This comment & representation focuses on documents including
· The CWAAP Publicaton / Submission Version 2010
· The CWAAP Consultation Plan
· The CWAAP Consultation Report
· The London Plan and Emerging London Plan – Major Town Center, mistake and error
· The CWAAP Assessment of Impacts (Stage 1 + Stage 2)
· The Canada Water Masterplan Brief (2002)
This comment cannot deal in detail with each of these documents and we will handle the 149 page CWAAP (in)Sustainability Document separately due its serious defective condition. Sustainability issues are set out here in the general.
In this comment we cannot do a full resolution and checking analysis between the CWAAP Consultation Plan (intended) and CWAAP Consultation Report (outcome). We have read the documents and find serious flaws and weakness it that what was to be done was not always done.
The “Canada Water” project is no longer a medium scale “town center” heart to fill the gap and unfinished work left over by the London Docklands Development Corporation (LDDC), it is no longer a smaller district scale development to sit between, and complement, the Rotherhithe Station and Albion Street in the North and Surrey Quays and Lower Road in the South. CWAAP has become something else and what it is becoming is only just emerging in the new London Plan and associated documents (Autumn 2009) and summed up by the erasing of “Surrey Quays (Docks) District” and the final stages of the rebranding and gentrification to emerge as a mammoth “Major Town Center” called “Canada Water”. CWAAP Publication / Submission Version 2010 page 29 sets out the real plan:
“4.2.8 Providing a substantial increase in the amount of shopping floorspace would mean that Canada Water becomes a major centre in our hierarchy of centres. This is consistent with policy 3 in our draft core strategy and Table A2.2 in the draft Replacement London Plan. It would also benefit the local economy and has the potential to provide around 1,750 new jobs, making a significant contribution to the London Plan estimate that Canada Water can provide around 2,000 new jobs (London Plan policy 5D.2).”
We must therefore object to draft core strategy Policy 3 on the basis of the information currently provided to us. The words “MAJOR CENTRE” need to be written large and the implications of the change set out. It must be pointed out that the phrase “major town centre” does not exist in the Issues and options Report (November 2008).
http://www.southwark.gov.uk/download/2960/report_part_1 Issues and options Report
http://www.southwark.gov.uk/download/2961/report_part_2 Issues and options Report
The repeated references to a “major town centre” first find prominence in the Preferred Options Report (July 2009) and we can only assume that it is the London Plan that is driving the CWAAP key components and therefore as the London Plan changes so must CWAAP. However, there is a great change in emphasis from a district scale Town Centre to a Major Town Centre. The latter was not even an “issue” or “option” as such, it has become a “preference” in the “mix” at the second stage in Summer 2009. It did not feature in the first stage from November 2008 to Spring 2009. The Council is pulling a fast one.
CWAAP is no longer one leg of a three legged stool - an addition to complement the existing centers if Albion Street and Lower Road, no, the chainsaws are out again, and this time all that surrounds the new civic centre and “heart” is to be integrated into the bureaucratic project that is “Canada Water”.
The CWAAP Publication / Submission Version 2010 claims on page 8 that the Council’s “vision” for Canada Water is supported by a strategy and policies however the neither of these stand on sound evidence. Page 10 refers to the relationship between the Core Strategy and the Sustainable Community Strategy (Southwark 2016) and this is a matter we will have to consider separately however the failure of CWAAP to be consistent with the Sustainable Community Strategy (Southwark 2016) in discussed below.
In this comment, and others, we set out reasons why the AAP is not consistent with the Mayor’s policies for London which are themselves founded on poor evidence and mistake for matters concerning the intensification of areas subject to extreme flood risk, high levels of pollution, capacity roads and traffic (in relation to alternative locations London wide).
The CWAAP Publication / Submission Version 2010, page 11, makes claims about an “evidence base”. The Council’s evidence base is selective, incomplete and very weak as we have already pointed out and illustrated in other comments. However the Mayor’s Office have also commented about problems with evidence and no mention is made of that. The CWAAP Publication / Submission Version 2010 document is almost written as marketing puff and not as a document to inform decisions or make planning comment. The Sustainability Appraisal has not validly, appropriately or reliably tested polices. The Equalities Impact Assessment process has become a mystery and odd curiosity met with silence. The Consultant Report and Officer Responses provide evidence that what was planned to be done , what “will” be done, was not always done. The Appropriate Assessment has been dealt with in another comment – and was found by us to be evidence of serious failure to identify habitats, flora, fauna and biodiversity.
Rotherhithe residents have not cottoned on to the Council’s switch and slight of hand (and ways of wording) and the full extent of what is now being planned has not been explained nor communicated in a way that local people understand.
Nobody from the Council is telling us that “Major Town Centers” have a much higher crime rate with more sex attacks, stabbings, arson and muggings etc. Nobody is telling us Major Town Centers have more youths and older yobs running amok along the high street on drink and drugs. Surrey Quays has no high street as such at present – it has a mall - and outside there is car parking that regulates behavior. Nobody is telling us that surrounding homes, estates and woodlands will become the rear exits and back passages of the new Major Town Center retail and office world. We understand the Council keenness for more residents to stay in Southwark and shop however we do not see the complex expensive infrastructure being put in place to produce and manage a successful, safe and sustainable shopping center – since Southwark do not have any at present we are concerned that they do not know what they are doing and what they are creating.
