Silchester Residents Association full Local plan partial reveiew response


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Local Plan Partial Review

Issues and Options

Consultation Response Form

December 2015




This consultation is open for 8 weeks from

Tuesday 15 December 2015 to 11:59pm on Tuesday 9 February 2016.



The Council prefers to receive your consultation responses on-line,

however, you may also respond by email or post using the details below.



: On-line (preferred)

or via


š Email

Please state ‘Consultation Response – Local Plan Partial Review Issues and Options’ in the subject line


+ Post  

Planning Policy Team

Planning and Borough Development

Royal Borough of Kensington and Chelsea

Kensington Town Hall

Hornton Street

London W8 7NX




Consultation responses, including for the Call for Sites, will be made public as part of subsequent stages of the Local Plan Partial Review (see section 1.4 of the consultation document). Please clearly identify any information provided which is commercially sensitive and/or you would like to be kept confidential.





Overall notes and comments


This response was written by a group of 11+ residents from the Silchester Residents Association.  Leaseholders, private and TMO tenants were all represented.


We found the timeframe of the consultation too short to organise a balanced response to such a large document from a group of people with extensive work and family commitments.  Advance notice of a longer consultation would have helped us. Furthermore, the manner in which the consultation was advertised placed the onus on residents to be aware of the consultation and to proactively seek out information. The Council should have been doing more to make residents aware of the consultation and also to clearly explain the significance of the local plan for the future of the borough and its residents.


The language used throughout the partial review and questions (as well as the adopted plan), length of document and information about submitting a response all formed barriers to resident engagement that is not acceptable.  As such, we have only answered what we felt able to do adequately and have deleted the other questions so our document is easier to read for those collating the information.


We are against what seems to be a drastic and naively simplistic policy of creating additional housing by demolishing/ regenerating entire estates.  This approach is disrespectful both to the well-established and cohesive communities that call the estates home and the well-designed buildings that are far from their end of life. The local plan revision is very negative in its description of the quality and design of the post-war housing estates in the area where the reality is much more mixed – not all are poor quality and some provide a very good quality of life. The high-rise buildings are the most poorly maintained but also the hardest and most expensive to regenerate. Whilst it is not a matter for the local plan, there should be more emphasis on maintenance and less reliance on developers for large scale regenerations that are very destructive to the borough’s character and communities. Indeed, it seems from the wording of some of the plan that it seeks to establish its own truth of what life is like for the communities in Latimer/ Silchester with the objective of establishing demolition and rebuild as the obvious course of action.


There is no safeguarding of right to return for secure tenants or leaseholders in this document.  A hope is not enough.  Leaseholders displaced by regeneration are often the original council tenants who bought to secure a future in the area for themselves and their families.  Forcing them to “take the money” and move on is another huge blow to the cohesion of established communities.


On p.30 it suggests that residents in the north of the borough die earlier because of the housing stock RBKC are looking to replace (presumably estates) “In North Kensington, many of our residents are missing out on years of good health. And much of our housing stock there requires refurbishment or replacement and is, in terms of architecture and urban design, markedly less attractive than the rest of the borough.”  There is no mention of any measures to reduce poverty in the north of the borough, which is a clear determinant of not just life expectancy but also years lived in good health. There is also no consideration of environmental issues such as air pollution. The presence of the Westway flyover would continue to result in high levels of nitrogen dioxide and other pollutants regardless of whether people were housed in the current stock or ‘Victorian mansions’. This leads to the conclusion that increased average lifespan will be brought about by decanting people out of the area or by regenerating to a much higher density with a mix of tenures, so the increased number of wealthier residents will bring up the average lifespan whilst the poor and vulnerable remain in the same position.  This is offensive.  Lifespan also has nothing to do with building aesthetics that are entirely subjective.


The Royal Borough is desirable because of its diversity of environments, architecture and population.  Sympathetic small-scale regeneration and programmes of gradual refurbishment, safeguarding independent shops and markets and maintaining all public green space will ensure the future desirability of RBKC.


Contact details




Silchester Residents Association

(if applicable)

Click here to enter text.

