Analysis of Planning Application

We are working our way through over 330 documents which make up the planning application. We’ll keep updating this as we go. We held a public meeting to go over what the biggest problems are, as well as explaining how the planning process works, including what types of issue the planning officers will consider and what types they won’t – more details here (sign up to our newsletter here and use the social media buttons at top/bottom of this page to keep in the loop)

Here is a summary of some of the problems we’ve found with the plans so far –

Women’s Building. The amount of space allocated for this facility is insufficient. The Supplementary Planning Document (SPD) produced by Islington Council called for replacement of the women’s support services that used to be provided in the prison, but they won’t fit into the space currently on offer. Islington Council consulted local women’s organisations and 85% of them said the current plans are not good enough.

Architects are concerned that the Women’s Building is poorly designed.  The design means a lot of the rooms are accessed via long internal corridors, and many rooms have no windows for light or ventilation.  The design does not allow natural ventilation, as required by Council Policy, and so risks being uncomfortable and have high running costs (and carbon emissions).

The so-called ‘Women’s Building’ facilities have been designed with no feasibility study to inform requirements or a meaningful consultation of women’s organisations.  This contributes to uncertainty over how this facility will work and be sustained.  The application confirms the facility solely as a women-only space, undermining its ability to support the wider community and local families, as required by the SPD.

Density and Design of the New Homes. The plans include 15 blocks of up to 15 storeys high. Yet the recent Islington Local Plan Topic Paper Tall Buildings 2020 states that “The Holloway Prison site was also subject to detailed appraisal and was not considered suitable for tall buildings”.

The proposed number of homes also exceeds a reasonable density for the site, and is not in compliance with LBI’s own Capacity Study for the site.  This found that 720 homes would be appropriate and even that 880 homes would be too much:  “The scale of this option is judged out of character with the local area. It represents an over development of the site that risks reducing the quality of the development, levels of residential amenity, daylight and sunlighting.”

Pushing the density up by another 265 homes to 985, is a matter for concern due to the poor-quality homes created, many benefiting from public funding.

The 985 units deliver a density of 237 units per hectare, this is 4 times higher than the current density of St George’s Ward which has 5,350 dwellings on 85 hectares , which at 63 dwellings per hectare already is the 75th most densely populated ward in London (out of 624). The population increase of 3,450 (based on the plans) would make St George’s ward the 12th most densly populated ward in London, out of 624, and by far the most densely populated in Islington. 

The proposed building heights of up to 45m is also 50% higher than the maximum 30m building height suggested by Islington itself. 

Mix and allocation of tenure.  The distribution of tenure is not in accordance with Council policy, which calls for “affordable and private housing built to the same standards and indistinguishable from one another in terms of design quality, appearance and location on site. There should be no separation of amenity or facilities according to tenure.” The majority of homes with an attractive view over the central landscaped area are proposed as private tenure, while the social housing overlooks Camden/Parkhurst Road, which sees 25,000 vehicle movements per day. Flats along Camden/Parkhurst Road normally have to keep windows closed at all times due to noise and air pollution. There is a clear differentiation in the quality of homes prone to overheating – more below. The blocks are segregated into either social housing (social rent and/or shared ownership) or private blocks (housing for market sale). 

No dedicated community space.  The plans show some resident facilities, but no community facilities that are publicly accessible. Islington Council’s own Supplementary Planning Document (SPD) for the site makes many references to the requirement for provision of community facilities, which is ignored in this application. Residents’ facilities are provided in a large block of private housing, but this is very different to community facilities that would be welcome to all members of the public and serve to build a strong sense of belonging and mutual support between residents and neighbours. Instead, the new residents will have to use existing community facilities in the area, but the impact of a nearly 30% local population increase has not been assessed. 

Re-use and recycling of the existing buildings.  Nothing is expected to be reclaimed for re-use – all materials will be recycled (except for a small proportion going to landfill).

Dual aspect and OverheatingDual aspect design is key to the wellbeing of residents. Single aspect apartments increase the risk of overheating and have serious health, economic and environmental implications. The Application proposes to build 55% of the homes with only a single aspect, with up to 9m from the back of the home to window(s) that are only on one side of the home. The inclusion of bay windows doesn’t give cross ventilation in compliance with GLA design guidance and Policy. 

The solution for overheating is a form of air conditioning (cooling), but the number of homes that actually need this is not confirmed.  This will add to fuel bills, maintenance costs and carbon emissions.

Daylight. The documents confirm that over 200 rooms will not meet minimum recommended daylight levels due to the density of the buildings, and these are predominantly in the social housing.  The proposed design means that over 53% of rooms will fail to meet recommended (BRE) levels of annual sunlight. 

Loss of daylight to neighbouring buildings.  Rooms all around the site experience a loss of daylight, including a series of kitchens in Kimble House that have a 60-80% loss of daylight. Crayford House loses 30% daylight on average and Bakersfield loses 20% daylight on average. Individual flats at times fare much worse than this, and there are many instances where the loss by BRE standards is material. Even far more distant properties such as Mc Morran House or houses on Crayford Road lose daylight. None of the residents in these properties have been informed of this significant impact and the information is hidden in tables in 1,284 documents.

Overshadowing of neighbouring gardens.  A number of gardens are confirmed to experience a significant loss of sunlight.

Privacy and security.  A number of ground floor homes are immediately adjacent to the pavement, with only a small strip of planting between the pavement edge and their windows.

The quality of the Central Park is undermined by the fact that it is heavily overlooked, overshadowed and windy. 

The Play area for ages 0 to 4 is located adjacent to the 2-way road at the end of the park (with no fence or enclosure).

The outdoor café area at the rear of the women’s building block (at the edge of the park) that is so beautifully depicted in the visualisations does not actually exist in the plans.  The area in question is narrow and surrounded by ‘rain gardens’ which are basically ditch-like planting areas for absorbing stormwater runoff.

Wind effects.  Large areas of the outdoor space are shown to be only suitable for “walking”, not comfortable enough for “sitting.”


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