WHGARA’s objection to 187-199 West End Lane

Local residents association WHGARA has perhaps been the most vocal opponent of the proposals to redevelop 187-199 West End Lane. Here is a copy of its submission to the Camden Development Control Committee, which it will make on March 1st.

187-199 WEST END LANE APPLICATION No 2011/6129/P

1. WHGARA represents the residents of the area of West Hampstead, immediately next to and south of the proposed development. This application directly affects every one who lives in this Association’s area and who will see – and experience the consequences of – these overbearing tower blocks every day of every year.

We speak also for the interests of the wider number of residents of this part of West Hampstead who come and visit our area who have no one to speak for them. Many individuals, groups and businesses in this community will be disadvantaged for no good reason other than the profits to be made by the developers.

2. We support and agree with all that has been said by all three of our West Hampstead Councillors, Keith Moffitt, John Bryant and Gillian Risso-Gill. They speak with one voice in opposing this development in its present form with convincing reasons. We ask you to accept what they say. West Hampstead is primarily a residential area of low-rise housing – none more than 4 or 5 storeys high. Our Victorian and Edwardian forefathers recognised that low levels in a suburban environment are a necessary and attractive feature of town planning. As a result, even the tallest existing buildings are within a human scale. Blocks along West End Lane’s going towards Abbey Road are only 4- 5 storeys high. There are no tall buildings away from West End Lane itself. In the last 40 years, there has been no permission in West Hampstead, Hampstead, Swiss Cottage, St John Wood or Child’s Hill for a developer to build a 12 storey residential tower block – a skyscraper – let alone two more blocks which are10 storeys high. We have a heritage of a built-environment with a rich social mix of residents and many small businesses. Many other developers are waiting to see what the outcome of this application is going to be.

3. We are at a defining moment. This joint development by a public body – Network Rail – and its private enterprise partner, Ballymore is totally out of keeping with anything that has gone before and is closer to the ghastly tower blocks which planners allowed to be built in the 1960s. It represents a massive overdevelopment of a small, narrow and tapering site. The site may be ripe for development, but not like this. It defies Camden Core Development policy CS 5 and is detrimental in great measure to the amenity of all local residents. It goes against Core Policy CS 14, because it is completely at odds with the context and character of the area. It has few saving graces and nil charm.

4. Much emphasis has, for instance, been laid on payback in the form of a small public square, just by the railway station. In reality, it is just about twice the size of the fire-station forecourt in West End Lane. It will contribute little to our community and the reality is that any developer of the site is going to do much the same kind of thing, because a small open space is needed there nowadays to allow for the current, very large number of daily commuters who use the 3 stations which lie next to each other.

5. The size and bulk of the development is hostile to our environment and will have a chilling impact on our community. This is not central, inner London, but a lovely village, close to the centre. Queen Victoria used to go riding along West End Lane because it was a pleasant place to come. These tower blocks are going to be directly visible from a great number of places – not least from West End. They overshadow (from the south) the nearest street –Iverson Road- robbing it of light. To allow the construction of 1 x 12 storeys, 2 x 10 storeys and 2 x 8 storeys anywhere, let alone on this small site of less than 1 hectare would be unforgivable. These tower blocks will be there, long after our lifetimes. The Members of this Committee must not bestow such a ghastly legacy on this generation and the many generations to come. Get it into perspective: the height of the 12 storey block is more than twice as high as St Pancras. There is an almost complete absence of a proper analysis of this impact in the Officers’ report.

6. Although the Mayor’s Intensification Plan may envisage 800 new homes in the area, it does not mean that 25% of that plan needs to be stuffed onto one small site. The designation as a growth area does not mean that just one developer partnership should be allowed by our elected representatives to rob our community of its pleasant environment and to set a chilling precedent that other developers will eagerly follow. This development represents over-ambition and a thirst for unjustified profits by Network Rail and its partners at our environmental and social expense. The size of the buildings is driven by the commercial decision to cram in 200 or so apartments – as if this was in the heart of the West End or the City. We ask the committee members, as our elected representatives, to moderate this scheme to not more than 6-8 storeys and send the message to the developers to go back to the drawing board. The development as proposed will devastate the infrastructure and village feel of West Hampstead, which the draft Place Shaping document describes as the KEY ATTRIBUTE of this area.

