. In other words, there appears to be a resistance by planners to the idea that the number of cars owned locally might fall or even remain static as residential density increases.
- It will be the first new public road created in Camberwell since before World War 2
- It will add capacity to the network, which is against the idea of Induced Demand expressed in Government guidance
- It will add an additional local traffic source to the network, by increasing car ownership on the site and in the new road
- It will be a one way road without contraflow for cyclists
- It will annul an existing deed right of two-way access belonging to Camberwell New Road shops, with no offer of compensation, minimum safeguards for access or alternative provisions for visitors. Traders currently use Miah Close in a way which reflects the benefits of the deed right of way, including:
- receiving visitors to shops
- receiving deliveries and loading and unloading directly from their rear gates, at a sustainable pace which is inconsistent with a through road
- access by pedestrians and cyclists with pedestrian priority, so that vehicles do not have the expectation that walkers and cyclists will move out of the way (unlike in Farmer's Road, the public road opposite)
- use by pets, including cats belonging to local residents, which is manageable due to the low average speed of motor vehicles along the Close (between 3mph and 5mph)
- In disregarding the covenant as reflected in current usage, the proposals do not have regard to existing local amenities including shops, as planning policy requires
- Loss of the covenant will mean there is no remaining safe space for shops to receive visitors
- At the same time as the right of way is proposed to be removed, red route visitor spaces are also being removed in the area, and this is likely to happen to the shops as well as part of policy direction
- The effect of the new road is that traders and suppliers will have to drive around the whole development, with no guarantee that the road is clear of vehicles servicing one of the 100 properties on it.
- It will increase traffic at a red route junction point where congestion and traffic are already an issue
- The new road will add to dangerous interactions at the junction with Farmer's Road, where early right turns are common (in which cars travel on the wrong side of the road to overtake traffic, and then turn directly into their target road on the right)
No protection for pedestrians[edit | edit source]
- There are no safeguards or guarantees in place of minimum footway width on the new road, or even that a footway will be provided on both sides
- The new footway is not of sufficient width to comfortably accommodate two-way pedestrian traffic
- The proposals extinguish existing pedestrian priority on Miah Close, enjoyed by Carey Court residents and Camberwell New Road traders and residents accessing their properties via the rear
- Pedestrian priority is best practice for new housing developments, reflected in the provision of estate roads rather than public roads on the land being developed. No explanation has been provided for this dilution of pedestrian rights in the current proposals
- There are no protections in place guaranteeing any kind of maximum speed limit on the new road commensurate with the existing average of between 3 and 5 mph on Miah Close
- There are no protections in place against the introduction of speed bumps, which would be likely to damage trade vehicles supplying local businesses, as well as create unacceptable noise for occupiers of adjacent properties
- There are no protections in place against the introduction of electric-vehicle chargepoints on the scarce footway provided
- It appears that the current designs will permit cars to drive directly past the gates of Camberwell New Road properties at the rear, despite the Council being advised that these are routinely accessed by foot
No cycling contra-flow[edit | edit source]
Cyclists will have to go fully-round the development in order to access properties or areas at the east side of the road. This is contrary to LTN 1/20, which sets out that all new planning developments should encourage and enable walking and cycling.
[edit | edit source]
- New social housing tenants who may occupy the site have not been asked whether they would like to be surrounded by a public road, in addition to the busy Wyndham Road, or whether they would prefer the alternative pedestrian-priority design approach proposed by the Miah Close side.
A public road would mean no protective covenants are possible for adjacent stakeholders[edit | edit source]
- Given the significant impact of proposed development, and great difficulty in preventing future car ownership of new residents, any road on the development site outlined in red should be a private estate road. This means it will be possible for Southwark Council to grant protective covenants ensuring that promises made on condition of planning grant are kept on:
- not breaching maximum speeds on the development to be negotiated in the planning phase
- not breaching maximum car ownership on the development to be negotiated in the planning phase
- not breaching privacy beyond that to be negotiated in the planning phase
- not breaching street light intrusion beyond that agreed in the planning phase
- not breaching outlook beyond that to be negotiated in the planning phase
- not compromising on pedestrian or cyclist access and pedestrian width space at any point, beyond that to be negotiated in the planning phase, including for example not installing EV chargers or cycle hangars which were not explicitly marked out in the planning grant
- covenanting to ensure a clearway for traders to both access and exit their premises at all times and without exception
- The introduction of a public road breaks the link between the site and adjacent land, meaning that it is no longer possible to secure the types of protection vital to ensure a minimum quality of life and a minimum level of practicable trading for local shops.
