Objections to planning application for refurbishment and extension of Aragon Tower on Pepys Estate, Deptford, SE8 :-
Ref : Application No. DC/02/52950



1 Planning policy


The proposal has no vision for the estate - it is merely a piecemeal development around its perimeter that will interfere with an overall strategy for the community of the estate. It lacks a coherent long-term policy for improvement and development of the estate. It will not belong with the remainder of the estate, rather it will be set apart.


It does little to take us forward in urban design, as this could be built anywhere, as it now commonly is. It has no uniqueness to the site. Which is on a part of the former Royal Victoria Victualling Yard.


Looking back to the original Hazle, McCormack, Young Form B Estate Action Submission - July 1992, when Estate Action was envisaged for Pepys. This thorough study identified the major opportunities that exist for radical improvements to its environment, and quality of life of its residents. Furthermore the recommendations were developed as a result of the needs and aspirations of tenants as identified through the Planning for Real exercise, together with the information derived from the many surveys and associated research that was undertaken.


Responsibility : Tenants need and want responsibility to enable them to remodel, develop and enhance the quality of their environment. This proposal does not offer that opportunity, it is a design 'imposed' on the community. Meant to achieve a new 'mixed' community. Yet by itself offering only a separate 'island', and is deliberately breaking up and throwing away an existing vibrant community, that has organically grown into a true mixed community.


The diversity of cultures indicates that the tenant profile has over 45% of the population on the estate made up of BME groups. There is a need to integrate these residents into the everyday life on the estate or there is a real danger that half the population will remain isolated and unable to contribute.


Further figures showing in excess of 30% unemployed with 50% of households claiming housing benefit give a clear indication to the economic status of many of the residents.


The policies and proposals in the Lewisham UDP ( 1992 ) ... in summary ... seek to :


1 - Protect the principal areas of open space in the estate.
2 - Protect and enhance the Thames Walk.
3 - Ensure that archaeological remains are preserved and recorded.
4 - Prevent new high-rise development.
5 - Retain the existing employment generating uses.


Page 18 of the HMcY report - Quote from Chisel Report 1992 on the estate :-


"The Pepys Estate contains a particularly high proportion of people with few opportunities for formal employment with a strong degree of reliance on state supports for income and welfare. Households are clearly varied in their structure with a very high proportion of small households, and single parent families and elderly people concentrated in specific blocks ... it would appear that for many people much of their time is devoted to 'getting by' and 'making out' in circumstances of hardship and poverty".


Yet there is no community benefit in this proposal for Aragon Tower by a private developer, which received approval as one whole development scheme by Secretary of State in January 2002, along with phases 1, 2, 3 of the Hyde Housing scheme. The only a suggestion for community benefit is that of a possible phase 4 - including a childcare centre, if building on the Redgra area were to be accepted. Which is not acceptable. Part of the site also threatens further phases of housing development on existing parkland and open public spaces. Clearly against the UDP.


Whatever happened to "preventing new high rise development" from the UDP quoted above ?


The UDP policy HSG 1: Preventing a Loss of Housing by Demolition and Redevelopment states that existing dwellings should be retained in residential use, either through rehabilitation or renewal. Rehabilitation is the better option to conserve the architectural integrity of the estate and the embodied energy therein.


At least the Aragon Tower proposal meets one of these UDP policies.



Policy HSG 20 relates to the density of new residential development and states that they should to be built within a density range of 70-80 habitable rooms per acre. The policy sets out a number of exceptions to the policy where higher densities can be acceptable in certain cases. One of the exceptions set out in the policy is the River Thames frontage at Deptford where higher densities may be acceptable subject to compliance with HSG 19.


Clearly this is being offered as an exception for the redevelopment programme as a whole, as density is being unnecessarily increased. Aragon Tower has always been left out of any of the calculations presented for the overall redevelopment scheme - the Master Plan. The density on Pepys is already very high owing to the three tower blocks, which should always be used in any overall calculation of density. It is why they exist.


It is not clear in this submission what the actual densities are to be. This may be deliberate to obscure.


