Silvertown Tunnel

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Silvertown Tunnel

Received 26 August 2016
From Knight Dragon

Representation

Summary of Objections
This summary of representation is made on behalf of Knight Dragon Developments Limited and Knight Dragon Investments Limited ("KD"). A full letter of objection which expands on the points below is also submitted together with associated plans.
KD is the master developer of Greenwich Peninsula; currently the single largest regeneration scheme in London which will help to deliver much needed homes and jobs.
KD is supportive of the principle of the proposed new Silvertown tunnel crossing ("the Application") but wishes to make the following objections which are considered significant enough to warrant the Application being refused consent.
1. AEG Car Parking

The replacement car park within the Application is ill conceived.

The Application fails to address and assess the disruption caused by providing a temporary replacement car park. No consideration is given to the impact upon the parking provision for The O2.

The Application identifies one area of land for the replacement car parking. The Application does not contain any traffic impact analysis of the proposals and its subsequent impact on the local highway network and KD also questions whether the reprovision of spaces is appropriate in this sustainable location.

KD requires confirmation from TfL that it will be responsible for all costs associated with the provision of any replacement car parking and associated infrastructure together with assurances of appropriate re-instatement of the land.

2. Closure of Edmund Halley Way

The Application proposals fail to suitably mitigate the impact of the closure of Edmund Halley Way on the local highway network.

3. Diversion of Millennium Way

The proposed temporary diversion to the east of Millennium Way will seriously disrupt traffic and parking on the Peninsula. The Application fails to propose a suitable alternative route to mitigate this impact.

4. Tunnel Avenue Extension to Peninsula Quays

The Application fails to propose an early reinstatement of Tunnel Avenue as a mitigation measure to the disruption caused to the Peninsula by the Application.

5. Direct Access to Silvertown Tunnel from Greenwich Peninsula
The Application proposals fail to provide suitable access for all vehicles to the Scheme.
6. Other Highway Impacts

The Application fails to provide a detailed mitigation strategy, despite the Transport Assessment stating that "the Scheme does have a significant adverse traffic impact on local junctions and highways links", including specific measures and monitoring of the impacts.

7. Failure to Adequately Mitigate the Impact of Construction

The Scheme does not mitigate the impact of the construction which will have a significantly adverse impact on the regeneration of the Peninsula.

8. Failure to adequately mitigate impacts on existing buildings

The Application fails to make specific provision for settlement agreements. The DCO should contain a requirement for these to be entered into prior to the carrying out of the development.

9. Location of Buildings

The proposed location of the southern portal building is inappropriately located on land to the north of the Tunnel.

The Application incorrectly states that both parcels of land previously considered are open to the same redevelopment opportunities. The current proposed location benefits from outline planning permission, the land to the south does not currently benefit from planning permission for any redevelopment.

The Application identifies a large and disproportionate area within which the head house can be located, creating an unacceptable level of uncertainty for KD in relation to its ongoing redevelopment of the Peninsula. The size and scale of this building is considered inappropriate for the proposed location.

10. Design of Buildings

Inadequate consultation has taken place with KD on the design of the buildings.

The Application fails to give suitable approval rights for KD regarding the design of the portal building given their close proximity to the 2015 Masterplan proposals.

11. User Charging

KD considers that user charging outside of peak periods will have a detrimental impact on the success of the Peninsula for both residents and businesses.

12. Programme

The Application fails to provide a detailed programme for the replacement of essential facilities namely the temporary car parking, access roads and pedestrian and cycle links. TfL’s procurement route (PFI) is considered inappropriate for this Scheme and an alternative procurement method should be considered to reduce the Scheme's delivery timescale.

13. Failure to Address the Existing Safeguarding Direction

The Application fails to make provision for the existing safeguarding to be removed upon completion of the Scheme. This should be included within the draft Development Consent Order.
Conclusions

KD considers that the Application is significantly lacking in relation to the consideration of alternatives, adequate assessment of existing proposals and adequate provision of mitigation measures. KD considers that the objections highlighted provide sufficient justification for Development Consent to be refused.