Planning Officers misrepresented the Police Secured By Design Report, in order to rule out a walking route[edit | edit source]
- Planning officers misrepresented the Police Secured By Design report as having ruled out new walking permeability in principle, when the report said the opposite.
- This was done by:
- refusing to supply the report when requested, or even prior to formal planning application
- paraphrasing the report to the effect that walking permeability was seen as a crime risk by police officers, when this was not the case
- Subsequently, the same officer from the Police Secured By Design team visited the site for a clarification meeting with local residents
- At that meeting, the officer clarified that a direct walking route would be the safest permeability option, whereas Southwark Council officers had described it as the most dangerous
Assurances of Access for Miah Close Traders are not adequate[edit | edit source]
- The creation of a public road means that any proposed arrangement of parking spaces is completely irrelevant for the medium term, as it will then be part of a wider zone, and its parking arrangements can be completely revised in the context of perceived needs for parking within that CPZ zone.
- A senior Council officer has already written to the Project Steering Group to confirm that it is intended to review the two small loading bays included in the proposals, "to see whether they are still needed", at the next CPZ Review.
- There is therefore no guarantee of loading bays designated for traders remaining after the next CPZ review, since planning officers have already indicated an intention to "test whether they are still needed"
- Officers have provided no details about what this loading-bay needs test is, how it is defined, or whether local traders have any input into it whatsoever
- The existing pattern of CPZ planning is for visitor and loading bays to be removed without consultation of local businesses (i.e. consultation is only done with local residents)
- Examples of Southwark Council's parking bias towards local motorists and against local shops include:
- the replacement of a visitor space, rather than a local-motorist space, with a new cycle hangar in Farmer's Road, opposite the development
- the stationing of a local-motorist CPZ space directly outside the Farmers Road Post Office frontage:
- partially blocking it from sight by passing custom
- physically blocking direct access from Farmer's Road to the kerbside by the Post Office for cyclists and walkers
- physically blocking access to Royal Mail collection vehicles, which are routinely forced to park on the red route segment of line next to the junction, due to the hindering presence of local-motorist cars in the CPZ space by the Post Office frontage
- placement of local-motorist-only parking directly outside and adjacent to the frontage of the grocer Food Link, further along Wyndham Road
- placement of local-motorist-only parking directly outside the parade of shops on Camberwell Road which includes Edwardes Cycles
- Due to the above-cited examples, Camberwell New Road traders have no expectation that any CPZ review of their requirements will incorporate their needs, rather than the current programme of maximising local car ownership instead
Assurances that new residents will not own cars beyond the disabled provision are not robust[edit | edit source]
- Zero-car provisions based on not issuing CPZ permits are yet to be confirmed in the drafts of new-resident leases and rental agreements
- Existing zero-car provisions in other Southwark developments are weakly enforced
- Southwark's development on green space by Bolton Crescent is an example of where zero-car provisions were entered and then ignored, with the result that the pedestrian access-way into Kennington Common is now routinely blocked by cars belonging to residents in that development, parked on double-yellow lines and unenforced.
- The Council has shown itself unable to engage in a dialogue with residents about car dependency, despite the many proposals made during the Steering Group process since 2016 on car sharing, improving walking and cycling routes, improving local junctions for cyclists and walkers and protecting local shops in order to ensure adequate local service provision.
Limited consultation with stakeholders on-site[edit | edit source]
- Consultation did not offer an opportunity for on-site stakeholders to have compensation or improvements within their reprovided accommodation, in return for giving up car parking space and private ownership.
