EGRA Response to Morden Wharf

EGRA's response to the Morden Wharf Development, Planning Application Ref:20/1730/O. Deadline for comments is Tuesday, 15th September.

Morden Wharf has been semi-derelict and under-occupied since the departure of Tunnel Refineries in 2009 and EGRA members are keen to see appropriate mixed use development on this crucial site. It is unfortunate that there is no proper masterplan for this significant area of riverside. So far this has resulted in disappointing ad hoc development with no co-ordinated design aesthetic. This impacts badly on the World Heritage Site and provides unsatisfactory public realm for both residents and visitors. Our concerns about the current proposals have been intensified by the Covid-19 crisis. It is time for a rethink about how residential and social spaces will be used in future.

EGRA members are very concerned that the presentation of this Planning Application as part Outline, part Detailed and with a very large number of accompanying documents is designed to prevent proper interrogation of the proposals by RBG Officers, Councillors and the general public. We believe that these should have been separate applications.

We intend to respond separately to the two elements of the application.

Part One - Detailed Application

Wharf “Flip” - We believe that the wharf “flip” between Tunnel Wharf and the existing public access Primrose Pier will damage the viability of the Thames Path for all users. There is a pending application for Sivyer to take over Primrose Pier in exchange for public access at Tunnel Wharf which seems to have been mothballed while the U+I application goes ahead. Sivyer intend to use Primrose Pier to bring in demolition waste by barge and transport it into their site by overhead conveyor. The Thames Path is only 48 inches wide at this point and has two blind corners. Sivyer operate heavy machinery within a metre of the path already and have a long history of complaints about noise, dust, vibration and excessively high stockpiles of material next to the path. The Environment Agency is investigating complaints about breaches of the current very lax operating conditions. We believe that Morden College as the landowner of the entire site should make a commitment to improving the whole stretch of Thames Path along its frontage. Otherwise there is a serious risk that the northern path may become untenable.
Gloriana Boathouse - It is unclear (despite the large number of accompanying documents) whether the boathouse and ancillary lifting gear on Tunnel Wharf is actually being funded by U+I or by the Gloriana Trust. We believe this requires clarification because there is a strong possibility that Councillors will back this project based on this new “visitor experience” only to find that the financing is not forthcoming and the jetty is not developed or only minimally. Meanwhile the safety of the northern stretch of the Thames Path will have been severely compromised.
No Thames Path closures - We welcome the developer’s commitment to keeping the Thames Path open throughout the construction period. We would like this incorporated into the s.106 Agreement since our experience is that these promises tend to be forgotten later on. We also think that the Thames Path should be considered in its entirety in this application not in a piecemeal way.
Landscaping and Public Space - Although the applicants claim that the green space and park area has been increased, there is little sign of this on the Thames river frontage. Most of the public space will be hard landscaping apart from a rather pointless strip of “amenity lawn” which looks to be unmaintainable. Underground parking will restrict the ability to plant any substantial trees. The public play space offer, described as “non-prescriptive play equipment”, is meagre. It looks as if the real intention is to provide a large overspill drinking area from the proposed bar/restaurant in the Southern Warehouse which may well impact on Thames Path users and residents of the riverside towers.
Thames Path “Bridge” - Although straightening out this one sharp corner on the Thames Path is unobjectionable, as we have pointed out above there are no plans to improve any section of the Path beyond that and very serious concerns that its viability will be damaged.
Riverside “Park” - In the light of the unambitious plan, we take exception to the statement at p.38 paragraph 5.16 in the Planning Statement that “A reduced scale of development would mean that the public park could not be provided”. If the developer cannot deliver even this pathetic level of public realm without building a number of inappropriate high rise towers perhaps they should reconsider their plans completely.

