THE SPITALFIELDS SOCIETY
The Planning Team, Greater London Authority, City Hall, The Queen’s Walk, London SE1 2AA
Dear Mr.Wilson 10 February 2016
Re: The Bishopsgate Goodsyard.
GLA ref: D&P/1200c/03. LPA ref: 2014/2425 and 2014/2427
I write on behalf of the Spitalfields Society to re-confirm our objection to the proposals for the redevelopment of the Bishopsgate Goodsyard following submission of amendments to the scheme that are the subject of the above applications for planning permission, and subsequently the “call-in” by the Mayor at the request of the developer.
The objections raised in our previous letter of 24 November, copy attached, are all still relevant and have in no way been satisfied by the recent amendments. Our further reasons for objection arising from these amendments are as follows:
- Height: The applicant states that it has lowered a number of the residential towers. This has largely been achieved by lowering the floor to ceiling heights in the flats throughout these towers. As the lighting studies now show, this has had very little beneficial effect on the loss of light and the extent of shadow cast over the Redchurch Street Conservation Area and the Boundary Estate. The lighting study extract taken at noon in December, even when the sun is at its highest during this winter month, still shows the whole of the Redchurch Street Conservation Area cast in shadow by the proposed development. This is a massively dramatic loss of amenity to this important, vibrant low rise residential and commercial area. We therefore object to the height of the towers because of the overshadowing of these adjacent areas.
- Overshadowing: We also repeat our objection to the arrangement of the seven residential towers as a “wall of towers” along the south side of the Bethnal Green Road where they are guaranteed to cause the maximum overshadowing of the low rise properties on the north side of this road and throughout the Redchurch Street Conservation Area. This is in stark defiance of the recommendations of the IPG that stated that “penetration of daylight and sunlight should be encouraged by ensuring that there is not a wall of development along the northern site edge”. That is exactly the form of development that the scheme proposes and exactly the form of development the IPG sought to guard against.
- Poor quality accommodation: The reduction in floor to ceiling heights is also an appalling and cynical move to obtain consent for the maximum number of units at the expense of the quality of accommodation by reducing the room heights to all the flats. It seems they have no more concern for their prospective occupants than they do for the local community in proposing this monstrous and brutal development in the first place. Except of course they are unlikely to be selling to occupants and more likely to be selling to foreign investors who will never visit the properties and who will have no regard to the quality of accommodation or the room heights just as long as they can let the space. We object, on behalf of potential future residents, to the reduction in floor to ceiling heights of the residential towers and insist that the towers should be reduced in height by a dramatic reduction in the number of storeys.
- Further overshadowing: The lighting studies also reveal that the height of the towers dramatically compromise the amenity value of the proposed park. At 6.00pm on a mid-summers day when the Park might be anticipated to be most greatly used by the numerous new residents the lighting study shows the entire park to be in shadow. This is ridiculously bad planning! We therefore also object to the height of towers F and G because of the damage they do to the external amenity space.
- Lack of affordable housing: The amendments have actually reduced the amount of housing and therefore the amount of affordable housing. It is beyond comprehension and entirely unreasonable that the redevelopment of land in the ownership of a publically funded institution should fail to provide at least the level of affordable housing required by the Local Authority. For the developer to offer only 10% when the target is 50% is wholly unacceptable and shows a complete disdain and disregard for the desperate need for affordable housing in the area, and particularly for housing for the key workers that the City desperately needs.
- Poor connectivity: Two years of consultation during which we have been told it is not viable to build over the railway in order to improve the connectivity of the Goodsyard with the City to the south (see paragraph 16 of our previous letter) has suddenly been shown to be entirely false with a proposal to do exactly that, except that the space created by bridging over the railway is entirely filled with a massive new office block that completely blocks any attempt to enhance connectivity to the south.
- Additional site and building proposal: The significant enlargement of the site by bridging over the East Coast main train lines and adding 10,000m2 of new office space has been submitted as an amendment to the original application, even though, under Tower Hamlets planning rules it qualifies as a major development in its own right. The new office block seems from the very rudimentary proposals to comprise 6 storeys of offices of over 10,000m2 above ground floor retail space. This is a building equivalent in height and size to the Tea Building, located between two Conservation Areas in an established residential area but has been the subject of no consultation at all and has been tacked on to the scheme as an amendment. It will therefore receive only the most cursory scrutiny and yet it is one of the largest new buildings ever proposed in the Spitalfields. We therefore object to this additional site and building being added to the Goodsyard application and insist that it be the subject of a separate planning application, made following a proper consultation that recognises its very different circumstances outside the main Goodsyard site.
- Wrong sort of office space: We note that the commercial space has been considerably increased by the recent amendments, by about 13,000m2. We also note that, in spite of the developers claim to be designing space to suit SME’s and the more entrepreneurial design, media and tech industries the floor plates of the proposed offices are nevertheless designed to be assembled to suit much larger corporate users. Such users would destroy the character and reputation of the area as the home for the emerging and highly successful tech industries that currently flourish in the area. We therefore maintain our objection that the office space proposed is the wrong sort of office space.
- Massive overdevelopment: The net result of the recent amendments is that the floor area of the proposed development has actually been increased. When every local consultee, local body, national body, every journalist, magazine and institution, the local authorities, locally elected Mayors, MP’s et al have all been telling the world that this scheme is a gross overdevelopment how can it be that the applicant responds by making it larger. This seems mad. So we again restate our objection to the massive overdevelopment of the site.
- Lack of public access: Much has been made by the applicant about the public open space that will be created on top of the Braithwaite arches in return for granting approval for the monstrous wall of towers along the Bethnal Green Road. This is a fallacy. The space already exists in public ownership. It is just that public access to this open space has been denied by the current owner who has seriously neglected the upkeep of this space, and the arches below, in spite of their listed building status. We object that the open space and the listed arches, all capable of viable public use as evidenced by previous temporary uses, is still mothballed and unused so many years after the station has been completed.
Our earlier letter concluded that this was the most poorly conceived and damaging development that this Society has ever been asked to review. The recent amendments have not changed this view and they have not resolved any of the 17 objections listed in our earlier letter. The scheme still promises to undermine a great many aspects of the area, whether historic, social, cultural, or commercial, that local residents, the working community and the great many visitors to the area love and value.
The fact that the site and scheme have actually got significantly larger and the amendments have completely failed to satisfy a single objection indicates a callous disregard for local residents, businesses and future occupiers. It is as though the developer feels that the scheme is too big for the authorities to refuse so therefore feels no obligation to take any care or consideration with the design or composition of the development.
Many local people remember using the Goodsyard in its previous incarnations and recognise its potential to provide vital facilities and add real character to the area. So it feels as though a vital part of the East End is being stolen from us by this brutal scheme, simply to provide luxury flats for foreign investors that will lie vacant forever, casting a dead shadow over the once vibrant area of Shoreditch.
Surely this site, owned by a publically funded body, should contribute to solving the area’s housing shortage and provide significant public, social and cultural facilities, or at least a school. The developer likened the scheme in scope and scale to the Barbican during their early presentations. So where is the theatre, the library, the concert hall, the school, the architecture, the defensible space, and the sense of a place that might generate a community? They don’t mention the Barbican in their presentations anymore!
We therefore repeat our request that this application be refused outright. We also repeat our request that this highly significant site be the subject of a properly consulted masterplan by the two authorities working in partnership that might guide a far more sensitive, detailed and sustainable form of development of which all of London can be proud.
For and on behalf of the Spitalfields Society