Preliminary comments on the Framework from our Planning Group (KAPF)
Vauxhall, Nine Elms and Battersea Opportunity Area Planning Framework (VNEB)
Nov 2009 Consultation Version
Comments and Unresolved Questions for the Planners, from the Kennington Association Planning Forum
The Framework
1 The final version of this document from the Mayor of London will set the framework for the next 20 years for the new town of 40,000 or so, with 27,000 new jobs and many tall towers, planned to be developed on our doorsteps from Albert Embankment down to Battersea. As it stands, we think the framework is unsatisfactory, and begs many questions, and this is our initial view, with questions on it for the planners and local councillors.
Why should Kennington, Oval and Vauxhall be concerned?
2 At para 7.3 VNEB recognises that neighbouring communities, like Lambeth, are extremely deprived, and that “New development must make a contribution to support and enhance education, health, skills and training, open space and public realm within and beyond” the VNEB area. If so, how? In Lambeth, only 32% of Lambeth jobs go to Lambeth residents, and 20 % of Lambeth residents of working age have no qualifications (25% in Prince’s ward).
· Will those on Lambeth’s housing lists be able to afford any of the new housing? (the “affordable” housing requirement is being watered down, and the Battersea Power Station developer is proposing none at all)
· What happens to the existing jobs? Will Lambeth jobseekers have the skills to do any of the new jobs proposed? How will these developments help to upskill them? What is the expected skills profile of the new jobs?
· The Vauxhall Gyratory equates, for most Vauxhall residents, to the equivalent of one of Dante’s Circles of Hell. Does TfL have the bottle to level with the community, face to face, about whether anything will come out of VNEB to mitigate its impact? Or does Vauxhall need to develop another heart south of the railway?
· What will be the permanent effects in our areas on traffic and public transport from 40,000 additional residents and tube users, on top of the extra already committed via developments at Elephant and Castle?
· What will be the impact on public services in neighbouring parts of Lambeth, eg schools and health services?
· Are we going to be cut off from the river by a palisade of tall buildings?
· Will we neighbouring communities have to suffer 20 years of construction traffic while VNEB builds itself, while the river lies unused (and unconsidered in VNEB) as a construction highway?
Chapter 5 - Land Use Strategy
3 VNEB lacks an adequate “before and after” analysis of land use and employment, to allow us to judge it properly. There are
· complications of shared oversight by Wandsworth and Lambeth, and historic problems of equitable sharing between the boroughs
· 20 ha (hectares) (with 1 hectare equal to 10,000 sqm or approx 2.2 acres) or so of existing social housing to be retained,
· escalating densities in existing planning applications and
· doubts whether adequate provision is being made within the VNEB area for social infrastructure.
4 So we need a proper breakdown, for the existing uses and for the Framework’s preferred option 5 modified, of the 192 ha of the VNEB area, between, for each borough
· existing housing;
· new housing;
· mixed use residential/employment;
· retail;
· office;
· other employment;
· open space;
· existing social infrastructure (inc schools and doctors); and
· new social infrastructure,
together with the resulting housing and employment yields per hectare.
5 Without this, there will be an active sense that everything is not being revealed, eg whether the developments are to be “social infrastructure lite”, relying on neighbouring areas, and how the residential density calculations are being struck.
Chapter 6 - Development Capacity
6 Option 5 is labelled as having a density of 255 dwellings per ha, equating to 65.7 ha to accommodate 16,750 dwellings, but is illustrated only by the example of Tabard Sq, which is repeatedly shown as having a density of 477 per ha, or 87% higher (and incidentally, higher than the 405 per ha indicative upper limit for such areas in the Mayor’s Plan). Tabard Sq is a slab like, inward focused, fortress development, with its only greenery on the inside, in manicured raised beds, and is frankly oblivious to the public realm (see actual pictures, attached). You get the sense that children have been designed out, in the interests of high density and financial return. So we regard development in this Tabard Sq form, at these densities, as completely unacceptable, and incapable of creating a demographically sustainable community. How have you struck your density estimate of 255? Have you averaged over the existing social housing and the proposed open space/linear park?