- Research shows that the provision of parking in new urban housing is typically cross-subsidised by non-car-owners as a hidden cost. Therefore, not offering on-site stakeholders the option of reduced car ownership for improvements is inequitable.
No demonstration of existing parking entitlement for on-site stakeholders[edit | edit source]
The Project Team was unable to demonstrate a basis for reprovision of parking facilities, with a lease or demise basis. The parking was permitted to consume development footprint despite only 6 residents within the sheltered housing owning cars, with none of them able to demonstrate a legal entitlement to on-site parking, and with none of the remaining 26 residents permitted a say in whether this parking should be reprovided, or it should become community space.
Existing Traffic Issues Remain Unaddressed, Even Before The Development Worsens Traffic[edit | edit source]
All surrounding streets have traffic issues, which have been the subject of lobbying local councillors for at least 20 years. These include:
- heavy traffic down Councillor Street both ways, which can only accept one lane of traffic at a time but which is two way
- speeding and aggressive driving in Farmer's Road, due to the way cycle hangars and resident car parking narrow the road on both sides
- speeding and aggressive driving on Redcar Street, due to the way resident car parking narrows the road on both sides
- sharply accelerating cars emerging from Wyndham Road due to frustration at existing light phasing and delays, when trying to enter Camberwell New Road
The development has not been designed with walking and cycling in mind[edit | edit source]
- LTN 1/20 requires that new housing developments put walking and cycling take-up at the heart of their designs
- The majority of on-site stakeholders and new residents do not, and will not, own cars
- The development has been designed mainly from the perspective of the small minority of cars owners
- Local car owners have dominated the consultation and in camera design proceedings, secret even from the purview of the Project Steering Group
- Alternative proposals enabling cycling both on- and off- site as part of the development implementation were not considered, were rejected, and were not consulted upon with the local community as requested by members of the Project Steering Group.
Increased Pollution and Reduction of Air Quality[edit | edit source]
- No pollution monitoring is being carried out either on Wyndham Road or Camberwell New Road. These are key areas affected by the development and also by road closure policies diverting more traffic onto main roads.
- The proposal to create a new road and extra junction interaction so close to a red route, and directly behind red route buildings, means air quality monitoring should be a core component of pre-planning-application monitoring, to understand the baseline situation before worsening it with a new public road.
- This worsens the loss of air quality due to the felling of mature trees which is part of the planning application.
Increased Light Pollution[edit | edit source]
The creation of a public road directly behind buildings on a red route will create an unacceptable amount of light pollution in an area which is required to be a place of refuge from the intrusive street lighting of the A202 Camberwell New Road arterial. This will interfere with both sleep and wildlife, and further contribute to making the rear of Camberwell New Road properties into a hostile environment rather than a refuge.
Increased Noise Pollution[edit | edit source]
The creation of a public road directly behind buildings on a red route will create an unacceptable amount of noise in an area which is required to be a place of refuse from the intrusive street noise of the A202 Camberwell New Road arterial. Combined with intrusive public road street lighting and the light from new buildings at six storeys, this will present an impediment to sleep, productivity and will have long-term detrimental health effects.
The noise assessment report was conducted on 24th and 25th May 2021, which is just one week after emerging from lockdown. Although the report authors purport to have accounted for this with a coefficient, it is unsafe to conclude that the level of noise asserted in the report would be representative of normal non-lockdown conditions.
Existing Loss of Shops in the area was not factored in[edit | edit source]
- Active frontage has been lost in the surrounding area due to a combination of redevelopment and conversions to residential. This includes shops on Camberwell Road, Wyndham Road and Camberwell New Road, and the major new Wyndham Studios development, which did not preserve the 100% ground floor commercial as set out in planning grant.
Loss of Shops Caused by The Impact of the Development[edit | edit source]
- The option of including commercial uses within the development to offset the height and provide for new residents was not considered. The effect on existing shops was ignored.
- The pre-existing loss of shops in the area, combined with the need for additional services as residential density increases, was not considered.
