Our response to the deferral decision on 10th Feb 2022

The Community Plan for Holloway (CP4H)’s collective response to Islington Council’s planning meeting on Thursday 10th February 2022

  • This document is CP4H’s response to the main concerns that were outlined by the councillors as reasons for deferral of Peabody’s plans for the legacy Holloway Prison site. 
  • Prior to outlining our response, CP4H feels there are three significant issues we must draw attention to:
  1. Public transparency and democratic decision making.  We are very concerned that the Design Review Panel report released with the Planning Officer’s report dated 24 September 2021 is the planning officer’s summary and not the actual letter that was sent to the applicant.  For reasons of public transparency and informed decision making, copies of all five letters sent by the Panel to the Applicant should be made public before the planning meeting. Our view is the meeting should not take place without those letters being made available.
  1. Content of the meeting.  We wish to draw attention to the official minutes of the Planning Committee of 10 February 2022 where it resolves “that consideration of the application be deferred for the reasons outlined above,” thereby encompassing all of the points of concern and reasoning raised during the meeting. 

The minute therefore concurs with our counsel’s advice that all aspects of the plans should be open for discussion at the upcoming planning meeting because the plans for the site must be considered as a whole for a balanced plan to be agreed. Topics cannot be ring fenced from the first meeting if they have a bearing on the topics to be discussed at the following meeting. We have therefore included issues in this response which are closely linked to the reasons given for deferral. 

  1. The need for sufficient time for the community to consider new information.

Peabody issued a ten page detailed update to aspects of its plan in response to the members’ concerns, which was made available to the public on 24 February 2022. The Officer’s report was issued at 6pm on 28 February 2022.  In addition, CP4H is anticipating that all five letters sent by the Design Review Panel to the Applicant will be put into the public domain and will need detailed consideration.

In respect to the paragraph above, it is self-evident the community will not have had enough time to properly analyse and respond to these changes. CP4H sent a request to planning officers on 24 February 2022 that the planning meeting be deferred. As of 6pm 1 March 2022, CP4H has yet to receive an official response to this request. 

After three years of deliberating the future of the site, it would be counterproductive to hold a planning meeting before the community has had a reasonable amount of time to consider the most recent plans and associated documentation in full. 

  • CP4H also has wider concerns, which include the size and location of the legacy Women’s Building; addressing Islington’s Climate Emergency targets, and complying with the Council’s own environmental requirements; the impact of the site design on its neighbours, such as Bakersfield Estate, Trecastle and Penderyn Way; aspects of site design especially lack of true dual aspect for ventilation; and slapdash consultation by Peabody. 
  • We believe that the significant changes we outline below are fundamental to the success of the development, and that in order to address these issues, Peabody must rewrite the plans. 


In summary, CP4H would like to submit the following response for consideration. More details on all these points follow this Summary.

1. The massive discrepancies between Peabody and the council’s assessments of the financial viability of the site: 

We share councillors’ concerns about these discrepancies and the higher figure’s potential for being used by Peabody, subsequently, to justify unacceptable retreats from previous commitments. More detail below.

2. The future running costs of the Women’s Building and the request for more public subsidy:

These costs should be borne by Peabody. The attempt to foist these costs onto the Council, at the very last minute, was completely unacceptable and has still not been resolved adequately by Peabody. CP4H is absolutely opposed to the sum of £2.9 million being used for this purpose rather than for providing much needed support for communities across the borough. There is no way in which CP4H would support taking such resources away from others in need of community facilities.

3. Tenure mix in the blocks and the hugely disproportionate number of social homes facing onto the busy main road:

Despite Peabody’s update, we are still very concerned about social segregation, as were the councillors at the meeting. CP4H has consistently argued strongly against tenure segregation and in support of ‘pepper potting’ across the site. This is vitally important in building community solidarity, as well as being essential in terms of equalities considerations. 

4. No community centre on the site for the over 3,000 new residents:

Community amenities are key to ensure a safe and thriving new community. At the very least, the residents’ facility in Block D should be democratically run by a co-operative group of tenants and residents, for the benefit of the whole community. It’s not clear what the role of the TRA proposed by Peabody would be in relation to Block D. 