7 So far, for residential development in areas with good public transport, the highest acceptable densities we have seen, that combine interesting built form with green edges, high levels of family friendly and affordable accommodation, and respect for the public realm, are around the 230 per ha level (cf the Southwark development on the former Braganza old peoples’ home, Ref Southwark 09-AP-2388). On this basis, and with this built form only, the 65.7 ha might support 15,000 dwellings, and then only if the transport infrastructure was massively improved.
8 We are fundamentally opposed to the expulsion of employment from the eastern end of the VNEB area mandated by the Framework, particularly given the presence of the railway embankment spine, and its railway arch workspace, which can only have employment generating uses. This misses an opportunity in real sustainability. 40,000 increase in population and activity will lead to a large increase in servicing requirements – white van man comes in from Herts (over the bridges) and from Kent or Essex (South Circular) and then through Brixton and Kennington – and an Arterial Road will only concentrate the problems at both ends. The missed opportunity is to seek to return key services industries to Nine Elms from which they can service all of inner London – significantly reducing inward traffic flow, pollution, improving service times and reducing costs as well as creating skilled employment for local people. The projected increase in industrial space at Stewarts Road is insignificant both in jobs and as an environmental impact.
Chapter 7 - Social Infrastructure
9 So far, pending its S106 study, VNEB is silent on the financial and land demands of the social infrastructure required to service such a large new development. But given the risk that escalating transport costs will eat up all the S106 money, and more, and dump social infrastructure costs on neighbouring boroughs and their council tax payers, we think it worth making cockshy estimates now, for key elements, based on the official assumption, that in a balanced community, 25% of the population are children. These are:
· schools - 3 primary at £8m and 2.5 ha each, 2 secondary at £27m and 5 ha each - £78m and 17.5 ha
· health – 14 GPs at 2,800 patients per GP, £1,000 per dwelling and 0.1 ha per GP - £16m and 1.4 ha
· libraries – 30sqm per 1000 inhabitants at £3,000 per sqm – say £4m and 1.5 ha
· community centres – 10 at £750,000 and 0.1 ha each – say £7.5m and 1 ha
· fire service contribution - £77 per head - £3m
· police - ?
10 So, for these key elements only, the total is on the order £108.5m and 21.4 ha, depending critically on whether developers are allowed to design the developments as “children lite”, and thereby successfully argue for a lower assumed child %age, and on whether developers successfully off load social infrastructure land requirements, and with them costs of provision, onto the neighbouring communities. Are you going to let them do this? What are your estimates? How much VNEB land does your plan allocate for new social infrastructure?
Chapter 8 - Transport
11 A number of the assumptions are questionable:
· The “borough balancing” assumption (p 78, para 8.2) is that for transport planning purposes future growth from elsewhere in the two boroughs is reallocated to the VNEB area, to “ensure that this study remains consistent with the London Plan forecasts” , ie that growth and transport demand elsewhere will be correspondingly less, as jobs and housing in VNEB increase. This seems wholly implausible, given the “Klondyke” nature of VNEB for developers, and the different time horizons of the borough plans and strategies and VNEB, and the overlap of VNEB into two boroughs. (This assumption eg makes the model predict, in the absence of a Northern line extension, a reduction of passengers at Kennington Tube station over time).
· Para 8.3 says that the intensification of employment in VNEB scenarios leads to “significant increases in inbound as well as outbound morning peak public transport trips”. So what assumptions are being fed into the model about what proportion of VNEB jobs are going to VNEB or neighbouring residents, whose journeys to work would have much less impact? Are these standard assumptions or are they tailored to a combination growth of housing and employment in the same area?
12 The Framework’s “Get out of Jail” card to bring the transport accessibility in the middle of the VNEB area up to high levels, (permitting developer friendly density levels under the Mayor’s Plan guidance) is an extension of the Northern Line from Kennington. Such extensions are notoriously difficult to cost, and often overrun timetable and budget. Eg, while developers were initially to pay for a large part of the Jubilee line extension to Docklands, in the end they paid less than 5% of the total cost of £3.5bn. A cockshy estimate of 4.3 extra kilometres of tunnel, at between £180m to £260m a kilometre, based on 1994 London Underground costings for tunnelling in the Battersea area, uprated for increases in earnings, suggests a cost of between £770m and £1.1bn. These costs dwarf other social infrastructure costs (above) and seem beyond the reach of “normal” S106 charges. What is your preferred route and cost estimate?
