WHO THE CAMDEN GOODS YARD WORKING GROUP ARE.

The CGYWG has now been joined by the Primrose Hill CAAC and the Camden branch of the London Cycling Campaign, and thus comprises every key third party stakeholder including representatives of:

• The most significant local community group: Castlehaven Community Association.

• All the impacted tenant and resident associations: Gilbeys Yard Tenants’ Association, Juniper Crescent Tenants’ Association, 30 Oval Road Estate Residents’ Association, Harmood Clarence Hartland Residents Association.

• All relevant local heritage groups: Primrose Hill CAAC, Regents Canal CAAC, Camden Railway Heritage Trust, Greater London Industrial Archaeology Society, The Regents Network.

• North Camden Neighbourhood Forum (in embryo),

• Camden branch of the London Cycling Campaign.

• All the surrounding landowners: Market Tech, One Housing Group, The Roundhouse.

• Local businesses and business groups: Camden Town Unlimited, Viacom International Media Networks.

Camden Town Unlimited and One Housing Group have participated in the group’s debate and collective decision-making that has resulted in the group’s list of concerns. They do not, however, wish to actively object to approval of the application, because of their own commercial interests in the Camden Goods Yard.

The CGYWG strongly supports the principle of development of the Camden Goods Yard in a manner which maximises the amount of accommodation whilst achieving the high quality and connectivity objectives enshrined in the adopted CGY Planning Framework.

The support of all the tenant groups to this principle of development is unprecedented and illustrates the mature approach of the CGYWG: these members are willing to sacrifice their current homes and show a maturity in embracing a vision for a better future that benefits the whole neighbourhood.

The CGYWG has reached its collective view on the planning issues after informed debate on the planning issues, developed in around 20 meetings and by reference to an approach sustainable before a planning inspector at appeal.

THE CAMDEN GOODS YARD: A ONCE IN A GENERATION OPPORTUNITY.

The adopted Camden Goods Yard Planning Framework SPD (the Framework) is an excellent guide to the vision and key objectives for the CGY. It rightly considers that “a crucial element of the framework is to consider the opportunities and challenges in a holistic way”, so that the design of the development of each part is first and foremost considered in the context of achieving the holistic planning objectives for the whole of the CGY.

As the Framework emphasises, the current disconnected and segregated nature of the design of each part of the CGY should fit within an overall vision / master plan of level links connecting the CGY from one end to the other, and from the CGY out to the surrounding streets, and it is against this fundamental requirement that the Application is assessed.

As the Camden Goods Yard Planning Framework Forward remarks, “this is a once in a generation opportunity” to re-connect this huge segment of Camden amounting to almost nine hectares into the surrounding neighbourhoods, open spaces and pedestrian / cycle / public transport links; to create a new neighbourhood that is a joy to live and work in; and to provide the high quality public places and linear park that the Planning Framework SPD requires.

This critique of the Barratt scheme on the Morrison’s site is made against the objectives set out in adopted Framework SPD, whose relevant requirements are relied upon. It is a “material consideration” in the decision making of the Application, and -because it is the Council’s formally adopted interpretation of all other adopted local and national policy and guidance requirements as those apply to the conditions on this site – any decision-maker must put significant weight to its objectives. For ease of identification, the Local Plan and Framework requirements are shown highlighted in bold italics.

KEY CONCERNS ON THE PLANNING ISSUES TO THE CURRENT MORRISONS SCHEME.

The Framework’s vision and detailed guidance for the development of the whole Camden Goods Yard requires adherence of each part to a coherent master plan vision for the whole of the Framework Area for its success.

This scheme repeatedly fails the Framework’s objectives:

1. It fails to provide public spaces of sufficient quality. In this regard key parts of the public spaces are sunless, and will be dominated by the height of the buildings surrounding them.

2. This scheme fails to provide any new or improved access to the Morrison site, so that the connection of the site to the Town Centre is totally inadequate.

3. This scheme fails to provide a clear transition of uses, and has an inappropriate mix of uses. In this regard:

a) There is no commercially-focussed mixed-use transition zone, separating the market edge from the residentially-focussed mixed-use accommodation elsewhere on the Camden Goods Yard, and

b) There is not enough: diversity in its retail and commercial offer; workspace including affordable workspace, provision of units suitable for small and independent occupiers, and there is a lack of retail units catering for local people.