5. The inadequacy of indoor and outdoor amenity space for children of all ages and especially young people:

CP4H strongly supports the councillors’ concerns about the lack of provision on the site for children and young people and have consistently argued for this. Peabody’s update, although welcomed, needs to be properly analysed, especially in the light of the suggestion of future consultation with the Metropolitan police. Children and young people living in all types of homes on the site must have access to amenities that support them as they grow into successful members of the wider Islington community.

6. Access to the proposed “residents’ lounge”:

The councillors are clearly as concerned as we are that this 1,000 sqm space should be available for the use of the whole community, not only private residents. Our proposal for this to be run by a democratically accountable co-operative group of tenants and residents has already been spelt out under Item 4. In any case, it is not clear how Peabody’s last minute proposal to allow one day a week free access will actually work in practice. 

7. Pedestrian and road access to and from neighbouring estates:

CP4H also supports the councillors’ concerns as well as concerns from local residents. People living locally should be properly informed and involved in discussions around this topic. 

8. The need to provide the London Living Rent model for the 18% “affordable homes”:

CP4H has consistently campaigned for the London Living Rent to be offered as the least objectionable form of tenure for the 18% ‘affordable’ homes. Peabody is continuing to exclude this model in favour of Shared Ownership. We agree with the councillors that Shared Ownership is not affordable in Islington and should not be offered on this site. 

9. Wifi provision on the site

CP4H agrees with the councillors’ concern that fast and affordable wifi access must be facilitated on the site for residents to access from their homes. All of the flats should be broadband-ready.

More detailed responses to these issues follow below, followed by other key issues of concern raised by councillors and by objectors during the planning meeting. 



Intro and Summary    

Section One

1. Discrepancies in financial viability    

2. Women’s Building – funding and other issues    

3. Tenure mix and social homes on the main road                

4.,5. and 6. Lack of community amenities and the ‘Residents’ Lounge’                

7. Access to and from the new development    

8. London Living Rent model for the 18% “affordable homes”                   

Section Two

10. The detrimental impact of the new development on local residents living in neighbouring streets and estates                                       

11. Failure to meet environmental and policy requirements                                                                

12. Compliance with design policy, especially regarding “dual aspect” design and ventilation of homes  

13. Problems with Peabody’s consultation                                                

Section One

1. The massive discrepancies between Peabody and the council’s assessments of the financial viability of the site: 

There are two issues around the viability of the site, and which the community needs more time to consider the implications of:

  1. The community is extremely concerned that despite the massive sums of public money invested in this site, the developer has declared a deficit of over £44 million. 

Do Peabody have approval from their Board for the £44 million deficit?  And if not – do they have general internal Board approval to subsidise the delivery of affordable housing? There are a number of other questions that need to be answered in order for the community to be able to take a view.

According to the most recent planning committee report, “a scheme deficit of circa £44 million raises concerns about the deliverability of the scheme..The applicants have responded to the Planning Committee’s concerns about viability in their letter dated 23 February 2023. Their approach to the benchmark land value and scheme viability as outlined above has not changed. Having taken advice from BPS and from Counsel, it is considered that the applicant’s position continues to be flawed.”

  1. CP4H shares the councillors’ concerns about the discrepancy of over £40 million in viability assessment by the developer and the council itself, and the higher figure’s potential for being used by Peabody, subsequently, to justify retreats from previous commitments. In fact Peabody is already doing this with its refusal to meet the fit out costs for the Women’s Building.

We will be providing more information about our concerns to councillors.

2. The future running costs of the Women’s Building and the request for more public subsidy:

As already stated, having received over £90m of public money Peabody still say that they don’t have enough funds to fit out the Women’s Building (WB), and request that these costs be met by the Council instead of being invested in other areas, as part of the CIL. Peabody promised to deliver a building, not a shell and they must be held to this commitment. 

