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).
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.”
Greater London Planning Report April 2022 – Conclusion
London Plan policies on housing, town centres, social infrastructure, public open space, affordable housing, urban design, strategic views, historic environment, transport, and climate change and the environment are relevant to this application. The application does not yet comply with these policies, as summarised below:
• Land use principles: The comprehensive redevelopment of a highly accessible, under-utilised site, made up of large areas of surface-level retail car parking, between two town centres and within a growth area, for the delivery of new housing and town centre uses, is strongly supported; subject to further consideration of the scale, type, and location of town centre uses. The demolition of the existing O2 Centre has been assessed against Circular Economy principles and parts of the existing substructure could be retained, which is welcome
• Affordable housing: 35% (by habitable room), split 60% London Affordable Rent and 40% intermediate rent within both the Detailed and Outline Phases. The applicant should confirm the affordability of the tenures proposed, and an element of London Living Rent should be considered. Subject to this, meeting all other policy requirements, and investigating grant funding; the proposals may be eligible to follow the fast track viability route.
• Urban design and historic environment: The site is not identified as appropriate for tall buildings and there are concerns that the scale and massing of Outline Phase 3 results in some areas of non-compliance with London Plan Policy D9(C), including ‘less than substantial’ harm to the significance of heritage assets.
• The applicant should provide clarification on the height strategy in response to site’s topography, consider means to reduce the level of harm to heritage assets and townscape, and better respond to Policy D9.
• The proportion of single aspect homes for the Detailed Phase should be reduced and family-sized removed, and separation distances between homes increased. Parameter Plan and Design Code changes are required.
• A revised Fire Statement is required.
• Transport: The move to a car free development in this highly accessible location is strongly supported; however, the potential to facilitate active travel, mode shift, and improved legibility is not yet realised. Improving the accessibility and capacity of public transport, in the context of displaced car trips, increased density, and range of land uses is a priority.
• The safeguarding of areas of land for the improvement of adjacent stations is required and discussions are ongoing concerning step free access. Improved bus access and infrastructure must be secured.
• Climate change and environment: Further information is required on energy, whole life carbon, circular economy, green infrastructure, water, and air quality.
“Feeling safe” was stated as a primary goal in the Safety Zoom Meeting consultation with Landsec before the application was submitted and it’s a key concern in the design of the congested O2 scheme but ‘feeling’ safe does not mean that residents will be safe on the site.
Statements from the Landsec application 2022/0528/P –
“Natural surveillance across the landscape is a core feature within the design with building footprints shifted to increase surveillance over the linear park during the masterplan evolution and ground floor uses (including cafes and retail outlets) offering passive surveillance.
Additionally positioning of windows and balconies has been considered to improve natural surveillance over children’s play areas.
The main movement networks across the proposals have been designed with clear visibility, lighting and good sight lines alongside the creation of active spaces.”
The safety and security sightlines diagram (shown above) is unhelpful as it fails to show the perspective in relation to the ground. In fact, at heights above 5 storeys, sight lines to the ground are limited and surveillance from that level upwards is unreliable as residents in the buildings will not routinely be at their windows nor will the ground be clearly visible.
This is also true in terms of amenity for families. Parents are likely to be unable or unwilling to supervise children in play areas from balconies in flats on higher floors. In fact, there is evidence from the GLA Planning and Regeneration Committee that: ‘…rooftop play in a tall building is problematic because of microclimatic conditions and difficulty with supervision. In the past the Committee has recommended family sized homes to be located no higher than on 5th storey… and that consideration should be given to design of access and surveillance of children’s play space and amenity space for children, specifically to amplify C1.4.2 in relation to tall buildings.
In case of Emergency?
No systematic patrols are indicated and the alarm points are linked not to the police but to a single concierge post on the site, in one building and relying on CCTV. There are hidden, unsupervised corners all over the site which cannot be fully lit and the application Environment statements contain minimum information about this vital safety consideration in a cramped, high rise setting after 11pm at night
Statements from the Landsec application 2022/0528/P – in italics
Environment statement Vol 1
a) 4.11.1 An integrated lighting strategy will ensure that the public realm is safe and accessible after dark. Light levels will be specified in accordance with the relevant standards including BS 5489-1:2013 and ILE Guidance
The latest Crime Statistics for West Hampstead put Violence and Sexual Offences at 20% – second place only to Anti-Social Behaviour. This is an alarming statistic and the Landsec proposal would do well to make more ambitious lighting and security provisions.
b) “The security of the Proposed Development will benefit from continuous public presence in well-lit, monitored, non-threatening spaces and the provision of a high-quality, well-maintained environment which people respect and in which people behave appropriately.”
