Westminster City Plan Partial Review – Site Allocation, Land adjacent to Royal Oak station
Dear Planning Policy
This is the response of PRACT to your consultation on the site named:-
Land adjacent to Royal Oak station
PRACT is a consortium of these four recognised amenity societies: BRA, HPEA, PW&MVS and SEBRA.
Our response
Land adjacent to Royal Oak station
Contents
* A. Review of ownership and use of the land
* B. Comments on the present draft of the new policy 10
Pedestrian links and environmental conditions
Use of the land for waste transfer – needs full consutation
Other land owners
Maintaining landscaping and as much green open space as possible
* C. The part of the site east of Ranelagh Bridge
Some potential for affordable housing
* D. The part of the site west of Ranelagh Bridge
Not available for a future regional coach station
Difficulties of developing the western part of the Royal Oak site
Difficult public access
Difficulties of building there
Preferable to retain it as open space and to landscape it
* E. Conclusion
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1. This site has two parts, both of them north of the railway – the part west of Ranelagh Bridge going up to Lord Hills Bridge, and the part further east, from Westbourne Bridge going up to Ranelagh Bridge. Both parts are at rail level – well below the level of Harrow Road and that of the bridges. The two parts of the site differ – that to the west being open space in a narrow strip constrained by the width of Royal Oak station (with its staircase and island platform). The part east of Ranelagh Bridge has more useable space.
A. Review of ownership and use of the land
2. There appears to be doubt about this question. The land previously belonged, we understand, to Network Rail but use of it was handed over to TfL/Crossrail, to facilitate
construction of the tunnel leading from its portal towards the Elizabeth Line station beneath Eastbourne Terrace. Apparently this did not necessarily involve a change of ownership of the land. Thus, once this use was completed one would expect the use to revert to its owner Network Rail; but it appears that TfL claimed the right to use it (? rent free) when they put forward their proposal to erect a coach terminal on its western part, later dropped.
3. In discussions on this recent coach terminal proposal it was assumed that TfL owned the land rather than merely having an arrangement for use of it. However, we ask that this situation now be reviewed. It appears that there was nothing in the Crossrail Act on this question, but (I am advised) settling the exact layout was to follow after enactment, in 2008. Those details, including the location of the portal, vent shaft, Westbourne Park sidings and the bus garage, the new concrete mixing facility etc were, as I recall, all governed by subsequent applications within the Schedule 7 process, which was a parallel system to a normal planning application.
4. As I recall, the Schedule 7 applications # included some for landscaping etc which presumably can still be accessed on the planning application register. We request therefore that these documents be reviewed to see what light they throw upon the wider question of use of the land, as well as that whether there was any commitment for retaining the landscaping etc.
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# This footnote is at the end. It is about this site, as it was mentioned in an earlier planning brief, of 2009.
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5. We request that Westminster follow up with TfL these questions regarding both ownership of the land, and its use once construction of Crossrail was completed. It seems to us that there can be no question of development on the land if there is not agreement and clarity about such matters. Please keep us informed about these issues.
B. Comments on the present draft of the new policy 10
Pedestrian links and environmental conditions
6. We think that the difference between the two halves of the site should be explicitly recognised in the wording of the policy; access to the eastern part being easier than to the western part, especially for vehicles. And the second plan of the site incorrectly implies that direct access is possible from Lord Hill’s bridge to the low level of the site (‘Potential permeability improvements’). We believe that this is not possible, even on foot, unless – perhaps – as part of a major and very expensive reconstruction of the station, including a new footbridge leading from the station building and going across the track for eastbound trains on the Circle/H & C Lines.
7. There is a need for greatly improved pedestrian links need to take account of the entire surrounding area – not just movements through Paddington Central towards Paddington Basin and return.
8. The existing environmental conditions around the sites and affecting residential communities should be taken into account in any new proposals; and a reduction in environmental impact or harm should be central to any new proposed use.
Use of the site for waste transfer – needs full consultation
9. Any proposal concerning interim or permanent use for “waste transfer” surely should be part of some corporate City-wide waste strategy linked to contractual arrangements, and not just mentioned here almost as if an afterthought.
10. We object strongly to the supposition in point F that ‘meanwhile’ – meaning, we suppose, during an interim period before development could start – the site could be used for waste transfer. This would be severely damaging to the air quality of residents living on the southern side of the railway, amongst other likely damaging consequences for the local environment. Full consultation is needed on an apparently Ill-thought out idea, which would almost certainly be strongly resisted locally because of its damaging environmental effects.
11. And vehicular access would only be possible through a lengthy route through the basement area of Paddington Central, where the road layout was not designed for this purpose. Beyond Paddington Central, routes for lorries would need to be determined. Furthermore, a use of the site in temporary buildings for this purpose would become established and lead to pressure to include waste transfer as part of any permanent development on the site.
Other land owners
12. Any proposed future use needs to be carefully reviewed with the active cooperation of British Land as well as taking account of the infrastructure and operational safety requirements of Network Rail & TfL, in respect of the Hammersmith & City and Eliizabeth rail lines, and the elevated A40 Westway, for access to their structures.
13. We would be glad to be informed about the discussions you have had with TfL/NEtwork Rail about this site and these proposals. so that we and others could see and review their responses to this exercise.
Maintaining landscaping and as much green open space as possible
14. In the following sections we set out our reasons for maintaining landscaping and green open space, particularly in the western half of the site.
