West and Gibbs Green Estates Tenants & Residents Associations

Response to OAPF SPD Document ‘Earl’s Court and Opportunity Area Draft Joint Supplementary Planning Document’

13 May 2011

Introduction Thank you for agreeing an extension of time for us to prepare this response, which has been agreed by the Committees of the West Kensington & Gibbs Green Tenants & Residents Associations, and is submitted by Sally Taylor, Chair of West Kensington and Diana Belshaw, Chair of Gibbs Green.

We have a number of comments about the proposals contained in the document and our response will focus on each of these areas in turn. Our main concerns are centred on:

- The overall viability, realism and sustainability of the proposals; - The prematurity of preparing the document prior to the completion and publication of important technical studies; - The disastrous traffic and transportation impacts of the proposals;

- The damaging consequences from the loss of vital infrastructure, local employment, cultural and historical assets - The absence of proper justification for demolition, the scale of housing development proposed and the relative lack of new affordable housing proposed; and - The overall harmful impact of the proposals on our community and on the quality of life within the area as a whole.

Taken as a whole, the draft SPD does not set out a convincing or attractive plan for the area. Indeed, it is destructive of perfectly decent homes and of other serviceable assets such as the rail depot – essential for maintaining the Tube network, and the Earl’s Court Exhibition Centres - which were the first to be awarded sustainable exhibition centre status.

The proposed scheme is utterly unsustainable; would destroy a functioning community along with its heritage and sources of employment; and would significantly worsen the quality of life for tens of thousands of people in surrounding neighbourhoods. It cannot be justified in planning or transport terms; it would unnecessarily release an unacceptable level of embedded, and generate massive new, CO2 emissions; and would divert scarce investment resources away from the key strategic development area of the Thames Gateway, distorting the future shape of .

We do not support either the broad thrust of the proposals, nor such detail within them as exists at the present time. Clearly the proposals have come forward following pressure from Capital and Counties (CapCo) to submit planning applications for parts of the site. We support a plan led system, rather than one that is led by developers. In this, we believe that it is right for the plan to be developed first and the planning applications to follow from that; rather than the current situation which is that CapCo’s speculative ambitions are driving the content of the development plan draft supplementary guidance documents. Since the Council, as landlord, has not yet decided whether to include the West Kensington and Gibbs Green estates in the redevelopment, and the vast majority of residents are opposed to redevelopment, the SPD is, in our view, presumptuous and precipitate.

We strongly support the Government’s ambitions to ensure that local plans are driven by local people. Yet, this scheme seems to us to represent everything that the Coalition Government has pledged to do way with – top-down redevelopment to unacceptable densities imposed against the wishes of local communities. We believe that, in line with the proposals in the Localism Bill, there should be a consultative referendum among local people on the plans now set out by the GLA, RBK&C and LBHF.

We strongly oppose the plans set out within the draft SPD. We are determined to exercise our lawful rights under S34A of the Housing Act 1985 to transfer the estates to a resident-controlled community based housing association so we can determine our own future and improve our neighbourhood under our direction.

The overall viability and realism of the proposals set out in the document Capital and Counties has apparently boasted that the Earls Court and West Kensington plans are “The biggest urban regeneration project outside China.” Yet, there is no evidence to suggest this scheme is deliverable, let alone desirable environmentally or economically. Indeed, we believe the proposed scheme is unsustainable and that the critical technical evidence – especially relating to the impact of demolition and the effect on transport - is missing. Nor, indeed is there any assessment of the impact these proposals are having on the mental and physical wellbeing on the local population, that will be broken up and displaced, deprived of employment and its cultural heritage.

The scheme has an estimated value of £4-8bn. This means it would be on the same scale as the Olympic Park development, a development of national significance funded from the public purse, not private equity (by way of context the ODA budget was £8.1 bn with its final outturn expected to be £7,3 bn). Where is the funding coming from for this complicated scheme within the built up fabric of the inner city? Large sites like King’s Cross, Greenwich Peninsular and others, especially in the Thames Gateway, have long standing planning consents, are cleared for development and have other genuine advantages like proximity to transport hubs that have the capacity to support them. Yet the development industry is unable to build out these sites due to lack of financing.

