Further to my earlier article about the letter from Berwin Leighton Paisner (Arrowcroft's lawyers), informing me that the Secretary of State had extended the deadline for making representations in respect of Arrowcroft's further environmental submission from 15 February to 17 March.
It seems that Berwin Leighton Paisner have made a "snafu" in their letter. They refer to the revised deadline (17 March) twice. However, in the final paragraph in bold print they state:
"If you wish to make any representations on the further environmental information you should do so in writing to the Planning Inspectorate...before 15 February 2008..."
The 15th of February is of course the original deadline for submissions, and ten days before the date of the letter sent out by Berwin Leighton Paisner.
It seems that Berwin Leighton Paisner are prone to making errors and mistakes.
The question is, have they made any other errors and mistakes?
Showing posts with label Berwin Leighton Paisner. Show all posts
Showing posts with label Berwin Leighton Paisner. Show all posts
Friday, 29 February 2008
Thursday, 28 February 2008
Letter To Hazel Blears
Submitted to Hazel Blears today:
"Right Honourable Hazel Blears MP
The Secretary of State for Communities and Local Government Planning Division
Government Office for London
9th Floor, Riverwalk House
157-161 Millbank
LondonSW1P 4RR
28 February 2008
Dear Ms Blears,
Subject London Borough of Croydon (Gateway Site) Compulsory Purchase Order 2007
I have received a letter (dated 25 February 2008) from Berwin Leighton Paisner, solicitors for Arrowcroft Ltd, in respect of Arrowcroft’s further environmental information submitted to you on 24 January 2008. They state that the deadline for submitting objections to Arrowcroft’s revised/new data has been extended to 17 March 2008.
I wish to formally object that, despite the fact that the public inquiry into the CPO has officially ended, Arrowcroft are still being allowed to submit revised/altered information:
· This is outwith the time limit of the inquiry
· It is my, and indeed many other residents’, understanding that once the inquiry ended no further information could/should be submitted
· Berwin Leighton Paisner, Arrowcroft’s solicitors, are seemingly setting the timetable and deadlines for objections
· Berwin Leighton Paisner, and by definition Arrowcroft, appear to be acting on your behalf
· The additional information being submitted after the end of the inquiry, and onus to object to it, is confusing to the residents of Croydon (myself included) who are negatively impacted by Arrowcroft’s plans. We have no specific legal expertise, and trust you to act impartially.
I have the following questions:
1. Who is running this inquiry, you or Arrowcroft?
2. Given the ongoing bombardment of information and changes by Arrowcroft, how can lay people possibly keep track or indeed understand what is happening?
3. Given the ongoing changes of information and revised deadlines for objections, how can we possibly keep track of the process that is being followed by you in trying to come to a decision wrt the CPO?
4. Has the application been altered?
5. Why is Arrowcroft being allowed to set the deadlines?
In my opinion the independence and impartiality of the inquiry is being severely, and openly, compromised by Arrowcroft’s and Berwin Leighton Paisner’s actions.
I look forward to hearing from you.
Thank you in advance.
Yours sincerely,
Ken Frost MA FCA FIPFM
Croydon Against The Arena
www.catarena.org
cc Deborah Tobin – Planning Inspectorate
Andrew Pelling MP"
"Right Honourable Hazel Blears MP
The Secretary of State for Communities and Local Government Planning Division
Government Office for London
9th Floor, Riverwalk House
157-161 Millbank
LondonSW1P 4RR
28 February 2008
Dear Ms Blears,
Subject London Borough of Croydon (Gateway Site) Compulsory Purchase Order 2007
I have received a letter (dated 25 February 2008) from Berwin Leighton Paisner, solicitors for Arrowcroft Ltd, in respect of Arrowcroft’s further environmental information submitted to you on 24 January 2008. They state that the deadline for submitting objections to Arrowcroft’s revised/new data has been extended to 17 March 2008.
I wish to formally object that, despite the fact that the public inquiry into the CPO has officially ended, Arrowcroft are still being allowed to submit revised/altered information:
· This is outwith the time limit of the inquiry
· It is my, and indeed many other residents’, understanding that once the inquiry ended no further information could/should be submitted
· Berwin Leighton Paisner, Arrowcroft’s solicitors, are seemingly setting the timetable and deadlines for objections
· Berwin Leighton Paisner, and by definition Arrowcroft, appear to be acting on your behalf
· The additional information being submitted after the end of the inquiry, and onus to object to it, is confusing to the residents of Croydon (myself included) who are negatively impacted by Arrowcroft’s plans. We have no specific legal expertise, and trust you to act impartially.
