Comments on 4Th Draft of Fortune Green and West Hampstead Neighbourhood Development Plan

Comments on 4Th Draft of Fortune Green and West Hampstead Neighbourhood Development Plan

Comments on 6th Draft of Fortune Green and West HampsteadNeighbourhood Development Plan

I support many of the proposed policies and recommendations but am now mainly concerned about the text in two areas:

Athe policy on Liddell Road. At the heart of this debate is the question as to whether there is another site which could provide the cash needed for additional Primary School places and which would provide equal or better educational provision. This needs to take into account theacute pressure on Central Government’s and Camden’s capital budgets and the implications this has for funding new Primary School Places. The draft text also needs to provide an accurate representation of policies on new school places in the National Policy Planning Framework, the London Plan and Camden’s strategic Plan.

Bthe policy on the Growth Area including the need for a more strategic approach. I do recognise/hope that this is still work in progress in the draft.

2.I have also commented about a number of other areas and have worked through the 6th draft in numerical order.

DETAIL

2.5 Recent development ….While new buildings should not slavishly copy the style of buildings built in the late 19th century and early 20th century, there is a need for new development to fit in with existing development in the Area. This means buildings that are not starkly modern or out of place. Most buildings therefore should be predominately made of high quality red brick. Recent buildings made of grey brick have proved to be

unpopular and are widely considered to be inappropriate for the Area, because of their impact on

conservation areas and the overall character of the Area.

3.Few would support developing starkly modern buildings in the middle of a run of late 19th or early 20th centuries terraces housing in side streets but I believe that prohibiting them throughout the area goes too far. There is already a huge (and I think rich) variety of styles on or just off the main thoroughfares and in the Growth Area. It is too late to talk about fitting in with existing development in the area as a whole as though there were just one style. Indeed there are already some starkly modern buildings e.g.the new Railway Station on Iverson Roadand its associated green wall which has been widely welcomed. The 1930s art deco block Weech Hall on Fortune Green Roadwould no doubt have been seen as starkly modern when it was built but now is a welcome part of our heritage. The key issue here is quality of design.

4.Prohibiting starkly modern architecture throughout the area does not fit with the vision of a mixed and vibrant community and would be a depressing approach to innovative architecture and design.It risks making new development particularly in the Growth Area and also to some extent in the main thoroughfares boring pastiche.

5.Although the first three sentences appear to be prescribing the design of buildings in the area (with the use of “should” and “need”), you explained that this paragraph sets out the context for Objective 2 on Design and Character. I am not clear whether these sentences are meant to have any affect but in any event they do appear to be the first provisions in the Plan on design and as such have a high profile.

6.There is nothing here at this early stage about welcoming high quality design and innovation which surely should be a key point. I do recognise your very welcome reference to high quality design in the first part of Policy number 2 and elsewhere but I think it could be helpful to reinforce it here.

A3. The NPPF (60) states that it is "proper to seek to promote or reinforce local distinctiveness" and says (58)

that development shall "respond to local character and history, and reflect the identity of local surroundings

and materials". As outlined in 2.2, many parts of Fortune Green and West Hampstead have a clear

architectural heritage – with an attractive character and a distinct local identity. These positive features need

to protected and preserved. New developments in such areas – particularly terraced streets – need to fit in

rather than stand out. Larger developments, while reflecting new design, need to incorporate design features

that reflect the character of existing development, using materials (such as red brick) which complement

existing buildings. Innovation is not ruled out, however schemes incorporating appropriate innovation will

need to make a persuasive case for such development and demonstrate widespread local support.

7.The last sentence implies that even if innovation is appropriate within the terraced streets i.e. fits in with requirements set out in the previous sentences of this paragraph, the rest of the plan and the provisions you highlight in the NPPF, it should only be made if widespread local support can be demonstrated. This sets a high (?almost impossibly high) bar for any development incorporating innovation e.g. new ways of building.

A4. The character of the Area is largely maintained by the height of existing development. Much of the Area

consists of terraced housing, which is normally two or three storeys high. Mansion blocks tend to be four, five

or six storeys in height. It is therefore the case that development higher than six storeys will result in damage

to the character of the Area. Isolated existing development higher than six storeys, such as Ellerton on Mill

Lane - as well as recently approved developments, such as 187-199 West End Lane - shall not be considered as

a template or a guide when assessing the height of new buildings. In order to protect the distinct and widely

appreciated local character of the Area, new development shall respect and fit in with the height of existing

buildings in their immediate vicinity.