C. The part of the site east of Ranelagh Bridge
15. This is effectively the larger part of the site, still north of the railway. Access is problematic but less so than with the western part. Any development there, eg of affordable housing, should respect the building heights alongside the southern edge of the railway, in the section between the southern approaches to Westbourne and Ranelagh Bridges, buildings which are within the Bayswater Conservation Area. Higher buildings on the north side, immediately opposite, would fail to preserve or enhance the character of this Conservation Area on the southern side of the railway. (The same would go for the height of any new construction in the part of the Royal Oak site further to the west, which we think should not happen.)
16. The major problem remaining is how to improve access to this eastern part of the site, and at what level, or levels. It is difficult to envisage direct access to any building on this part of the site being at street level, and access to it, if only at rail level, that is through the lower parts of Paddington Central, would be cumbersome. Alternative access from the pedestrian crossing over Harrow Road, at its junction with Westbourne Terrace Road, might be made possible through new construction – requiring an amendment to current planning consents for this part of Paddington Central.
17. However, this eastern part of the site, between Ranelagh and Westbourne Bridges, does appear to offer some potential for development of affordable housing, if buildings higher than those on the southern side of the railway can be avoided.
D. The part of the site west of Ranelagh Bridge
Not available for a future regional coach station
18. We note that the site allocation assumes that all the land is available for development and would not be used for a coach station. We know however that parts of Victoria Coach station may have to be closed and therefore we do not rule out the possibility that in future TfL will be looking to establish smaller regional coach stations elsewhere. However, there would be many difficulties in using the Royal Oak site for this purpose, such as the considerable distance on foot between the area of the Royal Oak station and the Elizabeth Line station and other public transport at Paddington Station (and bad links there, between the H & C line platforms and the other public transport). These difficulties would also apply to any smaller coach terminal at Royal Oak.
19. We ask to be kept informed about TfL’s response to the present consultation on site allocations. It goes without saying that we would strongly resist any future proposal of theirs either to use the site for a smaller coach station, or to safeguard its current use as open space for unspecified reason future development by TfL in it.
Difficulties in developing this western part of the Royal Oak site.
20. We think that, for many reasons, the narrow western part of the site should remain as open space, with new landscaping, both because of the considerable difficulties of building on it, as listed below, and because of the positive environmental benefits of retaining it as green open
Difficulties of public access to this part of the site
21. There appears to be no access possible at street level at or near Lord Hill’s Bridge, where the eastern span of the bridge extends right up to the overhang of the southern edge of the elevated structure of the A40. Major reconstruction of the station would be necessary, please see our questioning in para 6 above of your diagrammatic ‘Potential permeability improvements’. Otherwise access to any new building would have to be at rail level, involving a long walk beneath Paddington Central all the way from its eastern edge on canal side, or a similar long drive through the basement of Paddington Central, where the road system has not been designed for such a purpose.
Difficulties of building there
22. The difficulties of building on this western section between Ranelagh and Lord Hill’s Bridges, which sits in a narrow trough on its northern edge, include the following:-
* providing light to the lower two storeys of any building there, which would be particularly difficult. Would the site provide a reasonable amount of affordable housing, given that its bottom two floors probably could not be used in this way, through lack of light?
* Space on Lord Hills Bridge, probably beneath the overhang of the A40, is also used by a dedicated cycle route, which runs along the northern edge of the site, at road level, connecting Westbourne Bridge and Harrow Road, in the outward north-westerly direction. (It ducks beneath Ranelagh Bridge and then regains street level at Lord Hills Bridge.) Currently, cyclists have to dismount, to cross the road at Lord Hills Bridge, but we understand there are plans to improve this.
* TfL have a policy of providing step free access to underground iistations, and any development at or near Royal Oak could strengthen the case for doing this at Royal Oak. This could well require a widening of the station’s island platform, thus further narrowing this part of the development site, lying north of the station. We think therefore that there should be ‘passive provision’ for a possible future need to widen the station’s platform and so to determine by how much there would be further narrowing of the space for building, and whether it is practical and viable to improve permeability on foot.
Preferable to retain it as open space and to landscape it
23. In such circumstances it seems to us that it is by far preferable to retain open space and to create greenery in this part of the site. While we would prefer to see public access to it, we note the difficulty that the only entrance to it is at its eastern end, at rail level beneath Ranelagh Bridge; thus there would be a long walk either from canalside east of Paddington Central, or perhaps as part of an improved public connection between Harrow Road and the lower parts of Paddington Central, situated just to the East of Westbourne Bridge. And similarly a long drive for a vehicle through the basement complex of Paddington Central.
24. We think that there would be positive environmental benefits of retaining it as green open space, which we understand to have been the original intention.
E. Conclusion
25. There has been considerable local concern about building on the western part of the site and we ask that special consideration be given to the amenity and health benefits of greening this part of the site; and we remain concerned about the unclear processes on determining, during and after Crossrail construction, changes in the previous use and ownership of the land — on which we seek further information.
26. Much further consideration is needed on the controversial suggestion of waste transfer on the site, and if it is progressed there should be full consultation.
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Footnote #, to paragraph 4
As detailed design of the Crossrail tunnels progressed, there was a process under Sch. 7 of the Crossrail Act of (effectively) planning applications to Westminster City Council, including for the land north of the railway tracks adjacent to Royal Oak station, and its eastwards extension up to Westbourne Bridge. These applications followed the same procedure as normal planning applications. For instance, to authorise a decision on the location and design of the tunnel portal.
A much earlier WCC planning brief of 2009 had a paragraph 5.37 about possibilities for the use of this land, after completion of Crossrail. This indicated that landscaping was the basic option, but indicated also sports facilities and structures for small businesses. All three evidently suffered from access difficulties and housing – not then mentioned – even more so.
End of PRACT response, 8 May 2024