I have the following questions:
1. Who is running this inquiry, you or Arrowcroft?
2. Given the ongoing bombardment of information and changes by Arrowcroft, how can lay people possibly keep track or indeed understand what is happening?
3. Given the ongoing changes of information and revised deadlines for objections, how can we possibly keep track of the process that is being followed by you in trying to come to a decision wrt the CPO?
4. Has the application been altered?
5. Why is Arrowcroft being allowed to set the deadlines?
In my opinion the independence and impartiality of the inquiry is being severely, and openly, compromised by Arrowcroft’s and Berwin Leighton Paisner’s actions.
I look forward to hearing from you.
Thank you in advance.
Yours sincerely,
Ken Frost MA FCA FIPFM
Croydon Against The Arena
www.catarena.org
cc Deborah Tobin – Planning Inspectorate
Andrew Pelling MP"
Wednesday, 27 February 2008
Deadline Extended
Berwin Leighton Paisner LLP (Arrowcroft's lawyers) have written to me, and other objectors to the Arena, to advise that the Secretary of State has extended the deadline for making representations wrt Arrowcroft's additional environmental information (submitted 25th January) to the 17th of March.
Friday, 15 February 2008
Canning and Clyde Road Residents Association
Attention: Deborah Tobin
The Planning Inspectorate
4/04 Kite Wing
Temple Quay House
2 The Square
Temple Quay
BRISTOL BS1 6PN
13 February 2008
Dear Ms Tobin
APP / L52040 / V / 06 / 1198485
Application by Arrowcroft Limited in respect of a proposed development at land adjoining East Croydon Station
Notice of Submission of Further Information to an Environmental Statement
We have been informed by Berwin Leighton Paisner that we have an opportunity to comment upon the Further Information to an Environmental Statement for the important East Croydon Gateway site. As before, we are sending this objection on behalf of Park Hill Residents Association, Morland Park Residents Association, H.O.M.E. Residents Association and our own Association. This represents over 4,000 households in the vicinity of the proposed development. We are aware of strong opposition to the applicant’s scheme by other residents who do not have the representation of an association.
Our comments in this letter do not repeat anything we said in our letter of 11 August 2007 with reference to the Planning Application nor anything in the Canning & Clyde Road Residents Association letter of 18 August with reference to the Compulsory Purchase Order. We would ask that the comments in all three letters and supporting documentation be taken into account by the Inspector and Secretary of State.
Our comments are restricted to the Transport Assessment and Crowd Management Strategy sections of the revised statement.
1. Transport Assessment
1.1 The revised Transport Assessment states that the mass transport system has enough spare capacity to accommodate the peak hour of patrons arriving at East Croydon for an event at the Arena on a Monday to Friday. It only shows that there is spare capacity on trams from Wellesley and Lebanon Gardens or on trains from South Croydon, Selhurst and Norwood Junction. This is not adequate. The Transport Assessment needs to demonstrate that the transport system has spare capacity for the whole of the journey that is required to be made. In the evening peak hour there is no or very little spare capacity on trains leaving Clapham Junction for East Croydon or on trams from Wimbledon. This means that the usable spare capacity available for Arena patrons on trains from
Clapham Junction and trams from Wimbledon has been substantially overstated and indicates a need to increase train and tram services. It is our understanding that there is no spare track capacity to increase train services or trams available to increase tram services.
1.2 Patrons arriving for evening events at the Arena by car will be travelling into Croydon at a time when the main travel demand is out of Croydon. Most roads, except those such as the Mitcham Road, where peak travel demand is similar in both directions, will have some spare capacity but traffic congestion will be increased at junctions such as Purley Cross, Lombard Roundabout and Fiveways. Congestion at junctions has only been considered in the immediate vicinity of East Croydon but the impact of the Arena may be more serious on certain junctions further afield. This issue needs to be considered.
1.3 There is no comparison for door-to-door journey time between car and mass transport (if available) for homeward journeys after 2300 hours and no evidence that there is adequate spare capacity on all southbound trains after 2300 hours on a Friday night to demonstrate that mass transport is a reasonable alternative to the car.
Arena patrons are likely to want to get home without having to hang around too long and therefore leave en masse. There are likely to be severe capacity problems in and around East Croydon Station as people leave.
The simultaneous egress of large numbers of cars from any car park will be a slow, noisy and polluting process. It may well deter motorists from using the car parks again on their next visit to the Arena and will encourage them to park in surrounding roads instead.
After customers to public transport have queued and been subjected to stewards with loudhailers it may well make the use of cars seem more appealing for a subsequent visit.