Full representations below

The Planning Inspectorate
Temple Quay House
Temple Quay
Bristol
BS1 6PN

Ref: TR010021

26th August 2016

Dear Sir/Madam

WITHOUT PREJUDICE
PROPOSED SILVERTOWN TUNNEL ORDER
OBJECTION TO APPLICATION FOR A DEVELOPMENT CONSENT ORDER ("the Application")
This letter of objection is submitted on behalf of Knight Dragon Developments Limited and Knight Dragon Investments Limited ("Knight Dragon") in relation to the Application for a Development Consent Order to authorise the construction, operation and maintenance of the Silvertown Tunnel ("the Scheme").
Background
Knight Dragon is the master developer of Greenwich Peninsula which currently benefits from several planning permissions. These permissions will see over 60 hectares of brownfield land at the Peninsula being developed to provide:
• 15,720 homes;
• 60,000sqm of commercial space;
• a redeveloped North Greenwich tube and bus station providing additional bus capacity as well as neighbourhood retail, hotel and office accommodation;
• a 40,000sqm film studio;
• 24,000sqm of new retail/food/drink space;
• two hotels;
• two schools for over 2,000 pupils (one primary, one 'all through school');
• a 20,000sqm cultural and visitor attraction;
• a ferry jetty terminal;
• new parks and enhanced open space;
• a 5km running and leisure track around the whole site;
• a healthcare facility;
• a multi-storey car park accommodating up to 2,000 spaces for AEG (the current operators of the O2); and
• an expanded Ravensbourne College.
Attached to this letter is the 2015 Masterplan which shows the layout of the proposed development and uses and how the Greenwich Peninsula is intended to look once completed.
Knight Dragon has recently completed the first 506 homes and construction is continuing, with over 1,800 homes anticipated to be completed between 2017 and 2019. Knight Dragon is also undertaking a series of place making and meantime initiatives across the Peninsula including events held at the NOW Gallery and Peninsula Gardens and also at the recently opened temporary Golf Driving Range.
The Peninsula is identified as an Opportunity Area in the London Plan and is the largest single regeneration scheme in London. The 2015 Masterplan will help to deliver much needed homes and jobs in line with the Mayor of London’s priorities and, as will be noted from the above, Knight Dragon is accelerating development in order to meet these needs.
Knight Dragon is generally supportive of the principle of the proposed new tunnel crossing and considers that it has the potential to relieve the current congestion suffered on the Blackwall Tunnel and may also reduce travel times, particularly northbound.
However, having assessed the detailed proposals, Knight Dragon wishes to make the following objections to the Application which are considered significant enough to warrant the Application being refused consent.
These objections are as follows:
1. AEG Car Parking

2015 Masterplan Multi-Storey Car Park
The Application states that the 2015 Masterplan anticipates a multi-storey car park coming forward within the first phase of the 2015 Masterplan development to "gather up and concentrate current surface car parking associated with the O2 Arena". The Application states that it makes provision "for O2 car parking affected by the scheme's construction to be temporarily replaced if the multi-storey car park is not developed in time" .

Whilst it was anticipated within the 2015 Masterplan application documents that the development would follow the Development Zone Parameter Plan, with development in the Transport Hub commencing first, this is not necessarily the case and indeed, development within Zone C is commencing first, with a Zonal Masterplan and Reserved Matters in relation to that Zone having been recently submitted.

Additionally, the Application fails to consider the fact that a large amount of area of the Peninsula required for a work site associated with the Application is situated on the area of the Peninsula allocated to provide the multi-storey car park, making it impossible for the multi-storey car park to be brought forward whilst construction works in relation to the Scheme are ongoing.

The Application should therefore make sufficient provision for replacement car parking during the Scheme's construction works and should not be predicated on the multi-storey car parking within the 2015 Masterplan being brought forward beforehand.