In addition this means the loss of a great deal of much needed social housing on Pepys, as the current provision is in Aragon Tower is 100%.


2 Planning history on Pepys


1960's - London County Council / Greater London Council - Architects : Ted Hollamby 1921/1999 ( Chief Architect ) . Area of Pepys Estate development 45 acres and to provide 1,324 homes at an estimated cost of 7m.

Four main types of building :-


- three 24 storey blocks of maisonettes on an interlocking plan which resembles an open pair of scissors;
- ten 8 storey maisonettes, running through the length of the site providing continuity, a link from park to river, and a horizontal contrast to the tower blocks;
- 3 storey flats in colonnades near the river front giving a visual link into the site;
- 4 storey flats including old peoples homes, grouped around the central amenities of the site.

Amenities to be provided by the scheme :-


12 1/2 acres of open space; a car-free shopping centre;
garages under 8 storey blocks; parking spaces;
a tenants club room; a youth club;
an old people's clubroom; a maternity and child welfare clinic;
Deptford Park primary school to be enlarged for the children of the estate; an old people's home.


Themes :-


separation of pedestrian from vehicular traffic, elevated walkways;
new roads to bring into the estate, involving a new road bridge;
preserve the nautical and historical character of the site;
a promenade by the river front;
commanding views including London's docklands and the Greenwich Naval College;
the block names enshrine three centuries of history.


1966/7 - Scheme won British Award for Architecture. Commended by Civic Trust as "an impeccable scheme".
( Key document - Pepys Estate a GLC housing project ).


1980's - Lewisham Council take over Pepys Estate from GLC - debt free.


1980's - Estate deteriorates due to letting policies and poor management. Problems with overhead walkways, no security to individual blocks, original residents ( vetted ) begin to move away.
Increased number of teenagers on the Estate with 'nothing to do'. Rise in crime, vandalism, drugs, etc. Refugees, asylum seekers, often placed on large estates like Pepys as first location.
Around 70 different languages spoken on Pepys ( quoted in research background for 1992 report ).


Estate Action becomes key Government policy - John Gummer ( Housing Minister ) / Michael Heseltine ( DOE )


Early 1990's Estate Action bid put together by Lewisham together with tenants to regenerate inner city problem estates. Phase 1 approved by DOE in December 1992 to run until 1999 ( 7 years )
- estimated total cost 28.658 plus 1.85m for CRS.
In addition partnerships with Family Housing Association and Deptford City Challenge - overall resources of 39m.



3 Site layout


This proposal will contribute further to the over development of the site - with increased density of 158 units from 144 units. Car parking is proposed to open spaces presenting visual, noise and pollution detriment to an existing quite successfully planned and largely traffic free, extensively landscaped and pedestrian area around the base of Aragon.



The sale of Aragon Tower to the private sector does not allow a mixed community in the property as there is noaffordable housing whatsoever. This seems to be very unusual as a project, elsewhere affordable housing is always included. In accordance with Government guidelines.


The proposal, as drawn, is wrong on ground level as a new building on the site of Limberg House by Hyde Housing Association has already been approved by Lewisham Planning. Which establishes its footprint in seeming clear contradiction to this drawing.


When built the Hyde HA proposal will completely cut off access from Longshore to the Thames public right of way. Together with this proposal for car parking at ground level the combination will cut across existing cycle routes and cut across the Thames Walk pathway network, intended to link the riverside amenity which extends from Tower Bridge to the Thames Barrier as a unified route between the Boroughs of Southwark, Lewisham and Greenwich.


Disagree with the proposed new car parking arrangement to Aragon Tower on the Aragon Garden side because it contributes to the blocking described above.


Disagree with the proposed access to the new car parking via a new opening to George Beard Road, passing Fleming House Old Peoples Home. Which is classified as a quiet back street. Increased noise and traffic flow.


The high number of proposed car parking spaces at 79% is higher than the allowance for the Hyde HA part of the redevelopment scheme at 60%, already approved ( as a part of same Master Plan it seems ).


The income level of the new residents mitigates to more than one car per unit occupied. So where will the actual overflow of the new private occupiers cars, and their visiting cars, be located ?