1.4 The distribution of arrivals by time and the modal split for patrons arriving for events at the Arena are all based on those found at the inner suburban O2 Arena. There is no evidence provided to show that these distributions are valid for Croydon. The overstatement of capacity available for Arena patrons arriving by tram and train indicated in para 1.1 above indicates that the proportion arriving by car is likely to be understated.
Should evening events at the Arena cause mass transport to overload or the road network to gridlock, the prosperity of the town centre will be jeopardised together with the attractiveness of the town as a residential location.
The developer assumes that parking restrictions will be enforced (against fierce local opposition) on surrounding roads and that patrons arriving by car will park in designated car parks as this will prove cheaper. The car parks mentioned are all privately owned and the Council has no control over the pricing. The Council only controls four very small car parks in Central Croydon.
The Fairfield car park is as close as the Allders and Whitgift car parks, with better pedestrian links (i.e. avoiding subways) and more readily accessible by vehicles from the A232. There is nothing more quickly guaranteed to kill Fairfield than to deprive the car borne audience space in the underground car park which is both (relatively) safe and convenient; why should the existing audience be shunted off to somewhere else? The reverse policy should apply (i.e. very high parking charges unless one is a Fairfield/Ashcroft patron).
1.5 The responsibility for procuring an adequate train service lies with the Department of Transport. The Southern Railway does not have grounds to object as their franchise expires in 2009 which is before the Arena can open (para 18.7.27).
1.6 As the tram stops are outside the station, patrons leaving Arena events may well choose to access them along Dingwall Road. There would need to be crowd management on Dingwall Road, as non-Arena bus passengers for routes which stop in Dingwall Road would then prefer to use Dingwall Road stops rather than East Croydon Interchange stops to reduce the risk of being left behind.
2. Crowd Management Strategy
2.1 The Crowd Management Strategy only defines responsibilities. It does not give any indication of the controls needed to facilitate the free movement of buses and trams along Dingwall Road and over East Croydon bridge when patrons leave an event at the Arena.
2.2 The author of the Croydon Management Strategy does not appear to be familiar with East Croydon Station and its surroundings. All three island platforms can be, and are, served by both northbound and southbound trains so segregation of patrons into northbound and southbound is not practical.
2.3 The tram stops are outside the station which means that people wishing to reach them would use Dingwall Road.
2.4 There are normally queues for buses and taxis at East Croydon Station in the late evening even when bus and train services are running well. Further crowding is liable to occur when services are disrupted.
2.5 In 6.1.1 a pedestrian travel time of approximately 3.5 minutes indicates too short a time for any significant crowd dispersal of thousands of pedestrians. Only a much longer walk than this would work.
2.6 There is no mention of how the co-ordination is to take place of the control of customers into the Station using the exit ramp from the Plaza with those using the main entrance into East Croydon Station.
2.7 There is no mention of crowd control for those congregating to await coaches at the end of an event.
2.8 The developer does not consider pedestrian noise (with or without ‘binge drinking’) outside the immediate site. No account is taken of people returning to their cars in residential streets late at night.
2.9 Showsec state that the Police will be responsible for the crowd outside the Arena site. Has anyone asked the Police if they have sufficient resources to do this? Who will meet the cost?
Finally we note that many of the developer’s submissions of material for the Planning Inquiry have been late and have had to be revised when challenged.
Yours sincerely
Anne Bridge
Secretary, Canning and Clyde Road Residents Association
Also on behalf of Park Hill Residents Association, Morland Park Residents Association, H.O.M.E Residents Association and the Croydon Transport Focus Group
The Planning Inspectorate
4/04 Kite Wing
Temple Quay House
2 The Square
Temple Quay
BRISTOL BS1 6PN
13 February 2008
Dear Ms Tobin
APP / L52040 / V / 06 / 1198485
Application by Arrowcroft Limited in respect of a proposed development at land adjoining East Croydon Station
Notice of Submission of Further Information to an Environmental Statement
We have been informed by Berwin Leighton Paisner that we have an opportunity to comment upon the Further Information to an Environmental Statement for the important East Croydon Gateway site. As before, we are sending this objection on behalf of Park Hill Residents Association, Morland Park Residents Association, H.O.M.E. Residents Association and our own Association. This represents over 4,000 households in the vicinity of the proposed development. We are aware of strong opposition to the applicant’s scheme by other residents who do not have the representation of an association.
Our comments in this letter do not repeat anything we said in our letter of 11 August 2007 with reference to the Planning Application nor anything in the Canning & Clyde Road Residents Association letter of 18 August with reference to the Compulsory Purchase Order. We would ask that the comments in all three letters and supporting documentation be taken into account by the Inspector and Secretary of State.
Our comments are restricted to the Transport Assessment and Crowd Management Strategy sections of the revised statement.
