Guidance on how to object to KICC’s planning application for ‘change of use’ of 25 Church Road – Please act now!

The formal consultation period on KICC’s planning application’s for change of use of 25 Church Road to a D1 ‘Place of worship’, conference and counselling centre has now closed BUT Bromley council planning have confirmed that objections will still be accepted and considered up until the end of January. If you haven’t submitted your individual objection yet, please do.

Or if you want a quick and easy way to object then please pick up an objection postcard and fill it out on the spot at local shops Bambino and Papagaio on Church Road or Bookseller Crow on the Hill and Smash Bang Wallop on Westow Street or Brown and Green at Gipsy Hill and Crystal Palace Stations.  We will collect them at 12 noon on Tuesday 27 January and hand-deliver them to Bromley council.

Thank you for your support

 

Where can you find the application?

The application can be found on-line by following the link below:

14/04557/FULL2 | Change of use from Bingo Hall Class D2 to mixed Class D1 (church) and Class D2 (Assembly and Leisure) use |25 Church Road Anerley London SE19 2TE

Why object?

Kingsway International Christian Centre’s (KICC) planning application for the ‘change of use’ of 25 Church Road (former Rialto cinema) to a D1 ‘Place of Worship’, conference and counselling centre with D2 ’Assembly and leisure’ add-on has been validated by Bromley council and is now out for public consultation.

Based on our experience of the past five years, we and other stakeholders in Crystal Palace have no confidence that KICC will uphold the vague promises set out in their Supporting Planning Statement.

We suspect the proposals are no more than dubious and unsubstantiated statements in order to obtain the D1 planning consent which KICC need in order to justify their investment in the premises using charitable funds. There is scant evidence provided which demonstrates any serious commitment to the D2 components of the proposals or any serious local interest and need which could not be met and better served through existing community venues.

If KICC were serious about delivering a valid D2 offer to the local community, they would have already ‘opened their door’ and not waited until Members of Bromley council’s planning committee had taken a decision to enforce their unlawful use of the premises.

Significantly, previous approaches to KICC by community groups and organisations to use the venue for events within the existing D2 use have either been turned down, ignored or made so difficult, because of the protracted negotiations with KICC’s Chief Pastor whose approval is required, that they have come to nothing.

25  Church Road is the last remaining dedicated D2 ‘Assembly and leisure’ venue left in the Triangle, it is registered as an ‘Asset of Community Value’ and has a heritage of providing public entertainment from its origins as the Rialto cinema.  It still represents the best opportunity for a cinema in Crystal Palace.

Please object to this application now!

How to object

You can either object on-line using the link to the application on Bromley’s website above or you can email your objection:[email protected]

NB If you are a Bromley resident or trader please state this right at the beginning of your objection

Submitting your objection via Bromley council’s online form

We would prefer you to email your objection. However, if you prefer to use Bromley’s on-line form, it is worth preparing and saving your objection in a Word document first and then copying and pasting into the comments section as sometimes things can go wrong and you can lose all your hard work. Please don’t forget to click on Objection too.  Please could you also make a copy and send it to us and your political representatives.

Submitting your objection via email

Email: [email protected]

Cc:[email protected] and your Ward Councillors, London Assembly member and MP 

You can find out their contact details by following the link HERE

It is really important that you let your political representatives know that you are objecting to KICC’s proposals and what your views are.

It will also help us to keep track of the number of objections to the application.

In the subject line please quote:

OBJECTION – 14/04557/FULL2 | Change of use from Bingo Hall Class D2 to mixed Class D1 (church) and Class D2 (Assembly and Leisure) use |25 Church Road Anerley London SE19 2TE

YOU MUST GIVE YOUR NAME, ADDRESS AND POSTCODE TOO PLEASE

What are grounds for objection?

Please have a read of KICC’s Supporting Planning Statement and try and write your objection in your own words as it will hold more weight when being considered by Bromley council. We have set out some grounds for refusal below:

The proposed ‘change of use’ would result in the loss of an existing community facility within the D2 use class – the last remaining dedicated D2 Public entertainment venue in Crystal Palace which is also registered by Bromley council as an ‘Asset of Community Value’ – and would therefore directly conflict with the London Plan and Bromley council’s UDP and Bromley council’s emerging Local Plan  –  25 Church Road (the former Rialto cinema) has a long-established D2 use class which has been serving the community for the majority of the circa 100 years since it was built, first as a cinema and subsequently as a bingo hall. The building was recognised and registered by Bromley council as an ‘Asset of Community Value’ in 2014 and if the premises was available there is a clear interest in it from both the local community and from potential cinema operators who wish to restore the building’s original and current lawful D2 use, fulfilling the overwhelming demand for a cinema to serve the local population in Crystal Palace.

