Residents of Southgate.
Below is my full response to the application mentioned above. This has been submitted to both the Council Planning Decisions Team, and the Case Officer.
Be in no doubt that all three of your ward councillors are against this application and will fight against it at all costs for the benefit of the community.
We encourage you to take the appropriate steps to also e-mail the Planning Decisions team and the Case officer and use my comments below as a template for what you could potentially say.
CORRESPONDANCE STARTS:
For the attention of Enfield Council Planning Decisions Team relating to the application disputed below. Email: planning.decisions@enfield.gov.uk
For the attention of Allison Russell who is the Case Officer relating to the application disputed below. Email: allison.russell@enfield.gov.uk
I recognise that my comments made below can also be logged online via the Online Planning Register, but I would like my comments to be received and acknowledged by the department and the referenced Case Officer mentioned above.
In reference to planning application reference 24/00732/FUL – Change of use from police station with offices above (Sui Generis/ Class E) to a 65-room Hostel (Sui Generis) including associated refuse/recycling and cycle parking provisions.
Dear Planning Team,
I would like to have recorded my concerns regarding the planning application reference mentioned above to convert the former police station to a 65-room Hostel.
There are a range of reasons why I believe this application should and must be rejected, and I have made my points below. For your ease of reference I would like to take you through them section-by-section of concern.
Report Title: Planning Assessment
In reference to Core Policy 17 relating to town centres there are reasons to be sceptical of the application. The town centres policy mentions that Enfield Council will be strengthening the role of towns centres with commercial, retail, leisure, office, residential and other appropriate social infrastructure related uses. The core policy continues to mention aspects of community safety, policing, litter and the potential impact of noise and disturbance to local people.
From the start point this application relates to a former police station that served Southgate town centre. The police station is now owned by a privately owned company. From a community perspective we are disappointed with the decision that was then made to discontinue the former police station. However, we realise that in the current position that it is privately owned that we have to make do and make sure that any future applications made are beneficial to the cohesion and community in Southgate.
This leads me to the point that must be made that the application as it stands is reducing the amount of available office space from the first floor, second and third floor of the property. This reduced office space will impact the local economy, whether it be coffee shops or retail shops that thrive off people that shop during their lunch times and before or after work hours. The former police station did have office space on the first, second and third floor, and this added to the beneficial mix of use of buildings in the area. This application seeks to reduce the amount of office space available in the area to the detriment of the local economy.
This application will also negatively impact community safety around Southgate as the people that will be temporarily accommodated in the building could bring a broad spectrum of issues, to list a few could be robbery both inside and outside the premises, physical assaults, car break ins, anti-social behaviour and loitering outside the premises. In an area where already the police station has been discontinued and the only police station is in Edmonton, quite far away from this town centre, this adds to the concerns of the local community when they say that crime will almost certainly go up.
This application will also negatively impact noise and disturbance issues for local people as loitering and noise from inside the premises will most certainly increase as the premises operates. As mentioned before, there will be a broad spectrum of people that will either be using this as a hostel or for temporary emergency accommodation. This adds to the concerns that these people will bring with them increased noise and disturbance, which will negatively impact in Southgate as a whole.
Overall, it is entirely fair and logical to say in that this application does not add to the viability of Southgate town centre and will put the area on a faster trajectory of the downward slope that it is already on.
Southgate requires stable solutions and positive solutions to the area. This is not one of them.
In reference to Core Policy 18 of the Council Plan there is a mention of protecting retail uses in town centres and I quote “retail uses will be protected as the main function within the primary shopping areas” and “the vitality and viability of existing centres and planned investment in centres should not negatively impact local town centres”.
This application is in contradictory to the Core Policy 18 mentioned above as it will affect the vitality of Southgate by adding a new dimension that will bring horror to residents and businesses that will have to see a continuous, changing, and non-permanent solution for the building, and this is echoed by the applicant’s intention to turn this into temporary accommodation which is not a permanent measure. In addition, it would be worth for the planning department to consult with local businesses in the area to hear their views, as I have done in my capacity as a local Councillor. It is very clear in hearing their views that they are horrified by the proposals and fear that the harmony in Southgate will be permanently affected for the negative. It is also worth noting that Southgate High Street is home to local and major businesses that have been long established, and this proposal I do not believe would be a positive view in their favour and this could turn local businesses away from our High Street.
