by Julia Haythorn | May 10, 2017 | Environment
New consultation has emerged from Transport for London regarding central London Ultra Low Emissions Zone:
They would like to hear your views on proposals to:
- Introduce ULEZ (and the residents’ sunset period) 17 months earlier in central London
- Strengthen the emissions standard to also cover Particulate Matter (PM) emissions from diesel vehicles
Please take some time to fill in the online survey and provide your views:
The online survey, https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-2/?intcmp=47032,
It should only take 10 to 15 minutes. Please complete the survey before midnight on 25 June 2017.
Here is FitzWest Response
To Alex Williams
Director of City Planning
Transport for London
Dear Mr Williams,
Thank you for inviting the Fitzrovia West Neighbourhood Forum to provide views on the proposed changes to the Ultra Low Emissions Zone in central London (ULEZ)
We support the zone because we wish to rid ourselves of the polluted air we have to breathe every day in central London. We, who live and/or work here, know the niggling discomfort of ‘The London Cough’ which seems to effect all of us, which is never documented in pollution statistics. We are also aware of the needless deaths that occur from air pollution and that this level of air pollution is illegal under European Legislation. We trust that even though we may sever some ties with our European neighbours that will not mean that we relax our standards on air pollution.
Residents and businesses who own diesel vehicles:
The new proposals will have a financial impact to local residents with older diesel cars. We would be particularly concerned if central government proposals to introduce a diesel scrappage scheme do not come forward. If that were to be the case then we feel that TFL should introduce its own scrappage system for residents and small businesses within the ULEZ zone. We would support such a scheme even if it were means tested. There ought to be some low cost means of supporting residents and businesses of modest means to purchase a better vehicle for their personal use. We have a lot of elderly and disabled residents living in this area for whom a car is still important. Our small businesses are the life blood of the area.
Increasing need for private transport in central London:
In the light of bus service reductions in central London, (which we don’t support) the we must assume that resident car use will increase.
Need for Low Emissions Public Transport:
We trust that buses and taxis will also be subject to these stringent rules in central London and that TFL will lead by example, introducing zero emissions buses before long.
Emissions are not the full story:
While we support the reduction of exhaust emissions that does not contribute to any reduction in particulate matter, which we understand is caused by tire wear on uneven roads. What is being done about this? In addition we expect to see similar London wide planning legislation to reduce the use of carbon fuels like gas as a means of heating and air conditioning. The urban heat island effect is well documented as an added factor in central London, yet the ULEZ policies will do nothing to alleviate these problems. We understand that emissions from gas boilers constitutes about 35% of the NO2 in central London.
Pedestrians first:
The healthiest and lowest emission form of movement around central London is on foot, yet funding to improve pedestrian ways is very limited. Another way to improve air quality in central London is to encourage walking and cycling. We trust that wider TFL/GLA schemes are considering such improvements to complement planned reduction in polluting traffic.
Wendy Shillam
Chair FitzWest Neighbourhood Forum Executive
by Julia Haythorn | May 6, 2017 | Consultations
PEDESTRIANISATION OF OXFORD STREET
COPY OF RESPONSE FROM Fitzrovia West Neighbourhood Forum
I represent Fitzrovia West Neighbourhood Forum. Our forum is a 200 strong group that represents both residents and businesses in Fitzrovia. Our mailing list covers a further 500 small, medium and large businesses in the area. In our area both residents and businesses are united in wishing to improve the environment, making it a pleasant place to live work and visit.
We have already been in touch with Val Shawcross, officers from TFL and our local councillors to share our concerns for an unbridled pedestrianisation scheme that we feel would put far too much pressure on adjoining streets and communities.
We were gratified to learn that a simplistic approach was unlikely to be pursued and that any scheme that comes forward would consider the whole of the West End and not simply Oxford Street.
We support the careful consultation that TFL/WCC are establishing. Our chairman, Wendy Shillam and treasurer Yoram Blumann have been invited to attend meetings so that the views of local people and local businesses can be included in the work. However we recognise that these meetings are convened by Westminster’s PR department and we are concerned that consultation should continue to be just that – dialogue.
