West Kensington and Gibbs Green Estates Tenants & Residents Associations Response to OAPF SPD Document ‘Earl’s Court and West Kensington 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 LiLLie Bridge 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 London. 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.