7. Some of the statistics deployed by the developers are highly suspect and, as the Councillors point out, out of date. For instance, these 200 homes will produce some 700 – 800 new residents, given the mix of flats. The developers claim only 363 residents on the basis that no bedroom would be occupied by more than one person! That is obviously nonsense. They suggest that there will be only 72 children needing new school places, whereas the true number will be many more. There are just 2 doctors’ surgeries within or on the fringe of the West Hampstead Ward – So the developers used a one mile radius instead, and included any surgery in Kilburn, St John’s Wood, Swiss Cottage and so on. The calculations concerning increased pressure on public transport and traffic generally are also unusually low.

8. The impact on local parking is unpredictable because of car-capping. “Let them use car clubs” -you may say, but the Application provides for a tiny number of car club parking spaces and completely ignores the impact of residents and their visitors who will want to park – outside controlled hours. 14% of residents in West Hampstead, according to the Council, commute by car. For this development alone, that equates to well over 100 new residents’ cars, which will be searching the surrounding streets for spaces at night and weekends. And that does not take into account the delivery vans servicing the number of shops in the proposed scheme, for whom almost no special provision has been made.

9. This is an Application for a completely overwhelming and undistinguished piece of architecture, involving a huge overdevelopment of a small site and one which is going to impact adversely on all our lives and the future generations to come. If built, this is not going to win any prizes – only universal condemnation for the developers and the town planners who allowed it, contrary to the local community’s strong objections and in the face of broad local protest.

We, therefore, ask the Committee to refuse the application.
Stephen Nathan QC, Chairman, WHGARA. 27.ii.2012

187-199 West End Lane “non compliant” with London Plan

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.

Consultation on 187-199 ends on Feb 14th

These plans went into the council before Christmas. If you’ve no idea what I’m talking about then gen up on the background, maps, pictures etc.. In a nutshell: 203 flats to be built on the land between the tube and overground lines to the west of West End Lane, fronted today by the shops from Café Bon to Michael Leonard Estates: 187-199 West End Lane. The image below also misses out the 6-storey longer-block of affordable housing at the back (left) of the site.

The planning documents are lengthy and incredibly detailed, To access the whole lot, you need to enter ref 2011/6129/P into Camden’s planning search engine, click the application number when it comes up, and then click “View Related Documents”. I’ve linked to a few of the critical ones below, and the main planning document is here – I’ve drawn your attention to some paragraphs with red borders

If you want to comment on the plans you need to do by February 14th. You can do so via the Camden planning site (it’s easy enough to find). The sort of issues that have exercised people include:

  • Height – at 12 storeys high, the middle tower will dwarf anything else in West Hampstead;
  • Potential loss of daylight for houses close to the development (developer’s report here);
  • Whether the existing local businesses on the site will be allowed to continue operating until demolition is essential, whether they will be offered first option on the new commercial premises included in the proposals, and whether that would be at a reasonable rent (retail floor plans top left here, and see 6.30-6.33 in the main planning document);
  • The impact on traffic and transport in the area, despite being nominally a zero-parking development (developer’s report here).

There may be other issues you’re concerned about – although do check the documents to see if they’ve already been addressed. It’s probably fair to say that the plans are not going to be summarily dismissed by the planners. There is a need for housing, the land has aleady been identified as suitable for residential development, and it ties in with the London Plan that calls for 800 new homes around the stations in West Hampstead over the next few years. The details – especially the height – are up for debate though.

Local residents group WHGARA has been most vocal in its opposition to scale of the development, and is exhorting people to “Act now“. Meanwhile, WHAT has posted its letter to Camden, which I’ve added to the comments below.

Update via Cllr Andrew Marshall (Swiss Cottage): The council’s email address for comments on planning applications is changing. From the end of January, use .