It would not be possible to adequately ensure the retention of a significant element of community/ D2 ‘Assembly and leisure’ use by planning conditions – KICC refer to the building being available outside of the core D1 Church hours for D2 purposes; however, this appears to be nothing more than an aspiration. Firstly, many of the potential uses to which KICC refer (e.g. conferences, business seminars, political conventions etc.) are D1 uses, and would be of limited benefit and appeal to the local community and could not therefore be considered “community uses”. Given that the building has been fitted out primarily for use by KICC as a church with a single auditorium/worship hall with walk in Baptismal pool and has extremely high hire charges beyond the reach of most community organisations in Crystal Palace, it is very likely that there will be only a very limited number of both commercial & more importantly community organisations who will be interested in or able to operate from the building, or be able to afford to hire the auditorium outside of the core KICC D1 Church hours. Any such uses are likely to be temporary and limited as a result, and it would not be possible to adequately ensure the retention of a significant element of D2 use class by planning conditions.

The first priority for the use of the building should be exclusively for D2 ‘Assembly and leisure’ purposes in line with its current lawful use, and there is a clear demand for its use as a cinema. The fact that the site has been purchased by KICC,  (without first obtaining ‘change of use’ in direct contradiction to Charity Commission Guidelines), who wish to use the building as a ‘Place of Worship’ does not provide any justification to allow for a departure from planning policy.

There will be a negative impact on the vitality and viability of Crystal Palace Town Centre in conflict with the London Plan and Bromley council’s UDP – The primary use of the building will be as a ‘Place of Worship’ which is the only certain use proposed in KICC’s application which in itself will operate for only a limited amount of time during the week, and primarily on Sunday mornings when much of the town centre is likely to be at its quietest. This will not contribute to the town centre’s evening or daytime economy, or its vitality and viability.  It is unlikely that KICC’s proposals will incorporate anything more than occasional or temporary or short-term D2 ‘Assembly and leisure’ uses in addition to the proposed D1 use, and in practice it could well be the case that the building is left empty and unused for large proportions of the week to the detriment of the town centre’s vitality and viability.

There will be a restriction on and reduction of the type of D2 uses allowed and wanted by the local community at the building – All community/D2 ‘Assembly and leisure’ use/hire of the premises will be conditional and require the approval of KICC’s Pastor. The community/D2 use element of the premises will be no more than a church with a church hall for hire which is a D1 planning use – not a true mixed D1/D2 use as stated in the Supporting Planning Statement. There is absolutely no guarantee that the potential for a continued element of D2 use of the building for organisations and community groups will be realised as the premises will become a church and run within a religious context plus the proposed prices for hire are prohibitive. What is and isn’t allowed to take place will be decided by KICC’s Pastor.  Moreover, Crystal Palace already has a number of similar community venues and churches which offer exactly this and much more without conditions on use. 

A cinema would be a public use in line with the building’s original and current lawful D2 use, and would provide an active facility contributing to the Crystal Palace Town Centre’s economy, vitality and viability both in the daytime and into the evening

Negative impact on economic regeneration – KICC’s proposals will not support the wider economy of Crystal Palace throughout the daytime and into the evening. KICC’s primary use of the premises for their church services and their religious conferences, conventions and business seminars (all D1 uses) for their members who are provided with food on the premises will have a very limited positive impact on economic regeneration and local trade as already reported by local traders who have seen no evidence of increased footfall as a result of the events already held by KICC.

There will be a significant detrimental impact on parking, traffic and pedestrian safety – This has already been evidenced by the ‘unlawful’ D1 use events KICC have held for their congregation from Wimbledon, from across London, Kent, Surrey and the Home Counties which have resulted in complaints to Bromley council, local ward councillors and Transport for London. These events, evidenced with first hand eye-witness accounts, have resulted in a near miss with a TFL bus at a busy bus stop outside the building, the commandeering of parking and loading bays to the detriment of local traders on Church Road, parking in the disabled parking bay on Church Road, obstruction of the shared access with neighbouring residents and resulted in large numbers of cars parked in Crystal Palace Park without permission and cars parked in surrounding residential areas resulting in loss of amenity.

