gla planning report 187-199 west end lane annotated)

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    Provide other opp ropriote uses includ ing employment.Be set back t o ensure a m inimum 5 metre wide pavement to improve pedestrian movementan d assist improved interchonge between stations.

    Incorporate a new step free station entrance or facilitate impro ved accessibility to, ond/orexpansion of, the Overground station adjacent t o the site.Incorporate secure cycle parking to improve the transport interchonge.Ensure oppropriote relationship t o adjoining open spaces a nd ecological corridors an dprovide ne w open space.Positively contribute to an d integrate with streehcape an d interchonge improvements alon gWest End Lane.Provision o f Local Energy Generation o n site a nd explore options to export to surroundingdevelopments."

    20 In add ition the preferred approach also suggests, "based o n housing trajectory estimates,th at the site has the poten tial to deliver an oddition 180 residential units".21 The overarching policy direction suggests th at the area is therefore appropriate for a mix ofuses including residential. The site allocation is however less advanced in terms the examinationprocess. The weight to specific land uses in specific parts of the site is therefore yet t o be fullyconsidered or tested at policy level. The Mayor did no t comment on th e m erits of the specificallocation during th e previous consultation round in 2009, however, it i s apparent tha t there are anumber of specific site constraints that suggest residential development at high density i n certainareas of th e site needs t o be carefully considered and may no t be appropriate. The Mayo r maywish t o express this view as the document proceeds to its next round o f consultation in ligh t of th econstraints th at appear to be relevant t o mainly any residential component o f a regenerationscheme on this site.22 The apparent constraints t o the western end o f the site is also reflected in the preferredapproach suggested in the draft Site Allocations Preferred Approach documen t (2009 d raft) w hichindicates th at th e constraints o f the site place restrictions on large commercial vehicular use, bu tth at th e narrow containment o f the western section of the site by railway lines indicates non-residential uses wou ld sti ll be likely to be more approp riate towards the western apex - here insuggesting residential uses in this p art o f the site need to be considered carefully.23 The proposal, as submitted, includes residential accommodation all the way along the siteup t o th e western apex, excluding the area of pro tected natural open space. The scheme alsointroduces some ground floor commercial uses in some of th e blocks. The block located t o thewest and the t wo nearest t o i t have been identified fo r affordable housing. It is questionedwhether any residential accommodation in this particular part o f the site is suitable, let aloneiden tifying i t for affordable housing, given those residents in affordable housing do no t bene fitfrom th e same level of choice t o those who are able t o purchase or rent on th e open market.2 4 The application i s submitted wit h sup porting informa tion on noise, vibration and air quality.The GLA is in th e process of testing these areas of the submission t o see if the evidence issufficient t o su pport th e scale of residential development on such a constrained site and in certainparts o f th e site. The issue of t he block arrangement and density is linked t o these considerationsbu t further comm ent is set out later in this report.

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    33 London Plan policy 3.4 and table 3.2 set ou t the strategic guidance for residential densityo f new development proposals. The objective o f the policy is t o optimise housing out pu t havingregard t o local conte xt and character amongst other policy objectives. The context is an impor tan tconsideration and furth er discussion will be required regarding the su itability to parts of th e site ashas been consistently raised thro ughout th e pre-ap plication discussions.3 4 The applicant advises th a t th e proposed development wi ll provide 203 residential units andthe site area measures 0.9ha. The applicant needs t o confirm th at th e area relates t o the netresidential site area as set ou t in paragraph 3.35 o f the In terim Housing SPG which relates t odensity calculation. The applicant's cu rrent calculation generates a density of 226 units perhectare or 632 habitable rooms per hectare. This may however need t o be recalculated.35 in terms o f context, the site is urban in character and has a pub lic transport accessibilitylevel of between 4 and 6a. In such circumstances the London Plan normally suggests the site couldsupport a density of between 200 and 7 00 habitable rooms per hectare. The applicant needs t oset ou t the detailed density calculation and will need t o have regard t o the comments maderegarding noise, vibration, air quality and townscape.Urbandesign36 Good design is central to all objectives of the London Plan (201 1) and is specificallypromoted by the policies contained within chapter seven which address both general designprinciples and specific design issues. London Plan Policy 7.1 sets ou t a series o f overarchingdesign principles for development in London. Other design polices in this chapter and elsewhere inthe Lon don Plan include specific design requirements relating t o maximising the potential o f sites,the qua lity of new housing provision, t all and large-scale buildings, bu ilt heritage and WorldHeritage Sites, views, th e public realm and the Blue Ribbon N etwork. New development is alsorequired t o have regard t o its context, and make a positive contrib ution t o local character within itsneighbourhood (policy 7.4).Tall and large scak buildings37 London Plan policy 7.7, which relates t o the specific design issues associated wi th ta ll andlarge-scale buildings, is of particular relevance to the proposed scheme. This policy sets ou tspecific additional design requirements fo r tall and large-scale buildings, wh ich are defined asbuildings tha t are significan tly taller than the ir surroundings and/or have a significant impact onth e skyline and are larger tha n the threshold sizes set for the referral of planning applications t othe Mayor. Policies 7.10 and 7.1 1, which set ou t the Mayor's approach to prote cting the characterof strategic landmarks as well as London's wider character, are also important considerations38 London Plan Policy 7.7 moves away from active encouragement t o careful management oft a l l buildings and covers various tests fo r the location and design o f t a l l and large-scale buildings.This proposal incorporates a number of large scale buildings rising u p to 11 storeys. Policy 7.7focuses on th e impact on character by scale, mass or bui lt form o f a tall and large buildings andth at they shou ld relate well t o form, proportion, scale and character of surround ing buildings,urban grain and pub lic realm. Part B of th e policy seeks th at applications for t a l l or large buildingsshould include an u rban design analysis that demonstrates the proposals form part o f a strategyth at meets the criteria in Part C and tha t this is particularly impor tant where the site is no tidentified as a location for a tall or large building in the borough's LDF.

