It looks like the proposed 203 unit development, of which more here and here, will have to go before City Hall. Camden has been advised to reject it because it does not comply with certain aspects of the London Plan. Having seen a tweet linking to this Hampstead & Kilburn Conservatives news item saying that “Boris objects” to the scheme, I did a little digging.

It’s stretching it a bit to say he “objects”. This is based on a report by the GLA’s Development & Environment Directorate. The comments are advisory, and say that Camden must consult City Hall when it makes its decision on the application, at which point the Mayor can accept, refuse, or reassess the application. 

Before you all get too excited/angry/worked up, it’s worth noting immediately that the scale of the proposed buildings is not the main concern (although the report talks about buildings 5 to 11 storeys high, when in fact the tallest building is 12 storeys high).

It is also worth noting that the issues raised by the Directorate are also deemed to be addressable. The recommendation is “That Camden Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 108 of this report; but that the possible remedies set out in paragraph 110 of this report could address these deficiencies“.

If you want to read the whole document, then I’ve highlighted some of the key paragraphs, but paragraphs 108-110 are written out below (emphasis mine).

108 London Plan policies on noise, vibration, air quality, design, access, heritage, housing, affordable housing, climate change and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

• Principle of development (non compliant): Further testing is required regarding the noise, vibration and air quality conditions created across the site, in particular at the western apex which is proposed to accommodate affordable housing.
• Affordable housing, mix, tenure and density (non compliant): Further testing of the appraisal has been commissioned by Camden Council. The findings will inform further discussion regarding these policy areas.
• Urban design (non compliant): further testing and analysis is required on the townscape and heritage views. The layout of block G needs further work.
• Access (compliant): the provision of wheelchair accessible homes, Lifetime Homes and disabled parking should be conditioned by Camden Council.
• Climate change mitigation (compliant): the energy strategy is broadly supported.
• Climate change adaptation (compliant): conditions should secure water use targets and green and brown roofs and walls.
• Noise and vibration (non compliant): the noise impact is a concern and mitigation and design measures need to be secured. The suitability of the site for residential, particularly and the western apex is being considered in further detail.
• Air quality (non compliant): air quality impact is a concern and is being considered in further detail.
• Transport (non compliant): a contribution to fund enhancements at West Hampstead station may be required. Clarification of the trip generation methodology and number of trips at West Hampstead station is also required. A more robust and coherent travel plan is needed with associated funding and targets including a monitoring strategy.

109 On balance, the application does not comply with the London Plan.

110 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

• Principle of development (non compliant): Further testing is required regarding the noise, vibration and air quality conditions created across the site, in particular at the western apex which is proposed to accommodate affordable housing.
• Affordable housing, mix, tenure and density (non compliant): The findings will inform further discussion regarding these policy areas.
• Urban design (non compliant): the design team should consider verifying the views from the south and provide commentary on any potential heritage impacts. The layout of block G needs further work.
• Noise and vibration (non compliant): the noise impact is a concern and mitigation and design measures need to be secured. The suitability of the site for residential, particularly and the western apex is being considered in further detail.
• Air quality (non compliant): the air quality information is being further considered by the CLA.
• Transport (non compliant): a contribution to fund enhancements at West Hampstead station may be required. Clarification of the trip generation methodology and number of trips at West Hampstead station is also required. A more robust and coherent travel plan is needed with associated funding and targets including a monitoring strategy. Construction discussions and conditions may be required further to advice from London Underground’s infrastructure Protection Team.

Some of this is a dotting the i’s exercise, but there are some more fundamental issues at stake such as the suitability of the western apex of the site (the bit furthest from West End Lane) for residential use, and specifically affordable housing (see paras 22-23 and 48-49 in the report). Personally, I’d like to see the methodology that suggests 203 flats will contribute just 42 more rush hour passengers on the tube (see para 83 and 100).

For those wondering about the height issue, the report seems to be choosing to stay out of that discussion. Here are the relevant paragraphs (original emphasis):

38 London Plan Policy 7.7 moves away from active encouragement to careful management of tall buildings and covers various tests for the location and design of tall and large-scale buildings. This proposal incorporates a number of large scale buildings rising up to 11 storeys [sic]. Policy 7.7 focuses on the impact on character by scale, mass or built form of a tall and large buildings and that they should relate well to form, proportion, scale and character of surrounding buildings, urban grain and public realm. Part B of the policy seeks that applications for tall or large buildings should include an urban design analysis that demonstrates the proposals form part of a strategy that meets the criteria in Part C and that this is particularly important where the site is not identified as a location for a tall or large building in the borough’s LDF.

39 Camden Council’s Development Management DPD (paragraph 24.10) notes that “Due to the dense nature of Camden with extensive range and coverage of heritage assets, such as conservation areas, numerous listed buildings and five strategic views and two background views crossing the borough, the Council do not consider that it is practical to identify broad areas either suitable, or not suitable, for tall buildings.” The Council intend to test each case against design policy DP24 which covers the broad considerations of good design, scale, character and access.

40 Given the above, Part C of London Plan policy 7.7 becomes particularly relevant. Against the context of Part C, the proposal is within an area of intensification and partly within the town centre with good to excellent public transport access and therefore the principle of large scale buildings may be supported subject to other townscape considerations set out below.