To: mayor@london.gov.uk
Date: Monday, 29 March, 2010, 15:14
Dear Sir
Further to our interim comments of 4 February, I now send you on behalf of the Kennington Association Planning Forum (KAPF), our final comments on this consultation draft of the Vauxhall, Nine Elms and Battersea Opportunity Arae Planning Framework.
Kind Regards
David Boardman
Chair
KAPF
Vauxhall, Nine Elms and Battersea Opportunity Area Planning Framework (VNEB)
Nov 2009 Consultation Version
Representations from the Kennington Association Planning Forum
Who we are
The Kennington Association is a voluntary membership association of upwards of 420 members drawn from the wider Kennington area in the north of the Borough of Lambeth, an area that abuts the Framework area on its north east side. Our aim is to promote and maintain the Kennington area as a good place to live and work, and the Kennington Association Planning Forum is a group of Association members with interest in and experience of planning and development issues, that develops planning policies and makes planning representations on behalf of the wider Association. The Forum made preliminary comments about the Consultation draft on 4 February 2010, and the Committee of the Association meeting on 22 February authorised me as Chair of the Forum to make this further representation on behalf of the Forum, which builds on our earlier comments.
Summary – Whose Opportunity ?
If these proposals go ahead, a new town of 40,000 will be created on our doorsteps over the next 15 years. That is the equivalent of the population of Welwyn Garden
· Are much too dense – approaching the highest known urban densities in the world, and exceeding those of Mumbai, Delhi and Calcutta
· do not allow for nearly enough open space,
· fail to provide a civic heart or framework to the community of 40,000 they create
· do not measure up to the challenge and expectations of the Central Activities Zone, particularly as regards the lack of any cultural component
· appear to expect most of the supporting services like schools and doctors to be provided by and at the expense of the neighbouring communities , and
· are “supported” by a transport study which is not fit for purpose, because based on flawed “zero sum” and other assumptions
Nor do the proposals measure up to the Mayor’s own Plan Objectives to:
· Protect and enhance open spaces – they provide about a quarter of the open space targets!
· Deliver housing including affordable housing – downgrade the affordable target to an aspiration, with some developers now claiming they can’t afford any!
· Secure social infrastructure to support new and existing residents – new transport will eat up all the developers’ contributions and push £200m or more of costs onto neighbouring communities
· Ensure strong and diverse long term economic growth – plans to import 27,000 financial services style jobs are offset by the unquantified loss of many of the 26,000 existing mixed skills jobs, mostly from Lambeth or Lambeth residents
· Promote social inclusion and tackle deprivation and discrimination – worthy sentiments, but with little substance in the Framework, and no analysis of the neighbourhoods’ actual needs for jobs and housing
· Joined up approach to planning and transport – so joined up it forgets to include the impact of the Elephant development, or changes in freight traffic, and assumes developers will build its crucial transport links for free
· Make London
· Improve the public realm – Only around the American Embassy, which needs its surrounding greenery and moat for security purposes
· A strategic and co-ordinated tall buildings strategy – On the contrary, in the absence of clear planning rules, it is a free for all, with tall buildings coming forward thick and fast, each citing the others as precedents.
What concerns the neighbours?
At para 7.3 VNEB recognises that neighbouring communities, like Lambeth, are extremely deprived, and that “New development must make a contribution to support and enhance education, health, skills and training, open space and public realm within and beyond” the VNEB area. But if so, how? In Lambeth, only 32% of Lambeth jobs go to Lambeth residents, and 20 % of Lambeth residents of working age have no qualifications (25% in Prince’s ward).
· Will those on Lambeth’s housing lists be able to afford any of the new housing? (the “affordable” housing requirement is being watered down, and the Battersea Power Station developer is proposing none at all)
· What happens to the existing 26,000 jobs? Will Lambeth jobseekers have the skills to do any of the new jobs proposed? How will these developments help to upskill them? What is the expected skills profile of the new jobs?
