17 June 2004
Camden Green Party believes that the application as proposed should be rejected.
The plans fall well short of the sustainability criteria set out in the Planning and Development Brief and would not provide the regeneration that the community around Kings Cross needs.
The outline design for the site does not respect or enhance the heritage of the area and provisions for healthy living, education, familly life and biodiversity are completely inadequate.
Camden Green Party worked within Camden Council's Local Agenda 21 sustainability group to compile detailed comments on the plans. We also submitted our own criticisms, and encouraged all Camden residents to send in their comments.
Read more about the background to the development, as well as a summary of LA21 and Camden Green Party's criticisms, below.
kings cross plansBACKGROUND
By 2007, construction currently underway at St Pancras International station, Kings Cross Underground station, St Pancras Chambers and the 'Regents Quarter' development to the East of Kings Cross station is scheduled to have been completed.
Work can then being on regenerating the vast 62-acre site to the north of the railway stations - 'Kings Cross Railwaylands'. This development will take place between 2007 and 2018 and will include millions of square feet of new homes, offices, shops and leisure facilities.
In January 2004, Camden and Islington Councils published their Planning and Development Brief, which set out detailed requirements for the planning application to meet in order to make Kings Cross stronger, healthier, safer, more economically successful and sustainable, with excellent services.
The Brief was prepared after two years of consultation with the community by the two councils, the developers, local healthcare trusts, and community development trusts.
THE PLANNING APPLICATION
Developers Argent St George submitted their planning application for the regeneration of Kings Cross Railways to Camden Council in May 2004.
The plans involve completely re-landscaping the area, changing or removing current roads, and building a mixed-use development that retains some of the historic buildings while demolishing others. The development would include new crossings over Regent's Canal, homes for 5,000 people, and office and retail space for 24,000 jobs.
Residents and community groups had until 8th October 2004 to submit comments on the plans to Camden Council's planning department.
kings cross plansSUMMARY OF COMMENTS BY CAMDEN GREEN PARTY AND LOCAL AGENDA 21
Local Agenda 21 is Camden Council's sustainability forum, and members of Camden Green Party have been working within LA21's Core Group to help compile their comments on the plans.
The group recommends rejecting Argent St George's planning application for four main reasons:
* Inadequate provision for health care, primary and pre-school education and the community support facilities, which are needed for the development to benefit the surrounding area.
* Inappropriate over-development, leading to high buildings overshadowing the area's existing areas of biodiversity, including Camley Street Natural Park and Regent's Canal. The high buildings also lead to a lack of sunlight for large proportions of the development for most (if not all) of the year.
* Inadequate provision of open and green space.
* Excessive exclusivity, through the design, transport arrangements, accessibility and management proposals in the plans. The development is designed to exclude the neighbouring communities and will fail to provide the local elements of regeneration (especially employment) which are so urgently needed in the area.
The group believes that the development is unsustainable and concentrates too much on providing office space rather than the affordable homes and community facilities that are needed by people in the wider area around Kings Cross.
The fact that the site will provide housing for only around 5,000 people but jobs for 24,000 indicates that it is intended to attract huge numbers of commuters, many from Kent. Such long-distance commuting is the absolute antithesis of sustainability.
The purpose of a mixed-use development is to provide jobs close to peoples' homes, reducing the need to travel by any means other than on foot or by bicycle. Argent St George's development proposal not only fails miserably to reduce the need to travel, it is intended to increase it.
In addition, the plans fail against the other aspects of the UK definition of sustainability: improving access to opportunity for less advantaged groups and minimising the environmental and resource impacts of the development. In particular there is no indication in the planning application of how the Development Brief target of 15% local employment is to be met.
kings cross plansCRITICISMS OF INDIVIDUAL ASPECTS OF THE PLANS
* Overall, the reduced public highway provision, the reduction in capacity of the remaining public roads and the fact that none of the new routes through the site is designated for local authority adoption reinforces the feeling of exclusivity about the site.
