The Mayor of London has been consulting on the proposed new London Plan. This will replace the current version, which was prepared and subsequently updated during the Boris Johnson Mayoralty.
The new version includes many good policies, but has a strong focus on ‘intensification’ of development across London and especially in Opportunity Areas. It sticks to the 2012 target of 24,500 new homes on land at Old Oak. This target has become increasingly unrealistic, as major infrastructure obstacles surface in relation to OPDC proposals for ‘Old Oak South’ (the area around the planned HS2 station).
The new London Plan says even less than the current version about neighbourhood planning. It repeats familiar Mayoral statements about the needs to involve Londoners in the planning process, while ignoring the one route that Parliament has introduced to enable local people to have any real influence on Local Plans.
OPDC planning officers (Tom Cardis and Peter Farnham) gave an update on what the Development Corporation has been doing, at a session in Harlesden on February 8th. There was some important news, summarised below:
On the Draft Local Plan
There were 119 responses to the OPDC consultation last summer, on the Draft Local Plan. Following the efforts of OONF to see these responses published (see previous post ) a schedule of all responses has been made available at this link on the OPDC website.
A number of the key responses, including from HS2, Transport for London, and the Mayor of London, set out major concerns with the Regulation 19 Draft Plan. A range of draft OPDC policies are considered not to be ‘sound’ and to require revision before a final Draft Plan is submitted to the Secretary of State. (The full response letters from HS2, the Mayor and TfL were published via links in our January post)
OPDC planning officers are continuing to amend the Draft Local Plan. The extent of changes and revisions means that it is likely (but not definite) that there will need to be a further round of public consultation on ‘major modifications’ to the 2017 version. This consultation will probably happen in mid 2018, with submission to the Secretary of State in the autumn.
This delay will give the OPDC longer to take account of new policies proposed in the new Draft London Plan, currently out to public consultation until March 2nd 2018.
Among the responses submitted last summer, there are a number from landowners and developers, promoting particular approaches and policies for specific sites. These include detailed proposals from Raban Goodhall for a mixed use development immediately north of Goodhall Street (in the TITRA area and within the boundary of the designated Old Oak Neighbourhood Area).
Responses submitted last September from the Grand Union Alliance, Hammersmith Society, OONF, Harlesden Neighbourhood Forum and many individual residents are detailed, well argued, and take a broadly consistent line. It will be very hard for OPDC to ignore these comments.
It is already clear that major revisions are being made to the Regulation 19 Draft Plan as a result of views expressed by local people, as well as by major stakeholders such as HS2 and Transport for London. Significant changes include:
Recognition that plans for Old Oak South (the areas around the proposed HS2/Queen Elizabeth Line interchange) remain highly uncertain at present. While the prospect of ‘overdecking’ the main station ‘remains on the table’, HS2 make very clear in their own response that their remit is to construct a rail station with natural ventilation.
No funding is yet committed for decking over the rail interchange or providing artificial ventilation to the rail interchange below.
Hence the ‘vision’ of very high density 40-60 storey towers at the heart of a new Old Oak (i.e. a Canary Wharf of the West as shown in the Boris Johnson 2015 OPDC Opportunity Area Planning Framework) is by no means a certainty.
Old Oak North (the Cargiant/London Regional Property site) remains the area identified for early development (i.e. the next 10 years). Scrubs Lane and Victoria Road likewise.
Transport for London have asked that the proposed two new Overground Stations, at Hythe Road and at Old Oak Common Lane, be referred to as ‘potential’ new stations. No funding source has yet been identified for these projects.
Less emphasis is being placed on the proposed ‘Old Oak High Street’ because of the very high infrastructure costs of bridging rail lines and the Grand Union Canal.
The next version of the Local Plan will be more explicit about housing densities, the location of tall buildings, and what OPDC define as a ‘tall building’ (the absence of such information in the Regulation 19 Draft was one of the main complaints of OONF and other respondents).
On affordable housing, the next version of the Local Plan will take into account the Mayor’s ‘threshold’ of 35% affordable housing, for schemes where developers wish to avoid submission of detailed financial viability assessments.
OPDC are looking to achieve 25% ‘family homes’ (i.e. 3 bed plus) with a split of 30% social housing and 70% intermediate housing tenure.
