Letter to Southern Housing Group

Letter from No Hackney High-rise sent to Southern Housing Group opposing proposed tower at 22-44 London Lane

Linda Donoghue

Development Officer,

Southern Housing Group

Fleet House,

59-61 Clerkenwell Road

London EC1M 5LA

13 September 2009

Dear Linda Donoghue

Proposed redevelopment of 22-44 London Lane E8 3PR

Thank you for your presentation of the proposed development for 22-44 London Lane at Hothouse on the 25^th June 2009 and answers to questions addressed to you in our subsequent email dated August 5^th 2009.

I am writing to inform you that the vast majority of residents have strong objections to the above scheme as it was presented by SHG at Hothouse, 25 June 2009. In conjunction with our planning consultant, Louise Morton, we have listed these objections below, which we hope you will take into consideration when redesigning the above scheme. We look forward to a further public presentation and public consultation of the revised scheme.

1. Principle of redevelopment of the site

The site falls within a designated Priority Employment Area (PEA) and is occupied by small-scale commercial activity.  It provides valuable space for such users in Hackney.  We resist the loss of these uses. Any redevelopment of the site should make provision for commercial uses.

2. Principle of residential

There is no policy support for residential development within a defined PEA.  Core Strategy Policy 17 of the LDF does not support residential development within PEAs.

3.  Affordable housing

Should an exceptional case be made for residential development on the site, it is our view that the site should provide an appropriate quantum of affordable housing. Proposals put forward by SHG provide only 30% affordable housing, which is well below the strategic target of 50% contained within the London Plan and the borough-wide target of 50% contained within Core Strategy Policy 20 of the LDF.

4. Height

The proposal for a tall building on this site is wholly unacceptable for the following reasons:

a. Impact on the immediate townscape setting of London Lane and Ellingfort Road: These streets are characterised by small scale, predominantly two storey, predominantly Victorian properties, with some small scale modern infill development. A tall building of 19 storeys, as proposed by SHG, is completely out of character with the low rise, domestic scale of the area.

b. Impact on the skyline from London Fields: London Fields is a much valued park     within Hackney which provides an escape from the busy, urban streets around it. Piercing the skyline with a 19 storey tower to the east of London Fields will destroy the landscaped setting of the area, and intrude on the tranquillity of the park.

c. Overlooking: The tower will result in overlooking to existing neighbouring residential properties which will result in a lack of privacy and cause unacceptable harm to existing residents. The amenity of existing residential properties will therefore be seriously compromised.

d. Impact on sunlight and daylight: the location of the tower to the south of Ellingfort Road will result in a loss of sunlight and daylight to existing residential properties. We are unable to quantify this impact until we receive a copy of SHG’s sunlight and daylight assessment, which has informed the design, and we would be grateful to receive a copy of this.

e. Lack of policy support for a tower in this location: there is no policy support for a tower on this site.  The London Plan promotes towers where: (i) they will create attractive landmarks enhancing London’s character; (ii) they will help to provide a coherent location for economic clusters; and / or (iii) they will act as a catalyst for regeneration; with an overriding criterion that (iv) they are acceptable in terms of design and impact on their surroundings. The proposal by SHG site meets none of these criteria and is therefore not supported in strategic policy terms.

Furthermore, Hackney’s Tall Buildings Strategy, dated February 2005, excludes this site from the Tall Buildings Strategy Plan indicating that the site is not a suitable location for a tall building.  The Tall Buildings Strategy categorises tall buildings as either ‘mid rise’, ‘tall’ or ‘very tall’. At 19 storeys, the proposed tower by SHG is classified as a ‘very tall’ building which is “excessively taller than the surrounding built form”. There are very few locations where very tall buildings are acceptable in Hackney. Hackney Central is seen as being appropriate for only mid rise buildings of between 6 and 9 storeys, where the design and impact on the local surroundings is acceptable.

f. Design: The site is not ‘landmark’ and is therefore not a suitable location for a tall building. A proper urban and contextual analysis of the area would demonstrate that this in an inappropriate location for a tower, having regard to the small scale nature of neighbouring buildings and the surrounding conservation area. In design and townscape terms, there is no justification for a tower on this site.

5. Density

We understand that SHG’s scheme proposes 78 residential units, together with 261 sq m of employment floorspace.  With a site area of 0.24 ha, this presents a density of 325 units/ha. This results in gross overdevelopment of the site. The density proposed is wholly inappropriate for London Lane.

The London Plan density matrix does not support a density of this scale in this location. Table 3A.2 indicates that ‘urban’ locations such as Hackney could support densities of a maximum of 260 units/ha and considerably lower densities for schemes which provide an appropriate amount of family accommodation.

Core Strategy Policy 22 in Hackney’s LDF promotes densities in line with the London Plan matrix. There is no policy support for a scheme with such a high density in this location.

6. Design

The site falls within the Mare Street Conservation Area and accordingly new development should preserve or enhance the character or appearance of the conservation area.  We have seen nothing from SHG which indicates that the proposed scheme will meet this test. A tower in this location cannot be supported.

The Tall Buildings Strategy sets out a clear presumption against tall buildings within Hackney’s conservation areas on the basis that tall buildings would visually impinge on the setting of the conservation areas.  No exceptional case has been presented here to justify a tower in this part of the Mare Street Conservation Area. Aside from the tower, the design response is poor: it does not respond to the existing context.

7. Car Parking

We do not support car free residential development on this scale in this location.  Any scheme on this site should include appropriate provision for on-site residential car parking.

We trust that you will give all of these objections serious consideration and will begin to work closely with us in the next phase of work to realise our shared ambition for a sustainable development of exceptional design and quality, that preserves and enhances the existing and neighbouring communities represented by No Hackney High Rise. We look forward to hearing from you and to being consulted at the next stage, prior to your submission for planning consent,

Yours faithfully

Polly Richards

(for No Hackney High Rise)

cc. Meg Hillier (MP for Hackney South and Shoreditch), Emma Plouviez (Councillor for Queensbridge Ward),  Tom Price (Councillor for Queensbridge Ward), Patrick Vernon (Councillor for Queensbridge Ward), Ian Bailey (Senior Planning Officer for Hackney Council)