Temporary Replacement Car Park

Despite being anticipated that The O2 car parking will need to be re-provided, the Application makes minimal reference to the disruption this will cause, stating that during construction, the Scheme would "lead to some localised impacts e.g. access to residences and businesses in the immediate vicinity" . No direct consideration is given to the impact upon the parking provision for the O2. This is considered insufficient, given that approximately 600 parking bays will be displaced to make provision for the Greenwich compound for the Scheme and will need to be in place for the duration of the Scheme, currently anticipated to take approximately 4 years to complete.

The Application proposals state that TfL would reprovide these car parking spaces at "other suitable locations, local to the O2" . However, it is noted that only one area of land has been identified for the provision of a replacement car park, namely on land to the south of the Emirates Air Line cable car.

Knight Dragon is disappointed to note that the Application does not contain any traffic impact analysis of the car-parking spaces being relocated to this location. Further, it does not appear that any alternative locations for the provision of this temporary car park have been considered, nor has any detail been provided as to why this location is considered the most appropriate. Additionally, there does not appear to have been any consideration given to access to this location, taking into account the number of users of the car parking during events.

The provision of approximately 600 car parking spaces, located within close proximity to the Emirates Air Line, combined with the already existing 264 car parking spaces in Car Park 3, will result in the provision of just under 1,000 spaces on a part of the Peninsula that lacks the necessary road infrastructure to support this number of parking spaces. As a result cars will need to both access and egress onto the single carriageway at West Parkside to access the temporary Edmund Halley Way diversion, before reaching Millennium Way.

Taking into account the significant developments which sit to the north of (the existing) Edmund Halley Way (Ravensbourne College, TfL offices, offices at Mitre Passage and associated retail), the new residential neighbourhood at Upper Riverside (1,007 homes and commercial space with occupation commencing in 2018) and the peak arrival and departures to the car parks which will occur during major events held at the O2 (an average of 200 per year), together with associated construction and general traffic, the capacity of a single carriageway at West Parkside and the Edmund Halley Way diversion is wholly inadequate to cater for the level of traffic anticipated in this location.

AEG is constructing a Designer Outlet Village within The 02 Arena which, when it opens in 2018, will bring significant additional traffic to the Peninsula. In the situation where the car parking is re-provided by TFL in the proposed temporary location there will be a more constant demand for spaces not just when events occur thereby creating an even greater problem at the junction.

The temporary replacement car parking solution does not take into account that both the Prayer Space and GLLAB currently use significant land within the designated area. As they are not shown on The O2 replacement car park plan Knight Dragon has to assume that the Applicant intends to re-locate these buildings but no information is provided as to where they will be located. These are important resources for the Peninsula and must remain operational and easily accessible for users.

In addition to the above, are the numerous bus services which run to and from North Greenwich transport interchange via the Pilot bus way. Without significant junction and infrastructure improvements this will result in both the existing and proposed diverted highways becoming stressed to such a degree that the whole of the Peninsula will be brought to a standstill and result in conditions detrimental to the safety of pedestrians, cyclist and road users. An analysis of the traffic impact in this location as a result of temporary works required during the construction of the Application is required prior to the Application being determined.

Knight Dragon would also question the reasoning behind the provision of approximately 600 replacement spaces. As a whole, the Peninsula benefits from over 2,500 spaces, many of which are rarely fully occupied. Knight Dragon consider it surprising that TfL, as a sustainable transport authority, have failed to assess whether it would be more appropriate for alternative measures to be included to avoid the need for such a large number of car parking spaces. The Peninsula is well served by a range of public transport, including the Jubilee Line, a large bus station, the Emirates Air Line and river services; Knight Dragon consider it unacceptable that no analysis appears to have been carried out as to whether there is a need to re-provide such a large number of spaces, on land which could otherwise be used for the continued redevelopment of the site as illustrated by the 2015 Masterplan.

In light of the above, Knight Dragon considers that both the location and distribution of the displaced car parking needs to be revisited in consultation with both Knight Dragon and AEG so that any agreed solution can be programmed well in advance of the main construction of the Scheme, together with the necessary infrastructure improvements. This is to take into account the necessary design, planning and commissioning timescales to allow for the replacement car parking provision to be fully operational prior to the construction of the Scheme. Knight Dragon considers that such further analysis is required prior to the approval of the Application.