Part Two - Outline Application

Height and Massing - Local residents are incredulous that the developers believe that towers rising to 36 storeys are appropriate for the riverside section of the site. We think that the use of two unbuilt developments as precedents is unreasonable. The towers up to 32 storeys at Enderby Wharf were based on the alleged need to fund the controversial cruise terminal. Knight Dragon has outline permission for the north west of the Peninsula but has no detailed plans and in fact has used part of the area for the low rise venue, Magazine.
Appropriateness of units - there are currently a large number of unsold riverside units. Building work has not resumed on the unfinished developments at River Gardens or on the northern Peninsula, calling into question the relevance of the Morden Wharf property units to current housing problems. In the post-Covid world people might reasonably expect more living space for home working and individual outdoor space. The business model which has made many Greenwich developments attractive to Airbnb/short let property speculators may be a thing of the past.
Land banking - given that most of the site has been unused since 2009 and that U+I have been involved with Morden College for some years, we are concerned that this project will be landbanked once planning permission is granted.
Housing mix - The 35% social housing is, as usual, not actually 35% of the actual units. The “affordable” element is going to be wedged between the riverside towers and the new road link into Blackwall and Silvertown Tunnels. Is this really appropriate?
Environmental impact - The riverside towers will create a huge carbon cost. There seems little ambition to meet any but minimum build standards with no consideration of more stringent environmental standards - for example, the sustainable drainage scheme only meets the minimum standard. In addition, the wind modelling is quite inadequate for the extreme local conditions which often pertain on the riverside. We do not want the public “park” to be a windswept, un-useable space. We believe that there is a risk of extreme overshadowing particularly for the social/affordable blocks. There is also an obvious problem with solar glare for neighbouring properties particularly those across the river.
Electricity - The absence of local capacity was used to justify the lack of on-shore power for the Enderby Wharf cruise terminal. Neighbouring industrial sites including Hanson rely on diesel generators. U+I have been unable to explain where the additional capacity is coming from at any of the public consultations.
Water and Sewerage - Once again, local infrastructure is at breaking point. Thames Water have recently had to dig a new water main from Lewisham to the Peninsula as Knight Dragon and GMV developments were at the limit of capacity. The connection of new builds at River Gardens and Enderby Wharf to the sewerage system has caused both new and existing properties to be flooded with raw sewage. We would like clarity about how these new units will be supplied without extreme disruption to current residents.
Integration with industrial sites - The photomontages produced by U+I showing the Morden Wharf towers surrounded by other high rise developments are fanciful. These new property units are going to have a large hinterland of heavy industry sites for the foreseeable future. New residents will need to be aware of the amount of noise, dust, vibration and HGV traffic that these businesses generate. They will be a lot nearer to Sivyer, Hanson, the Boatyard and Brenntag than those of us in the old part of East Greenwich. EGRA already receives lots of comments and complaints from new residents at Enderby Wharf and Precision about the disturbance from nearby industry. We would like to see some realistic amelioration measures incorporated at this stage of the planning process rather than pretending that the surroundings are going to change soon.
Silvertown Tunnel Impact - Even more pertinent to the success of the project is the unknown impact of the new road network which will be required to service Silvertown and Blackwall Tunnels. The eastern side of Parkside Towers will have a vista of a minimum of 18 lanes of traffic from Tunnel Avenue to West Parkside. The social/affordable units will be right beside this new sea of roads. Once again, we would like to see proper care taken to protect new residents from the noise, light pollution and, above all, poor air quality that this will produce.
Traffic generation - We are also concerned about how much additional traffic this development will generate. Despite having a tube station close by, the developers appear to have based the Transport Assessment on the notorious and discredited Charlton Rockwell development meaning this is intended to be “car lite” rather than a car free. We think this is very unambitious and inappropriate.
Possible Distribution Centre - The new warehouse building at W01 appears to be intended as a “last mile” distribution centre. This will obviously generate a large amount of additional traffic (both HGVs and vans) in Tunnel Avenue and onto the already overloaded local road network. We question whether this is a suitable site for such a traffic intensive business, particularly given the poor air quality for which this area is notorious and the proximity of the warehouse site to the social housing units.