After the recent presentation of plans for the BHL2 section of Blackhorse Lane re-development, BAG has sent the official response of our residents group to Harry Hudson of Green Issues.

We look forward to hearing their reply to residents concerns. 

Download: Word doc: BAG’s response to developers proposal for BHL2

Feedback from the Blackhorse Action Group

Following your recent second public open evening, I am writing to you on behalf of the Blackhorse Action Group, the Residents’ Association for the area bounded by and including Blackhorse Road, Hawarden Road, Lloyd Road, Cornwallis Road, Courtenay Road, Edward Road, Coppermill Lane, Elmfield Road, Salop Road, Stephenson Road and Leucha Road.

As well as providing feedback on the design, housing mix and traffic plans (as you have requested), we believe that there are two other important issues that need to be addressed: local amenities and community safety and crime prevention. We have covered these as well, insofar as they relate to the proposed development.

We have some major concerns about the proposed development because of the following issues. We do not think that the proposals respond adequately to the vision set in:

• • the Government’s Planning Policy Statements and Guidance;
  • the London Plan; and
  • the London Borough of Waltham Forest’s Interim Planning Policy Framework and UDP.

and because of this do not offer a robust strategy for sustainable development. In addition, we are concerned that little regard seems to have been paid during the open evenings to the views of local residents or to their suggestions and the proposals have been put forward as more or less a done deal.

We sincerely hope that this is not the case and herewith offer our own considerations. We would appreciate it if you could please respond to the questions we have raised.

We look forward to hearing from you.

Chair
Blackhorse Action Group

Read on for full document…

DESIGN

We are starting from the basic tenet of PPG1 which stresses the need for good design to promote sustainable development and the importance of design considerations. It states that the ‘appearance of proposed development and its relationship to its surroundings are material considerations in determining planning applications’ and urges the need for new design to improve the quality of the existing environment. PPG3 sets out the need to ensure that ‘new housing and residential environments are well designed and make a contribution to promoting urban renaissance and improving the quality of life’.

Tower blocks

We are concerned that your plan to build a series of high rise buildings does not offer the level of creativity and sensitivity that is so much evident in the vision put forward in the London Plan and Planning Guidance both at a pan London and local level and does not fully take into account its likely impact on the existing residential area. We would also like to make the point that experience of building high rise developments in previous decades has demonstrated how they can, if the design is not exemplary, and if there is not an adequate infrastructure to support the residents, the centre of anti-social behaviour and become ghettos – no go areas for anyone who does not live in them.

Waltham Forest’s UDP (Chapter notes that environmental conditions in West Walthamstow are ‘less satisfactory’ than some other parts of the Borough and attributes this in part to ‘larger slab and tower block estates’. It recognises in this respect that ‘the environmental problems in this part of the Borough are largely due to traffic, noise, pollution, ‘bad neighbour’ uses and lack of building repair and maintenance.

In contrast to ‘larger slab and tower block estates’, it proposes that the ‘design and layout of all new developments should be of a high standard and be seen as providing a worthwhile contribution to the Borough’s environment. Proposals should pay careful attention to the size, appearance, materials and fine detailing of new buildings and in addition demonstrate an equal consideration to the design and layout of surrounding public and private space’.

As the UDP notes, RPG3 urges London Planning Authorities to give careful consideration to the height, density, scale, massing, bulk landscaping, design and architectural quality of proposed buildings. Paragraphs 8.29 - 8.30 of the UDP (First review 2006) notes that:

‘Waltham Forest is characterised by low rise developments such as two storey terraced houses and shops with two floors above. Most of the taller buildings are blocks of flats and maisonettes built in the 1960s and ‘70s and which are now generally regarded as being out of keeping with the character of the area…..in general the erection of further tall buildings is not appropriate in Waltham Forest.’

The London Borough of Waltham Forest has stated in the UDP that it will not normally allow the erection of buildings or other structures which significantly exceed the height of their surroundings. An exception might be where ‘the development is of high architectural quality and does not have serious disadvantages to its immediate surroundings’. Paragraph 8.31 notes that it is particularly inappropriate to erect tall buildings in or next to Green Belt land or Metropolitan Open Land as this would spoil the open character of these areas. We would add to this that it is inappropriate to erect tall buildings adjacent to the Lee Valley Special Protection Area.