In addition to the above, Knight Dragon requires confirmation from TfL that it will be responsible for all costs associated with the provision of all replacement car parking and associated infrastructure together with assurances of appropriate re-instatement of the land.

Knight Dragon therefore objects to the Application on the basis of the location, design, access and scale of the proposed temporary car parking provision.

2. Closure of Edmund Halley Way

In addition to the failings of the location of the displaced car parking it is noted that the Application proposes the closure of Edmund Halley Way from approximately March 2019 to June 2022 , with a planned diversion located south of, and running parallel to, the existing Edmund Halley Way .

The closure of the existing Edmund Halley Way will result in the entrances to Car Park 2 and the station car park being removed. The Application fails to detail the provision of alternative access to both of these. It is not clear whether new access will be provided to Millennium Way, or whether users of these car parks will be required to travel via West Parkside, and the diverted Edmund Halley Way, further exacerbating the problems already outlined above. Without suitable detail as to the provision of alternative accesses, and appropriate mitigation measures being provided, Knight Dragon considers the Application proposals to be wholly unacceptable and ill-considered.

The proposed location of the Edmund Halley Way diversion will result in a much heavier usage of West Parkside. The Application does not appear to consider the fact that West Parkside is currently a priority bus highway and consideration has not been given to changing this piece of highway to a dual carriageway, with no bus lanes. This would allow greater flexibility and increased road capacity on a road which is likely to become a significant thoroughfare during the construction of the Scheme. Knight Dragon notes with concern that no assessment of this amendment to West Parkside appears to have been considered within the Application.

Knight Dragon therefore objects to the Application on the basis of the proposed diversion of Edmund Halley Way.

3. Diversion of Millennium Way

Knight Dragon has held detailed discussions with TfL on this matter, and is pleased to note that the proposals in this regard have been amended to ensure full access will be maintained along Millennium Way for the full duration of the construction period in response to representations from service providers, operators and businesses.

Knight Dragon notes that there will be some temporary localised diversions during some periods of construction, with traffic moving back to the original alignment once the "cut and cover" section of the Scheme has been constructed. Knight Dragon considers it imperative that any diversions should be kept to an absolute minimum given the importance of Millennium Way as a primary means of access to the Peninsula.

Despite the above Knight Dragon considers that the temporary diversion to the east of Millennium Way seriously disrupts traffic and parking on the Peninsula. An alternative route to the west of Millennium Way can be achieved and would significantly mitigate the impact of the diversion.

Knight Dragon therefore objects to the Application on the basis of the proposed diversion of Millennium Way.

4. Tunnel Avenue Extension to Peninsula Quays

It is noted that the Application seeks the reintroduction of Tunnel Avenue to connect both the north and south of the Peninsula and in line with the east west pedestrian/cycle route.

Knight Dragon considers that this route should be implemented prior to the main tunnel construction to offer an alternative connection north to south that is not currently enjoyed. This will be particularly beneficial as lorries and commercial vehicles wishing to exit Victoria Deep Water Terminal will be able to access main routes without navigating through the Peninsula site which will already be heavily impacted by the disruption to the Peninsula highway network caused by Millennium Way and Edmund Halley Way diversions and relocated car parking.

5. Direct Access to Silvertown Tunnel from Greenwich Peninsula
Knight Dragon considers it important from both an urban design and traffic management perspective that all vehicles have the ability to access directly both the Blackwall and Silvertown Tunnels at the earliest opportunity rather than via the existing access point at the southern end of the Peninsula. Knight Dragon believes that this would have the potential to reduce both congestion and travel times across the River Thames and has the potential to prevent unnecessary southbound journeys along Tunnel Avenue and Millennium Way.
This is also considered particularly important for the success of the emerging Greenwich Peninsula district and particularly for the Meridian Quays neighbourhood which sits on land to the east of the A102. Knight Dragon believes that this can be achieved by designing both the orientation and priorities of the slip way off Millennium Way directly onto the north bound land of the proposed Silvertown Tunnel.
It is noted however that no consideration appears to have been given to alternative accesses to the Scheme and Knight Dragon considers this to be a failure of the current Application.
Direct access, as set out above, would also provide a convenient means of departure of vehicles from the proposed multi-storey car park which will eventually replace the existing surface car parks that serve The O2, particularly following evening events which occur up to 200 times a year. The location of the multi-storey car park in relation to the proposed access to the Scheme does not appear to have been considered within the Application and this omission is considered unacceptable by Knight Dragon.
Knight Dragon therefore objects to the Application on the basis of insufficient consideration of alternative accesses to the Scheme.
6. Other Highway Impacts

