Objection against redevelopers planning application - Reference 2017/01887/FUL - OLD LAUNDRY, LAND AT REAR OF PENNARD ROAD, W12 The Shepherd’s Bush Market community is strongly opposed the new application 2017/01887/FUL submitted by redevelopers U+I Group Plc. The Shepherd’s Bush Market community believe that this application is a confused and incoherent proposal against the interests of the Shepherd’s Bush Market Tenants. It would appear that the proposal is to create a temporary office/social/catering area, which will be difficult to implement in the short term without damaging the current infrastructure and causing prejudice to the Shepherd’s Bush Market businesses. Opportunity for comments and responses may be sent to the Hammersmith & Fulham Council before the closing date of Thursday 17th August 2017. The Shepherd’s Bush Market community are most concern that the Hammersmith & Fulham Council have issued their notification letters late, offering some Shepherd’s Bush Market tenants less than 7 days to view this application and offer comment. If you wish to support the Shepherd's Bush Market Tenants' Association's view against this application then please send your objection to the Hammersmith & Fulham Council If you wish to comment on this application online go to: - http://public-access.lbhf.gov.uk/online-applications/applicationDetails.do?activeTab=makeComment&keyVal=OPNA1IBIMH000 Or You may write to the London Borough of Hammersmith & Fulham – Planning Division, Transport and Technical Services Town Hall Extension King Street London W6 9JU. (Please quote application reference number 2017/01887/FUL in all correspondence). OBJECTION TO PLANNING APPLICATION ON BEHALF OF SHEPHERDS BUSH MARKET TRADERS ASSOCIATION OLD LAUNDRY, LAND AT REAR OF PENNARD ROAD, W12 REFERENCE 2017/01887/FUL Shepherds Bush Market Traders Association previously commented on the application, which was submitted earlier in the year. We believe that the amended application is a new application and should be treated as such. Although the current planning application’s description has been amended the previous objections from the Shepherd’s Bush Market Tenants’ Association (SBMTA) still stands. 1. The application is for a temporary period of three years and yet is seeking to put 46 containers into office use and other uses which require service in order to allow them to operate. For example if you are employed in an office are you going to have to go to one of the 2 toilet blocks referred to when it is pouring with rain or the ground is covered with snow? If you are a sole operator you are going to have to lock your container to use the facilities. Is this practical? Where is it proposed to find 46 companies wishing to operate on a temporary basis to be found? What kinds of offices are envisaged? Computers and other equipment need high levels of security to ensure safety of the equipment and the users. 2. A3/A4/A5 – the application proposes 8 containers for the use of food and drink purposes The proposed form of cooking is crucial as once an A3 or A5 is permitted any restrictions cannot be imposed at a later date. It is not good planning practice to grant a planning permission under A3/A4/A5 if it cannot be clearly demonstrated that issues of noise and odour are capable of resolution. It is always good application practice to submit detailed drawings demonstrating the route of an extract system to above roof level and the type of extract system proposed. This is the only method of extract that minimises odours in the surrounding area. The equipment must also be capable of minimalizing internal and external noise levels. The form of cooking is crucial as once an A3 or A5 is permitted any restrictions cannot be imposed at a later date In the planning statement accompanying the planning application it concedes that no permanent kitchens are envisaged. It is not clear therefore how those units will be effectively operated in terms of preparation, cooking, serving and cleaning. These containers too will presumably use the 2 toilet blocks proposed. Do the proposed A3/A4/A5 containers meet all the health and safety, environmental health and other legislation to allow the sale of food and drink for consumption on the premises? Is it proposed that the containers have running water to allow cleaning down to tables; efficient preparation of food; water to make drinks with; washing up facilities that meet health regulations; cleaning of floors etc.? 3. Class D1 Community Use (7 containers). Are there firm proposals as to who is going to occupy or use these containers? Local community groups often have problems in being able to fund the cost of public liability insurance. Who is going to be responsible for that and other costs? What kinds of community activities are proposed? Communities need long-term provision and not something, which is temporary and will disappear in three years time. These users to will presumably have to use the 2 toilet blocks provided. 4. 9 storage containers (sui generis). What is proposed to be stored in these units? B1 uses do not need storage, as they are offices. Food and Drink uses will presumably have storage within their units to provide sufficient resources for the individual units. 5. Bicycle Storage (2 containers). Bicycle racks would suffice and if these units are to be secure who is to be given keys? This would appear to suggest that these are not for visitors to the site but for people employed on the site. 6. Toilets (2 containers). Who is to be responsible for the regular cleaning of these, as with so many people on site and potential visitors this will need frequent and regular attention? Will the toilets be plumbed into the main sewage system or will they be portable/chemical units? 7. 1 fridge unit – who is expected to use this, as presumably each A3/A4/A5 unit will have their own fridge to meet their needs? 8. The description also includes 10 timber sheds at first floor level – what use are they requiring? Is there disabled access to these proposed units? Can buggies easily achieve access? What are they for? 9. Event Space - What type of events space is to be developed? Will licences be required to hold events in it? How frequently will they be held? Will there be concerts? Will music be played and amplified? 