187-199 West End Lane: The Ballymore proposals

“We actually live here, it’s not just a ‘place with great transport links’, it’s our home”

Last week, quite a large group of locals turned up at Sidings Community Centre to hear a presentation from the developers and architects of the 187-199 West End Lane site. It was chaired by Frances Wheat, Head of Development Control at Camden’s planning department.

Full minutes will be written up, and I’m not going to try and cover everything that was discussed in the session which ran for two hours. I’ve already covered the basics elsewhere, so I’ll try to shed some light on some other issues that arose and set the context very briefly.

The area around the three stations (known as “The Interchange”) has been designated as an area for intensification in the Mayor’s London Plan. That’s a done deal – the expectation is for 800 new homes by 2015. Therefore, land such as this strip which runs between the underground and the overground lines will be developed for housing, but the scale and type are not set in stone.

The site is ~450m long

The boards that were exhibited beforehand are now accessible on the architect’s website (see these for issues I haven’t covered here, for example the parks, gardens and environmental issues, or site constraints). Some changes have been made since the last designs were discussed – the “public” square (presumably private space) has been made bigger to accommodate potentially the fillip that is a farmers’ market, and more smaller retail units have been added.

West End Square

First up, perhaps the most controversial of the issues: the height. There was quite a lot of confusion and, I have to say it, obfuscation, on the part of the architects here. At the exhibition the previous weekend I’d been told point blank that the highest building would be 11 storeys. Yet, JamesEarl from Fortune Green Residents Association had been told it would be 12 storeys. It’s a fairly basic fact without much room for error. You’d think. As Eric Holding, architect at John Thompson Partners ran through his presentation he rather hurriedly said that the highest building would be 11 storeys “from West End Lane”.

When it came to audience questions, the first was: “how high are the buildings?”. No clear answer was forthcoming, with talk about the top floor being set back from the sides of the buildings, and the land sloping away, and no flats on the ground floor. The audience was getting a little irate, and it took someone (me) to shout rather loudly “how many metres tall is the highest building from the ground to the roof and how many storeys is that?” before we finally got an answer: 36m high, 12 storeys. So there we have it. That’s the height of the highest building, which would sit in the middle of the site. “From West End Lane”, it will have a relative height of 11 storeys because (presumably) the plot is about 3 metres lower than the road level.

Equal size blocks on the left, proposed layout on right

Everyone clear now? Why the developers would think that evading the question (or giving the wrong facts) would be helpful or win sceptics over when we’ll find out eventually is beyond me. The heights are also notable by their absence on the exhibition boards. The building heights running east to west (away from West End Lane) are 15m (5 storeys), 24m (8), 30m (10), 36m (12), 30m (10), 24m (8) and then a longer block that looks to be 6 or 7 storeys high at the back of the site.

They explained in more detail why they had decided to go for this ‘rise and fall’ design rather than having the buildings rise steadily with the tallest block at the back or have a uniform height across all the blocks. Some of this was aesthetic, and I agree that their design is more pleasing this way. This also means that the 30% of affordable housing that the scheme proposes can be in family home-size dwellings at the back of the lot rather than somewhere in the middle dwarfed by blocks around them (more on this issue later).

There was also the issue that if the tallest building was at the back it would block the light (think of those lovely whampsunsets) from the rest of the site. They also argued that the trees that flank the site (none of which are actually on the site and thus their long-term future cannot be guaranteed) give adequate screening for the larger buildings, although the photographs that tried to prove this were taken before the leaves began to come off the trees – they said they would be taking pictures again in winter.

Click for larger view: red outline shows building behind trees

There was understandable concern from residents in streets that are closest to the site about the effect on their light. The developers explained that they had tried to take natural breaks in existing housing into consideration – but it feels like this issue could run and run as it may well have a big impact on some houses.

From Iverson Road

Big change to view looking north

In total, the development will have around 200 units (roughly equal to 540 people). I asked what was driving the total number of units – i.e., why 200 not 230 or 170, and what the minimum number of units would be that would still give the developers a reasonable return.

