King's Cross Railway Lands Group (KXRLG): response to Mayor's Sub-Regional Development Framework for Central London

Context Individuals and groups (including KXRLG) had a 28 Oct deadline for responses to the Mayor's sub-regional development framework (SRDF) for Central London. That document is both part of the implementation of the 2004 London Plan (including a special section on what will be permitted at King's Cross) and also a first trawl for ideas about the next London Plan. It is thus very important that everyone responds.
Chis Gidden / Michael Edwards went to a consultations about it on 7 July and 15 September, various members have been involved in drafting this and it was discussed by the management Committe on 31 October (after GLA gave us a short extension). Text of SRDF is on the Mayor's web site [ link ].

Context: the KXRLG was founded in 1987 to represent the interests of groups and individuals living or working in the areas round the Railway Lands and specifically to work towards a redevelopment of the Railway Lands of a kind which would meet local, alongside other, needs. The Group's members have been (a) represenatives of organisations in the area (TAs, TRAs, small businesses, environmental, housing and transport groups) and (b) individuals resident and / or working in the area. The group was highly active in public consultation and debates surrounding the LRC scheme of 1988-90 and the KXT project; then again in calling for the re-routing of the CTRL and lobbying the House of Lords to great effect during the passage of the CTRL Act 1996. It is strongly engaged now in representing local interests to LBI and LBC during the preparation of the Planning Brief (although deeply discontented with the outcome) and in responding to Argent's successive Planning Apllications. Its work, supported by the magazine "Network", an excellent web site (www.kxrlg.org.uk) and 3 or 4 open General Meetings each year, has been supported to varying degrees over the years by small grants from both Boroughs, Central Camden SRB/NR and charitable bodies. It is constituted as a Company Limited by Guarantee and the Management Committee, elected annually at the AGM, constitutes the Board of Directors. This response draws upon the KXRLG's established policies, hammered out through months of debate and discussion, and has been approved by the Management Committee.
 

For members' information: highlights The SRDF (and four others for N S E and W london) are a kind of bridge between the London-wide strategies in the London Plan and the Boroughs and localities of London (given added importance by the Inspector/Panel of the Examination in Public). The preparation of the SRDF has been the main arena for compromise and discussion between the GLA and the Boroughs - tho' mostly done rather in private. The document is mainly about how the provisions of the London Plan would work out at local level.

The SRDF also reports (in a patchy way) on progress since the London Plan, effectively saying that we are under-achieving on housing (especially social housing to rent) and over-achieving on the provision of office space (especially in parts of Central London outside the very centre (= outside the Central Activities Zone CAZ = West End + Holborn/Covent Garden + the City (which is in the "east" sub-region). This is good news for King's Cross because it heightens the need for the Mayor and the Boroughs to stiffen their position in favour of social housing to rent and to reduce the calls made in the London Plan for a massive expansion of offices.

Despite all this, the SRDF clearly does not expect to slow or stop displacement of ordinary people or of small and medium enterprises: on page 10 para 19 they say, as a simple statement, "Local communities and small businesses may be displaced by higher value Œworld city¹ uses, especially in the Œfringe¹ areas around the boundaries of the CAZ." We challenge that most strongly: London Plans should be a major instrument for stopping and reversing this displacement - in the interests of equity, community cohesion and inter-generational sustainability, and in the interests of SMEs' contribution to diversity, BME employment and local employment.

The London Plan authors are their own worst enemies on this because the main thrust of their 2004 proposals was for more Argent-type schemes, but they do not acknowledge that these are a major element in displacement.

Housing. In the wards around King's Cross the displacement of low- and midddle-income people through the property-market effects of "regeneration" is already advanced through:

The impending completion of the CTRL and the impact of the Olympics both seem bound to acellerate this displacement / gentrification. The impending redevelopment of the Railway Lands "Opportunity Area" offers a unique (once-only) opportunity to compensate for these recent changes and to minimise the further damage.

In the light of the SRDF's finding that production of social housing to rent in the Central sub-region is falling behind the (modest) target set in the London Plan, the KXRLG considers that the SRDF should be revised in such a way as to correct for that earlier under-achievement by raising the affordable housing, and especially the social housing for rent, requirement for the opportunity area.

Local Economy. At King's Cross we are acutely conscious that a very distinctive economy has grown up here over recent decades: virtually no large corporations (or even branches of large chains). It is the opporite of "clone-town-Britain". Apart from local government and the railways, the economy has consisted of small and medium enterprises, self-selected as ones which need central London locations at low rentals: charities and campaign groups (like the cradle of The Big Issue, the Peace Movement, many civil rights and trades union bodies) and the professsional lawyers and others who support them. Another segment has been craft and specialised retailers, arts and cultural bodies. This has not just given the area some of its most positive characteristics but has also tended to employ people with shorter work trips than do the larger organisations - many of these workers being local. (UCL survey of firms 2000 http://www.bartlett.ucl.ac.uk/research/planning/kx ).