1. Transport Assessment
1.1 The revised Transport Assessment states that the mass transport system has enough spare capacity to accommodate the peak hour of patrons arriving at East Croydon for an event at the Arena on a Monday to Friday. It only shows that there is spare capacity on trams from Wellesley and Lebanon Gardens or on trains from South Croydon, Selhurst and Norwood Junction. This is not adequate. The Transport Assessment needs to demonstrate that the transport system has spare capacity for the whole of the journey that is required to be made. In the evening peak hour there is no or very little spare capacity on trains leaving Clapham Junction for East Croydon or on trams from Wimbledon. This means that the usable spare capacity available for Arena patrons on trains from
Clapham Junction and trams from Wimbledon has been substantially overstated and indicates a need to increase train and tram services. It is our understanding that there is no spare track capacity to increase train services or trams available to increase tram services.
1.2 Patrons arriving for evening events at the Arena by car will be travelling into Croydon at a time when the main travel demand is out of Croydon. Most roads, except those such as the Mitcham Road, where peak travel demand is similar in both directions, will have some spare capacity but traffic congestion will be increased at junctions such as Purley Cross, Lombard Roundabout and Fiveways. Congestion at junctions has only been considered in the immediate vicinity of East Croydon but the impact of the Arena may be more serious on certain junctions further afield. This issue needs to be considered.
1.3 There is no comparison for door-to-door journey time between car and mass transport (if available) for homeward journeys after 2300 hours and no evidence that there is adequate spare capacity on all southbound trains after 2300 hours on a Friday night to demonstrate that mass transport is a reasonable alternative to the car.
Arena patrons are likely to want to get home without having to hang around too long and therefore leave en masse. There are likely to be severe capacity problems in and around East Croydon Station as people leave.
The simultaneous egress of large numbers of cars from any car park will be a slow, noisy and polluting process. It may well deter motorists from using the car parks again on their next visit to the Arena and will encourage them to park in surrounding roads instead.
After customers to public transport have queued and been subjected to stewards with loudhailers it may well make the use of cars seem more appealing for a subsequent visit.
1.4 The distribution of arrivals by time and the modal split for patrons arriving for events at the Arena are all based on those found at the inner suburban O2 Arena. There is no evidence provided to show that these distributions are valid for Croydon. The overstatement of capacity available for Arena patrons arriving by tram and train indicated in para 1.1 above indicates that the proportion arriving by car is likely to be understated.
Should evening events at the Arena cause mass transport to overload or the road network to gridlock, the prosperity of the town centre will be jeopardised together with the attractiveness of the town as a residential location.
The developer assumes that parking restrictions will be enforced (against fierce local opposition) on surrounding roads and that patrons arriving by car will park in designated car parks as this will prove cheaper. The car parks mentioned are all privately owned and the Council has no control over the pricing. The Council only controls four very small car parks in Central Croydon.
The Fairfield car park is as close as the Allders and Whitgift car parks, with better pedestrian links (i.e. avoiding subways) and more readily accessible by vehicles from the A232. There is nothing more quickly guaranteed to kill Fairfield than to deprive the car borne audience space in the underground car park which is both (relatively) safe and convenient; why should the existing audience be shunted off to somewhere else? The reverse policy should apply (i.e. very high parking charges unless one is a Fairfield/Ashcroft patron).
1.5 The responsibility for procuring an adequate train service lies with the Department of Transport. The Southern Railway does not have grounds to object as their franchise expires in 2009 which is before the Arena can open (para 18.7.27).
1.6 As the tram stops are outside the station, patrons leaving Arena events may well choose to access them along Dingwall Road. There would need to be crowd management on Dingwall Road, as non-Arena bus passengers for routes which stop in Dingwall Road would then prefer to use Dingwall Road stops rather than East Croydon Interchange stops to reduce the risk of being left behind.
2. Crowd Management Strategy
2.1 The Crowd Management Strategy only defines responsibilities. It does not give any indication of the controls needed to facilitate the free movement of buses and trams along Dingwall Road and over East Croydon bridge when patrons leave an event at the Arena.
2.2 The author of the Croydon Management Strategy does not appear to be familiar with East Croydon Station and its surroundings. All three island platforms can be, and are, served by both northbound and southbound trains so segregation of patrons into northbound and southbound is not practical.
2.3 The tram stops are outside the station which means that people wishing to reach them would use Dingwall Road.
2.4 There are normally queues for buses and taxis at East Croydon Station in the late evening even when bus and train services are running well. Further crowding is liable to occur when services are disrupted.
2.5 In 6.1.1 a pedestrian travel time of approximately 3.5 minutes indicates too short a time for any significant crowd dispersal of thousands of pedestrians. Only a much longer walk than this would work.