(e.g. self or client)

Silchester East and West residents
Email Address
Postal Address


24 Shalfleet Drive, W10 6UB
Telephone Number








Section 4: Site allocations

Issue 1: There has been progress in delivering most of the strategic sites since the Local Plan was drafted (as the Core Strategy in 2010). The Council needs to consider whether it is appropriate to update the Local Plan to reflect the progress that has been made to make the Allocations and Designations chapter easier to use and to identify new (strategic) sites.




Question 3

The following potential new (strategic) site allocations have been identified:


·               Royal Brompton Hospital/ Chelsea

·               Pembroke Road

·               Barlby and Treverton Estates

·               Silchester East and West

·               39-49 Harrington Road


Do you agree that any / all of these should be allocated in the future and do you have any comments on the draft indicative boundaries?

The document is very negative in its description of the quality and design of the post-war housing estates in the area. The reality is much more mixed – contrary to the suggestion that housing is of poor quality, and many estates provide a very good quality of life. 

On Silchester, the high-rise buildings are the most poorly maintained but also the hardest to regenerate.   We must not confuse poor maintenance with poor design. This is a crucial point to understand, not just in the present circumstances but also for the future where any new stock, if not properly maintained, will simply repeat the hardships experienced by current tenants. Given the current dire financial circumstances facing many local authorities it is alarming to find that the local plan is silent how the council plans to fund the maintenance of future housing stock.

Silchester East and West have a well established community living in well designed buildings which are far from their end of life. It is not appropriate to designate the area as a strategic site where the default position would be that all existing buildings and green space would be completely rebuilt. Buildings and green space should be protected and assessed to ensure they meet resident’s requirements. They are likely to reach end of life one at a time and a more sympathetic regeneration can then be undertaken that serves the community’s needs.


It seems completely perverse that on the one hand the Council cites life expectancy and health as justification for regeneration yet on the other openly admits that regeneration would dramatically increase housing density and drastically reduce the amount of open green space currently enjoyed by residents on the Silchester Estate. The proposals are also silent on how exposing a significantly increased population to detrimental pollutants such as nitrogen dioxide from the Westway Flyover would help create a healthier community.



Section 5: Infrastructure and planning contributions

Issue 2: Public art




Do you have any other comments, issues or options (reasonable alternatives) you would like to raise regarding this section?
These planning contributions should not be at the expense of contributions for other public amenities such as making Latimer Road station accessible to disabled commuters or the introduction of cycle routes. In addition, residents must be consulted on public art and their views acted on. They should also be involved in its production.




Issue 3: Open space


Option 1

Local Plan policy should set out high level principles regarding ‘planning contributions’ for open space and not make a distinction between S106 / CIL, for which the detail can be considered in any revisions to the R123 List and/or the Planning Obligations SPD.

This question is not clear


Option 2

Local Plan policy should reflect the detail of the R123 List and no longer seek open space through S106s (except where the R123 List exceptions apply).

This question is not clear


Do you have any other comments, issues or options (reasonable alternatives) you would like to raise regarding this section?
All existing public space, playgrounds and gardens must be maintained at their original scale, and mature trees left in situ.     If developers are allowed to build on public land then these public amenities must be maintained and their access to the public safeguarded (i.e. not locked for neighbouring residents’ use only). They are public amenities, not just residents’ amenities.



Issue 6: Viability and transparency


Do you have any other comments, issues or options (reasonable alternatives) you would like to raise regarding this section?
All matters regarding infrastructure and planning contributions should be completely transparent with a genuine effort made to engage communities.


It would be helpful to publish clear definitions of jargon so that when someone refers to, for example, ‘affordable’, we have a reference as to what that means rather than everyone assuming their own interpretation.



Section 6: Shops and centres


Question 3

Should the Council continue to influence the nature of new shop units being provided within a centre?

Shops should be relevant to the community, not just a ‘Notting Hill’ address for businesses to exploit. Please see q.4.


Question 4

Should the Council continue to seek the provision of affordable shops in new large scale retail developments?






Question 7

Should the Council continue to ensure that street markets remain a vibrant part of the Borough’s retail offer?


Double Yes




Issue 3: The Borough’s centres must be seen in the context of a hierarchy of centres. Do the Borough’s centres lie within their correct position within this hierarchy, and are the boundaries of these centres still correct?



