Statement

STATEMENT IN OPPOSITION TO A PLANNING APPLICATION

Preface

1This statement has been prepared to rebut the planning application HGY/2009/0953
2It mirrors exactly the ìsupporting information submitted under the reference quoted above

1Description of Site and surrounding area
1.1 No Comment
1.2 No Comment
1.3 CCTV does little or nothing to ensure safety. The recordings from CCTV cameras may on occasion help to identify miscreants after an event has taken place. CCTV may deter an otherwise honest citizen from a reprehensible act, it does nothing to prevent the determined criminal, the socially maladjusted or those under the influence of drink or drugs from committing anti-social acts. It is not clear how far the external CCTV extends and what point the badly behaved become the problem of the police and the community.
1.4 The surrounding area is predominantly residential. Of 71 adjacent properties circulated by Haringey in respect of this proposal I have counted only four which do not have a  have a residential component either currently or in proposal. One is a primary school. Number 184 Tottenham Lane is the largest direct access Hostel in the London Borough of Haringey with 152 vulnerable residents. The Car Wash business is temporary until planning permission on a primarily residential development is finalised. The Texaco garage site is subject to a Site Specific Proposal which will see it revert to residential should the opportunity arise. I repeat, the surrounding area is predominantly residential. For a firm of land agents to misleadingly claim otherwise borders on the unprofessional.
1.5No comment.
1.6 No comment
1.7I am unaware of any Tottenham Road in the area. Haringey’s policy in Crouch End is profoundly anti-parking. Residents near Bar Rocca, Cheekee Monkeez and The Music Palace have reported problems with cars parked by clients of these premises.
2PLANNING HISTORY
2.1This paragraph documents an apparent change from D2 to A3 in 1988. No such change was made, nor has any such change since been granted to 159a Tottenham Lane. Ths site is not now and has never been A3. Under reference HGY/1995/1286  number 159a was refused a sui generis change of use.
2.2 No comment
2.3 No Comment
3PLANNING POLICY
3.1 No Comment
3.2 The UDP cross refers to other policies published and adopted by the borough, notably in section 6.43 of TCR 5 to licensing requirements.
3.3 (a) The nature of the proposed business will generate ì a steady flow of customers throughout the day and nightî. It is the coming and going of these customers which generates the perception of fear of crime. Appendix A pertains to the actual occurrence of crime. This perception will adversely affect the mainly female clientËle of the YMCA gym and exercise hall, immediately opposite.
CLT1 also states ìThe preferred location for new facilities is in the Borough’s metropolitan and district town centres, the Cultural Quarter and Tottenham Green. Small-scale local facilities meeting a local need will be supported in local shopping centres. ì The Music Palace is not in any town centre nor is it in a local shopping centre. The tenant of the premises, Mr Hassan has publicly stated that there is no local demand [need] for a lap dancing club. Local opposition suggests that such a facility would be unwelcome
It is true that CLT2 seeks to protect all leisure facilities, but qualifies this in 9.9 with ìmuch neededî. This facility is admitted by the tenant of the premises not to be needed.
3.4But these premises are not in the Crouch End town centre.
3.5 A ìGentleman’s Clubî is not a community facility. It appears by its title to exclude from membership women, certainly it caters for their tastes only in exceptional cases.  Appendix A attests to the degrading and unsatisfactory employment conditions to which the female employees are subjected. In what way does a ìGentleman’s Clubî enhance diversity? The introduction of a facility for which the tenant of the premises states there is no local demand will not result in an improvement.
3.6 PPS1 How is this relevant? No additional land is being brought forward. What linkage is proposed between a primary school, or a terrace of houses and a lap dancing club? It is the continued well being of the community that has been brought into question by local action groups, should this permission be granted.
3.7 The Music Palace is outside all existing centres. The presence of a ìGentleman’s Clubî will do nothing for social inclusion.
3.8 PPG4 relates primarily to the location of industry. It emphasises the need to site developments so as to minimise emissions. The location of a ìGentleman’s Clubî with no local demand, requiring a large number of private hire vehicle journeys to bring in custom, will increase emissions and runs counter to Haringey’s ìGreenest Boroughî ambitions. PPG4 admits the superiority of local plans.
