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O2 Development- Information & Sample Letters for Objections

The O2 proposals include 15+ closely-spaced towers between 10 and 15 storeys high. Construction will begin with three buildings-605 dwellings- at the centre of the site with outline planning consent for the rest of the site –over the next 15 years. 

See Application Documents here: https://tinyurl.com/y9v96wyu

Send your objections as soon as possible, by email to the Planning Officer, David Fowler: David.Fowler@camden.gov.uk

Below are example letters and points which you are welcome to cut and paste in your objection – Please do comment on this application. The closing date has been extended beyond the summer.

Example Objection – Letter 1

I disapprove of this application 2022/0528/P and wish to object on the basis that:

The development, is a destructive over-development of the site – 6x Camden average density.

The heights of the towers are out of keeping with the surrounding landscape and conservation areas.

It brings  4500-5000 new residents to the area – which existing infrastructure cannot sustain.

All the flats are for rent with the minimum @ affordable rates. They are not homes but dormitories for a transient population.

West End Lane & Finchley Road tube stations have no step- free access, are heavily congested at peak times with already-overcrowded trains. There is no guarantee that new access arrangements will be part of this development.

The loss of the O2 centre, a community hub providing a large well-supported supermarket Sainsbury’s and many social benefits – is damaging for the integration and resilience of our established neighbourhood .

Demolishing the O2 Centre itself, with the removal of all short-term shopper parking and a piecemeal rebuilding of smaller versions of some of its amenities, will generate additional carbon emissions, fragmented community resources and increased traffic disruption in the surrounding area.

Please refuse this application.

Example objection – Letter: 2

I am writing to raise strong objections to the proposed application 2022/0528/P for the redevelopment of the O2 Centre.

Like many other local residents, I have legitimate concerns about the density of high-rise tower blocks being proposed, when the local area has been subjected to an onslaught of development over the last few years resulting in already over- crowded pavements, public transport, shops, community facilities such as doctors surgeries, dentists, etc

No one seems to be listening to the local residents and the tireless objections being raised. The response from the developer is to attempt to bulldoze the scheme through regardless of tlocal objections. Camden emphasise the need for ‘housing’ but co-design this ‘new neighbourhood’ – cramped, for-profit high rise buildings.overshadowing ‘wind tunnel’ paths and token ‘green spaces’.

  • little consideration given to the need to upgrade infrastructure BEFORE development.
  • little consideration given to the pressure already on community facilities and medical services.
  • little consideration to the amount of flats empty, or buy-to-leave in other tower blocks built over the last few years.
  • no consideration given to the fact that the there’s already a development of flats underway on the old Travis Perkins site on West End Lane, and the impact of this on local services and resources.

Please refuse this application.

Some Other Points:
The developer has sacrificed ALL car parking for more flats and Camden Council are enforcing a no-car policy throughout the borough yet this proposal does away with a DIY store, supermarket, gym, cinema etc which many residents can currently walk to. Those with heavy shopping, the elderly or people with children need to be able to drive and park.

Camden must think again, not just prioritise ‘box-ticking’ to meet the government arbitrary house building quotas or Section 106 and CIL payments but about what human beings need for a healthy, meaningful environment- open green space, community facilities, reliable infrastructure, supermarkets, daylight/sunlight and quality design.

The equally harmful recent development proposals for Murphys Yard near Dartmouth Park/Kentish Town received 1500+ objections. It’s planning application was withdrawn by the developer.  Can we achieve a similar show of disapproval for the O2 Centre proposals. 

The following websites give a good overview on how to object, and the best grounds on which to object, in terms of planning considerations that Camden planners must pay regard to.