The proposal to multiply tenfold the number of homes in the area, in addition to loading in office, retail, hotel and other development is quite impractical, and would distort detrimentally London’s development over the next two decades by depriving Thames gateway sites of previously agreed priority investment, as set out in national, regional and local policy.

The vision is unrealistic given the relative lack of land in the so called Opportunity Area. Furthermore, it is based around a ‘cultural hub of national significance’ but lacks even the first idea about what that facility might be once the existing exhibition and conference centres have been torn down.

There is no evidence of a robust phased decant and relocation strategy for residents. It seems that only a maximum of 188 new social rented homes would be made available for the entire decant programme (representing 25% of the capacity of the Seagrave Road car park site where the only new social rented homes are to be built, subject to viability). This is unrealistic given there are nearly 500 social rented homes on the estates and that there would inevitably need to be additional homes provided to cater for rehousing grown-up family members. It suggests the Council’s policy is to residualise the existing mixed community into a much-reduced rump. Instead of more homes for those in need at genuinely affordable rents, there would be less than half the number that exist now, and likely many of the new homes would be bought by foreign investors to the exclusion of existing residents and many people who live in the neighbourhood and need access to decent affordable rented housing.

Even if deliverable at all (which is doubtful), the programme will not be delivered within 20 years – causing massive disruption for residents and the surrounding neighbourhood throughout this period. Such an extended period of major upheaval and displacement would fatally undermine the cohesive functioning of the existing community and prevent the formation of a new one for more than a generation. The social consequences of such an approach are clearly undesirable, and are nowhere assessed.

The vision itself includes a plan to deck over the railway lines – to ensure the creation of a park. This would cost many millions. Where will this funding come from? Why would any private developer invest here – particularly to provide an unprofitable park - when they could instead build homes for a much less risky return outside central London, particularly in the Thames Gateway or on the many brownfield sites undeveloped since the 2008 property recession? This process itself will add risk, uncertainty to the programme and cause massive disruption for users of the railways as large number of railway possessions (and consequent interruptions to service) will be required.

Since, the vast majority of new homes would be sold, whether at low cost, or at market rates, the many hundreds that would be required to be sold each year would distort the local housing market. It is incredible that the developer could realise the projected prices, which are nearly double present values.

The prematurity of preparing the document prior to the completion and publication of important technical studies This framework is for an ambitious and long term programme. Yet, crucial studies (transport, viability, energy, townscape) are missing from the analysis altogether; and where they are referred to, e.g. the Strategic Transport Study and its subsequent review by TfL, they are not made available for public scrutiny and analysis.

The draft SPD itself refers to the emerging nature of these studies and the need to keep these areas under review. Yet, without this information the consultation on the SPD is flawed. The capacity research and analysis should have been prepared prior to drawing up a policy document, so that local people could see the true damage this development would cause.

If a developer wishes to put in a planning application within the planning context where the local authorities are preparing a strategic plan for the area it can be refused on the grounds of prematurity. There is no need to rush for the convenience of the developer. Instead, LBHF, RBK&C and the GLA should be urging the developer to wait so as to develop a proper and thoughtful plan for both the communities who are living in the area now and any future residents of the area, and its surrounds. The disastrous traffic and transportation impacts of the proposals These plans have been brought forward ahead of a thorough transport impact assessment. Nonetheless, it is clear from the documents that the local traffic and transportation impacts will be hugely unfavourable both for residents within the area itself and surrounds, and anyone else from West London who uses the District and Piccadilly lines or the network.

In every respect, the plans are a massive over development of the land which cannot be supported by any aspect of the local and sub-regional transportation infrastructure, from pavements to cycle ways, roads and railways.