The Development would damage the Grade 2 Listing of Clarendon Terrace, the adjacent Georgian shops[edit | edit source]
- Southwark Planners have conceded in two recent separate planning application that a development above 3 storeys would be out of keeping with the character of the local area
- The proposal of 6 storeys along Miah Close would be even nearer to the listed buildings and conservation area than the previous application by Ark All Saints for height above 3 storeys, which was ruled out based on inappropriate massing
- The proposed massing of 6 storeys would be in definitive contradiction to both the neighbourhood character identified by Southwark planners in previous applications, and to the listed building status of Camberwell New Road shops
- The negative impact of removal of access from traders will mean the loss of several commercial uses, bearing in mind several have already been converted to residential
- The substantive value of the English Heritage Grade 2 Listing lies in the continued use of the majority of its buildings as commercial at ground floor level
- By causing further loss to residential, the development will defeat the purpose of the listing, and is therefore inconsistent with it.
Lack of Planning for Surrounding Schools[edit | edit source]
- There has been no consultation of schools, of which there are 7 within a short walking distance of the development
- There has been no discussion of how the development fits into school travel plans or the Council's obesity strategy, knowing that schoolchild obesity is a significant local issue.
- There has been no assessment of how much the new road will encourage additional car commutes to school, which would negatively impact local residents, traders, schoolchildren, parents and their teachers, by increasing traffic.
- The extra traffic which the development will cause will increase:
- road danger for vulnerable road users
- the likelihood of road rage or unpredictable or unreasonable driving
- difficulty for parents and schoolchildren in safely crossing Wyndham Road and the hazardous Wyndham Road junctions with Farmer's Road and Camberwell New Road
- difficulty for elderly residents in crossing the road to access shops such as the Wyndham Road Post Office.
This violates the Council's manifesto commitment to address increased traffic outside schools on main roads, and in any case violates the human rights of children, due to the life-changing impacts of daily experience of pollution at levels above WHO limits. These documented impacts include:
- decreased lung capacity
- increased propensity to obesity
- cognitive impairment
Apart from these demonstrated impacts, there is the Public Sector Equality Duty outlined in the Equality Act 2010 not to disproportionately impact protected classes. This is also breached by the development's additional traffic, because the majority of schoolchildren at both Ark All Saints Academy and Highshore School are BAME.
Increase in Local Car Ownership And Local Car Parking Capacity Due to the Development[edit | edit source]
- Southwark Council has targets to reduce car ownership, agreed with the Mayor under the Local Implementation Plan.
- This development will immediately increase the number of cars owned:
- on-site, and
- in neighbouring properties
- This development will add the capacity to increase local car ownership by adding significant sections of public road which can be parked on, if designated at next review.
The Development Would Introduce Excessive Height, as previous Southwark Council planning decisions confirm[edit | edit source]
- The six storeys proposed by Miah Close and Wyndham Road are too close to the rears of the properties.
- The height is not consistent with local conservation character
- The proximity of height creates security risks for the rear of commercial properties overlooked on Camberwell New Road.
- The proximity of height to commercial properties on Wyndham Road is too close, and will deprive the BAME traders and their customers at this location of natural light.
- The height does not take into account the likelihood of infill at the rear of Miah Close properties, which is even depicted in some of the concept pictures of the new development, to give the idea of a "neighbourhood street". Therefore daylight assessments should have been done as if these had already been constructed.
- The disproportionate impact of height and loss of privacy and natural light experienced by the West Camberwell side is obviously linked to the decision to provide a dedicated area for car parking, whereas no resident can demonstrate an actual right to park that would necessitate reprovision of that parking (such as a lease demise). The development design deliberately impacts those who do not own cars and have existing areas of pedestrian priority, and imposes on those people a new public road and height, for the sake of providing a car parking area which does not technically need to be reprovided.