However, we all know thanks to Hawkstone T&RA that over £3 Billion of property will only deliver £18 Million of contributions towards community works, plus of course the £14 Million vanity library project and the civic plaza. We object to Policy 33 on page 85 of the CWAAP Publication / Submission Version 2010 and find it totally inadequate. 6.4.5 states that all S106 charges will be “reasonable”. To be reasonable for the community the charges must be fully and correct costed and what we have seen so far is unreasonable charging that has been to the detriment of local residents and to the advantage of developers and land owners. It is not just the developments that need to be tested to see if they are “viable” it is also the overall project and the damage and costs that it causes towards local residents and the environment. What value should be factored in for Rotherhithe ward male residents almost living 5 years less that the average for England? The community is subsidizing the development and that must be reversed. Developments that have not paid their fair share of s106 over recent years should charged more.
Section 6.7 “Risk” on page 88 is very inadequate. The funding gap on infrastructure improvements is not small it is enormous! It is only small due to defective process and a failure to adequate set out the resources and costs necessary for creating and sustaining a Major Town Center and the surrounds. Simply all work should stop until all the matters are sorted out properly and that include key relationships with residents, TfL, Thames Water and other very important parties to the project.
The planners and the Council set the goal of achieving the “Major Town Center” classification way before consultation began for Preference Stage. Let’s be clear – the decision had already been made. And when a decision is already made consultation is practiced as a “courtesy” (polite) or a sham (less polite). The other “Major Town Center” in Southwark is Peckham. The Council has set out a determined plan to “tick-box” all the prerequisites to produce a Major Town Center at Canada Water and the consultation has been managed as a tool for this result. So we see 50,000sqm of retail, we see more offices and we see student accommodation blocks etc. The final outcome of the consultation is, it just so happens, all the ingredients to produce a Major Town Center – an outcome that Option 1 would not have produced. The loss of Option 1 was the end of the “district” lesser scale center and the cementing of the Major Town Center grand plan.
A MAJOR Town Center intention that brings so many negative impacts with it. Further impacts that accumulate with the already substantial issues that the locality must contend with - here and now, not in the future. Drunks, louts, hooligans, stabbings, muggings, attacks, noise, litter etc. all the behavior that we can see on the TV and in other “Major Town Centre” developments around us will aggravate and escalate conditions already being experienced and tolerated.
“No! It will be OK and like Canary Wharf!” They might say - Not a chance. Canary Wharf is a very carefully policed and controlled private development with carefully designed physical infrastructure barriers between itself and the other – Tower Hamlets. It is a very valuable development that has made very large investments into features, design, systems and shared and open spaces.
Rotherhithe private property owners who supported the Councils consultation might think again and consider how creating a “Major Town Center” will impact on their real estate wealth and quality of surroundings.
We already know that “family homes” in the private sector are in fact largely occupied by single sharers under 25 (including students) and with only 89 borough wide “bidders” recently for a Hawkstone family property we do not see the demand for housing that the Council claims. Homesearch bidders are becoming a fussy bunch and that indicates to us that they may not be as “needy” as is made out by the Council. The Council’s housing allocation system is near collapse as families are placed into the wrong type of property. And Rotherhithe has a very high level of under occupiers with many elderly people who find no alternative in their neighbourhood suitable for them.
So why is there a target of 35% for Family Housing in CWAAP? The evidence does not support the policy / target and the focus should be on housing the elderly / under occupiers into homes tailored for their needs and locations in their neighborhood where they want to live in order to free up the under-occupied homes. We find the housing demand / supply arguments put forward by the Council extremely weak and evidence suggests muct better ways to tackle the housing “crisis”. Despite the “housing crisis” the Council decided that Canada Water – home to so many students already – must tick the “Major Town Center” box and have a separate student digs block. Rooms that will also be occupied by foreign students paying £115+ per week.
The Council cynically and wrongly used demolition of the Hawkstone Estate to create Issues and Options choice Options A and B. The demolition and opportunity of new homes over at Canada Water was promoted by doorstep politicians / canvassers and the impression in the community was 90% sure that demolition would go ahead. However the withheld “Hawkstone Mandate” “Feasibility” documents and process determined that demolition would not take place. The carrot to choose option B was whipped away after the consultation closed. In these circumstances it would have been right for the Council to formally re-consult the Hawkstone on Option A and B, and with our associations help it could be done in a week. Our association has repeatedly offered help to Southwark Council and provided information to the Council.
However, finally at the end of the sham courtesy consultation process the Council jettisoned what they never intended to carry forward all along and retained what was planned before the launch of second stage consultation. By design and purpose the outcome “mix” matches the requirements for a Major Town Center.
So we say - Rotherhithe you have been had, you have been subjected to a sham “courtesy” consultation process that was prefigured and gerrymandered from start to finish to produce the “right” result for the Council and other land owners, and not in any way meeting the Council SCI aspiration:
3.2 Our aim for this Statement of Community Involvement is to give Southwark’s diverse communities real opportunities to influence the way that the community strategy Southwark 2016 and the Local Development Framework shape the borough.
and
If we plan well, we can make a positive difference to people’s lives creating jobs and homes and opportunities; while at the same time protecting places people value such as open spaces and historical buildings. Whether a development is a success often depends how well we understand and provide for the needs and aspirations of the community.