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OPDC’s proposed ‘modifications’ to its Draft Local Plan

Back in November 2019, the Old Oak ad Park Royal Development Corporation announced a ‘change of direction’ and a ‘new focus’ for its much delayed Local Plan.

An interim report from Planning Inspector Paul Clark had ended the Development Corporation’s aspirations for a new town centre and 6,000 new homes, to be built on the 46 acres of land owned by Cargiant at Hythe Road. Cargiant had decided to stay put and expand its business on its existing site. The planning inspector concluded that attempts by OPDC to compulsory purchase the land it needed were financially unviable.

This meant further delays on a Draft Local Plan, then already three years behind schedule. An original timetable of Local Plan adoption in Spring 2017 has now slipped 4.5 years to Autumn 2021 with this date far from certain.

During 2020, the OPDC planners have been working up an alternative strategy and a set of ‘modifications’ to the existing Draft Local Plan. This involves a shift of focus away from Hythe Road and towards East Acton. OPDC has christened this area the ‘Western Lands’. Two large sites at Atlas Road and Channel Gate on Victoria Road/Old Oak Lane are planned as the location for a ‘major new town centre’ along with 3,000 new homes.

For our StQW neighbourhood, the abandonment of plans for ‘Old Oak Park’ on the Cargiant land has removed the risks of steadily increased traffic congestion on Scrubs Lane and Wood Lane. But OPDC remain determined to meet their long-term housing target of 24,500 housing units at Old Oak, with nearly 14,000 of these to be delivered in the first ten years of their Local Plan. Hence the hunt has been on to identify extra housing sites that can be brought forward to make up the gap created by the loss of the Cargiant land.

Three sites along Scrubs Lane, owned by Cargiant but separate from their main operations, have been added to OPDC’s revised plans. These are shown above and are destined to be developed for a total of 600 housing units. On the site of the existing Cumberland House, an ‘additional single tall building’ will be allowed under the Local Plan.

In 2017/18 the OPDC Planning Committee granted planning consent to three other tall buildings along Scrubs Lane, at 2 Scrubs Lane, ‘Mitre Yard’, and ‘North Kensington Gate’. The latter two sites have City & Docklands as the developer. These residential towers are all planned to be above 20 storeys. The site at Mitre Yard has been cleared for construction, while City & Docklands are in the process of seeking permission for an extra 40 housing units at North Kensington Gate (South).

As a location very very high density residential towers, Scrubs Lane now makes little or no sense in planning terms. There will be no new town centre next door at Old Oak Park. There will be no new Overground station at Hythe Road, as once promised in the OPDC Local Plan. Access to public transport is very poor, with a 15 minute walk to Willesden Junction. Shops, GP surgeries and other basic amenities are lacking. So there must now be some doubt whether developers will build out these schemes, in a very uncertain London property market.

The StQW Forum continues to submit objections to the latest application at North Kensington Gate South and our latest letter can be found here

A large site on which OPDC now intends to ‘accelerate’ development is the eastern part of the North Pole Rail Depot at Mitre Bridge on Scrubs Lane. Railway use of this land dates back to the 19th century and the depot has housed rolling stock from Eurostar and now Great Western Railways (GWR). The land is owned by the Department of Transport.

This site was previously planned to come forward for development in later phases of the Old Oak Local Plan. It is not yet clear exactly when the site will be available for redevelopment, to accommodate a proposed 600 new homes. The diagram above (from November 2019 OPDC consultation sessions) also appears to show the Mitre Industrial Estate as allocated for ‘residential-led development’ in due course.

Road access to the Depot site is currently limited to a access track running alongside the rail lines from Ladbroke Grove. The above diagram shows a new road link to Scrubs Lane (in a broken purple line) which the key explains will not be in place for ’21+ years’. A new tunnel beneath the West London Line would be needed.

A proposed ‘Wormwood Scrubs Street’ would connect eastwards to the Kensal Canalside Opportunity Area in RBKC. But if this and the existing Mitre Way are to be the only vehicle access routes to the North Pole Depot site, these proposed 600 new homes will remain isolated and distant from the local road network.

New development at this site is likely to impact severely on views from Little Wormwood Scrubs. OPDC are always very coy about housing densities and building heights when proposing site allocations in their Draft Local Plan. But from past experience these densities will prove to be at 500-600 units per hectare (commonly termed a ‘super-density’ or ‘hyper-density’). This is double the level at which RBKC works to, when undertaking estate renewal schemes such as Wornington Phases 1-3 north of Golborne Road.

The OPDC treats its 24,500 housing target as an unalterable fixture, despite the fact that this figure was largely plucked out of the air to be included in the 2016 London Plan. The New London Plan, now finally adopted, retains this figure. But there is growing demand across London for Opportunity Area housing targets to be re-examined.

