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Dear Camden Council,

I am writing to respond to the two planning applications submitted for the Liddell Road
redevelopment: 2014/7649/P and 2014/7651/P. These comments relate to both planning
applications.
1. The Fortune Green & West Hampstead Neighbourhood Development Forum (NDF) has spent
much time discussing and debating the proposals for the redevelopment of the Liddell Road site as
the plans have come forward. We have had meetings with council officers, local councillors and
cabinet members; we have discussed the issue many times at our regular meetings (all of which are
open to the public); and have consulted and engaged the local community about their views. The
NDF has more than 400 members and represents the views of those living and working in Fortune
Green & West Hampstead.
2. The NDF has produced a Neighbourhood Plan for our Area, which was submitted to Camden
Council on 1 September 2014 and which passed its independent examination on 8 January 2015.
While not yet formally approved, the document is a very advanced emerging Plan and is a material
consideration for this planning application, as acknowledged by the references to it in the Planning,
Design and Access Statement (PD&AS) which accompanies this application. We would also like to
draw your attention to the examiner's comments about the Plan:
"The plan is a very commendable document that will help to guide growth and sustainable
development in this significant area of London. It is a credit to all those who have worked hard
to produce such a readable and well-presented plan in such a short period of time. The plans
real strength is in its articulation of the concerns and aspirations of the local community, by
reflecting the results and outcomes of a very extensive engagement process".
3. We remain somewhat confused as to why this planning application has been submitted in two
parts and how these two parts will be assessed. We have asked for clarification on this point, but
have not received a reply. We understand that each planning application will have to be assessed
and decided on separately.
4. We note that the Council has been served a Freedom of Information request for the Financial
Viability Report which accompanies this application - and that a heavily redacted version (with no
figures) was recently published. If and when the full report is published, the NDF reserves the right
to submit further comments about the planning applications, if any further issues arise as a result.
We also note that, in terms of financing the construction of the school, Camden Council has
received a central government grant of 6.7 million - which will pay for half the cost of the school.
In addition, Camden Council has made a political - not a planning - decision to make a 3 million
profit from this scheme, which it will spend elsewhere. We strongly believe this sum should be

reinvested in the scheme to reduce the height of the tower block and to provide more affordable
housing.
5. We appreciate that the scheme has a number of positive features. We recognise the need for a
new school in the area and support the provision of badly needed primary school places. We also
support other aspects of the scheme, as outlined below, including the provision of space for
business and employment; and some of the proposed housing. However, we consider that the
scheme as a whole is not policy compliant - for the reasons listed below - and we therefore
strongly object to these two planning applications, as submitted.
6. When assessing both applications, we note that the main aim of both schemes is to
accommodate the school. It is clear from the PD&AS that the requirements and wishes of the
school have given the fullest consideration. In contrast the views of local residents have largely
been dismissed and ignored. As a significant, mixed-use scheme in the heart of our community, we
strongly believe that all opinions should be listened to with equal weight. The outcome of the
course taken is a proposal that is clearly unbalanced and unsustainable - and which has resulted in
widespread opposition across the Neighbourhood Area.
7. In order to gather the views of local residents, the NDF carried out a survey to assess views about
the proposed development. This online survey was open for two months during November and
December, and was widely publicised in the area. In all there were 128 responses. The answers to
the Q&A section and open responses are attached to this email. We request that the content of
both documents is assessed as part of the NDF's response to the two planning applications. The
results of the survey are very clear. While they demonstrate that there is support for the provision
of a school, business space and housing - there is strong opposition to key aspects of the scheme. In
terms of the proposed 11 storey tower block, 13% are in favour and 87% against. In terms of the
proposal for just 4% affordable housing, 80% of respondents consider this to be too little. When
asked the question "Overall, do you support Camden Council's current proposals for the
redevelopment of the Liddell Road site" - the response was Yes 27%, No 73%.
8. In terms of the height of the 11 storey tower block, there has been a clear failure to respect local
character and the context of the site. The main reference point for the building appears to be the
Ballymore/West Hampstead Square development (currently under construction on West End Lane).
In planning terms, this comparison is seriously flawed - the Ballymore development is in the West
Hampstead Growth Area; the Liddell Road site is some distance from the Growth Area. A tower
block on the Liddell Road site fails to respect or consider the character, setting, context, and the
form and scale of neighbouring buildings.
9. The design of the tower block is also a cause for concern. We note from the PD&AS that the
design references for the tower block come from tall buildings in Rotterdam, Amsterdam and

