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The OPDC Draft Local Plan – our second set of comments July 2021

The consultation undertaken by the Old Oak and Park Royal Development Corporation on its Post Submission Modified Draft Local Plan finished on July 5th. We prepared a second set of detailed representations, which were submitted to the OPDC.

The Development Corporaation now reviews all the submissions made, and prepares reponsed to these before passing them on to Planning Inspector Paul Clark. The Inspector;s final report on the Draft Plan is not expected for several months.

Our comments were summarised below in our representations. We are aware that Hammersmith & Fulham Council, the Friends of Wormwood Scrubs, Friends of Little Scrubs, and the Hammersmith Society sent in responses making many of the same points.

• We consider the consultation material, including online sessions and the sub-site set up by OPDC to be inadequate for reasons explained below. The magnitude of the changed spatial and transport elements of the Draft Plan was seriously understated by OPDC.
• Anyone reading the Table of Modifications alone might well not even notice the fundamental changes relating to Old Oak North, Scrubs Lane, Channel Gate and transport infrastructure.
• Unmodified parts of the Plan continue to make exaggerated and unevidenced claims for the ‘connectivity’ of ‘Places’ at Old Oak and the impact that the OOC rail interchange will have on the wider area of West London.
• This impact will emerge only after 2030 by which time this PSMDLP will need to have been reviewed once if not twice.
• Levels of uncertainty on funding for infrastructure remain very high. For the next 10 years until OOC station is in operation, OPDC and Mayoral ambitions for the area should be scaled back – particularly at a time of major change resulting from the pandemic.
• With a high probability of no new Overground stations and no new east-west road connection between East Acton and North Hammersmith, the whole coherence of the 19.2 version of the Draft Local Plan is undermined.
• We are not persuaded by the content of the BNP Paribas Strategic Site Allocations Viability Study (see Annex C).
• Entirely new proposals for concentrations of very high density and high rise housing are introduced as modifications to a Local Plan already 3 years into its examination stage.
• Proposals for a ‘major Old Oak town centre’ are unclear and incoherent.
• Lack of adequate new public transport improvements means that proposals at Channel Gate and Scrubs Lane will not conform with 2021 London Plan policy.
• There is no evidence that the Duty of Co-operation with neighbouring Boroughs has continued to be met since September 2018, and some evidence to the contrary.

Our full ‘Part 2’ response is too large a file to be added here as a download. But please email inf@stqw,org if you would like a copy. See also our earlier post for Part 1 of our representations.

We will continue to arge that OPDC should make a fresh start on what is a ‘modified’ Draft Local Plan which no longer sets out a coherent set of future proposals for the Old Oak area. .

Last chance to influence the OPDC Draft Local Plan

This Draft Local Plan form the Old Oak and Park Royal Development Corporation was ‘submitted for examination’ as long ago as October 2018. After a series of public hearings the following year, Planning Inspector Paul Clark issued ‘interim findings’ and ruled that the Plan’s proposals for locating new housing on the 45 acres of land owned by Cargiant were not viable.

This meant that the OPDC had to look around for new housing sites. It spent 16 months doing so and in March 2021 submitted a set of ‘modifications’ to its part examined Draft Local Plan.

Usually such modifications are relatively minor tweaks. But in this case, the changes are very substantial. Gone are plans for ‘Old Oak Park’ and an new Overground station at Hythe Road. New housing sites are being identified in East Acton (labelled by OPDC as the ‘Western Lands’) and at Scrubs Lane. The part of the plan located in Ealing now has no road connection planned with the part of the plan in North Hammersmith. These are effectively two separate Local Plans.

This is not the joined up and coherent vision for a new Old Oak that was promised back in 2015. The StQW Forum has been working closely with the Old Oak Neighbourhood Forum since 2016 in responding to OPDC proposals. The more we have looked at the details, the less convincing is this 2021 version of a Draft Local Plan. This does not feel like the best solution for regeneration of this part of London.