Knight Dragon is also concerned to note that whilst the Transport Assessment identifies that "the Scheme does have a significant adverse traffic impact on local junctions and highways links" there is no detailed mitigation strategy for improvements to be made to the local junctions and highways as a result of the Scheme.

It is noted that monitoring of the impacts of the Scheme will take place once the Scheme is completed and operational however Knight Dragon does not consider this sufficient as any impacts will have a significant effect on the redevelopment of the Peninsula under the 2015 Masterplan; any bringing forward mitigation measures "after the event" is not a satisfactory strategy, given the size of the Scheme and the surrounding area.

Greater security is required around what mitigation measures will be provided should surrounding the highway network suffer significant impacts as a result of the Scheme.

Knight Dragon therefore objects to the Application due to the failure to appropriately mitigate the impacts of the Scheme on the wider highway network at an appropriate stage.

7. Failure to Adequately Mitigate the Impact of Construction

The regeneration of Greenwich Peninsula is currently providing, and will continue to provide, much need homes and jobs for London over the coming years. Knight Dragon considers that the impact of the Scheme is so significant that it will adversely impact on the regeneration of the site.

It is important to emphasise that given the proximity of the Scheme to the redevelopment proposals under the 2015 Masterplan, Knight Dragon has been in regular dialogue with TfL to ensure that the continued and accelerated regeneration of Greenwich Peninsula can continue at its present pace; that The O2 car parking remains effective and operational and that the Silvertown Tunnel project can proceed with minimal disruption to the residents, businesses, visitors and workers.

Mitigation of the impact of the construction of the Scheme is proposed to be addressed by the requirement for a CEMP and CTMP to be developed prior to works commencing which would address "a variety of environmental impacts of construction activities, including construction traffic-related impacts" .

Knight Dragon does not consider this to be adequate or appropriate, given the extent of the proposed redevelopment works taking place under the 2015 Masterplan. Despite the regular meetings and workshops, Knight Dragon considers that the Application proposals will cause such significant disruption, which has failed to have been adequately addressed within the Application proposals, that the entire project should be considered unacceptable until such impacts have been appropriately analysed, addressed and mitigated against.

Knight Dragon therefore objects to the Application due to the failure to appropriately mitigate the impacts of the construction of the Scheme.

8. Failure to adequately mitigate impacts on existing buildings

Knight Dragon is aware that TfL are seeking to enter into Settlement Agreements with landowners affected by the DCO to address any mitigation which may be required as a result of settlement arising from the construction works.

Whilst Knight Dragon welcomes this, they are concerned to note that specific provision for the entering into of these agreements is not provided for within the DCO.

Specific provision is made for protective works to be carried out by TfL both during and following the development , but this does not address the provisions which are to be included within the Settlement Agreements.

Knight Dragon considers the measures contained within the Settlement Agreements to be of such importance to the carrying out of the Development, that a requirement to enter into Settlement Agreements prior to the carrying out of the development should be contained within the DCO itself.

Knight Dragon considers that without this, the DCO should be refused.

9. Location of Buildings

Southern Portal Building

Within the designs put forward during consultation in autumn 2015, the southern portal buildings were located to the south side of the tunnel portal. It is noted that the Application states that this was considered "unbalanced" and the southern portal buildings are now proposed to be located on land to the north of the southern portal, on land which benefits from outline planning permission for coach parking pursuant to the 2015 Masterplan.
The Application states that the siting and building arrangement of the southern portal "has been refined and organised to reduce and make equal their impact on neighbouring landowners and their future development proposals" despite the fact that whilst the land to the north of the portal benefits from outline planning permission, the land to the south does not currently benefit from planning permission for any redevelopment, and is further subject to restrictions on development due to the consultation zones in relation to the historic Hazardous Substances Consent relating to the gas holder.