Naturally the second part of the question was ignored, as I expected (and having asked a question (and heckled to get a straight answer over height) I was subsequently passed over for more questions, which was frustrating as both my other questions were very straightforward). The answer to my first about driver of total size was a bit vague, but talked about the need for housing in the area, balancing the affordable housing requirements, the need to make a profit (absolutely valid) etc. It also pointed out that the density (594 habitable rooms/ha.) was below the legal limit of 700 that the site could take. This didn’t convince everyone in the audience and there were mumblings of “why are you doubling the height of West Hampstead’s buildings”.

Architecturally, the buildings seem reasonable. Unlike the initial proposals for the Iverson Rd garden centre site with its bizarre aeroplane wing roof, these are fairly simple blocks, and are a modern attempt to reflect the traditional red brick and white render of much of the area’s long-standing architecture. Given the noise from the trainlines, the apartments will have internal cooling systems so windows can remain closed, although lots of flats will have balconies, for those who really like to hear the trundling of trains. Corner balconies also reduce the visual boxyness of the buildings.

Tallest building would be 2 storeys higher than left/centre image here

Affordable housing
Thirty percent of floorspace is designated as affordable housing, split into 25 “intermediate” units and 20 “social housing” units. Note that Camden’s guidelines are for 50 percent affordable housing (by floorspace not no. of units) in mixed-use developments, which this falls well short of. As I understand it (and happy for someone to correct me as I’ve not had time to wade through the reams of planning docs.), developers who fall short of the guidelines may be/are? asked to pay the council a set amount based on a formula that is put towards building affordable housing elsewhere in the area.

Cllr Mike Katz pushed for more details on the decision to keep all the affordable housing at the far end of the site, suggesting this might not aid what he termed “community cohesion”, ie., the integration and mix of people that generally leads to more harmonious social outcomes.

To the developers’ credit they had quite a full answer to this, and referred largely to the specifics of the site: the end location would allow for gardens attached to properties rather than the communal gardens and “pocket park” that sit between the other blocks. This relates to the elevation relative to the railway lines and at ground level this would be the quieter end of the site (note that an “acoustic wall” will flank the southern side of the site using foliage as sound proofing against the noise of the trains). This is clearly seen more as family housing than single occupancy housing. It would be interesting to know, however, whether the developers have looked at integrating the non-family affordable units into the other blocks rather than forcing all the less affluent residents into the far end of the site.

The development is classified as “zero parking”. It won’t surprise you to know that this doesn’t mean no parking. There was will be 20 disabled parking bays, five car club spots (enlightened), and five commercial parking spaces. Residents will not be allowed to apply for parking permits on nearby streets. The developers argued that given the site’s current use as a car wash and repair yard there would actually be less traffic once the development was finished than there is today – suggesting an 85-90% reduction.

It’s true that there is a steady flow of traffic into the site today, but hard to believe that lots of the residents won’t be ordering their parcels from Amazon, or their shopping from Ocado, Tesco and the like. Not to mention service vehicles, refuse collection etc.. It may not be a increase in traffic, but I would like to see the evidence that leads to the conclusion that there would be such a large drop in traffic. In addition the single road that would run the length of the development will also be the pedestrian access for the whole site, but I wasn’t able to ask whether it would be a single track or a two-way road.

A question was raised about whether residents who needed vehicles for work – e.g., tradesmen, would therefore effectively be excluded from moving to the development if they couldn’t park. There seemed no clear answer to this.

Part of the scheme involves changing some of the West End Lane streetscape around the interchange. The zebra crossing by the Overground would be replaced by one more or less where Rock hair salon is now, and the newish southbound bus stop (long fought for by WHAT) outside the post office would be moved further north to roughly where Greene & Co. is. The idea of moving the bus stop prompted outrage from some in the audience, given the battle they’d had to get the new stop put in in the first place and there was a rapid assertion from Camden and the developers that these proposals were in their very early stages. The zebra crossing makes sense, but I didn’t understand the rationale for moving the bus stop.

red zebra crossing/bus stop = existing; blue = proposed

As we know, right now there are six businesses with West End Lane frontage on that site, from Café Bon to M.L.Estates, as well as the auto-related businesses behind including the motorbike shop and the repair business. The buildings they inhabit would be replaced by “West End Square”. There will be seven smaller retail units in the new development as well as a large 600m2, which is metro format supermarket size – and, if I understood correctly, one of them will be let only temporarily because it will need to be demolished at a later date because of something to do with the Overground station infrastructure. Apologies for the lack of clarity here, this was the second question I wanted to ask but wasn’t allowed to. I have followed up with JTP and am waiting for them to get back to me.