The existing West London Waste Plan and present locations of major waste sites in the Old Oak area are a further complication.
The Old Oak masterplan
A masterplan for the Old Oak part of the OPDC area is being prepared by the consortium led by AECOM. The clients for this work are a separate department of the OPDC, acting as a developer of the large swathes of public land involved.
Little information about this masterplan is yet in the public domain. Some form of public engagement process is expected in early summer.
A key document emerging from this masterplanning exercise will be an updated Development Capacity study for. This will test the realism of the 24,500 housing target set for Old Oak. The adequacy of the existing evidence base for this target (which dates from the 2015 Further Alterations to the London Plan) was a question picked up strongly in responses from OONF and others to the Regulation 19 Draft Plan.
The new London Plan sets an increased annual housing target for the OPDC area, from 1,100 units per annum to 1,360 units. Whether this proves at all realistic will depend on future (and uncertain) demand within the London housing market and the rate at which major developers such as Cargiant/London & Regional, and QPR/Genesis, choose to build out their schemes.
Opportunities for future community engagement
The Great Place Scheme involves a widening group of local organisations and individuals. OPDC has been awarded almost £1.5 million of funding from the Heritage Lottery Fund, which will be used to enhance the role that arts, culture and heritage plays in the future of the area.
A Local Heritage Listings consultation runs until 22nd March, giving people an opportunity to identify buildings for local listing. Listings do not benefit from statutory protection from demolition but they do assist OPDC in identifying non-designated heritage assets. This ensures that the conservation of a non-designated asset is a material consideration in determining planning applications.
OPDC will be setting up a Community Design Review Group, which will involve local people in providing input on proposed developments, alongside the existing Place Review Group managed by CABE. No details are yet available on how this new group will be formed.
Public consultation on the Regulation 19 OPDC Local Plan ended last September. Since then news has emerged that the timetable for publication of a final version of the Draft Plan (for submission to the Secretary of State) has slipped to May/June 2018.
OPDC has not so far published the responses to its consultation last summer. Given this delay, we asked to see those responses which had been submitted by the main statutory agencies involved, and by landowners and developers. Otherwise it would have been nearly a year before local people could know how these various bodies had responded to the proposals that OPDC published in June 2017.
Copies of the responses as provided to us can be downloaded from the links below. These documents were submitted as part of a public consultation exercise, so are in the public domain. They demonstrate that there are several aspects of the OPDC Draft Local Plan which will need a rethink, particularly around the proposed HS2 station in ‘Old Oak South’ .
There were 119 responses in all to the OPDC Regulation 19 Local Plan consultation. These includes responses from community groups (including this forum), amenity societies, and individuals. A report to the OPDC Board in November 2017 gives a summary of the issues raised, and a link to this report is in the list below.
One important response is not yet available. This is from Cargiant/London & Regional Properties. We understand that their original response included some errors which are being revised.
The locations of these proposed new stations were consulted on back in 2014, in the early days of plans for Old Oak. The stations are intended to provide an interchange for passengers between the HS2/Queen Elizabeth Line (Crossrail) station at Old Oak Common and the London Overground network.
This interchange will be less than ideal, as neither Overground station will be adjacent to the main station (the Hythe Road station will involve a 700m walk between the two). The business case for each station is still being developed and there is as yet no certainty on sources of funding.
The proposals for the Old Oak Common Lane station are not going down well with residents in the immediate vicinity. The ‘visualisations’ suggest a 4 storey office block at the top of Midland Terrace and an elevated pedestrian/cycle bridge across to Victoria Road. The impact on neighbouring houses would be huge.
The preferred option for a Hythe Road station involves a new station and railway viaduct to the north of the existing embankment. The existing embankment would be removed, opening up access between the north and southern parts of Cargiant’s 43 acres – destined to become ‘Old Oak Park’ with 6,500 new homes.
The Old Oak Interim Neighbourhood Forum will be submitting a response to the consultation. Please email email@example.com if you would like your views reflected in the Forum’s response.