4. This scheme fails to provide coherent high-quality routes across the Camden Goods Yard. In this regard:

a) The so-called spine route through the centre of the site is narrow, convoluted, oppressively-proportioned and sunless, and

b) The routes that are created are not direct, accessible, attractive and safe places for cyclists and pedestrians.

5. This scheme does not provide the required attractive green landscaped leisure route. In this regard, it totally fails to fulfil the Framework objectives of a park, which - when completed by the development of the One Housing land parcels - will:

a) Have a level access route along the south-western railway edge,

b) Join both ends of the Camden Goods Yard from Regents Canal to Bridge Approach,

c) Adequately facilitate suitable access arrangements for the regeneration and redevelopment of the Winding Vaults,

d) Create a wildlife corridor between the designated Sites of Nature Conservation Interest, that is Regents Canal and Adelaide Road Nature Reserve, and

e) Fulfil the only significant community provision, called for by the community,

6. This scheme fails to have an adequate transport and highways strategy. In this regard:

a) It does not eliminate and /or minimise vehicular use in the predominantly residential areas,

b) Even on its own inadequate capacity assumptions, it does not provide safe and comfortable arrangements for entering and leaving the site for pedestrians, cyclists, and vehicles.

c) It does not achieve the optimal regeneration possible beyond the boundaries of this site, and thereby prejudices the development of other parts of the Camden Goods Yard, and

d) It does not protect residential amenity.

7. This scheme fails to produce new housing of adequate quality. In this regard, in relation to the BRE and Camden standards:

a) 15% of the dwellings would not receive adequate sunlight,

b) 26% of the rooms have insufficient sky visibility,

c) 12% of habitable rooms have insufficient daylight, and

d) Most habitable rooms windows fail the 18m.privacy distance guidance.

8. This scheme fails to justify the harm created to heritage assets. In this regard:

a) The acknowledged harm to the Primrose Hill Conservation Area is not outweighed by the public benefits of the development, and

b) Major harm is created to the Horse Hospital, whose Grade 11* heritage significance is further enhanced by its group value setting. There are no public benefits to outweigh this harm.

1. FAILURE TO PROVIDE ADEQUATE PUBLIC REALM QUALITY.

1.1 All the public realm at the heart of this scheme with the likely greatest density of population – i.e. Roundhouse Way, Makers Way, Goods Yard and Camden Yard – are made sunless and will feel dominated by the height of the buildings surrounding them.

1.2 They have a very high height to width ratio, thus giving a sense of being overwhelmed by the size of buildings surrounding the space. A prime example is the sense of being in a canyon within the so-called “primary spine” route of Roundhouse Way that has an average width of 15m and is 32.6m high.

1.3 All these spaces would fail the BRE test that requires 50% of outdoor areas to have 2 hours of sunshine at the equinox. The developer seeks to justify this failure by noting that the average of all the spaces in between the buildings would exceed the 50%: however, this calculation includes all the roads in the development where sunlight is not an issue. The proper interpretation of the BRE standard is to for each of the discrete public places to be assessed individually.

2. THE APPLICATION’S FAILURE TO CREATE ANY “NEW OR IMPROVED ACCESS” TO THE MORRISON SITE.

2.1 The Framework emphasises the fundamental importance of “creating new and improved access to the CGY”, and notes that “the market edge represents a strategically important opportunity to connect the framework area with the Town Centre”. The Application creates no new or improved access, and totally fails to adequately connect the Morrisons site with the Town Centre.

2.2 The Framework particularly requires the provision of “a public pedestrian route between the new neighbourhood in the framework area and the Town Centre via Camden Lock Place” that “seeks to protect the amenity of residents”. The Application fails to provide this.

2.3 Given the 5,000 population that will be working and living in the CGY when it is all developed, and the severe congestion that will ensue at the only current entry / exit points to the CGY (under the rail bridge and through the Gilbey’s Yard passageway), it is fundamental to the success of the Development that the levels are configured to facilitate natural and level routes under the viaduct that currently acts as a barrier between the area and its surroundings.

2.4 The biggest challenge to fulfilling this opportunity of re-integrating this segregated part of Camden back into the fabric of the Town Centre is the problem of how one deals with the approximately 5 m level change from Chalk Farm Road to the upper level that is broadly like that at Oval Road. how and where the level change takes place is fundamental to making these level connections to the outside world across the railway viaduct at the NE of the site, whilst protecting residential amenity from anti-social behaviour from some market and night time economy visitors.