* A new all-traffic through route should be introduced, giving views to the centre of the site from parts of the periphery, reducing the sense of exclusivity and reducing stress on existing roads for access to the site.
* The design for the northern Boulevard has a gradient that is too steep for unpowered wheelchair access. All main streets in the site should have gradients compatible with wheelchair access.
* A new pedestrian/cycle route is proposed to cut across the Camley Street Natural Park. This should be abandoned as it would damage the park and alternative routes can be provided.
* No improvement in access to the site from the Maiden Lane estate (Agar Grove) is proposed. A proper transport link must be provided to the north of the site, linking Camley Street with Agar Grove.
* No car-free housing has been proposed, despite this being a specific requirement of the Development Brief. This must be provided before the plans will be acceptable.
* The application contains no clear commitments or definitions of social housing. In fact, the supporting information indicates that the developers believe there is already a surplus of social housing in the area.
* Affordable housing should be delivered in tandem with private housing at least at the levels set out in the Planning Brief and preferably at 50% of the total housing. The definition of social housing adopted in the brief should also be used in the plans.
* Housing must be integrated across the site to avoid the creation of 'no-go' isolated areas at night where office buildings dominate. The application segregates housing and office space, and has tall commercial buildings overlooking the south side of the canal, which would reduce the safety of people in this area at night.
* To improve security, there should be substantial amounts of housing from the second floor upwards above shops and overlooking the canal.
* Although the number of dwellings seems adequate, the plans should include more family homes and a commitment to house a wide range of ages and social and ethnic groups.
* A proportion of car-free housing should be included, as set out in the Planning Brief.
kings cross plansEnergy and Materials
* The plans give a commitment to a non-existent 'high' rating on the EcoHomes scale. To be accepted, they should contain a commitment to at least the 'Very Good' standard in all buildings, and 50% of the site should be at the 'Excellent' standard.
* The site should also contain flagship, state-of-the-art, sustainable buildings that exceed the EcoHomes 'Excellent' standard. The fact that the plans do not contain any such flagship developments is a major lost opportunity for the site.
* The Planning Brief sets out energy requirements that are not addressed by the proposals. The developers note that energy use depends on the tenants' behaviour, but designing in the use of renewably generated electricity would mitigate even poor behaviour by tenants.
* BedZed in East London was built as an affordable housing development and uses renewable power, so the developers' arguments about the prohibitive costs of the wide use of renewables do not stand up.
* The Planning Brief also sets out materials requirements that are subject to no commitments in the proposed plans.
* We believe that the re-use of heritage materials from the buildings to be demolished must be a requirement of the plans, in order to improve the integration of new buildings and to reduce the transport burden on the site during its construction.
Water and Drainage
* Camden's planning brief sets out requirements to reduce demand for water and to encourage the retention and re-use of water on the site. These requirements are not addressed in the plans
* More Green/Brown roofs would help to reduce drainage requirements.
kings cross plansBiodiversity
* More areas of green space are needed in the plans in order to reduce the fragmentation of natural areas and act as stepping stones for wildlife across the site. Requirements for roof gardens should be added to plans for Green/Brown roofs on the site.
* The proposed pedestrian and cycle route across Camley Street Natural Park should be abandoned as it would reduce the park's value for biodiversity, introducing light pollution at night and traffic during the day. In addition, the very tall buildings proposed for the south side of the Park will overshadow it and cut out sunlight.
* The south bank of the canal and its retaining wall is at present an unmolested area providing a wildlife corridor. The plans would diminish this effect by demolishing the wall and allowing overshadowing from tall office buildings to the south. The height of buildings along the south of the canal should be strictly limited.
* We want to see more buildings that will be regarded as the heritage of tomorrow, and which could reflect the features already found on the site. The emphasis in the present plans is on faceless buildings of the sort that can be found anywhere.