2.6 There is no mention of how the co-ordination is to take place of the control of customers into the Station using the exit ramp from the Plaza with those using the main entrance into East Croydon Station.
2.7 There is no mention of crowd control for those congregating to await coaches at the end of an event.
2.8 The developer does not consider pedestrian noise (with or without ‘binge drinking’) outside the immediate site. No account is taken of people returning to their cars in residential streets late at night.
2.9 Showsec state that the Police will be responsible for the crowd outside the Arena site. Has anyone asked the Police if they have sufficient resources to do this? Who will meet the cost?
Finally we note that many of the developer’s submissions of material for the Planning Inquiry have been late and have had to be revised when challenged.
Yours sincerely
Anne Bridge
Secretary, Canning and Clyde Road Residents Association
Also on behalf of Park Hill Residents Association, Morland Park Residents Association, H.O.M.E Residents Association and the Croydon Transport Focus Group
Monday, 28 January 2008
Another Bite of The Cherry
I understand that Arrowcroft's Solicitors (Berwin Leighton Paisner) are sending out to various parties another document, attempting to bolster Arrowcroft's case for the arena, which they intend to submit to the Secretary of State.
It is from Showsec about Crowd Management Strategy, and the hard copy is accompanied by a CD.
Unfortunately for Arrowcroft the CD seemingly contains numerous errors, and is accompanied by an errata slip.
The package makes much of the staggered arrival of spectators before events, but ignores that fact that people will leave afterwards en masse (particularly, late at night).
Whilst they are allowed to send it to the Secretary of State, the inquiry inspector will not look at it now that the inquiry is over.
In other words, it is a waste of time and effort.
This act of desperation by Arrowcroft appears to be a last ditched attempt to plug holes in their case.
Those who take a second bite of the cherry, need to beware that they don't swallow the stone.
It is from Showsec about Crowd Management Strategy, and the hard copy is accompanied by a CD.
Unfortunately for Arrowcroft the CD seemingly contains numerous errors, and is accompanied by an errata slip.
The package makes much of the staggered arrival of spectators before events, but ignores that fact that people will leave afterwards en masse (particularly, late at night).
Whilst they are allowed to send it to the Secretary of State, the inquiry inspector will not look at it now that the inquiry is over.
In other words, it is a waste of time and effort.
This act of desperation by Arrowcroft appears to be a last ditched attempt to plug holes in their case.
Those who take a second bite of the cherry, need to beware that they don't swallow the stone.
Friday, 20 July 2007
Arrowcroft's Case Demolished
My compliments to the Canning and Clyde Road Residents' Association who have written and excellent letter demolishing Arrowcroft's case for the arena.
They have given me permission to publish the letter here.
It is a pity that our local media have not probed Arrowcroft's claims very thoroughly, if at all, nor indeed acknowledged that there is widespread opposition to the arena within the borough.
"The Planning Inspectorate
Attention Deborah Tobin
4/04 Kite Wing
Temple Quay House
2 The Square
Temple Quay
BRISTOL BS1 6PN
17 July 2007
Dear Ms Tobin
Town & Country Planning Act 1990 – Section 77 Application by Arrowcroft Ltd Site and Land Adjoining East Croydon Station, George Street, Dingwall Road and Lansdowne Road, Croydon Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 (SI 1999/293)
We have been informed by Berwin Leighton Poisner that we have an opportunity to comment upon the latest planning material for this important East Croydon Gateway site.
We are sending this objection on behalf of Park Hill Residents Association, Morland Park Residents Association, H.O.M.E. Residents Association and our own Association. This represents over 4,000 households in the vicinity of the proposed development. We are aware of strong opposition to the applicant’s scheme by other residents who do not have the representation of an association.
Our own Association has commented on the original application to the London Borough of Croydon on 7 February 2003 and to the Government Office for London on 10 February 2004. We trust, as we intend to speak at the forthcoming Inquiry, that these
previous objections will be considered by the Inspector.
As you are aware, the potential developer has just released a considerable amount of last minute new information and we would like to further object by adding the following:
1. We believe the current plans are amongst others contrary to the Secretary of State’s Policy in PPG13 and Policies PPS1, PPS3 and PPS6.
2. The plan completely fails to show any improvement to the public transport
infrastructure, only a woolly reference to a new platform at East Croydon Station.
3. The statement of impacts on transport generation and modal travel patterns is severely flawed. For example, the traffic assessment is based on two days, Wednesday 18 July 2006 and Saturday 6 January 2007. There is no evidence that either of these days is representative. It would be expected that traffic would be relatively light on a Wednesday in mid-July because it is in the holiday season and some educational establishments were on holiday.