Berlin. This clearly demonstrates that there has been a complete and demonstrable failure to
consider the local character and site context in terms of this proposed structure. In both it's height
and design, the tower block would cause considerable harm and damage to the local character of
the area - as well as possibly leading to ever higher buildings outside the Growth Area; and
undermining already agreed height limits. As set out in A4 of the Neighbourhood Plan, the
predominant character of the area is terraced housing of 2/3 storeys and mansion blocks up to 6
storeys. We therefore support the proposed housing in the blocks along Maygrove Road - but can
see no justification in any planning documents or policy for a tower block on this site.
10. We also note that planning officers recently rejected a proposal for a 7 storey building on the
neighbouring Iverson Tyres site (159-161 Iverson Road). The decision on planning application
2014/5342/P (dated 8 December 2014) states that the proposal is not acceptable on the grounds of
the height of the proposed building. The relevant paragraph from the officer's report, under
'reasons for refusal' states that:
"The proposed development, by virtue of its height, mass and scale would result in
an overdominant form of development causing harm to the streetscene and
negatively impacting on long views, contrary to policies CS14 (Promoting high quality places and
conserving heritage) of the London Borough of Camden Local Development Framework Core
Strategy and policy DP24 (Securing high quality design) of the London Borough of Camden Local
Development Framework Development Policies."
Clearly, if a 7 storey building is considered unacceptable on this site, it is not possible for an 11
storey building to be considered acceptable on a neighbouring site.

11. In light of the above three paragraphs, it is clear that the proposed 11 storey tower block is
in clear breach of NPPF paragraphs 58, 60, 61, 64 & 66; London Plan policies 7.1, 7.4, 7.6 & 7.7;
Camden Planning policies CS14 & DP24; and Neighbourhood Plan Policy 2.
12. The NDF is very concerned about the low level of affordable housing in the proposed
development. We note that the Council's original proposal was for 0% affordable housing on the
site, and that this has now been raised very slightly to around 4%. Camden Council's planning policy
for developments of this scale is for 50% affordable housing. We appreciate that the provision of
the school on the site reduces the amount of affordable housing that can be provided - however,
having taken independent planning advice, we believe the level of affordable housing for this
development should be in the region of 15-20%. The NPPF requires development to "create
sustainable, inclusive and mixed communities". This scheme - with 96% of the housing proposed for
luxury, expensive flats for private sale on the open market - clearly fails to achieve this. As
submitted, the scheme is in clear breach of NPPF paragraph 50; London Plan policies 3.8 & 3.9;
Camden planning policies CS6 & DP3; and Neighbourhood Plan Policy 1.

13. We understand from senior councillors that they would like to link the lack of affordable
housing at this site with an "ambition" to provide 50% affordable housing at 156 West End Lane,
when the Council sells this site. We note that the sale is at a very early stage - and one preferred
bidder has already pulled out of signing a deal, due to the constraints of the site. The Council has
provided no information about the kind of development envisaged for this site and so we are
unable to make an accurate assessment of this commitment. Further - in planning terms - it is not
possible to link two sites in such a way. So any consideration of this issue should be disregarded
when assessing these two planning applications.
14. We are concerned about the proposal to create a new/second entrance to the site opposite
Ariel Road. This would result in the loss of a significant part of Maygrove Open Space - which is
designated as a protected site, both in Camden Council's Proposals Map and the Neighbourhood
Plan (where it is designated as Local Green Space). The proposal to remove part of this Local Green
Space is in clear breach of NPPF paragraph 76 & Neighbourhood Plan Policy 15.
15. In early discussions with Council officers about the redevelopment, we stressed the need for the
development to allow for an expansion of Maygrove Peace Park. This is a small, popular, and well
used green space. Due the already approved new developments on Maygrove Road and Iverson
Road - as well as this proposal - there is likely to be a substantial increase in use of the park. The
proposed scheme's failure to allow for an expansion of Maygrove Peace Park is a significant
omission and - as well as the failure to provide any significant new green space in the development
- is a clear breach of Camden planning policy CS15 and Neighbourhood Plan Policy 16.
16. We note the proposals offer plans for a new 'open space' on the site. This appears to be mainly
hard landscaping. While the pictures in the planning document give the impression of planting and
greenery - on the basis of other recent developments in the Neighbourhood Area - we consider it
unlikely that this plans will be realised in the form portrayed. We all note that this area will be used
by vehicles making deliveries to the school, business space, and tower block - as well as providing a
turning space for bin lorries. Therefore the space dedicated solely to pedestrians is likely to be
minimal. The proposal for this open space is therefore in clear breach of Camden planning policy
CS15 and Neighbourhood Plan Policies 9 & 16.
17. As reflected in the results of our survey, there are significant concerns about the
proposed layout of the site - where, once again, the views of local residents have been ignored.
Given that the school has been given 'preferred status' in terms of its position on the site and the
amount of land it occupies - as well as being a very low rise building - it means the rest of the
development is squashed on a small proportion of the site. Such a high density of development on
the non-school part of the site is neither welcomed nor appropriate for this location. We would also
like to point out that that the residential part of the development appears to exceed the Mayor of
London's density matrix for the number of habitable rooms and dwellings per

