stop the tower!

Letter from (former) Brent Councillor (Queen’s Park Ward) Jonathon Davies
6 April 2006

QUEEN’S PARK TOWER BLOCK

Many people have been asking me about the Council’s plan to put a 26-storey tower block on the car park next to Queen’s Park Station. The Council is not prepared to have an open public consultation about the proposal. My view is that the people who elected me as their councillor deserve to be informed about the proposal.

The Council was in extensive pre-application talks with the proposed developer, Genesis, from at least the middle of 2004. In April 2005, the Council amended the planning guidance relating to the site to allow for a building of up to 20 storeys, paving the way for Genesis’s planning application for a set of 26+18-storey tower blocks. The Council persuaded them to withdraw it in September 2005 due to the unexpected level of public opposition to the proposal.

Unfortunately, the proposal is not dead. Genesis will be making a new application after the May 2006 local elections when the Labour leadership, if re-elected, will not have to worry about the electoral consequences of building a concrete and glass skyscraper on the edge of a conservation area.

The Labour leadership refuse to change the planning policy for the site, which calls for a 20-storey building. They opposed a LibDem motion criticising the Council’s policy of encouraging tower blocks. Planning permission for a tall building will increase the value of the land. The Council owns the land and has agreed sell it off to the developer, so it has a vested interest in making the tower as tall as possible to maximise profits from the sale.

Brent Council has set up a “Stakeholder Forum” to discuss the new planning application that will be submitted after the May 2006 elections. You might think that is a good idea. It is a total sham. You can’t take part because it is not even open to the public. Participation is by invite only. Just eight local residents have been allowed to attend – completely outnumbered by other people at the meeting who have other vested interests. A genuine public consultation would be open to all.

At the first stakeholder forum, the Council revealed the ground floor plans of three new proposals, but refused to say how tall each proposal would be! The Council will reveal the height of each proposal at the next meeting due to take place after the May election!!! The Council and Genesis came to the meeting unwilling to discuss the height of the proposed building! The conclusion I draw from their secrecy is that the proposed height will be as unacceptable as it was under the previous planning application.

The policy of the currently Labour-controlled Council is to support the proposal. Although I am a Labour Councillor, I am totally opposed to the plan and I am appalled at the Council’s secrecy about their intentions and their refusal to respond to public opposition to the proposal. As a result, I am not standing as a candidate myself in May 2006. I have enjoyed representing the people of Queen’s Park of the last four years and I wish you all a happy, tower-free future!
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Here are just a few of the letters local people wrote to Brent in response to the original tower block plans. Names have been withheld to protect privacy, but have been supplied to STT and Brent.

Dear Sirs,

It came to my attention that you were considering the building of 2 Towers of approx 26 storeys on the car park next to the station…
I am personally dreading it and really would like you to consider very carefully all the implications and all type of huge problems it will add to the already existing unsolved problems in Brent.
We all have difficulties getting a doctor appointment as it is, so I would like to know how Brent is thinking: are you going to establish a new medical centre to accommodate the extra demands? What about a sports centre? Or are we going to have even more youth hanging around not knowing what to do with themselves? Are the Police to your opinion geared up to deal with this huge extra pressure? I had to report an accident last week and had to queue for over 3 hours and so were many other people… I can’t imagine what would happen with this huge new addition, should you take the somehow unwise decision to go ahead.
I am sure that the developer have done financial offers to Brent as they do everywhere else, the problem is that most of the time they do not deliver and always run out of money before the end of their projects.

I am concern with the aesthetic aspect of this tower, most unattractive and the fact it will shadow most of the area. It is also not in keeping with the ‘village-like’ atmosphere of Salusbury road and Queen’s Park.
Are you prepared to organize that Kilburn Lane should also be exempted of congestion charges, as so near to the Zone, or do you view this tower as a definite income-bringer, as you pile all these people on the fringe area?
The increase of Zone C resident will be huge and the spaces are already not enough as it is… so what are you offering to the resident who is already paying you huge amounts for rates?
What do we get in compensation for having our area spoiled by ugly and unwished for skyscrapers? I can’t think of anything you could do to make it even worse. These towers are always a centre for crimes of all sorts; nobody feels safe around them.

I personally really hope that common sense will prevail and that you will realize that those towers would only be the beginning of huge and costly troubles for you and your residents.
I also would like to know how you proposed this development without informing your residents? If you did inform them, how come I did not receive anything and had to be informed by word of mouth? Please kindly note that the way this entire project has been handled is chaotic and wearing a very thin make up to pretend you consulted us while… you really did not, because deep down you knew we would not approve of it……
If that is a sample of the efficiency with which the tower will be built and run, I am afraid it will confirm all my fears about the safety and good running of the area.