Chapter 7 of the draft SPD document itself sets out the most comprehensive case against the local authorities’ development plans. Using a study prepared by Capital and Counties, which has not been made public (or at least is not locatable after a comprehensive online search by ourselves) states that:

- Footway capacity is insufficient and would require interventions to accommodate scenarios 1 and 2 (para 7.24), further that improvements would be required to station access routes and to the crossing on Old Brompton Road to accommodate pedestrian movements. - All transport scenarios would generate substantially high numbers of new cycle trips and significant improvements to the local cycle network would be required (para 7.29) - The three stations that serve the area (Earls Court, and West Kensington) are all operating at or near capacity and West Brompton lacks step free access. The lines serving the Opportunity Area are some of the most congested in London, with crowding levels in excess of four people per square metre in some sections of the District and Piccadilly lines in the morning peak (para 7.47). Despite significant planned increases in capacity on these lines, background growth (without taking account of development in this area) will mean that by 2031 those lines will remain as crowded as they are today. In other words there is no capacity on the rail network to absorb the level of growth proposed in any scenario in the draft SPD. - In terms of bus services, there is little spare capacity on the services serving the south of the site (routes 74, 190 and 430). To the west of the site there is some spare capacity on routes 28 and 391. However other developments, particularly Riverside, will reduce any spare capacity available. It is likely that with the scale of development being examined extra capacity and new direct bus links will be required (para 7.53). - On the roads, all the boundary roads carry very high levels of traffic and operate at, or near, capacity in the peak periods (para 7.84). Furthermore, growth in population and employment, without taking account development in the Opportunity Area, as well the removal of the Western Extension of the Congestion Charge zone, will increase traffic and congestion (para 7.90). As a result, parking levels of significantly lower than 0.4 spaces per residential unit will need to be sought (para 7.114) and In order to minimise the impact of additional parking demand on surrounding streets a review of existing controlled parking zones will be necessary and a strategy developed that includes any amendments necessary to minimise the impact of the development (para 7.115).

So, the draft proposals state that accessibility and capacity improvements are required to every form of public transport available and furthermore, to avoid complete gridlock on the surrounding roads, the parking standards for the new residential accommodation will need to be ‘significantly lower than 0.4 spaces per unit’ and that existing resident parking permits would need to be taken away. We object most strongly to losing the hundreds of garages, on-property parking spaces and off- street parking spots that we currently enjoy on the estates and that enable people to use vehicles as part of their means to support themselves.

Damaging consequences from the loss of vital infrastructure, local employment, cultural and historical assets We are alarmed that not only might the removal of result in job losses and the worsening of conditions for workers, but its relocation could compromise a vital public transport servicing facility and undermine the overall effectiveness of London’s Underground network.

Removing the Depot further down the would provide a less efficient service for the Tube system. There is a serious risk that this could cause delays to service on the District Line, as repairs take longer to carry out and trains take longer to get on and off the lines at the beginning and end of each day. It is more efficient for servicing yards and depots to be located close to the middle of rail lines. The operational impact of compromising essential maintenance has not been spelt out: given the potential consequences for London’s economy and the health and safety of passengers, it would be highly irresponsible to remove the depot on the grounds of financial benefit to TfL.

The Lillie Bridge Depot should not be closed and relocated: the strategic requirements for the efficient and safe operation of the Tube system must take priority. Furthermore, the depot includes a 40m bus layover facility which is sufficiently important to TfL to require re-provision within the area itself.

Currently, the depot is an area of peace and quiet for the eastern boundary of our estates, as well as a source of employment. We therefore object most strongly to the loss of this facility.

The Earl’s Court Exhibition Centres are at the heart of London’s West End and attract more than 2.5 million visitors, 30,000 exhibiting companies and hundreds of events per year. Together with Olympia it supports £258m of expenditure in their boroughs and over £1.25bn in the London region, and accounted for (directly and indirectly) over 1,000 jobs in the boroughs and around 12,500 in London. One in two Londoners visits the venues every year. At peak times exhibition space within Central and West London has reached capacity. The destruction of Earl’s Court will significantly reduce already stretched capacity and this will have a negative impact on the UK exhibition and events industry.

The loss of Earls Court and the resultant reduction in overseas exhibitors, conferences and business tourists will deprive the UK of billions of pounds in lost revenue, and will severely damage the local economy, and the prospects for accessible employment for the local community.

The Exhibition Centres are an important landmark - a neighbour we have no complaints about. They are woven into our local culture and history. They are a substantial source of employment for local people, and we, therefore, object most strongly to their loss.