High density at a reduced height

It is our understanding that this site is a Major Opportunity Site as identified by the London Borough of Waltham Forest, but is not in the Opportunity Area (as set out by the Mayor in The Opportunity Area Planning Framework, Strategic Planning Guidance, January 2007). Even if it were, the Mayor has made it clear that high density housing does not necessarily mean high rise blocks. (London Plan Supplementary Planning Guidance 2005. Indeed in paragraph 5.4 the guidance notes:

‘Different forms of development can have similar densities. High density does not always mean higher rise development, and there are many studies that explore how high density schemes can provide good quality attractive housing and ensure the most efficient use of land’.

There is an inference in this paragraph that higher rise developments do not mean good quality attractive housing and this is a sentiment we share.

We are keen for your views on how you consider that the proposed development, including now a 23 storey building (higher than at the previous presentation) addresses these issues and how you have responded to the London Borough of Waltham Forest’s policies on high buildings, conservation areas and areas of special character.

High standard of design and architectural quality

In the proposals you have put forward (both on the Green Issues website and in the public displays) you make reference to ‘a high standard of design and architectural quality’. It would be helpful if you could advise in what ways this design and architectural quality is of a high standard.

We would also appreciate it if you could give us details of how you will achieve such high quality standard (including methods and materials. Indeed, in this landmark development we are keen to see that the quality is of the highest standard. In relation to the use of sustainable building practice in the development we are disappointed that developers are only working to achieve Code for Sustainable homes level 3 (on the basis that this is the minimum requirement to attract funding for social housing from the Housing Corporation). For the development to be exemplary, as the LWI suggests it is, we would like to see the development achieving level 5. This has already being achieved in other London Wide Initiative schemes in London.

Physical environment

You state that the development: ‘will make a significant contribution to improving the physical quality of the area, whilst respecting the nature conservation value of its location’  and ‘The form, scale and layout of the development respect the character and amenity interests of the adjoining residential streets whilst making full use of the site’.

Whilst some of the land is not being used, and indeed has been left to deteriorate (pending planning applications as regards the site adjacent to Blackhorse Road tube station), there is an argument that any development will improve the physical quality of the area. However, we strongly dispute the assertion that what is being proposed respects the nature conservation value of its location.

As you know, the adjacent land is a mix of playing fields, green belt land, marshes and a Site of Special Scientific Interest (SSSI) with a wide variety of breeding species and protected by European Law. We believe that it is fundamental to incorporate this landscape (together with the existing architecture) into any future design plans. We fail to see how buildings that rise to 23 storeys achieve this in a sympathetic way.

Lack of private and defensible space

The ‘Strategic Guidance for London Planning Authorities’ issued by the Government Office for London in 1996 stressed the need to consider the desirability of private and defensible space. We question the most recent design with what appears to be a brick wall surround, a carpark behind and a concrete podium above. A more attractive frontage of shops and other working and recreational spaces (including shops, cafes and other services) on the ground floor instead of garages would create a safer and more animated environment on the streets. In terms of a layout we believe a better design would be a perimeter block providing a street which would facilitate surveillance with private and defensible space in front of the dwellings.

Economic regeneration

You note that these buildings will: ‘…contribute positively to the area by becoming landmark buildings and by promoting regeneration through improved economic confidence in the area’.

We remain to be convinced of this, and would appreciate further information on how this might be the case. At a time when there is some uncertainty in the housing market, and when little flesh has been added to the bones of the other development plans in the Blackhorse Lane area, we have strong concerns that these buildings will not on their own provide the catalyst for regeneration that Walthamstow so dearly needs.

The London Plan (3.31) notes that large scale residential developments present the potential to provide not only additional housing and related uses, but to create a new sense of place with its own character and identity where people will want to live and work. Overall we very much doubt that the designed concept aims to meet the Mayor of London’s requirement for maximising residential development in sustainable locations.

A ‘sustainable location’ is not simply an area close to a tube station, served by few buses. A sustainable location with a ‘sense of place’ will enable residents to live, work and socialise, there. In order for this to happen, there needs to be a social, economic and service infrastructure in place. Jobs, services, amenities, leisure, culture, work and community spaces are essential to a ‘superdensity’ development such as the one proposed. Your current proposal means that potential residents will have to travel and commute either using private means or public transport to work, shop and go out. A sense of community and neighbourhood will never be achieved in his way. The Mayor, in his Housing Strategy draft announced recently stated:  “We will create communities that are strong, inclusive, safe and sustainable and supported by excellent social, physical and economic infrastructure. We will help to empower residents”

HOUSING MIX

The UDP notes that the current estimated population of 221,000 living in 93,000 households is likely to remain stable and fall slightly over time. However, projections to 2016 suggest that one person households will dominate and this will result in a 22,900 increase in the number of households, giving a predicted total of 115,900.