There are further serious concerns about the plans for the Womens’ Building: 

CP4H does not believe that the plans are compliant to the SPD and the Women’s Building brief. Most importantly, the proposed WB will not be able to replace the services lost when the prison was closed – a key aspect of the council’s vision for the site as laid out in the SPD. 

The size and feasibility of the Women’s Building 

Peabody claims that they have scoped a stand-alone Women’s Building – CP4H question that this has taken place. 

Peabody asserts that the single floor on offer is adequate and fit-for-purpose. However they have not yet done a Feasibility Study and women’s service providers have told us that their views have not been taken on board during the consultation. 24/28 of the service organisations who responded to the early brief felt it was not adequate, and that it did not respond to the legacy of the prison in a satisfactory way.

Future service providers should be closely involved in discussions about the size and design of the building. If not, there is a risk that this space will not be fit-for-purpose and that funds spent on fitting out the building will be wasted. The WB should be finalised only when the organisations who will be involved in running it in future are satisfied with the plans. At that point, CP4H believes that the fit out of the WB should be done in collaboration with the service provider/s who will run the building. 

The feasibility study: LBI and Peabody are suggesting a restricted feasibility study limited only to the space offered in the plans. CP4H has advocated for an open study to inform what the building needs to be, including the community and service experts and have indicated our willingness to take part on appropriate terms. 

This study should be properly resourced. CP4H has been told that a full feasibility study that covers business and governance issues would cost over £20,000. CP4H believes that the community and women’s sector organisations, with its wealth of expert experience, must be involved in deciding how the WB will be governed and by whom. CP4H has always advocated independent governance. 

There has been a large emphasis on Community Centres as a model for the Women’s Building Model, for example Brickworks Community Facility. But Brickworks is approx. 1000sqm and doesn’t have sufficient space for the offices, services and educative services the Women’s Building needs to house. As a Women’s Building, this is a unique project and requires a unique approach. 

Peabody has claimed that the Women’s Building could not be any bigger as it would impact on Social Housing, which CP4H disputes. Yet a Residents’ Lounge, that is approx two thirds the size of the Women’s Building has suddenly appeared in the plans. 

Location of the Women’s Building

CP4H suggests that Block E2, currently for private homes, be allocated as a landmark standalone Women’s Building.  In order to avoid overshadowing Penderyn Way flats, it is noted that Block E2 should be reduced by up to five floors. Block E2 is currently seven or eight storeys high and approx. 500 sqm in footprint. Four floors of this block would provide 2,000 sqm, which although a lot less than the 4,600 sqm that was available to women in the prison, would provide much better provision than what is available for service providers in the current offer. This scenario would also allow for a sunny legacy garden that could be shared with the older people’s accommodation.

3. Tenure mix in the blocks and the hugely disproportionate number of social homes facing onto the busy main road:

CP4H has consistently argued strongly in support of ‘pepper potting’ or mixed tenure blocks across the site, necessary to build a cohesive community based on a culture of equality of opportunities for all regardless of age or background. The success of mixed tenure blocks in Hackney and Haringey demonstrate that there is no reason why mixed tenure blocks should not be successful on the Holloway Prison site. 

This should be a condition for any future development on the site and is key for the life chances of all new residents of all ages and backgrounds.

Segregation of housing tenures on the site: 

The social rent units are poorly located. They constitute 42% of housing on the site so can be compared to the private sale units which constitute around the same percentage at 40% of housing on the site –  so you would expect their distribution on the site to be comparable. 

Peabody now say: 

“On Blocks B4, B5 and B6, the homes facing Camden/Parkhurst Road comprised of 22% Social Rent, 63% Shared Ownership, and 15% market. We have listened to the comments made by Members and have redistributed the tenures on Block B3 and Block B4 to convert Block B4 to a 100% market home building, as shown in the enclosed axonometric view. Blocks B4, B5 and B6 now provide a market sale building, a London Shared Ownership building and a Social Rent building. The homes within the blocks that face Camden/Parkhurst Road now comprise 22% Social Rent, 49% London Shared Ownership, and 29% market. By moving the London Shared Ownership homes from Block B4 to Block B3, we have been able to ensure that six of the 11 buildings that have a direct view of the public park, still have affordable accommodation.”