1) The local Councillors’ website,

2) The RedFrog association website,

Camden Trees Get the Chop

LONDON BOROUGH OF CAMDEN WARDS: All
REPORT TITLE
Tree Maintenance Policy
REPORT OF Director of Place Management
FOR SUBMISSION TO Culture & Environment Scrutiny Committee
DATE 6th November 2019
SUMMARY OF REPORT
The London Borough of Camden is responsible for the management of
approximately 28,000 trees and a further 10-15,000 in woodland sites. An itree
inventory report in 2017 estimated that they supply £234,202 worth of benefits per
year in carbon sequestration, pollution removal and avoided water runoff for the
residents of Camden. In total they store 10,800 tonnes of carbon. They are an
important and necessary part of the urban environment and valued by residents
for the benefits they provide. This report outlines the Council’s tree management
and maintenance procedures and policy to ensure that Camden has a sustainable
urban forest for now and future generations.

Camden Council is responsible for public street trees with a Capital Asset value (CAVAT) of £343.2 million (2019).  Studies in the 2020 report, Trees on the Edge by Bartholomew Area Residents’ Association, Canopy Coalition and others, found that Camden has ‘The largest tree maintenance and planting budget.’ but also ‘The weakest benchmarking for tree maintenance standards’. So what is going wrong?

Failure to follow recognised basic standards? 

The Council’s policy from 2015, guiding tree management is three pages long.  Policy 3 — Arboriculture Standards, Maintenance and Biodiversity states that: ‘The Council will ensure all Council tree work is carried out according to BS3998: 2010 British Standard Recommendations for Tree Work.’ 

But those BS3998 standards, which describe essential good working practices concerning established trees are contained in a small book costing £229.  Very few of the contractors hired to ‘manage’ Camden’s tree stock every year, possess a copy of this instructive but expensive book. A Kent tree company –  About Trees-  quotes on their website: ‘search high and low and you will not find BS3998 (2010) in either the office or yard of most tree care companies.’ 

 Procurement and oversight problems?

At a Camden Environment Scrutiny Committee meeting held in December 2021, a senior manager revealed that there are only two tree officers for the whole of the borough.Tree firms work largely unsupervised and some working locally are not registered under the ARB approved contractor programme, the only comprehensive accreditation scheme for tree surgery businesses in the UK. The programme is there to certify that businesses have been thoroughly assessed and found competent to carry out tree work to a high standard.

 Lack of expertise?

All our plane trees are currently being pollarded in late autumn, but the Arboricultural Association recommends the best time for pruning — not pollarding — is between late spring and summer. Cherry trees should only be pruned (not pollarded) in summer as should Acers. Some species such as Whitebeam should never be pruned and, if at all, only in late spring to summer, yet we have witnessed these ornamental trees being pollarded in late autumn…

“In 2018 in the Cantellows Ward 11 trees were felled due to disease or imminent death. Seven of these trees were of the same species, Swedish Whitebeam, a variety of the Service Tree. They had all been pollarded several times even though it is well known they should never be even lightly pruned.”

Trees on The Edge

Fear of Liability

Camden Council’s Trees Department continues to maintain that large parts of the borough have significant subsidence problems, often giving this as the ‘default reason’ for the numerous aggressive interventions taking place in the borough these days.   

Camden’s biennial reduction regime is based on the misguided belief that it somehow protects the council from expensive subsidence claims. In fact, the council’s brutal maintenance programme, pollarding by default, disfigures mainly harmless trees, which are often a significant distance from any private property, historic foundations and cause no obstruction. Indeed, Camden’s latest statistics regarding third party tree root claims show that claims are negligible, the last declared cost being only £2,500 whereas precautionary pollarding costs Camden £134,000 a year.

Before and After

According to the same report, ‘pruning everything at the same time and in the same way can in no way be considered best practice or complying with industry standards.’ 

Tree Topping

Heading, stubbing, tipping, dehorning, rounding over, hat-racking… are all names for one thing: Topping.

Camden’s indiscriminate “pruning”, ie topping, removes the top section of a tree’s crown in order to reduce the height for either fear of the tree becoming too large, too close to another object (like house or power lines), or to clear a view. It ruins the structural integrity of the tree and leads to epicormic growth (shoots or new growth that is weakly attached to main scaffold branches or limbs). This new growth is an attempt to recover from the shock of losing its photosynthetic area and further weakens branches, increasing the potential for failure. 