- The recently-built Highshore School and All Saints Academy buildings were not permitted to exceed three storeys for reasons of neighbourhood character and 19th Century heritage, which the Wyndham Redcar development claims is now not an issue. This is inconsistent. The Officer's Report for Southwark Council made the following comments in the 2011 planning approval recommendation:
“The height of the main SMAAA building has been reduced by one storey… In contrast to the previous withdrawn scheme, the main SMAA block would be developed to a height (at part two, part three storeys) that relates better to the domestic environment of Wyndham Road.”
“The nineteenth century houses at the corner of Farmers Road and Wyndham Road are the only buildings of some historic character that closely neighbour the development site. Whilst these buildings are not in optimum condition they do provide an articulation of this corner that makes a positive contribution to the local townscape context and the new development would have a massing that does not sit easily with these buildings. However the height of the proposal is reduced and the regular pattern does work marginally better than the previous submission.”
- It is notable that the Southwark Council planning officer's wording conveys that even the three storeys granted approval for the Academy have massing which has an impact that "does not sit easily", and is only "marginally better" than previous submissions considered unacceptable for the neighbourhood context.
- Given the above remarks, it would be reasonable to expect that building heights imposed on Wyndham Road and Miah Close / Camberwell New Road should be expected to go no higher than 4, or even 3 storeys.
Flaws in the Consultation Process Prevented Effective and Fair Community Engagement[edit | edit source]
- It was requested that consultation wording be pre-agreed and co-authored with the Project Steering Group, and screened by the PSG prior to circulation to the wider community. However, this was not done. As a result, consultation included several errors and misleading statements.
- Consultation was not evenly focused. Meetings were all held on the east side of the proposed development, and consultation papers and notices were not circulated to Camberwell New Road residents either initially or at final planning application.
- The Council committed to consult within a 150 metre radius for the planning application notification, including Lambeth residents, out of recognition that the Camberwell New Road side had been inadequately consulted. However, at planning application stage it defined the radius as 100 metres.
- The Council subsequently declined to consult Lambeth residents within either 100 metres or 150 metres, asserting that it had suggested to Lambeth that it could consult its own residents, at its discretion. This was not done by Lambeth, so Lambeth residents have received no planning notification.
- It was requested that the Project Steering Group have sight of the planning application before submission, to clarify that:
- all needed reports were included and
- the wording of the planning application and planning notices were not misleading either through specific wording or omitting details central to the proposal's impact.
- Because the PSG did not have the opportunity to review the application, misleading wording was included in the application, and key omissions were made on the planning notices. For example, the development is described as 3 storeys on Miah Close on the planning notice, whereas there will be 6 storeys along half of Miah Close.
- A majority of the Project Steering Group are motorists, which is not representative of the local area. For this reason, the issue of how the development affects local shops and opportunities for walking and cycling was not discussed.
- Carey Court residents were not consulted about the possibility of receiving advantages in the development or compensation, in returning for giving up any claims they are making about parking. However, at least one Carey Court motorist was interested in this possibility.
Flaws in the Planning Notification Prevented Full Notification and a Fair Timeframe to Comment[edit | edit source]
- The Project Steering Group was not notified directly of the application being published.
- No written notifications of the planning notice were sent through the doors of properties adjacent to the development site
- No written notifications of the planning notice were sent through the doors of properties within the 100 metre statutory radius for a development of this scale
- No written notifications of the planning notice were sent through the doors of properties within the 150 metres promised for final planning notice, due to previous flaws in the consultation process.
The Project Team had an irrational attachment to preserving the intent of the Site Allocation Brief[edit | edit source]
- The basis on which the original site allocation brief was created is unclear, and there is no evidence that any local consultation was carried out to inform it.
- This means it should be capable of significant adaptation if facts on the ground make its initial assumption impracticable.
The Project Team incorrectly claims housing cannot be delivered on the site without building a new road[edit | edit source]
- The first several iterations of design for the Wyndham Comber proposals did not incorporate a through road.
- Therefore, even in the opinion of the Project Team, it is possible to deliver housing without building a through road.
- In early design proposals, the Project Team drafted parking for the new residents which would have blocked access to the rear of Camberwell New Road properties, on Miah Close.
- These early designs reveal the urge of the Project Team and Council to create a new supply of parking as part of the development.