But out of these 11 blocks, there are 3 blocks where only the corner flats face the park. Of these 3 blocks, 2 are for social rent and one for private sale. 

Of the eight buildings that fully face the park: 

– 5 and a half of the buildings are for market sale 

– 1 and a half are shared ownership 

– 1 is social housing 

According to Peabody’s figures, 71% of the flats facing the main road will be either at social rent or “affordable” shared ownership. 

So even according to the new proposal, the private flats have by far the best position on the site. This is clearly discriminatory.

An estimated 25,000 vehicles pass along Parkhurst Road every day. Therefore the affordable homes are still disproportionately exposed to higher noise and pollution levels, as discussed at the meeting. The acoustics advice is that opening a window in this location will lead to higher noise levels than are recommended. To avoid excessive noise and pollution the tenants are therefore more likely to shut their windows, which will lead to problems with air flow and heat control. Using cooling systems to control the higher temperatures will cost money and this will disproportionately impact social tenants who are on the lowest incomes.

Peabody claims that not having mixed tenure blocks is to do with service charges but has not provided any details – what exactly are the owners getting that the social tenants are not to demand a higher service charge? For example, if it is simply the quality of the fixtures and fittings in the apartments then why can this not be distributed according to floors rather than blocks?

At the beginning of the consultation, we were told that the site will be ‘pepper potted’ and Peabody at one point indicated that they would provide blocks with different tenure types of different floors. This would have been acceptable, with at least people living in different tenures sharing the same lifts and entrances. 

In research carried out in East Village in Stratford (formerly the Athletes’ Village), it was notable that people sharing the same blocks did mix, including via block-facebook sites and the shared residential housing. However, the Holloway site will be segregated.

We note that Peabody claims that they are delivering mostly family homes. Yet at another point they said that they  were mainly delivering 2 bed flats, with some 3 and some 4 bed flats.

Figure A: Design and access statement showing the tenure and the flat layouts

4.,5. and 6. Lack of Community Centre and indoor and outdoor amenities for young people, issues with the proposed Residents’ Lounge:

There is a clear link between the density of the site and the feasibility of providing sufficient community facilities that would encourage community cohesion within the new estate and with their neighbours.

Peabody has now provided a list of local community centres, where they say residents on the new site can access facilities. However, more than half of these are over ten minutes walk away, and frequently across busy roads. Of the centres on the list less than ten minutes away, one is a single room in a library and another is Islington Arts Factory; neither are community centres. We don’t believe that these other facilities would foster community cohesion on the site. What is required is a dedicated community centre for use on the site.  

The assertion was made that the £13.6 million community contribution to LBI will be used to upgrade existing community facilities rather than supply new community facilities on the site for the new community. CP4H supports investment in local community amenities. However, this does not address the needs of the 3000+ new residents who will be living on the site.

It has rightly been pointed out by councillors that there is no indoor provision for youth on the site. The single floor in Blocks C1 and C2, currently planned as the Womens’ Building, could be a Community/Commercial Hub with a focus on Youth. This Hub could house the creche, café, multi-purpose hall, bike hub, IT hub, hot desks, media centre and other much needed youth facilities. 

This would make for an excellent community facility that would make a great space for teenagers and adults and provide the indoor spaces the council is looking for. This is a chance to try something that could have a positive and measurable impact on the cohesion and long-term success of this huge new community.

CP4H has said that the Women’s Building should include community facilities to encourage re-integration for women who have experienced the Criminal Justice System back into the community and counter social stigmatising of those who have been in criminal justice.

CP4H welcomes the inclusion of girl-centred planning for the outdoor spaces but questions how much influence this has had on the plans as it has only now been mentioned.  

The Residents’ Lounge is designated by Peabody as not-for-profit. It is unclear to date which scenario of accessibility to public and private residents this will have. Will social housing tenants have to pay? See point below when Tom Williamson of Peabody informed us as recently as January that they would.