Why Not to Top a Tree- Eight Good Reasons
     1. Starvation – Topping removes too much of the tree’s leafy crown, an area that is used for making food. Good pruning practices do not typically remove more than 1/4 of the crown.  Without these leaves creating nutrients for the tree, it can become stressed and lead the tree into survival mode.
      2. Shock -The tree’s crown shields the bark from direct rays of sunlight, the reduction of the crown can cause sun scald. 
      3. Insects and Disease – Large areas of newly pruned branches leave the tree vulnerable to insect invasion and the spores of decay.
      4. Weak Limbs – Wood from a new limb generated from a larger cut limb, will attach more weakly compared to limbs that develop naturally. This leads to branches that are more liable to break.
     5. Rapid New Growth- While the goal topping is often to control the height of a tree, it often has the opposite effect. The branches that sprout after topping are fast growing and can reach the original height of the tree in a short time.  Also this crown grows more dense!
     6. Ugliness -The natural form of trees is graceful and characteristic of the species.  Topping creates a disfigured tree that robs a community of a valuable asset.
      7. Tree Death – Some trees are more tolerant of topping than others.  However, beeches, for example, do not sprout rapidly after pruning, and the reduced foliage surely will lead to death of the tree.
      8. Cost – If you have found a tree service to top your trees, chances are they are doing it cheap.  ISA Certified arborists know this is an unacceptable method of pruning.

The Camden Council Tree section needs a critical review, reform of its tree managment criteria and new staffing arrangements to safeguard the valuable green assets we entrust to them. Simply planting new saplings cannot offset the harm done to mature trees by this unsustainable, one-size-fits all approach.

‘Camden As Developer’

with reference to the Report of the Camden Community Investment Programme Scrutiny Panel March 2022. https://tinyurl.com/rkc2ctt9

Objectives of Community Investment Programme –

(clause 7 in report) – The CIP programme was created in 2010 to deliver new homes (including replacement council homes; new council homes and affordable housing) together with new community facilities and schools, financed through the sale of land and cross-subsidy by market housing. Camden’s preferred option is to deliver the majority of schemes through direct delivery (i.e. Camden as developer).

Questions raised about the CIP programme:

Is it value for money and do the new homes and facilities it delivers justify its budget and expenditure?

Are the social, environmental and long-term economic ‘indirect’ costs of the programme -usuallly experienced by residents and tenants- being adequately considered in decision-making?

What is the level of financial risk to the Council?

Does the overall transparency and accountability of the CIP project need improvement?

“It’s shrouded in secrecy, mired in debt and looking at the report it seems to be failing even in its main basic aims of providing net new or additional social housing for Camden. I think that summary in itself is pretty damning.”

Labour Kilburn councillor Douglas Beattie, quoted in Camden New Journal March 2022:

Some Recommedations paraphrased from the Scrutiny Committee Report

Targets and Oversight

  • CIP housing targets should be specific, measurable, achievable, relevant, time-bound and based on a 3-yearly cycle.
  • Camden’s RCP (Resources and Corporate Peformance) and Housing Scrutiny Committees should monitor performance.
  • The Council should review the probity of the Cabinet Member responsible for CIP sitting on the Planning Committee when CIP applications are being decided.
  • Greater collaboration with residents, tenants, community groups, councillors, and relevant organisations is needed. Information, both strategic and in relation to individual sites, should be available in one central, publicly accessible dedicated spreadsheet on the CIP website as well as published as an Annex to the CIP Annual Report.
  • Projects should be tracked, setting out the anticipated and current date for completion and any material change in project benchmarked.

Level of risk

Council housing, once the cherished centrepiece of Bevanite socialism, took just twenty years for successive governments to pick apart.

Lynsey Hanley

The Council’s overall exposure to financial risk, with anticipated expenditure of £283m in the approved CIP programme, relies on receipts of £295m. This cross-subsidy, direct delivery model depends on private sales so is vulnerable to movements in the housing market.