In the run up to the September 2017 decisions made by the OPDC Planning Committee, OPDC Board, and Hammersmith & Fulham Cabinet, we tried to make decision-makers aware that they were ignoring Government guidance on neighbourhood planning, as well as the very clear outcome of the public consultation on our proposals for an extensive Old Oak neighbourhood area.
Concerns over the Hammersmith & Fulham Council decisions
Our letter to members of the Hammersmith & Fulham Cabinet can be read here OONF letter to LBHF Cabinet.V4. This includes a detailed annexe setting out why we think that the decisions recommended by officers were unjustified. The inaccurate information about responses from the Old Oak Friends and Residents Association is a particular concern.
Unlike other London Boroughs, Hammersmith & Fulham still does not seem to understand the basics of neighbourhood planning. As on a previous occasion in 2012, the Council’s response has been one of minimal compliance with the 2011 Localism Act by designating a much smaller area than that proposed, and one that nobody has applied for.
In designating a separate neighbourhood area, the Council has also frustrated the expressed wishes of those respondents to the consultation who wished to see Wormwood Scrubs, the Old Oak Estate, the Linford Christie Stadium, Woodman Mews, Scrubs Lane and College Park as part of a coherent wider neighbourhood area.
Concerns over the OPDC decisions
OPDC officers have devoted an enormous amount of time and energy in finding reasons to justify removing 89% of the 280 hectare neighbourhood area originally proposed in the OONF designation application. This was after 18 months of discussion on the proposed boundary.
A letter was sent to OPDC Board members from the St Quintin and Woodlands Neighbourhood Forum, prior to the Board’s final decision on September 12th. A copy can be read here StQW to OPDC on OONF designation. Sept 2017.
The principle applied by OPDC officers, that parts of a neighbourhood area have to show uniform or consistent characteristics to be ‘appropriate’ for designation, is entirely novel. Nowhere else across England has this approach been applied, in the 2,000 or so neighbourhood areas designated to date.
London already has several neighbourhood areas as large as the 280 hectares proposed at Old Oak, and ones that include brownfield land, railway infrastructure, Opportunity Areas, open spaces of London-wide significance, and other features which OPDC officers seem to think should be classed as ‘diverse character areas’ and hence ‘inappropriate’ for inclusion as part of a single designated neighbourhood.
The attitude of both these local planning authorities is proving to be very defensive and negative. Significant and sustained efforts by local residents to contribute to the planning of a future Old Oak have been rebuffed.
Both bodies are offering meetings to discuss alternative forms of ‘dialogue’ and ‘engagement’. But this is not the same thing as granting local people what is now a widely accepted and meaningful role in the planning process, through preparation of a neighbourhood plan.
Parliament introduced neighbourhood plans in 2011 as ‘powerful tools’ for local communities to influence what sort of development takes place in their area (within clearly defined limits). The OPDC and Hammersmith & Fulham Council appear to have taken fright at this prospect. This does not bode well for creating a successful and sustainable new part of London.
The planning application for the development pictured below is due to be considered by the OPDC Planning Committee on 12th July 2017. The scheme is at 104-8 Scrubs lane, opposite the recently approved developments at ‘North Kensington Gate.
Hammersmith & Fulham Council’s Planning and Development Control Committee considered the application at its meeting on June 12th. The committee agreed with officer advice that the proposed scheme is premature, and should await future decisions on a new road layout for Scrubs Lane.
The site is bisected by the private access road to the EMR and Powerday waste sites. Many HGV waste vehicles enter and exit this road every day, often queuing up in Scrubs Lane to do so and bringing traffic in both directions to a halt. It is hard to see how a development of apartments at this location could be successful until an alternative access road is built. EMR do not see this happening anytime soon.
The second of the two ‘observations’ from Hammersmith & Fulham Council is that the proposed affordable housing offer is not acceptable. The developers are proposing flats at ‘discounted market rent’, an option which many London councils see as unaffordable to residents on median incomes.
Although the developers have improved their offer in latest negotiations with OPDC planners, LBHF councillors still see it as inadequate and are looking for flats at London Living Rent to be part of the S106 package.
The OPDC has published the independent advice its has received from BNP Paribas, on the financial viability of the proposed scheme. Such transparency is welcome, and reflects the Mayor of London’s policy of greater openness on financial viability assessments.