A local interest of very great importance is Hornsey School for Girls. The school has produced a telling video in the form of a news item stating at some length the demonstrable harm that would be caused by the presence of such a club. Parents of pupils at Rokesly Primary school have submitted objections based on the harm they perceive from the presence of such a club near to the school.
3.9The site in question, is as previously stated in a residential area away from all town centre and shopping facilities.
3.10 As stated by the tenant of the premises, there is no demand, so consumer choice would not be enhanced.
3.11 The premises are not in a town centre.
3.12. Local response suggests that the scale and impact of this proposal are unwelcome. Lap dancing is not complementary to any other evening activity. The environment will be subject to increased noise and traffic pollution from ì a steady flow of customers throughout the day and nightî
3.13 Haringey’s Licensing Policy states that Adult Entertainment venues will not be located near to Schools, Places of Worship, Residential Accommodation, Community Centres and Youth Clubs. As previously stated, the proposed location consists mainly of such facilities. To achieve an integrated approach this planning application should be rejected.
3.14 The presence of a ìgentleman’s clubî adds nothing to the choice of those of us who are not gentlemen. The tenant that there is no quantitative need for such a facility. Local residents have stated that there is no qualitative need.
3.15 Is this consideration relevant to a business which is located outside the town centre and which claims it will only ever attract a small number of clients.
3.16 No comment
3.17. No comment
3.18 ClientËle will arrive and leave the premises by private hire vehicle, thereby increasing the number of car journeys.
3.19 Would there be a facility within the premises for the gentlemen to store their cycle clips?
3.20 A ìGentleman’s Clubî appears to exclude 50% of the population in contradiction to laws on gender equality. Various studies (see Appendix A) suggest that safety in the vicinity of such a club deteriorates dramatically, especially for women.
3.21 No physical development is proposed, and the internal layout remains unchanged.
3.22 Noise has been one of the major complaints in respect of this site during its [unauthorised?]  time as operation as a night club. It is to be noted that no change is proposed to the layout, meaning that smokers attending the club will use the pavement generating noise, litter and obstruction.
3.23 Local residents query the effectiveness of such conditions at this site based on previous experience and the newly introduced smoking laws which will give rise to frequent excursions from the club.
3.24 Local residents query the effectiveness of such conditions at this site based on previous experience.
4Development Proposals
4.1 The major part of the proposal.
4.2 An extract from the licensing application
4.3 An extract from the licensing application
4.4 An extract from the licensing application. This may improve the situation inside the club, however residents and the police will be left to deal with those under the influence of alcohol or drugs, known trouble makers and their associates.
4.5 An extract from the licensing application
4.6 This is an assertion. It implies that in total there will be a greater number of movements of individuals to and from the club. Would the management be willing to accept a condition that only a limited number (to be specified) of clients will arrive or leave in any five minute period.
4.7 This shooing away of late night custom will displace rather than remove the noise and disturbance. How robust will the encouragement be? How far will the problem be displaced?
4.8 This application is for a ìGentleman’s Clubî in Tottenham Lane, it is not an attempt to prove wither that such clubs are a good thing or a bad thing. Nevertheless the applicants have submitted a series of letters and emails purporting to be from persons in positions to speak with authority on the relationship between anti-social behaviour/crime and lap dancing clubs. This ìevidenceî is of very poor quality.
One of the so called experts, Amanda McVittie, states ìI have no experience of lap dancing clubs  . . ì, she speculates on how they might operate and refers the question to another team. No evidence is provided from this other team.
Another witness, Tom Wright, states ì . . we [ ] have not been in a position to reasonably assess the application.î He then refers to a conversation with another group (I.e. hearsay). No evidence is provided from the other group.
The evidence provided in the applicant’s Appendix 1 is anecdotal, some of it is hearsay and all of it is specific to particular dates and places.
The main body of the submission contains the statement ìThere have been no reported incidents of crime or disorder or anti-social-behaviour by staff or customers at or as a result of these clubsî. This is patently untrue ñ consider the headline ìCelebrity lap-dancing club ‘is used as a brothelî from the Independent of 3rd August 2002 http://www.independent.co.uk/news/uk/crime/celebrity-lapdancing-club-is-used-as-a-brothel-638635.html a reported incident of crime at such a club.