- After much lobbying by locals, the Project Team finally agreed that the development would be zero-car.
- However, the "new public road" design is an obvious attempt to create more car parking policy, with the capability of fully designating this as able-bodied parking for anyone in the CPZ, at the next review.
The Project Team claims a walking route cannot be considered, because the site allocation brief is sacred[edit | edit source]
- The site allocation brief did not contain a proposal to create a new public through road.
- Incorporating the proposed new public road in current proposals was a major improvisation and experiment.
- The new public road proposal is so experimental and untried that the Project Team remains unable to provide an example of a similar development where a new public through road has been carved out of private land, let alone directly behind a red route.
- If the Project Team can propose such a high-risk and experimental design, which was not contemplated in the site allocation brief, then a more proven and sustainable proposal of a direct public walking route through the development can also be considered as part of an adapted design, in consultation with the community.
Lack of Transparency, including reports not provided for scrutiny by the Project Steering Group when ready[edit | edit source]
- Reports underlying decisions were not provided on request, or at all. The reports requested but not provided prior to planning application include:
- tree report
- police Secured By Design report on permeability and safety
- traffic report
- retrofitting cost options for Carey Court
- EPC/EPR energy efficiency scenario assessments for Carey Court, if carried out
- Repair options report for Brandon Church
- Legal Opinion that overriding the two-way access and pedestrian priority covenant held by Camberwell New Road properties was an option
No Flood Risk Assessment Prior to Application[edit | edit source]
- Video examples of flash-flooding on the development site and on Camberwell New Road were forwarded to the Project Team, without response.
- There has been no explanation of how a development requiring deeper foundations will not worsen the situation.
No Equalities Impact Assessment Carried Out[edit | edit source]
- The majority of local traders affected by the development are from the BAME community.
- A majority of schoolchildren attending Ark All Saints Academy opposite the development are also from the BAME community.
- Both of these are Protected Classes under the Equalities Act 2010, and both will be negatively impacted by the development.
- Neither schools nor traders have been consulted directly over the development as to the individual needs of their groups as protected classes in the Equalities Act. Interactions have been limited to the Project Team presenting existing proposals to traders at a meeting at the New Dewaniam, and to the chance to attend a public walk-in of a detailed model of development proposals agreed in private without the involvement of schools or traders.
No Impact Mitigation Proposed or Discussed by the Project Team[edit | edit source]
The Project Steering Group has heard recommendations for impact mitigation involving:
- speaking to TfL about including Santander Bikes
- speaking to TfL about junction improvements with Lothian Road and Camberwell New Road, to encourage safer driving
- speaking to Lambeth about addressing Lothian Road, which is currently a one way road towards Camberwell New Road, meaning that cyclists face a dangerous right turn if they wish to approach Brixton, rather than go the direct route down Lothian Road
- speaking to existing car owners who are residents being rehoused, about what incentives they would require to give up their car ownership, which would reduce local traffic
However, the Project Team has rejected discussion on all these points, and has indicated that impact mitigation will come solely from CIL funding, and that they way it will be spent will be decided by the Council without consultation with the community.
RIBA recommends demolition only as a last resort[edit | edit source]
The Council has argued that demolition is justified purely on the grounds that existing flats would be too small for minimum sizes if building new flats now.
This reasoning is not consistent with recommended best practice set out in RIBA guidance, which does not mention accommodation size as a justification for demolition and urges that demolition be considered only as a last resort.
Demolition of structurally-sound buildings has levels of environmental impact which are considered beyond the threshold of public interest justification, where retrofit is an alternative.
There are increasing examples of developments being called in solely on the grounds that existing buildings are of sound construction, therefore demolition is not justified, for example the proposed Marks & Spencer development on Oxford Street.
No investigation was made of retrofitting Carey Court[edit | edit source]
- A copy of the report assessing the energy efficiency benefits and carbon emissions implications of a rebuild vs a retrofit was requested from the Project Team.
- The Project Team stated that they had not looked into a retrofit or done any energy efficiency assessments of a retrofit as compared to a rebuild.