In reference to Core Policy 19 regarding offices the Council talk about the “modernisation” and “encouraging” the renewal of premises with existing office space, and again I want to echo that this space will be lost. In addition, there was an opportunity for this space to be turned into a managed workspace with a flexible lease for small and medium sized businesses to operate and this was a massive missed opportunity by the developer.
I also find it deeply concerning that on the section “Impact on Amenity and light levels” that the applicant has said disturbances would not be set to increase should the plans go ahead. This is an entirely false claim as any hospitality building and in this case are hotel, hostel or temporary accommodation – whatever you would like to wash it over as- will bring increased noise disturbance whatever the case. I therefore believe that the police should be more involved in this application to highlight the negative impact that would be brought should this application be approved.
Report Title: Marketing Assessment
The Marketing Report set out by the agent on behalf of the client is a very poor piece of work. This document shows very little relationship with the area and very little local knowledge, which again is to the detriment of our local community.
In reading the section regarding the compatible sites, I believe that the Royal Chase Hotel being converted into a care home was a poor choice of example as a hostel has absolutely no resonation with a care home. Hostels do not provide adult social care and do not provide local community use and are used for the sole purposes of business as is the case here.
Mentioning this poor comparison, I also want to bring to the attention of the planning department that the applicant is not even clear themselves whether this is a hostel, a hotel or a temporary accommodation block. The applicant has been very vague in mentioning this is a hostel and has at times mentioned that this is a hotel, which is a massive contradictory. In saying this, can I please ask the planning department if they (being the council) are sure what the intended use of this building is? They mention leisure and tourism and hospitality needs, and then on the other side talk about emergency accommodation needs, which are again two very opposing comments. This leads me to the perception that the applicant is not loyal and honest and upfront about the comments being made to the intended purpose of this building.
Moving forward, I want to talk about the target market and that the agent has mentioned tourists seeking affordable accommodation as a reason for this development to be approved. In looking again at the Marketing Report, it is very clear that the applicant has no local knowledge as they have not mentioned the other two hotels that are currently in Southgate providing this service already (Premier Inn and Southgate Hotel). This could raise the case that this is a surplus to requirements and the application is not necessary.
The Marketing Report also mentions residents needing temporary or emergency housing. I want to make my feelings clear in that this section in no way shape or form addresses the real needs of family housing that is most pressing in this borough. This is a temporary fix to a situation where persons and families are constantly on the move with no stability, and hostels in no way provide security or certainty to families and persons who know they will eventually be moved on.
And if we are to address the applicants mentioning of affordable housing, there is no certainty that the applicant will adhere to criteria of 80% of the local market rent. The proprietors are free to charge their own rate whether it be at or nowhere near the current rate for housing needs.
But what is more concerning is that the applicant is talking about local housing needs and affordable housing, but at the same time addressing the needs for a hostel in Southgate. Let us be clear when we say that affordable housing and hostels are in antithesis to each other. Nobody will consider a hostel a home, and nobody expects to be in a hostel for a long period of time therefore this is a temporary measure and a purely commercial venture the applicant seeks to achieve with no real benefit to our area. Hostels have no relationship to alleviating the pressures on housing targets and most certainly do not provide long-term benefits to our housing issues in the borough or capital.
And finally, may I take the opportunity to say that I find the way of advertising this development in the future (should it be approved) ludicrous. The applicant has mentioned that there will be an online listing via Zoopla. At what point is a hostel advertised on an online platform like this which is involved In short lettings, long lettings, sales or leases of properties. I believe I am right in saying that the applicant is confused, and Zoopla is not used to advertise hostels in this way. Again, may I encourage the Planning Team to confirm exactly what the applicant intends to use this building for as there are many contradicting statements on its use.
Report Title: Highway Safety Impact Assessment
This is a small comment to bring to the attention of the department. The applicant has mentioned that Chase side currently has a speed limit of 20 mph to ensure pedestrian safety, which is false as TFL clearly mentioned on their supporting documents that Chase side is a 30 mile per hour zone.