Islington Homes for All had a meeting with Peabody and Cllr Diarmaid Ward on 7th January 2022 when Peabody (Tom Williamson) told us that the Residents’ Lounge would be pay-as-you-go for social renters, whilst it would be included in the service charge for shared owners and private owners. Not-for-profit space is not the same as not charging money for a space or service. This is clearly discriminatory. 

They talked of exploring different “market options” for the lounge, indicating it is not a community space but envisaged as a commercial space. This means it is not an inclusive space easily accessible to the lowest income social renters, who will anyway be marked out as the only residents on pay-as-you-go. The siting of the facility in the private block is telling. 

Research carried out on the experiences of pioneer residents in East Village suggests this kind of commercial space could exacerbate divisions rather than heal them. In East Village many of the social renters struggle to access the retail facilities and many said they were unable to participate in the social interactions and community building occurring in these spaces. 

(This also has implications for the commercial spaces, which would best be affordable for local businesses and not selected according to their appeal to higher-income groups.)

7. Pedestrian and road access between neighbouring estates and the new development: 

CP4H also supports the councillors’ concerns with permeability / pedestrian and road access. 

The issue of permeability specifically with Bakersfield has been raised by the Bakersfield Residents Association. There is strong opposition to opening up the gate between Bakersfield and the new estate, especially among residents who have lived there for a long time. There is a lack of trust that Peabody, the council and NHHG will act in the interest of residents who have concerns about the social impact of an overdeveloped site on Bakersfield and potential use of the car parks by the new residents. These concerns are based on past and current experiences on Bakersfield and should not be dismissed. 

Trust has been further eroded by a complete lack of concern shown about the acknowledged effect on Bakersfield resulting from the overdeveloped design of the new estate. The residents feel it is also important to remember that Bakersfield is a private estate and that residents pay for security and parking controls through their rents and service charges.

8. The need to provide the London Living Rent model for the 18% “affordable homes”:

We disagree with Peabody’s statement on London Shared Ownership – these properties are not genuinely affordable in a high-value area such as LB Islington. Looking at an existing Peabody shared ownership property for sale on the Patchwork site, a 2-bed property with a minimum share of 25% requires a minimum household income of £67,546.00. This is around twice the median household income for non-owners in Islington, which, according to the London Borough of Islington Strategic Housing Market Assessment, 2017, is £31,500. 

CP4H have consistently said that shared ownership is not a product that will sell well at Holloway. Peabody suggests that they will wait for two years to see if the shared ownership units sell and if they don’t, then they will offer them up as London Living Rent (LLR) – the product that Sadiq Khan wants.

The first plan offered by Peabody included no LLR apartments. Such flats provide rents calculated with reference to average incomes, and would be more affordable for key workers and median incomes households in the borough. 

Peabody now states that:

“Nevertheless, the s106 agreement will include an early stage review, which will be triggered if substantial implementation is not reached within two years of planning consent. Should the early stage review generate a viability surplus, the s106 will require that the surplus is used to convert London Shared Ownership homes to London Living Rent.”

We believe it would be better to hedge against this and accept LLR from the start, especially as there are 14,000 people in desperate need of housing on the Council’s waiting list. 

Peabody now states: 

“London Living Rent is only an intermediate rent product for a short period of time, as residents can purchase their home on a London Shared Ownership basis at any time they wish, or Peabody can after 10 years.”

While LLR has large drawbacks, CP4H wants to stress that 10 years is a long period of time, which could make a huge difference in the lives of many residents. This is a fundamental benefit of LLR as it will allow some residents, perhaps with small children, to access stable homes at a critical point. 

Therefore the plan currently only has housing for people on the housing waiting list OR households with very high incomes, with no housing at all for those who do not have enough points to be on the waiting list but do not have a high enough income to access shared ownership. 