· The Vauxhall Gyratory equates, for most Vauxhall residents, to the equivalent of one of Dante’s Circles of Hell. Does TfL have the bottle to level with the community, face to face, about whether anything will come out of VNEB to mitigate its impact? Or does Vauxhall need to develop another heart south of the railway?
· What will be the permanent effects in our areas on traffic and public transport from 40,000 additional residents and tube users, on top of the extra already committed via developments at Elephant and Castle?
· What will be the impact on public services in neighbouring parts of Lambeth, eg schools and health services? How much land for new schools, doctors etc does the framework include in the VNEB area?
· Are we going to be cut off from the river by a palisade of tall buildings?
· Will we neighbouring communities have to suffer 20 years of construction traffic while VNEB builds itself, while the river lies unused (and unconsidered in VNEB) as a construction highway?
Chapter 5 - Land Use Strategy
VNEB lacks an adequate “before and after” analysis of land use and employment, to allow us to judge it properly. There are
· complications of shared oversight by Wandsworth and Lambeth, and historic problems of equitable sharing between the boroughs
· the need to accommodate the 20 ha or so of existing social housing which is to be retained,
· escalating densities in existing planning applications and
· doubts whether adequate provision is being made within the VNEB area for social infrastructure.
4 So we need a proper breakdown, for the existing uses and for the Framework’s preferred option 5 modified, of the 195 ha of the VNEB area, between, for each borough
· existing housing;
· new housing;
· mixed use residential/employment;
· retail;
· office;
· other employment;
· open space;
· existing social infrastructure (inc schools and doctors); and
· new social infrastructure,
together with the resulting housing and employment yields per hectare.
In the absence of an official breakdown, we estimate the 195 ha, under the Framework proposals (see Figure 5.1 Land Use Strategy), to break down as follows
Land area in Hectares | |||
Wandsworth | Lambeth | Total | |
SIL consolidation & intensification | 33 | 33 | |
Main market consolidation | 12 | 12 | |
Retained social housing | 20 | 20 | |
Limited intensification | 6 | 11 | 17 |
High density mixed use focal point office and retail including housing | 36 | 14 | 50 |
High density mixed use housing led intensification | 30 | 15 | 45 |
The “Lambeth strip” | 18 | 18 | |
Total | 137 | 58 | 195 |
[The “Lambeth Strip” is the south east fringe of the Framework area, added at a relatively late stage to the area, and lacking a designation in Figure 5.1. ]
On this basis, the area for intensified development is 112 ha, split 72 ha Wandsworth and 40 ha Lambeth. From this must be subtracted about 10 ha of existing open space and educational uses, about 4 ha of railway embankment and the promised 15 ha of linear park, leaving 83 ha to accommodate the 16,000 new dwellings and 20,000 to 25,000 new jobs contemplated. This would generate a population density of 451 per hectare, about the density of Dhaka (455 people per hectare) , the densest city in the world. To use the same area to sustain 20,000 or more jobs beggars belief, and leads us to doubt that there is any prospect of the 20 or so ha (our estimate) of the land requirements of the social infrastructure for 16,000 dwellings ever being provided in the Framework area, unless the intent of adding the Lambeth Strip to the Framework area was to provide an area of Lambeth to quarry for such purposes.
Chapter 6 - Development Capacity
Option 5 is labelled as having a density of 255 dwellings per ha, equating to 65.7 ha to accommodate 16,750 dwellings, but is illustrated only by the example of Tabard Sq, which is repeatedly shown as having a density of 477 per ha, or 87% higher (and incidentally, higher than the 405 per ha indicative upper limit for such areas in the Mayor’s Plan). Tabard Sq is a slab like, inward focused, fortress development, with its only greenery on the inside, in manicured raised beds, and is frankly oblivious to the public realm (see actual pictures, attached). You get the sense that children have been designed out, in the interests of high density and financial return. So we regard development in this Tabard Sq form, at these densities, as completely unacceptable, and incapable of creating a demographically sustainable community.