10. Disabled Access - There still appears to be no attempt to demonstrate how access can be achieved for the disabled. In order to obtain access to a container of this type it is necessary to climb across the threshold, which is above ground level. This is not possible for the physically disabled or for families with pushchairs. In order to obtain access there would need to be ramped entrances to all the units and these would cause a further hazard to blind and disabled people and too anyone with a pushchair or children. There are several units at two levels within only an outside staircase which does not offer access to many members of the public for reasons of agility or because they are accompanied by young children in buggies or on foot 11. The placing of containers adjoining a conservation area is contrary to good planning. NPPF paragraph 57 states: “It is importance to plan positively for the achievement of high quality and inclusive design for all development, including individual buildings, public and private spaces and wider area development schemes.” Mr Horada, the chair of the market traders association, has clarified as follows: “It is my understanding that the Redevelopers Orion had dropped the cargos in autumn 2014 in the laundry Site Area to create a temporary market area (TMA). The redevelopers were very bullish in wanting to push the market tenants out of their shops and stalls in Shepherd’s Bush Market and place them into these cargo containers. They had no legal right in place to move the traders nor did they have replacement lease agreements for the tenants. The redevelopers wished for us surrender our leases but as there was no legal obligation for us to do this, the tenants refused to agree. The traders remained in their original premises and held onto their leases. It is my understanding that Orion had no official right to dump these containers on this Ground.” 12. The long term success of Shepherds Bush Market should be the priority of the local planning authority and at no point does the application demonstrate that the proposed use of the land enhances this long established and successful market (est. 1914) The reality is that two totally different concepts will be side by side but with no coherent principle. 13. The popularity of the market has been achieved by a combination of its linear nature and wide ranging mix of tenants. This proposal threatens the future of the market rather than complement by the diversion of footfall from the long traditional route taken by customers to the market. IN EXAMINING THE “BENEFITS OF THE SCHEME” WHICH WAS SUBMITTED WITH THE APPLICATION WE WOULD MAKE THE FOLLOWING OBSERVATIONS: 1. SUSTAINABLE RE-USE OF VACANT, CURRENTLY UNDER USED AND ABANDONNED BROWN FIELD SITE. The temporary planning permission will not make the proposal sustainable and in a short period of time will return it to “an abandoned brownfield site”. The site is covered with containers, which appear not to have permission and the application is an attempt to legitimise the situation. 2. AN IMPROVED OUTLOOK AND PUBLIC OUTLOOK AND PUBLIC REALM, THROUGH HIGH QUALITY DESIGN AND LANDSCAPING PROPOSALS. The use of existing shipping containers with roller shutters does not meet this aspiration. 3. “ACTIVATING” THE SITE AND IMPROVING SECURITY FOR LOCAL RESIDENTS, INCLUDING THOSE ON PENNARD ROAD The containers have been placed immediately to the rear of houses on Pennard Road and it is difficult to see how this will improve security. 4. REINVIGORATION, REINVENTION AND REINVESTMENT TO THE EXISTING MARKET TO ENSURE THAT THE LONG-STANDING BUSINESSES CAN BE MAINTAINED. This ignores the views of the market traders themselves who are the best judges of commercial reality and do not see any benefit in the cul de sac of temporary unsightly containers allegedly enhancing their businesses. 5. INCREASED TURNOVER AND FOOT FALL FOR THE EXISTING MARKET. This is a temporary project and bolting on temporary offices with no long term coherent policy will create uncertainty as the commercial future would be dependent on letting a large number of units very quickly. 6. CREATION OF MANY NEW AND RE-LOCATED JOBS. THE A3/A4/A5 FLOORSPACE COULD PROVIDE EMPLOYMENT FOR C. 10 PEOPLE AND THE PROPOSED B1 FLOORSPACE COULD PROVIDE EMPLOYMENT FOR AROUND 53 PEOPLE. There is no analysis to justify these figures. Are many organisations likely to relocate on a temporary basis? Would the uses be transient and the employment temporary and insecure? 7. INCREASING SOCIAL AND CULTURAL VALUES THROUGH REGENERATION, WITH SPARKLING LOCAL INVENTION AND CRETIVITY AND CELEBRATING CULTURAL DIVERSITY AND ARTISTIC TALENT; This assertion is not supported by any substantial evidence. 8. PROVIDING A SPACE AND OPPORTUNITY FOR COMMUNITY EVENTS, TO BE HELD THROUGHOUT THE YEAR No evidence how this could be accommodated with limited access. Would the landlords be responsible for the public liability insurance and other costs associated with community events? 9. SUPPORTING START UP BUSINESSES, INCLUDING SMALL AND MEDIUM SIZED ENTERPRISES, AND PROVIDING SIGNIFICANT OPPORTUNITY FOR THEM TO BE RETAINED WITHIN THEIR LOCAL AREA AND WITHIN THE BOROUGH No explanation had been given as to how this can be achieved. The opportunities would only be short term as the application seeks planning for 3 years. 10. CLOSE COLLABORATION WITH NEIGHBOURS SUCH AS THE BUSH THEATRE, BUSH STUDIOS, LONDON FASHION SCHOOL AND SURROUNDING BUSINESSES TO SUPPORT THEIR VISION AND OVERALL OBJECTIVES FOR THEIR BUSINESSES AND THE LOCAL AREA There is no evidence or information to demonstrate how they can support existing organisations. 11. A CATALYST FOR INVESTMENT: THE PROPOSALS WILL ACT AS A “TEST BED” TO DETERMINE WHAT WORKS BEST FOR THE FUTURE INVESTMENT OF THE MARKET. The local community and business community do not wish to be guinea pigs in a temporary experiment with a proposed short life span. Where do companies and community organisations find alternatives in three years time? CONCLUSION The application has emerged not from a coherent and considered development plan but an attempt to achieve a retrospective justification for what is in essence an unsightly and muddled site.