Chapter 9 - Public Realm
13 Lambeth is the fifth densest populated borough in the country. It is already deficient in public open space, with levels set to fall from 1.54 ha per thousand population to 1.44 ha, against a national target of 2.4 ha. And Lambeth’s attenuated target for new developments is 1.6 ha per thousand, which would yield a target of 64 ha under the VNEB preferred option for dense housing. Against that, we are offered 14.9 ha of mostly linear park! We conclude that VNEB and Lambeth residents are being seriously short changed by the VNEB proposals for open space, even if you supposed that the River Thames counted for half the requirement (and not even planners have yet learnt to walk on water).
14 Furthermore, the St George’s Sq comparison made in the Framework is flawed – given the built forms, the ratio of breadth to visible height of the 5 storey sides to the square is 4, giving a spacious sense, while the proposed linear park, with 8 to 10 storey sides at minimum, narrows at times to no more than 2.5, giving a more canyon like effect. As regards the built forms, one inward looking, gated Tabard Sq would be bad enough, 33 would be intolerable, leaving perhaps only the American Embassy, which seems to need a 35 m free fire zone around itself, as the only major building which has a green edge.
Chapter 10 - Tall Buildings
15 Now that the planning authorities have opened Pandora’s box, planning applications for tall buildings are coming thick and fast, with eye watering residential densities, and under par private amenity space (cf the recent appeal win at 81 Black Prince Road at a density of 1263 per ha and 23 storeys, and the recent revised application for the Vauxhall Sky Tower at a density of 1285 per ha and 36 storeys, a density up by a third on that of the previously granted permission). Unless the indicative heights and “no palisade” principle in the VNEB are turned rapidly (probably in a very early separate planning document just for that purpose) into material planning rules, the game is lost, and Vauxhall and the Albert Embankment will turn into tall building forests, with the early developments paying well under the odds in S106 payments.
16 In addition, some rule will be needed to limit how much of the 16,000 dwellings can be provided at these excessive densities (perhaps no more than 3%), else instead of VNEB development at 255 per ha, with corresponding infrastructure, we shall start at the 477 per ha of Tabard Sq and accelerate rapidly upwards, with an inhuman public realm, with gated inward looking family unfriendly blocks.
17 The Framework expresses lots of concern for how towers will affect views from London Bridges – what about our views of Big Ben from Imperial Court or the Ethelred Estate?
Chapter 12 - S106 Contributions
18 Plainly, the indicative £400m for S106 yield sketched in the Framework is quite inadequate to pay for the Northern Line extension, and the tariff would need to be 3 or 4 times higher at least. Here are our suggestions:
· make sure that the other social infrastructure is a first call on the fund, not the last;
· why not tier the charges, so that floor space above 30 metres from the ground pays at an escalating rate, given the extra demands it makes on public amenity and services (eg fire rescue);
· common experience with grand developments is that at some stage developers go bust, the authorities panic, and allow the enticing community and green trimmings previously promised to go by the board in desperation to see something built: so make the S106 promises also bind the land through land obligations, so successors in title to the land are equally bound by the enticing promises accepted from their predecessors.
Questions for Councillors
1 Do you accept VNEB development at these Tabard Sq densities and forms?
2 Do you agree with the meagre allocation of open space?
3 How will you ensure enough affordable housing?
4 How do we keep jobs in VNEB that our jobseekers can do, and skill them up to get new VNEB jobs?
5 How are you going to stop Lambeth council tax payers and voters having to pick up the tab for the social infrastructure of schools, doctors etc needed by these dense VNEB developments?
6 What are you and your planning colleagues going to do about the rush of tall tower planning applications?
7 How is Lambeth Council going to respond to this consultation?
Kennington Association Planning Forum
4 February 2010
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