4. In an endeavour to prove transport capacity, the importance of chronology seems to have been forgotten. It is highly likely that patrons will arrive in a pulse during the hour before an event. This coincides with rush hour for both vehicle and public transport, particularly trains. Most certainly a 17.00 hours to 19.00 hours assessment, possibly of a Friday, is needed for all modes of transport. The patrons’ choice of transport will of course be decided by ease, cost and sociability. Particularly with a mind to returning after an entertainment event, the car seems a preferable choice. There is no price sensitivity analysis to disprove this and encourage more sustainable transport choices.
5. The road infrastructure in and around central Croydon is poor and very fragile. As an example, in a three week period earlier this year, there were three instances when traffic gridlocked due to minor incidences. The gridlocking of course affected bus and tram services.
6. The difficulty in using the Whitgift, Allders or any other car parks on the other side of Wellesley Road is that patrons will have to cross the Wellesley Road either at a busy road junction or through a subway which not everyone views as safe. Arena patrons will likely be competing with patrons of the Fairfield Halls to use their car parks. The temptation to use on street parking in adjacent and neighbouring residential areas is therefore overwhelming. All of our residents associations do not wish to see any changes to existing controlled parking zones. This will damage our community and inhibit activities including attendance at clubs and places of worship. Where will patrons of the 12,000 square feet night club park up?
7. We note that the supermarket has grown to over 110,000 square feet. The original
plan was that people would use this supermarket to do their weekly shop. Given that the total site contains more cycle parking places than car parking (1,477 / 1,186) and given the difficulty of driving into the centre of Croydon, it seems unlikely that people would want to use it for a weekly shop. What will be the purpose of this supermarket that is not already provided for in the centre of Croydon? Cycling in central Croydon is known to be extremely hazardous.
8. The Means of Transport Statement is severely out-of-date. The tram routes have
changed and bus service listings are out-of-date at time of traffic assessment. The
volume and distribution of public transport travel in Greater London has increased
substantially since 2000 so for example updating a seven year old SRA rail travel
survey is not likely to give valid results.
9. Although the applicant presents Croydon as having quick public transport links from all areas, this is not the case for certain places within the potential catchment area, such as Orpington, Bromley, Biggin Hill, Selsdon and Sanderstead amongst others. These people will likely come by car.
10. We think the nature of the development is such that it should be required to
demonstrate that a sequential approach has been applied in selecting the location for
the proposed development. This is dismissed by saying that none were considered.
Why?
The most cursory of investigations would have revealed the potential of the nearby Crystal Palace Arena. It has a seated capacity of 16,500 and can handle up to 45,000 for large concert events. It has Crystal Palace Station adjacent to the main entrance and has three other railway stations within easy walking distance.
The Arena is well served by a variety of bus services from throughout London – the East Croydon Gateway site being just a 25 minute public transport ride away. The Crystal Palace area is highlighted for regeneration. Plans proposed by Croydon Council and TfL include a Croydon Tramlink extension to Crystal Palace.
11. The application should demonstrate regeneration which we take to mean creating a
sustainable community. We believe that the Arena scheme in this location will severely harm existing demonstrable, local, sustainable and diverse communities and not create one in its own right.
12. The application contains a new building for the Warehouse Theatre, but conditional upon the Theatre being able to provide a viable business plan for the future. Since the applicant’s development plans would mean displacement of the Theatre for at least a 3-4 year period then this could prove tricky (and seems fatuous, since the applicant lacks one of their own). We think this ‘last minute’ concession to the Theatre is due to the overwhelming public outrage – local, national and international - at its previous exclusion from the earlier planning application.
13. Nothing in the new material leads us to believe that the proposed development is
commercially and financially capable of delivering the metropolitan status, rebranding and regeneration of Croydon. Since the Arena idea was first mooted, alternative arena venues have opened in London, for example Wembley (12,200 fully seated) that with the 70% increase in tube capacity can easily cope with the patronage. In addition of course we have the O2 and Indigo venues at The Dome.
14. We have yet to see a business plan for the operation of the proposed Arena. A year ago we were told by the applicant that a full capacity (12,500) audience was needed 100 times per year for the Arena to be commercially viable. We note from the latest application material that a capacity crowd has now been redefined to mean either 60% or 70% of the total possible. Apart from having to do so to suit the Transport Plan, surely this raises doubts over the commerciality of the project and raises questions as to why the Arena should be so large in the first place.
15. Is there any reason why Croydon needs yet another night club? Problems with existing clubs have recently led to the Council reviewing its licensing procedure.