* While pleased by the intention to preserve several of the area's heritage buildings (for example, the German Gymnasium, the Granary and the Great Northern Hotel), we feel that greater efforts should be made to preserve several others.
* Where historic buildings are to be demolished, their materials should be re-used in some of the new buildings to act as bridge between new and old
* The only reason for demolishing the northern Stanley Building as planned is to straighten Pancras Road. It would be better to realign this road completely to the east, allowing for some tall buildings along the new St Pancras trainshed, where they would be more appropriately placed.
* The Culross Building and Battle Bridge Road should also be preserved. The current plans would demolish Culross but would not use this as an opportunity to open views to the interior of the site. The proposals merely reblock the view with new, taller buildings.
kings cross plansCommunity services
* The total space allocated for community facilities, including primary and secondary schooling, health services, libraries, community centres, nurseries, tourist information, museums, art galleries, and youth facilities, is 75,765 sqm (compared with nearly 500,000 sqm of office space).
* However, 40,000 sqm of this is provisionally allocated to the relocation of a Higher Education institution to the area, and it is hard to see how enough space remains for all the community facilities needed the residents of the development.
* The Planning Brief clearly shows that a multi-use community centre, providing training for jobs as well as other services, is necessary to achieve the 15% target for local employment. However, there is no definite planning for this centre in the proposals.
* A proper commitment is needed to at least those community facilities found to be necessary in the Brief.
* The Brief estimates that primary school provision with 2-form entry will be needed for the residents of the site and that this cannot be accommodated within existing local primary schools, which have already expanded to their full capacity to meet local needs
* In addition, the Brief specifies the need for an associated sure-start children's centre and for nursery places to be provided with play areas.
* The application is incredibly vague about any commitment to providing space for a primary school on the site, saying it will be provided within the space allocated to the community "should it be necessary or appropriate to do so".
* We believe that the plans should contain concrete intentions and land set aside for a primary school, including play space and the sure-start centre recommended in the Planning Brief.
* Secondary education is better provided for in the plans, and South Camden Community School is likely to be able to expand to provide the extra capacity needed.
* The only nursery provision on site not attached to a workplace is the creche in the 'Triangle' development, at the north east corner of the site. This won't be built until well into the development timetable - after phase 2 when most of the housing will already have been completed. Nursery provision should be built in tandem with the housing, and be available as soon as the first housing is completed.
* The play area for the creche is to be in the central amenity space for the Triangle, which is surrounded on all sides by buildings of significant height. There is no land set aside for other children's play areas in the development, despite the significant amount of workplace childcare proposed. There should be more play areas planned for young children, especially in the south of the development
* More green space is also needed for older children to play in. The plans propose only one play area for older children, within the rebuilt gasometer next to the multi-storey car park in the west of the site. This would not provide space for ball games, but would be for climbing, skateboarding and other similar activities.
kings cross plansEmployment
* The Planning Brief requires help for disadvantaged people in the surrounding areas to access new job opportunities and for 15% of new jobs to be taken by local people by 2012. It is unclear from the plans how this target will be achieved or enforced.
* The only concrete plans for local employment proposed are centred around the construction industry. Detailed plans for involving local organisations to achieve the local employment target in all sectors must be provided, particularly for the financial, service and clerical sectors identified in the Planning Brief as essential.
* The total number of sustained jobs planned for the area (24,000) is more than twice that required by the London Plan, and this makes the site as a whole less balanced and more dominated by offices. Consideration should be given to replacing some of the offices with small-scale business space and housing.
* To provide local jobs involving self-employment, a higher proportion of retail units, workshops and other business premises should be small and low-cost. The principle of affordable rents should be extended into the retail and commercial sectors, with commitments in the plans to a significant percentage of such units.
