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1. Legitimacy. Having read the Framework and supporting papers I am confused as to its significance. Paragraph 1.23 describes it as having very little weight at present but that this may increase. Previous SPDs, notably that for Shepherds Bush Market which forms part of the WCOA, have been legally challenged and quashed. This seems to have created some uncertainty in the Council’s mind as to the purpose of SPDs. Planning Committees have been instructed to ignore those for Shepherds Bush Market and West Kensington; other major development areas like Hammersmith Town Centre have struggled on without them The most important guidance in the Framework is that based on the Development Infrastructure Funding Study (DIFS). But this document is based on hypothetical and speculative reasoning as to the amount it is reasonable to expect developers to contribute to public benefit. It appears to have been devised as a piece of defensive briefing to validate the Council abandoning its own targets for affordable housing. As the Council’s officers have told me the ‘outcome from the DIFS therefore need to be used with caution.’ It does indeed as it is a political rather than a financial appraisal. In any event the Framework is about two years too late. Most of the major sites have already received planning consents without the benefit of the Framework. Because the development of White City has therefore progressed in a piecemeal, anarchic way, some of the consented schemes are already proving unfeasible and sites are changing hands (eg Dairy Crest) or new applications are being prepared (eg Westfield). Bizarrely this means that the Framework despite its lateness already looks out of date. 2. Affordable Housing. As the document notes, White City is in the top 5% areas of deprivation in the UK, housing overcrowding is 18% and house prices, to rent or buy, are beyond the reach of White City residents Against this background the Council voluntarily lowers its target for affordable homes from 40% to 15%. But in reality this is 5% as the 10% of social rented homes must be filled by emptying and disposing of social rented housing
elsewhere, a policy driven solely by ideology and damaging to both social cohesion and the welfare of residents. This one policy makes the document worthless and risible as an attempt to set guidelines to regenerate White City. It is a thinly disguised political fix which distorts any legitimate purpose of the Framework. It is a pity that H&F, unlike Westminster, does not quantify the sum it donates to developers by failing to achieve its own planning policies. Here, this must run into hundreds of millions. The paucity of ambition and surrender of public benefit to sectional interests is disgraceful and it is surprising that professional officers want their names associated with it.
3. Viability. Councillor Dame Sally Powell, who represents White City, and I questioned offers about the quantum of affordable housing in the document, we were told by officers that: ‘It is important to emphasise that the target for affordable housing in the Opportunity Area
remains at 40% in line with the objectives set for White City in the Core Strategy. The DIFS outcome raised a concern that due to the high site abnormal costs and the need to contribute to considerable highway and social infrastructure costs when financial viabilities are provided by developers these will most likely propose a level of affordability below this target.’
With respect, this is gibberish. At best it is throwing in the towel before negotiations have started on any individual site. However, the towel was thrown in long ago: there is zero affordable housing in the Imperial West and Shepherds Bush Market consents and 10% on the Westfield 2 site. The Framework notes (7.13) that ‘the DIFS viability assessment was carried out on the basis of general assumptions and not actual detailed schemes’. It, and the Framework, are a giant Christmas present handed to the country’s wealthiest developers, paid for by local residents and taxpayers.
Review. At 7.18 the Framework states: ‘In negotiating recent s106 Agreements in the area, the Council has sought to include review clauses, particularly with a view to increasing affordable housing in the future, if possible.’ Where this has happened, as with Westfield, the review clause is pathetically unambitious, envisaging a possible increase from 10% to 16% in affordable housing should the property value of one of the country’s prime retail sites increase over the coming years. But we are lucky to know even this as very little of the viability assessments or review mechanisms are publicly available. In any event, where it suits the Council it dispenses with review altogether, as with the West Kensington/Earl’s Court application, despite this being the largest single site in the borough with the longest gestation.
5. White City Estate. The document explicitly excludes the White City (and smaller) estates from its compass (2.18). Why? This is a once in a generation opportunity to help regenerate one of the economically poorest areas of London. The Council’s previous strategy was demolition, relocation and social engineering as with other parts of the borough. No doubt this is the long-term aim still, but not feeling able to express this view with elections pending, they remain silent on the future living conditions of the majority of current White City residents. 6. Infrastructure. Public transport, roads, GP and other health services, schools and leisure facilities are all given inadequate weight in the document. The quantum of development is huge in an area with current low level or discontinued uses. The only plausible explanation for this is that the Council does not expect many of the 5,000 flats to be constructed to be occupied, or, if they are, for their owners to use public services. 7. Density and tall buildings. There is no precedent or reason given for encouraging very tall buildings in this location. They have become a feature of the various applications for the area simply because the Council will approve them. In the case of the Dairy Crest site the application for a dense development including a very tall building appears to have been a way of increasing the site value. As soon as consent was granted the site was sold on to Imperial who do not intend to build out the scheme. 8. Strategy. There is none here. The previous White City Masterplan was built around the BBC and cultural industries. Sadly, the BBC is abandoning the area. But there is an opportunity via Imperial to make health, education and research its focus. There is nothing about this in the document just the promotion of faceless over-developed redundant tower blocks. The loss of industrial and employment land is simply driven by what makes developers most money in the London housing price bubble 9. Open space. Because developers have been given their planning consents cheaply and chaotically there has been no provision so far for open space. Now there is White City Green, a sliver of land that has to be prised out of St James. It is wholly inadequate. Meanwhile, the major existing public open space, Hammersmith Park, is seeing a third of its area sold on a 35 year lease to a private company who will price local residents out of its use. 10. QPR. Loftus Road Stadium is a landmark in the area but there is nothing about QPR’s contribution to the local community, to the need to keep the club in the area or how the intensification of land use elsewhere will affect the area on match days. 11. Emergency services. There is nothing about the proposed closure of Hammersmith Hospital A&E, or the ability of St Mary’s to cope with the extra demand from 5000 homes. Nor about the closure of Shepherds Bush police
station to the public. What service will residents get when huge additional numbers of visitors and residents are added to the local population? 12. History. Although this is paid lip service to in the document there is no attempt to preserve the character of White City. Shepherds Bush Market is being sanitised and important parts of the area, such as 30-52 Goldhawk Road, being destroyed. Every part of White City has character: WCE, BBC TVC, QPR, Shepherds Bush Green and Market. The Council clearly either ignores or dislikes the history of White City. This document colludes with the destruction of the area. It adds nothing and takes away a lot. I suggest it is quietly buried.
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