16. We could find no mention in the new material of off-site law, order and crowd control nor emergency evacuation arrangements. Who will undertake this? We have been
made very aware of how overstretched the Croydon Police force already is at peak
times.
17. Regarding the quality of design, it appears to be more oppressive greyness and glass with which Croydon has been architecturally overburdened since the 1960s.
18. Although this applicant’s scheme is preferred and promoted by the London Borough of Croydon, at no time has the Council undertaken any proper public consultation to ask the people of Croydon whether this is what they want. In fact we learnt about the
original planning application by chance and were sent details of this latest application apparently because we have formally objected to the Council’s Compulsory Purchase Order to the site. Notification did not come from the London Borough of Croydon but a third party. For a development of this size and with the impact that it is likely to have on Croydon for many years to come, it begs the question why the public’s opinion has not been carefully canvassed and why the Council so willingly granted the original planning application (now the subject of the call-in) apparently without any viability or impact assessment.
We take heart from the UDP Inspector’s Report that said an Arena on this site was not
essential.
We are grateful to the applicant, Arrowcroft, for inviting us to meet to discuss our concerns about their latest development plans. We did this on 12 July 2007 but regret we received no satisfactory answers to the above and other matters raised.
Steve Collins
Chairman, Canning and Clyde Road Residents Association
Also on behalf of Park Hill Residents Association, Morland Park Residents Association,H.O.M.E Residents Association and the former Croydon Society Transport Group."
They have given me permission to publish the letter here.
It is a pity that our local media have not probed Arrowcroft's claims very thoroughly, if at all, nor indeed acknowledged that there is widespread opposition to the arena within the borough.
"The Planning Inspectorate
Attention Deborah Tobin
4/04 Kite Wing
Temple Quay House
2 The Square
Temple Quay
BRISTOL BS1 6PN
17 July 2007
Dear Ms Tobin
Town & Country Planning Act 1990 – Section 77 Application by Arrowcroft Ltd Site and Land Adjoining East Croydon Station, George Street, Dingwall Road and Lansdowne Road, Croydon Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 (SI 1999/293)
We have been informed by Berwin Leighton Poisner that we have an opportunity to comment upon the latest planning material for this important East Croydon Gateway site.
We are sending this objection on behalf of Park Hill Residents Association, Morland Park Residents Association, H.O.M.E. Residents Association and our own Association. This represents over 4,000 households in the vicinity of the proposed development. We are aware of strong opposition to the applicant’s scheme by other residents who do not have the representation of an association.
Our own Association has commented on the original application to the London Borough of Croydon on 7 February 2003 and to the Government Office for London on 10 February 2004. We trust, as we intend to speak at the forthcoming Inquiry, that these
previous objections will be considered by the Inspector.
As you are aware, the potential developer has just released a considerable amount of last minute new information and we would like to further object by adding the following:
1. We believe the current plans are amongst others contrary to the Secretary of State’s Policy in PPG13 and Policies PPS1, PPS3 and PPS6.
2. The plan completely fails to show any improvement to the public transport
infrastructure, only a woolly reference to a new platform at East Croydon Station.
3. The statement of impacts on transport generation and modal travel patterns is severely flawed. For example, the traffic assessment is based on two days, Wednesday 18 July 2006 and Saturday 6 January 2007. There is no evidence that either of these days is representative. It would be expected that traffic would be relatively light on a Wednesday in mid-July because it is in the holiday season and some educational establishments were on holiday.
4. In an endeavour to prove transport capacity, the importance of chronology seems to have been forgotten. It is highly likely that patrons will arrive in a pulse during the hour before an event. This coincides with rush hour for both vehicle and public transport, particularly trains. Most certainly a 17.00 hours to 19.00 hours assessment, possibly of a Friday, is needed for all modes of transport. The patrons’ choice of transport will of course be decided by ease, cost and sociability. Particularly with a mind to returning after an entertainment event, the car seems a preferable choice. There is no price sensitivity analysis to disprove this and encourage more sustainable transport choices.
5. The road infrastructure in and around central Croydon is poor and very fragile. As an example, in a three week period earlier this year, there were three instances when traffic gridlocked due to minor incidences. The gridlocking of course affected bus and tram services.
6. The difficulty in using the Whitgift, Allders or any other car parks on the other side of Wellesley Road is that patrons will have to cross the Wellesley Road either at a busy road junction or through a subway which not everyone views as safe. Arena patrons will likely be competing with patrons of the Fairfield Halls to use their car parks. The temptation to use on street parking in adjacent and neighbouring residential areas is therefore overwhelming. All of our residents associations do not wish to see any changes to existing controlled parking zones. This will damage our community and inhibit activities including attendance at clubs and places of worship. Where will patrons of the 12,000 square feet night club park up?