hectare. Furthermore, all of the suggestions for an improved layout - including building a higher
school building (with the possibility of offices above the school); maintaining the existing entrance
to the site; moving the highest building to the east end of the site; moving the business space closer
to West Hampstead Town Centre and stations; moving the school playground to join on to
Maygrove Peace Park - have been rejected by Council officers, with very little explanation or
justification.
18. We welcome the fact that the PD&AS (Appendix 2) sets out a views assessment about the
proposed development. However, the basis of the assessment appears to be somewhat flawed and
takes a very dishonest and misleading approach. A summary of the findings would reasonably be
"hardly anyone will see the tower block". Such an approach is clearly designed to mislead and to
misrepresent. We note that there has been no assessment of the views from Mill Lane to the east
of the railway line - where many properties will have a clear view of the tower block. We also note a
clear discrepancy between the photographs at eight view points and the actual view points - View 6
is an obvious example of this. We take particular exception to View 8 which shows the view of the
proposed tower block from Maygrove Peace Park, where the tower will be most visible. The image
shown depicts a number of large trees in full leaf obscuring the tower - which represents a
fundamentally dishonest impression and is extremely patronising to the residents of the Sidings
Estate - as well as users of Maygrove Peace Park and Sidings Community Centre, who will be
completely overshadowed and dominated by the proposed structure.
19. We strongly support the provision of business space on the site. We welcome the fact that the
original proposals for the site - which allowed for a reduction in business floorspace - was, following
comments by the NDF, revised. However, we remain concerned about the significant loss of light
industrial space which will take place as part of this development - without replacement. We note
that such space is in very short supply in the London borough of Camden and that the Council
normally requires floorspace which is suitable for light industrial space to be replaced by floorspace
which is suitable for light industrial use. Many mixed-use developments have been brought forward
across the borough which have provided employment space suitable for light industrial space
alongside residential development. We note that one of the reports which forms part of the
planning application states that light industrial use is appropriate and viable for this site. We
therefore object to the failure to incorporate any light industrial space in the proposed new
development. Such an approach is in breach of Camden planning policy CS11 (also see 8.10-8.14)
and Neighbourhood Plan Policy 11.
20. In terms of the plans for a co-sited school on the site, we note that the admissions point for the
school is a key issue. The issue is of great concern to local residents - particularly those living near
the Liddell Road site, on the Sidings Estate and at Templar House. The NDF is making a separate
submission as part of the proposal for a new admissions point, which is available on request.

