Objections
Below are some objections that have already been submitted to Islington Council.
If you wish to write an objection of your own then you should send an e-mail to:-
Simon.greenwood@islington.gov.uk, planning@islington.gov.uk
...with this subject: P2016/4805/FUL Regent's Wharf
You should supply your full name and address and if appropriate please state any connection you have with the canal, the area, heritage, architecture, etc.
You might find it useful to read the council's own policy guidelines that apply specically to this stretch of the canal.
Possible reasons for objecting
- Contraventions of the council's conservation area policies.
- Loss of daylight for nearby homes and for the canal.
- Unsympathetic architecture (especially the proposed dormer windows)
- The applicant wants to use HGVs rather than the purpose-built canal for all deliveries and waste. See pages 19 and 21 of the Construction and Waste Plan. Yet this site is on the same stretch of the canal as King's Place, where the canal was put to proper use during construction.
From: Malcolm T. Tucker
To: 'simon.greenwood@islington.gov.uk'
Subject: Regent's Wharf, P2016/4805/FUL, GLIAS objection
Dear Mr Greenwood
Please find attached the Greater London Industrial Archaeology Society's objection to the Regent's Wharf proposals.
Yours sincerely
Malcolm Tucker
Voluntary Caseworker for GLIAS
Please click here to see this objection in full or else you can open it in PDF format .
Objection from CBOA (Commercial Boat Operators Association)
Dear Mr. Greenwood,
The Commercial Boat Operators Association (CBOA) represents water freight carriage by barge on the UK's inland and estuarial waterways and is accepted by the Government as the representative industry body.
The CBOA has an interest in promoting use of the River Thames and London's canals and basins for carriage of freight by barge, to relieve road congestion and reduce exhaust emissions. This is particularly relevant where movement of materials is proposed for developments that are adjacent or near to waterways. This is in line with Government proposals for assisting reduction of road congestion in London. (See GPG 2122 - Planning for Freight on Inland Waterways www.aina.org.uk/docs/Planning4freight(1).pdf, and also the London Plan http://www.london.gov.uk/priorities/planning/london-plan; the latter as a good example of use of the 'Blue Ribbon Network' of navigable waterways for freight). Leeds, Tower Hamlets and Greenwich in London are examples whose local authorities are keen on freight use of waterways in this way.
I refer to the statements in the Construction Management and Site Waste Management Plans, Report ref number 8/1396, sections 3.19 and 4.8 as follows:-
Section 3.19 Traffic Management - Regents Canal
The Regents Canal has always been used for freight traffic, albeit more irregularly in recent years, and is fully capable of allowing deeply loaded full size barges and other special purpose craft to navigate carrying waste from construction work and also construction materials to site. To say that there is "...lack of navigable width and depth" is therefore inaccurate as a statement. CBOA has commercial barge operator members who operate on this canal and can vouch for its useability. Therefore full use of the Regents canal for assisting with freight to and from site should be recommended, and a report should be requested demonstrating how this can be achieved.
London has a difficult problem with road traffic congestion, air quality and hazard. To eliminate exacerbating these issues with extra lorry movements when the canal could be used instead makes very good sense.
To conclude, some of the advantages of barge transport are listed below:-
- Significant reduction of road congestion
- Lower risk of road accidents/fatalities
- Lower noise on highways
- Reduced highway wear and tear from HGVs, meaning lower long term highway maintenance costs
- Lower fuel consumption meaning reduction of the carbon footprint
- Lower exhaust emissions, meaning less air pollution in the district.
- Each barge can carry 2 or more lorry loads.
- For just the excavation alone, if the estimated quantity of material is 11,300 tonnes, this represents approximately 565 lorry loads or 1,130 lorry movements (for 8 wheel solid axle lorries).
Section 4.8 - Deliveries and Removal of Plant and Materials
An additional function that barges can provide is additional storage area for materials awaiting use on site, where space is limited.
Canal transport is stated to be "...inefficient and unsustainable" due to transshipping to lorries for the final journey. This does not have to be the case as barge borne waste can be taken directly to a canal side waste recycling depot at Park Royal, Powerday. Therefore it can be efficient in addition to environmentally friendly in every way as shown above.
