18 Reasons This Turkey Should Never Fly

Gobble Gobble

It's nearly Christmas and candles are burning late into the night at the planning offices of Islington and the City, as the officers sharpen their quill pens writing up the reports for the planning committees on the enormous Christmas turkey that is the RCS Tower.

We think the design is a mistake and there is a better way. So do SAVE, the C20th Society, The Islington Design Review Panel, John Allen (who wrote the listed building guidelines for Golden Lane), our MP, 1400 signatories to the petition online and on paper and 135 local residents who wrote in to register their detailed objections.

If you have not written in, it is still possible to do so up to the date of the planning Committee, which will probably be in January. Here are 18 reasons this scheme is unsupportable, even after six months of tweaking it:

Ready for Take Off?

Strange Nimbys

If you stand up to any kind of development, you had better be prepared for the "N" word to be flung in your direction sooner or later. Its usually the developers who complain, but it was Common Councillman Mark Boleat, who sits on the planning committee, who did the honours this time. He would like to "reign in" selfish middle-class Nimbys.

But its a strange kind of Nimby that wants more social housing and development built on a site than the developers propose; in fact it has been christened the Yimby movement. GLERA has brought forward alternative plans for the former Richard Cloudesley School site that skip the single-staircase residential tower and propose a low-rise developement instead. The interesting part is that this approach, which follows the general layout of the Golden Lane Estate and doesn't seem to break every planning policy known to man actually allows 15% more social housing on the site. The build cost is dramatically reduced by not building high rise. Who knew?

It is achieved by integrating the school and the housing. This pattern was followed at the successful Kings Cross Academy and is probably the future for schools in London.

Anyway we think its really strange to be elected as a common councilman and then tell local residents that they shouldn't have a voice in the planning process. Here is the full text of our open letter to Sir Mark:

"Sir Mark Boleat has a vision for housing in London. It just doesn’t happen to involve anyone who actually lives here. (London’s housing crisis can be solved by reining in middle-class nimbys, Evening Standard, 18th October). He would like to see local communities and their councillors excised completely from the planning process. As chair of one of those pesky City of London residents’ groups he scorns in his remarks, I have seen the future he envisages for London close up. 

His team plans to extend our Estate with a social housing scheme two and a half times the maximum density and three times the height that planning policy permits, with no outdoor space, no playground and a tower block with a Grenfell-style single escape staircase. As local residents we stand up for getting decent, good quality social housing on the site, not repeating the disastrous mistakes of the 1960’s.  

Of course these new social housing voters will be strategically placed in Islington, just a few feet outside the City boundary. After all, Sir Mark’s policy is for housing, yes, just not in his backyard. 

It was local “nimbys” who campaigned against  the absence of affordable housing at The Denizen, Taylor Wimpey’s overbearing development. In the end their in-lieu payment provided 14 affordable homes. If planning guidelines had been followed then TW would have been supplying  66 affordable homes off site.  

Weakening planning rules creates opportunities for developers and house builders. Sir Mark’s networking/lobby group, the loftily titled  “Housing and Finance Institute” brings them together with financiers and local authorities, as they put it “building relationships between capable councils, businesses and investors who want to do more”. 

If Sir Mark has so little time for the role of local Councillors in standing up to development plans that bulldoze planning policies and communities then perhaps it is time he resigned from the City of London planning committee and focussed on those important housing industry partnerships instead."

Charles Humphries,  Golden Lane Estate Residents Association 

Sorry to Hear That

Aaagh not another dodgy report?

The RCS noise report that accompanies the planning application looks pretty technical, so we asked a helpful acoustic expert (HAE) to cast an eye over it:

GLERA: You've read through the report, it seems to say that the school playground won't cause any disturbance for residents.

HAE: Hmmm...

GLERA: Hmmm what? Is there something we should know?

HAE: It estimates that the nearest sound receptors are “about 25m to the South”. In fact Basterfield house windows are 8.8m away from the playground.

GLERA: And that's important because?

HAE: Distance is the main form of attenuation of the noise from the playground - perimeter fencing won't have any effect for the first floor windows and above - its line of sight.

The assessment levels they have used are not correct (table 8.1). By definition,  the levels in policy (LOAEL/SOAEL) are absolute levels and not variable.

GLERA: They make the following assumption from similar playgrounds: "At the edge of an external play area with a similar number of pupils, noise level was found to be around 75 dB LAeq,1h."  Is this realistic?

HAE: Yep. Now ask about Ambient Noise.

GLERA: What about Ambient Noise? That's the background level at our windows now right?

HAE: Yes, The report assumes the Typical Ambient Noise Level (LAeq,9h) to the South is 65dB, which seems unlikely. Their own survey within the Estate boundary gave readings of between 50 and 54 dB (Table 4.3) No acoustic survey was undertaken to the South of the site (Basterfield) which is the most directly affected, but it most closely resembles the location to the West.

GLERA: How do we check?

HAE: Here, borrow one our sound meters. Check the background noise at different times of day

GLERA: Anything else?

HAE: Give it back when you're done.