21. We feel the planning application, as submitted, fails to have sufficient regard for the traffic
impact of the proposed development. While we welcome the requirements to reduce traffic,
reduce pollution caused by vehicles, and for car-free developments - we don't think this has been
thought through for this site. The development will cause a large and significant rise in the level of
traffic in the area - not least through delivery, servicing and school traffic. In particular, with a cosited school, the likelihood of parents driving their children to school will increase. Maygrove Road
is a narrow road with parking on both sides - in effect, a single track route - and is not capable of
accommodating the traffic demands that will be placed upon it. It appears no proper consideration
has been given to this issue. We further note that the traffic consultants employed to assess this
issue have worked on other schemes locally - where their findings have been widely questioned;
and which appear to be somewhat detached from reality. We therefore suggest that the
conclusions of the travel and transport documents are disregarded in terms of assessing these two
planning applications. Overall, the approach taken to this issue in the planning application signifies
a clear disregard for the well-being and amenity of people living on Maygrove Road and
surrounding streets.
22. We note the response submitted by Transport for London (dated 23 January 2015) and echo
the numerous concerns it raises. We believe the scheme fails to make any contribution to the
cycling infrastructure of the area - in breach of national, London & Camden policies - as well as
Policy 8 in the Neighbourhood Plan. We would welcome proposals for new cycle paths in the area particularly on Maygrove and Iverson Roads. We also note TfL's proposals for a cycling Quietway
along Maygrove Road in 2016 - no consideration appears to have been given to this and the
submitted scheme could prevent this going ahead. We also have concerns that the co-sited school
will lead to an increase in vehicle traffic and are concerned that the School Travel Plan is based on
out of date data - and that it fails to take into account the significant new development that has
recently taken place. We are very worried that the submitted scheme has "a vague and inadequate
provision of disabled accessible spaces" and that "the applicant has not analysed the operational
needs and management of the vehicles that the office units will generate". Finally, we note that
there are no bus routes or bus stops in the immediate vicinity of the school/site - which could
prevent people using bus to access the site.
23. If the development goes ahead, we would like the local community to benefit by way of a S106
legal agreement. We note that it appears likely that his development will be decided on before the
Camden CIL comes into effect. We would strongly argue that this agreement includes provisions for
substantial sums for both Sidings Community Centre and Maygrove Peace Park, so that they can
cope with additional pressures caused by this large development. Funding should also be allocated
to improve the pedestrian and cycling infrastructure of Maygrove Road - including improved
pavements, new pedestrian crossings, and cycle lanes. Due to the extensive damage caused to the
surface of the road during the building of the recently consented schemes in the immediate area and due to the likely impact on the road of the construction of this scheme - a payment should be

made to allow for the resurfacing of the entire length of Maygrove Road following the completion
of building work on the Liddell Road site. Finally, funding should also be made available for local
voluntary groups and other schemes that would clearly benefit the immediate area.
24. Any S106 legal agreement should also mandate the formation of a Construction Working
Group, which should meet at least every two months for the duration of building work on the site.
Among those invited to the join the Group should be: the NDF, local residents associations, Sidings
Community Centre, Friends of Maygrove Peace Park, local councillors for Fortune Green & West
Hampstead wards, a representative from Kingsgate School, and a representative from Camden
Council.
25. We consider that the submitted scheme fails to take into account the clear wishes of the local
community - as set out in both Camden Council's Place Plan for West Hampstead and in the Fortune
Green & West Hampstead Neighbourhood Plan. The NDF welcomes developers who come forward
with proposals for sustainable development that has regard for the policies in our Neighbourhood
Plan - sadly, this proposal fails on both counts. There is also a substantial degree of frustration and
disappointment in the local community - which feels that decisions are being taken regarding the
future of this site which do not reflect the views and concerns of local stakeholders and local
residents, who have worked hard to have a constructive input as these proposals have been
brought forward.
26. Overall, it is clear to us that this scheme - as reflected in the two planning applications - is in
breach of a number of key policies in the NPPF, the London Plan, Camden Council's LDF, and in the
Neighbourhood Plan. The two proposals must therefore both be refused as together neither are
planning policy compliant. The NDF remains committed to working with Camden Council and local
residents to bring forward a scheme that is compliant with adopted and emerging planning policy and which reflects the wishes of our community.
We would like to be informed when:

this response is registered and posted on the Camden Council website


the officer's report for both planning applications is published
both proposals are listed for decision at DC committee
how the NDF can register to speak at the relevant DC committee meeting(s)

Yours sincerely,
James Earl
(Chair, Fortune Green & West Hampstead Neighbourhood Development Forum)
www.ndpwesthampstead.org.uk