2.5 The obvious way of dealing with this is to create a street at the low level from the Roundhouse down to the Horse Tunnel from which Camden Lock Place is closely reached. There would be no heritage issues associated with crossing the Horse Tunnel and Market Tech – whose land would be passed through – have confirmed that would welcome the opportunity to provide this route at low level through the Horse Tunnel to give access down Camden Lock Place. The practicability of this solution is demonstrated in the diagram at Appendix A.

2.6 Unfortunately, this scheme fails to rise to the challenge of dealing with the 5m level change. They have retained the upper level through to the yard north of the Interchange in the hope that agreement might be made with Market Tech to allow access down the current staircase that leads to the end of Chalk Farm Place. However, the gate at the top of this staircase has now been closed, following significant disturbance to the amenity of the Gilbey’s Yard residents, and Market- Tech – who are mindful of their social responsibilities and who fully support the provision of a low-level route – will not allow the access to be re-opened.

3. FAILURE TO PROVIDE A CLEAR TRANSITION AND AN APPROPRIATE MIX OF USES.

3.1 Failure to provide the Clear Transition of Uses.

3.1.1 The Framework requires that any development should provide “a clear transition of uses between the core of the town centre and the new neighbourhood” that are “compatible with the nearby residential”. This is reinforced by the Land Use diagram in the Framework, that requires a “commercial focus” to the mix of uses on the North- Eastern third of the Morrisons site, as opposed to the more residential focus elsewhere.

3.1.2 The strategic land use of this development fails to provide this commercial focus, and instead blends the commercial and residential across the whole development. Overall, the scheme has around 62% residential to 38% non-residential floorspace: there is scope to increase the commercial use as Camden exceeded its residential housing target in 2015-16 by around 50% whereas its Employment Land Study 2014 forecast that Camden the most critical issue need was for premises in central London / Camden Town Centre to nurture small dynamic businesses.

3.1.3 If the levels of the scheme were to be reconfigured to allow access to the CGY from Camden Lock Place at low level, then visitors would pass through a lower level commercially/actively - fronted “buffer zone” before reaching the central plaza in front of the supermarket where the steps would link with a predominantly residential upper part away from the market edge, which would fulfil the Framework requirement for a clear transition of uses.

3.2 Failure to provide an appropriate mix of uses.

3.2.1 Local Plan Policy TC5 promotes the provision of smaller units and encourages the occupation of shops by independent businesses and the provision of affordable premises. The Framework also requires that “development should diversify the local retail and commercial offer. Goods and services aimed at local residents and workers and the provision of units suitable for small and independent occupiers will be encouraged”.

3.2.2 In this scheme, the non-Morrison foodstore A1-4 uses area comprise only 3.5% of the whole, which proportion should at least double to mitigate the domination of retail use by Morrison which would prevent the diversity and variety of commercial offer required by the Framework. The non-Morrison A1-A4 use should be restricted by S106 for use only by small scale independents providing goods aimed at the local residential and office markets and should be of affordable rents to allow such small-scale independents to compete with the overwhelming buying power of Morrisons.

3.2.3 Similarly, of the 14,325 sq m of office and workspace, only 1,344 sq m is either workspace affordable office, i.e. 10%. This should be doubled to at least 20% of the whole.

3.2.4 By having the south-western half of the site as being a predominantly residential mixed-use area (with some ancillary small scale local retail or local café use at ground floor level) the new and existing adjacent residential areas have their amenity protected from disturbance from the transient daily influx of office workers, and the commercial focus mixed use area then serves as a buffer zone between the residential and the adjacent market and night time economy areas.

4. THE APPLICATION’S FAILURE TO PROVIDE “DIRECT, ACCESSIBLE, ATTRACTIVE AND SAFE ROUTES” ACROSS THE CAMDEN GOODS YARD.

4.1 The Framework’s “Movement and Connections” diagram calls for a new “spine route” through the centre of the site, joining the Morrisons and One Housing sites. It makes clear the strategic priority for this to be given to pedestrians and cyclists: “new and improved access for pedestrians and cyclists as a strategic priority” and “walking and cycle routes must create direct, accessible, attractive and safe routes”.