Question 4

Should the Council designate a new Neighbourhood Centre at Latimer Road, close to the underground station?

Within a few hundred metres of the proposed neighbourhood centre residents   have the two World Renowned Centres of Westfield for top end retail and Portobello Road for budget shopping.

The shops further south on Bramley Road are often closing and re-opening which suggests there may not be demand for more shops. There are well established shops at St Helen’s, Ladbroke Grove and further south as well as the existing shops on Bramley Road which is already subject to considerable traffic congestion and resulting pollution and could not take additional traffic.   The residents of Silchester and MoreWest were offered aspirational cafés and retail as part of the MoreWest development. This has not materialised with the units remaining vacant. We do not want this to happen again as to do so would increase not address economic blight at a local level.


A neighbourhood centre must serve the needs of current residents. The description of the area being poorly served in terms of shops is subjective. The shops are tailored to the local community, e.g. offering credit, which is unlikely to be the case with chains and new shops.




Do you have any other comments, issues or options (reasonable alternatives) you would like to raise regarding this section?
The Council, Architects and Developers should when making presentations ensure that they clearly define what is aspirational and what they have the control to deliver.


Section 8: Arts and cultural uses



Issue 2: What spatial approach should the Council adopt to support enhancing thecultural draw and promoting the arts and cultural uses across the Borough?



Question 2

Should the Council specifically support enhancing the cultural draw of the following places?


Those within the existing policy:

·      South Kensington Strategic Cultural Area

·      King’s Road / Sloane Square

·      The Notting Hill Gate and Portobello Road area

·      Kensington High Street


Possible new creative industries clusters at:

·      Kensal Employment Zone and Kensal Gasworks

·      Freston / Latimer Road Employment Zone (linking to Imperial West Innovation Hub)

·      Lots Road Employment Zone

·      Somewhere else

We do not have have a geographical definition of the Freston/ Latimer Road Employment Zone 

Whilst we applaud the council’s initiative to support these vibrant industries, these creative industry clusters must not be at the expense of established local communities and affordable residential homes. Smaller scale businesses would be more appropriate given the scarcity of available land in the area. Artist’s studios such as those on Blechendyn st and small business units as at Baseline on Lancaster West are a good fit for the area.


The council should play a facilitating not a determining role in the future cultural development of the borough. History shows us that the cultural, artistic and historical heritage of London that makes it such a desirable place to live is because the city has grown organically and has not been determined by dictat. As such the council should be supportive to new locally led initiatives but not try to prescribe what these should be.






Section 10: Housing

Issue 2: Amalgamations and de-conversions



Option 3

Resist the loss of all residential units unless it can be demonstrated that the de-conversion is required to create a decent standard of accommodation.




Issue 3: Setting an affordable housing target


Option 1

Adopt a Borough wide affordable housing target of between 30-35%.

Yes or greater. This is to include social housing



Option 2

Adopt a split affordable housing target to enable a higher percentage target in the highest value areas.

This question is not clear



Do you have any other comments, issues or options (reasonable alternatives) you would like to raise regarding this section?

There must be a clear defiition of the various strands of social, affordable and intermediate housing, both to rent and to buy, and who is elegible for these properties.


Issue 4: Affordable housing tenure split


Option 1

Set a Borough wide target of 72% social/affordable rented housing and 28% intermediate housing to take specific account of the findings of the SHMA.

Yes, although the definition of affordability in this question is not clear.



Option 2

Set a Borough wide target of 17% social/affordable rented housing and 83% intermediate housing based on the Council’s adopted Intermediate Rent Policy.

This question is not clear



Option 3

Set a Borough wide target of 56% social/affordable rented housing and 44% intermediate housing based on the mid-point intermediate rents set out in the SHMA.

This is not clear



Option 4

Set a Borough wide target that takes account of the three scenarios (set out under the first three options) together with further information collated from Registered Providers and developers on the viability of delivering intermediate rent units.

This is not clear



Do you have any other comments, issues or options (reasonable alternatives) you would like to raise regarding this section?
There is a lack of clarity throughout this section.     We are in favour of the maximum amount of social and affordable housing alongside some for intermediate rent.

