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Mr S Sahadevan
Planning Officer
Planning Department
Newham Borough Council
Newham Town Hall
High Street South
East Ham
London
E6 2RP

1st August 2008


By: Email & Post
 

Dear Mr Sahadevan,

Re: Planning Application: Queens Market, Upton Park, London

        Application No. 08/00894/FUL

We object to the planning application concerning Queen’s Market by St Modwen PLC on these four points:Climate change impactDesign and context issuesReduced retail diversityParticipation and consultation issues. 

In addition we would like to express our view that the St. Modwen’s proposal acts against all three cross-cutting themes of the London Plan[1] as it undermines local people’s access to food, does not consider the impact on ethnic minorities’ families and livelihoods in the area and does not consider the best use of renewable energy provision.
 

Climate Change impact

The St. Modwen’s proposed development is not a forward-looking green development in line with the London Plan policies on climate change[2] and national planning policy on climate change. 

The London Plan, in particular Policy 4A.7 Renewable energy states that developments are expected to “achieve a reduction in carbon dioxide emissions from on site renewable energy generation”[3]. We urge Newham Borough Council to take note of London Plan Policy 4A.1 Tackling Climate Change, in particular the need to consider the developments’ use of energy, sustainable design, energy supply and using renewable energy. PPS 1 Sustainable Development: Climate Change Supplement states that “Applicants for planning permission for substantial new development should through their Design and Access Statement demonstrate in broad terms how the proposed development will comply with the target carbon emission rate applicable through Building Regulations. In particular, applicants should explain the contribution to be secured through decentralised energy supply systems including from on-site renewable sources.” We believe that the considerations that the PPS sets out in terms of environmental design have also not been properly considered in this development (para 35, PPS1). The application does indicate alterative energy methods such as photo-voltaics, but has no detail as to how these will be incorporated and sited, and to what extent they will provide renewable energy to the market and residents.
 

In addition, the St. Modwen plans indicates a huge increase from currently 150 parking spaces to 308 (St. Modwens Planning & Economic Statement, point 3.18, page 7) parking spaces despite Upton Park tube station existing next door to the site. This will increase road traffic to the site contrary to the London Plan’s Policy 3C.23 which states that boroughs should “seek to ensure that on-site car-parking at new developments is the minimum necessary and that there is no over-provision that could undermine the use of more sustainable non-car modes.” The cycle storage proposed on the first floors in the development is not publicly accessible to shoppers and local people who currently can leave bikes at street level. Bicycle routes are not indicated in the plans submitted, nor does the type of bike storage meet the BREEAM Standards. St. Modwens’ BREEAM for Retail document states “T5 Cycle spaces will be provided, though are not expected to be BREEAM compliant. T6... There are no cycle paths” (point T6, ‘Transport’ table, page 11). The application also does not comply with Newham’s own policies on reduced emissions from transport which promises to be “reducing the need to travel and by promoting energy-efficient modes of transport such as public transport, cycling and walking” (para 3.80, UDP Environmental Quality)

Improvements to biodiversity and urban drainage systems have also not been addressed. The development should look at enhancing biodiversity through green roofs, and the creation of green space and space for trees where possible. The mezzanine level communal planted area proposed does not constitute an adequate children’s playing area.

Design and context issues

The proposal is an uninspiring, high-rise development, out of character with local buildings or precedents. Local buildings are an average of 2 to 3 floors, mainly traditional Victorian terraced houses and the St Modwen’s proposal is 31 floors, high-rise. London Plan Policy on high rise buildings states that tall buildings should be ‘suited to their wider context in terms of proportion and composition and in terms of their relationship to other buildings, streets, public and private open spaces’ (Policy 4B.9 Large-scale buildings – design and impact). 

The St. Modwen’s proposal is therefore out of context, will increase congestion in an already heavily congested Green Street. The St. Modwens Planning and Economic Statement states a that design panel of 30 reputable architects and other professionals in the built environment, chosen based on their design experience, critical ability and understanding of development pressures facing Newham described the scheme as creating “the sense of a citadel”, and exclusive, fortified place. This is not a positive, inclusive development which will enhance the area. As a high-rise, there are also impacts on existing residents in terms of increased light pollution, overshadowing of family homes and businesses, and possibly affecting prices of property and businesses (again this is contrary to Policy 4B.9 which urges developers to “ pay particular attention, in residential environments, to privacy, amenity and overshadowing.”)

 
Reduced retail diversity

The development proposal fails to enhance and preserve what is currently “London’s most ethnically diverse market” New Economics Foundation Report 2006: this report includes the result of a survey of shoppers at the market, carried out by Mori for Newham Council in December 2005/January 2006, which found that 54% of shoppers were Asian or Asian British, 27% Black or Black British and 16% White.

This diversity would be severely affected if this development is to go ahead.

The St. Modwen’s proposal will adversely affect ethnic minority and local businesses most. The Newham UDP (UDP People, figure 7) indicates the distribution of Indian Pakistani and Bangladesh, Black and African residents in the immediate area in and around Queen’s Market is 60-80% which if considered alongside residents who “suffer from poorer health and shorter life expectancy than national and

London wide averages”, and taking into consideration that “nearly one third of Newham’s working residents are in the generally lower paid manual sectors”, Queen’s Market is both a life-line and means to enter into work. A lot of businesses are family owned, thus allowing ethnic minority women a working freedom who would in normal circumstances “face social barriers to employment such as child care responsibilities.” In addition “the Borough has the highest percentage of children aged under five in the country. People aged under 30 years make up a much higher proportion of the population (about 48%)” and their health is utmost priority to families who shop at the market and for the sustainable future of growth in the local area. “1.26 Figure 7... In Newham, persuading the younger generation of minority ethnic communities to stay would make an enormous and positive difference to the Borough (UDP People, para 1.26, page 44), yet the St. Modwen’s plans will adversely affect these emerging communities, their access to culturally appropriate food and confidence in starting their own businesses.

