CAMDEN GREEN PARTY From: "Sian Berry" >To: dc@odpm.gsi.gov.uk >CC: enquiries.gol@go-regions.gov.uk >Subject: Urgent letter requesting call in of Kings Cross Central planning >applications >Date: Tue, 07 Mar 2006 11:27:23 +0000 > >The letter below is also being sent today by fax and post: >Camden Green Party >c/o 129D Fortess Road >London >NW5 2HR >camden@greenparty.org.uk/sianberry@hotmail.com >7th March 2006 > > >The Rt Hon John Prescott MP >First Secretary of State >Office of the Deputy Prime Minister >26 Whitehall >LONDON SW1A 2WH > >Dear Sir, > >We are writing to request the call in of planning applications 2004/2307/P >and 2004/2311/P, submitted to Camden Borough Council by Argent Kings Cross >for the development of Kings Cross Central. > >We have already submitted our objections to the proposals, setting out why >they will not provide the sustainable community, local jobs and community >facilities needed in the area, and why the mix of housing, level of >car-parking provision and environmental proposals contradict the Boroughâs >Unitary Development Plan (particularly Alteration No 1, relating to Kings >Cross, adopted May 2003) and the regional London Plan. > >It now appears that Camden Borough Council may grant permission to the >plans at its Development Control Subcommittee meeting on 8th/9th March, >attaching only extremely weak conditions that would leave the >contradictions of these planning policies in place. > >This project is one of the largest developments in Western Europe and is of >regional and national importance, not just local significance. The area has >the potential to be a flagship development, located as it is in the heart >of London and at the new gateway to Europe. As such, we believe that it is >inappropriate for this decision to be made by the local authority at this >time. > >There is also a great deal of local controversy surrounding the current >proposals and their failure to meet the standards of environmental design >and affordable housing needed on this site. > >We therefore urge you to call the applications in. > >Details of deviations from local and regional planning policies which are >of concern to Camden Green Party are below. > >1. Housing > >The plans and proposed conditions allow for only 44% affordable housing >(750 units out of 1700 units). In terms of gross external floorspace, the >percentage is even lower ö 39%, which reflects a bias in the planned >affordable housing towards smaller units. >ð Only 40 units (8% of the 500 social rented units) are 4-bed for large >families >ð Only 125 units (25% of social rented units) are 3-bed for families >ð None of the intermediate housing is 3- or 4-bed > >This mix of housing is contrary to the local consultation findings, where >the community indicated a strong need for family homes in Kings Cross. It >is contrary to Camdenâs UDP and the London Plan, both of which specify a >50% target for affordable housing in all new developments. > >The UDP also identifies an urgent need in Camden for family homes within >social rented housing and in intermediate housing. > >There is no good reason why Kings Cross Central cannot meet the London plan >and UDP targets for affordable and family housing, being effectively a >Îblank slateâ, and therefore no reason why the Council should accept any >shortfall proposed by Argent. > >Section 3.3.52 of the SPG for Alteration No. 2 of the UDP states explicitly >that ãThis [50% target for affordable housing] is easier to achieve in >larger schemes but should be the starting point for all housing proposals.ä > >2. Open spaces and biodiversity > >Section KC10 of Alteration No. 1 of Camdenâs UDP covering the Kings Cross >Opportunity Area states: >ãThe Council will grant planning permission for development proposals for >the Kingâs Cross Opportunity Area that include well managed and maintained, >high quality open spaces that: >1. provide recreation areas accessible to where people live and work >2. incorporate a network of linkages for pedestrian and cycle ways through >the site >3. protect and enhance Camley Street Natural Park and the Regentâs Canal, >and >4. complement and separate groups of buildings and other features.ä > >The grassed open spaces in the plans are not sufficient for sports or other >exercise, and no new space for wildlife is proposed, even to replace the >existing areas of biodiversity on the brownfield site. > >The amenity of Camley Street Natural Park is threatened by a new bridge >across it, and the biodiversity of both Camley Street and the canal is >threatened by the overshadowing that will result from the tall buildings >proposed for the southern side of the canal. > >3. Regentâs canal > >Section 13.69 of Alteration No. 1, Amendment of Chapter 13 of the UDP >covering the Kings Cross Opportunity Area states, >ãIt is important that the redevelopment of the area captures the potential >that the canal offers. In particular the Council will seek development that >achieves a successful balance of: >ð the protection of the historic canal environment >ð the enhancement of the canalâs biodiversity >ð access to and along the canal for pedestrians >ð the use of the canal for recreation >ð the use of the canal for transportation, especially during the >construction of development (sic).