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Comment: Dear Southwark Planning, I am writing to object to the planning application for the redevelopment of the shopping centre and LCC campus at the Elephant & Castle (ref:16/AP/4458). Affordable Housing: This application does not propose a policy compliant affordable housing mix. Southwark's policy for the Elephant & Castle requires a minimum of 35% affordable housing, of which 50% should be social rented. The applicant's offer does not make any provision for social rented housing or any payment in-lieu. The applicant has submitted a viability appraisal, arguing that providing social rented housing would render the development unviable, but despite the Council's new transparency policy this has still not been made public. Given that the development is coming forward as a result of the Council's own planning directives and given that the developer is an offshore company registered in the BVI and Bermuda, there is a greater need for transparency - especially so given that the application is not policy compliant. Affordable retail & existing traders: The Council's strategic planning framework requires a minimum 10% affordable retail for new developments. Paragraph 5.1.7 of the Council's local planning policy (E&C SPD), further requires a number of "affordable retail units which are made available to existing occupiers displaced by development", in order to "ensure that development opportunities provide opportunities for existing and future SME businesses". The SPD also refers to a 'Traders Charter' agreed with the Council in 2007 and which sets out a number of guarantees for traders. However, the charter has been ignored and Delancey has made no provision for any affordable retail in its application, making only a vague reference to a 'relocation strategy' - but providing no detail on what this 'relocation strategy' actually entails. Its diverse economy of small retailers are at the heart of the community and make Elephant & Castle the vibrant destination it is. Southwark should be supporting and cultivating these - not using its CPO powers to help Delancey evict them. Coronet Cinema: Delancey has dismissed the campaign to save The Coronet theatre. The Coronet takes up a sizeable part of the shopping centre site and is a popular music and event venue. The building dates back to 1872 and is a popular local institution. The Theatres Trust has objected to its demolition as have local preservation groups, on the basis of its Art Deco interior and exterior, which currently remains hidden behind its blue corrugated facade. Transport: The plans make insufficient provison for the necessary public transport infrastructure to support the high-density development as well as extra capacity requirements that will result from the proposed Bakerloo line extension and all of the other major developments currently under construction at the Elephant & Castle. Delancey is using a network of shell companies registered in tax havens including Bermuda, Panama and the British Virgin Islands, in order to avoid paying tax on its redevelopment scheme. Southwark should not be bending over backwards and making planning policy concessions for developers who don't pay their tax. Please register my objection and keep me informed should any of the above shortcomings be addressed and the planning applications amended accordingly. Yours sincerely,

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