Queen’s Market currently has many small ethnic minority businesses which will not be able to survive if there is a rise in service charges and rents for small shops. The market currently attracts people from all sections of the community and local area and caters for many communities from around the world living in Newham[4]. It is a lifeline for thousands of families from ethnic minority backgrounds who will be adversely affected by the proposal. Queen’s Market offers jobs to people with little qualifications, mainly ethnic minorities and the surrounding areas also rely heavily on secondary trade as a result of the market being there[5]. The London Plan’s Policy 3D.3 particularly states that “Boroughs should work with retailers and others to prevent the loss of retail facilities. Including street and farmers’ markets, that provide essential convenience and specialist shopping and to encourage mixed use development”.  

St Modwen has made assurances, repeated in the Equalities Impact Assessment Report on the proposals that it would work with the tenants in the small shops to ensure sustainable rent levels: 

"5.7.1.4 The current offer available at Queens Market provides affordable, healthy food in a recognised food desert that is Newham.

5.7.1.5 The importance of maintaining this affordable offer is paramount. In recognition of this St. Modwen is prioritising the retention of the existing market offer. In response to this, St. Modwen is offering existing traders first refusal on the new leases and wants to support and encourage them to continue trading. St. Modwen is working with the market traders and shop keepers to agree sustainable rent levels. St. Modwen is proposing that the shop units will have step-rents and that the rent level within the occupancy charge for the market traders will be frozen for a period of five years."

We have been made aware that St Modwen is currently demanding a hundred percent rent increase from the trader at 43 Queens Market and over 40% increase from 66 Queens Market. This flies in the face of the reassurances given by the Council and St Modwen that the market will survive the redevelopment.

The St. Modwen proposal does not take into consideration the negative impact it will have on ethnic minority communities[6]. There has been no assessment of local retailing information as demanded by the London Plan Policy 3D.3.

Local people are not able to afford the price of homes on offer, even under the category of ‘affordable housing’. Of the homes proposed approximately 55 homes are deemed affordable[7]. Newham Council’s UDP on Housing (para 4.24) states that “The people of Newham face a range of housing problems including an overall shortage of affordable housing”, citing this as a priority. Yet the proposal for Queen’s Market offers less than a quarter of the overall dwelling proposed as affordable. The UDP states (para 4.27) that “In Newham the majority of households in housing need cannot afford to buy properties nor pay rents at market prices.” It is our understanding that the one and two bedroom dwellings proposed by St Modwen’s are unsuitable in this context and do not consider local people’s needs, seeing as “prevalent amongst the Asian community, with 52% of Bangladeshi, 32% of Pakistani, and 19% of Indian household” (UDP- Housing, 4.29, page 153) suffering from overcrowding in the area directly surrounding the Queen’s Market.

 
Community Participation

Queen’s Market works with an interdependent community who rely on it and sustain it. The local community have not been involved properly in the regeneration of the site because the retrospective style of consultation was inflexible. There was no real participation in the process of development, thus discriminating against local people, bypassing their views. Residents have demonstrated their objections to the developers by handing in a 12,000 petition against the St. Modwens involvement on the site. More recently over 2,500 objections have been logged into Newham Council planning department as (verified by Razia Khanon, Front Desk, Newham Planning Dept, 09.07.2008).

 
Newham has not compiled a Needs Assessment. Locals have not been thoroughly consulted on the plans by either the local Council or St. Modwens[8]

 
Sustainability 

PPS6 states that plans must ‘deliver more sustainable patterns of development’ (section 1.5). All the evidence is that the developer cannot currently deliver sustainable development. Building and Engineer Online on the 14 July 2008 quoted a spokesperson from St Modwen properties as saying that "What was not expected, either by us or the market generally, was the pace and severity of decline in the residential market, which has yet to find a stable level…..This means that, for residential land, there is currently no genuine market, as the major housebuilders are unwilling to invest in land until they can see the way ahead more clearly." As a result, St Modwen said it has decided not to attempt to sell any of its residential land until the market has stabilised. St Modwen has currently put on hold one of their other developments, Hatfield Town Centre, as a result of difficulty in attracting tenants to the proposed retail units (see part copy of their official leaflet on the matter). 

 
Summary

We believe that the St Modwen’s proposal fails to implement national planning policy on climate change (PPS1) and retail (PPS6), and has failed in ensuring proper consultation and involvement of the community in the plans, to ensure that any redevelopment of the market meets their needs and provides a secure long-term future for this vibrant and diverse market.

 

Yours sincerely,
 

Saif Osmani                                        Pauline Rowe

 

 

 

Cc.      Mayor of London, Boris Johnson

            Jenny Jones, Greater London Authority

            Widemar Spruijt, Greater London Authority

            Mayor of Newham, Sir Robin Wales

            Kevin Blowe, Aston- Mansfield Community Involvement Unit

 
[1] The GLA Act requires London Plan to take account of three crosscutting themes: health of Londoners, equality of opportunity, contribution to sustainable development in UK. Add date and page number[2] London Plan, Chapter 4 The Crosscutting Policies, p.195,  February 2008[3] London Plan, Policy 4A.7 Renewable Energy, p205, February 2008[4] London Plan, Section 1.2, 1.3, 1.5 [5] London Plan, Section 1.60-1.63[6] London Plan, Section 2.6[7]London Plan, Policy 3A.6; 3.26[8]London Plan, Policy 3A.4