Below is the full text of the comments sent by the Charlotte Street Association to Camden Council’s planning officers in response to the planning application submitted by Derwent London (Ref: 2010/6873/P 80 Charlotte Street and 65 Whitfield Street).

(A summary of this text was provided in the Development Control Committee report provided by Camden’s planning officers.)

The proposed development occupies a whole street block in the heart of Fitzrovia. It is in part within the Charlotte Street conservation Area and the remainder abuts it. It is in an area identified as being deficient in public open space. Fitzrovia is identified as an area of high deprivation with regard to both living environment and access to housing and services (from indices of deprivation 2010).

It is located within Camden’s Central Area where policy requires mixed-use schemes with a substantial residential content including affordable element and where a scheme of this size would be expected to provide positive and substantial benefits to the local residential community. The proposal fails to meet policy on all these counts. In the case of public open space provision it actually worsens the existing situation.

It should be refused on the following grounds.

1. Overdevelopment. The proposals for the Saatchi block represent gross overdevelopment increasing the existing floorspace on an already fully developed site by 69% (17144sqm).

It increases the plot ratio from the existing 4.78:1 to 8.10:1 giving a higher density than Central St Giles and totally inappropriate for Fitzrovia.

2. Conservation. The overdevelopment described above would be seriously damaging to the quality of the conservation area particularly in relation to Chitty Street and Whitfield Street. Additionally

(a) 71-81 Whitfield Street (former Humphrey’s Film Lab) is identified in the conservation area appraisal as a positive contributor. The proposal involves its demolition with only an unsympathetically altered facade retained. Yet there is no heritage assessment in accordance with PPS5 to justify its loss.

(b) The applicants submission (p22 Design and access statement) does not show the existing former mews – North Court – now closed to the public but very much part of the historic fabric of the area. This should be retained and reopened as part of restoring the historic fabric and achieving greater permeability.

3. Public Open Space (POS). No Public Open Space is offered. An area of 231sqm of publicly accessible open space is proposed in Chitty Street representing a mere 4.5% of the site area and quite derisory in an area identified as deficient in POS. Not only is the proposed open space in Chitty Street minute it is backed by a cliff-like 8 storey building.

The total increase in commercial floorspace is 10925sqm including adjustment for existing and consented space at 65 Whitfield Street. This produces an additional 910 workers (based on London Plan 12sqm/worker) and the residential proposed provides 184 bed spaces.

On the basis of calculations set out in Planning Guidance, this produces a requirement for the provision of 3285sqm POS yet only 231sqm of publicly accessible open space is provided.

In addition it is claimed that 1180sqm of private amenity space is provided of which 640sqm relates to the commercial element.

Planning Guidance in 39.14 says private amenity space will be taken into account and may reduce use of POS. However it does not override need to provide POS which will meet play and recreational needs and can provide for community activities or opportunities for social interaction.

Nor does the proposed provision meet the requirements of PPG17.

So that the reality is that in an area of identified POS deficiency and living environment deprivation the development does not even provide sufficient open space to meet the additional demands generated by the scheme. So far from ameliorating the existing identified shortage it will actually exacerbate the shortage by increasing demand.

This aspect itself warrants rejection of the proposed development.

4. Residential. Planning policy requires increases in commercial floorspace to be matched by an equivalent area of residential floorspace of which 50% should be affordable. In the present case only half (53%) of the required residential floorspace is provided — 5462sqm — instead of the target of 10925sqm. The level of provision of affordable is even worse; only just over a quarter (27.5%) of the required provision is offered. 1500sqm instead of a target of 5462sqm. A mere 15 units instead of 55.

5. Ground floor uses. The scheme proposes A1/A3 uses on the ground floor of all four frontages. This is a quiet part of Fitzrovia and it is not considered desirable to bring the frenetic activity of the perimeter main roads or even the southern part of the area into this part of Fitzrovia. Part of the character of a city is derived from the contrasts between active and quiet areas. The tranquil character of this part of Fitzrovia would be undermined by extensive A1/A3 ground floor uses. In the current proposal such uses should be limited to the Howland Street frontage.

6. Pre-application consultation. It should be noted that the developers refused a request from the Council to hold a Development Control Forum, usual for schemes of this size. It is hard to see how the Council’s acceptance of this refusal can be reconciled with its Statement of Community Involvement. The only pre-application consultation consisted of two stage managed exhibitions at which only limited selected information was available and requests for further information actually refused.

Summary. The proposal should be refused on the grounds of:

  1. Overdevelopment with consequent damage to the quality of the conservation area.
  1. Woefully inadequate provision of POS to the extent that the development would actually exacerbate the existing identified POS deficiency.
  1. Inadequate provision of residential both market and affordable.

It should be noted that the buildings presently on site are not derelict or under occupied, but fully operational and let to a company of international repute and there is no practical reason why they should not continue to be so used.

The retention of the status quo is considered greatly preferable to allowing a scheme so lacking in merit and contrary to policy to proceed. A refusal would safeguard a situation where a future development which meets the Council’s policies and the needs of the area would not be prejudiced.

Yours sincerely

Max Neufeld