We understand that the aim is to create 2000 new homes in the area over the next 10 years. The current plans propose:

• 418 units
• 672 HrH
• 46% private
• 18% LWI
• 30% Affordable rented
• 6% Shared Ownership
• 100% lifetime homes.

Proportion of new units in this development

There are a number of issues surrounding the housing mix that cause us concern. We were under the impression that this site was part of a larger development of the Blackhorse Lane area and that as such it would be accommodating some of the 2000 new homes. Given the area concerned, we had not expected that it would be accommodating  over 25% of the new homes. We believe that there is a need to reconsider the extent to which this site CAN accommodate this many homes and be sustainable especially without provision of services, amenities, work and community space.

We would strongly argue for the number to be reduced. In addition, we have serious concerns about the claim made in the IPPF that:

‘the Station Area might qualify for density of up to 450 habitable rooms per hectare and also with reference to  the London Plan that higher densities might be appropriate in urban areas with good access to public transport if low levels of car parking are provided. It also adds that for sites within 10 minutes walk of a Town Centre and with good access to public transport could be suitable for higher densities, of up to 700 habitable rooms per hectare’.

Whilst the proposed development does have access to the tube station and to some local buses, there is a question around the capacity for public transport to accommodate a large increase in the number of residents. We will cover this in the next section.

LWI units

We had understood from earlier discussions that the percentage of housing allotted to the LWI was higher than 18%. We would be pleased to receive any information you have about the projected demands for housing in this area in the coming years as well as any work you have done to identify how you might increase the number of units owned by cooperatives and other types of housing association. In addition, it would be helpful if you could advise which organisations will own the properties that are offered for affordable rent and shared ownership. The previous plans identified more social and less private housing than the current plans. Could you please explain why this has happened?

Number of family homes

The percentage of family homes is only 13% in your plans. Could you please explain the criteria used to decide that that is the proportion of family homes most appropriate for this area? Could you also please provide an explanation of how you arrived at this proportion.?  Additionally it would be helpful if you could confirm that  family homes for this development are at a minimum  3 bed-bedroom flats.

People living alone

The London Plan notes at 3.29 that lifestyles are changing with people working from home and people living alone who no longer require one bedroom flats and bedsits because they need a spare room for visitors, carers and families. It would be helpful if you could please supply the room sizes for  all types of dwellings.

TRAFFIC PLAN AND TRANSPORT ISSUES

Roads

One of the key issues for the surrounding neighbourhood is the impact that this proposed development will have on road, rail and tube facilities in the area.

As far as the roads in the area are concerned, we understand that the plan is to make Hawarden Road one way (with cars not being able to enter the Road from Blackhorse Road). This will mean that cars accessing the BAG area will be forced to use Lloyd Road or one of the other Roads which will increase the level of traffic. Blackhorse Road and Ferry Lane already suffer from severe traffic congestion particularly during the rush hour, but there is a constant flow of traffic throughout the day. We are concerned that this can only increase with the current proposed development and a further 1572 homes planned for the area.

In addition, the plan is to allow 30% parking provision in the proposed development. We are keen to hear how this limit is going to be policed, particularly if a number of the units are going to be privately owned and owners may argue that they need their cars. We are concerned that car owners from the proposed development, unable to find a parking space in the development, will park their cars in the BAG area (on the basis that not all roads in the BAG area are part of the Controlled Parking Zone). This will cause problems for current residents if they are unable to find a space to park their car.

Whilst we welcome the proposal for an on-site car club with membership for all local residents, we would question how this is going to work. It is difficult to be precise, given that we have not been given an indication of what the likely occupancy rate is going to be of the proposed development, but in the event of there being at least 1000 residents and 124 parking spaces, there would appear to be a likely high demand for the car pool. It would be helpful if you could indicate how many people you envisage living in the development and how many cars there will be in the car club.

Two other initiatives you plan to introduce are: ‘Good quality, secure cycle parking for all Scheme residents and visitors’ and ‘Safe, convenient walk links and pedestrian priority in the Scheme’s Home Zone’.

We are keen to see these programmes supported in any development, but have concerns about the security and safety of the area in general (and specifically in relation to theft and personal security) because of the way in which the development has been designed. I will return to this in the Crime section below.