The depth issue, as mentioned again has been covered above.
There are many places where health and safety issues are adequately catered for beside water side premises and works. Many people work alongside water and the training of personnel and provision of safety equipment is a matter of course to prevent this being of any consequence.
Environmental and ecological impact by using barges on the canal. In the same section 4.8, protection methods have been described to prevent material from vehicle wheels from being washed into the canal. Similarly, procedures can be put in place to prevent any contamination of fluid waste (run off or drip) into the canal, and also for solid waste. If this is of particular concern for solid matter due to the possible hazardous nature of some of the material, containers or bags could be used, filled away from the canal area. With careful lifting, no spillage into the canal would occur. Again, this issue can be satisfactorily resolved with adequate planning and procedures.
I hope that this provides you with some useful information on how the Regents Canal could be successfully used for construction. Please feel free to contact me in the first instance if you require further information. I would be pleased to assist.
Yours sincerely,
Richard Horne.
Commercial Boat Operators Association (CBOA)
2 High Street, Eccleshall, Stafford ST21 6BZ,
Tel 01252 844259; Mob 07792 149942
r.horne@cboa.org.uk
The CBOA is the prime trade organization involved in sustaining and promoting freight carriage on our waterways for economic and environmental reasons.
Regents Wharf Development - Review of Daylight and Sunlight Assessment Executive Summary
The GIA daylight and sunlight study has been undertaken in line with the general principles set out within the BRE Guidelines, has employed the full suite of recommended assessment methodologies and has used data that is of a quality commensurate with the scale and nature of the proposed development. The report identifies a large number of windows that do not meet the standard assessment criteria and in response, focusses heavily on the references within the guidelines that acknowledge the need for a flexible approach when applying the criteria.
Further reference is made to precedents for adopting reduced target values for retained levels of daylight and in line with these, a lower target value is used. However, with the proposed development in place, 44 of the windows belonging to the neighbouring buildings fail to achieve this reduced target. Further tests are applied in an attempt to examine the impacts using different techniques and reference is made to the architectural design of the impacted buildings suggesting it is this that is the primary reason for the low levels of daylight.
This review has identified numerous instances where it is considered that the 'flexible' interpretation of guidance has been pushed way beyond what is reasonable and as a result, many rooms will be left with significantly reduced levels of daylight. Whilst it is acknowledged that a degree of impact on the amenity of neighbours is often unavoidable when developing in dense urban environments, there does have to be an acceptable limit nevertheless. In this case, GIA's assessment has identified that there will be significant impacts, but has tried to justify that this is acceptable. However, the fact that GIA's analysis shows one of the main living rooms of an apartment within Ice Wharf to be left with no natural daylight whatsoever, highlights just how far beyond reasonable limits the interpretation of results has been pushed. Notwithstanding the significant impacts to the 40 or so rooms highlighted by the report, the fact that the proposed development would leave at least one main living room completely devoid of daylight would be in complete contradiction of the Council's planning policy. On this basis alone, it is the conclusion of this review that the application should be refused.
Simon Herrington BEng CEng MICE CWEM MCIWEM
The above comments have been copied from this Executive Summary and further details are available in this 8-page report .
Dear Mr Greenwood,
I would like to raise objections to the above planning application.
I am aware of Conservation Area Seventeen Regent's Canal West.
17.3. The proposed design will harm the character of the conservation area. In particular the giant dormer windows are ugly, inappropriate and completely out of keeping.
17.7. The scale of the proposed development is oppressive and overbearing and not appropriate to its location.
There will be a significant loss of light to both adjacent buildings and the Canal if the development goes ahead as proposed.
I have been an Islington resident since 1985 and a member of the Angel Association for almost 20 years, serving on the committee for 13 years (7 as Secretary). I am also a long standing member of Friends of Regent's Canal and care deeply about our beautiful Canal.
Yours sincerely
Beverley Dean
Objection from NBTA (London branch)
Dear Simon Greenwood,
The National Bargee Travellers Association London branch strongly object to the planned redevelopment of Regents Wharf area on the following grounds: firstly, that needs boat dwellers in the area have not been considered.