So I will certainly ask you when is the consultation period over?
What are the solutions to all those problems?
Why do YOU think it is good for Brent? If it is financial, please explain how you propose to spend the extra income it would bring Brent and how do you think it will benefit to the existing residents?

I am sorry but I DO care and hope you do too.
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Dear Sirs,

Re: Development at Salusbury Road Car Park and 50, Claremont Road, London W9
Your Ref: 05/1317/1941

With reference to the above planning application made by Genesis Housing Group at the site Salusbury Road Car Park and 50, Claremont Road, London W9, I write to ask that the time for commenting upon the Application be extended, and to make to preliminary objections to it.

1.0 Inadequate Consultation period

Brent Council’s initial consultation letter to neighbours was sent out during the middle of July this year. As many people were away on holiday no effective consultation with residents resulted from this letter. I understand that as a result of complaints about the procedural unfairness of the above arrangement the consultation period for the Application was extended to 29 September 2005. As residents were not advised of this extension of time, however, the additional period for consultation has been wasted and consultation has again been ineffective and inadequate.

In view of the significance of the proposed development and its potential impact on the surrounding community, I would therefore ask that a further letter be sent to all affected residents giving them a further short period in which to comment on the Application.

2.0 Non-compliance of the proposal with Government PPG and the Brent UDP

In addition to the procedural objection outlined above, based on what I have seen to date I also wish to make a preliminary objection to the Application on the following substantive grounds which are contrary to planning policy guidance published in the Brent Replacement Unitary Development Plan as well as government PPGs:

1. The bulk, scale and massing of the proposed buildings are out of keeping with the character of the local area, which, aside from the very unsuccessful tower blocks of the Carlton Vale estates, consists of two to four storey houses and mixed use buildings.
2. The shadow cast by the proposed development will have an adverse effect on many of the existing residential properties in the surrounding area.
3. Due to the scale and height of the proposed development, it will have an unacceptable adverse visual effect on the local Queen’s Park Conservation Area.
4. The development is likely to have a serious adverse effect on traffic and parking congestion on the bridge entrance to Salusbury Road. Although the project is described as ‘car free’ this does not account for the fact that many residents will have cars that will occupy local residents parking places if not accommodated on site.
5. The development does not provide adequate amenity space for the number of dwellings
6. For a development of this scale inadequate visual information and architectural detail has been presented. The information does not adequately indicate the visual impact of the buildings on the neighbourhood in terms of streetscape and the architectural quality of the proposal.
7. The proposed development literature suggests that the development consortium will make financial contributions to support local schools and other community facilities. This is unsubstantiated with any documentary evidence.
Please note that these objections are without prejudice to further comments that I may wish to make on the Application following proper consultation with local residents.

I would appreciate confirmation of receipt of this letter as well as any information concerning the progress of the application including the details of the Planning Committee meeting at which the Application will be considered.

Yours sincerely,
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Dear Sir/ Madam

I have recently heard the unsettling and surprising news about the planning application made by Genesis as regards the above site.

I would urgently ask for an extension of time for commenting on this application and to make immediate objections to it.

An extension period for consultation and our views to be taken into account:

Brent Council sent out a consultation letter in mid-July this year. Many people, obviously, were on holiday over this time, and so had no time to seek advice from Brent planning service, and also gave little time to gather a reasonable consensus of opinion on the matter.

It seems that the period for objection to the plans has been extended already, but talking to quite a few neighbours it is clear to say that no one knows about the intended deadline. More to the point, no one seems to know about the scale of the proposed plans, in particular the size of the proposed tower block - 26 storeys.

I would ask that a further letter be sent to all affected residents giving a further reasonable period in which to comment on the application.

Specific preliminary objections:

As well as the above procedural objection, I’d like to object on the following grounds:

1. The height of the main tower block is completely out of keeping with the character of the area.

2. The shadow cast by the proposed buildings will have a derogatory effect on many of the existing residential properties in and around the area.

3. The development would cause a major traffic and parking congestion problem, especially with the intention of diverting a significant new weight of traffic onto Salusbury Rd., an already traffic-heavy area.

4. The increase of traffic on Salusbury Road would be a danger to the local school children at Salusbury School, with the hundreds of children coming in and out of school. As well as the dramatic build-up of pollution this extra volume of traffic would cause. This would be a threat to the health and wellbeing of the hundreds of children at the school.

Please note that these objections are without prejudice to any further comments I might make on the Application, after consulting with local residents.