Much of the regeneration in the north of the borough is being done in the name of reducing the council’s housing list. We must have clearly presented figures including percentages that give details of additional social housing as well as affordable and intermediate as a proportion of overall housing stock so that we can understand that this can happen.



Issue 8: Meeting specific housing needs

Older people’s housing


Option 1

In light of the need identified for older people’s housing the Council should introduce policy support for the provision of new extra care and sheltered housing where this will meet identified local needs, and resist the loss of existing accommodation subject to criteria such as need and the quality of the provision.

Yes, this accommodation should be preserved or increased.



Option 2

The Council should identify specific sites or locations for the provision of specialist older people’s housing.

No. They should be integrated into established communities, along with the relevant level of support


Extra care and retirement housing


Option 1

The Council should rely on regional level guidance to determine the key characteristics of extra care and sheltered housing.

We do not understand the terminology


Option 2

The Council should set out the essential characteristics for schemes to be classed as extra care or sheltered housing at a local level. .

We do not understand the terminology


Supported housing


Question 1

Should the Council resist the loss of existing supported housing which meets identified community needs?

This housing should be preserved or increased


Self build


Option 1

Provide only in-principle support to the self/custom build housing.




Option 2

Identify sites which may be appropriate for self/custom build proposals.




Option 3

Consider introducing a requirement for large schemes over a specific size threshold to make a proportion of units available as custom build.




Do you have any other comments, issues or options (reasonable alternatives) you would like to raise regarding this section?
This would promote housing outside of the market driven scope of the developers


Issue 9: Securing a Suitable mix of housing

Dwelling size requirements


Option 1

Continue with current policy CH2(a) which requires residential developments to take account of local needs as set out in the Council’s evidence.

Do not understand



Option 2

Set out specific targets for housing mix within a revised planning policy.

This is my preferred option

Click here to enter text.



Do you have any other comments, issues or options (reasonable alternatives) you would like to raise regarding this section?
Housing standards should be as Parker Morris for social, affordable and leaseholder properties. Dwelling sizes should not be reduced.


Buy to leave.


Option 1

The Council should not seek to introduce any restrictions on the period of occupation for new residential properties through planning policies.

There should be restrictions, not just on planning



Option 2

The Council should consider introducing a policy limiting the period during which residential properties can be left vacant to prevent new homes from being used as ‘buy to leave’ assets. This would be enforced through planning obligations.

Yes there should be a policy. This should be introduced through fiscal policy as well as planning




Issue 10: Housing estate regeneration


Question 1

Should the Council retain all elements of the existing policy including the requirement for no net loss of social housing provision? Should the policy be changed in any way?

There should not be a net loss of social housing provision.

Increase in social housing is the only viable reason for regenerating established existing communities.     There must be security of tenure for adult children of existing tenants living on estates being regenerated.

The North Kensington estates have exceptionally long tenure (avg of 38 years according to the TMO). This has implications for their families which must be respected.

Regeneration is being undertaken on the basis that more homes must be built to reduce the council’s housing list.     To suggest that there could be a net loss of social housing provision makes a mockery of this.

Noise pollution must also be taken in account both during and after regeneration. This should be both noise resulting from construction and an increase in noise levels due to changed ground floor use of buildings or increased density of occupation.





Section 12: Access and space housing standards

Issue 1: Access standards



Do you have any other comments, issues or options (reasonable alternatives) you would like to raise regarding this section?
We support the maximum number of accessible properties, especially in light of the aging population in the borough




Issue 2: Space standards


Option 1

The Council should continue to refer to the space standards in the London Plan (assuming the changes in the MALP in respect of space standards are adopted).

Not understood



Option 2

The Council should not refer to the space standards in the London Plan (assuming the changes in the MALP in respect of space standards are adopted).

Not understood



Do you have any other comments, issues or options (reasonable alternatives) you would like to raise regarding this section?
Space standards in regenerated properties need to be at least as large if not bigger than current/ previous homes. This should be for each room, built in storage and entrances as well as overall within the property.


Download the response as submitted:  Final SRA response 151215LPPR_IandO_v13_Appendix_C_Consultation_Response_Form_and_Call_for_Sites