We also object most strongly to the loss of the factory in Beaumont Avenue. Adel Rootstein has manufactured lifelike mannequins on this site for half a century. This world-renowned company provides many skilled and unskilled jobs and is a leader in the fashion industry. It’s a good neighbour, a source of employment, and is woven into our local history and culture. We object most strongly to the loss of the Queens Mill School, located on the Gibbs Green estate. This provides important educational services from a building that is relatively new and quite fit for purpose. Indeed, we shall be using it as the base to hold our summer festival this year. Like so many others threatened with demolition, it is also a source of local and accessible employment for our community.

We object most strongly to the loss of our two community centres, one of them barely ten years old and the other not much older. Both of these buildings are structurally sound, used by residents and the local community for educational, social and organisational purposes. They are a familiar and functional part of our surroundings and there is no justification for demolishing them.

We also object to the potential loss of the unusual Victorian public house, the Three Kings. Again, this is an important landmark and meeting place that is part of our history and culture and is a source of employment.

There are even more buildings in the opportunity area whose demolition is unjustified and would cause irreparable harm. Indeed there is no justification for any demolition in the opportunity area.

It seems to us this proposed redevelopment would waste perfectly decent and valuable assets that over many decades have anchored the local economy, providing many jobs for local people. Their destruction would rob the district of its cultural heritage and a major source of its on-going ability to sustain itself.

Such vandalism is unjustified in planning terms, and can only be condemned for its waste of historic investment, destruction of the cultural/historic fabric, wholly unnecessary release of CO2, deprivation of employment to local people, and damage to the mental and physical well-being of the local community.

The scale of housing development proposed and the relative lack of new affordable housing proposed There are far too many new homes proposed in the current SPD. While there is scope within the ‘Opportunity Area’ to provide new homes, this should be limited to appropriate vacant sites and to very selective intensification within existing estates, if this is supported by local people.

The SPD does not set out any clear justification for ‘regeneration’ of the existing homes, which meet decent homes standards. The fact is that the homes do not need to be ‘regenerated’, i.e. demolished, as they are quite satisfactory for their purpose now and for many years to come. They are occupied by a settled and diverse community, comprising a mix of social renters, owner- occupiers and private renters, many of whom are working in jobs in the local area including vital public services and small businesses.

The Council has recently completed the Decent Homes programme for the estates. Over the past decade, £15 million has been invested in West Kensington & Gibbs Green. This has included roof replacement, renewal of kitchens and bathrooms, window replacement and repair, new front doors, railings and new play areas. Additionally, the tower blocks have had their lifts refurbished, and additional fire protection has been applied. The tower blocks also benefit from a concierge scheme, one of the first in the country, which has been operating for almost 20 years. This service ensures the blocks are well maintained, anti-social behaviour is kept under control, and there is an on-site point of contact and support, especially for elderly and vulnerable residents.

The Council has been unable to cite a single technical, structural or long-term repair problem with the estates. The vast majority of residents are happy with their homes, cannot understand why they should be demolished, and believe the destruction of the estates would be a terrible waste of money. Visitors are shocked and amazed that such nice homes in such a peaceful, quiet and tidy environment occupied by a decent and diverse community should be the object of wholesale demolition.

The SPD document claims in scenario 2 that inclusion of the estates for redevelopment is justified due to ‘disproportionately high socio-economic problems, including long term unemployment’ and an ‘inefficient use of stock’ owing to 16% of the homes being overcrowded. But there is also under- occupation. Inefficient use of the stock is a management failure by the landlord, and certainly not a rational justification for demolishing decent well-loved homes.

Yet nowhere within the SPD is it explained how the development of new homes for wealthy people will address these problems. Nor is it clear why this area of inner London (which is typical of many other areas in London) has been targeted for demolition on the basis that some residents are unemployed. Were this to be applied more widely, much of London and huge swathes of property around the country would be demolished not on the basis of condition, but on the grounds that residents were vulnerable and poor. How ridiculous!

60 of the homes on the estates provide family accommodation, nearly all in houses with gardens and parking places, which were built within the past ten years by Housing Associations. These homes, like those built by the Council, were built from the public purse. Yet, though almost brand new, they are proposed for demolition to profit a private developer. This is certainly not sustainable, and cannot possibly be right.