Secretary of State Robert Jenrick has intervened, in the final stages of preparation of the New London Plan, to require tall buildings to be limited to locations identified in Local Plans and to encourage ‘gentle densification’ of existing neighbourhoods. The OPDC Draft Local Plan has a way to go before its adoption, including a further set of examination hearings during 2021.

The StQW Forum, the Old Oak Neighbourhood Forum, and other local groups will be making our voices heard at these examination sessions. Londoners are all too well aware that Covid, high rise towers reliant on lifts, and lack access to any private open space, are not a good combination.

Kensington and Chelsea Council starts on a new Local Plan

The Council has been carrying out an initial consultation on a new Local Plan for the Borough.  It was only last year that the current 2019 Local Plan was formally adopted, but the Planning Inspector involved was willing to endorse this version only if the Council committed to make an early start on a new Plan.  This was because RBKC changed its plans for delivering new housing and following the Grenfell fire dropped a series of half completed plans for ‘estate renewal’ of the Silchester Estate and others..

Starting on a new Local Plan is made more complicated by the fact that the Government published proposals in August, for a radical rethink of the English planning system.  See our earlier post. There has been significant push back to this White Paper The Future of Planning from local councils of all political persuasions. For London, the idea that all land can be ‘zoned’ in Local Plans and subsequent stages of planning permission simplified and streamlined is viewed with scepticism.

It is early days yet to know how far these new proposals will pursued by a Government with many other problems on its plate.  Meanwhile the RBKC consultation on changes that it should introduce in its own Local Plan is open until November 10th.  See the New Local Plan section of the RBKC website.  

The StQW/SHRA management committee has put together a draft response, to send into the Council. We think that the ‘Issues’ document published by the Council is clear and helpful. It includes a series of questions and we have responded to these with our views. A draft of our response can be downloaded below:

We would welcome further views from StQW and St Helens Residents Association members. Please send these to info@stqw.org or to sthelensassn@aol.com. We will be sending in a final response on November 10th.

Our response to the White Paper on Planning for the Future

The Government’s proposals for ‘radical reform’ of the Planning system in England were published in August 2020. These involve a new approach to Local Plans as prepared by local planning authorities.

The Government’s stated aim is to streamline and simplify the preparation and adoption of Local Plans (which under present arrangements can take 3-4 years). Under the proposed new system Local Plans would categorise all land within their area under three ‘zones’ of ‘Growth’, ‘Renewal’ and ‘Protected’ (such as Conservation Areas).

A national set of generic development management policies would be introduced to replace much of the detailed policy set out in Local Plans.

The White Paper says that neighbourhood plans should be retained under a new planning system. But the document is wholly unclear what scope would remain for these ‘community-led’ plans. While there are only 19 neighbourhood plans in London which have been adopted as part of the development plan for their area, there are now over 2,000 in place and used daily by planning authorities across England.

With our experience of having a neighbourhood plan in force, with its policies tailored to our part of the Borough, we think it would be a serious backward step for such plans to have their scope reduced in the future.

The site allocations in the 2018 StQW Plan are now strongly supported by RB Kensington and Chelsea. The three Local Green Spaces designated as part of the Plan remain as importnat to us as when first propose din 2015.

The Government’s White Paper can be downloaded here

We have submitted a response from the StQW Forum. This argues the case for neighbourhood plans to retain their present scope and powers. A copy can be downloaded as a PDF below

Latimer Road ‘design code’ makes progress

As a result of huge opposition by residents of Latimer Road in response to a planning application for a 6 storey mixed use redevelopment on the site of Unit 10, the Council has agreed to accelerate work on preparing a ‘design code’ for the section of the street. Units 1 – 14 are light industrial/warehouse buildings, built in the 1980s.

A design code, in the form of a Supplementary Planning Document (SPD), can set parameters for new buildings. These guidelines can cover building heights, site coverage, daylight/sunlight impact on neighbours, a recommended palette of materials to be used, and other aspects of building design.

RBKC has set up a project team led by Daniel Massey, who also heads the team of Council planning officers working on regeneration of the Kensal Gasworks site.

Residents in the street have organised themselves into a new group which is now involved in discussions with this RBKC team. So too are members of the StQW Neighbourhood Forum management committee.

A series of planning policies for the street are set down in the StQW Neighbourhood Plan. These now form part of the statutory development plan for the Borough. They include a policy on heights of new buildings. The Council has made clear that approval to the application at Unit 10, in its current form (see earlier post) is now very unlikely.

The working group is looking at the potential impact of buildings with 3 or 4 storeys fronting onto the street, with scope for one or more further floors set back so as not to be visible by pedestrians on the opposite pavement.

A further option would be ‘staggered’ building heights with taller buildings at the southern end of the street (where the Imperial buildings block out the western skyline).