For car parking at present on Pepys it is 'first come first served'. The residue car parking from the new proposal will be using local facilities, of Deptford Wharf, which at present has clear roads as the parking is in front of the homes. Yet the local community will not be able to use the private areas.


Increase in pollution from several sources, e.g, car exhaust, noise, increased volume of use, etc, for all new properties as they will have a new access road built adjacent to the dwellings in quiet residential back streets.


This will reduce the 'defensible space' for nearby properties, as they will be located alongside an intended access road and view onto an open car parking area, rather than the existing very local estate access roads and walkways, giving rise to more opportunities for crime.


The proposed car parking and podium will Infringe and be prominent into land currently laid out predominantly as open public park space, thereby reducing an amenity that benefits the residents of the estate who have no gardens of their own, as well as the freedom of public access.


For example, residents of The Terrace will have to cross many vehicular access points to reach their home. At present pedestrian ( and cycle ) route is well catered for. This is especially important to young children and the elderly, as there is a well established community.


Concern that existing access to garages at the rear of The Terrace will not be accessible, owing to insufficient turning space.


The raised podium enables the residents to overlook the estate when sitting out in open and viewing others close by. Is it proposed to be a public facility ?


The raised podium proposal for Aragon contradicts the removal of raised podium from Daubeny Tower under Estate Action, to rationalise street level access and prevent anti-social behaviour. This also introduces confusion of design features not coherence within the estate.


'Play safe' areas for children and young adults adjacent to the existent dwellings are being further eliminated by the new access road and car parking. Supervision needed is increased and safety jeopardised.


Disagree with diminishing access to Aragon Gardens and the size of the approach - loss of a valuable public amenity and open space that benefits the estate. Aragon Gardens was a part of the re-design of the successful Estate Action scheme 1992-2001.


Loss of mature trees alongside Aragon Gardens.


A higher building will be out of character in architectural style sight line to the Foreshore - which is of historical significance as a Grade II listed building.


Interfere with the wind turbulence by being very tall with an additional height of six storeys to become 30 storey.


Disagree with the increased height of the proposal, in contrast to the already refurbished Daubeny Tower and Eddystone Tower. It will stand from out rather than harmonise with the other two existing towers.


Concern over the extra height for wind deflection within factor of safety, as well as extra weight imposed on the foundations.


The river Thames is an open 'wind tunnel' for London. The existing 3 tower blocks on the estate were carefully positioned and tested as a trio to minimise downdraughts and turbulence when the existing estate planned - one is positioned at a right angle to the other two for this reason. Alterations in this arrangement will have significant effect on nearby properties and people on the ground.


Sight lines to the river are blocked by the podium build and by the increased height of the new proposal for the immediate neighbours of The Terrace and Harmon House, as the 2 nearest effected, and all other existing properties in the vicinity. Resulting in loss of amenity. This will be further added to by the big reduction from the existing LImberg House vista, in the Hyde HA proposal of the redevelopment.


An increased height building would cast a longer shadow over adjacent properties at certain times of the day.


No consideration of the new Limberg building being sited closer to the proposed increased height tower block - overlooking.


Former local Councillors in office, Mottingham, Mee Ling and the Council, promised that there would be no segregation from the community. This design clearly shows a wall all around it with a wrought iron fencing on top. This is segregation which does not happen anywhere else on the estate.


The sculptures on the river side elevation of Aragon Tower are now an established part of the tourist attraction for the history of Deptford, e.g, boat trips on the Thames. Where will they be re-located to view, if at all ?


The proposed conversion to 100% private occupation takes away a 100% social housing facility from Lewisham tenants.


Proposed 24 hour concierge being established contradicts the Councils Neighbourhood Wardens policy of withdrawing all concierge from its own secure tenancy tower blocks.


Item 7.1.2 in the report, until it was picked up in consultation with the local community there was no allowance for existing decanted tenants to move to the new properties being built in the redevelopment proposal. However, no tenants can move into the privatised Aragon Tower. Despite an agreement to giving existing/former Aragon Tower residents the one-off Right to Return as passed at the Executive Committee in 2001.