The timing now makes little sense. Completion of the HS2/GWR/Crossrail station is not now scheduled until sometime between 2029 and 2033. There is a decade of construction work yet to happen. The new station has a cost estimate of £1.7bn, will be 1km in length, and yet will now have no vehicle access at its eastern end. So no means of arriving at or departing from the station on this side of the Scrubs, other than via the canal towpath at Mitre Bridge. Claims that this rail interchange will be a ‘catalyst’ with a ‘transformative’ effect for our part of London no longer stack up.

In their search for further housing sites, OPDC planners have added a fifth ‘cluster’ along Scrubs Lane, at the site known as the North Pole Depot (to the north of the Mitre Bridge Industrial Estate). This is earmarked as a housing site with further tall buildings, although it is not yet clear how road access will be provided.

Our Forum has joined forces with the Old Oak Neighbourhood Forum in submitting a set of representations to Planning Inspector Paul Clark, midway through the consultation. This will be followed up with detailed comments on the ‘modifications’

We hope local residents will share our view that the OPDC’s Post Submission Modified Draft Local Plan does not meet the legal tests of ‘soundness’ and should not proceed to adoption. There is time for a different and better Plan to be prepared, taking account of all that has changed for the future of London as a result of the pandemic as well as changes in London Plan policy towards further tall buildings in the city.

The OPDC consultation remains live to July 5th. Comments can be sent to OPDC via email at localplan@opdc.london.gov.uk

Our response to RBKC proposals for St Helens Gardens

The Council at the end of April 2021 launched a consultation on a set of improvements to St Helens Gardens. These were aimed at making the street more pedestrian-friendly and safer in terms of traffic speeds. The deadline was June 15th.

We held an open Zoom session for all members on June 10th to discuss the proposals, some of which had strong support while others did not. Using Zoom polls, we were able to capture everyone’s views on the specific elements of the scheme.

Our final consultation response, including the results of the Zoom polls can be downloaded at the link below:

The strongest support was for a new Zebra crossing on St Quintin Avenue, just south of the junction with St Helens Gardens. This should slow traffic on a stretch of road where speeding has always been a problem and where the 20mph limit is widely ignored.

Other proposals were less popular or seen as not needed. We have asked for any savings from the original proposals to be diverted to renewing the paving in North Pole Road – seen as a higher priority than installing porphyry setts in the parking bays of St Helens Gardens. There was a also a majority for retaining all current parking bays in the street rather than adding a raised crossing (not a full zebra) roughly opposite the church gates.

The Council will now consider all responses to the consultation and decide which parts of the overall scheme to put in place. The works are due to place later this year,

Our responses to recent RBKC consultations on Latimer Road

The Council has been consulting in recent weeks on two consultation documents on Latimer Road. Members who took part on our AGM on 13th May discussed both of these. At the end of these discussions views on a number of questions and statements were collected via Zoom polls.

Our responses, in final draft form, can be read and downloaded at the links below. These will be submitted to the Council late on 19th May to meet the consultation deadline.

Draft Design Code for Units 1-14 Latimer Road at this link http://stqw.org/wordpress/wp-content/uploads/StQW-response-to-Latimer-Road-Design-V5.pdf

A PDF version of the slides on the Design Code, as used at our May 13th AGM can be found here http://stqw.org/wordpress/wp-content/uploads/Slides-on-Draft-Design-Code-1.pdf

Extension of the boundary of the Oxford Gardens/St Quintin Conservation Area to include sections of Latimer Road. at this link http://stqw.org/wordpress/wp-content/uploads/StQW-and-SHRA-response-on-Conservation-Area-boundary.pdf

Any final comments should be sent to sthelensassn@aol.com

Consultation on streetscape improvements in St Helens Gardens

One further RBKC consultation on stretscape and traffic safety measures in St Helens Gardens runs until June 14th. In this instance the Council has a circulated a hard copy leaflet to household shops in the immediate area, but not the whole neighbourhood.