4.2 The Application fails to fulfil these requirements. It does not create a “direct, accessible, attractive and safe” link as the primary spine across the CGY from Oval Road to the Roundhouse to knit the segregated elements of the CGY together. To fulfil the requirement that it be “direct and accessible”, and to prioritise its ease of use by pedestrians and cyclists, the route from Oval Road to a new ramp on the Network Rail land at Bridge Approach should be level throughout as far as practicable.

4.3 The route that the Application has designated as its primary link from Oval Road to the Juniper Crescent land (through Roundhouse Way) has several failings:

• It is narrow, convoluted, oppressively proportioned (height being more than double the width on Roundhouse Way), and sunless (fails BRE standards).

• It lacks coherence.

• It fails to properly open up a vista to the Roundhouse, as called for by the Framework, but instead allows only a glimpse of the listed icon from one edge of the street at the end of a canyon.

• For pedestrians and cyclists to travel from one end of the site to the other, they need to twist around corners, drop down a 2m staircase, cross Stephenson Way, and climb back up again.

4.4 The road on the Application site adjacent to the SW railway edge – which is the only level and direct route across the site to Juniper Crescent - is no substitute for a properly designed pedestrian / cycleway spine, being a relatively hostile environment compare with a landscaped pedestrian / cycle path, and its primary use for vehicles is contrary to the Local Plan policy T1 that prioritises pedestrian / cycle use of routes over that for vehicles. This road takes commercial delivery / service vehicles and all the supermarket and disabled people’s cars, and pedestrians and cyclists would have to traverse what the Framework described as the dominating service road roundabout to get to Juniper Crescent.

4.5 Local Plan Policy T1 confirms that developments should “provide for and makes contributions towards connected, high quality, convenient and safe cycle routes, in line or exceeding London Cycle Design Standards, including the implementation of the Central London Grid, Quietways Network, Cycle Super Highways”.

4.6 The London cycling network map in the Transport Assessment at Figure 3 shows how the Camden Goods Yard is a block to a continuous cycle route from the centre of London through Regents Park to the north (Kentish Town / Maitland Park). A level spinal route from Oval Road to the Roundhouse, connecting eventually to Bridge Approach and via this new central landscaped car free public realm to the Chalk Farm road / Ferdinand Street junction, would radically improve the connectivity. The current proposal does nothing to remedy this lacuna.

4.7 It is notable that the Camden Design Review panel shared the concerns that we raise here in relation to the way that public spaces are designed and used across the site. The officer’s report at page 130 notes that their recommendations were as follows:

“The panel recommends a strategic review of the way that public spaces are designed and used across the site. Further detailed scrutiny is required of the overall landscape and movement across the site. The street pattern for the site is crucial to its success, and should connect it as far as possible with surrounding areas. The importance was emphasised of the main route through the site, from Oval Road to the east of Block B. This needs to be treated as a main street, with pinch points removed, public space increased, and uses designed to activate street frontage. It should be distinguished from routes through the residential parts of the development, to avoid night- time crowds being drawn into housing areas. A number of points were also made about the liveability of the development, stressing the need for sufficient green space, amenities and play space for the families living there, and whether the more isolated, western routes will feel safe late at night.”

5. THE APPLICATION’S FAILURE TO PROVIDE THE LINEAR PARK.

5.1 The Framework calls for “green corridor walking / nature routes along the railway edges, which could connect with wider green networks such as the existing Jubilee Walk along the canal and the Camden Highline proposal” However, it makes clear its “preference will be for a level access route in this (the SW railway edge) location for the “green pedestrian and cycle route connecting from the existing opening on the canal towpath through to the Primrose Hill footbridge”.

5.2 Further objectives set out in the Framework reinforce the need to produce this linear park along the SW railway edge, joining both ends of the site together and to the wider green networks:

• It is only by situating the required “attractive green landscaped leisure route” in this location, that there could be created the “open public space” proposed in the Framework that “facilitated the refurbishment and re-use of the (Grade 2*) Winding Vaults with suitable access arrangements”. The Application fails to provide this.

• This location for the linear park is the only position that would enable it in practice to be part of a continuously connected “green corridor walking / nature route” to the wider “green networks”. The Application provides no green landscaped pedestrian / cycle route at the SW railway edge and only situates a small park (that narrows to almost no width at its dead-end northern end) along the NE edge of the Morrison site. It is impossible for any park in this situation to connect to the wider green networks by way of any green corridor walking / nature routes which were direct, accessible, attractive and safe: any route would have to traverse adjacent streets that were congested, noisy, (at times) inhospitable, and commercially fronted.