- This is contrary to the recommendations of RIBA (The Royal Institute of British Architects).
- The Project Team asserted that the only pretext required to rebuild a building was that its current average room size was less than would be required of a modern build. This is not a sufficient public interest justification to justify the environmental damage caused, including to the local environment.
No investigation was made of repairing Brandon Church[edit | edit source]
A copy of the assessment of Brandon Church for repairs was requested, but not provided by the Project Team. This gives the appearance that repair of the church was not looked into seriously, which is against the recommendations of RIBA.
The basis for reprovision of car parking to on-site stakeholders was never identified[edit | edit source]
- As soon as the existing Project Team convened, the architects and planning officers were asked to identify the following:
- existing parking provision per stakeholder
- proposed reprovision per stakeholder
- The Project Team was asked to distinguish between car parking as access, and car parking as a demise for an individual car owner to store their car long term
- The Project Team did not reply to any of these requests
- The Project Team subsequently asserted a parking reprovision right, and created a dedicated new private parking area in addition to the access area newly created by the extended road
- This is an inequitable and untransparent approach, because the majority of each stakeholder group is not car owning. Therefore, the process has smuggled through a cross-subsidy of car owners by non-car-owners, without offering the non-car-owners a full choice in how the land should be used for fair community and stakeholder benefit.
Development Finance / Local Finance Issues remain unaddressed, in terms of stakeholder & grant finance[edit | edit source]
- As the developer is the Council and already owns the land, and land is the main cost, it is possible to deliver 100% affordable housing on the vacant area of the site, without the complications including environmental issues arising from a rebuild of existing properties. The Project Team refused to discuss this possibility, or whether the Affordable Housing Fund grant awarded to Southwark was being applied to the development.
- The Project Team declined to disclose the proportion of contribution to redevelopment costs being made by on-site stakeholders. This leaves the impression that the private housing included is being used to subsidise the rebuild of Carey Court and Brandon Church, rather than the affordable housing. Here is an example of how such disclosure might have been made (with figures based on rough estimates):
|Stakeholder||Overall % of construction cost||% Contribution of stakeholder to construction segment||Southwark % Contribution % to construction segment||Southwark % contribution to retrofit alternative|
|New Social-Rent (22 flats)||10%||NA||NA||NA|
|New Keyworker Rent (10 flats)||5%||NA||NA||NA|
|New Private (33 flats)||30%||NA||NA||NA|
- In proposing to deliberately extinguish trader access, visitor and loading rights, this appears to be done as a direct result of externalising the cost of subsidising the rebuild of Carey Court and Brandon Church on to the Camberwell New Road and Miah Close side. This can be seen from:
- the massing of most building height to the north-west (Miah Close side)
- the inclusion of a low-rise Mews "village" on the east side, where Brandon Church and Carey Court are located
- the decision to run a public through road directly behind red route buildings, which the Project Team was unable to identify a precedent for.
No public interest is identifiable from this process, given that the buildings are both structurally sound, with Brandon Church requiring a repair to one wall.
Reasons to Observe[edit | edit source]
There is a better option on the table[edit | edit source]
- Alternative proposals have been made which would:
- safeguard the access rights of shops backing on to Miah Close, giving them a chance to survive
- enable a social housing development which is not surrounded by a new public road
- maintain the sanctuary of a private access road to the rear of Miah Close, for minimum air quality standards away from the main road, protecting the human rights of Miah Close traders and residents to clean air
- enable a safe walking and cycling route for children, to help address the Obesity Crisis which is affecting so many Southwark schoolchildren, as reported in national statistics.
Any proposal for new homes is an opportunity to address long-standing problems in the area[edit | edit source]
There is a baseline of problems with:
- traffic and congestion
These have been known about and getting worse over the last 2-3 decades, and proposals for solutions have been made to the Council, but nothing has been done.
Any proposal for this site should identify key impact mitigations which address these issues, otherwise they will worsen even further, which would be unacceptable and inconsistent with planning guidance.
Contacts[edit | edit source]
All the contact information below is public domain.