Report Title: Community Infrastructure Levy (CIL)
I have concerns on subsection 4 regarding the liability of CIL, as question B clearly mentions the creation of one or more new dwellings through a new build or a conversion, and this application most certainly applies as the applicant is seeking to build a hostel for the use of supposed tourism and emergency and temporary accommodation. The answer to this question in the application form must therefore be yes.
I feel the applicant has not taken this documentation seriously and has not completed all the relevant fields and I would encourage the department to review this document and make sure that all the applicable fields have been filled.
Review: Floor Plans for proposed development
I would like to take the opportunity to bring to surface some inconsistencies I have discovered in the application drawings.
On the drawings- Proposed Ground Floor Plan- the applicant has mentioned X10 cycle storage spaces clearly however they have contradicted themselves by then saying X22 cycle storage spaces on Application Form – Without Personal Data.
On the drawings- Proposed Ground Floor Plan- the applicant has mentioned that there will be X1 Recycling and X3 General Waste contained bins. This is not in line with council policy and recycling facilities on premises must be parallel to refuse facilities. This does not contribute well to Enfield’s Net Zero ambition.
On the drawings- Proposed Ground Floor Plan- the applicant has mentioned that there will be one Disabled WC for the entirety of the building. This is disappointing given that hotels are expected on all floor levels to have by law a Disabled WC and that the ration must be 10% of your total rooms or bedrooms. This therefore falls short.
On the drawings- Proposed Ground Floor Plan- the applicant has mentioned the retention of two existing staircases but no elevator. In most hotels and hospitality buildings an elevator must be present on the premises to ease overcrowding on stairwells.
On the drawings- Proposed Ground Floor Plan- the applicant has mentioned three rooms will have an area space of below 7.5m2. . This is against the nationally described legal minimum space standard for rooms of this type. This is in addition not an example of quality housing and is a desperate attempt by the developer to cram in as many rooms to the developer for profit seeking.
On the drawings- Proposed First Floor Plan- the applicant has mentioned seven rooms will have an area space of below 7.5m2. . This is against the nationally described legal minimum space standard for rooms of this type. May I also add that the applicant unlike the Proposed Ground Floor Plan has been vague in displaying which rooms will have 1,2,3 beds which is testament to the inaccuracies all over this application.
On the drawings- Proposed Second Floor Plan- the applicant has mentioned six rooms will have an area space of below 7.5m2. . This is against the nationally described legal minimum space standard for rooms of this type. Again, also the applicant unlike the Proposed Ground Floor Plan has been vague in displaying which rooms will have 1,2,3 beds.
On the drawings- Proposed Third Floor Plan- the applicant has mentioned one room will have an area space of below 7.5m2. . This is against the nationally described legal minimum space standard for rooms of this type. Again, also the applicant unlike the Proposed Ground Floor Plan has been vague in displaying which rooms will have 1,2,3 beds.
In terms of one bedrooms under 7.5m2 there is a potential total of seventeen rooms under the national standard.
On the drawings- Proposed Ground Floor Plan- the applicant has mentioned five rooms will have an area space of below 11.5m2. . This is against the nationally described legal minimum space standard for rooms of this type with two-beds. Again, the applicant unlike the Proposed Ground Floor Plan has been vague in displaying which rooms will have 1,2,3 beds.
In terms of one and two bedrooms under the national legal minimum that brings us to 22 rooms potentially.
I echo the word potentially as the applicant has also caused confusion in the number of rooms being applied for. The applicant says 65 however when counting the rooms on the floorplans the number is 62.
Review: Application Form – Without Personal Data
This section will seek to highlight the inaccuracies and contradictions the applicant has made.
The inaccuracy comes first in the Description of the Proposal where the applicant has made the claim that the change of use has not already started. This could not be further from the truth. Please see references to the videos below:
https://www.youtube.com/watch?v=9WCPxHinO3I&ab_channel=NickMatthews
https://www.youtube.com/watch?v=u-y5NC-e1-E&ab_channel=NickMatthews
These links attached clearly show the dishonesty from the applicant and the developer, and the scant regard that they have for the planning department, and disrespect for the community. The applicant has clearly made-up their own minds and their own decision and gone ahead without prior consultation even in the form of a pre application or even waiting for the application to be complete to go ahead with the works.