So far, for residential development proposals in areas with good public transport, the highest acceptable densities we have seen, that combine interesting built form with green edges, high levels of family friendly and affordable accommodation, and respect for the public realm, are around the 230 dwellings per ha level (cf the Southwark development on the former Braganza old peoples’ home, Ref Southwark 09-AP-2388). This is for exclusively residential developments, and allows the family accommodation on the ground floor to benefit from the garden and green fringe elements of the design. Mixed use developments, with employment uses on the lower floors preempt this family friendly space, and given the necessity of providing a significant proportion of any residential development as family friendly 3 and 4 bedroom dwellings, we do not believe even these densities are acceptable in mixed use developments.
We are fundamentally opposed to the expulsion of employment from the eastern end of the VNEB area mandated by the Framework, particularly given the presence of the railway embankment spine, and its railway arch workspace, which can only have employment generating uses. This misses an opportunity in real sustainability. 40,000 increase in population and activity will lead to a large increase in servicing requirements – white van man comes in from Herts (over the bridges) and from Kent or Essex (South Circular) and then through Brixton and Kennington – and an Arterial Road will only concentrate the problems at both ends. The missed opportunity is to seek to return key services industries to Nine Elms from which they can service all of inner London Stewarts Road
Chapter 7 - Social Infrastructure
So far, pending its S106 study, VNEB is silent on the financial and land demands of the social infrastructure required to service such a large new development. But given the risk that escalating transport costs will eat up all the S106 money, and more, and dump social infrastructure costs on neighbouring boroughs and their council tax payers, we think it worth making cockshy estimates now, for key elements, based on the official assumption, that in a balanced and demographically sustainable community, 25% of the population are children. These are:
· schools - 3 primary at £8m and 2.5 ha each, 2 secondary at £27m and 5 ha each - £78m and 17.5 ha
· health – 14 GPs at 2,800 patients per GP, £1,000 per dwelling and 0.1 ha per GP - £16m and 1.4 ha
· libraries – 30sqm per 1000 inhabitants at £3,000 per sqm – say £4m and 1.5 ha
· community centres and places of religion – 10 at £750,000 and 0.1 ha each – say £7.5m and 1 ha
· fire service contribution - £77 per head - £3m
· police - ?
So, for these key elements only, the total is on the order £108.5m and 21.4 ha. How is such an area of land in the OA to be valued? Using the GLA recommended value of £4 million per hectare for land in the OA (see Transport Study p 97) the land element would cost a minimum of £85.6 million. This would give an aggregate cost of for social infrastructure of £194.1 million, say £200 million, excluding public open space. It is worth noting that an open space provision that actually contemplated achieving 1.6 hectares per thousand inhabitants would comfortably exceed this amount, at £256 million at the GLA recommended rate. And there are suggestions that some plots in the OA have changed hands recently at far higher rates – perhaps 10 or 20 times higher, which would put the cost of social infrastructure above that of the transport improvements including the Northern Line Extension. Such calculations also depend critically on whether developers are allowed to design the developments as “child lite”, and thereby successfully argue for a lower assumed child %age, and on whether developers successfully off load social infrastructure land requirements, and with them costs of provision, onto the neighbouring communities. What are your estimates? How much VNEB land will your plan allocate for new social infrastructure?
Chapter 8 – Transport
We think the transport study underlying this Framework, although elaborate and complicated, is not fit for purpose, because based on flawed assumptions
· The PTAL output measure of accessibility, used in the studies, high levels of which mandate denser developments under the Mayor’s Plan guidance is itself flawed. In areas where the issue is congestion and lack of capacity, it measures the time you take getting to the bus stop, plus the time you spend waiting at the stop until the first bus arrives, but if that bus is full, it omits the time you spend waiting until the one comes with room for you to get on it.. (As the VNEB transport study notes “PTALs are only able to represent the ability to reach public transport; they take no account of available capacity either on public transport services or at stations.”)