• This location for the linear park is the only position that would enable it to “create a significant wildlife corridor extending a partial corridor between the canal and Adelaide road Nature Reserve, both being Sites of Nature Conservation Interest (SINCS)”, as called for by the Framework. The Application fails to provide any wildlife corridor.

5.3 The Framework requires the “Development to provide community provision and infrastructure in line with community requirements” which “should contribute to health and well-being of communities” and importantly which “should be developed in consultation with the local community”. The local community has been trying from the outset to explain to Barratt that the particular provision that they are most keen to see is this high quality landscaped, generously wide, green lung from the canal up to Bridge Approach. Although the community welcomes any other community provision as well (e.g. urban farm, community hall) it has not asked for that and by contrast has had its plea for this linear park of this nature and in this position ignored.

5.4 This park in the Application is situated in what is simply left-over space unfit for any other purpose, with a cul-de-sac at its northern end. It has insufficient scale, width or connectivity to enable it to be the attractive, safe, connecting route that the Framework calls for. The CGYWG welcomes any further green landscaped leisure space, but this park fails in many respects to fulfil the many very clear Framework objectives that the CGYWG would like to see as a priority.

6. THE FAILURES OF THE APPLICATION’S TRANSPORT AND HIGHWAYS STRATEGY.

6.1 The Application’s Transport and Highways Strategy fails in four main respects:

• It fails to eliminate where possible, and otherwise minimise, vehicular use of the public realm in the predominantly residential areas on the Morrison site.

• It fails to provide either safe and comfortable arrangements for entering and leaving the Site for pedestrians, cyclists, cars and other vehicles (even on its inadequate capacity assumptions).

• It fails to achieve the optimal regeneration beyond individual boundaries.

• It fails to protect residential amenity.

6.2 Failure to prioritise the needs of pedestrians and cyclists and to minimise vehicular use of the public realm

6.2.1 Local Plan Policy T1 confirms that: “development should prioritise the needs of pedestrians and cyclists and ensure that sustainable transport will be the primary means of travel to and from the site." The Framework notes that “the existing service road roundabout adds to the vehicle dominance” and requires that: “Development should future-proof for (its) removal in the longer term.” This Application fails to maximise the potential of fulfilling the first policy objective, and totally fails to fulfil the second. To do so, the creation and use of vehicular roads should be minimised to benefit the pedestrian and cycle public realm, which the proposal fails to do.

6.2.2 Unnecessary use by cars and buses. The proposal unnecessarily brings cars and buses up to the upper level, where the road use should be strictly limited to deliveries, refuse, and emergency vehicles. All the car parking in the development has to be reached from the upper level from where the food store cars then descend down again, when it could all be accessed from the lower level which is where the bottom food store parking is situated. Similarly, all the buses have to rise up Stephenson Way, pass around the roundabout at the top, and pass down again, when all the buses could be accommodated on the petrol filling station site instead.

6.2.3 Unnecessary Dominance of Stephenson ‘s Way and the roundabout. Bringing buses up this road and providing bus stands along its length necessitates the retention of its large width and of its roundabout after 2031 (when it is no longer safeguarded for HS2 use), which reinforces the vehicle dominance of this part of the environment that the Framework seeks to reduce. Providing for the potential of relocating and reducing in size of the roundabout - as called for by the Framework - would then allow the linear park to extend the full length of the CGY without interruption. Dramatically reducing the traffic flow up Stephenson Way and raising the level where the pedestrian / cycle central spine crosses it would also improve the “direct, accessible, attractive and safe” connectivity across the CGY as envisaged by the Framework.

6.2.4 Unnecessary Roads required by Position of Concierge and Delivery office, and Consequential Impact on Residential Amenity. The position of the concierge’s office - to where deliveries are made - is at the southern end of the site adjacent to the pedestrian entrance to Gilbey’s Yard. This position necessitates the provision of a dedicated road across the upper residential area, and promotes delivery vehicles that come up Oval Road to park in Gilbey Yard, thus harming residential amenity in either case. Inevitably, taxis will also use this road for drop-off and pickups. If this concierge’s office and taxi / delivery drop off were contained in a limited area near the top of Stephenson’s Way, then that would allow the whole of the rest of the upper area to be vehicle free during the day. Rubbish and emergency vehicles could then use the pedestrian / cycle spine central route, the former being restricted to early morning use only.