7. We note that the supermarket has grown to over 110,000 square feet. The original
plan was that people would use this supermarket to do their weekly shop. Given that the total site contains more cycle parking places than car parking (1,477 / 1,186) and given the difficulty of driving into the centre of Croydon, it seems unlikely that people would want to use it for a weekly shop. What will be the purpose of this supermarket that is not already provided for in the centre of Croydon? Cycling in central Croydon is known to be extremely hazardous.
8. The Means of Transport Statement is severely out-of-date. The tram routes have
changed and bus service listings are out-of-date at time of traffic assessment. The
volume and distribution of public transport travel in Greater London has increased
substantially since 2000 so for example updating a seven year old SRA rail travel
survey is not likely to give valid results.
9. Although the applicant presents Croydon as having quick public transport links from all areas, this is not the case for certain places within the potential catchment area, such as Orpington, Bromley, Biggin Hill, Selsdon and Sanderstead amongst others. These people will likely come by car.
10. We think the nature of the development is such that it should be required to
demonstrate that a sequential approach has been applied in selecting the location for
the proposed development. This is dismissed by saying that none were considered.
Why?
The most cursory of investigations would have revealed the potential of the nearby Crystal Palace Arena. It has a seated capacity of 16,500 and can handle up to 45,000 for large concert events. It has Crystal Palace Station adjacent to the main entrance and has three other railway stations within easy walking distance.
The Arena is well served by a variety of bus services from throughout London – the East Croydon Gateway site being just a 25 minute public transport ride away. The Crystal Palace area is highlighted for regeneration. Plans proposed by Croydon Council and TfL include a Croydon Tramlink extension to Crystal Palace.
11. The application should demonstrate regeneration which we take to mean creating a
sustainable community. We believe that the Arena scheme in this location will severely harm existing demonstrable, local, sustainable and diverse communities and not create one in its own right.
12. The application contains a new building for the Warehouse Theatre, but conditional upon the Theatre being able to provide a viable business plan for the future. Since the applicant’s development plans would mean displacement of the Theatre for at least a 3-4 year period then this could prove tricky (and seems fatuous, since the applicant lacks one of their own). We think this ‘last minute’ concession to the Theatre is due to the overwhelming public outrage – local, national and international - at its previous exclusion from the earlier planning application.
13. Nothing in the new material leads us to believe that the proposed development is
commercially and financially capable of delivering the metropolitan status, rebranding and regeneration of Croydon. Since the Arena idea was first mooted, alternative arena venues have opened in London, for example Wembley (12,200 fully seated) that with the 70% increase in tube capacity can easily cope with the patronage. In addition of course we have the O2 and Indigo venues at The Dome.
14. We have yet to see a business plan for the operation of the proposed Arena. A year ago we were told by the applicant that a full capacity (12,500) audience was needed 100 times per year for the Arena to be commercially viable. We note from the latest application material that a capacity crowd has now been redefined to mean either 60% or 70% of the total possible. Apart from having to do so to suit the Transport Plan, surely this raises doubts over the commerciality of the project and raises questions as to why the Arena should be so large in the first place.
15. Is there any reason why Croydon needs yet another night club? Problems with existing clubs have recently led to the Council reviewing its licensing procedure.
16. We could find no mention in the new material of off-site law, order and crowd control nor emergency evacuation arrangements. Who will undertake this? We have been
made very aware of how overstretched the Croydon Police force already is at peak
times.
17. Regarding the quality of design, it appears to be more oppressive greyness and glass with which Croydon has been architecturally overburdened since the 1960s.
18. Although this applicant’s scheme is preferred and promoted by the London Borough of Croydon, at no time has the Council undertaken any proper public consultation to ask the people of Croydon whether this is what they want. In fact we learnt about the
original planning application by chance and were sent details of this latest application apparently because we have formally objected to the Council’s Compulsory Purchase Order to the site. Notification did not come from the London Borough of Croydon but a third party. For a development of this size and with the impact that it is likely to have on Croydon for many years to come, it begs the question why the public’s opinion has not been carefully canvassed and why the Council so willingly granted the original planning application (now the subject of the call-in) apparently without any viability or impact assessment.
We take heart from the UDP Inspector’s Report that said an Arena on this site was not
essential.
We are grateful to the applicant, Arrowcroft, for inviting us to meet to discuss our concerns about their latest development plans. We did this on 12 July 2007 but regret we received no satisfactory answers to the above and other matters raised.
Steve Collins
Chairman, Canning and Clyde Road Residents Association
Also on behalf of Park Hill Residents Association, Morland Park Residents Association,H.O.M.E Residents Association and the former Croydon Society Transport Group."
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