· The “borough balancing” assumption (p 78, para 8.2) is that for transport planning purposes future growth from elsewhere in the two boroughs is reallocated to the VNEB area, to “ensure that this study remains consistent with the London Plan forecasts” , ie that growth and transport demand elsewhere will be correspondingly less, as jobs and housing in VNEB increase. This seems wholly implausible, given the “Klondyke” nature of VNEB for developers, and the different time horizons of the borough plans and strategies and VNEB, and the overlap of VNEB into two boroughs. (This assumption eg makes the model predict, in the absence of a Northern line extension, a reduction of passengers at Kennington Tube station over time).
· The transport modelling takes no account of the developments at Elephant and Castle
· Para 8.3 says that the intensification of employment in VNEB scenarios leads to “significant increases in inbound as well as outbound morning peak public transport trips”. So what assumptions are being fed into the model about what proportion of VNEB jobs are going to VNEB or neighbouring residents, whose journeys to work would have much less impact? Are these standard assumptions or are they tailored to a combination growth of housing and employment in the same area?
· In this regard, it is not reassuring that the bulk of benefit from the NLE appears to accrue out of area, both as regards origins and destinations (Transport Study p 161). Is the NLE, designed to raise PTAL ratings in the interior of the OA, thereby enabling denser housing development, actually just benefitting through traffic?
· The transport modelling takes no account of the displacement of freight traffic caused by concentration at Stewarts Road
· The Framework’s “Get out of Jail” card to bring the transport accessibility (measured in PTALs) in the middle of the VNEB area up to high levels, is an extension of the Northern Line from Kennington (NLE). Such extensions are notoriously difficult to cost, and often overrun timetable and budget. Eg, while developers were initially to pay for a large part of the Jubilee line extension to Docklands, in the end they paid less than 5% of the total cost of £3.5bn.
· Our cockshy estimate of 4.3 extra kilometres of tunnel, at between £180m to £260m a kilometre, based on 1994 London Underground costings for tunnelling in the Battersea area, uprated for increases in earnings, suggests a cost of between £770m and £1.1bn. We note that the transport study at p 97 estimates a cost of between £670m to £1060m, depending on route chosen.
· Such an NLE is barely cost effective unless built for free by developers, and these costs dwarf other social infrastructure costs (above) and seem beyond the reach of “normal” S106 charges. Developers asked to stump up the best part of a billion pounds will in our view inevitably seek to recoup this sum in extra development density, on what is already expected to be one of the densest developments in the world.
We note, at p 171 and Table 39 of the Transport Study, that further studies are contemplated:
· Further sensitivity tests assessing the value and effects of:
• borough balancing of future OA development; and
• addition of OA development without applying borough balancing.
· Investigation into the effects of interaction of OA development with adjacent development areas such as the development nodes at Waterloo
· Revised Scenario 5 Further modelling to assess the impact of the ‘Revised Scenario 5’ which, subsequent to this study was taken forward in the final OAPF document
· A comprehensive review of the Vauxhall gyratory and other key TLRN routes within the OA, with particular consideration for proposals to improve the urban realm and cycling provision. This should be a joint review by TfL and the relevant planning and highway authorities.
· Investigation of the effects of displacement of freight activities following reallocation of existing land use to new developments; this will be further addressed in the final OAPF document.
· Investigation of station design and provision of capacity at Vauxhall, Battersea Park Road, Queenstown Road and Wandsworth Road NR stations.
To be frank, these should have been the starting points of any study that addressed the realities of the transport issues underlying the Framework, and we await the results of such a study with interest. It should also address the station design, accessibility and capacity of the Grade II listed Kennington Underground station, under a NLE option – the residents of Kennington do not relish the prospect of being held at the ground level gates in rush hours because their limited lift capacity and congested platforms are not equal to the extra transit traffic generated by a Northern Line Extension.
