The overdevelopment of this site was drawn to my attention by the residents of the Princesses Louise Close, Winnicott House, Mary Adelaide House, 149 & 151 Church St, Paddington Green who’s HA landlord had given over their rights to light easement in the first phase of West End Gate development, to a previous developer.
The further development of the site immediately South of West End Gate further takes away any light easement they may have left now, more so with the latest proposal of actually increasing the heights of the three towers on the Paddington Green Police station site, one even taller than the Landmark Tower. The above photo illustrates this well.
The height and bulk of the proposal also affect the air and light easement to the East of the site, on the opposite side of the Edgware Rd, along Penfold Place & Corlett St, NW1, particularly affecting Miles Buildings which has some of the poorest private rented properties in the City maybe in the whole of Greater London. Please see the above photo again.
Another area of concern relates to the quality of the accommodation being provided in terms of natural daylight and sunlight. A number of the affordable flats, especially those in the Western elevation of Block K and the East and West elevations of Block J, will have exceptionally low levels of light well below the BRE guidelines. Whilst it is recognised that the provision of recessed balconies will affect light levels to these flats, overall it is considered that these flats will have poor levels of light and outlook, and this is very disappointing given these are the affordable housing units. So in terms of the impact of the proposal on daylight and sunlight to existing neighbouring buildings and those also being raised by the revised proposal, I do not consider that the revisions have addressed the losses of daylight and sunlight to adjoining residents and consider that the increase in the height of the buildings has worsened the impact of the development overall, when compared to the 2021 scheme. So as to maintain my original objection on this ground.
Finally in regards the bulk and height of the proposal, it also has an impact on the skyline of Little Venice and indeed the Westway has not been considered at all. This is particularly concerning after the protests over the Brunel Building in Hyde Park ward from Little Venice residents. These residents would have expected these concerns to be addressed in this instance particularly as it is in one end of Little Venice Ward.
The proposal thus fails to provide high quality residential accommodation and is contrary to policy D6 of the London Plan (March 2021) and policy 12 of the City Plan 2019-2040 (April 2021).
Façade Design Inconsistences
As for the facade design, it does not have any continuity of design with phase I of West End Gate. The changes made are in some respects subtle, but overall has the effect of making the use of metal and glass more prominent as now proposed than the use of masonry cladding elements. Those residents l have met in West End Gate in Bond, Jeremy & Garrett Mansions, have found the facade agreeable to them, so l do not see why this use of orange masonry has been dropped by the developer for aluminium and smaller windows.
Public realm Design – Misses the subways!
Whilst I understand the Towers have been squeezed to make more space between the towers between the two proposals for Paddington Green Police station site albeit increasing the height of the three blocks, l am sorry to see no consideration of the landscape to the Marylebone flyover junction and in particular the blocked up subways owned by TfL and managed by the Council which the Towers would be almost on top off in the proposal.
Increase in the amount of the public realm from 3,553 sqm to 4775 sqm, decrease in play space provision from 1138 sqm to 841 sqm. The revised proposal also includes improvements to the Harrow Road subway. And a complete stopping up of Newcastle Place and partial pedestrianisation of Newcastle Place with the exception of servicing by small vehicles.
It is clearly an opportunity for TfL to invest in these assets along with the developer and bring it up to required active transport standards for all users.
Housing elements Concerns
The development proposes only 38% affordable housing, below the required 50% on GLA planning policy for land formerly in the public sector (Pol. H5), this is contrary to one of the main objectives for the London Plan.
The revised scheme increases the total level of affordable housing to 219 units (38% as opposed to 37% by habitable room in the 2021 scheme). The tenure split has also been amended and is now 59.9%:40.1 split social rent to intermediate compared to 48.6%:51.4% in the 2021 scheme, by habitable room. And a slight increased amount of family sized homes within social rent (44% as opposed to 42%). The affordable housing flats are now located in Block J and the lower floors of Block K.
Shared Ownership Affordability
Concern is raised about the affordability of the 43 Shared Ownership Units. Low cost home ownership is generally unaffordable in a high value area like Westminster to households registered with the Council’s Intermediate Housing Service, either because their incomes are not high enough or households do not have sufficient deposits.
Based on the development’s average proposed pricing this development is knowingly unaffordable to local residents not only in the LSOA (Lower Super Output Areas), ward but the majority of the borough. This proposal’s average prices would also seek to further deepen the level of unaffordability as compared between average wage and house price. Therefore, this proposal is clearly unaffordable, and exclusively priced which would exclude an overwhelming percentage of local residents, and those in the borough. The Council would clearly prefer shared ownership changed to intermediate rent.
The return of “Poor Doors”
98 social rented homes will be provided within block J (17 storeys), which is a 100% affordable housing block. A further 11 social rented homes, 67 discounted market rent units and 43 shared ownership units will be located within the tower building, block K (39 storeys). The social rented homes will be located on the 1st floor and part 2nd floor. The intermediate homes will be located from part 2nd floor to part 12th floor. Market housing units will occupy the remaining upper floors.
The affordable housing units will be provided with their own separate access arrangements and separate cores. I am not sure this is acceptable in this day and age and l had thought we had moved on from those days and given some of the adverse publicity of other schemes in London with similar access issues, it is regrettable that it is even being proposed here.