Westminster City Council’s Labour Councillors object to the current proposal for 285-329 Edgware Road (West End Green) [council ref: 15/11677/FULL] on the basis that the proposed scheme conflicts with the council’s policies relating to:
- Affordable housing;
- Tall buildings and protection of views;
- The impact of the development on local school resources; and
- The lack of wider public consultation on such a large scheme.
The proposal for a scheme which would see 691 residential units, a 39-storey tower, 2,923 m2 Retail floor space and 1,484 m2 Leisure floor space, represents a major scheme within the local area and Westminster as a whole.
The site has stood empty for decades; therefore it is welcome that it is being brought forward for development. However, this will be a major scheme and it is vital that it is adequately judged against any detrimental impact on local residents/businesses and against the need to maximise benefits for the wider borough. This is especially true give that the supply of on-site affordable housing, school places and access to health services are all key concerns in Westminster, and especially in the Paddington/Church Street areas.
Within Westminster City Council’s City Plan policy S16 sets out the council’s intention with regards to affordable housing. It states: “WCC will aim to exceed 30% of new homes to be affordable homes and proposals for housing developments of either ten or more additional units will be expected to provide a proportion of the floorspace as affordable housing.”
The council’s own housing markets analysis sets out that there are 4,500 households on the waiting list for social housing within the local authority area. In 2014 the council’s commissioned housing market study set out that “The backlog need for affordable housing is estimated to be circa 6,068.”
It also estimated that local households would need a gross annual income of £63,200 to rent a one-bedroom flat without assistance, a family in need of a three-bed property would need a gross income of £119,200.
Given this desperate need for affordable housing locally and the size of the proposed development, it is unacceptable that the proposal does not meet the council’s on-site affordable housing expectations. The current proposals for only 84 socially rented units and only 74 intermediate rented units provides only 158 affordable units or 22.8% out of the total number of 691 residential units proposed. That is a minimum of 50 on-site affordable homes less than the policy intention set out in the council’s policy S16.
The previous development plans, granted in October 2005 [council ref: 03/03463/FULL)], which gained consent, sought to deliver a total 107 affordable housing units or 35 per cent of the total number, 307, of residential units proposed. Consent for the proposed development should be withheld unless the scheme can exceed the council’s policy of 30% on-site affordable housing provision.
This is an easily accessible site, a straight-forward flat build and there are no reasonable arguments as to why it cannot be compliant with the council’s policy S16. We object to the scheme on the basis that unless the scheme can be made to exceed the council’s policy S16 with on-site provision, it will not deliver a commensurate benefit to the borough given its proposed size.
The previous planning consent for the site provided for a building of a maximum of 22 stories and a height of less than 120m. The proposed scheme includes a block of 39 stories, 11 stories higher than that previously consented scheme, reaching almost 160m in height. To put this in context, the proposal includes a building taller than the London Eye (135m) and Centerpoint (127m), and the same height as 20 Fenchurch Street (“the Walkie Talkie”) which is the 13th tallest building in London.
The current Westminster City Plan identified that there was a case for a tall building, 1 Merchants Square, in the Paddington Opportunity Area but that there was very limited scope for new tall buildings in the rest of Westminster, due to the settled character of the townscape and significant concentration of heritage assets. Given the scale of the proposed tower, unless the scheme can deliver local area changing levels of affordable housing and public amenities, we object on the basis it would otherwise contravene existing strategic council policies.
Even within the context of Westminster Council consulting on a revised City Plan, including a new tall buildings policy, the Council’s suggested policy identifies that it would not consider a tall or higher building acceptable where it did not “minimise the effects of overshadowing and overlooking, especially within predominantly residential areas”.
The council asked for a comparison of the proposed development against the extant 2005 permission. It is unclear how the overshadowing assessments on the local amenity areas can be considered as having a ‘negligible adverse effect’. As indicated in the Vol 2, Chapter 11 of the Environmental Assessment, there are severe concerns about the overshadowing effects on the local residential population would be:
- Minor Adverse in terms of daylight and sunlight when compared to the baseline condition at Winnicote House;
- Negligible to Major Adverse in terms of daylight and sunlight when compared to the baseline at 1-80 Hall Tower;
- Negligible to Moderate Adverse in terms of daylight and sunlight when compared to the baseline at Gilbert Sheldon House;
- Minor Adverse to Moderate Adverse in terms of daylight and sunlight when compared to the baseline at 352-330 Edgware Road;
- Negligible to Minor Adverse in terms of daylight and sunlight when compared to the baseline at 328-314 Edgware Road;
Taken together there would be a material impact on the existing local population. We support the comments made by local residents concerning the adverse impact of overshadowing and reduced sunlight. Unless the applicants can show, materially, how it plans to realistically mitigate resident concerns, we object to the scheme on the basis that it would have a significant adverse effect on local resident populations.
Impact on local school population
As the supporting documents indicate, the families in the proposed development will face a deficit in local school places: “…forecasts identify that by 2021 (when the first residential units are likely to be occupied), there will be deficits at both primary and secondary level for those schools in close proximity to the Site”. We disagree with the EIA’s conclusion that a 52% increase in the local residential population would have a ‘negligible adverse residual effect’ on the projected school deficit places. The latest projections forecast a deficit of -642 secondary school places for 2020/21 and only 18 spare primary school places for the St Johns Wood planning area. As set out in the environmental statement, this would require the need for 1.83 primary classes (of less than 30 children) and 0.83 secondary school classes across the local authority.
However the pressure on the local area is likely to be higher than this. Therefore it is a more credible conclusion that the effect would be ‘moderate’ and should be adequately reflected in the developer’s contributions.
Given the scale of the proposed scheme, it is disappointing that there has been so little time given to public consultation, a public exhibition was only provided between 2-5 December. Given the number of objections and concerns that have been given in relation to this scheme (currently running to 192 comments) seems to indicate that the applicants did not take enough time to consider and reassure them of the impact of the proposed scheme on local residents and businesses.
Cllr Vincenzo M .C Rampulla
Westminster Councillor for Church Street Ward
Tel: 07900 912 587