It would be good to have views from local residents on these and other design issues. Are modern buildings preferred? The RBKC planning team has identified some ‘precedents’ of smallish mixed used buildings in London, such as that below.

Or do residents prefer more traditional designs for Latimer Road such as for the redevelopment at Unit 1? (granted planning consent in early 2019. Image below is a CGI)

The RBKC/StQW/Latimer residents working group will be holding a couple of further meetings before widening out informal local consultation. There will be a 6 week statutory public consultation in late autumn before any Supplementary Planning Document is finalised and adopted by the Council.

The Government’s proposed planning reforms include the wider use of design codes, and talks about these being agreed with local communities at ‘street level’. So it will be interesting to see how this initiative at Latimer Road works out. Will it prove possible to achieve any consensus between residents. planning officers, and all parties involved – including existing and any new building owners in the street.

The bids we have submitted to RBKC for NCIL funding

The Coumcil opened a bidding round this summer for projects to be funded from the neighbourhood element of the Community Infrastructure Levy.

RBKC has been collecting in ‘developer contributions’ since 2015. The Coummunity Insfrastructure Levy is a form of tax on new development. levid by local planning authorities. The ‘neighbourhood’ element of CIL is intended to be used in consultation with local residents. Normally this sum is 15% of the total collected.

In areas where a neighbourhood plan has been prepared and adopted by the local authority, this proportion rises to 25%. This measure was introduced by the Government as an incentive to encourage neighbourhood planning.

The Council has set an allocation of £30,000 for the StQW neighbourhood area. There are separate allocations of £39K for those parts of St Helens and Dalgarno wards that lie outside the StQW neighbourhood boundary.

We have submitted funding applications for two projects:

  • installation of two CCTV cameras in North Pole Road, to be added to the RBBKC system to monitor and reduce public concern over anti-social behaviour and crime in the street.
  • measures to improve air quality at the St Quintin Gardens. Barlby Road. Highlever Road ‘triangle’ and mitigate the impact of daily traffic congestion at the North Pole Road ‘pinchpoint’.

The applications can be downloaded above and give more details of these proposal, both of which will need to be worked up in more detail with council officers.

Our objection letter on the application at Unit 10 Latimer Road

The planning application for a six storey office and residential development to replace Unit 10 Latimer Road has drawn strong opposition from many of those who live in the street.

A copy of the letter of objection submitted by the StQW Forum and St Helens Residents Association can be downloaded below. The Forum and our Neighbourhood Plan support the principle of mixed use development in Latimer Road. But any proposals need to pay heed to the specific planning policies for the street, on building heights and other issues.

These StQW policies were discussed and agreed locally in 2015, when the neighbourhood plan was prepared.

This application fails to take account of these policies and we are asking the Council to refuse it.

CGI of proposed office and residential development on the site of Unit 10, Latimer Road

RBKC proposals for Low Traffic Neighbourhood

The Council has responded to new guidance from the Secretary of State for Transport to test out new traffic to encourage more cycling and pedestrian movement and few cars on London’s streets.

Most of the publicity locally has been on further vehicle limits in Portobello Road and a pop up cycle way in Kensington High Street.  But amongst the package of measures is a proposal for a Low Traffic Neighbourhood in parts of St Helens and Dalgarno wards.

The impact of this scheme would be dramatic, and it will no doubt have supporters and objectors.  The Council says The instruction from the Government is that councils must introduce changes likes these quickly, which does not allow time for the level of consultation that we would normally like to do. We would implement this scheme on an experimental basis. We would consult on whether to keep, modify or remove the scheme, within six months. The barriers and cameras could be removed, or relocated, easily and quickly if required.

The Council wants responses by 26th June and have asked for feedback from ward councillors, St Helens Residents Association and from BetterStreets4RBKC.  There is no consultation web page on the Council website so comments (of which there will no doubt be many can be sent to sthelensassn@aol.com and these will be collated and forwarded on.  And/or you can send comments to ward councillors.

We discussed very briefly the idea of Low Traffic Neighbourhoods at our March 12th meeting.  There are examples in several Boroughs.  But we had no idea then that events would move so fast.

If you ever want to see what life in the neighbourhood like with measures that could solve the daily traffic queues to exit North Pole Road, now is your chance.  We need to give our views on the realism of these proposals and where traffic may divert to and create new problems.

The full version of the proposal can be downloaded below. 

Planning application for Unit 10 Latimer Road

An application has been submitted to RBKC for a 6 storey redevelopment of the present light industrial building at Unit 10 Latimer Road.  

Many Latimer Road residents are very opposed to this proposal and have formed a group to fight the application. 

The applicants have submitted a Planning Statement which addresses RBKC Local Plan policies but have made no attempt to explain how their proposal conforms with the detailed StQW policies for the street.  The StQW Forum/SHRA will be objecting to the application on various grounds, including the height.