We checked the typical (Ambient) noise levels at Basterfield House. they hovered around 50-55 decibels in the mornings, went down slightly in the afternoons. Here's what we found out:


RCS Noise Report 2 from Charles Humphries on Vimeo.

Don't Let the Sun go Down on Me

The developers of the RCS site have submitted a daylighting report prepared by Anstey Horne. To go by the Executive Summary it would appear that nothing is amiss:

"Considering the proposals as a whole we believe that the daylight, sunlight and overshadowing results for the scheme as designed are good given the city centre location"

But this disguises the true situation.  For example the bedroom of Flat 1, Basterfield House will have the Vertical Sky Component (That's your view of the sky) reduced to less than 50% of existing. Worse, the kitchen of Flat 12 will be reduced to 40% of its current VSC. BRE guidelines state that a reduction beneath 80% is likely to be noticeable, so these effects are likely to be highly significant.

The situation is obscured by the way that Anstey Horne have tabulated the results. The loss of daylight to each window is expressed using a random code number. So it is necessary to go to a set of abstract plans inserted at the back of the document to find out that, for example, F00, R7,W7 is the kitchen of my flat at Basterfield House. There is no need for this obfuscation – it would be perfectly possible to annotate the table so that it shows the address. So far I have yet to meet anyone on the estate (other than architects and even then...) who understands how to interpret the tables and diagrams.

So is it just one or two flats that are affected? I counted the number of windows where the VSC will reduce to less than 80% of existing (and breach BRE guidelines). Of the windows measured a total of 122 windows are losing more than the BRE guidelines.  Some rooms are losing 60-70% of their access to natural light.

My own kitchen at Basterfield House is losing 48% of its natural light. (In case you cared)

Sorry seems to be the hardest word

Anstey Horne immediately proceed to try and establish wiggle room. The BRE guidelines should be “flexibly interpreted”. Lets take a look at how Anstey Horne wiggle.

Candle in the Wind - its so BRIGHT in here

1. The existing site is very open and we enjoy an unusual amount of daylight for London. Anstey Horne do not provide any justification for this; for example by measuring the actual light levels. The existing RCS site is two storey and clearly does not block the same amount of light as a 14 storey tower.  However the existing site was designed with due regard to the pattern of urban design established by  Chamberlin, Powell and Bon which sets the residential blocks East-West with open space to the North and South to allow light to penetrate the relatively deep plan. This gives the lie to the next argument that Anstey Horne adduce:

Rocket Man - you look familiar

2. If you were to build an imaginary mirror image of Basterfield House immediately on the other side of the access mews it would be more impactful on daylight levels than the CoLPAI proposals. Whilst perfectly true, this argument is meaningless and is used inappropriately. The access mews is not a public highway and was never designed as such. The proposal has been described by the developers as an “An Extension to the Golden Lane Estate”. There is no imaginary boundary that can be used for this purpose –  and the use of Appendix F of the BRE report is inappropriate in this case. The extension to the Estate needs to be designed with due regard to the existing buildings and following the urban pattern established by the original architects.

Can you Feel the Love Tonight?  No, I said Transgressions and I meant it.

3. These reductions are inevitable given that they currently face a low-rise site, and any meaningful development will result in BRE transgressions . 
This argument ignores the fact that the principal transgressor is the residential tower. There are several alternative schemes that have been brought forward that have development on the scale and density of the existing estate and that do not involve a residential tower. It would be more truthful to say that any over-development will result in BRE transgressions.

If There's a God in Heaven (What's he Waiting For?)

4. The majority of rooms that face the development are kitchens and bedrooms, which are considered to be less important than living rooms for daylight and sunlight.  
This is an “interpretation” of the BRE guidance, which in fact says that “sunlight is viewed as less important in bedrooms and kitchens where people prefer it in the morning rather than the afternoon”  It makes no mention of daylight in this connection and misses the point that the tower, being situated to the East of Basterfield House will rob daylight and sunlight precisely in the mornings, when people prefer it in the kitchen and bedrooms.

A Town Called Jubilee. Did someone mention a balcony?

5. The most sensitive neighbouring windows are effectively self – obstructing due to their own design, namely projecting balconies and bays. In other words, contrary to the assertion in (1) above, the affected windows already receive rather less light than they might expect. Anstey Horne go to the trouble of making all the calculations with a re-design of the Grade II and II* listed Golden Lane Estate Blocks, removing the access balconies.

They needn’t have wasted their time; It turns out that the  new tower still blocks so much light to the kitchens that they still fail to meet BRE guidelines even after Anstey Horne’s  imaginative architectural redesign.

Of course there are no “projecting bays” (They are confused with the South Elevations) and the bedroom windows are in fact flush with the face of the balconies, so there is no effect on those.

Don't Go Breaking my Heart

The fact is that no amount of wiggling can conceal that the proposed CoLPAI tower blocks extraordinary, excessive amounts of light from Basterfield House, Hatfield House, Banner Street and even the Community Centre, where one window apparently loses 79% of its natural light.

