Brian O’Donnell Strategic Lead – Planning Policy Department: Planning London Borough of Camden Our reference: LDF06/SPDs/SPD01/HA01 5 Pancras Square Date: 28 January 2020 London N1C 4AG By email: [email protected] Brian.O'[email protected] Dear Brian, Statement of general conformity with the London Plan (Planning and Compulsory Purchase Act 2004, Section 24(4)(a) (as amended); Greater London Authority Acts 1999 and 2007; Town and Country Planning (Local Development) (England) Regulations 2012 RE: Kentish Town Planning Framework November 2019 (SPD) Thank you for consulting the Mayor of London on the Kentish Town Planning Framework SPD. As you are aware, all Development Plan Documents in London must be in general conformity with the London Plan under section 24 (1)(b) of the Planning and Compulsory Purchase Act 2004. While it is noted that the draft document is not a Development Plan Document, it has elements of strategic importance that are considered worthy of the Mayor’s input. The Mayor has afforded me delegated authority to make detailed comments which are set out below. Transport for London (TfL) have provided comments, which I endorse, and which are attached at Annex 1. This letter provides advice, setting out where amendments should be made so that the document is more in line with the emerging draft new London Plan. The draft new London Plan As you already know, the Mayor published his draft new London Plan for consultation on 1st December 2017. The Panel’s report, including recommendations, was issued to the Mayor on 8 October 2019 and the Intend to Publish version of the London Plan was published on the 17 December 2019. Publication of the final version of the new London Plan is anticipated in March 2020, at which point it will form part of Camden’s Development Plan and contain the most up- to-date policies. General The Mayor welcomes Camden’s ambitions to deliver much needed growth in the Kentish Town Framework area and recognises the positive contribution it can make to delivering development across London for industry, jobs and genuinely affordable housing. It is understood that this location has been identified as an area for potential growth over the long term. The site was originally designated in Camden’s Local Plan for employment-led comprehensive redevelopment. It must be recognised that since that time, based on strategic evidence, the Mayor’s strategic approach to the management of London’s industrial land has become more proactive. As it stands, the ambition of the framework to accommodate around 2,000 new homes and over 3,000 jobs would only be considered acceptable where it is able to also demonstrate the area’s ability to take on the Mayor’s priorities for the retention of valuable industrial land in close proximity to the Central Activities Zone (CAZ). The draft SPD early on provides a comprehensive contextual analysis which is welcome. A map illustrating the area’s geographic relationship with the CAZ is included at page 18 which is welcomed. However, the implications and opportunities arising from this should be considered and prioritised where appropriate in line with draft new London Plan Policy SD4. Industrial Capacity Kentish Town Industry Area is the only designated industrial site in Camden. It is comprised of two parts: Regis Road Growth Area to the south and Murphy’s Yard to the north. Camden’s adopted Local Plan establishes the Regis Road Growth Area as an area for mixed use development, resulting in the release of its industrial designation. Murphy’s Yard, on the other hand, still retains its industrial designation as Locally Significant Industrial Land (LSIS). As Murphy’s Yard is the designated LSIS, the Mayor’s preferred approach is one where the remaining industrial part of the site to the north (Murphy’s Yard) is retained and industrial uses intensified to offset any losses of industrial floorspace as a result of the redevelopment of the Regis Road Growth Area or elsewhere in the borough. The approach to be followed is set out clearly in the draft new London Plan Policy E7 and supporting guidance. Camden is identified as a ‘retain capacity’ borough in Table 6.2 of the draft new London Plan. This means that Camden should seek to intensify industrial floorspace capacity following the general principle of no net loss across designated LSIS. Camden is also located within the Central Services Area and should therefore be seeking to prioritise the provision of essential services to the CAZ and in particular sustainable ‘last mile’ distribution/logistics, ‘just-in-time’ servicing (such as food service activities, printing, administrative and support services, office supplies, repair and maintenance), waste management and recycling, and land to support transport functions. This makes it especially important that existing B8 and B2 uses are specifically identified early on and their wider CAZ significance taken into account. The Mayor strongly encourages Camden to recognise the