The closing date for comments on the application is July 10th and it can be found at s https://www.rbkc.gov.uk/planning/searches/details.aspx?adv=0&simple=latimer+road&simpleBatch=20&simSubmit=Search&id=PP/20/03048&cn=257479+Salisbury+Jones+Planning+33+Bassein+Park+Road+London+&type=application&tab=tabs-planning-1

A note can be downloaded below which explains to those who are not members of the StQW Neighbourhood Forum the background to the preparation of the StQW Neighbouhrood Plan. This note includes the details of the StQW policies for Latimer Road. These policies now form part of the development plan for the Borough and will be taken into account in the decision on this application,

A second tower in Wood Lane?

Back in October 2019 our open meeting at St Helens Church hall looked at a slide image of a proposed new tower in Wood Lane, opposite the 35 storey ‘Imperial Folly’. Plans for this development have come from the Womens Pioneer Housing Association in partnership with property company HUB.

The subsequent planning applications has yet to be decided by Hammersmith & Fulham Council. Meanwhile a new residents association on the Ducane Estate has submitted an objection with 40 points ranging from the impact on local traffic, to the wind tunnel effects of very tall buildings.

It was always a concern that the decision of LBHF to grant planning approval to the Imperial tower would be followed by other proposals for very tall buildings. In this case, the planned development is for 80 flats (for existing Womens Pioneer residents) and 350 ‘co-living’ units aimed mainly at the 25-30 year old generation.

CGI of proposed development at 227 Wood Lane

Womens Pioneer are an admirable housing association, but is this the right sort of building at the right location? And are very tall buildings, with some communal amenities inserted on several of the upper floors, a suitable form of ‘co-living’ accommodation?

The experience of Londoners stuck in in blocks of high rise flats for the last two months of lockdown has re-opened debate about the pros and cons of tall residential towers in London. This type of building is expensive to construct and maintain.

After the high rise flats built by councils in the 1960s, there were a couple of decades when few were built, following the Ronan Point collapse in 1968. The Grenfell fire has led to what the Government promises will be a major overhaul on building regulations and fire risk in residential towers.

The Collective building in Old Oak Lane is proving a successful example of co-living. But its communal areas and bar/restaurant are on the ground floor, and used by locals as well as residents. And the building is 9 storeys high rather than 39. Co-living residents are often both young and on short tenancies, and not always the first group to familiarise themselves with fire escape procedures in a single staircase tower block.

The StQW Forum has submitted a letter of objection to the application, which can be downloaded here http://stqw.org/wordpress/wp-content/uploads/StQW-representation.-final-1.pdf. Our main objection is that tall buildings are supposed to be resisted by policies in the Hammersmith & Fulham Local Plan, other than in designated regeneration areas such as White City. The Imperial tower is within the White City regeneration area but the site at 227 Wood Lane falls outside this boundary. If the Council finds a 29 storey building acceptable here, why not on e.g. the site of the Pavilion pub?

Not one of the series of tower developments granted planning consent by the Old Oak and Park Royal Development Corporation along Scrubs Lane has yet started on site. In two cases, the developer (City & Dockland) have have plans to vary and ‘optimise’ the existing planning consents by adding a further 40 housing units to each scheme. But this developer may now be having a rethink in light of the impact of Covid 19 on London’s property market.

The tall building boom in London over the last two decades may be coming to an end as patters of working, living, and commuting undergo a major transition as one aspect of a ‘new normal’..

OPDC abandons plans for Cargiant land at Old Oak North

In a sudden and unexpected turn of events, a press release from the OPDC On December 13th announced that the Corporation was halting its plans to assemble land at Old Oak North.

This brings to an end the legal tussle between the OPDC and Cargiant Ltd.  In early 2019 Cargiant dropped its own plans for housing development (badged as ‘Old Oak Park’ and decided to remain as a business on its    existing 45 acre site. 

Despite this decisions, the OPDC chose to progress its own ‘masterplan’ for Old Oak North, making use of its powers of compulsory purchase to acquire tracts of Cargiant land.

10 months later, OPDC has recognised that its land assembly proposals were unworkable. 

The OPDC Board has not met since September 26th 2019 and is not meeting again until January 30th 2020 (a four month gap).  So there has been no report or Board discussion that explains the consequences of this major change of direction by the Corporation. 

OONF and the StQW Forum has sent the OPDC a list of questions.

We will be ensuring that members of the London Assembly Budget and Performance Committee see a copy of our questions before they meet in early January to scrutinise the OPDC Budget submission for 2020/21.    While the OPDC is scaling back its budget for next year, the fact remains that much public money has already been spent on preparing a Local Plan which now has to be substantially revised, along with consultancy costs on site assembly which is now wasted.

We will post more news as it becomes available.