6.2.5 Unnecessarily Over-Sized Supermarket Car Park. The application is for a 300-space car park for the foodstore. This capacity exceeds its daily requirements, contrary to policy to reduce reliance upon car use. The Application Transport Assessment confirms that the maximum existing use of the current car park is for 287 cars at the weekend, 13% of which are not using the foodstore, thus producing a peak current requirement of 250 cars. The Applicant’s reason for maintaining this extra capacity that this would allow for the pre-Christmas rush is simply not sustainable. The Applicant should propose a far more robust Green Travel Plan that provided for bus access and local deliveries to mitigate the need for cars.

6.3 Failure to produce safe and comfortable arrangements for pedestrians, cyclists, cars and other vehicles entering and leaving the CGY

6.3.1 Local Plan Policy T1 confirms that developments should:

• “provide for and makes contributions towards connected, high quality, convenient and safe cycle routes, in line or exceeding London Cycle Design Standards,” and

• “provide high quality footpaths and pavements that are wide enough for the number of people expected to use them.”

6.3.2 Unnecessary Removal of Northern Exit from behind the Petrol Filling Station. The road junction to the NW of the petrol station site (PFS) has been removed for all vehicles save for petrol tankers or articulated vehicles, which burdens the remaining junction and prevents the use of the PFS site as a through route for buses, whose stands could be ideally situated against the viaduct wall away from residential areas. The reconfigured remaining junction with Chalk Farm Road, that now must take all incoming and leaving traffic, has unacceptable vehicular congestion and cycle safety issues.

6.3.3 Vehicular Capacity and Unacceptable “Severe” Impact at the Chalk Farm Road junction.

The Transport Future Year Assessment of required capacity excludes the redevelopment of the whole of the Camden Goods Yard. By not taking account of the capacity of a redeveloped Juniper Crescent, the Morrison development that controls the only road access into the whole of the Camden Goods Yard, prejudices the development of Juniper Crescent. The development of the rest of the CGY after the Morrison site could broadly double the living / working population of the CGY from 2,500 people to 5,000 people.

The development of the Juniper Crescent site is unlikely to produce any reduction on car use, notwithstanding Local Plan policy T1, calling for car-free development, as this policy also provides that in redevelopment schemes, the Council “will consider retaining or re-providing existing parking provision where it can be demonstrated that the existing occupiers are to return to the address when the development is completed.” As the Framework requires that all existing tenants on the One Housing sites are to be offered the opportunity to return to their homes under the same terms as they enjoyed previously, they would retain the right to keep a car.

There would therefore be no reduction of car use and a doubling of the capacity required for noncar modes of travel in and out of the site which is not accounted for in the Development’s assessment of the road junction and cycle lanes and pedestrian paths.

Even on its own inadequate capacity assumptions, the Development Transport Assessment shows that Chalk Farm Road (east) and Stephenson Way (here called Juniper Crescent) to be completely saturated, with an increase in queuing of 37.4 seconds down Chalk Farm Road, and that the junction overall would be operating with an overall “negative” capacity of -7.6%. Furthermore, articulated vehicles must cross into opposing traffic lanes and the two lanes to the exit can only takes the length of a bus and a car.

In addition to the retained car use, the additional population from a redeveloped Juniper Crescent would proportionately increase the need for all other vehicles at this road junction that is already operating over its optimum capacity, and thereby increase the impact to “severe” which is the level of stress that would make the junction unacceptable in planning terms.

6.3.4 Cycle Pedestrian Safety and Comfort at the Chalk Farm Road junction and under the Railway Bridge

Cycles safety leaving and accessing the CGY is severely compromised. There in insufficient width for a dedicated cycle lane under the railway bridge and up to Chalk Farm Road. There is only a cycle box after the entrance / exit to the petrol filling station and set back from the junction with Chalk Farm Road. The cycles must jostle for the same space to move with the buses going under the bridge and turning left on to Chalk Farm Road. There is no cycle lane at all for incoming cycles.

