Swanley Town Centre entrance

More Objections!

Below is a considered critique of U&I’s proposal for developing Swanley Town Centre by a resident. We are inviting all residents to post us their criticisms and will publish them where possible.

I am writing to express my unequivocal opposition to this planning application, ref. 17/02279/FUL, for the “Major Phased Redevelopment of Swanley Town Centre” by Developer U&I. My letter addresses the application, public consultation, public comments and provides U&I with my thoughts on how they might progress in future to deliver an application that would actually benefit Swanley as a whole.

I have been a resident of Swanley for my entire life; almost 28 years, and base my conclusion on the fact that this development is not in keeping with the vernacular for a small town in Kent, and does not provide sustainable development in keeping with local public requirements. I can only conclude that this series of high-rise residential towers have been proposed as a means of U&I expanding their Build to Rent portfolio, utilising land which is currently open space (i.e. ideal for a developer, not for local people).

I have downloaded all documents associated with this application from the online portal (summating to 101 pages of drawings, 1732 pages of supplementary reports, documentation, and public comments totalling 47no. files). I have undertaken a comprehensive assessment of U&I’s statements, assessments, planning drawings, and the public comments posted between 27/06/2017 and 16/08/2017 (in preparation for the public consultation meeting), and made my opinion known at the meeting, as summarised below. I would recommend that in future U&I should make any future applications more accessible, as I am sure a number of local residents have been unable to waste time undertaking the exercise that I have to download and review these documents. For example, provide a pdf drawing binder rather than 101 separate files and people may be able to review the drawings with greater ease, to see just how nonsensical this scheme is.

To review the Local Residents Meeting, 16/08/2017:

  • I am aware that the key representative from U&I was their Director for Build to Rent, which makes it clear to me that this application’s key driver is for U&I to expand their Build to Rent portfolio for their investors (from the meeting this was noted to be development for a Pension Portfolio).
  • Might I recommend that at such meetings in future, U&I should provide a presentation of the proposition that they are making. A scattering of drawings on boards and 4no. ring binders only made available immediately before the start of the discussion will not provide local people with enough time to adequately review the literature.
  • Thankfully, it was not difficult for people to clearly identify major flaws with what U&I had to propose, having had less than 2 months to consider the application, whilst U&I (with over 2 years with paid teams preparing the application) could not easily rebuff these concerns. This showed me clearly that the proposal could not be substantiated to provide holistic benefit for the local people.

To review my statement from the Meeting:

I expressed the following concerns and opposition of the application;

  • I asked whether U&I were looking to “manage expectations”, by proposing high-rise towers now, to then “shave off” floors under future applications, until a scheme gets approved allowing higher structures than should be acceptable in the town of Swanley.
  • I suggested that U&I should propose a more sympathetic development in keeping with the town, rather than capitalising on car parks.
  • I suggested that the “redevelopment” should be in keeping with the vernacular of Swanley town; 8-13 storey towers would not be in keeping with this (being some of the tallest blocks in Kent), and that Swanley is not a town like Croydon, nor should it ever become a concrete jungle.
  • I discussed how areas to the north of Swanley were within the top 20% most deprived areas in England, while the area to the south of Swanley is within the top 20% least deprived areas in England (See U&I’s report 17_02279_FUL-ECONOMIC_BENEFITS_REPORT-1659110 Pg7, on “Deprivation”). To me, this is why U&I have chosen to develop Swanley now – as Swanley would be well suited to them now, as a “cheap” site, to capitalise on their assets (they have owned the site for approximately 10 years, without looking to provide similar regeneration previously).
  • I discussed how U&I’s existing retail and parking assets had been left to fall into disrepair, and that U&I should show some level of responsibility for what they already operate before being trusted to manage such a development. I do not believe that U&I will be able to suitably maintain this development, and it would become an undesirable habitat to be in.
  • I discussed how U&I should show more investment in community infrastructure and spaces; inclusive of local healthcare (inc. surgeries), education, refuse collection (and general litter management), lighting, parking (14 more net parking spaces under this scheme is ludicrous), etc. and other amenities as a “residential and commercial space” outlook on development will not be sustainable. Existing facilities are already oversubscribed.
  • I identified that Swanley required investment in other infrastructure, inc. road, rail, and sewerage – a failure to provide assurance that these could be secured would prove any such development to be a non-starter. Similarly, their highway assessment that no more parking need be provided as U&I believe (hope) that new residents do not want to own a car has grossly overlooked simple statistics that people in Kent use cars. I also mentioned that if a crater of a pot-hole can’t be fixed in Swanley in under a fortnight, then I severely doubt existing resources are up to task.
  • As to the above, how could U&I maintain their proposed development, and the increased strain it would provoke on the surrounding infrastructure, without adequately quantifying it at this stage with a robust strategy in place?
  • I discussed how people might “Buy to Rent” in London, as it provides flexibility of living and good connections for work, however this is not what people are looking for in the countryside. These residencies would be a 20+ minute walk away from the station, offering a commute (to Victoria) inc. waiting/connections in excess of 60 minutes. I would be interested to know how U&I expect to fill so many rental flats, when the recently refurbished Horizon House (which should not have been built so high in the first place) has always had several “For Sale” or “To Let” signs outside since it was opened (i.e. proving that it is not currently fully occupied).
  • I highlighted how people want houses, not poke-holes for flats, and that I for one (as a “young professional”, U&I’s supposed target audience) wound not even consider living in one of these monstrosities.
  • I discussed that I had read over 100 of the public comments (150 no. had been posted at the time that I read them). Not one of the comments provided support for the scheme, with 98% stating opposition to the application. I asked how U&I would usually proceed with an application that had a 100% failure rate with respect to public backing.
  • (Note, I was intrigued but the “public consultation” statistics (See doc. Ref. 17_02279_FUL-STATEMENT_OF_COMMUNITY_ENGAGEMENT__PART_4_-1659170 Pg 20-25). This is clearly not representative of the population of Swanley, and I am intrigued by the ratio of “positive vs. negative” feedback that was documented by U&I, while the comments published outside of U&I’s control showed blanket rejection of the proposals. Something must have happened between then and now to invoke such a drastic response (my suggestion would be that the actual proposal ref. 17/02279/FUL is nothing like what people would want or expect to have seen under this application).
  • I identified that the renders that had been provided for the proposed scheme were misrepresentative of the actual product; U&I have selected angles that would show the high-rise in a positive light, e.g. from a low angle with the high-rise hidden behind the existing YMCA building (See 17_02279_FUL-STATEMENT_OF_COMMUNITY_ENGAGEMENT__PART_3_-1659178 Pg 1, “Visual Impact Reduction”).
  • Similar misrepresentative images on Pg 1, images 1, 2, 3 and 4 which fail to provide visuals to compare against with none of the proposed towers present, Pg 2 which fails to show the scale of the height of the tower (similarly for Pg 9), Pg 3 which has Block 3 omitted to falsely represent open space (Pg 10 and 11 similarly with buildings omitted), and the highest tower tucked nicely (for U&I) behind existing retail, faded into the background. I would like to identify to U&I that, though “favourable imagery” may be in their best interests, misrepresentation will not secure public trust, and should not be included in a planning application.

