1
These
further objections are made in the light of:
a. revisions made to the planning
application lodged by the applicants agents CMA Planning on 18.11.19 and
b. Hackney Council’s decision dated
13.12.19 that 51-63 Ridley Road is an asset of community value
2
51-63 Ridley
Road London E8 2NP is a substantial and strategically located building and land
on the central north side of Ridley Road. It has a covered market on the ground
floor known locally as the Ridley Road Shopping Village. It presently
comprises:
- 60
small retail units ( Use Class A1) occupying
879sqm on the ground floor which are presently
occupied by about 20 independent, and predominantly black Asian and minority
ethnic, business owners
- 718sqm
storage facilities in the basement (Use Class B8) which is predominantly used as
ancillary storage (for retail stock and barrows) by the street market and covered
market traders,
- 1,567sqm
of studios on the first and second floor (Use Class B1) providing work and
exhibition space for approximately 60 artists.
- a
forecourt providing day time and night time open amenity space including use in
part for night time storage of street
traders stalls/barrows
3
The planning
application has been revised on 18.11.19. The development proposal now
appears to be, in summary, for:
- a
reduction from 718sqm to 300sqm (58%) of
B8 market storage facilities in the basement and a change of use of the
remaining basement by conversion into B1 office use
- a
65% reduction in the number of ground floor small retail units from 60 units of
approximately 9sqm each totalling 540sqm to 21 units of approximately 9sqm each
totalling 200sqm with the remaining
ground floor use to comprise A1 circulation/storage/entrance/lift, B1 office lobby and core of 139sqm and C3
residential lobby and core of 123sqm
- the
refurbishment of the first and second floors to create 1,435qm “high standard of commercial accommodation”
and 56sqm C3 residential core
- the
omission a ground floor building extending across the frontage forward to the
pavement edge but instead to retaining it as landscaped open space
- development
of a new third floor comprising 484sqm
C3 residential being five “very high
standard” flats for families ( 4x3 beds and 1x2 beds) all for private sale.
4
The proposed
development will require a change of use of part of each floor of the building
by the addition of B1 use on the basement floor, B1 and C3 use on the ground
floor, C3 use on the 1st and 2nd floors, and C3 use on
the new third floor.
5
For the reasons explained
below the development proposals are contrary
to the Council’s planning policies and are detrimental to the social wellbeing
and social interests, including the cultural and recreational interests, of the
local community.
6
The planning
authority does not appear to have undertaken an equalities impact assessment of
the proposal.
7
For these
reasons the application is objected to and should be refused.
Detriment to the social wellbeing and
social interests of the local community
8
The
Council’s decision that the land and building at 51-63 Ridley Road is an asset
of community value is a material consideration when a development application
for changes of use is considered. The decision noted that the existing uses of
the building, namely the small retail units, storage areas, open space and
cultural and creative uses of the upper floors, contribute to the social
wellbeing of the community and that the building and land had been used in its
current form for a considerable amount of time and that this was an actual use
which furthered the social wellbeing or social interest of the local community and
which satisfied the statutory requirements for reaching the decision.
9
The proposed
development would harm the social wellbeing or social interest of the local
community by the loss of 39 of the existing 60 small affordable retail units by
their replacement in part to service upper floor B1 office and C3 residential uses,
by the loss of 50% of existing basement market storage facilities and
replacement in part by B1office uses, by the replacement of existing affordable
artist’s studios with “high standard of
commercial accommodation” of which only 10% are to be affordable and
replacement in part to service residential uses above, by the introduction on a
new third floor of five private family homes with residential interests which will
conflict and compete with the market’s commercial interests and by the proposed
landscaping of the open space which would prevent its use in part for overnight storage of
street market stalls/barrows.
Loss of affordable retail units
10
Planning
policy designates Ridley Road as primarily for retail uses. If the development
is approved there will be an overall loss of 39 (65%) of ground floor indoor market
stalls. Approval of the development would be contrary to the Council’s draft
Local Plan Policy LP40.A.i, which resists permanent loss of market pitches, and LP33.D6 which provides that
development in Ridley Road should “ further enhance the retail offer”
whereas the proposed development would substantially reduce the retail offer
and the diversity of that offer.
11
The existing
retail units in the Shopping Village are affordable for independent traders due
to their small size. The reduction from
60 to 21 small retail units without alternative provision would be contrary to
the Council’s policy DM8 which requires “proposals
for the redevelopment of small shop units to incorporate adequate reprovision
of small shop units”.
12
The reduction in affordable
units will in turn result in a reduction in
the diverse range of affordable and specialist products which the market
presently offers its customers and as a consequence will result in a loss of
local character and diversity contrary to Council policy.
13
The proposed
use of part of the prime ground floor retail space for storage, cycle racks,
refuse storage and an office would be an inefficient use of land.
14
Approval of the development would also be contrary
to emerging New London Plan policy E9. B.7 which expects LPAs to “support the range of London’s markets, including
street markets, covered markets, specialist and farmers’ markets, complementing
other measures to improve their management, enhance their offer and contribute
to the vitality of town centres and the Central Activities Zone”
Loss of storage facilties for traders
15
If the
development is approved half of the existing basement storage use which is used
by street market and Shopping Village covered market traders will be replaced
by office use.