We are also having difficulty in envisaging how these programmes will be inclusive and involve the existing community. We question the extent to which the development will be open to non-residents. The current drawings suggest a quasi-gated community with little access to people outside.

Rail and tube provision

You have noted:

‘With good rail and tube connections to London it is the view of Waltham Forest Council that the Blackhorse Lane is an area with significant untapped potential, adjacent to the wonderful natural resources of the Lee Valley Regional Park’.

The majority of people who use Blackhorse Road station do so for the Victoria Line and not for the overground service. In addition, the overground system does not run into central London. Indeed, many people who do not live in the area change from the overground to the underground at Blackhorse Road. This means that underground is already stretched and with this proposed development (and future plans for more homes) can only become more stretched. As anyone who lives in the area will know, the Victoria Line often suffers from delays and parts of the line being closed (including the section from Seven Sisters to Walthamstow). In addition, last year and this, the line is closing at 10pm each evening for repairs. Any limitations in the service have an enormous impact on the current residents – and this can only get worse when the number of residents in the area increases.

This pressure could lead to a move by an increasing number of residents to either opt for car use or to opt to take a bus. Bus services in the area are already stretched and often held up because of traffic congestion – we would appreciate feedback on how you envisage this working. 

Furthermore, proposals need to take into account further developments in Walthamstow, Tottenham Hale and Seven Sisters. All of these sites are on the Victoria Line which is the only Underground Line. Any discussions about the ability of the Victoria Line to absorb the capacity from this proposed development need to take into account the future demands on the service which will be an inevitable consequence of this proposal and future development.

LOCAL AMENITIES

The UDP notes in Chapter 5, a more equitable, and locally based, provision of services (including education and health) and recreation and leisure facilities should be achieved. Paragraph 5.28 states:

‘There may be opportunities in the development of the Major Opportunity Sites and other major schemes to include community facilities that would otherwise become over-extended or are absent in the surrounding area’.

Impact of proposed development on existing services

We are concerned that the current proposals do not fully address the impact  this development will have on local services (and no attempt has been made within the context of this proposed development to explain how it sits alongside other projects for the other side of Forest Road/Ferry Lane).

We would be grateful if you could provide further information of the projected needs of the proposed residents (including their demography) together with information about what services will be available within easy reach of the development. We would like clarification in relation to:

• Education
• Health
• Leisure
• Community centres
• Religious buildings
• Services for children and young people
• Services for young families
• Services for older people
• Services for people with disabilities

PPG 17 sets out requirements for local sports and recreation facilities and PPS 3 identifies what play looks like within new housing developments.

The Mayor of London’s Supplementary Planning Guidance (November 2005) notes at 5.10 that where a development includes family housing, accessible play spaces designed to meet the needs of younger and older children should be provided, taking account of the projected child population.

We understand from your proposals that you will contribute to improving play facilities and areas that already exist in the locality of the site and are identified for improvement by the LBWF offering improved access to those within walking distance e.g. at Stoneydown Park and Garden or Coppermill Park. We have concerns about the reality of these venues, particularly for young children. A walk from the farthest tower block to these locations may be ill-advised for children who are not accompanied by adults. Without these, however, it is difficult to see where children will play.

COMMUNITY SAFETY AND CRIME PREVENTION

DOE Circular 5/94 ‘Planning out Crime’ states that crime prevention is also capable of being a material consideration when considering planning applications. The need to take into account crime prevention is also part of PPG 3. PPG3 stresses the need to ensure that new housing developments respect and enhance the local character and designs and layouts are safe and take account of public health, crime prevention and community safety considerations.

We are concerned that the current design does not allow people to easily access the development. In addition, the lack of ‘sense of space’ and defensible space will result in residents not feeling a sense of ownership of common areas which will lead to them being neglected and potentially becoming a focal point for anti-social behaviour. There is a risk under the current proposals that there will be a lot of residents who lack the opportunity to access amenities including shops and leisure facilities and could instead become nuisance residents.

Added to this, we are concerned that if many residents are going to be at work there will be potential for criminal activity to take place unnoticed because of the layout of the blocks. 

We understand that there has been recent criminal activity in Stephenson Road where there is a new development. That development is now protected by a security company 24 hours a day. We would be disappointed if this were to be one of the outcomes of the proposed development.

It would be helpful to hear what consideration has been made of crime prevention in this development and whether you have developed a Crime Prevention Through Environmental Design strategy. In particular, it would be helpful to know whether (as is recommended in the UDP) you have contacted the Metropolitan Police Service Crime Prevention Design Advisers and what they have contributed.

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