It is also concerning that Knight Dragon was only informed of the new proposed location of the portal buildings, after the expiry of the consultation period with unjustified reasons being put forward in support of this amendment.

The Application infers that both parcels of land are open to the same redevelopment opportunities, which is clearly incorrect. Knight Dragon considers that the proposals now directly impact upon the 2015 Masterplan, which will require amendment to ensure that adequate provision for coach parking is made elsewhere within the site. Knight Dragon considers that the previously identified location of the portal buildings, to the south of the tunnel portal is a much more appropriate location.

Knight Dragon therefore objects to the Application on the basis of the proposed location of the southern portal building and the failure to properly assess and consider alternatives.

Head house

This building is proposed to be located at the northern end of Central Park, on Metropolitan Open Land. It is noted that the Application considers the head houses to be "small structures" despite having a footprint of approximately 50sqm. The size and scale of this building is considered inappropriate in the proposed location.

Additionally, the Application identifies an extremely large and disproportionate area within which the head house can be located. This creates an unacceptable level of uncertainty for Knight Dragon in relation to its ongoing redevelopment of the Peninsula and a smaller area should be identified within the Application.

Knight Dragon therefore objects to the Application on the basis of the proposed location of the southern head house building.

10. Design of Buildings

The Design of the Greenwich Portal Building is stated to be "similar to that of the Silvertown Portal and so together, establish a strong identity for the tunnel and its important within the city's infrastructure" . Whilst the Application states that the design of buildings and structures have been designed to integrate with the 2015 Masterplan Knight Dragon fails to see how this can be stated, given that limited consultation has taken place with Knight Dragon on the design of the buildings.

The final design of the buildings is currently undefined and the detailed design is to be brought forward in accordance with the principles and parameters as set out in the Design Principles submitted with the Application. The detailed design will be the responsibility of the Contractor for the Scheme. Knight Dragon is concerned to note however that the Design Principles in relation to the Greenwich portal building (GREPO.01 to GREPO.02) make no reference to the design of the portal building integrating into the 2015 Masterplan. Knight Dragon considers that this should be a Design Principle applicable to the design of the Greenwich portal building.

Given the strategic importance of the 2015 Masterplan, and the size and scale of the buildings, Knight Dragon considers that the design of the buildings to be located on the Peninsula should be approved by Knight Dragon to ensure that the buildings comply with the objectives for the 2015 Masterplan as a whole. The design should be brought forward at an early stage to ensure compliance with the redevelopment proposals and place making objectives of the 2015 Masterplan.

The Applicant has so far failed to commit provide any assurances in this regard and Knight Dragon therefore objects to this element of the Application.

11. User Charging

Knight Dragon is concerned with regard to the proposed charging for users of the Scheme and considers that the residents of the Peninsula will be directly impacted by these proposals.

Whilst the principle of user charging at peak periods is generally supported, Knight Dragon considers that user charging outside of peak periods will have a detrimental impact on the success of the Peninsula for both residents and businesses. It must also be emphasised that the introduction of tolling at these major river crossings is considered deeply unfair to both residents and other users of the Peninsula, as well as the wider south east London area, given that residents in other parts of London are not required to pay a toll to cross the river. In the event that Silvertown Tunnel proceeds, Knight Dragon considers that all river crossings should be treated equitably. If this is not done, Knight Dragon objects to the overall principle of user charging for both the Scheme and the Blackwall Tunnel.

It is noted that the main aim of user charging is primarily to reduce "induced traffic" and secondarily to provide reimbursement towards the costs of constructing, operating and maintaining the Scheme. However, Knight Dragon does not consider that the impact on residents and businesses on the Peninsula has been adequately assessed.