Pedestrians leaving and accessing the site would be congested. Of the 5,000 people that will be living and working at the Camden Goods Yard when it is all developed, perhaps three quarters i.e. 3,750, will be leaving or arriving at the morning peak hour. Even if one ignored the population from the redevelopment of the rest of the CGY, after the Morrisons development most pedestrians - i.e. around 1,200 people - will be seeking to pass under the current Chalk Farm Road rail bridge in that hour down a pavement 3.0m wide.

6.4 Failure of the Transport Strategy to provide for the optimum regeneration beyond its boundaries.

The Framework requires that: “landowners are expected to work together to achieve the optimal regeneration beyond individual boundaries,” and that “(Vehicular) servicing arrangements should be designed to promote good levels of residential amenity” The Morrisons site contains the only possible low level vehicular access route into the Camden

Goods Yard. It is likely that the current number of cars will be re-provided upon the development of the One Housing adjacent sites. The Morrisons scheme has car parking and a service vehicle yard at low level, which could easily extend to the Gilbey’s Yard boundary, thus providing for low level access therein.

If the Morrisons site was developed in accordance with a coordinated vehicular strategy that made best use of the levels across the combination of sites, then the retained car parking on the One Housing sites could be be underground and reached from low level thus allowing the upper level to be car free.

An additional benefit of this lower level connection is that it facilitates the future serving of the commercial buildings to the east of Gilbey’s Yard (Gilgamesh / Interchange / Henson). Currently these commercial buildings are serviced by large commercial vehicles, some of which operating late at night (Gilgamesh), which detrimentally impacts on the residential amenity at Gilbey’s Yard.

6.5 Failure of taxi and bus strategy to protect neighbouring residential amenity

6.5.1 Taxi drop-off /pick-up in Gilbeys Yard. The Framework requires that “facilities for taxis must be in an accessible location that avoids adverse amenity impacts on local residents”, and “Facilities for taxis should be considered within the framework area. If required, this must be located in an accessible location which avoids adverse impact on the amenity of residents.”

There is a longstanding problem of taxis arriving from the centre of town stopping at the end of Oval Road throughout the day and night to reach the market and night time economy venues on Chalk Farm Road through Gilbey’s Yard, as it is the route down Jamestown road is highly congested and the taxis then gets stuck in the one-way system. This has caused an influx of revelling visitors throughout the night with cars revving and slamming of doors etc. The situation will be greatly exacerbated by taxis seeking to reach this new development.

The scheme does not show the position of taxi-drop-offs. The development needs to provide for taxi drop-off in positions that are away from residential windows at both levels of the development. That at the upper level should be near the top of Stephenson’s Way, by the position of a relocated concierge’ office, which would avoid taxis traversing the predominantly residential upper level areas.

The development should also be required to provide S106 contributions to pay for a plan for preventing the use of Gilbey’s Yard for taxi-drop offs.

6.5.2 Bus stands adjacent to residential windows The Framework requires that “the location and nature of bus facilities should be designed to avoid the adverse impacts on residential amenity”.

The Development fails to protect residential amenity in its positioning of the bus stands and stops. There is a long-standing noise, pollution and child safety issue caused by bus stops and stands on the Stephenson Way adjacent to the existing Juniper Crescent dwellings, where the buses stand with their engines idling. This development exacerbating the problems by increasing the bus stands and stops in this location from 2 to 6. If the scheme did not remove the northern exit from the petrol filling station site, then the bus stands and stops could be relocated here and an expanded layby/bus stop on Haverstock Hill adjacent to Chalk Farm tube, which locations already used for this purpose.

7. FAILURE TO PRODUCE NEW HOUSING OF ADEQUATE QUALITY.

7.1 This scheme fails to produce adequate internal residential amenity quality in respect of its lack of dual frontage units, sunlight, daylight and privacy.

7.2 Dual frontage. GLA policy prescribes that north facing single aspect dwellings (which includes dwellings that face NE, NW or in between) should be avoided, for the principal reasons of securing adequate sunlight and ventilation, together with other benefits of dual aspect and outlook. Apart from the dwellings on the corners, all the dwellings on the NW & NE outward facing frontages of Block B and block F fail this guidance. This is an unacceptably high proportion notwithstanding the urban environment situation.

7.3 Sunlight. The Applicant has confirmed that 15% of the dwellings would not receive adequate sunlight to the BRE standard, and that 26% of the rooms fail the BRE test for sky visibility, which would explain the sunlight penetration failure. This is an unacceptably high proportion notwithstanding the urban environment situation.