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    39 Camden Council's Development Management DPD (paragraph 24.10) notes th a t "Due tothe dense nature o f Camden with extensive ronge a nd coverage o f heritage assets, such asconsenmtion areas, numerous listed build ings an d five strategic views and two ba ckg rou nd viewscrossing the borough, the Council do n o t consider tha t it s practical to identify broa d areas eithersuitable, or no t suitable, f or ta ll buildings." The Council intend t o test each case against designpolicy DP24 which covers th e broad considerations o f goo d design, scale, character and access.4 0 Given th e above, Part C of London Plan policy 7.7 becomes particularly relevant. Againstthe context of Part C the proposal is within an area of intensification and partly within the to wncentre wi th good to excellent public transport access and therefore th e principle o f large scalebuildings may be supported subject t o o ther townscape considerations set o ut below..Views an d historic assets41 The townscape work is set ou t in section 6 o f the design and access statement. Thirteenviews have been tested, as agreed by Camden Council, t o illustra te the impact o f the scheme in itslocal and townscape context.42 At pre-application stage the key views appeared from the no rth -fa ci ng south (view 6,7and 8) and further no rth along West End Lane (untested). The submission analysis suggests th a tthese will be hidde n from the existing canopy line of th e trees and therefore the impact is broadlyacceptable.43 The majority o f the other views are broadly acceptable, however view 12 appears closer inthe view than th e plans suggest. There is a reasonable distance between the back o f prope rtiesalong Sherriff Road and the proposal site. The design team should review the work on th isparticular view t o ensure it represents an accurate visualisation o f the proposed developm ent.4 4 The design and access statement provides very lim ited comm entary or analysis of th eimpact on heritage assets. This may be due to t he fa ct th at th e proposals do no t impact on th etw o adjacent conservation areas, their character or setting. The design team m ust confirm th eimpact in the townscape analysis.Circulation and l a m.-....--45 The design team has introduc ed a range o f changes since pre-application discussions whichseek t o address a number o f key concerns raised by GLA officers. In summary the changesproposed are set ou t below:

    Removal o f podium level between block E and D which increases th e level of public openspace at street level.* Integration and distribution of affordable housing now extends up to block D.0 Access route has been set ou t as a narrow pedestrian friendly route wi th add itionallandscaping.0 Reduction in parking spaces resulting in on ly limite d parking space for com mercial use anddisabled parking for residential use and car club spaces (total parking 21 spaces).e Relocation o f concierge to main access route, set away from square.

    46 The changes create a more integrate d environmen t between tenures with blocks D, E Fand G now including a mix of social rent and interm ediate or social rent and private market units.