Claiming an environment will be ‘well-maintained’, for which no test can be made from this theoretical application, does not alone compel people to ‘behave appropriately’.
c) It is anticipated that the commercial aspects of the Development will close before the Institution of Lighting Engineers (ILE) guidance curfew time of 11pm.
If, after 11pm there is no continuous retail activity and it is unlikely to be reliable ‘continuous public presence’ -how will site-wide monitoring be managed? Will contact with services to access urgent or emergency help be prioritised? Will any staff be trained in First Aid?
The Fire Statement in the application is generic and lacks detailed reference to height but makes a very significant point:
‘All blocks within the buildings are served by single staircases which will be 1200mm wide and are therefore compliant as per guidance in BS 9991’
Detailed Planning Application : first Construction Phase
N3-E, N4 and N5 (coloured dark and light orange and yellow). The N3-E block consists of 10 storeys. The N4 and N5 buildings are each split into four blocks, A-D. The N4 A, B and C plots comprise a single building that has between 9 and 14 storeys (the connection between N4-A and N4-C has 8 storeys. N4-D has 10 storeys. N5 A, C and D plots comprise a single building that have between 9 and 15 storeys (the connection between N5-A and N5-C has 8 storeys. N5-B has 10 storeys.
Landsec’s application is said to conform to BS9991. This is technically true but short-sighted. The revised edition of BS 9991 Fire safety in the design, management and use of residential buildings, published in draft format in August 2021 proposes significant change to the design of single stair residential buildings.
The smoke ventilation arrangements in case of fire are also of concern. Current guidance states that: ‘Residential buildings with a floor level above 18m – (5-6 storeys) with a single stair should be provided with a pressurization system (in accordance with BSEN12101-6), protecting the staircase, firefighting lift shaft and lobby.
The fire safety strategy in the O2 construction uses smoke shafts rather than a pressurization differential system (PDS), ‘to provide smoke ventilation in escape stairs, common lobbies and corridors in residential buildings – as required by Approved Document B and recommended… if the building is residential, taller than 18m and the new draft of BS 9991 is being followed.’ These changes should force building designers to reconsider their approach. Whilst some developments may proceed with a single stair design, provision of a pressurization system would add an extra level of safety that would maintain a smoke free stair in the event of a fire There is no mention of such a system for any of the single staircase buildings in the Hoare Lea fire statement for Landsec’s scheme of 8-16 story towers.
‘Where a stay-put strategy has been designed into a proposal, the Fire Statement should include additional measures that have been engineered and designed into the proposal in the event that either; the asset fails to successfully deliver on the stay-put strategy, or, residents decide to evacuate the building. For this purpose, in addition to recommendations made within the chosen design code(s), further passive and active measures may be provided…the applicant should provide clear details within the Fire Statement. Where lifts have been proposed in a development, London Plan Policy D5 (B5) requires a minimum of one lift per core to be an evacuation lift. The provision of evacuation lifts may be utilized to propose alternative evacuation methods to mitigate the risks involved with any failure of the stay-put strategy.” from the London Plan – “High-rise residential development proposal with a ‘stay-put’ design strategy‘
N.B. Thames Water has reported additional concerns about providing even sufficient water pressure on the site for residents. How would resources in a major fire be managed? There is little detail in the statement in terms of more complex evacuation demands, a secure water supply or access to flats at higher levels should the proposed smoke ventilation fail.
