The Chelsea Society has responded as follows on 1st October 2021 to the New Local Plan Review: Issues and Options Consultation:
“The Chelsea Society was founded in 1927 to represent the interests of all those who work and live in Chelsea and to preserve the unique character of this part of London. We have around 1000 members.
The following are our comments on the Council’s Issues and Options document on the new Local Plan.
THE CONTEXT OF THE PLAN
The existing Local Plan was issued in 2019 and would normally not need to be revised until 2024. The Council argues that the Grenfell fire and changes, or potential changes, in planning legislation mean that this revision needs to be brought forward.
We accept that, like all plans, the Local Plan needs to be kept up to date. But this is a particularly challenging time at which to embark on a wholesale revision. The Covid pandemic, the UK’s withdrawal from the European Union and other recent developments are likely to have profound, but as yet unpredictable, consequences for the Borough’s economy: for example on patterns of shopping, work arrangements, transport requirements, levels of immigration and demands for housing. It will take time for the implications of these changes for Council policies to become clear. We urge the Council therefore not to set in stone policies which may turn out to be based on false assumptions; and to focus on those amendments to the current plan which can be justified by solid evidence.
CHELSEA’S CHARACTER AND HERITAGE
We are disappointed that the document pays so little attention to the unique character of our part of the borough. Most of Chelsea is in a conservation area and the need to preserve the heritage of conservation areas should, in our view, be a, if not the, key priority in any new iteration of the Local Plan. Section 13 of the document, on conservation and design, is insufficiently robust. The many references to growth and development in the document need to be balanced by a clear commitment to the preservation of Chelsea’s character.
Particularly so in relation to policies on tall buildings. Part of Chelsea’s charm is the variety of our conservation areas. But their common feature is that they are low-rise. Unlike much of the Thames in Central London, the Chelsea embankment and waterfront is (with the sad exception of Chelsea Harbour), unscathed by tall buildings. It should be an explicit policy of the Council to ensure that this remains the case. We reject strongly the claim in para 13.8 of the document that the definition of a tall building could be revised in such a way as to loosen the present restrictions. The Council should have an unequivocal policy of resisting any increase in the height of buildings in conservation areas.
HOUSING AND EMPLOYMENT SPACE
The need for more housing is a consistent theme throughout the document and indeed seems to be a principal generator of the review itself. We recognise that the Council is under pressure from both the Mayor London and from central government to deliver over 4000 new homes over the coming years. But it is wrong, in our view, to treat housing/homes as a single commodity, without any attempt to distinguish between different types of accommodation, for example between luxury flats for absentee landlords and affordable housing for key workers. A glance at the unlit facades of many buildings in Chelsea at night shows how few of them are actually lived in. Meanwhile many of the workers on whom we rely for our services, including Council staff, cannot afford to live in the borough. Addressing this problem should be the Council’s principal housing priority.
But we question the emphasis given in the document to the need for more houses as opposed to more jobs. At the time of the 2011 census only 70% of residents in the economically active age group (16 to 65) were in work or seeking work. It should be a priority for the Council to reduce the number of inactive residents: this means improving the opportunities for training and generating more affordable managed workspace across the Borough. This is particularly urgent as we seek to recover from the disruptive effects of the pandemic.
In view of the small size of the Borough and the fact that it already has the highest density of dwellings in Greater London at 7,047 per square kilometre and the highest land values (according to a FT analysis in September 2018), the demand from the Mayor of London to build yet more housing is disproportionate. The last Census showed that Earls Court’s density was already over 200 people per hectare as compared with 20 people per hectare in Richmond.
According to the 2011 Census the percentage of social housing across RBKC was already almost 25% (almost exactly the same percentage as for Greater London as a whole). Yet this was spread very unevenly across Wards: Riverside Ward with a density of 162.3 people per hectare already has 41.3% of its homes as social rented properties and when the new homes on the Power Station site (420) come on stream shortly this percentage will rise to 50%. If we are to ensure balanced and viable local communities, further population growth in this highest density UK borough, where so much social and physical infrastructure is already under great pressure, should be avoided. Why should RBKC, rather than lower density outer London boroughs take the strain of providing more housing?
According to the last published Census only half the population of RBKC residents were actually born in the UK, and probably far less than half born in London itself. It is by and large not “local people” who are creating the demand for more housing in this borough, but developers who sell to overseas buyers, many of whom are unlikely to participate actively in the life of the local community. The last published Census showed 29.9% of households in Brompton and Hans Town Ward were classified as “second addresses”, about twice the level in Riverside Ward.
This Census also showed the extent of churn in Brompton and Hans Town during the previous ten years: in terms of length of residence in the UK, 24.7% of residents had only arrived in the last 5 years and 13.9% in the last 5 to 10 years (3950 residents). In RBKC as a whole this Census indicated that 19% of residents had a second address split between the UK (41%) and outside the UK (59%). The 2021 Census will reveal whether this trend has continued or whether other patterns have emerged, for example a loss of residents back to the EU or out of inner London to much lower density boroughs and the Home Counties. It would surely be wise for the Council to wait until this picture, and its economic and demographic implications, are clearer before reaching any conclusions on future housing policy.
We are also concerned that the emphasis on more housing regardless of its nature is distorting planning decisions. The Council has a policy, which we support, of requiring, in the case of developments above a certain size, 35% of the floor space to be reserved for affordable housing. In practice however applicants are often able to argue that this would not be commercially viable unless the Council agrees to a building higher or larger than would be justified on normal planning grounds. We urge the Council not to give in to pressure of this kind.
GROWTH AND DEVELOPMENT
The paper is full of references to growth and development, without any explanation of what these terms mean and why they should be encouraged in conservation areas, of which Chelsea has many. There is also no recognition in the paper of the need to ensure that no significant development sites in this densely populated borough are approved unless and until it can be shown that in step with such developments (and not a decade later) the additional social, educational, public health and recreational infrastructure will be built to absorb their impact. The driving force in any new Local Plan should be the well-being of the borough’s residents. This means, as noted above, a much greater emphasis on the provision of local employment. In Chelsea there is only one employment zone: the Council should be seeking ways or enhancing and expanding it, rather than squeezing it out with more housing.
THE COUNCIL’S ABILITY TO DRIVE CHANGE
The document exaggerates the current ability of the Council to drive change or to influence development. Most investments in the borough are made by the private sector on the basis of its judgement of what the market will bear. Property developers will not include social or affordable housing or social infrastructure in their schemes unless they are forced to do so; and even when the Council purports to impose obligations (for example the 35% affordable housing rule for large developments) they are adept at finding loopholes for avoiding or mitigating them. The Council needs to be honest with residents about what it can, and cannot, do.”