7.4 Daylight. The Applicant has confirmed that 12% (182 out of 1554) habitable rooms fail the BRE standard for daylight, and of these 117 are living rooms or kitchens. This is an unacceptably high proportion notwithstanding the urban environment situation.

7.5 Privacy. Most of the habitable room windows within the development are well within the GLA and Camden SPD guideline requiring an 18m distance within which those rooms cannot be overlooked. Some of these windows which are as close as 12m apart, and the privacy distance is then reduced further to 10.5m by protruding balconies on the other side.

7.6 The justifications by the applicant that the narrowness of Roundhouse Way is appropriate to promote a desirable intensity and that that the 18m guidance does not apply to windows on building fronts are not reasonable ones. The obvious solution, which would simultaneously deal with multiple failures, is to widen Roundhouse Way. It would enable privacy guidance to be respected, produce a much more direct and visually permeable primary spine route, allow the public realm to comply with sunlight criteria, provide a proper vista of the Roundhouse and produce a much more comfortable height to width ratio in the space.

7.7 The development also creates a minor impact on the existing neighbouring residential amity in relation to sunlight / daylight to habitable room windows to Juniper Crescent. 7 out of 132 (5%) of the windows facing the development fail to meet the BRE criteria of having a minimum 27% VSC and no less than 80% of its former value.

8. CREATION OF UNJUSTIFIABLE HARM TO HERITAGE ASSETS.

8.1 The height, bulk and siting of some of the buildings fail to preserve or enhance the setting of the Primrose Hill Conservation Area, the Regents Canal Conservation Area, the nearby Grade 11 Interchange building, and the Grade 11* Roundhouse and the Horse Hospital. Of particular concern is the impact on the Regents Canal Conservation Area, and the Grade 11* Horse Hospital.

8.2 Primrose Hill Conservation Area.

8.2.1 The harm caused to the Primrose Hill Conservation Area is most clearly evidenced by the view of new buildings down Edis Street, which are the top 4 floors of A1, 5 floors of A2 and 2 floors of F.

The important significance of the character in local area is the uniformity of the sky horizon above a simple regular rhythm of articulation in the fenestration, which is disturbed by this muddle of buildings dominating the skyline.

8.2.2 The Applicant accepts that harm is created here and argues that this is outweighed by the economic social and environmental benefits of the development. However, in weighing whether this harm is justifiable, it is not in relation to the public benefits of the scheme as a whole, but only of the additional bulk that causes this harm: this additional bulk accommodates approximately 25 flats.

8.2.3 The CGYWG is not arguing that all these flats should be lost, merely that what becomes visible should have a simpler form with less damaging impact and so complement the existing uniform character. There are no social and environmental benefits of these additional flats and the economic benefit of increasing the number of flats by less than 5% of the whole cannot reasonably be assessed to outweigh the harm.

8.3 Horse Hospital with ramps and north boundary wall, and the Regents Canal Conservation Area at the Stables Market.

8.3. The scale and massing of the PFS building dominates the Grade 11* Horse Hospital and its surrounding group of buildings within the “Camden Wall” in this very important part of the Regents Canal Conservation Area. The Applicant acknowledges the importance of this building and the enhancement of its significance through its group value, in its partaking of a shared material palette, scale and character, shared history as integral parts of the original Camden Goods Yard, and shared group value of buildings in the Stables Market.

8.3.1 The scale and massing of the PFS building dominates the Horse Hospital and its surrounding group of buildings within the Camden Wall: its’ glazed structure is 35m deep and 35m high, which is three times the height of the Horse Hospital itself. Glazing is never transparent, and it appears as a dominating wall when viewed from the south. The CGYWG has no objection to a striking contemporary character building intended to signpost the entrance to the development, but the bulk and height of this one would unduly dominate the Horse Hospital.

8.3.2 The Applicant does not argue that the presence of this building g is outweighed by any public benefits. As this additional bulk does not contain any dwellings or office space, there are no public benefits that could outweigh this harm.

IN CONCLUSION, this is a once-in-a-lifetime opportunity to get this right, to reconnect the segregated parts of the Camden Goods Yard with Camden town, and to create a neighbourhood that Camden residents and workers deserve.