From : O2 Masterplan Site, Finchley Road Volume 1: Environmental Statement – Main Text Chapter 3: Alternatives Plowman Craven 43284 January 2022 The sequence of the main alternatives, demonstrating the design evolution of the Proposed Development. LBC feedback in bold
LONDON BOROUGH OF CAMDEN Pre-app Meeting 01 – June 2020 At the first pre-application meeting with Camden, AHMM presented an early iteration of the Proposed Development. The main elements were: • The reduction of the overall site boundary; • The replacement of a road through the centre of the site with a linear park; • The introduction of a large public green space at the Western end. At this stage the principal idea was for a central avenue to run diagonally across the site, linking West End Lane and Finchley Road and improving connectivity between east and west with a landscaped public thoroughfare
Feedback: Many of the ideas presented were welcomed by the planning officers, however there was a general feeling that there should be further investigation into the masterplan layout to ensure that the several options had been explored. In particular, officers felt that the building forms should have more variation and that the position of the pedestrian thoroughfare should be considered further. The quality and use of public spaces should also be investigated in more detail. It was concluded that the next meeting would be in a workshop format to discuss ideas more widely.
LONDON BOROUGH OF CAMDEN Pre-app Workshop 01 – July 2020 At the first design workshop AHMM presented a series of high level sketch proposals looking at differing approaches to site layouts. The main conclusions from the exercise were: • To relocate the entrance to the pedestrian link further south on Finchley Road; • To retain the existing vehicular access on Blackburn Road to allow for a more complete pedestrian thoroughfare; • To follow the site’s topography and geometry with the pedestrian route.
Feedback: The exploration of different approaches was welcomed; however, the officers still did not get a sense of the variation of geometries and plot sizes. There were queries regarding the public spaces and how these would feel – particularly that of Blackburn Road.
LONDON BOROUGH OF CAMDEN Pre-app Workshop 02 – September 2020 At the second design workshop AHMM presented more detailed sketch proposals focusing on the quality of public streets and spaces, as well as initial ideas about the building heights. To take advantage of the potential for sunlight and views from the south facing aspect, the plots were rearranged into a chequerboard-like pattern. Further development gave more definition to the public spaces with clearly delineated thresholds where the enter the avenue. Each public space between the building plots extends its character across the avenue to signal their uses, adding to the pleasure of pedestrians on the avenue. The overall masterplan envisaged: • A series of pocket parks with unique and specific characters; • Two large public spaces with defined uses; • A variety of building sizes and plots; • Greater permeability along the frontage to Finchley Road.
Feedback: The approach to public realm was welcomed, however officers were not convinced that the public spaces were large enough, with a clear and recognisable hierarchy between them.
LONDON BOROUGH OF CAMDEN Pre-app Workshop 03 – October 2020 At the third design workshop AHMM presented a series of options for the masterplan layouts exploring the position, hierarchy and scale of public spaces.Two options were considered in greater detail, an iteration of the previous proposals, and a new approach which moved the linear (park) The main changes were: • Rearranging the plots to consolidate the buildings on the north of the site, giving this part greater density while increasing and consolidating the public realm to the south; • Taking the opportunity this move afforded to create a linear park along the south; • Preserving the public spaces between the buildings to add area and variety to the public realm.
Feedback: The new approach consolidating the public space to the south of the site was welcomed and it was felt this gave a good sense of hierarchy to the sequence of public spaces. The scale comparisons were well received and led officers to conclude that those proposed were appropriate in scale for their uses
LONDON BOROUGH OF CAMDEN Pre-app Workshop 04 – October 2020 At the fourth design workshop AHMM presented a series of small developments to the masterplan.They proposed buildings along the southern boundary, and the eastern and western ends of the site. Two different approaches to explore the massing of the buildings and their effects on townscape were also presented, before the workshop concluded with a discussion of residential typologies. Comments at the previous workshop led to the following amendments of the masterplan:
• Buildings on the site’s southern, eastern and western edge; • Connections to the east and west; • More developed designs along Finchley Road to establish a distinctive character for this part of the site; • Manipulating the public realm to maximise dual aspect accommodation; • Introducing a corridor for wildlife; and • Address circulation by looking at building entrances and cyclists’ requirements
Feedback;: The officers broadly welcomed the new iteration of the masterplan while expressing some concern about the loss of permeability and geometric character of the town square. The work on typologies was appreciated but more information on tenure, unit mix and resident experience is needed. In addition: • Exploring the character of each area was also welcomed; • The studies of typologies made a good start but invited further detail about forms of tenure, mix of units and the experience residents will have; • Further detail about the nature of the ground floor and the spaces between the buildings was also sought; • Blackburn Road and the western part of the site needed more focus; and it was thought inappropriate to have a building to the south of the square.