ä > >The provisions in the UDP for the Canal have been almost totally >disregarded, with tall buildings overshadowing the canal, reducing the >utility of the canal for biodiversity and wildlife, as well as its >recreational amenity. > >While access for pedestrians and cyclists has been opened up, plans for >making actual use of the canal are absent, with no useful transportation >use proposed, despite this being specified in the UDP. > >4. Small business provision and local jobs > >Section 13.41 of Alteration No. 1 of Camdenâs UDP covering the Kings Cross >Opportunity Area states, ãThe Opportunity Area should provide accommodation >for a range of business uses that contribute to both the London-wide and >local economies. Office space for large corporate organisations as well as >small business units should be included. This will help ensure a range of >employment opportunities are created, at various skill levels, and provide >for a mix of business uses.ä > >The current plans, and the proposed conditions and obligations, fail >utterly to ensure adequate space and support for small local businesses, >independent small retailers and business start ups. > >No conditions or obligations have been made to ensure small business or >retail space will be available at affordable rents for local people, and >Obligation 102 of the proposed Section 106 Agreement only asks for 4,000 >sqm of B1 floorspace to be for small businesses. This clearly a bare >minimum at just 0.9% of the total B1 floorspace, and will not provide any >significant opportunities for small, local businesses and jobs. > >5. Car-free housing > >One of the most notable deviations from planning policies is in car parking >provision, where the requirements of the local UDP are clear. > >Section TR16 of Camdenâs UDP states, ãThe Council will encourage car-free >housing developments in locations: >a. which are easily accessible by public transport; >b. where there is a range of amenities, including shops and leisure >activities; and >c. within a controlled parking zone.ä > >Section KC7 of Alteration No. 1 of Camdenâs UDP covering the Kings Cross >Opportunity Area states, ãThe Council will grant planning permission for >development proposals for the Kings Cross Opportunity Area where proposed >car usage and car parking provision is at minimum levels necessary and >where the provision of car-free housing is maximized.ä > >Section 13.55 states, ãIn accordance with PPG3, PPG13 and the Urban White >Paper, and by virtue of the exceptionally high levels of public transport >accessibility enjoyed by the Opportunity Area, the Council expects to see >car parking provision at very low levels· Based on current circumstances >within the Borough, the Council will seek a significant proportion of >car-free housing possibly up to about the 75% level.ä > >Section 13.57 states, ãThe Council expects to see measures such as car free >residential schemes·ä > >The Kings Cross area has some of the best public transport links in the UK. >However, the development proposes no properly car-free housing at all, with >even the student accommodation including car parking spaces. The overall >provision of car-parking is 800 spaces for the 1700 housing units, or 0.47 >spaces per unit. This provision bears no relation to the requirements of >the UDP. > >Camden Council is proposing to accept the level of parking provision >suggested by the developer despite the serious deviation from planning >policies, and this is unacceptable. There is no reason at all why car-free >housing at or even above 75% could not be achieved in Kings Cross Central. > >6. Renewable energy use > >Section 2.3.2 of the Sustainable Design and Construction section of the >London Plan Draft Supplementary Planning Guidance, published March 2005, >states, ãThe Mayor requires a proportion of energy demand in new >development to be generated >by renewables on site. The Mayorâs Energy Strategy suggests that this >proportion should >be 10 percentä > >However, the plans and proposed conditions allow for the contribution of >renewable energy other than biomass CHP on the site to be only 0.6%. In >order to bring the renewable energy provision up to 10%, the conditions and >obligations attached to the conversion from fossil fuel CHP to biomass >under the proposed Section 106 agreement are incredibly weak and can easily >be circumvented by the developers. Full conversion is required only by the >completion date of the development and then only once supplies of >appropriate biomass can be sourced cheaply by the developers. > >This is a highly unsatisfactory way of achieving the 10% target for >renewable energy, and shows a lack of vision or commitment to renewable >energy by the developers and the Council. > > >Our views on these matters, and others, are supported by the Kings Cross >Railwaylands Group and other local community and heritage groups, several >of which will also be writing to you on this subject. Local groups have >been encouraged by the Council to divide up topics to avoid duplication and >other groups will set out additional deviations from local and regional >planning policies in their letters. > >In addition, more than 30 other community groups are lodging urgent >objections with the local planning committee. We also support their >objections on subjects other than those we have outlined. > >Please inform us of your final decision on this matter. > >Yours sincerely, > > >Sian Berry >On behalf of Camden Green Party > >cc. Liz Meek, Regional Director, Government Office for London. Riverwalk >House, 157-161 Millbank, London SW1P 4RR