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    47 The main route throu gh th e site is active with a mix of commercial, residential and parkinguses, giving a mixed elevation o f brick, glazing, landscap ing and greenwalls. The balance o factivity plan ting and materials is well considered and creates a self po licing environm ent that iswell surveyed and human in scale. It could be further improved by introducing f ron t doorsbetween blocks D, E and F onto the central space.48 The loca tion of block G as being suitable for residential development is still beingconsidered as set out elsewhere in this rep ort. A number of other matters raise concern regardingthis block as set out below:

    Environmental constraints as set ou t elsewhere in this repo rt (noise, vibra tion and airquality).Block G is located at th e bo ttom o f the site in a location perceived as being isolated.Block G is no t naturally surveyed on bo th sides like the other blocks.Block G takes a differe nt architectural form to the point blocks across the rest of the site.(tenure blind concern)The ground floo r layo ut includes the bin store and sub station directly as the principle frontground floor elevation. The entrance should be visible from the t o p o f the main entranceroute - .e throu gh the vegetable garden, which could be located elsewhere -t hi s wouldallow an entrance po int th at is not flanked by bins and energy centres.

    49 For these reasons it is still difficu lt t o ustify, in design terms, how this block fits within themasterplan design. The matter will required further consideration in the co ntext o f the ongoingenvironm ental analysis o f th e site.50 The pu blic realm and square is suppo rted and the eastern end o f block A safeguardspossible alterations to create a new step free entrance to the Overground. The mix of commercialand retail uses and low ren t units at first floor will help support the to wn centre function. Theselayouts are broadly well considered.ks ih ent ia l quali ty51 London Plan Policy 3.5 promotes qua lity in new housing provision and sets ou t minimumspace standards at Table 3.3. The Mayor will produce a new Housing SPG (a dr af t of wh ich waspu t before th e London Plan EIP), on the implemen tation of Policy 3.5 for a l l housing tenures,drawing on his London Housing Design Guide, paragraphs 3.37 -3.39 provides furt he r guidance onindicators of quality th at th e proposed SPG will cover.52 In most instances the layou t of blocks is well considered and includes a mix of between 4and 6 units per floor most wi th m ultiple aspects. There are no single aspect nor th facing u nitswhich has been designed based on the principle of creating small foo tpr int po int blocks broken upby open spaces between. The space standards will be met and should be cond itioned b y CamdenCouncil. Whilst m ost aspects are well considered the approach to block C D and E include a singlelift where some of th e blocks have up to eleven floors. The Housing Design Guide seeks t o includetw o lifts where proposals exceed eight or more floors to ensure th at should one be ou t o f servicethere are other opportunities t o access the higher levels o f the building. The design team need t oset ou t the particular constraints t o meeting this standard.

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    100 In summary, a number o f issues need to be resolved before the application can beconsidered to be in line with th e transport policies set o ut with in the London Plan. This includes acontrib ution secured by section 1 06 agreement t o fu nd enhancements a t West Hampstead station.Clarification of the t rip generation methodology and number o f trips at West Hampstead station isalso required. A m ore robust and coherent travel plan is needed wi th associated fundin g andtargets including a mon itoring strategy.10 1 A meeting should take place between TfL, the applicant and the council t o discuss theabove points. Further discussion o f the proposals is required with London Underground'slnfrastructure Protection team wi th conditions attached to this application. Tf L will also need tobe closely involved in future discussions on the section 1 06 and dra fting of conditions w ithCamden Council.Comm unity lnfrastructure Levy102 In accordance with London Plan policy 8.3, the Mayor of London proposes t o introduce aLondon-wide Comm unity lnfrastruc ture Levy (CIL) th at will be paid by most new development inGreater London. Fo llowing consultation on b oth a Preliminary Draft, and then a Draft ChargingSchedule, t he Mayor has forma lly submitted th e charging schedule and supporting evidence to theexaminer in advance o f an examination in pub lic. Subject t o the legal process, th e M ayor intends t ostart charging on 1 April 2012. Any development that receives planning permission after th at da tewill have t o pay, includ ing:

    Cases where a planning application was subm itted before 1 April 2012, bu t no t approvedby then.Cases where a borough makes a resolution t o grant plann ing permission before 1 April2012 bu t does no t formally issue the decision notice un til after tha t date (to allow asection 10 6 agreement to be signed or referral to th e Secretary of State or the Mayor,for example),.

    103 The Mayor is proposing t o arrange boroughs i nto three charging bands with rates of 50 /35 / 2 0 per square metre of ne t increase in floor space respectively (see table, below). Theproposed development is with in the London Borough of Camden where the proposed Mayoralcharge is 50 per square m etre. M ore details are available via the GLA website~ h n d o n . ~ o v . u k / .10 4 Within London bo th the M ayor and boroughs are able t o introduce CIL charges andthere fore tw o distinct CIL charges may be applied to development in future. At th e present time,borough CIL charges fo r Redbridge and Wandsworth are the most advanced. The Mayor's CIL wil lcontrib ute towards the funding of Crossrail.