LONDON BOROUGH OF CAMDEN Pre-app Workshop 05 – October 2020 At the fifth design workshop AHMM presented a focus on residential typologies, including number and position of dual aspect homes, and the relationship between the courtyards and the wider public realm as shown on plan and in section. There were also minor revisions to the masterplan which included reinstating a triangular public space at the eastern end, while the building to the south of this space was amended to incorporate a lower ground floor mews to activate the southern edge.
Feedback: Responses to points raised at the previous workshop included: • Improving N5 tenure; • Studies of brick types and the ‘Arts and Crafts’ character of the local area to respond better to the context.
LONDON BOROUGH OF CAMDEN Pre-app Workshop 06 – January 2021 At the sixth design workshop – AHMM presented Design developments to several areas of the masterplan. The building line and massing of the plots in the centre of the site was a particular focus, with amendments to the western edge of Blackburn Road and the street between the Nido and plot N7 also explored in more detail. The main new features presented were: • Maintaining the route for cyclists through to Blackburn Road West; • A preliminary strategy for Blackburn Road to accommodate bins, bicycles and cars • Massing view from West End Lane; • Exploration of options for retaining and re-using parts of the 02 Centre; • Improvements to the linear park to work better for cyclists and pedestrians; • Defined locations for bus stops; • Making the courtyards more private and secure for children to play in them. Studies of brick types and the ‘Arts and Crafts’ character of the local area to respond better to the context.
Feedback: Design development of the building line and shoulder height was welcomed; • Scale and character of the building on the western edge of Blackburn Road was broadly supported; • More clearly defined purpose of the space between the Nido and plot N7 was sought, to take account of its role as a route and location for buses to turn; • The strategy for the massing was broadly supported though exact heights of individual buildings not agreed, and deferred to the next workshop.
LONDON BOROUGH OF CAMDEN Pre-app Workshop 07 – February 2021 At the seventh design workshop AHMM presented focused on newoptions for massing across the masterplan. Each option contained the same built area and number of masterplans, though these were massed and distributed differently. Base option Massing as presented in the previous workshop. Linear Option Reducing the height on buildings on the central plots, and raising heights of those at either end. Stepped Massing A A single tall building at the western end, with height concentrated on the northern side of the plots. Stepped Massing B No tall buildings with height distributed evenly across the site
Feedback : Officers acknowledged that the effect of the options significantly reduced the impact of the development from agreed viewpoints, but believed there needed to be stronger justification for the proposed density in comparison to other schemes in and beyond Camden; • Public benefits offered by the scheme could be taken into account when considering density; • The overall approach to affordable housing, amount of publicly accessible space, the impact on public transport, education and healthcare provision needed clarification; • Any tall building should not be within the square; • The horizontal expression of the facades on the three central plots gained positive comments, though variation would be required; • Strategies for distributed height generally appeared to be logical; • The scale and character of Blackburn Road was well received; • The corner of Blackburn Road needed clearer definition.
LONDON BOROUGH OF CAMDEN Pre-ap Workshop 08 – March 2021 At the eight design workshop AHMM presented a significant revision to the Masterplan.The principal points were: Altering the geometry along Finchley Road and reinforcing the junction between Finchley and Blackburn Roads; Re-aligning the corner of Finchley and Blackburn Roads allows two blocks to be located closer to Finchley Road and to be longer; Framing the central terrace on Finchley Road & Shortening the crescent along the south eastern part of the site; Remove the cruciform shape from the plan and adjust the building geometries accordingly; Resize the plots to add a fourth courtyard block; Add townhouses to the southern courtyards; Remove the building on the south side of the community green so the linear park flows into it; Increase the size of the northern building on the green to create a larger and more flexible plot
Feedback: A broad welcome to the reduction in height and massing, though some of the moves made to achieve this were regarded as detrimental to the overall masterplan; • A preference for the previous scheme at the eastern and western edges of the site; • A request for more space between the blocks; • A request to know how much of the open space is fully accessible to the public; • Public space N7 needs a purpose; • The possibility of community uses in the first phase was raised; • The apparently regimented character of the central section caused concern and needed more work; • Introduced splayed blocks, further development of housing typologies and increasing the number of dual aspect homes was appreciated; • The proposed height at the eastern end seemed to work, though not on Finchley Road. Variation in height should be introduced; • Accessibility of the courtyards needed clarification.