16
The existing
on-site storage facilities are critical to the sustainability of the businesses
of the traders who use them. Without on-site storage facilities traders will
incur the additional costs of transporting goods daily from off-site stores and
holding stock locally during the trading day. This will add to traders’
overhead expenses and compromise their businesses’ viability. For these reasons
approval of the application would be contrary to the Council’s draft Local Plan 2033 and its Core
Strategy Policy 14 which is to “protect
and promote” Ridley Road market. Approval would also be contrary to its
Development Management Local Plan Policy DM 13 which requires “Safeguarding sites allocated for the storage
of market equipment, market facilities and parking for traders’.
17
Approval of the development
will result in traders having to resort to commercial vehicles for transporting and holding their stock locally
which will increase road and parking congestion, and air pollution, on local
roads and in the market at the commencement and close of the trading day.
18
The Shopping
Village forecourt is used for overnight storage of street market traders’ stalls/barrows
for which no alternative storage is proposed or available locally. For these reasons approval of the development would be contrary to the Council’s policy Policy
DM 13 and of seeking to “promote and
secure improvements to the markets' environment, and management”
Loss of affordable cultural workspace
and increase in office accommodation
19
If the development
is approved there will be an increase in office accommodation which, as
explained above, would be at the cost of a substantial reduction in retail and
ancillary storage space and of affordable artists’ studios. Ridley Road is not
designated for employment workspace. Approval of the development would be
contrary to the Council’s policy (LP33 PP2) which designates Ridley Road for development opportunities which further enhance the retail offer
whereas this proposal significantly reduces that offer.
20
The
development proposes a “high standard of
commercial accommodation” and the applicant relies upon its consultant’s
opinion that the existing offices on the 1st and 2nd
floor are “not fit for purpose”
because, for example, they lack raised floors, air conditioning, server rooms
and cabling which tenants “particularly
those in the creative industries”
require.
21
In fact many
sectors in the creative industries have no requirement for ‘tech hub’ type facilities
. The existing offices have been used as artists’ studios and exhibition space
for over 13 years and that use could conveniently continue. What the cultural
industries primarily require is affordable workspace but the expenditure anticipated
to meet the proposed “high standard of
commercial accommodation” will render the offices unaffordable. Only 10% will
be reserved as “affordable” and this is defined by the applicant as 80% of
market rent whereas the Council’s policy LP29 C ii provides for 60% of market
rent. Approval of the development would
be contrary to the Council’s policy DM6 and LP10 which commits the Council to resisting
the loss of cultural facilities unless
it is “necessary
to secure a development which will deliver wider planning benefits for the
community” which this development does
not claim to and will not deliver. We also
refer to New London Plan policy HC5.1 which expects LPAs to “protect existing cultural venues, facilities
and uses”
No gain in employment opportunities
22
The
applicants consultants advise that the development could support 137 jobs. The
existing uses provide employment capacity for some 60 artists and some 90
traders in the 60 retail units. It is not considered that the proposed
development would provide a greater number of employment opportunities than the
existing development nor increase footfall to benefit the market.
23
It is
correct that the numbers of traders in the Shopping village has recently
reduced significantly however this has arisen from historic poor management,
threats of eviction and the perception that redevelopment was imminent.
New family homes to conflict with market and
night-time economy uses
24
The Dalston
Area Action Plane policy DTC24 designates Ridley Road for “predominantly retail/market use” with
residential above.
25
Ridley Road is a 6-day week street
market. Traders are permitted to set up from 6am and are required to trade during
the trading day and vacate the road by 6pm or 7pm on Friday and Saturday. There
is a popular neighbouring licensed premises with permitted hours extending to 3.30am
on Thursday-Saturday. Absent extensive acoustic insulation, Ridley Road is
unsuitable for noise-sensitive uses.
26
The existing
residential accommodation in Ridley Road comprises hostel accommodation for
single people above ground floor retail uses. The development of 2 and 3 bedroomed
“very high standard” private family
homes in this bustling street market is without precedent. The applicant’s acoustic consultants advise
that the “front [façade] will see noise
levels in excess of upper guidelines” and these levels cannot be mitigated
for exterior balconies or when windows of the flats are opened. The development
is likely to give rise to conflict between the competing interests of resident
families, market traders, the Council’s market management and night-time
businesses.
27
Whilst there
is some policy support for residential development above retail we suggest that
residential uses, and particularly family homes as opposed to single person’s
accommodation, are inappropriate.
Planning Conditions
28
If
permission is granted planning conditions should require the prevention of later amalgamation of the small retail
units into larger retail units and require a higher proportion of upper floor
affordable office units and ground floor affordable retail units.
13th February 2020
I feel like the proposals were planned out of site of the people who use the market and they knew the effects way before it was announced.
ReplyDeleteI feel like this is another part of ethnic cleansing where they will be genrifying the area so that the enthic culture and people are not seen.
They say that they can provide jobs but overheads will not be affordable to the general existing people in the area.
I feel that the is another way of wiping ethnic people out just like Tulsa because there is an agenda and we will soon learn by finding out who or what kind of person is behind this and how much profit do they make.
This is all about profit but buy destroying a people and their form of living and culture destroys history and families for selfish disconnected needs that are totally inconsiderate.
We need to fight against the institutional racist dicisions of these people who can't stand to see us prosper.