Chapter 9 - Public Realm
Lambeth is the fifth densest populated borough in the country. It is already deficient in public open space, with levels set to fall from 1.54 ha per thousand population to 1.44 ha, against a national target of 2.4 ha. And Lambeth’s attenuated target for new developments is 1.6 ha per thousand, which would yield a target of 64 ha under the VNEB preferred option for dense housing. Against that, we are offered 14.9 ha of mostly linear park! We conclude that VNEB and Lambeth residents are being seriously short changed by the VNEB proposals for open space, even if you supposed that the River Thames counted for half the requirement (and not even planners have yet learnt to walk on water).
Furthermore, the St George’s Sq comparison made in the Framework is flawed – given the built forms, the ratio of breadth to visible height of the 5 storey sides to the square is 4, giving a spacious sense, while the proposed linear park, with 8 to 10 storey sides at minimum, narrows at times to no more than 2.5, giving a more canyon like effect. As regards the built forms, one inward looking, gated Tabard Sq would be bad enough, 33 would be intolerable, leaving perhaps only the American Embassy, with its green and moated security perimeter, as the only major building which has a green edge.
And the Public Realm is not just open space. The King’s Cross Central Regeneration Area, in just 30 hectares, shows what can be done with imaginative master planning to balance housing, employment and the public realm. It offers not only 2,000 new dwellings, 44% affordable, Combined Heat and Power for all buildings, 50,000 sq m of retail, and no less than 490,000 sq m of offices, but also world class public space, with 10 new parks and squares, new theatres, cinemas, exhibition spaces, and new community facilities. The OA here is being far worse served, with far less excuse, and lacks the civic heart and framework its future inhabitants deserve. A heartless development indeed.
Chapter 10 - Tall Buildings
Now that the planning authorities have opened Pandora’s box, planning applications for tall buildings are coming thick and fast, with eye watering residential densities, and under par private amenity space (cf the recent appeal win at 81 Black Prince Road at a density of 1263 per ha and 23 storeys, the recent revised application for the Vauxhall Sky Gardens at a density of 1542 per ha and 36 storeys, a density up by a third on that of the previously granted permission, and the Octave/Bondway Tower application at 1297 per hectare ). Unless the indicative heights and “no palisade” principle in the VNEB are turned rapidly (probably in a very early separate planning document just for that purpose) into material planning rules, the game is lost, and Vauxhall and the Albert Embankment will turn into tall building forests, with the early developments paying well under the odds in S106 payments. And in the 50 hectares designated as “high density mixed use centre focal point for office and retail including housing”, under the OAPF, the employment objective will be lost sight of. This argues against the blanket removal of the SIL designation from the east of the OA, without some effectual substitute designation forcing a reasonable share of employment generating floorspace uses.
In addition, some rule will be needed to limit how much of the 16,000 dwellings can be provided at these excessive densities (perhaps no more than 3%), else instead of VNEB development at 255 per ha, with corresponding infrastructure, we shall start at the 477 per ha of Tabard Sq and accelerate rapidly upwards, with an inhuman public realm, with gated inward looking family unfriendly blocks.
The Framework expresses lots of concern for how towers will affect views from London Bridges – what about our views of Big Ben from Imperial Court or Lambeth Walk Gardens
Chapter 12 - S106 Contributions
Plainly, the indicative £400m for S106 yield sketched in the Framework is quite inadequate to pay for the Northern Line extension, and the tariff would need to be 2 or 3 times higher at least, if the Transport Study’s numbers for the NLE are to be believed. Here are our suggestions:
· make sure that the other social infrastructure is a first call on the fund, not the last;
· why not tier the charges, so that floor space above 30 metres from the ground pays at an escalating rate, given the extra demands it makes on public amenity and services (eg fire rescue);
· common experience with grand developments is that at some stage developers go bust, the authorities panic, and allow the enticing community and green trimmings previously promised to go by the board in desperation to see something built: so make the S106 promises also bind the land through land obligations, so successors in title to the land are equally bound by the enticing promises accepted from their predecessors.
David Boardman
Chair
Kennington Association Planning Forum
29 March 2010