The architect argued that the number of units on the site was rising from five to seven (they are counting Rock and the car hire place as one unit I presume), but this clearly doesn’t translate into seven similar permanent small units for these or similar busineses to occupy. The exhibition boards say “There could be scope for some of the existing retailers and businesses to take new premises in the scheme and the developers would be happy to discuss potential tenant requirements at the appropriate time“. I find the plan for the shops baffling in terms of the first floor and ground floor plans. I look forward to being enlightened on this.

Do the ground and first floor plans on the left match those on the right?

There will also be 650m2 of commercial office space. It seems that this could be used for all manner of purposes and would not necessarily be let to one business but might be shared use (in theory this could be a great idea for shared office space for local independent sole traders – a business hub sort of thing, but I’m getting ahead of myself).

There were inevitably questions about the construction itself, which would take place in two phases and if all went to Ballymore’s plan would start in spring 2013 and take two years. The idea of both the Blackburn Road development and this overlapping should alarm anyone who already finds West End Lane traffic a problem.

The site’s location between rail lines limits the access points, and cunning ideas like adding a tunnel from Iverson Road were rapidly ruled out on cost grounds.

Summary (and “my two cents”)
Overall, the audience was initially respectful, with a few exceptions. As the meeting went on, things became a little more confrontational, and some frustration was directed at the chair who some thought was moving things on a little too quickly, not allowing all questions to be asked or pursuing answers adequately. Of course some people just wanted a good old rant and were inexplicably permitted to do this on more than one occasion, which meant other people’s legitimate questions were missed out (I’m not just talking about me here by the way).

Sadly, not all the members of the panel looked as engaged as they might have done when not speaking. As one woman in the audience pointed out “We actually live here, it’s not just a ‘place with great transport links’, it’s our home“, and it does feel insulting if the people planning large-scale changes don’t at least pretend to be interested, even though I’m sure there are plenty of things they’d rather be doing on a chilly Wednesday night in November than dealing with a bunch of disgruntled locals. Credit to David Laycock, from Ballymore, who did in fact make an effort to engage throughout.

What do I think? As longer-term readers know, I tend to try and be reasonably balanced on such matters, especially those where emotions can run high. I don’t oppose development on the site, and I think that there are some good ideas within these proposals.

I think the height is a major concern, as it is out of keeping with the character of the area (reference to the 8-storey student accommodation being built is fair, but that is on lower ground still, so “relative to West End Lane” it won’t be as dramatic), and has the potential to affect some properties’ light quite considerably. I also hope that existing businesses are given first option to take over the retail premises and that the inevitable and justifiable increase in their rent is realistic.

I do wonder whether in shooting for such high buildings, the developer is prepared for a challenge and will be happy to “compromise” at e.g., 10 storeys, which might have been just as hard for people to swallow had it been the initial proposal. But then I can be very cynical. I also hope that if the height IS a problem, the retail spaces aren’t sacrificed for extra flats in an attempt to recoup any lost profit.

I think that West End Square has the potential to be an asset to West Hampstead. It will vastly improve the image of the area for those arriving by tube and, together with the large open space by the new Thameslink station, it gives the community more flexibility for events, markets etc. I’m also acutely aware that given that this area is earmarked for intensification, the developers have a trump card up their sleeves. Should Camden refuse the plans that will be submitted later this month, an appeal to City Hall could see them passed anyway with fairly minimal concessions, which was what happened to the Blackburn Road student residences.

(all photos taken from the JTP exhibition boards)