OPEN Dalston objections to Ridley Road Shopping Village redevelopment: planning application 2017/2897

1                    51-63 Ridley Road London E8 2NP is a substantial and strategically located building 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 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 shopping village traders, 
-     1,567sqm of studios on the first and second floor (Use Class B1) providing work and exhibition space for approximately 60 artists.

2                    The owner’s planning application has been recently amended. The development proposal is now, in summary, for:
-     a change of use of the basement floor by conversion of the storage units into office use
-     the extension of the ground floor building frontage forward to the pavement edge
-     a reduction in the number of ground floor small retail units from 60 to 20 units
-     the refurbishment of the first and second floors to create “high standard of commercial accommodation” and
-     development of a new third floor comprising five “very high standard” flats for families ( 4x3 beds and 1x2 beds) all for private sale.

3                    Once redeveloped the building will comprise:
-     535sqm retail, 73sqm of storage plus other uses at ground floor level
-     2,602sqm of employment workspace at basement, first and second floor level of which 10% will be capped at 80% of market rents
-     5 luxury flats at third floor level

4                    For the reasons explained below the development proposals are contrary to the Council’s planning policies and should be refused. The development would threaten the character and sustainability of the street market by the loss of 40 of the existing 60 small affordable retail units, by the loss of 90% of existing ancillary storage facilities, by the replacement of existing affordable artist’s studios with unaffordable “high standard of commercial accommodation” and by the introduction of five private family homes with residential interests which will conflict with the market’s commercial interests.  

5                    The planning authority should undertake an equalities impact assessment of the proposal.

Loss of affordable retail units

6                    Planning policy designates Ridley Road as primarily for retail uses. If the development is approved there will be an overall loss of 344sqm (40%) of ground floor retail usage with the remainder of the ground floor uses being used for storage, cycle storage, lobbies and an office. 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.

7                    The existing retail units in the Shopping Village are affordable for independent traders due to their small size.  The development would see a reduction from 60 to 20 small retail units ie the loss of 40 (66%) of the existing affordable retail units For this reason approval of the development 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”.

8                    The reduction in affordable units will in turn result in a reduction in the diverse range of affordable 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.

9                    Whilst there will be re-provision of 73sqm (10%) of storage space this will be on ground floor level prime retail space and so is unlikely to be affordable. The proposed use of prime ground floor retail space for storage, cycle racks, refuse storage and an office would be an inefficient use of land.  

Loss of storage facilties for traders

10                If the development is approved all existing basement storage use will be replaced by office use, although 73sqm storage would be re-provided on the ground floor. There would be a net loss of some 645sqm (90%) of the existing storage space which is used by street market and Shopping Village covered market traders.

11                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 compromises 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’.

12                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. In addition the Shopping Village is used for overnight storage of street market traders’ barrows which, if the development is approved, will in future have to be left out on the street or pavements overnight. For these reasons approval of the development  would be contrary to the Council’s policy of seeking to “promote and secure improvements to the markets' environment, and management” 

Loss of affordable cultural workspace and increase in office accommodation

13                If the development is approved there will be an increase in office accommodation from 1,567sqm to 2,602sqm 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. 

14                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.

15                In fact many sectors in the cultural 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

16                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.
17                It is correct that the numbers of traders in the Shopping village has recently reduced significantly however this has arisen from poor management, threats of eviction and the perception that redevelopment was imminent.

New family homes to conflict with market uses

18                The Dalston Area Action Plane policy DTC24 designates Ridley Road for   “predominantly retail/market use with residential above
19                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 a 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 this 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 and the Council’s market management.
20                Whilst there is policy support for residential development above retail we suggest that family homes, as opposed to single person’s accommodation, are inappropriate

Planning Conditions

21                If permission is granted a planning condition should be required preventing the later amalgamation of the small retail units into larger retail units.
1st April 2019

ADDENDUM to OPEN Dalston objections to planning application 2017/2897
Site Address 51-63 Ridley Road London E8 2NP 

1                     We refer to our objections dated 1st April 2019 . We now add an additional objection. The application includes building over the existing forecourt of the Ridley Road Shopping Village which is presently used for night time storage of street market traders’ barrows. There is a shortage of such storage facilities locally. Approval of the application to redevelop the forecourt 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’.

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