8.I found this paragraph a bit is confusing. Could it be tightened up?The fourth and fifth sentences (underlined) imply that the Area has one distinct character. As paragraph A3 recognises different parts have different characters. The Growth area and parts of the main thoroughfares have different characters to the terraced streets.The new student hostel in Blackburn Road, 187 to 199 West Lane and the Blocks on Finchley Roadare firmly there.Fortunately this is line of argument is redeemed by the final sentence which would permit new development in the Growth Area and parts where there are already high buildings to go higher than six storeys but elsewhere not. This seems a sensible outcome but could the underlined paragraphs be brought into line with the rest.

A10. Infill developments: any replacement of a house or houses within an existing terrace should be to the

same scale as the terrace, including the roofline. It should be similar in form, materials and details. Replication

of particular exterior details is strongly recommended where such details are consistent in streets. Houses

should be set back from the pavement and match or fit the building lines of existing properties, with front

garden areas remaining unpaved. The same principles should apply to vacant sites in streets where there is

already existing development.

9.This would appear to prohibit modern materials which have the same appearance as old ones but which could do a better job than those used say 130 years ago.

10.The last sentence appears to require any new development where there is existing but possibly ugly surroundings to replicate the ugly surroundings just because they are already there. Do you really intend this or have I misunderstood the paragraph.

B. West Hampstead Growth Area

11.You said in your email of 1 September that you were leaving the update on this section until later in the year. This seems a good idea as presumably it will enable you to include any input from Camden’s framework for the area. I have however made a few comments about this section even though they may be overtaken by events.

12.My general comment is that I think it would be useful to consider the trade off between the height of buildings and the amount of ground space used. Other things being equal the higher the buildings the less ground space will be used. I also think it would be useful to consider whether more floor space might be allocated to business and possibly to housing than as set out in the Camden’s strategic framework. This would need to consider the impact on heights, ground space and affordable housing. I would be concerned about any adverse impact on affordable housing. The impact on views would also need to be considered. A joint working party with Camden planners would be needed to consider options and I would be happy to help.

13.As part of this strategic approach it would be good to see some options as to how the undeveloped parts of the site might come about. Could one bring in experts (if Camden does not have them) on how the infrastructure of buildings, open spaces, paths and views might be developed to make the Area as attractive as possible? It may well be that you already have this in mind.

B1. Part of West Hampstead has been identified as an “Area for Intensification” in the London Plan (Table

A1.2) – see Map 3. Between 2010 and 2031 the stated aim is to provide a minimum of 800 new homes and 100

jobs. The CCS expects there will be around 1,000 new homes in the area during this period.

14.You should add the important point that as well expecting 1000 new homes, Camden expects there to be around 7000 sq metres of business floor space (along with some other uses).

B3. The NDP supports the target of a minimum of 800 new homes in the Growth Area. However, it believes a

number above 800 can only be accommodated with considerable additional investment in the infrastructure

of the Growth Area and the area around it.

Development above 800 homes should only proceed if there is:

A significant redevelopment of West Hampstead Underground Station, including greater capacity at

the entrance/exit and the installation of lifts.

An extensive redevelopment of West Hampstead Overground Station, allowing for greater passenger

numbers and giving additional space for pedestrians at the entrance to the station on West End Lane.

The provision of a new GP surgery and/or a primary health care clinic.

The provision of a new primary school, a new secondary school & new nursery places.

The provision of new social housing.

The provision of new community facilities and/or a new community centre – in particular to cater for

the needs of young and old people living in the Area.

The provision new east/west and north/south pedestrian and cycle links – including new bridges and

paths – and improvements to existing paths.

The provision of green/open space, parks and trees – as well as ‘green corridors’.

A limit on the height of new developments.

The protection of views across the WHGA.

15.The Camden Core Strategy already provides for in the region of 1000 new homes. Accordingly,I may be wrong, but I am not sure ifit is possible to impose a control on increasing the number of homes from 800 to 1000.That said I recognise that many of these provisions are already in the Core Strategy or in the Place Plan.