Many of these firms (and even more of the mundane car-repair and similar businesses) have already been displaced by the CTRL works and from the Opportunity Area, have departed to cheaper locations or ceased trading. Most of the survivors are very anxious about the impact of impending change on rents, rates and the affordability of premises.

The potential of the new, secondhand and antiquarian book trade to blossom in the area (close to the BL and University) is clearly very strong and there must be many other potentials not yet envisaged. Clearly it would be unrealistic to expect that King's Cross (either inside or outside the Opportunity Area boundary) will remain a very low rent area. However we are deeply concerned to see that the SRDF and the Appendix on the KX OA seem to contain no provisions to ensure that a wide variety of unit sizes of business premises are created or retained, nor that parking/loading arrangements are planned with SMEs in mind. Economic diversity is just as important in our view as biodiversity and we can already point to its erosion.

There is a lot of unemployment in the area but more corporate office jobs will not reduce this problem: there are hundreds of thousands of such jobs within a 20-minute bus ride already. The barriers to local people entering work are diverse. Lack of relevant skills is one factor but others include ill-health (of self or dependant), child care problems and benefit traps which are very severe in Inner London. http://www.bartlett.ucl.ac.uk/research/planning/kx ). We see little in the SRDF about these problems.

Further Comments on Appendix A17 Opportunity Area King's Cross (see also above sections)

In many respects this is an excellent document and we are gald to be able to welcome most of what it says. However we have the following objections and suggestions.

Procedure and timing. The LP runs to 2016 while the development of this OA will extend well beyond that date. We consider (and have made representations to LBC and LBI) that no applicant should be given a blanket outline permission spanning development over 15-25 years because the planning authorities (Boroughs and Mayor) would thereby be abrogating their responsibility to adjust development to changing environmental and policy imperatives. It is already clear that the desirable mix of uses foreseen in the LP should be changed, only 2 years later. Accordingly we consider that the Mayor should not approve permissions covering development beyond 2016 but instead insist, in consultation with the Boroughs, on a phased approval process for the OA.

Housing
Appendix A17 indicates "1250 LP target homes" without stating whether that is within the 2016 date or not. We assume it is the target to 2016. No affordable percentage is stated. The Boroughs' Planning Brief contained a target of 1800 by 2020. We have 3 comments upon this section: (i) In the light of the increased imperative for more affordable housing in the Central SR (see above), we consider that these target figures should be doubled: 2500 by 2016 and 3600 by 2020. (ii) Since the affordable housing content (and especially the social rental) is of paramount importance, we do urge the Mayor to express these targets in precise numbers, not just as percentages. Thus the OA should deliver 2500 housing units by 2016 (1250 of them affordable, including say 1000 social housing to rent) and 3600 units by 2020 (1800 of them affordable, including, say, 1200 social housing to rent). (iii) We do not consider that 'units' is an appropriate unit for control. We consider that the affordable housing units should be specified as being of average net lettable floorspace of 60 square metres to ensure that a good range of sizes can be acommodated. The very poor delivery of larger units in the Central SR in the last few years lends weight to the importance of this proposal.

Employment
The broader remarks above apply. We have also been particularly concerned about the escalation in the proposed figures for office employment and even more so for floorspace (since the conversion coefficient from jobs to floorspace was surreptitiously changed in the Planning Brief from 10msq to 16msq per worker). In our view the overall LP employment target of 11,400 jobs of all kinds (apart from railway employment) was more than enough, and suggest the figure should grow to not more than about 15,000 when the site is fully built (assumed to be 2020). This would be accommodated in 150,000-200,000 sq m if all the employment were in offices (though we realise that a wide range of kinds of work and workspace are desirable).

For unemployed people in the surrounding estates, and elsewhere in the locality (whose interests we consider we represent) the imperative is for the barriers to their employment to be removed. In some cases these barriers are their lack of language or job skills and for those people educational and training provisions are necessary. For others the barriers reflect their own or relations' ill health; for others again the problems relate to affordable child-care. In all the above cases the Mayor should insist that developers in the Opportunity Area make appropriate provisions and that Section 106 agreements enforce these provisions on developers and their lessees and assigns. There is also evidence, however, that some of the non-employment in this area is the result of benefit traps: many people simply cannot afford to take low-paid jobs if that means giving up their benefits, and risking delay in reinstating benefits if the job ends. This is a problem on which the SRDF is silent but on which the Mayor and the GLA/LDA should be campaiging. actively.

Blue Ribbon (the canal)
The group and its member organisations have long been concerned about over-development of the site. We are particularly alarmed by proposals in which a proposed cliff of buildings along Goodsway would - if permitted - land the Regent's Canal in deep shade for much of the day and much of the year. If the Mayor is serious about protecting the Blue Ribbon he must protect the light falling on the canal and we should point out that buildings stepped-back to achieve this would be a delight for their users.

There is an annexe on each of the "opportunity areas". Our one is pages A17-A19 [ copy attached here ].

revised 26 October 05

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