Additional comments re Appeal against refusal of Planning Application 2016/1117/P

This representation is in addition to the one I made to the Planning Application 2016/1117/P when it was first published. It is not a replacement. I am against this appeal and both my previous objections and the ones set out below give my reasons.

REASON FOR REFUSAL 1 - LOSS OF EMPLOYMENT

Any provision of employment space that the developers claim to include should be considered in the context of the jobs that may be lost in the neighbouring business - Rainbow Wave. This is a fashion business and currently enjoys a great deal of light in their large showroom. This natural light is vital to their particular business which depends on colour. The proposed development will completely overshadow their showroom as one of the buildings is very close to their boundary and is nearly twice as high as their building - Eagle Wharf.

REASON FOR REFUSAL 5 - PROVISION OF AFFORDABLE HOUSING

Undeniably Camden needs more housing and Bangor Wharf is an unused site but this proposed development appears not to reach the Council's Affordable Housing Target now and this may be raised in the future i.e. before the development actually takes place. Policy H4 in the draft Camden Local Plan 2016 appears to set a much higher target.

REASON FOR REFUSAL 6 - HEIGHT, MASS, SCALE AND DETAILED DESIGN

This developers' response to this reason for refusal seems to be roughly as follows: 'We are right and you are wrong because design is subjective'. They have quoted an email from the Case Officer and picked out 'in general terms' and 'broadly supported' and taken this to mean 'supported'. They have ignored the fact that the Regents Canal Conservation area limits the height of any proposed development to ensure it fits well within its context and does not detract from its character and appearance. How can a huge, dense development not detract from the character of this part of the canal? How can a huge building nearly twice the height of a period warehouse - Eagle Wharf - not detract from its character? How can the developers possibly claim that it can't 'fail to either preserve or enhance the character and appearance of Regent's Canal Conservation Area'? How can a hard, overshadowed courtyard provide 'attractive, enjoyable and valuable amenity space for employees, residents and neighbours'? This courtyard is only accessible through a gated tunnel-like entrance, off a little used street and will be in shadow most of the time. Why would the public choose to visit this courtyard when there is a much more accessible and inviting towpath on the other side of the canal?

REASON FOR REFUSAL 7 - ACTIVE FRONTAGE TO GEORGIANA STREET

The developers claim that providing new public space as a courtyard is a plus point but why since there will be no reason for the public to use it? This part of Georgiana Street is not much used by pedestrians but they go down it to access the canal towpath on the other side of the bridge. Why would they want to go into a courtyard which is almost always in shadow and with very little accessible pathway when they have the alternative of an open sunny towpath within a few yards of the proposed gated, tunnel-like access through the middle of the development? Most people will assume it is just a private access for the residents. The developers say that one of the business units will have a window looking onto the entranceway. Is this intended for a watchman or would-be vigilante? Windows work both ways and some businesses would not like to open to the public gaze even if the public could find the entranceway in the first place.

REASON FOR REFUSAL 9 - OUTLOOK, PRIVACY AND DAYLIGHT FOR EXISTING RESIDENTS

The opening onto the water is described as 'generous' by the developers. The actual entrance is narrow and made narrower by the railings and gates. An 'open' aspect is claimed for many of the existing houses. What is meant by 'many'? Most of the flats in Royal College Street currently have a view of the canal from the top floors. How can this be maintained when they are looking out onto a 5 or 6 storey building - stepped back or not? How can the impact not be overbearing? It will cut out most of their sky and light. The houses in Royal College Street are mostly divided into flats and some of those flats are subdivided into bedsitters. Consequently, the rooms that the developers class as non-habitable or bedrooms are actually used as sitting rooms as well as bedrooms or kitchens. The houses in Royal College Street will not only be much darker and lose any views that they currently enjoy, they will also be overlooked from the windows, balconies and terraces of the new development and shut in by towering brick walls just yards from their flats.These residents are mostly tenants but they are not well-off. They could not afford even the few so-called affordable flats that the development is apparently providing. The proposed daylight levels in some of these rooms are dismissed by the developers with the implication that it is for the greater good that the numerical values set out in the BRE Guidelines are not achieved. Isn't it really for developers' good?

REASON FOR REFUSAL 18 - ENHANCEMENT OF THE CANAL

The overshadowing as shown in the developers' document 'Daylight and Sunlight Report, Appendix B' the drawings 1944_203 and 1944_204 clearly show the effect in March of shadowing from such high buildings. This will seriously alter the biodiversity of the canal. It will also affect the plant growth on the opposite towpath bank as well as the nature reserve. The developers claim that it will offer public access to their side of the canal but it will be at the cost of killing off growth on the side where growth is currently healthy e.g. the existing towpath and the nature reserve. It will also have a serious effect on the canal itself by depriving it of sunlight and daylight. What they describe as high quality landscaping is simply a hard landscape with a few insignificant trees which will have to survive without much light or sun.

In this 'Statement of Case' the developers make use of empty words such as: 'high quality; opportunities for biodiversity through variety of plant species; rain gardens; enhancing the appearance; valuable amenity; generous'. They emphasise the opening up of the canal as a public space. Will it really do this when it is so unwelcoming? What is the cost to the residents of Royal College Street and the people trying to run a business next door at Rainbow Wave? What is the cost to the canal users or those who currently enjoy the existing towpath?

CONCLUSION

This site is in a particular position and any construction will have a dramatic effect on the very close neighbouring properties and the lives of the inhabitants. Development on the site is inevitable and necessary but this development must be sensitive to the people living around it and to the biodiversity and heritage of the area. It should not be just a question of 'ticking boxes'.

The residents of Royal College Street and Reachview Close, and the managers of Rainbow Wave would welcome a site visit by the Planning Inspectorate as it really is important to see the site in person before deciding on its future. Google maps are not enough.

Many thanks.

Penny Gamez