Anyone interested in the ‘dark arts’ of how developers and their consultants use financial viability assessments, and the data that goes into them, to minimise the level of affordable housing that a scheme can support will find this document and informative read. See at Mitre Yard BNP Paribas.
Scrubs Lane (the A219 north south route on the eastern border of the OPDC area) is seeing a wave of development proposals.
Planning approval granted to the scheme at North Kensington Gate (South site) was swiftly followed by a decision of the OPDC Planning Committee to grant permission to Aurora Development’s second application on its northern site at 115-129a Scrubs Lane.
This scheme involves a 22 storey tower, with 164 housing units above ground floor commercial space. Give that this is the first building of anything like this height within the surrounding area, the application proved very contentious.
Strong objections were submitted by Historic England, RB Kensington & Chelsea, and LB Hammersmith & Fulham. There were 39 objections from local residents. Neighbouring waste contractors European Metal Recycling pointed out that they are not intending to move their own operations anytime soon.
The density of residential development on the site (448 housing units per hectare) is in excess of London Plan standards even for sites with the highest levels of public transport accessibility. ‘North Kensington Gate’ has very poor transport links. This will remain the case until the HS2 terminal and a (possible) Hythe Road Overground station open, scheduled but not certain for 2026.
The vote at the OPDC Planning Committee was close, with the three independent members of the committee and its non-elected chair outvoting three of the four local councillors on the committee.
This decision was followed by submission of a planning application for a further residential development at ‘Mitre Yard’. The developers are the City and Docklands Property Group. This involves two sites across the road from North Kensington Gate.
The sites are separated by the private access road to the EMR and Powerday waste sites. This road is used by large numbers of HGVs and already creates daily traffic jams in Scrubs Lane as these vehicles enter and leave the site. EMR has again objected strongly to the application.
The proposed development is for 200 housing units above ground floor commercial space. The affordable element of the development, in the application, is for 35% of the units to be at ‘discounted market rent’.
The discount proposed is the minimum 20% of market rent. This qualifies (just) as ‘affordable housing’ in terms of current London Mayoral housing policies. But in reality the building of such flats will open up viable housing opportunities for few if any of the existing low income residents in the area.
It is understood that the application will be considered by the OPDC Planning Committee on July 12th 2017.
If this application is approved, and this development constructed, the view looking south along Scrubs Lane will be as above. In the first draft OPD Local Plan, this location was described as a ‘sensitive edge’ of the OPDC area, suitable for low and medium rise buildings and adjacent to two conservation areas. The latest Regulation 19 Draft Local Plan introduces the concept of four ‘clusters’ along Scrubs Lane, each to be allowed one tall building.
An application for a third proposed tower at 2 Scrubs Lane looks likely to surface shortly.
At the meeting of the OPDC Planning Committee on March 1st, approval was granted to the planning application for the proposals from Aurora Developments for the northern of its two sites in Scrubs Lane NW10. The address is 93-97 Scrubs Lane, overlooking St Marys Cemetery
The site is shown below, along with a CGI image of the completed building. The development includes 47 new housing units in two blocks (11 and 4 storey) with some commercial space on the ground floor.
The St Helens Residents Association spoke at the committee to object to the scheme on several grounds:
the density of 440 housing units per hectare is way in excess of London Plan policies for a site with very poor public transport accessibility
future planned improvements to public transport (the proposed Overground station at Hythe Road and Crossrail) are 10 years away and should not be used as justification for approval in 2017.
the plans take no account of traffic congestion in Scrubs Lane, arising from waste vehicles entering and leaving the private road to the EMR and Powerday waste sites.
The planning committee at Hammersmith and Fulham has not yet discussed this planning application, nor the even more controversial proposals from Aurora for a 22 storey residential tower at 115-129A Scrubs Lane (see earlier post).
The application was approved with only Hammersmith & Fulham councillor Natalia Perez voting against. Further applications for Aurora’s southern site, 2 Scrubs Lane, and ‘Mitre Yard’ (all on Scrubs Lane) look like coming before the committee in the next few months.