Under the Planning and Housing Act, Section 124 "Assessment Of Accommodation Needs" states:
"In the case of a local housing authority in England, the duty under subsection (1) includes a duty to consider the needs of people residing in or resorting to their district with respect to the provision of-
(a) sites on which caravans can be stationed, or
(b) places on inland waterways where houseboats can be moored."
http://www.legislation.gov.uk/ukpga/2016/22/section/124/enacted
On looking at the proposal, the above has not been taken into consideration.
Secondly, the plans demonstrate a huge decrease in light as a result of an overshadowing and overbearing proposed building, which will have a direct impact on any moorings.
Furthermore, the height of the buildings are likely to create a wind tunnel, which will be unpleasant and dangerous for boats on moorings, and which is likely to deter other canal users and visitors to the canal.
We would like to see the needs of boat dwellers considered in your development of Regents Wharf, according to Section 124 of the Planning and Housing Act.
Best wishes,
Marcus Trower
Chair of the National Bargee Travellers Association London branch
P2016/4805/FUL Regent's Wharf
To: Simon.greenwood@islington.gov.uk,planning@islington.gov.uk
Dear Mr Greenwood,
I am writing as a resident of Islington and as a canal user to object to several features and arrangements in the Regent's Wharf planning application.
Please note that I have been chair of the Friends of Regent's Canal since December 2010, but on this occasion I am writing in a personal capacity since we have not had the opportunity to discuss this plan at any of our public meetings.
You will have read the comments on page 19 of the Statement of Community Involvement where it was stated that feedback was positive at our public meeting on 19th September. I agree with this, because nobody had any objections in principle to the idea of re-configuring the. internal courtyards and there did not appear to be any impact on the canal. However, since the detailed plans have been published several of us have noticed significant changes to the height and appearance of the warehouse buildings and the feedback would be much less positive if we were to hold another meeting.
I object strongly to the statements on pages 19 and 21 of the Construction and Waste Plan, where the Clancy consultants have ruled out the use of the canal for [environmentally friendly] transportation of deliveries and waste. Their excuses are poor. There is a canalside waste recycling centre a few miles upstream, so there is no need to transfer to lorries at the other end. Also, it is totally wrong to suggest that the canal is not deep or wide enough to accommodate barges in this section of the canal. The evidence for this is illustrated in these photographs taken during the construction of the nearby King's Place.
http://friendsofregentscanal.org/features/freight/Kings-Place/Kings-Place-construction.html
I urge the council to reject this construction and waste plan and to make it very clear to the developers that the residents of central London do not want any avoidable use of HGVs on our busy streets. The canal is quite fit for purpose for transportation of construction and waste and this is a rare opportunity to revive its main function.
I object strongly to the large dormer windows proposed for the raised roof on the Eastern End. These are unsightly and unsympathetic to the style of the historic warehouse.
I am concerned about the loss of light due to the increased height of the buildings. This affects not only the nearby residents but also the wildlife in the canal and the usage of solar panels on boats.
I am concerned that several of the council's own guidelines for this conservation area are being ignored. I have attached a copy of these guidelines to this e-mail and they are also available via this link.
20120303ca17regentscanalwestdesignguidelines
I am concerned that the plans assume that all refuse and recycling will be collected via road vehicles. (See section 7 of the Design and Access Statement). Can you please get an assurance from the developers that the plans are future-proofed to ensure that refuse and recycling can be collected by boats as well as by road vehicles?
Please keep me informed of any changes to these plans or of other decisions relating to them.
Best wishes,
Ian Shacklock
Dear Mr Greenwood,
I write to you on behalf of the Islington Society and also the Islington Archaeology and History Society. James Dunnett a committee member of the Islington Society has already written to you in respect of the Regent's Wharf planning application. He has now alerted the Islington Society and the Islington Archaeology and History Society to the planning application. Both Societies have now looked at the planning application and are disappointed and unhappy and write to object.
I would first copy below James Dunnett's e-mail to you as it expresses our two Societies' general views of the proposed development.