16.Installation of new lifts and greater capacity at the Underground Station would involve large sums of money and disruption of the service. Have you checked with London Underground about the practicability of this? Have you estimated what might be the impact on the number of people using the Underground Station if the extra 200 homes are built and whether it would be sensible to limit the number of homes because of this?

17.The financing of a new secondary school would again involve serious sums of money and (unlike primary schools whether Free or Council controlled) are a matter for central government. Is it sensible to link the increase from 800 to 1000 homes to a new Secondary School? At the moment there is massive pressure on the capital budgets for central and local government. You talk about new nursery places but only of a new primary and a new secondary school. It is not clear why the option of more places is excluded particularly as it is the option chosen by Camden for consultation for a Primary School places. Isn’t this prejudging the results of the consultation?

18.Please see the second paragraph of my comments under “B. West Hampstead Growth Area”in relation to setting a limit on the height of developments.It may be sensible to set a limit but it is too early to do so.

The target of 100 new jobs in the Growth Area is considered to be too low and should be increased. In line

with Objective 4, there is greater scope for providing additional employment opportunities in the Growth

Area. This figure should also take into account the significant loss of jobs from sites in and around the Growth

Area, so should be a net figure. Developments should provide flexible employment space for a wide range of

businesses.

19..As mentioned above, the target for 100 new jobs is in the London Plan. Camden’s Core strategy provides for 7000 sq metres of business floor space which could be more than 100 jobs. As I say above, I think that a joint working party with Camden should look in detail, among other things, at the question of more floor space for business. This could also look at:

athe advantages and disadvantages of setting a target in terms of floor space and jobs;

bwhat the impact would be of setting higher figures for housing and jobs

cwhat the demand would be for more business space (very much dependent on the subsidy perhaps)

dwhat the trade off between business space and affordable housing as both require a subsidy from developers.

ehow many jobs there are in West Hampstead altogether and what losses and gains could be incurred from recent developments

fwhat sort of jobs and businesses are needed to serve local jobs, consumer and business markets.

While there may be a need for high density development in some cases, this should be the exception and not

the norm. Large tower blocks are not considered appropriate in the area.

20.I think it would be sensible to undertake the study I mention above before coming to a view on heights.

West Hampstead Growth Area targets

London Plan target of a minimum of 800 homes & 100 jobs by 2031; Camden Council target of around

1,000 homes:

>As of August 2013:

187-199 West End Lane – 198 homes (estimated 70 jobs)

Student block, Blackburn Road – 347 units (potential for 150-200 jobs on ground floor)

Midland Crescent, Finchley Road (proposed) – 138 units (c.11-112 jobs)

TOTAL: 683 homes

21.Do you have the number of square metres of floor space for these developments to facilitate reference to Camden’s target?

B6. 156 West End Lane. This site, currently owned by Camden Council, is expected to be sold and redeveloped.

As part of the West Hampstead Growth Area it is expected to provide a significant number of new homes, as

well as employment opportunities. Any future development of this site needs to provide a mix-used use

development, satisfying a range of needs:

Housing (including family-sized homes & affordable housing)

Offices for small, micro and start-up businesses, including serviced offices and studio space

Flexible commercial/retail space that can be used for a range of employment uses

Possible space for education use, such as a primary school or nursery

Retail space on the ground floor along West End Lane to fit in with the town centre area (see map xx)

More closely fit in with the design of neighbouring buildings & the neighbouring Conservation Area

Be no higher than the existing building (five storeys)

Provide open and green space

Provide space for a market

Provide space for an affordable community & business meeting room

Provide a new footpath & cycle route to the O2 Centre and/or Finchley Road, which is safe and well lit

22.Most of these align with the Site Allocations document. I have only a few comments:

Awe stand a better chance of restricting the height of any new building here to five storeys as it is on the opposite side of the railway to most of the Growth area and hence its height could be compared to that of the neighbouring buildings. This is brought out well in the Site Allocations document and it would be useful to pick their ideas out or refer to them

BI would keep the reference to possible educational use without going into further detail. The ChildrenSchools and Families department consider 156 West end Lane as unsuitable for a primary or nursery school.

The ground floor of this site is currently occupied by the builders' merchant, Travis Perkins. They "request that

this section recognises that Travis Perkins currently operate a viable employment business from the premises

and that the site is wholly suitable for continued business use".