This building is an asset of community value, has a heritage attached to it and needs correct and formal planning consent before any works should begin, and this should have been made very clear to them. I believe the planning department should treat these videos as unfavourable and it should be viewed negatively in part of reviewing this application. This is not in the spirit of planning and people should not be undertaking construction works without prior consent. This is in clear violation to the Description of the Proposal and therefore the applicant has lied. For the department’s reference this YouTube video was taken before the formal application was made.
May I also take the opportunity to say that when asked for further information about the development, there is a contradiction when the applicant says that the proposal does not include affordable housing and has selected no, when in other supporting documents they have talked about alleviating social housing needs and generating affordable housing. Clearly the applicant does not know again what the use of their building is and is not being transparent.
The applicant has also mentioned regarding the Development Dates that the building works were expected to commence in May of 2024. However, the application was received on the 7th of March and validated on the 27th of June. This reaffirms my point that the applicant undertook works just after applying and again without consent.
I would also ask that the planning department investigate the existing use of the building as there are claims of short leasing having been done on this property when apparently the applicants said that it was in vacant possession under their ownership.
It is also concerning to see that this application of its significant value and development opportunity does not include any plans to install electric car charging points for vehicles, which is something that the London Borough of Enfield has been very keen on installing and progressing, and especially on residential and commercial applications. Has the department investigated why this applicant does not want to install them? Should there not be a commitment by them?
The applicant has made yet another contradiction in this section under the section of residential units where they have ticked no in terms of mixed-use residential. The applicant has made it very clear that the site will be used for affordable housing, for temporary accommodation, and for hostel use. I do not believe these points that they are making, but nevertheless they have made them and that option for mixed use should have been ticked.
The applicant has also said that they will be installing a green roof of 166 square metres on the property. At what point was this in the drawings of the application? I have seen no evidence, not on the third floor or the fourth floor or in the yard at the back. Can the department please ask for clarification on this?
I also find it baffling that an application with an estimated cost of £2,000,000 for the applicant to bring it up to the standard that they desire, has not sought pre application advice.
Conclusion:
This application is riddled within accuracies, misinterpretations and instances where the applicant has made-up their own decision without prior consent and with scant regard to the local community. This is not a transparent application, and I must admit in seeing applications for the last six years as a ward councillor I find this extremely distasteful and disrespectful to the planning department and the local community.
The applicant has displayed very clearly that they have very little local knowledge of the area. This has been testament to the fact that they do not know what other hospitality facilities are in the area and are contradicting their claims on the intended use of the building whether it be as a hostel, temporary accommodation or for use of social housing.
I find it even more concerning that the applicant and the agent involved have not been transparent in the application form that is a simple tick box exercise for any developer.
Never have I seen so many in accuracies in what should be a simple exercise.
This application will set a precedent for poor quality accommodation in Southgate, whether it be for a short or long term offer, or temporary accommodation. These rooms are not fit for purpose and the applicant has been very vague in the drawings as to whether these will be one, two or three bedroom rooms. As a council, we have a duty to uphold minimum standards and this application falls extremely short of that.
I am even more concerned by the prospect of increased crime rates and anti-social behaviour in the vicinity as this will bring a new spectrum of people to the area that will not be in line with the current situation of families and young people who live in the vicinity. I already mentioned that the Department for Planning should consult more vigorously and more seriously with the policing department and get their thoughts on this.
This application is not in line with the spirit of the area, the character of the area, and I do not believe will be a positive addition to our town centre. I believe this application will set a downward spiral for businesses to vacate the area and for people to consider their position within Southgate. Families I am sure and have heard that they will be moving out to other areas of London if this were to be approved.
I urge the Planning Department to take this application very seriously for the sake of the community here in Southgate. Approval of this application will be detriment to the area and will significantly decrease community morale and confidence in our local democracy and local authority that is Enfield Council.
Please note as well I have requested this application be taken to committee for the hearing and vote it deserves.
Yours with best intentions always,
Cllr. Stephanos Ioannou,
Conservative Councillor for Southgate ward, London Borough of Enfield.
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