People with average and median incomes are being excluded from this area. As well as excluding key workers, this means the social mix is extremely polarised which is more likely to lead to issues with social division (especially given there is no community centre).  Do we really want a site without these median income households? With no teachers or nurses or single parents? No plumbers or office workers? Do we really want a site with huge socio-economic divides and nothing in between? Given that the Holloway prison site has received £49.864 million in two public grants and a £41.636 million loan from the Greater London Authority, we expect a higher proportion of genuinely affordable housing on the site – i.e. social rent or LLR – not shared ownership.

Section Two

Other key related issues raised by councillors and by objectors at the meeting:  

As stated, CP4H believes that the significant changes we outline below must be resolved for plans to go ahead. They are so fundamental that in order for them to be addressed, the plans must be rewritten. 

10. The detrimental impact of the new development on local residents living in neighbouring streets and estates: 

It was noted that during the Planning Committee meeting on 10 February that the Committee members overlooked several issues that were central to the nearly 200 objections (many representing dozens or even hundreds of residents) that were received after the application went public.

A principal concern raised by the public is the impact of the development on neighbouring properties. 

Noise and the impact of disturbance, overshadowing, overlooking, privacy, direct sunlight and daylight, over-dominance, sense of enclosure and outlook were all specifically mentioned in Local Plan policy.

The SPD (at paragraph 5.14) notes that ‘Given the site is bounded on three sides by residential accommodation it will be important that proposals for new development respect this context and provide a good level of amenity.’

Hundreds of local residents on 275 Camden Road, 2/4 Dalmeny Avenue, Kimble House, Dalmeny Avenue Estate, Trecastle Way, Penderyn Way, Bakersfield Estate, Crayford Road and the Holloway Estate will see material, BRE guidelines breaking, reductions in daylight and sunlight, often reducing further day- and sunlight for windows and rooms that already have below current design standards access to daylight and sunlights. It is not fair that residents’ existing poor sunlight and daylight levels should be used to justify the Proposal further reducing their light. On the contrary, residents with existing poor sunlight and daylight levels should be protected from further reduction.

We are concerned that this has been raised time and time again by local residents and did not receive any questions or comments from either Committee members or Applicant.

Building height has been raised by many of the objectors, but even though 9 out of 15 of the new proposed blocks will breach the 30 metre height indicated in the SPD as the maximum acceptable, no Committee members questioned or commented on the building height breach of planning policy.

The smallest of the 15 blocks proposed is 24 metres tall and the tallest block is 49.6 metres tall. The residents of Penderyn Way live only 19 metres away from the smallest block. 

This illustration shows what this will look like when completed.

Figure B: ALL other proposed new housing blocks are even taller, more overbearing, more overwhelming and in many instances  have even more impact in terms of loss of daylight and sunlight, in some instances leading to an 80% drop in VSC.

Paragraph 10.4.31 of the officer’s report states:

“Therefore, in its current form, the proposal needs to be considered as a departure from the

Local Plan. To be acceptable any such departure from Local Plan policy must be robustly

justified by other material considerations and would need to demonstrate overriding

planning benefits. While the scheme does not include any landmark very tall towers, the

large proportion of buildings higher than 30m and the amount to which they are higher than

the surrounding context, is a clear increase in scale which will change the character of the

area. The proposal is a marked move away from the typical lower rise character of some

residential areas in Islington which has been identified and long protected by the tall

buildings policies in Islington.”

Planning Committee members must consider, question and comment on the impact on the neighbouring properties. Planning Committee members should robustly justify to the local community why a departure away from planning policy outweighs their concerns.

Impact on local amenities, especially on health provision

At the planning meeting, the members mentioned a letter received from the local Health Clinical Commissioning Group about the lack of consultation about the level of health services needed for up to 3000 people eventually at the site. Residents are concerned that this issue has not been adequately addressed and want to know how the increased costs to health services by the new community will be met. 

11. Failure to meet environmental and policy requirements:

Addressing Islington’s Climate Emergency targets. The Council places considerable priority on reducing the impact of climate change and this requires that the development meet net zero carbon on site and embodied carbon emissions targets, higher environmental standards and LET requirements.