Given the apparent lack of commitment  and uncertainty regarding the number, frequency and type of D2 occupiers proposed, there is no way to ensure or demonstrate that the cumulative level of activity, traffic, parking and noise will not detract from the character of the Conservation Area or cause an unacceptable increase in traffic, parking and highway safety.

KICC’s proposals will not bring new jobs and regeneration to the area whereas a cinema would 

Lack of a Business Plan – KICC have had over two years to work up their business plan and open up the building to the local community to use within its existing D2 planning use. Instead, KICC have kept the doors firmly closed to the local community since their formal opening for their members in August 2012. Why? 

Expanded Programmes are proposed for the Church Road facility which will operate alongside the Church’s use (5.14 of the Supporting Planning Statement ) – Lots of considering, proposing and anticipating but no actual plan or analysis of what is actually needed in the area or what is already being delivered in the area or already proposed via other community venues in the town centre and elsewhere in adjoining boroughs. More importantly, many of the proposed uses e.g. conferences and conventions, business seminars, political conventions etc. are also D1 uses, and would be of limited benefit and appeal to the local community and could not therefore be considered “community uses”. Crystal Palace is well served by schools which already provide ‘excellent’ educational activities for a very diverse and mixed community.  Crystal Palace also has loads of cafes. The proposed café is situated in the foyer to the main auditorium and there are no onsite catering facilities.

There is no defined need for another Place of Worship for local people – Crystal Palace and the surrounding boroughs already have many churches. And, there is certainly no need for a another church for a non-local KICC congregation at the expense of the only D2 Public entertainment venue left in Crystal Palace especially when there are lots of D1 venues available to buy in London and the South East with dedicated parking and good transport links.

The leisure and entertainment needs of the wider local community – which include BME and other under-represented groups – will be significantly reduced if KICC are granted planning permission for ‘change of use’. The religious needs of the Black and Minority Ethnicity (BME) are already met through the many existing churches and community venues in Crystal Palace and the surrounding areas.

The Statement of Community Involvement (SCI) demonstrates overwhelming demand for a cinema – The reality is that the responses received to KICC’s survey, which has been described by experts in the field as being poorly constructed and skewed to achieve a positive response, have been manipulated in the SCI and when examined more carefully do not demonstrate any convincing support for KICC’s proposals for ‘change of use’. The survey does, however, demonstrate the overwhelming demand for a cinema. Many, many residents and community groups/key stakeholders in Crystal Palace have had no communication from KICC and were not able to take part in the sham of a survey.

 

Matters raised by KICC’s Planning Consultant which are irrelevant to the application and not a material planning consideration

KICC’s Trustees have invested considerable charitable funds in the speculative purchase of a building and consequential refurbishment as an identikit of their Walthamstow Church without first obtaining the appropriate D1 planning permission which is needed to deliver their charitable activities as set out in their annual returns. This is contrary to Charity Commission Guidelines and a significant risk.

The fact that KICC has gone to considerable expense refurbishing and modernising the building is irrelevant and of no consequence to this application for change of use.

 

KICC’s planning application documents

All the information relating to the application can be found on-line by following the link below:

14/04557/FULL2 | Change of use from Bingo Hall Class D2 to mixed Class D1 (church) and Class D2 (Assembly and Leisure) use |25 Church Road Anerley London SE19 2TE

The documents below form KICC’s planning application. The most relevant documents to read are highlighted in bold and can be read and downloaded by clicking on the link.

KICC Supporting Planning Statement – the detail of the change of use application

KICC Supporting Planning Statement – Appendix 5 Bromley’s Pre-application advice

KICC Supporting Planning Statement – Appendix 6 KICC’s representations & objections to Bromley council’s emerging Local Plan Policies

KICC Statement of Community Involvement

KICC Statement of Community Involvement Annex 1 Communications materials

KICC Statement of Community Involvement Annex 2 Images

KICC Statement of Community Involvement Annex 3 Comments

KICC Transport Assessment

KICC Travel Plan and Event Management Strategy

KICC Noise Survey

KICC Entertainment Noise Assessment

25 Church Road GROUND_FLOOR_PLAN

25 Church Road BASEMENT_PLAN

25 Church Road FIRST_FLOOR_PLAN

25 Church Road SECOND_FLOOR_PLAN

25 Church Road ROOF_FLOOR_PLAN

25 Church Road FIRE_ESCAPE_OUTLINE

KICC Planning Application Form

 

 

 

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