"As a nearby resident (Barnsbury Road) who loves the canal and often walks along the canal towpath, I should like to submit my personal strong objection to this proposal. Canals are like streets, but quieter and more pleasant - they cannot be allowed to turn into canyons. The buildings along this stretch of canal, rising sheer from the water, are quite high enough already. Fortunately on the opposite side of the canal along this stretch the buildings are lower and set back behind landscaping, but that cannot be allowed to mean that overdevelopment should be permitted on this site - we do not know what might happen opposite in due course. If the canal was three times as wide it might be a different story, but as it stands the buildings are quite large enough in scale in relation to the width of the canal, and to avoid an effect of oppression and over-bearing mass, and additional unwelcome shadowing from the south, no increase in height should be permitted. The additional storeys on the canal front, even where set back, are not set back nearly far enough to avoid this risk."
We note and have seen a number of other objections to the application and believe that the Victorian Society has now put in an objection. There is a common view that what is being proposed is detrimental to these historic buildings and destroys for ever their authenticity. The following is a quote from the Council's own design policy document for the Canal, " The Council will operate special policies in the Regent's Canal West Conservation Area in order to preserve and enhance the special character and appearance of the area". The Council is looking to "preserve and enhance"while this development looks to change windows, change brick work, increase heights, fill in spaces with more buildings, and erect a tower which will tower over all. The Canal is rapidly becoming one long canyon of high rise of homes too expensive for the vast majority of Islingtonians to afford either to rent or buy. Other old building along the Canal are under attack from developers, as no doubt you are aware, and we are reaching the point where people will say "We can't allow any more "development" because we are in danger of not having any examples of the original Canal buildings". They are our history and should be our children's history.
As I wrote above, we have seen the other objections and agree with them and do not feel that it is necessary to repeat them again. We think that the objection from the Greater London Archaeology Society is particular powerful and well argued. It is 50 years since Conservation Areas came into being. It would be strange if the Council were to celebrate this birthday by agreeing to this proposals. We urge the Council to celebrate by rejecting this Application.
I would be grateful if you would acknowledge our objections.
Yours sincerely
David Trillo
Secretary of the Islington Society and also deputed to write on behalf of the Islington Archaeology and History Society
Dear Mr Greenwood,
I object to the above-named planning application.
The proposed additions would make the building far too large in relation to the narrow canal.
The architecture is unsympathetic, especially the proposed dormer windows.
There would be a loss of daylight for nearby homes and for the canal.
It contravenes the Council's Conservation Area policies.
For deliveries of materials and removal of waste the applicant does not propose to use the purpose-built canal. It plans to further burden the streets and the public with dangerous HGVs. Yet the site is on the same stretch of the canal as Kings Place where deliveries and waste removal were water-borne, thus putting the canal to its purpose-built use.
I have had a close interest in the Regents Canal for many years as a member of the Regents Network and Friends of Regents Canal. I have fought,and am still fighting, for access for pedestrians and pedal cyclists to the City Road Canal Basin periphery. The east side of the basin still needs to be opened up.
Yours sincerely
Leo Chapman
I am appalled at the proposals, both on the aesthetic travesty of the substantial increase in height with little sympathy for the original building line and form, and the removal of coherent access to the canal as a transport corridor, and call for a refusal of planning permission, or substantial modification of the proposals Battlebridge Basin, should have taught planners a lesson over 30 years ago through the failure to consider the needs of boat dwellers in development control, with the clear evidence on display for all to marvel at (and ridicule) in the form of a floating toilet block with underwater connection to the sewers on the canal bank.
The development also erodes the delivery of materials and removal of waste from sites along the canal corridor. There is clear economic benefit from many canal-side businesses, and many examples of deliveries made by barge, notably the beer barges (all-electric) of Amsterdam. Depending on the configuration barges of 80-100T capacity (max theoretical displacement 139T) can be worked up through Camden Locks, from where there is a long pound connecting to the Grand Union and running out to Uxbridge, that has provided a fast and efficient bulk transport route. I find the statement on Page 19 of the Construction Traffic Management Statement jaw dropping., especially as you have the clear precedence of the nearby Kings Place by Sir Robert McAlpine as an example of using the canal as a key part of the site logistics plan - but given my experience, and long history of Concrete Bob's batallions finding efficient and environmentally sound regimes for site operation this is exactly what they deliver as a benchmark for others to match. http://friendsofregentscanal.org/features/freight/Kings-Place/Kings-Place-construction.html The statement (italics) should be rejected The developer should be required to review this, with a recommendation to consult the Commercial Boat Operators Association (CBOA) who have wide knowledge of commercial barge types and the sources from which these can be obtained.