The Developer did not respond to any of my comments at the meeting. I would recommend that U&I conduct a full assessment of what the local public in attendance had to say at the meeting, and take this into account when moving forward with their application. As far as I am aware, I saw no minutes taken by the U&I representatives present. If they were to do so, I believe their only conclusion would be to retract this application, which is not fit for purpose, and propose a scheme that is actually suitable for Swanley and the surrounding population.

The council should be aware that, on 18/08/2017 (following the Public Consultation Meeting, which demonstrated strong opposition to the scheme from all speaking parties involved), U&I posted leaflets through local resident’s doors on the subject of “SWANLEY … building a future … We would like to encourage everyone to give their feedback … as having local support would really make a difference.”. The leaflet provides little to no valuable information on the proposed development, and fails to mention critical information; for example, the height and number of towers proposed, the use of existing brownfield sites (namely car parks and the demolition of the existing Cedar Surgery and shops), and the severe lack of new parking provisions. As such, I can only conclude that the leaflet is paramount to propaganda to attempt to gain some local backing from people whom may not be able to take the time to review the application in full, as it fails to identify the key points. The imagery used on the leaflet is also grossly misrepresentative of the proposal, as it implies that the development is predominantly 2 storeys, as existing, with a distant faded example of a residential block beyond. I would suggest that this should be taken into account if any positive public comment is received after 18/08/2017.

To conclude, I would hope that any rational consideration of this planning application would result in the scheme being rejected. U&I should know already from the public consultation that this scheme should be retracted; it is my belief that U&I are looking to “manage expectations”, and will continue to make applications offering towers that are marginally shorter, but with similar massing (e.g. shaving off 1-2 floors, but keep the occupiable floor space by increasing floor plates wherever possible, else providing residencies with floor plans meeting the minimum allowable requirements to ensure their profits). U&I should not waste any more time for both themselves or the local people. Expecting this application to be rejected, any subsequent application for 10, 9, 8, 7, 6 or 5 storey blocks should unequivocally be rejected on similar grounds. Might I suggest that they actually hold a public consultation meeting PRIOR to drawing up a scheme, which would hopefully mean that U&I take some of the public comments on board, and propose a scheme that might actually gain some local backing.

Swanley undoubtedly needs investment, and I am fully understanding in the fact that U&I, as a developer, expect to see a profit from their investment, for their investors (which they are fully entitled to). However, do not do it at the expense of the people of Swanley. Think about what you are doing, plan the application with the people both present and in mind, and come back with a scheme that will put Swanley on the map for all the right reasons.

Thank you for your time,

Kindest regards,

Josh L

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