Or from the first of April this year ìPremiership star Djibril CissÈ arrested outside lap-dancing club after ‘grabbing woman by throatî http://www.mirror.co.uk/sport/football/2009/04/01/premiership-star-djibril-ciss-arrested-outside-lap-dancing-club-after-grabbing-woman-by-throat-115875-21243800/
Whether ultimately substantiated or not, these are certainly reports of trouble associated with such clubs.
The overall assertion made in section 4.8 is contradicted by studies carried out by the Lilith Project, Object and Glasgow City Council, of which the general conclusion is that the area around such clubs becomes a ìno go areaî for women. The Appendix to this rebuttal is not well organised, it is not rigorous in its presentation, we are responding to a planning application, not to a massive social change. However, it does contain lots of pointers that lap dancing clubs are not an unalloyed blessing, and that often they bring with them very real and substantial problems
4.9 The application is for a change to a sui generis use not presently represented in the statutory instruments. The introduction of a new exception to the existing rules surely needs a strong justification. This document rebuts what little justification has been put forward. In planning terms I would expect to see as justification some evidence that the area needs a Gentleman’s Club, in order perhaps to prevent some decline in its standing; to satisfy local demand; to fill in some gap in the social provision of the area or to augment existing provision. None of these things is suggested as justification, and none of these things is true. The application should be rejected as no case has been made for introducing a further exception too the uses set out in the statutory instruments.
It is asserted that the premises are neither nightclub nor pub and that it does not rely on binge drinking. On those occasions when the club is used a venue for corporate events or stag nights it will be both nightclub and pub and will benefit from binge drinking, to the detriment of the neighbourhood.
4.10 No comment
4.11 Would the applicants agree to conditions enforcing this level of use? It seems disingenuous to suggest that the premises will become commercially viable without an increase in custom.
4.12 The applicant re-asserts the entirely inaccurate and unjustified assessment that the area is commercial.
The bus routes seem almost entirely irrelevant to clients paying ?8 admission, as does a long walk to a railway station
5 SUMMARY
5.1 The purpose of this application is to substantially increase the the levels of business at the Music Palace to the point where it is viable as a ìGentleman’s Clubî. It is disingenuous to propose that this increase in business will not be accompanied by a proportionate increase in comings and goings, whether over time or en masse. This is not acceptable in a primarily residential / educational / religious area outside a town centre.
5.2 A ìGentleman’s Clubî would contribute nothing to the vitality and viability of the Crouch End District Centre, which visibly and practically ends at  Rosebery Road and Rez the Barber. The tenant has publicly stated that custom would be sought from outside the area.
5.3 This proposal is wholly inconsistent with Haringeyís Sustainable Communities Plan. The council, in its Community Strategy for 2007-2016, makes a commitment to ëprovide support and protection to the most vulnerable people in our community .. [and to ] safeguard children and adults from abuse and neglect wherever possibleí. The plan places ëpeople at the heart of changeí and purports to be ëpeople and customer focusedí. The facts are that children at the nearby schools  have a right not to be exposed to sexually aroused men entering or leaving these premises. This is an abuse of their innocence (not to mention their safety in the case of older, teenage girls) and their right to a childhood untouched by the sex industry. In addition local people do not want this and most of the people visiting and working in the club are likely to come from outside the area, outside Haringey even. It aims for a community that is ësafer for allí ñ we know that lap dancing clubs increase sexual crime and increase fear of crime in women ñ and which promotes ëhealthier people with a better quality of lifeí ñ being involved in the sex industry is hardly a healthy career choice, either in terms of a womanís physical or mental health, or her self-esteem. Lapdancing clubs by their very nature objectify and demean women and situating one in a residential area and opposite a school will only normalise the idea that this is acceptable. We should not be telling our schoolchildren ñ who are taught about respect for others and the equality of the sexes while in school ñ that taking your clothes off for money is an acceptable and respectable career choice for girls.