Meanwhile the daily reality of Scrubs Lane remains one of traffic queues, little pedestrian footfall, and a very busy waste site. It is not clear how the addition of four residential towers will help to achieve the OPDC aim that ‘Scrubs Lane will be transformed into a pleasant street, respectful of surrounding heritage assets with a high quality public realm’ (OPDC Regulation 18 Draft Local Plan).
Planning applications submitted by Aurora Developments for two schemes on the eastern side of Scrubs Lane, overlooking St Marys Cemetery are awaiting decision by the OPDC. Many objections have been lodged on the OPDC planning website, especially for the southern scheme with its proposed 22 storey tower at 115-129a Scrubs Lane (see at this link).
RB Kensington and Chelsea have submitted strong objections. The application is due to be considered by Hammersmith and Fulham’s Planning and Development Control Committee of February 8th.
We hope that this committee questions the logic of building at this height and density a decade before public transport accessibility levels in this section of Scrubs Lane increase from their current very low level.
Across the road from these proposed schemes, developers City and Docklands are holding a second exhibition of proposals for their site just north of Mitre Bridge. The density of the latest plans is some 374 housing units per hectare, as compared with the 450 proposed by Aurora.
The public exhibition will be at the City Mission Church, 2 Scrubs Lane on Wednesday 25 January between 2.00pm and 8.oopm.
2 Scrubs Lane
The third new development in the pipeline for Scrubs Lane involves demolishing the existing City Mission church and nursery at 2 Scrubs Lane (corner of Harrow Road) and replacing it with a new residential tower.
The developers are Fruition Properties, and the architects are Stiff and Trevillion. A first briefing session for local people was held in December, but no drawings are available yet. The new building will provide space for the church and nursery at ground floor level, with some 70 housing units above. Building height is likely to be 18-20 storeys, with a density of 450-500 housing units per hectare.
This site at the northern end of Scrubs Lane has Willesden Junction in walking distance and hence better public transport access than at Mitre Bridge. But this density exceeds the maximum in the London Plan Density Matrix, even for the most ‘central’ locations with the highest PTAL levels.
If these schemes set the bar for building height, at what the OPDC define as a ‘sensitive edge’ of new Old Oak, what is likely to happen at the centre of the regeneration area, around the HS2 station? Predictions of 40-60 storey buildings are looking all the more likely, unless Sadiq Khan as Mayor of London takes a tougher line on building height than his Mayoral predecessor.
Proposals for new developments at Scrubs Lane are coming forward thick and fast. Too fast, in that developers are trying to exploit an assumed level of public transport accessibility that is not there yet (and may never be).
The two planning applications for North Kensington Gate have been ‘under consideration’ by the OPDC since mid September. The Hammersmith Society, and St Helens Residents Association, submitted objections several weeks ago pointing out that these schemes involved super-densities of 450 housing units per hectare.
Such a density is above the maximum in the London Plan Density Matrix for a development in a ‘Central’ area with the highest possible level of public transport accessibility (PTAL). Scrubs Lane as a location comes nowhere close to meeting this context, having no nearby station, a single bus route, and a PTAL level of 1b on a scale of 1-6.
This has not stopped Aurora from taking their proposals to planning application stage. More disturbingly, the OPDC and TfL planners seem to have closed their eyes to this basic flaw with the Aurora scheme.
The comments on the applications from Transport for London notes the current PTAL level of 1b, and fails to mention that ‘extensive planned transport improvements‘ will not be in place until 2026 (assuming they happen at all – the new Overground stations remain in doubt).
We have been pressing the OPDC to release copies of the pre-application planning advice provided to Aurora. Copies of four such letters have now been added to the OPDC online planning pages for these applications.
It is good to see that the OPDC seems now to to be following the example of London Boroughs such as Kensington and Chelsea, and publishing such advice routinely once a planning application has been submitted. The Grand Union Alliance has argued for such transparency. Many councils continue to treat such letters as ‘commercially confidential’ and refuse to release them.
You can see copies of the four letters at these links:
These letters cover many issues about the detailed design of the proposed buildings. But they start from the premise that mixed use development is acceptable with a density of 300 housing units per hectare. The developers initial plans were for 3 towers of 29, 22 and 18 storeys, with an averaged density of approximately 820 units per hectare.
