Hookham Court Resident Objection to planning application 2014/2810

 

In short, I can only deduce that VSM have made inaccurate analyses on the amount of noise the van washes and consolidation/loading bays will generate. As a result, they may well be misleading yourselves and also the Covent Garden Market Authority.

 

The Battersea Society: 31st July 2014

Re: Covent Garden Market Authority, 2014/2810

 

We also note and agree with CABE’s concerns that the design of the key market buildings does not yet match the ambition of the scheme overall, the care taken to provide first-call functionality and to the very commendable opening up of a garden heart to the whole scheme to the benefit of market traders, residents and the public.

Royal borough of Kensington and Chelsea: 31st July 2014

The scheme would result in the loss of major amount of coach parking which would reduce the capacity for coach parking in inner London and would therefore displace coach parking onto the public highway contrary to Core Strategy policy CT1 (b) and the loss of coach parking would contravene policies 6.2 and 6.8 of the London Plan.

The development includes three towers in close proximity that coalesce to form a tall and bulky development with an unattractive silhouette that fails to have positive effect on the townscape and London skyline. The development harms views out of the Royals Hospital and Thames conservation areas and the setting of a registered park. The proposed development is of unwarranted metropolitan scale and as an outline application, there is insufficient information to determine whether the towers are of exceptional architectural quality. As such, the proposals do not accord with Core Strategy policies CO5, CR5, CL1 and CL2 or with UDP policies CD1, CD2, CD 8 and CD63 and policy 7.7 of the London Plan.

 

Greater London Authority 30th July 2014

Re: 2014/2810

 

The Mayor considers that the application does not comply with the London Plan, for the reasons set out in paragraph 187 of the above-mentioned report; but that the possible remedies set out in that report could address these deficiencies.

 

If your Council subsequently resolves to make a draft decision on the application, it must consult the Mayor again under Article 5 of the Order and allow him fourteen days to decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 to refuse the application, or issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application, and a copy of any officer’s report, together with a statement of the decision your authority proposes to make, and if it is proposed to grant permission, a statement of any conditions the authority proposes to impose, a draft of any planning obligation it proposes to enter into and details of any proposed planning contribution.

 

 

 

Strategic issues:

The principle of the mixed-use redevelopment of these sites to provide temporary and permanent replacement markets along with housing, retail, and office uses is supported. However, there are a number of outstanding strategic planning concerns relating to social infrastructure, children’s play space, housing, urban design, strategic views, climate change, inclusive design and transport.

 

Recommendation:

 

That Wandsworth Council be advised that, whilst the principle of the redevelopment of these sites I supported, the application does not comply with the London Plan, for the reasons set out in paragraph 187 of this report. However, the resolution of those issues could lead to the application becoming compliant with the London Plan.

 

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3.            Once Wandsworth Council has resolved to determine the application, it is required to refer it back to the Mayor of his decision as to whether to direct refusal; take it over for his own determination; or allow the council to determine it itself.

 

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14.          The notable differences to the existing consent are a reduction by 50% of proposed retail floor space due to the elimination of a supermarket use in the proposals, and reduced amount of market floorspace; these reductions are balanced by an increase of 11,000 sq.m B1 office space, and approximately 500 additional residential units.

 

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  Maximum floorspace (sq.m. GEA)
Use Previous Consent Current Proposal
Wholesale Market 93,240 62,211

 

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28.          Subsequent to the granting of permission the current applicant was appointed as the preferred development partner by Covent Garden Market Authority (CGMA). In reviewing the extant permission the current applicant and the CGMA identified opportunities to further consolidate the market which would allow the provision of more housing on what is now called the Apex Site; and opportunities to resolve challenges of access, transport, and design issues on the other sites.

 

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33.          Identifies the OA as having scope for significant intensification and increase in housing ( a minimum of 20,000 new homes) and commercial capacity, and notes that existing industrial uses should be rationalised whilst sustaining capacity for those which are of particular importance to CAZ and capable of operating more intensively, such as the wholesale market and waste management provision.

 

34.          Thessaly and Apex sites for consolidating and intensification of Market operations.

 

35.          The Market site to provide a consolidated wholesale market accords with the VNEB OAPF land use strategy and Wandsworth’s local plan and is supported in principle.

