Camden Council has extended the consultation period for people to comment on the proposed Planning Framework to 20th January. Comments can be emailed to GOHCommunityVision@camden.gov.uk.
The link to the consultation website is here. Please go on line and tell Camden Council what you think.
West Kentish Neighbourhood Forum have submitted a response. The full version can be downloaded here.
A summary of WKTNF’s objections are is as follows:
The wording and presentation has been inconsistent and confusing. Without a coherent Planning Framework and Neighbourhood Plan to comprehensively benchmark the urban and socio-economic profile of the area, the Vision’s aspirational bullet points amount to no more than a noncommittal wish-list.
The ‘Vision’ as presented has no legal status and cannot serve as the comprehensive planning tool it advertises itself to be. It is a marketing device rather than planning guidance that could be effectively implemented or used to build upon existing policies. At worst, it could be used to justify a ‘pick and mix’ approach, with no overall coherent approach to mixed use, density, massing and open space.
There is no analysis of the problems that residents identified in their responses; and no input from the key service sectors such as health, policing or social services. There is no data to show what the starting point is, nor a timetable for addressing these problems.
There is no detail given regards how the two neighbouring planning frameworks relate to the Vision area, or examples of special guidance documents which have been produced elsewhere, eg. Canalside.
The Framework Area
The area considered in the Vision is arbitrary. The Vision asserts that a neighbourhood is defined by a 15 minute walk from its neighbourhood frontage but excludes the area south of Prince of Wales Road.
The exclusion of streets south of Prince of Wales Road makes no sense. The area north of Mansfield Road is included, even though there are no developments or any road re-planning being considered.
Our opinion is that the whole of the proposed WKTNF area should be included in the Vision, extending the area south to Chalk Farm Road.
Historical Analysis of the Area
The document should include an in depth and authoritative history of the development and urban interventions in the area.
The 1960s and 70s estates such as Bacton and West Kentish Town followed the post-war model for housing estates as island configurations that disrupted the established 19th century street pattern. The resulting urban and social issues have not been properly identified or understood. Without a Neighbourhood Plan that recognises these issues, it is very difficult to address the current problems in an informed and efficient manner.
Analysis should recognise large-scale phenomena with direct impact on recent evolution of the neighbourhood and planning policy, eg.
- continuous property appreciation
- deindustrialisation
- immigration
- inequality
Conservation Areas and Urban Design
No mention is made of the three conservation areas within the Framework Area: West Kentish Town, Mansfield Road and Parkhill and Upper Park Conservation Areas. There is no strategic thinking about their importance and contribution to the urban fabric.
There is no analysis in the document of the existing architectural context in terms of scale, massing and urban fabric, and no reference to what might be considered appropriate scale.
Urban Context and Character Analysis would lead from historic and heritage considerations to design recommendations and guidance, even codes.
Safety
The company Camden engaged to conduct the consultation used leading questions. Asking respondents how unsafe they feel can lead only to answers stating different degrees of feeling unsafe. People were not encouraged to comment on issues outside those formulated by Camden’s questionnaire.
There is no indication that either the police or Gospel Oak Safer Neighbourhood were consulted.
Impact of development
The social implications of the disruption to existing communities are not acknowledged or addressed. The demographic make-up of the area is not addressed.
PROPOSED REVISION OF THE VISION
Housing
A starting point or analysis of the existing condition and problems to be addressed within a realistic timeframe should comprise:
- An assessment of housing need, with pertinent data showing how this informs the number of new family homes proposed to address overcrowding whilst also meeting the needs of more transitory populations.
- Details of the social infrastructure required for the proposed number of additional people and upgrading of existing infrastructure such as schools, doctors surgeries and transport.
- The ratio between family homes and single-bedroom flats should be dictated by responsible, good-practice community planning that fosters sustainable growth rather than being dictated by a particular funding model.
- A strategy for responding to the needs of the elderly, with and indicate of the linespace and changing needs of people living in the area.
Strategy for local business, shopping streets and circulation
A coherent economic strategy is required, extending beyond Queen’s Crescent, supporting and enhancing local shops. The part-pedestrianisation of Queen’s Crescent ignores the practicalities of supplying the small food shops that have kept the market alive and give it its unique inclusive identity.
Malden Road needs to be developed as a key part of the urban structure of the place.There is no labelling on the Vision plans in of Malden Road, a major local artery with wilting shops that currently functions only as a drive-through.
Design guide
Design guidance should be provided for what is an appropriate height and massing for the area, with specific reference to streets such as Grafton Road, Malden Road, Queen’s Crescent.
This should include guidance in improving 19th century properties in relation to:
- Extending existing homes to meet the needs of post-pandemic society
- Retrofitting and forward planning for the introduction of sustainable heating systems both within and outside of conservation areas
CLIMATE AND ECOLOGICAL STRATEGY
The bullet points and wish lists relating to sustainability are piecemeal and inadequate, and do not address the reality of the climate and ecological emergency in any meaningful way.
Open space and eco-system services
Density is due to be significantly increased (trebled), resulting in the loss of green and community amenity key spaces. The statement that trees will be saved “if possible” is not good enough: these mature trees make major contributions to improving air quality, cooling, biodiversity and carbon sequestration. Replanting existing trees results in these benefits being significantly reduced over the next 40 years, which is unacceptable.
Retrofit and Embodied carbon
A policy of demolishing and rebuilding at higher densities is being actively promoted, instead of upgrading and adapting blocks of flats. Many of these that have been inadequately maintained for the last 20 years, so explaining the benefits of retention is made harder.
The Vision document discounts the possible retrofit of estates without examining what may be possible. The fact that the buildings have been neglected is not reason to demolish them. The embodied carbon cost of this approach is colossal. Camden is refusing to acknowledge the importance of embodied carbon. CIP developments will not become carbon neutral for 60–100 years, hindering attempts to mitigate climate change.
Conclusion
The Community Vision addresses itself to the neighbourhood, but there is no definition of what is meant by ‘neighbourhood’ and how it relates to Planning Policy or the area chosen for consultation.
‘Community-Centred’, ‘Design-Centred’, etc are isolated concepts without a coherent core that would give them meaning. None can be tested against policy.
Camden’s Site Allocation Local Plan states that sites should be “planned in a way that respects the local character of the surrounding area. They should also meet the needs of local communities and businesses.” The document fails to address these issues.
West Kentish Town 