Concerns abut the O2 Application provision of Affordable Housing, Dwelling Mix and Single-Aspect dwellings

This document highlights the non-compliant aspects of the O2 Centre redevelopment proposals against specific planning policies (from the London Plan, the Camden Local Plan, the Fortune Green and West Hampstead Neighbourhood Plan and the NPPF) relating to Affordable Housing, Dwelling Mix and Single-Aspect Dwellings.

It also calls attention to a recent letter to Councillors by the Chairman of the London Assembly Planning & Regeneration Committee, giving the findings of their Housing Typologies Investigation, including the problems and excess financial and carbon costs associated with excessively tall buildings. Letter (london.gov.uk).

Introduction

Inadequate % Affordable Housing, and insufficient % Low Cost Rental within the affordable housing total

Only a 35% proportion of affordable housing is provided on site, significantly below the policy requirement of 50% specified in Local Plan Policy H4, and in London Plan Policy H4. This requirement is also specifically strengthened by Policy 1(i) of the Fortune Green & West Hampstead Neighbourhood Plan. 

The current affordable housing offer is precisely the least affordable allowed under the threshold approach based on not just one metric, but three. The ‘Financial Viability Assessment’ (FVA), which shows a marginal return and is used as justification for the very minimal amount of affordable housing. It needs careful review by an independent expert not someone already deeply involved in preparing the current Planning submission for the developer. To understand if the viability is genuinely as poor as is being asserted, there must be an impartial assessment. 

Duncan Bowie, former lead housing planner at the GLA and one of the key instigators of the London density matrix,…predicts that the unilateral pursuit of higher densities and the abandonment of the London density matrix will do all of the following: lower affordability, reduce sunlight levels, restrict privacy and – since it reduces amenity space – create inadequate housing for families.  Housing density: does it stack up? from Building – 28 March 2018

Landsec should be asked to consider cost reduction measures that would allow the percentage of affordable housing (and the percentage of low cost rental housing within that) to be improved. Such measures could include reconsideration of the wasteful (in terms of both carbon emissions and cost) proposal to demolish the O2 Centre and replacing the floorspace for a proportion of its amenities and retail activities piecemeal through the scheme.

The measure of % affordable housing expressed as % Units, rather than by % floor area would create results 4% worse against both the 35% overall affordable target (Policy H4), as well as against the Low Cost Rental target of 60% of all affordable housing (Policy H7 of London Plan). This is glossed-over in the developer’s Affordable Housing Statement, and means even greater non-compliance against both Policies, than already appears to be the case.

Inappropriate Dwelling Mix

In the absence of controls, developers (both public and private sector) will tend to reduce the size of dwellings being developed whilst trying to minimise any reduction in value. Studies indicate a pattern of increased “cramming” of rooms (such as additional bathrooms) into dwellings leading to smaller habitable rooms and significant reductions in storage space.

Mayor of London – Housing Space Standards -2006

The Camden Local Plan Policy H7 states “The Council will aim to secure a range of homes of different sizes that will contribute to creation of mixed, inclusive and sustainable communities and reduce mismatches between housing needs and existing supply”. 

The dwelling mix currently offered is heavily skewed towards excessive numbers of studio/1 bed flats, and far too few larger 3-bed and no 4-bed units. This will simply encourage more transient single tenants, and discourage growing families from settling in the area long-term; families will instead continue to be forced to move out of Camden altogether in search of larger, more affordable, housing, as many already do. This is already a major problem in West Hampstead. It must not be exacerbated by the O2 Centre redevelopment.

Excessive proportion of Single Aspect Dwellings

Some 45% of the 608 homes proposed in the detailed proposal will be single aspect, broken down as follows: Private – 420 homes, 210 single aspect; Social rent – 104 homes, 10 single aspect; Intermediate – 84 homes, 52 single aspect. 

This flagrantly breaches the London Plan Policy D6 that housing development “should normally avoid the provision of single aspect dwellings.” No effort is made to meet the condition set out in London Plan Policy D6 that “a single aspect dwelling should only be provided where it is considered a more appropriate design solution to meet the requirements of Part B in Policy D3 Optimising site capacity through the design-led approach than a dual aspect dwelling, and it can be demonstrated that it will have adequate passive ventilation, daylight and privacy, and avoid overheating” resulting in a significant policy conflict.”

WithThanks to Eric Peel

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