Object to this planning application as a whole as being wrong in itself ( for reasons given above ) and as a 'trojan horse' for future building 'phases' to greatly increase the density of properties on the Pepys Estate. With the addition of new roads links aimed at joining into the Convoys Wharf site. As well as the proposal from Richard Rogers Partnership for a grouping of three exceptionally high tower blocks on the adjacent Convoys Wharf.



4 Effect on Neighbouring Property


The increased height and podium structure will negate all the most valued views provided by the unique stilted construction of the existing buildings of Limberg House, for adjacent properties of the Foreshore, The Terrace, and the Colanade. As well as Harmon House, Pelican House and Bembridge House, and also further back in the estate. This will diminish, not enhance, the vision and airiness of the whole estate. Which is rare and should be celebrated.



5 Effect on Surrounding Area


The proposed exterior treatment is a stark style, out of keeping with the historical and listed buildings of the Foreshore, The Terrace, and the Colanade. As well as the 1960's buildings Harmon House, Pelican House and Bembridge House. The building would be prominent, especially from the public ground level, and visually damaging to the overall context and landscape.


The development would attract more commercial traffic to have access to what is a uniquely envisaged pedestrian and extensively landscaped area. It would destroy the vision of a breath of air and light brought through the estate to all its surrounding from the nearby river Thames.


Increased traffic movements and on-street parking would create a new set of safety hazards for all.


6 Other factors


Storage for cycles, etc, not shown in any proposed buildings.
Improvement of disabled access not clear in the proposal, and only two parking spaces.
Proposed balconies overlooking new build immediate neighbours on Limberg site.
Road access to Aragon Tower is potential for nuisance to quiet estate road and Old peoples Home.
Raising the height by six storeys of Aragon Tower will make it different to other two towers - destroys the design concept of Ted Hollandby, GLC architect.
Tower block built to withstand 120mph wind at peak, at present height. Higher structure will alter this deflection.
Only seven houses are proposed in the redevelopment scheme part by Hyde HA with an increased number of flats from 222 to 253. This proposal with add even more flats - here all of 'penthouse' proportions and style. The 'mix' of houses and flats is 7 to 267, a ratio of 1: 38. Which is very poor by any standard.
The number of habitable rooms on the estate will be increased by this proposal from the present 4,441 ( including 144 Aragon Tower at 6 per flat ). It is not made clear exactly what the habitable room number will be with the total redevelopment scheme of 261 units and the proposed additional penthouse flats to Aragon Tower.
There has been no recent consultation with Aragon residents on the new proposal.



7 Conclusion


This proposal conflicts with best environmental policies, particularly as it comes at the beginning of a new century - the 21st. It will create potential traffic hazards by introducing a new road system on a quiet estate road. Be wholly out of place in a residential estate set in such a unique riverside position. Which is also uniquely landscaped.


The redevelopment proposal as a whole - which is assumed to be the referred to Master Plan - of which this is a part gives nothing back to the community as a benefit. No Section 106 agreement benefit from the 30m of the Hyde HA part, and no indication of anything from this private sale refurbishment and extension proposal which has an estimated value of 50 to 60m. Despite this part itself taking away from the local community 144 secure tenanted units, and from the housing stock of Lewisham, in the socially deprived Evelyn Ward, at a time of housing shortage.


Rofle Judd report page 25 - "The sale of Aragon Tower is crucial in supporting the comprehensive regeneration of the Pepys Estate and enables the Council to decant its existing tenants into new modern accommodation being developed elsewhere on the Estate."


This is a 'surreal' justification. Existing Aragon Tower residents have been 'decanted' well before any 'new modern accommodation' has been even built; even if they wished to move. The total number of units lost is 366 ( 144 units in Aragon and 222 in the five low rise blocks ), the replacement in 261; so easily a loss of 100 units. As well as the social residents being denied in Aragon the benefit of - "each flat has a split level double aspect, therefore enjoying expansive views".


Lewisham Planning Service is urged to recommend rejection of this proposal to the Planning Committee after examining in detail these objections, and others submitted.




Tenants Action Group, Pepys - TAG.