LONDON BOROUGH OF CAMDEN Pre-app Workshop 09 – May 2021 At the ninth design workshop AHMM presented further revisions to the masterplan addressing comments on previous iterations were set out at this workshop: 1 Eastern and western edges of the scheme to revert to iteration prior to version presented in workshop 08; 2 Spaces between buildings enlarged by inflecting the plots to exploit the varying widths of these spaces; 3 A new open space in the centre of the site (the central square) provides respite and adds variation to the linear park;The green space at the western end of the site increased by straightening the western edge of plot N5; 4 Taller buildings removed from Finchley Road; 5 Great height and density concentrated around the town square, off Finchley Road; 6 More variety to the heights along the linear park; 7 Treating each building as an object in a park creates more breathing space along the linear park; 8 Slight increase in height at the corner towards the west.
Feedback: Officers were generally comfortable with the level and disposition of higher buildings, subject to review during design development; • Heights at the eastern end of the site were also comfortable, but there needed to be a more direct architectural relationship between the plots of the northern edge of the square and those along its southern and eastern edges; • Re-orientating the building at the back of the new square (where’s that?) would define the square better; • Detail sought as to how the linear park would feel safe and its southern side activated; • Possibility raised of a direct link between Finchley Road Underground station and the development; • Plot N7 discussed as a possible bus turnaround but it still needs a clearer purpose.
LONDON BOROUGH OF CAMDEN Pre-app Workshop 10 – July 2021 At the tenth design workshop AHMM presented further revisions to the masterplan to take account of comments on previous iterations: 1 Shape of plot N7 amended to create a larger shared surface and to become a more generous and obvious destination at the end of Blackburn Road; 2 Gaps introduced to the eastern wing of plot N5 and the western wing of N4, increasing the number of dual aspect apartments, break down the length of the façade and introduce variety to the buildings along the linear park; 3 Plot N3E at the rear of the central square reorientated to make a more generous space and to define its northern edge; 4 Investigating a finer building grain to plots N1 and N2, in keeping with southern side of the town square, and to differentiate this plot from those in the residential neighbourhoodd. 5.Introducing gaps between the buildings allows the building edges on the linear park to be slightly lowered; 6 Building on plot N7 rises slightly so infill units can be removed; 7 Massing on buildings on plots N1 and N2 made closer to that on S1 with pitched roofs.
Feedback: Officers were generally content with the revisions proposed at this workshop, subjectto further review during design development.
LONDON BOROUGH OF CAMDEN Pre-ap Workshop 11 – September 2021 At the eleventh design workshop AHMM presented, Progressing designs from the broad brush of master planning to the detailed architecture of the buildings. Detailed site studies showed how these designs would tie into the most significant existing buildings. Presenting a range of possible ‘elements’ for the plots if taken to the greatest level of detail allowed different solutions to be tested as the base for a strong architectural language and narrative to run through the entire project.
Feedback: High quality public realm throughout the site would make its high density and large scale acceptable;• Either reducing overall height or outstanding benefits needed to justify the ‘less than substantial harm’ judgement of the impact on neighbouring conservation areas; • Architectural approach to phase 1 (identify plots) broadly welcomed, subject to reinstate the splays on the buildings, and lowering the height of buildings adjacent to the open space; • Officers had concerns about various aspects of the proposed residential accommodation, including their aspects, distance between them, amount of daylight they receive, variety and balance of the typologies proposed and their connections to open space; • Accordingly, number of dual aspect units to be significantly increased; • Mixture of uses along the linear park encouraged to maintain its character as a park rather than becoming a route; • Bus turning point and Blackburn Road need further design development; • Health Centre must be provided as part of phase 1.