 

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36.          Although the redevelopment of the Thessaly and Apex sites for mixed used including housing and retail alongside the Market redevelopment are a departure from the OAPF and local plan land use designations, their release for residential and mixed use is an opportunity created by the improvement in efficiency of the new market design compared to the previous consent, which has been one of the key drivers of the OAPF.

 

 

37.          However, as noted in the precious consent, the existing market infrastructure is no longer fit for purpose and these proposals seek to provide modern, fit for purpose market.

 

 

38.          The current proposals have come about as a result of the detailed design process undertaken in consultation with the Authority and Tenants which identified opportunities for release of further land for redevelopment due to reduction in floorspace requirements by the Market. The new proposals provide for a market in a smaller footprint than previously consented, comprising 4 buildings and 2 car parks. The proposals incorporate a phasing and decant strategy that provides space for the markets to continue to operate during the anticipated twelve year build-out. Discussions with tenants about the decant strategy and the detailed specification of the individual units are ongoing.

 

39.          The detailed design process also allowed for the resolution for transport and hardstanding concerns raised by traders with regards the existing consent, and allowed for an increase in the amount of the public facing retail/café element to provide a critical mass to allow it to be self-sufficient.

 

40.          The OAPF land use strategy supports consolidation of the market operations on the main market site, and the redevelopment of surplus sites for high density mixed use housing-led intensification on the Entrance site and high density mixed office, retail and housing uses on the Northern site. The principle of the proposed development, including the consolidation of the market is therefore acceptable and accords with London Plan policy 4.4 which seeks to ensure any surplus of industrial lands allows market consolidation to meet London’s lo9ng term wholesaling needs.

 

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51.          The approach on Thessaly Road is also of concern given the already high concentration of social housing in the area. Neither of these aspects of the proposal would contribute to the creation of mixed and balanced communities as required by London Plan policy 3.9 and is not currently supported. Furthermore, on the Northern site, the submitted layouts illustrate the opportunities for multiple cores and entrances which would easily allow incorporation of affordable rented accommodation within that site; the applicant should therefore give much more consideration to increasing the proportion of affordable housing on the Northern site and introducing an element of affordable rented accommodation on the site.

 

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71.          This is a concern and should be addressed in the further development of the plans.

 

73.          However, there are still unresolved issues in specific areas that require further consideration. Given the high-density nature of the development, the design of the scheme needs to be of an outstanding design quality, and further work is required to achieve this.

 

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Main Market Site

Site Layout

 

92.          The current application for the Market site has been submitted in full details, in contrast to the existing consent which is in outline form. The proposal has benefited from the applicant taking the outline consent through the process of detailed design in consultation with the market and traders, which has resulted in refinement and rationalisation of the plan for the Market. The proposal shifts the gateway and entrance to the market to the south of the railway viaduct, and also incorporates the land along the southern boundary which was the ‘College Site’ in the previous consent. This has allowed land north of the viaduct to be released resulting in improved public realm and permeability on the entrance site. It also shifts the eastern boundary of the side slightly westwards, to provide more space on the Apex Site.

 

93.          The site master plan recognises the importance of the market to London’s economy, by providing a facility optimised to allow efficiency of circulation for the tenants and management, increased attraction with improved facilities and way finding for customers, supported by reliable infrastructure. The design and access statement explains that the proposed layout represents an even more efficient and fit for purpose design than the existing outline consent, increasing current operational efficiency with wider and more flexible hardstanding areas to address issues raised by the tenants with the existing consent. It incorporates a distinctive arrival space and logical circulation strategy for vehicles and pedestrians which considers safety and security in great detail.

 

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Architectural approach

 

100.        Flexibility is built into the exterior treatments and internal layouts form the fruit and vegetable market proposals in recognition that tenant requirements will not be confirmed until six months before construction.

 

Apex Site

Site Layout

 

101.        This site has been enlarged on its western end with the further consolidation of the market, and the scale, mass and layout reconsidered to take into account the future Northern Line station to

 

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Entrance Site

Site Layout

 

106.        The park would be secured and access from the Entrance site assured given the different ownerships and timescales; further detail on the practicalities and proposed mechanisms for implementation (i.e. legal agreements) should be submitted before stage 2.

 

108.        Sufficient justification for inclusion of the building has not been presented to date, and these proposals should be revisited to address this concern.

 

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120.        The height of the proposed N8 and N10 should therefore be reconsidered.