Regents Canal
"It is not intended to use Regent's canal as a method of delivery and removal of plant and materials due to the lack of navigable width and depth. Regarding any temporary works that may encroach the canal during construction a warning of these works will be made visible to the canal users. Consultation will be undertaken with the Canal and River Trust to agree appropriate measures are undertaken to protect existing and future river traffic throughout the duration of the construction works. Consultation will also be undertaken with the Environment Agency to ensure they are content with the proposed management".
The statement is also far too vague concerning encroachment on the navigation and any encroachment proposals should have clear soundings and above waterline profile checks to ensure navigation is not compromised. Any structures should be protected by fenders and grillage appropriate to deflect or absorb impact from a barge or combination of barges/tugs of a realistic combined displacement (150T?) Any structures placed in the canal to cause no adverse effect on the puddled lining
An inventory of plant/materials at the canalside to be managed to ensure that no planet or materials are 'lost' in the canal to the detriment of navigation.
A safety plan and a responsible person on place to manage and monitor the enhanced risks for the hazard of materials & plant falling in to the canal and appropriate equipment maintained on the site to prevent harm to or from/recover persons or material falling from, the site into the canal.
Dave Holladay
I am writing on behalf of the Friends of Regent's Canal to reconfirm our objections to the design and construction plans for Regent's Wharf.
My previous e-mail on this subject can be found below. I have examined the revisions to the plans and they are insufficient to reduce the strength of our objections. I am quite sure that most if not all of the previous objections from other groups and individals are still valid.
I note from your earlier correspondence to me that there would be a planning condition to require the constructors to carry out a feasibility study before deciding whether to use road or water for waste transportation. The condition needs to be a strong one because some very bad precedents have been set in recent years and developers use the slightest excuse to avoid environmentally friendly forms of transport. It is evident from the construction planning document that the consultants are uneducated in this area because the nearby Kings Place made extensive use of the canal during its construction. We all know that it is technically feasible to use the canal and we must ensure that you receive expert advice from organisations such as the CBOA before accepting any feasibility study recommendations. I feel that there should be heavy penalties for using the roads in these situations yet I fear that the roads receive unwarranted subsidies instead. This is an opportunity to change mindsets and to set a new precedent.
Regards,
Ian Shacklock
Chair, Friends of Regent's Canal
23rd November 2017
I am writing on behalf of the Friends of Regent's Canal to object to the design and construction plans for Regent's Wharf.
You will have already seen my personal objection, dated 27th February, which I have included below. We discussed these plans at our public meeting at the London Canal Museum on 22nd March and it was agreed unanimously that we should object as a group. Since then, the plans have undergone some revisions but none of the recent changes are significant or helpful enough to diminish our objections.
We object to the intensification, the loss of light for surrounding homes and for the canal, the thoroughly inappropriate dormer windows and we note that the scheme delivers zero benefits to the canal and its users. You will already have received numerous objections from residents and local experts that cover these points, but one additional point that we must highlight is the wasted opportunity to utilitise the canal for construction materials and waste in the [unfortunate] event that planning permission is granted.
I have copied this objection to Richard Horne (Commercial Boat Operators Association), Gerry Heward (http://www.whhbarges.co.uk/) and to David Hilling (Inland Waterways Association) who are experts on using this particular stretch of the canal for construction. They will be able to offer advice on [proven] feasibility of using the canal.
I urge you to impose a firm condition to ensure that the developers make good use of the canal - and to avoid the use of HGVs wherever possible - during construction. It is unacceptable if they choose to avoid the canal for economic reasons as there is a lot more at stake than their balance sheet and it is important that their feasibility checks are transparent.
Regards,
Ian Shacklock
Chair, Friends of Regent's Canal
30th August 2017