importance of these uses by identifying and protecting or relocating them as part of the emerging Local Plan so that they can continue to serve the important functions of the CAZ. In light of the above, the development objectives listed on page 40 should be amended to include the principle of no net loss of industrial floorspace capacity across both sites with a strong emphasis on the prioritisation of B8 and B2 uses, reflecting the implications of the area’s relationship with the Central Activities Zone. Camden should set out a clear strategy as to how its industrial floorspace will be protected, intensified and increased to meet local and strategic demand, especially within LSIS. It should be noted that the strategic evidence shows the greatest demand is for B8 floorspace, and Camden’s framework should ensure it provides sufficient capacity for this type of provision in line with draft new London Plan policies SD4 and E4 and Paragraph: 031 Reference ID: 2a-031- 20190722 of the revised Planning Practice Guidance. The Mayor expects the framework to follow the guidance set out in his practice note on industrial intensification through plan-led and masterplan approaches. Following on from this, Camden should conduct an industrial land audit in the first instance to establish the exact quantum and nature of existing industrial uses across both the Regis Road Growth Area and Murphy’s Yard. In accordance with the Mayor’s Practice note on industrial intensification and co-location through plan-led and masterplan approaches, phasing should ensure that proposed intensified industrial development is delivered and completed in advance of the residential components; and the approach to decanting and relocating any businesses affected. Housing The Mayor supports the introduction of housing where it is established through evidence that there will be no resulting net loss of industrial capacity and that industrial activity can continue unimpeded (or improved) by the careful introduction of non-industrial uses in accordance with draft new London Plan Policy E7. The framework should recognise that the approach to affordable housing has changed, and the draft new London Plan has introduced the Threshold Approach as set out in Plan Policies H5 and H6. The threshold for the Fast Track Route is set at 35% and this increases to 50% where there is a loss of industrial floorspace capacity across the whole site i.e. both Murphy’s Yard and Regis Road Growth Area combined. It should be noted that the strategic target for the delivery of affordable housing is set at 50% and the framework should be amended accordingly to reflect this. Offices A large part of the southern end of the borough lies within the CAZ and as such Camden should prioritise the development of office space within that area in accordance with Policy E1 of the draft new London Plan. In addition, the office guidelines identify those town centres within the borough where office development is considered appropriate. Beyond the CAZ the office guidelines, as set out in Table A1.1 of the draft new London Plan identifies Kentish Town as having mixed use office potential and Kilburn, Camden Town, Hampstead and Swiss Cottage/Finchley Road as areas where existing office functions should be protected. Therefore, in line with the draft new London Plan Policy E1, Camden should be directing office development towards the CAZ and the town centres identified as part of the office guidelines. The intention to create new office floorspace within industrial areas does not reflect the draft new London Plan which promotes a town centres first approach. As the Regis Road Growth Area lies adjacent to the Kentish Town Town Centre boundary, the SPD should explore how it might extend that boundary so that any proposed offices are focused within an enlarged town centre and policies should ensure a range of town centre uses are provided. Waste The Regis Road Reuse and Recycling Centre is identified in the draft North London Waste Plan in Table 17 and is a safeguarded site. This should be identified and set out clearly in the framework. The framework currently mentions the re-provision of the recycling centre and this should be prioritised in order that the North London Waste Plan can effectively achieve net self sufficiency in accordance with draft new London Plan Policy SI8 and the Mayor’s ambition that 100% of London’s waste should be managed within London by 2026. The loss of the site could potentially mean that Camden is no longer able to meet its waste apportionment figure and that would be unacceptable. The framework should identify suitable reprovision prior to the existing sites release from its waste designation. Transport As referenced within the consultation document, TfL has contributed a Future Transport Context (FTC) Report to the evidence base and officers have appreciated the opportunity to work with Camden Council policy officers on production of this final draft of the planning framework.