I would be grateful if you would confirm receipt of this letter and keep me informed of progress with the Application, including details of the Planning Committee meeting at which the Application will be considered.

Yours, sincerely,

Dear Sirs
Objection to Planning Application
Thank you for your letter of 8 July 2005 consulting us on the above application.
The Council website did not allow proper viewing of the reports in the application which would have limited the number of people who could view them and comment. It has also proved impossible to speak to the planning case officer. Therefore more weight should be placed on the comments that are received.
Please find our objections to the application below.
The SKNDC master plan shows that the views of residents of South Kilburn were sought and listened to more closely than residents in surrounding areas and that resulted in locating the tall development to the edge by Queens Park. The tall development is not wanted by anybody but is required to facilitate the redevelopment of South Kilburn social housing and the area around the site under current public funding regimes. This is not a just outcome.
As the need for funding of a larger programme are driving the development proposal at Claremont Road this has resulted in a proposal with insufficient resources and with low aspiration. For successful tall buildings the most excellent design, technologies and management are required. The building design is not excellent quality even in aspiration. This should not be the case for the landmark, major building of the South Kilburn development. This building may set the scene for the future development.
Low aspiration is evident in the sustainability report and the design statement and has resulted in the absence of innovative structural engineering to mitigate wind problems, scant travel plan, choice of architect with no demonstrated experience of tall buildings of this scale, minimal design response to green-walls idea.
The development will increase the number of residents and visitors. Local facilities are already very busy and the applicant cannot guarantee any improvements.
DESIGN
The proposed development includes ugly slab buildings. The application descriptions of the arrangement of internal areas do not disguise the fact that this is a deck access slab building - the same pattern that are being demolished all around.
It does not offer an overall improvement to local residents – the existing low-key eyesore would be replaced by a hugely prominent eyesore with new management problems.
The proposal is out of context. The illustrated view south along Salusbury Rd demonstrates this. The worst facade (north elevation) faces and dominates the conservation area.
The design decreases quality of experience of open space at Queens Park and streetscape at Salusbury Road and Kilburn Lane through being out of context in size and design. It brings the city into the park decreasing the sense of getting away and reducing health benefits of the open parklands. The proposal detracts from the Queens Park conservation area and shades gardens.
The Council’s area planning brief allows for far fewer stories. A maximum of 18 stories with appropriate lower buildings massed around which would bring down the whole scale of development to a more appropriate level. This could reduce all the harmful impacts of the development. If the building narrowed as it rose the visual impact could be reduced and the form could become more aesthetically pleasing.
Non-activated frontage at car park entrance - lack of windows to stair well. On two elevations at the pedestrian entrance to the proposed car park blank walls present to the street and should be more active.
Design statement sketches show new street trees which are not included in proposals.
Caveats in reports and on design drawings undermine their reliability.
Several answers on the sustainability checklist and TP forms are arguable.
Descriptions of some of the possible benefits overlap in the reports and conflict with one another so that it will not be possible to have all the benefits proposed. This is obscured in the reports by different consultants. There is no statement that brings all the conclusions together and clarifies what is being proposed.
TRANSPORT
The existing CPZ’s in the area would need to include weekends to prevent parking congestion for current residents and their visitors. This would be objectionable.
The transport study shows that some local junctions will almost reach saturation. Their study assumes free-flowing conditions and does not allow for non-permitted parking or deliveries which will make the situation worse. More parking management staff would be required at these junction areas.
The assessment of public transport capacity relies on arguing that potential occupants are already using the network in order to conclude that the development will not further strain provision. However the basis of the proposal for a tall building here – the London Plan – aims to provide for several million more people in London over the next 15 years. Therefore each major new development such as this proposal must add to the public transport network. Queens Park station is already congested at peak hours.
The study also does not discuss or take into account comfort on the public transport but talks of total operating capacities not being exceeded which means more congestion, standing and commuter discomfort. This will discourage use of public transport.
Insufficient space at corner of Claremont Road/Kilburn Lane for safe and easy manoeuvres as shown by service vehicle track overlay.
Travel Plan
Coordinator role undefined.
The proposed lift share scheme will not be helpful as there is no parking available!
Inadequate and poorly sited cycle storage. 70 spaces indicated in transport study in private and public areas. This does not allow for visitors cycle parking or to encourage cycling or for adequate storage of family bikes for leisure use. Cycle parking in same area as refuse stores.
6 car club spaces seems much to low for a viable scheme. Could 10 members share each car? This would provide for only 60 people in the club.
ENVIRONMENTAL
Shadow and Wind
Shadowing of business premises and pedestrian sidewalks in the Salusbury Rd local parade will reduce residents’ enjoyment of these areas. Similarly the building’s strong wind effects to be experienced by pedestrians at street level. This will create an inhospitable environment and discourage walking and cycling and make reaching public transport less comfortable.
The wind study caveats include that the context of the building proposal has not been modelled. The wind study should consider the canyon effects of Kilburn Lane, the railway and Harvist Road which could alter findings. The study relies on the slowing effect of the urban area around the site for its calculations. This may not be the case if the wind can flow along a relatively uninterrupted area along some length.
Drainage
There should be questions asked about drainage capacity for the development. There are already floods due to foul sewer discharge in the area in NW6 and at heavy rains the whole system already cannot cope. There should be reports submitted to demonstrate that capacity exists to ensure that backing up does not occur.
Noise/Vibration
There are many ground floor flats in the roads around the site. The increased number of residents, visitors and deliveries would add to noise and vibration in these streets mainly affecting these households. This is not discussed in the noise/vibration assessment and should be addressed so that the impact of the development can be properly taken into account.
Sustainability
Such a building should aim for a score of 75-100 on the Council checklist. More experienced architects and engineers have achieved better elsewhere. This is not the best team to develop this site with such an ambitiously sized building.
The submitted sustainability statement is misleading and analysis should bring the score down further. E.g. so-called external amenity space is not truly flexible as it is decked and therefore does not have topsoil for alterations to planting, does not have easy access except via lift/stair. Any alterations in the future will therefore be very costly and difficult and hence unlikely to be made.
The proposed living wall appears to be of limited benefit and no study is included demonstrating its wildlife benefits. This is one of the key features raising the score on the checklist.
CRIME
The design of the building is sufficiently problematic that the applicant intends to rely on clauses in as yet undrafted leases and resident agreements to attempt to manage the built in potential for anti-social behaviour affecting residents. This demonstrates that the building itself cannot work socially. Once flats are rented out by private landlords such agreements will be forgotten.
Separate and adjacent entrances for social housing and private are divisive and can lead to resentment and anti-social behaviour.
The proposed amenity spaces will allow nuisance from anti-social behaviour within the flats which could be pushed out to local streets and open spaces.
SUMMARY
In summary I would have less objection if the building was lower and more elegant, if the developer offered more improvements to existing facilities for existing residents, if the building scored significantly higher in terms of sustainability e.g. BREAMM excellent standard, if management proposals formed part of the application, if consultation was extended and the website problems remedied, if more design effort was made to mitigate the wind problems and ensure that wind generation has been properly assessed, if visitor parking was clearly assessed and discussed, if the caveats in the reports and drawings were reduced, and if the proposal accorded fully with Council policy.