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    Local planning authority's position10 5 The officer recommendation is currently unknow nLegal considerations10 6 Under th e arrangements set ou t in Article 4 o f the Town and Country Planning (Mayor o fLondon) Order 2008 the Mayor is required to provide the local planning authority with a statementsetting o ut whether he considers tha t the application complies wi th th e London Plan, and hisreasons fo r taking tha t view. Unless no tified otherwise by the Mayor, the Council must consult theMayor again under Article 5 o f the Order i f it subsequently resolves t o make a draft decision on t heapplication, in order tha t the Mayor may decide whether t o allow the draft decision to proceedunchanged, or direct th e Council under Article 6 o f the Order to refuse the application, o r issue adirection under Article 7 of th e Order th at he is t o act as the local planning authority fo r thepurpose o f determining the application and any connected application. There i s no obligation atthis present stage for th e Mayor t o indicate his intentions regarding a possible direction, and n osuch decision should be inferred from th e Mayor's statemen t and comments.Financial considerations10 7 There are no financial considerations at this stageConclusion108 London Plan policies on noise, vibration, air quality, design, access, heritage, housing,afford able housing, climate change and transpo rt are relevant t o this application. The applicationcomplies wi th some o f these policies bu t n ot wi th others, for th e following reasons:

    Principle of development (non compliant): Further testing is required regarding thenoise, vibration and air quality conditions created across the site, in particular at thewestern apex which is proposed to accommodate affordab le housing.Affordab le housing, mix, tenure and density (non compliant): Further testing of theappraisal has been commissioned by Camden Council. The findings w ill in form furt he rdiscussion regarding these policy areas.Urban design (non compliant): fur the r testing and analysis is required on the townscapeand heritage views. The layout of bloc k G needs furthe r work.Access (compliant): the provision of wheelchair accessible homes, Lifetim e Homes anddisabled parking should be conditione d b y Camden Council.Climate change mitigation (compliant): the energy strategy is broadly supported .Climate change adaptation (compliant): conditions should secure water use targets andgreen and brow n roofs and walls.

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    0 Noise and vibration (non compliant): the noise impact is a concern and mitigation anddesign measures need t o be secured. The suitability of t he site for residential, particularlyand the w estern apex is being considered in furth er detail.o Air quality (non compliant): air quality im pact is a concern and is being considered in

    further detail.e Transport (non compliant): a contribu tion t o fun d enhancements at West Hampsteadstat ion may be required. Clarification of the tri p generation methodology and number o ftrips at West Hampstead station is also required. A more robust and coherent travel plan isneeded wit h associated funding and targets includ ing a mon itoring strategy.

    109 On balance, the application does no t comply wi th th e L ondon Plan.110 The foll ow ing changes might, however, remedy the above-men tioned deficiencies, andcould possibly lead t o the application becoming compliant w ith th e London Plan:

    0 Principle o f development (non compliant): Further testing is required regarding thenoise, vibratio n and air qua lity cond itions created across the site, in pa rticular a t th ewestern apex which is proposed t o accommodate affo rdable housing.Affordable housing, mix, tenure and density (non compliant): The findings will informfurther discussion regarding these policy areas.

    0 Urban design (non com pliant): th e design team should consider verifying the views fromthe south and provide commentary on any p otential heritage impacts. The layout of blockC needs furth er work.Noise and vibration (non compliant): the noise impact is a concern and mitigation anddesign measures need to be secured. The suita bility o f th e site for residential, particularlyand the w estern apex is being considered in furth er detail.

    0 Air quality (non compliant): th e air quality inform ation is being furth er considered by theCLA.e Transport (non compliant): a contributio n t o fun d enhancements at West Hampstead

    station may be required. Clarification o f the trip generation m ethodology and number oftrips at West H ampstead station is also required. A more robust and coheren t travel plan isneeded wi th associated fundin g and targets includ ing a mon itoring strategy. Constructiondiscussions and conditions may be required fu rthe r t o advice from London Underground'sinfrastruc ture Pro tection Team.

    for further information, contact Planning Decisions Unit:Colin Wilson, S enior Man ager - Planning Decisions020 7983 4783 email [email protected] Carr, Strategic Planning Manager (Development Decisions)020 7983 4895 email [email protected] tthe w Carpen, Case Officer020 7983 4272 email [email protected]

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