Not the the first time, it appears that such proposals were an opening bid by the developers, who retained plenty of room for negotiation while arguing that any reductions in density would compromise viability.
Neighbouring landowners and waste operators Powerday and ERM have caught up with the Aurora proposals and have submitted letters of objection. Their concerns are that their own operations will be impacted on. They point out that the Aurora proposals are premature and present a picture of Scrubs Lane which bears little relation to its daily reality (queues of waste vehicles queuing to get and out of the EMR/Powerday access road, on one of London’s dirtiest and more congested streets).
Given this background, we are becoming more optimistic that the Aurora proposals will not be approved in their current from. And we hope that the developers of ‘Mitre Yard’ are taking note of the points raised in the emr and powerday objections, which apply equally to the City & Docklands site at 2 Scrubs Lane.
Scrubs Lane is a location in need of regeneration and redevelopment, no one would deny. But this needs to be ‘plan-led’ and not ‘developer led’. The first version of the OPDC Local Plan envisaged Scrubs Lane as a ‘high quality street’ on a sensitive edge of the OPDC area and adjacent to two conservation areas.
The OPDC Planning Committee on 15th December will be considering a Direction of Travel document for Scrubs Lane, incorporating work carried out by East architects. The report forms part of a committee agenda too large to publish via this website (12MB) but which can be downloaded from this link to the OPDC website.
This Direction of Travel document is the first stage in preparing a Supplementary Planning Document for Scrubs Lane, to accompany the final Local Plan. This draft document will be consulted on in early 2017. It contains a set of ‘principles’ for Scrubs Lane which reflect earlier consultations and most of which local people would probably support.
But it also includes ‘guidance for four clusters to guide the location of active uses and shape built form’ . The proposed clusters are at Harrow Road, what the OPDC has termed Laundry Lane, Hythe Road and at Mitre Bridge. The Mitre Bridge cluster is shown below:
‘Principle 9’ in the draft document reads as below:
Principle: Delivering a range of heights and massing that responds to sensitive locations and development opportunities including: a. generally 6-8 storeys onto Scrubs Lane and Harrow Road; b. lower massing opposite the Cumberland Park Factory and adjacent to Mary Seacole Gardens; c. increased heights adjacent to the railway; d. a single taller building in each cluster; and e. visual permeability between buildings.
Two options for the single taller building at at each cluster are explored in the document, 10 storeys and 18 storeys. Images providing a visual assessment of each option from a range of viewing points are included in an appendix, and are worth looking at.
It needs to be remembered that buildings of 8 storeys remain a rarity at present in this part of London, let alone 10, 18 or more. 6-8 storeys as the norm is justified by the OPDC as providing an appropriate sense of enclosure to the street in response to the width of Scrubs Lane and Harrow Road and surrounding context.
Cumberland House, currently the tallest building in Scrubs Lane, is in this range. Is this building height appropriate, on both sides of the street, with an extra very tall buildings at each ‘cluster’. Will this provide a high quality street, of a kind familiar to Londoners, at the edge of the OPDC area?
As will be the case for the remainder of the Old Oak area, the massing and height of development in Scrubs Lane is being driven by two forces:
developers arguing that their proposals are not financially viable unless they are allowed to build at extreme densities, above London Plan guidance.
the task faced by OPDC planners in allocating across individual ‘Places’ a target of 24,00 new homes at Old Oak.
This target was inserted into Annexe 1 of the current London Plan in its last review. As OONF and the Grand Union Alliance pointed out (in responses to the first draft OPDC Local Plan) the justification for this target rests on a Development Capacity Study which works backwards from this 24,000 figure, rather than explaining where it came from in the first place.
Scrubs Lane, as an area in which developers have been assembling landholdings, is the first real test of how a proposed OPDC average housing density of 447 units per hectare will pan out at each Place, Cluster, and individual site.
The current review of the London Plan provides the only opportunity to see this overall housing target revisited. Meanwhile we can only hope that the OPDC and its Planning Committee will continue to pursue a ‘plan-led’ approach and resist attempts by developers to max out their profits on every site in Scrubs Lane, in a period before sufficient transport infrastructure is in place.
Proposals for 2 Scrubs Lane will be on display next week. There will be a further post on this site with more news.