Anticipated costs should be benchmarked against other CIP projects, other private development projects in Camden, and compared against other projects being delivered by other local authorities. Any abnormal and additional costs associated with estate regeneration proposalslso should be accounted for.

Maitland Park Development

Quote from Letter from Neighbours of West Kentish Town – September 2021 CNJ

“Here, in our bit of the borough, Camden is the one with “huge powers”, the over-mighty developer.

Sadly, over the past 10 years of their Community Investment Programme Camden has gone ahead with all kinds of local intervention without the benefit of a planning framework. Resulting unwanted side-effects include: massive delays on housing schemes, very low return of additional council flats, over-dense development (CIP’s cross-subsidy model means building many more small flats than family homes), loss of open space and play areas, confidential negotiations / partnerships with buyers of public land to dodge Camden’s own planning policies, destruction of mature trees, demolition of the last remaining council-owned workspaces in the neighbourhood and, now, the botched road closures around Queen’s Crescent.

There has been no open space planning, no community facilities planning and no strategising on housing needs specific to our area (with Carlton School now closed as a result) and no economic development planning…Over the next five years we will find ourselves living in the teeth of three major housing developments at Bacton, West Kentish Town and Wendling.

We have no confidence our council is interested or capable of planning this properly. …we want proper town planning in our neighbourhood and have been asking for it now for the best part of 10 years.”

Ensuring public confidence is essential and Camden has not ensured residents know what is happening to their estates and their borough.

Delivery Update

The focus of the future CIP programme must be on the delivery of new additional social-rented homes, rather than replacement homes, new schools or community facilities. The key question when deciding on future CIP projects should be whether a particular proposal delivers sufficient value for cost in comparison with alternative options.

O2 Flyer

To inform residents in the area what the O2 development plans are and how to comment on them, WHGARA have circulated 6000 of these flyers locally.

Many thanks to all those who have donated funds, distributed flyers and supported this effort to inform residents.

Comments on this application can be made throughout the summer.
Disregard the dates given on the Camden Council planning portal website.

Local Community Opposes O2 Development Plan by Landsec

Featured

With thanks to O2 Development Residents Action Group & Jason Peacock

“…meaningful contact with ground level events is possible only from the first few floors in a multi-story building. Between the third and forth floor, a marked decrease in the ability to have contact with the ground level can be observed. Another threshold exists between the fifth and sixth floors. Anything and anyone above the fifth floor is definitely out of touch with ground level events.”

Jan Gehl Architect

West Hampstead ‘interchange’ was made an ‘intensification’ area in 2015. Since then it has endured uncoordinated planning decisions, conflicting architectural schemes, excessive building heights and increased overcrowding. Existing infrastructure, community services and amenity have all been compromised.

Camden is ranked third in the country for their number of empty properties, there are at least 4,000 unoccupied homes in the borough. In early 2020, Camden set the projected total for the 02 Centre/Sainsbury’s site @ 950 dwellings (two thirds of those consulted opposed even this number). They are said to have ‘co-designed’ these unpopular plans for the 5.7 hectare Landsec site between West End Lane and Finchley Road which will impose1800 flats housing 5000+ new residents without our consent or a matching upgrade/investment in local resources.

To Comment on O2 Sainsbury’s site Application 2022/0528/P

Online link to Camden Council Planning: https://tinyurl.com/Camdenplan

Email or write to planning officer : David.Fowler@camden.gov.uk 5 Pancras Square, London N1C 4AG

Reasons to object

The Government’s Guidance on planning decisions says that:‘…the decision must be made in accordance with the development plan unless there are material considerations that indicate otherwise’ (taken from Section 38(6) of the Planning and Compulsory Purchase Act 2004).

All these considerations – listed below- are valid reasons to object to the Landsec O2 scheme as it stands.