Knight Dragon is concerned to note that the Application states that "the charges for the Blackwall and Silvertown Tunnel would apply to a relatively confined stretch of highway where there are no residential dwellings" . Whilst this may be the case at present, there will be a high level of residential dwellings in the medium to long term due to the implementation of the 2015 Masterplan.

It is further noted that users would have a choice to use either the charged crossings, or change their route to an uncharged crossing. Knight Dragon believes that this would cause significant disadvantage to residents of the Peninsula, due to the close proximity of the Scheme and residents would have to travel significantly further in order to access a crossing not subject to charging. Knight Dragon would consider this to cause significantly more than "some inconvenience" to residents. Further Knight Dragon is surprised that this would be considered a sustainable way to travel.

Knight Dragon considers that further assessments should be made in relation to a reduction in charging for local residents and businesses, and consideration should also be given to car club users, a sustainable transport measure which Peninsula residents will be able to benefit from.

Knight Dragon welcomes the proposals for charging at both the Blackwall Tunnel and the Silvertown Tunnel to ensure that access to river crossings in this location is fair (subject to other major river crossings being subject to the same charges, as stated above). However, Knight Dragon believes that consideration should be given to charging being introduced for the Blackwall Tunnel prior to the implementation of the Scheme. The significant beneficial impacts of charging for the Blackwall Tunnel are considered within the Application and Knight Dragon considers this to be of such significant benefit that it should be introduced as a mitigation measure to reduce the construction impacts of the Scheme.

12. Programme

Whilst Knight Dragon notes that there is a high level programme contained within the Application with a commencement of development beginning in 2019, it is noted that there is no detailed programming in place in relation to the replacement of essential facilities namely the temporary car parking, access roads and pedestrian and cycle links.

Knight Dragon considers this to be wholly inadequate, given the importance of these facilities to the Peninsula, as well as the redevelopment of the site pursuant to the 2015 Masterplan. These details should be included within the Application as soon as possible.

In addition the current delivery programme is elongated due to TfL’s procurement route (PFI) and Knight Dragon considers it appropriate that an alternative procurement is pursued to reduce the delivery timescale. This will have huge benefits to the local area, users and businesses alike.

13. Failure to Address the Existing Safeguarding Direction

Reference is made within the Application that a benefit of the Scheme is to "unlock" the future regeneration of the land which is current subject to safeguarding and that "once the scheme is complete, the rest of the Safeguarding Area not used will become available for development".

These assertions are incorrect: the existing safeguarding only provides a heightened level of consultation in relation to development of the safeguarded land, as opposed to preventing development coming forward at all. Knight Dragon therefore wishes to ensure that any safeguarding is brought to an end at the earliest possible time.

Despite the Application making reference to the safeguarding falling away upon completion of the Scheme, no provision is made for a direction to be made ensuring this. Knight Dragon therefore considers that the appropriate direction should be included within the draft Development Consent Order ensuring that upon completion of the Scheme, the 2001 Direction is cancelled.
Conclusions

In conclusion, whilst Knight Dragon is generally supportive of the principle of the Scheme, it is considered that the Application is significantly lacking in relation to the consideration of alternatives, adequate assessment of existing proposals and adequate provision of mitigation measures that the Scheme will cause a significant detrimental impact upon the regeneration of Greenwich Peninsula and the implementation of the 2015 Masterplan.

Failure to address the points outlined above will result in conditions that put the delivery of much needed homes and jobs for London in jeopardy.

Knight Dragon considers that the objections highlighted provide sufficient justification to warrant the Application being considered deficient and wholly unacceptable and that Development Consent for the Application should be refused.

Should Development Consent be granted, without the above objections being addressed, Knight Dragon would consider any such grant to be open to challenge by way of judicial review.

Should you wish to discuss the contents of this letter or require any further clarification please do not hesitate to contact the writer, Neil Smith, at the below details.

Yours faithfully

Neil Smith
Head of Planning
T +44 (0) 203 440 7201
M +44 (0) 782 501 6288
[email protected]
www.knightdragon.com


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