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Objection - Revised Planning Application for Queensland Road - P08/2018
Highbury Community Association objects to this application on six grounds: - The residential density is too high
- The buildings are too tall
- The “Affordable Housing” is segregated
- Provision of Amenity Space falls far short of the required level
- The application, the last part of the “Arsenal scheme” still does not provide a final resolution of the Matchday Coach Parking issue.
- These plans have no "Architectural Merit", which was used as a “defence” previously
- We will now lay out the grounds for our objection in more detail.
1. The residential density is too high
The residential density of the proposed development is 933 hr/ha as compared with 790 hr/ha for the previous application. We maintain that the residential density is too high for two reasons:
a) The density is much higher than that deemed acceptable by the London Plan (2008).
The applicant maintains that the area where the development is to take place has the characteristics of a "Central" area as defined in the London Plan Density matrix (2008). We do not agree with this assertion for two reasons: It is not up to the applicant to define the characteristic of the neighbourhood under the density matrix. It is the prerogative of Islington Council to define this. However, we have seen no statement from Officers defining this. Until such a statement is made, no assessment of the appropriateness of the density may be made and the application may not proceed. However, since the applicant has made their own assertion here, without any supporting arguments, we offer our own reasoned assessment of this. We assert that the area where the development is to take place has the characteristics of an "Urban" area as defined in the London plan. This is for the following reasons : The London Plan (2008) has the following definitions of "Central" and "Urban" areas: - Central – areas with very dense development, a mix of different uses, large building footprints and typically buildings of four to six storeys, located within 800 metres walking distance of a International, Metropolitan or Major town centre
- Urban – areas with predominantly dense development such as for example terraced houses, mansion blocks, a mix of different uses, medium building footprints and typically buildings of two to four storeys, located within 800 metres walking distance of a District centre or, along main arterial routes
- As the area of the proposed development:
- Is not an area with "very dense development",
- Does not have "large building footprints", except for the actual football ground, which does not count in this assessment as it is ancillary to this very application,
- Does not consist of buildings of four to six storeys,
- Is mostly more than 800m on foot from the Nag's Head, a "Major Town Centre" as defined in the London Plan. We accept that a small part of the area is just less than 800m away on foot.
Therefore it is not a "Central" area as defined in the London Plan (2008). This would seem "self evident" to anyone visiting the area. The "Angel" may well be a "Central area", but a minor industrial estate in a "cul-de-sac" in Lower Holloway, of one to two storey workshops and warehouses would not strike anyone visiting it as a "Central area"! We do agree with the PTAL (Public Transport Accessibility Level) rating of 5. Applying a PTAL of 5 to an "Urban" area as defined in the Density Matrix gives an allowable density range of
200 – 700 hr/ha. The 933 hr/ha proposed by the applicant exceeds this range by a considerable margin. The density of 933 hr/ha is higher than that for the previous application for this site, which was 790 hr/ha.
In the officer's report of the previous application, the officer acknowledges that this figure is far higher than the policies allowed, but justifies it under a series of headings which we will address later under item 5, "Architectural Merit". Since the Council's policies on density have not changed since that time (the UDP policies did change prior to the report) and the figure is even higher, the officer's point still stands.
2. The buildings are too Tall We maintain that the buildings are too tall for two reasons: b) The tallest building in the previous application was 42m high.
At that time, the Council's Conservation Advisory Panel stated: "The Panel remained very concerned about the excessive height of the residential blocks rivalled the centrepiece of the stadium in an unacceptable fashion. The scale of the blocks would also have a harmful impact on Drayton Park and the adjacent school."
The officer made the following points in the report on the previous application: - "The remaining elements straightforwardly break the policy." This point included the Queensland Road developments.
- "It is then argued that the high buildings adjoining, the Plaza and north Queensland Road buildings, need to be of an equivalent height" (to the stadium, implied).
- "The remaining buildings – the Plaza, the Queensland north ‘fingers’ and the Northern Triangle – are, however, a different matter. As a cluster the first three could detract from the architectural integrity of the stadium itself, spoiling the hierarchy of scale which the stadium should establish. Further, they would act as precedents elsewhere in Holloway or Highbury."
Rather than taking these comments into account in the new application, we find the maximum height increased to 49.4m. The points made previously by the officer apply even more strongly to this new application. We do not believe that the height of this new application is acceptable. This area is not included in the list of locations in the Central London area where the Mayor will promote tall buildings, as defined in October 2007: Eastern City cluster, North western City cluster, City Fringe – Aldgate, City Fringe – Bishopsgate, City Fringe - Old Street, London Bridge, Bankside, Elephant and Castle, Waterloo, Victoria, Euston Road, Canary Wharf, Vauxhall/Nine Elms.
Therefore buildings of more than 30m high should not be permitted in this location.
3. The “affordable Housing” is segregated
The London Plan (2008) says: "Affordable housing should be integrated with the rest of the development and have the same external appearance as the rest of the housing." Yet, across the development we only find one building with both "affordable" and "market rate" units and even this is divided into two parts – lower floors as "affordable" and upper floors as "market rate". We find no evidence "conformance" with the requirement as stated in the London Plan. Since there is this level of segregation, it impossible to assess the second part of the requirement. The affordable housing should be integrated across the development on a unit-by-unit basis. 4. Provision of Amenity Space falls far short of the required level The standards for the provision of Amenity Space have not changed since the previous application. 30sq.m. must be available for each “Family Dwelling”. This was taken to mean all units with two or more bedrooms. This application contains 356 such “family units”, now requiring at least 10,680 sq.m. of Amenity Space to be provided. In the application, the applicant does not actually perform this calculation nor show how such a requirement would be met. However, in looking at the figures in the Appendix 5 of the Planning Statement, it can be inferred that the provision of Amenity Space falls far short of this requirement. The applicant should furnish figures for the provision of Amenity Space and these should be judged against the required standard. 5. Final resolution of the Matchday Coach Parking issue At present, the issue of "Matchday Coach Parking" continues only to be addressed in an interim fashion. This development finishes the "physical redevelopment" of the area around the new stadium and is built, in part, on the space that was previously proposed to house the coaches. The remainder of that space is already part of the stadium. As there will be no further major applications associated with the redevelopment, the resolution of matchday coach parking should be included within it. It is not satisfactory to talk vaguely of a "parallel process" to determine this, as this process will have no leverage against the applicant, this application being determined separately. The resolution of the coach parking must be included within this application. 6. Architectural Merit Although we opposed the previous application for Queensland Road, the buildings, designed by Piers Gough, were visually interesting. They had various curved profiles, interesting details to the tops of each building and a range of colours. They were not like any other buildings in London and complemented the curved shapes of the "Signature Building" of the development – the Stadium itself. The officer's report used the following points in particular, to justify the violation of many of Islington's Planning policies: - "The urban design context: What is proposed clearly differs from the present context but is of a scale to generate a fresh one of its own."
- "The quality of building design (is) Outstanding"
We maintain that the present design is NOT of a "scale to generate a fresh one of its own", but in fact "overpowers" the design of the Stadium and diminishes its design context. We also maintain that this application is mundane, pedestrian and similar to many other developments across London. It in no way "echoes" or "complements" the Stadium, has no interesting design features whatsoever and we wonder whether Piers Gough has had any real hand in its design at all! Comparing it with other works of CZWG across London – Hopton Street, for example, which does relate well to the nearby Tate Modern, you would not think this scheme was produced by the same architects. We do not believe any resort to "Architectural Merit" in defence of breaking so many policies is possible with such a routine design. Therefore we do not think this application should be approved.
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Queensland Road (Arsenal)