Yours faithfully,

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Dear Sir/Madam,

I refer to the planning application made by Genesis Housing Group in respect of the above site.

I wish to object to the application on the following grounds:

The scale and height of the building is entirely out of keeping with the area. It is a really preposterous idea to consider buildings of 26 and 18 storeys. Even one of 5 storeys is too high.

The design of the building bears no relation to the style of the area.

The building would cast an enormous shadow, in the immediate environs, blocking what little sun we get in this country. An oppressive thought.

Traffic, already a problem, would be increased and I fear that local facilities would be over stretched.

Yours faithfully,

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Dear Sir,

I wish to complain about the planning application for the above site made by Genesis Housing Group.

I wish to object on several grounds, not least that the consultation process for this planning application has been somewhat suspect, both in terms of active community consultation, timing and the length of time allowed for comments. In view of the significance of the development, I call for an extension to the consultation period and a more proactive, community-focused approach.

My other points of objection are as follows:

Firstly the scale and design of the development is totally out of keeping with the local area. I think 26 storeys is far too excessive, and any development should be limited to a height similar to, or lower than, neighbouring William Saville and William Dunbar houses.

Secondly, there will be considerable destruction of local visual amenity in the Queen’s Park area, particularly in Queen’s Park itself, from which the development will be visible. With the proposed height and scale there will be significant impacts relating to the casting of shadow on the surrounding area. Surely, the reason there is a Queen’s Park Conservation Area is to preserve the character of the area, and although it is just outside the Conservation Area, the proposed development will do nothing to enhance the Queen’s Park area.

Lastly, the application does not adequately address the impacts on local traffic volume, traffic congestion and parking. The Queen’s Park gyratory area is already a highly congested area at peak times and a relatively high volume traffic area in general. I fear the development will exacerbate these existing problems and there is no detail on how they will be addressed or ameliorated.

Yours sincerely