Climate Emergency targets. The plans do not address Islington’s 2030 net zero carbon targets, as confirmed in the planning department’s report (p. 162) in terms of net zero carbon on site and embodied carbon emissions, which are more than double the target. This concerns, for instance, heating demand, reuse of materials and energy generation. 

The development fails to ‘comply with Passivhaus and/or LETI requirements’ despite assurances from Peabody that it would meet high environmental standards. This was an opportunity for Peabody to improve its record in this regard and is also critical for Islington Council, given that it only scored 62% in the recent Climate Emergency research UK and is behind other London boroughs in its climate plans, especially in terms of mitigation and adaptation.

Complying with the Council’s environmental requirements: There are a range of environmental policies and requirements drawn up, which the development needs to comply with, including: a) in terms of density and tall buildings as set out in the SPD, Core Strategy and Capacity study; b) Islington’s biodiversity emergency plan; c) Islington’s Green Space policy; d) BRE minimum daylight requirements and recommended levels of annual sunlight for all flats; e) GLA design policy, regarding “dual aspect” design and ventilation of homes.

The SPD, Core Strategy and Capacity study set down clear necessities for the site, in particular in terms of density and tall buildings. The application fails to comply with these requirements, being well over 200 units above the preferred option, despite the need to do so following the Council’s successful court case in relation to the Territorial Army site development nearby. 

The Peabody plan is for 36%  above the maximum envisioned  by Islington Council. Most of the problems with, and objections to Peabody’s plan are the result of Peabody making a plan that exceeds the recommended limit of units.  Quality is heavily sacrificed for quantity and a dangerous message sent to developers.

Islington’s biodiversity emergency plan is undermined by overdevelopment of the site.

Islington’s green space policy is undersized by the equivalent of six and a half tennis courts

BRE minimum daylight requirements and recommended levels of annual sunlight are not met in many flats.

12. Compliance with design policy, especially regarding “dual aspect” design and ventilation of homes:

CP4H wants tenure blind design. Social tenants will bear the greatest cost for the design issues outlined below, both to their health and finances. The disproportionate impact of all these problems on social tenants is non-compliant with Council policy calling for equity between tenures. This is particularly concerning given over £90 million in public grants and loans that Peabody has received to ensure a suitable social rent housing delivery.

The design review report that was released with the Planning Officer’s report dated September 24th 2021 is the planning officer’s summary and not the actual letter that was sent to the applicant.  CP4H’s Environment & Architects working group has members with shared experience of chairing design review panels for over 15 years, and tell us that it is extremely surprising that there is no mention of overdevelopment, overheating or overshadowing.  

We have requested that copies of the five letters that were sent by the Design Review Panel to the Applicant (Peabody) be circulated to the community and to all members of the Planning Committee before the meeting on 8th March. We have also submitted a Freedom of Information request. We strongly believe the meeting should not take place without those letters being made available.

There are still problems relating to misinformation in Peabody’s application regarding the percentage of single-aspect apartments, which disproportionately impacts social tenants. In Figures B & C you can see what are termed “stepped/dual aspect” windows – similar to bay windows. However, these windows are not in fact dual-aspect when all the windows are located on only one side of the apartment. This would mean that the air flows across the stepped windows but not through the flat. Calculated properly, this means that 55% of the apartments in the current plan are in fact single aspect, subject to no air flow through the homes, which presents further risks of overheating. 

Due to the disproportionate number of social tenures that will be single-aspect this again means that those least able to afford it will have to pay more for cooling systems – and if they can’t afford it they will face the threat of serious health problems. 

The high proportion of single-aspect windows is non-compliant with Peabody’s 2018 Design Guide, Islington’s SPD and the Mayor’s Housing Design Quality guidance, which obligates all new buildings to be dual aspect though the majority of flats proposed, particularly those for social rent, are single aspect according to the Mayor’s own definition, presenting significant overheating and ventilation problems and costs. We question Peabody’s claim that referring to these windows as ‘dual aspect’ is approved by the GLA.