* Part of the site should include space for a market, which could provide flexible space for the selling of affordable fresh food, farmers' produce, crafts etc, as well as opportunities for local business start-ups.
kings cross plansHealth
* Health services and facilities in the local area are over-stretched at present. With 5,000 new residents, and if provision is not increased, the quality of care and the health of local people will suffer. The developers' own consultation found that at least a health centre/surgery, pharmacy and dentist would be needed.
* We have serious concerns that the GP surgery included in the plans is within the Triangle and therefore not scheduled to begin until most of the housing has been completed.
* The only publicly accessible sports venue on the site is again within the Triangle (a health and fitness centre, possibly to include a swimming pool). The plans should ensure that this development is more co-ordinated with the provision of housing in phases 1 and 2.
* To increase the availability of exercise to local people, the plans should contain a commitment that all private gyms and sports facilities within the site will make arrangements for the community to use them during certain times. This principle should be extended to any facilities within the proposed Higher Education institution.
* There is poor provision for outdoor exercise in the plans, particularly due to the lack of green space. The 30 metre wide 'Long Park' is unsuitable for games or jogging and too close to buses and taxis on the roads either side.
* There should be more provision of cycle paths and vehicle-free routes through the site to benefit joggers and cyclists.
* The north of the development, which contains most of the housing, should include a playing field or other green space suitable for games and exercise, and more play areas for young children should be included in the plans as a whole.
* The site should be redesigned with child-friendly street areas throughout, as well as designated 'home zones' where there is the greatest concentration of family housing.
* Space for a market, which would help local people access affordable fresh food, and which would help low-income families achieve a healthy diet, should be added to the plans.
* The planning brief emphasises the need for safety to be designed into this development, with dead streets and dark alleyways particularly to be avoided. However, the plans do not provide for a vibrant street life across the area.
* The proposed distribution of businesses, hotels and housing makes this worse, with a lack of ground-level activity and a long, inward-facing development on Pancras Road. There must be more active street frontages designed into the plans, particularly on Pancras Road.
* Housing should be included in reduced-height building proposals to the south of the Regents Canal, in order to prevent this becoming a 'no-go area' at night.
* The opportunity to integrate the proposed development with the surrounding area has not been taken in the application. Existing transport links would in fact be weakened by the plans.
* The urban form proposed is unacceptably dense in most areas and unlikely to be sustainable. The mean number of storeys on buildings in the north of the development is 10.2 and in the south 9.9, making the development out of proportion with the surrounding area.
* The developers' illustrative schemes and solar shading patterns show that most of the new buildings will receive little sunlight and it is likely that many of the housing units would have no sunlight at any time of the year.
* In design terms, the plans fail to knit the proposed development into the surrounding area and will not encourage openness or accessibility. The lack of any view into the centre of the development from the periphery is off-putting and adds to the feeling of exclusivity apparent throughout the plans.
* Connectivity in all directions must be improved, the height and density of the buildings must be reduced, views into the development should be opened up, and the amount of open space should be increased for the plans to be acceptable.
* The regeneration potential of the site is enormous, and we believe that the plans fail miserably to meet this potential, particularly on social and environmental grounds.
* In many ways, the application sets out to be very exclusive. In its architecture, land-use, transport, management and safety aspects it tries to distance itself from the communities surrounding it. Permission for the development should only be granted when the plans have been amended to improve the permeability and transparency of the site.
* Although the development is 'mixed use' in general terms, there is not a single residential ground level frontage in the plans. This sets it apart from the surrounding neighbourhoods, which feature a high proportion of ground level housing.
* The housing provision on the site includes very few family-sized units (and no proper houses at all), and will do nothing to help young professionals working in the on-site businesses to stay in the area to raise their families. Some residential streets should be included in the plans, preferably arranged around squares to mirror the composition of the surrounding area.
* The location of the development provides a unique opportunity to use Regent's Canal for deliveries and servicing, and even for water taxis and buses. However, no mention in the plans is given to using the canal for these purposes. The application should be amended to include proposals to utilise the canal for the benefit of residents and businesses on the site.