This is not a question of fine judgment,  of a balance of good and necessary evil, or of a small change that won’t be noticeable. This is a massive and permanent change to the character and quality of a large number of homes.

Public Meetings Blast RCS Scheme

Two Public Meetings held at the Golden Lane Estate following the submission of the Planning Application for the RCS site have heard how the proposed scheme will impact life on Golden Lane and provide poor quality social housing.

GLERA Meeting at Community Centre 31/8/17

Too Much Stuff

Extraordinary as it may seem Islington and the City of London have brought forward a scheme that breaches their own planning policies on Height, Density, Access to Nature and Playspace. Even policies such as Cycling Provision, Disabled Parking and Refuse Collection are breached. When challenged the planning consultants point to the "constrained" nature of the site. Which is another way of saying that they have stuffed far too much onto the site.

Is that it?

It would be bad enough if that was it. But the height and density give rise to all sorts of other problems for residents on Golden Lane and Banner Street such as excessive noise, overshadowing, traffic congestion. The planning application tries hard to make light of these effects, but as the meeting heard - is unconvincing as soon as you drill down into the details. The noise report submitted was littered with errors, saying for example that the school playground was "about 25m away from the nearest residential receptors". In fact Basterfield House is less than 9m away.

Link to give your comments and views on the scheme:

Islington Planning Website

City of London Planning Website

Densely Does It

Why do we keep saying that the RCS proposals are too dense? Surely we are in a housing crisis and  the more social housing units on the site the better?

Slum housing in Islington,  1909

Let's start by looking at some context. Golden Lane Estate was designed at the height of the post-war housing crisis when it was estimated that 750,000 new homes were required in England and Wales to provide all families with accommodation. Against this desperate need an ambitious target of 200 Residents per Acre was set and the architects worked hard to achieve this number. The original design had low blocks arranged around open courts, but the architects felt that in the original competition scheme, the buildings were too large for the courts. By raising the height of Great Arthur House they were able to provide better amenity space around the blocks.

The competition scheme was given more open space by introducing the tower

These days we measure density in terms of residential units per hectare (u/ha), and in these terms with 558 units arranged over 2.8 hectares Golden Lane Estate achieved a density of 200u/ha.

That was then. How does that density relate to our modern standards? In the planning policy maze, guidance on strategic matters such as density is the responsibility of the Mayor of London and the GLA. The Mayor publishes his standards in a document called The London Plan, which gives a matrix of density, thought to be sustainable throughout London.

For a central London site with very good access to Public Transport, the target range is 140-405 u/ha. In fact, with 66 units on a site area of 0.06 hectares the density of the RCS tower will be 1100u/ha. This is nearly three times the maximum limit in the London Plan and five times the density of the rest of the Estate. So if you have been looking at the plans wondering how the scale relates to Golden Lane; maybe that is why - it just doesn't.

Wiggle, wiggle

The London Plan gives some wiggle room. It says that the policy ought not be applied "mechanistically", and this sends the developers of the RCS tower into a frenzy of wiggling. "The density ranges should be considered as a starting point rather than an absolute rule when determining the optimum housing potential of a particular site".  They go on to argue that, if they don't meet the standard; there should be some flexibility if the housing meets very high standards in other ways.

We are pretty sure the "wiggle room" was meant to be a factor of 10 or 20% above the maximum, rather than the full on, blow-it-out-of-the-water 270% of the maximum, but lets look at the factors which might allow some departure from the standards in the first place.

Local context, design and transport capacity are particularly important, as well as social infrastructure, open space and play.

The access to public transport is good, but that is already accounted for in the table. What about local amenities and services? There is no evidence in the application that the developers have even tried to assess local facilities. With multiple recent closures of GP practices in Islington and patients being bounced from one practice to the next, the MP for Islington South and  Finsbury, Emily Thornberry, has called the situation a “mess”. The excellent report into the Whitecross Street Estate by Peabody Tenants' Association found that there were few local amenities for young people and "the park gets so overcrowded in summer there’s literally no space to move, and the bins overflow." 

 What do you mean you want to sit down? Fortune Street Park.

Pay to Play?

Islington earmarked the RCS site for Public Open Space in the Finsbury Plan, (See our previous blog), but none is to be provided in this proposal. What about play provision? Well the proposal has literally no external amenity space for the residents other than the balconies of the flats. They are supposed to provide 430sqm of play space for children on site and will be providing zero. Rather desperately they suggest that the children living in the Tower could use the School Hall to play in, but presumably they will have to pay the rental fees to do so. It seems unlikely that this will happen. And what is the reason for this lack of provision? "The Site is heavily constrained in terms of the available area for children play space that can be provided on site. " Well quite.

They go on to claim that the standard of the flats is so high that this counterbalances the incredible density. They are much larger, for example than usual.

In fact, most of the the flats exceed the bare minimum space standards by just 1 square metre and the combination of old fashioned deck access, lack of amenity space, lack of disabled parking, compromises on fire safety and substandard cycle provision make the claim of "outstanding quality" hard to understand.

Or maybe we are just being dense?