Flats that are not Dual-aspect (from the Design and Access Statement – p. 52)

Numbers provided by Peabody

Stepped aspect units  441

Single aspect units       60

Total units                       985

We do not believe that stepped access (triangular bay windows) creates a through flow of air and so we think they are single aspect. Which means 441 + 60 = 501 unit on site will have poor quality flow of air and lack of circulation. 501 out of 985 units will only face one direction and depending on where the flat sits could be either too cold or too hot. Future residents including market buyers should be advised as to this feature and made aware of it. Unfortunately, this feature cannot be addressed in future so will last the lifetime of the site.

Figure C: Design and access statement showing ‘stepped’ (misnamed ‘dual) aspect windows

Figure D: Design and access statement showing how air does not flow through the flats with ‘stepped’ (misnamed ‘dual) aspect windows

13. Problems with Peabody’s consultation:

Peabody’s presentation to the planning meeting came across as typical smoke and mirrors.

Many of the speakers against the proposals stressed Peabody’s failure to properly consult with them. It was noticeable that Peabody’s presentation did not answer the questions raised by objectors and by the councillors. The architects were never allowed to meet the community to respond to its questions and feedback despite our asking for over two years. This looks like a deliberate policy of obstruction.

The late addition of extensive documents from Peabody just 24 hours prior to the meeting on 10 Feb 2022 demonstrates a carelessness not worthy of this important legacy site. 

Questions about overheating or overshadowing have been dismissed with “We’ll tell you when we have done the calculations.” They would have done these calculations very early on in the process and yet they were only presented as part of their 447 page Design and Access statement. 

During the planning meeting, Peabody said they had consulted with neighbours and clearly described the impact on their homes. In fact, they held one last minute Zoom meeting with a single resident which included a very unclear description of the impact on daylight and overshadowing at the end of the meeting and no time for discussion. Local residents deserve more. 

The disdain shown to the community was nowhere clearer than at a meeting convened by Peabody with representatives of the community to present the application in November. About eight residents, all masked as it was at the height of the pandemic, were sat around a table outside in a marquee in freezing temperatures and faced with three men from Peabody, all unmasked, who proceeded to dismiss all the concerns expressed. Similarly, Peabody’s representatives were unable to answer questions asked by the Bakersfield Residents Association committee members around this time.

Peabody mentioned several ways in which the community has been informed about their plans, including the hoardings and the use of a marquee. But the banners were up on the hoardings for 3 days before they blew off in the wind and were never replaced. The Marquee was not prominent from the street. 

Figure E: The banners were up for only three days. 

Figure F: The Marquee was not prominent from the street 

Figure G: the Marquee

CP4H disputes that Peabody has responded to feedback from the community, including expert service providers. 

For example, in a presentation to Women’s Service Providers on 15 July 2021, hosted by LBI, Peabody showed slides that suggested that CP4H supported the plans and thought that they were “good” but CP4H have never supported the plans. Peabody later conceded that this was “a bit misleading.”

Women’s Building development 

Peabody says:

“We have worked closely with the local community, service providers and Officers to design a landmark Women’s Building that exceeds the requirements in the Women’s Building brief.”

Peabody has not meaningfully taken into consideration concerns and advice from the community, or from experts. It has persisted to work only to its 2020 Draft Brief, despite extensive feedback from the community since then. The following illustrations show that the plans have not substantially changed.

Figure H: Jan 2021 – Peabody’s original interpretation of the Draft brief for the Women’s Building.

Figures I + J: From Peabody’s July 2021 Presentation

Figure K: – The third illustration is where we put the Jan 2021 plans over the July 2021 ones to demonstrate how, although the whole site was overhauled, the Women’s Building only expanded slightly due to the expansion of Block C footprint

Figure L: October 2021 – Peabody’s updated plans for the Women’s Building – No floorplan.

Figure M + N: November 2021 – Submitted plans. These demonstrate that no fundamental changes have been applied to the Women’s Building, just some room reconfiguration with no reference or understanding of how the spaces will operate or what services will be delivered. 

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