 

122.        The height of buildings N8 and N10 should be reconsidered to ensure the application complies with London Plan policies 7.11 and 7.12.

 

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Traffic Modelling

 

152.        Given changes in background traffic flows, junction designs, committed and planned developments, new traffic modelling has been undertaken. The applicant has submitted standalone junction modelling for the access junctions. It is TfL’s view that this modelling cannot fully demonstrate the cumulative impacts on the network of this and other developments in the OA, and a micro simulation model is therefore required. Further discussion is occurring with the applicant to agree the approach.

 

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Market Parking

 

161.        The existing market site provides circa 1,500 care parking spaces, with 36,301sqm of hardstanding for LGV’s and HGV’s which is largely uncontrolled. The proposals seek to formalised the number of spaces in the market into two multi-storey care parks (MSCP), one existing and one new, along with hardstanding for the fruit and vegetable market.

 

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Coaches

 

168.        The proposal will lead to a reduction in the provision of coach parking at this location. Demand for coach parking in and around central London is high and increasing, and this facility forms and incredibly important function as a pay and display coach park for the central London market. TfL has a strong view that the applicant should retain a minimum of a 25 coach bay pay and display parking facility on this site as part of the wider redevelopment proposals.

 

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Conclusion

 

187.        London Plan policies on industrial land, social infrastructure, retail, housing, urban design, world heritage site, tall buildings, inclusive design, climate change, and transport are relevant to this application. Whilst the principle of the redevelopment of this site is supported, a number of serious strategic concerns are raised, and consequently the application does not accord with London Plan Policy.

 

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Environment Agency

Raised concerns on their letter Re: SL/2014/112875/01 – L01 dated 18th JUN 2014

 

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Transport for London

2014/2820 New Covent Garden Market, LB Wandsworth – TfL’s initial comments

Letter dated 20th June 2014

 

The applicant has submitted standalone junction modelling for the access junctions. It is TfL’s view that this modelling cannot fully demonstrate the cumulative impacts on the network of this and over developments in the OA, and a microsimulation model is therefore required. This could be undertaken in TfL’s existing One Model (VISUM) or Nine Elms Lane corridor and Vauxhall Cross models (VISSIM) and further discussion is required with the applicant to agree the approach.

 

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English Heritage

Letter dated 16th June 2014 with Re: LAG/32/499-4

 

A significant aspect to the archaeological potential of the application area is that associated with Battersea Channel, a silted former route of the River Thames. An area subsequently reclaimed for development. A landscape within which there would have been a series of branded channels and eyots. The channel edges and eyots have therefore the potential to contain evidence of past human activity particularly with the prehistoric periods. This application area is therefore a key site within the Battersea Channel Project area.

 

Geoarchaeological survey: Market, Apex, Thessaly Road and Entrance sites

With the exception of the Northern site, it is recommended that the on-going archaeological interest can be progressed by a programme of geoarchaeological borehole survey work. Given the limited data from the geotechnical survey, the proposed programme will provide a much greater resolution as well as a more even coverage of the sites as well as the first data from the Entrance site.

 

 

Thames Water

Letter dated 20th June 2014 with Re: 2014/2810

 

TWUL has submitted an application for Development Consent for the construction and operation of a wastewater storage and transfer project in London which is known as the Thames Tideway Tunnel (TTT). The Examination into application close on 12 March 2014 and the Examining Authority sent its recommendation to the Secretaries of State for Communities and Local Government and for Environment, Food and Rural Affairs on 12 June 2014. A decision is anticipated in September 2014.

 

The proposed planning application site (reference 2014/2810) is in the vicinity of three proposed construction sites required for the construction of the TTT; kirtling Street, Heathwall Pumping Station and Albert Embankment Foreshore.

 

We are aware that the primary access for the New Covent Garden Market is via Nine Elms Lane / Battersea Park Road / Kirtling Street Junction, which will be shared with vehicles accessing the Kirtling Street TTT construction vehicles on Nine Elms Lane. TTT works at Kirtling Street are anticipated to commence in 2015 with completion in 2022.

 

It is not clear from the applicant’s documentation whether Junction Capacity Assessments have been undertaken for the New Covent Garden construction phase traffic. It is also not clear from the documentation exactly how construction access will be provided across the phases although the assumptions in ES Table 7-7 Link construction Vehicle Distribution are noted. The application documentation includes a number of commitments relating to construction access but these are not consistent throughout.