We will hold a further Zoom session open to all members, in early June to discuss a response.

Oxford Gardens Conservation Area – proposed extensions in Latimer Road

RBKC is currently consulting on proposals to extend the boundary of the the Oxford Gardens/St Quintin Conservation Area to include certain sections of Latimer Road.

The Conservation Area was originally designated in 1975. The boundary was extended in 2002 to take in Brewster Gardens and Bracewell Road.

The consultation page on the RBKC website is at https://planningconsult.rbkc.gov.uk/OGSQCA/consultationHome

For owners of all types of property than can be perceived pros and cons as a result of location within a conservation area. For houses, there is evidence of increased values (provided that conservation policies are adequately enforced by the local authority). The downside can be increased controls and restrictions on alterations, particularly on roofs, installation of rooflights, rear dormers, frontages or parts of the property where changes are seen as causing harm to the heritage of the area.

The interrelationships between national Permitted Development Rights, Article 4 Directions (which withdraw such rights in specified streets) is complicated. Add to this conservation policies in the RBKC Local Plan and in the StQW Neighbourhood Plan and research is needed to check what rules may apply.

The StQW Neighbourhood Plan at Annex A (page 73) seeks to explain these interrelationships. But Government has changed national Permitted Development Rights since we drew up the Plan.

We have asked the Council’s conservation staff to give us a summary of the current position, on the effects of a property finding itself in a newly designated part of a Conservation Area. We hope that this will be of help to those considering how to respond to the current Latimer Road consultation. This guidance is below:

You are not able to have the large – up to 8 m deep and 4 m high – rear extensions but otherwise the normal pd rights for enlargement, improvement or other alteration apply with the exceptions of cladding of any part of the exterior of the house with stone, artificial stone, pebble dash, render, timber, plastic or tiles; where the enlarged part of the house would extend beyond a wall forming a side elevation of the original house; or where the enlarged part of the house would have more than a single storey and extend beyond the rear wall of the original house; or where any total enlargement (that is the enlarged part together with any existing enlargement of the original house to which it will be joined) would exceed 50% of the total area of the curtilage (excluding the ground area of the original house) or the height of the part of the house enlarged, improved or altered would exceed the height of the highest part of the roof of the existing house. 

It is not possible in a conservation area to take advantage of the recent changes allowing additional storeys to houses.

Normal pd rights apply relating to creation of ancillary outhouses, pools, enclosures etc. for enjoyment of the dwellinghouse, with the single restriction that in land within the curtilage of a house in a conservation area development is not permitted if any part of the building, enclosure, pool or container would be situated on land between a wall forming a side elevation of the house and the boundary of the curtilage of the house.

Normal pd rights apply in relation to the installation, alteration or replacement of a chimney, flue or soil and vent pipe on a dwellinghouse except on roof slopes fronting a highway or on the principal or side elevation of the house.  Similarly, normal pd rights apply for installing microwave antennae (satellite dishes) except on a chimney, wall or roof slope which faces onto and is visible from a highway or on a building of over 15 m high.

However, provided there is no relevant Article 4 Direction normal permitted development rights apply in conservation areas in relation to additions or alterations to roofs; erection of porches; provision of hard surfaces; Exterior painting; and provision of electrical outlets electric upstands for charging vehicles; the erection, construction, maintenance, improvement or alteration of a gate, fence, wall or other means of enclosure; and creation of a means of access to a highway.

In more general planning terms, the Council has a legal duty to preserve the character and appearance of the conservation area, meaning that the effects of any development on this will have to be given careful consideration and weight in planning decisions. 

The StQW Neighbourhood Plan gives other information on RBKC policies of which houseowners often seem unaware. It also explains which streets are covered by Article 4 Directions removing certain national Permitted Development Rights. Planning permission may be needed to change front boundary walls or install a bike and bin store of any size. Paving over front gardens with impermeable surfaces is a potential breach of planning controls. So if in doubt, best to contact the Conservation team at RBKC.

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.