We object most strongly to this obscene waste of public assets in a time of austerity and global warming. We object most strongly to the loss of our gardens, to the cutting down of the many mature trees around the estates, and to the loss of the many open and green spaces we currently enjoy.

There is no rational justification for ‘regeneration’ of the existing homes.

The scale of what is proposed even in scenario 1, would so overwhelm the area as to significantly degrade local people’s quality of life and to restrict economic activity. We would be deprived of the peace and quiet we currently enjoy on our estates, and instead be subjected to the noise and commotion of new roads lined by massive buildings and tower blocks servicing many times the residents and workers here now.

Our estates do not need to be demolished. Following the recent judgement in the Court of Appeal, (SAVE Britain’s Heritage V Secretary of State), there needs to be a environmental impact assessment of demolition for all of the buildings affected, so as to comply with the European Environmental Impact Assessment Directive. This would reveal the true environmental damage this scheme would cause. The environment, local community and neighbourhood would benefit far more through the preservation of the estates, and through sensitive and careful management by the residents through their own housing association.

In terms of economic activity there are two risks:

First, in failing to provide any new genuinely affordable housing poorer people will either be excluded from accessing new homes or caught in a benefits trap caused by excessively high market and near market rents. This means that people living in the new homes would either be at the top end of the earnings scale or would be restricted to those claiming benefits due to the high level of rents chargeable on intermediate properties including the new so-called ‘affordable rent’ model. There would be no place for the working poor, who carry out vital economic functions within inner and central London.

Second, the severe restrictions on car parking spaces available to all the new dwellings (significantly lower than 0.4 spaces per dwelling) would mean that people who rely on their vehicles for work (taxi drivers, trades people, etc.) would no longer be able to carry out their jobs. Existing residents will lose access to parking spaces. New residents would not be able to park either, thereby restricting their access to, and ability to take up employment.

We live in a mixed community, including those who work and a minority who don’t; those who rent and those who own our own homes. We don’t want to become an exclusive enclave for the very rich and we don’t think that is a desirable or sustainable vision for the area.

The SPD as proposed is contrary to the established regional development plan in restricting new affordable homes to intermediate tenures, with the exception of the 188 new social rented homes on the Seagrave Road site (if these are indeed viable), which would necessarily be occupied for the foreseeable future for the decant strategy for existing residents. Indeed principle HO6 goes against the LBHF core strategy, which is itself not in conformity with the London Plan. The Core Strategy says that 40% of new homes should be affordable, of which 100% should be for intermediate housing. However, Principle HO6 of the draft SPD states that “In LBHF, 40% of new housing should be affordable. The priority will be the replacement of the existing social rented accommodation to meet the needs of the existing tenants of the two housing estates. The remainder of the affordable housing must be intermediate, subject to viability.” Replacement homes are of course not net new affordable homes. They should count in addition to, not instead of, the requirement for new affordable housing.

The overall harmful impact of the proposals on our communities and on the quality of life within the area as a whole The proposed planning framework would degrade our quality of life and the future quality of life of residents within our area, taking away the peace and enjoyment we have on the estates and in our homes. It would damage people’s wellbeing now, over the 20 years of the redevelopment programme, and thereafter.

There is no energy impact assessment yet available, but it is likely that the scale of development proposed would have significant negative consequences for air quality, energy use, CO2 emissions and the volume of waste generated on site. The sustainability assessment, such as it is does not explain adequately what steps need to be taken to make any new plans exemplary from a sustainable development point of view.

The transportation and traffic impacts alone should be enough to make the local and regional authorities think again. Nowhere does the draft SPD set out how these effects could conceivably ever be mitigated. We need improvements to the existing infrastructure rather than a renewed onslaught through gross over development of the site.

The proposals are already causing unnecessary damage to the mental and physical wellbeing of residents. People are disturbed by the shocking nature of the scheme and feel uncertain about making plans for the future. This worries elderly and vulnerable people in particular. Where people have many other stresses, this further pressure adds an oppressive burden to their lives.

Fortunately, the community is sustained by its unity against demotion, and by its shared vision to take over our homes using S34A of the Housing Act 1985. 80% of residents signed our petition in the Autumn of 2009 opposing demolition and calling for self-determination, and now we find a similar appetite to join our new community-based association that we expect will take over ownership of the estates.