  • Overshadowing
  • Overlooking and loss of privacy
  • Layout and density of building
  • Overbearing nature of the proposal
  • Design and appearance of materials
  • Landscaping
  • Adequacy of infrastructure and /or social facilities
  • Effect on surrounding area (including conservation areas)

Too High & Too Dense

A ‘tall building’ is defined as anything higher than 10 storeys. This development should be limited to 10 storeys under London Plan policy D9.  The area is unsuitable for high rise buildings and the primary benefits of this’new neighbourhood’ of sub-standard architecture – more lin keeping with an office than a residential setting- will go to the developer, Landsec and Camden Council, not to the community.

Suzanne H. Crowhurst Lennard, co-founder and director of the Making Cities Livable International Council says, “the construction industry is a powerful engine for fueling economic development. Tall buildings offer increased profits for developers. However, the higher a building rises, the more expensive is the construction. Thus, the tallest buildings tend to be luxury units, often for global investors. Tall buildings inflate the price of adjacent land, thus making the protection of historic buildings and affordable housing less achievable. In this way, they increase inequality.”

The density is abnormally high and significantly exceeds the London Plan Density Matrix even for a site of PTAL 6. Camden, a borough which has produced some of the highest quality homes in the last 50 years, is said in a report that went to cabinet in early March, to have ‘co-designed ‘ this insensitive housing environment.

Impact on Conservation Areas and Heritage Assets

The O2 site is bordered by five conservation areas: South Hampstead Conservation Area; West End Green Conservation Area; Fitzjohns/ Netherhall Conservation Area; Redington/
Frognal Conservation Area; and Belsize Conservation Area. In point 3.2.2 of the FG&WH Neighbourhood Plan it states: ‘The height of new buildings shall have regard to conservation and respect the proportion, scale, massing and rooflines of existing buildings in their vicinity and setting. In all development there shall be a clear presumption in favour of preserving the distinct character and appearance of the Area, as well as the views across it.’

In observations, posted on the O2 planning application, Historic England comments: ‘The buildings on the site are substantially greater than that found within the conservation areas and would appear in some views from within them and out of them.The volume and scale of the development means that there is a harmful impact to designated heritage assets through development within their setting.’

Overbearing height, mass and form + Overshadowing and Loss of light to neighbours

Skylight, sometimes known as diffuse skylight, is diffused all around us even on cloudy days, whilst sunlight is the light which comes directly from the sun on clear days. BRE define daylight as a combination of skylight and sunlight, adding, “The quantity and quality of daylight inside a room will be impaired if obstructing buildings are large in relation to their distance away”. In a British context, skylight is the more important component. A loss of view is not a valid planning objection but the ‘right to light ‘of nearby neighbours to the north of this scheme is protected by the Rights to Light Act 1959.

In conflict with Camden’s Climate Change and Clean Air Action Plan? 

There are sound reasons not to demolish the O2 Centre. In the words of a Camden Council Planning officer: ‘Land Sec will need to demonstrate that the redevelopment of the 02 centre is more sustainable than refurbishing the building. To do this they will need to submit a whole life carbon assessment’. The embodied carbon as energy consumed in manufacturing, delivering and installing the materials to build, and fit-out these buildings over a planned 15 year construction and their disposal at end of life as well as operational carbon associated with heating, cooling, ventilation, lighting, hot water, and other electrical equipment must be accounted for.

Construction also has a significant and negative impact on local air quality and potentially public health if it is not carefully managed. Construction activity is responsible for 4% of NO2 emissions, 24% of PM10 emissions and 9% of PM2.5 emissions in Camden.

Increases Pressure on Infrastructure, Utilities and Community Assets

Where is the significant and long overdue increase in medical resources in West Hampstead to reflect the needs of 5000+ new users? NHS England published guidance in February 2018, requiring extended access to GP services, including at evenings and weekends, for 100% of the population by 1 October 2018. Access to basic health and dental care for local residents has diminished not increased.

The area will face more overcrowded pavements,roads, transport and the loss of all the amenity of the O2 centre, including a large supermarket with 520 parking spaces – none of which can be effectively replicated in this scheme. Without any parking, no large format store in place of the current Sainsbury’s would be viable.

Taking action together – Protect West Hampstead.