CONSULTATION RESPONSE
We have a number of concerns that we wish to raise:
- Phasing of the work – reducing the range of the modelling system
- Coordinating with neighbourhood plans and ambitions for the wider West End including:
a). Linking Oxford Street improvements to improvements in the Oxford Street hinterland,
b). Great Titchfield Street/Mortimer Street local hub and
c). Closing the Great Portland Street gyratory
- Impact on congestion and road safety
- Servicing the West End
- Impact on local movements (occasioned by reduction/redirection of buses)
- Pollution
A detailed response can be downloaded here:
170506 FITZWEST OXFORD STREET CONSULTATION RESPONSE
OUR IDEAS
We do not wish to be purely negative about the prospect of improvements to the West End. We would like to work more closely with your engineers and transport planners to achieve a better result. We feel that we have knowledge and ideas that could help. We truly hope that this consultation isn’t hiding a foregone conclusion and that genuine dialogue can occur before decisions are made. Thus we also include, at the end of our consultation response some ideas that we believe should be entertained.
LINK TO OXFORD STREET EXEMPLAR
CONSULTATION RESPONSE
- Phasing of works – reducing the range of the modelling system
Since the pedestrianisation was first announced, we now understand that it is to be made in two sections, from Orchard Street to Oxford Circus and then from Oxford Circus to Tottenham Court Road. We think phase 1 will adversely effect Fitzrovia, tending to push all vehicular access to this end of Oxford Street. We are also concerned that phase two might simply happen on the back of phase one, without the careful work that needs to be done to establish an integrated solution.
For example, we understand that no detailed junction traffic modelling for phase 1 will be done east of Portland Place and Regent Street. Thus, there will no way of knowing what the impact of phase 1 will be on major junctions in Fitzrovia or in Soho.
- Improvement of The Oxford Street Hinterland
One crucial aspect of our neighbourhood plan, triggered by strong public support, is to improve the streets where we live and work. There is no public green space in our area, little sitting-out space and hardly any pedestrian streets. We suffer from some of the worst pollution of any residential area in Europe. Pollution is influenced by traffic, by an intensity of carbon based heating and ventilation systems (we have a lot of development around here) and by the urban heat island effect, which intensifies pollution in the area and works to restrict the dissipation of bad air.
FitzWest Strategy Diagram – highlights certain streets and spaces to be traffic calmed, where we wish to see better pedestrian facilities, more green space and fewer traffic movements.
We support the intention to design for improved pedestrian access to side streets, but we are concerned that new bus routes, taxi routes and delivery routes will break the camel’s back. WQe have heard of no proposals to tackle these important issues:
- Deliveries
- Pedestrian movement
- Parking and Servicing
- Road safety
- Improving pedestrian crossings
- Cycle routes and cycle parking
So far FitzWest public consultation has strongly prioritised the greening of streets, the reduction and calming of traffic and the improvement of arrangements for pedestrians. We see three key areas:
a). The Oxford Street Hinterland – this is the zone of streets and alleyways between Market Place and East Castle Street and Oxford Street itself. Many of these streets have great potential to provide services that Oxford Street itself cannot offer, like cafes, smaller shops, sitting out space and services like banks, stationers and copy shops. But in order for these streets to become attractive they would need improving. We support a grid of pedestrian streets running off Oxford Street and we are prepared to supply the necessary detailed planning policy in order to allow such streets to thrive and take some of the pressure from Oxford Street itself.
b). As we move further north into Fitzrovia West we come to the Great Titchfield Street/Mortimer Street local hub. This is a critically important part of our area offering local shops and services to the businesses and residents around us. This has become a dynamic focus for local and specialist shops, small businesses and provides the area’s vitality. But it is already stymied by the fact that Mortimer Street is used as an emergency bus by-pass street for Oxford Street. We are very concerned that current plans for phase 1 will increase traffic in our streets and that a phase 2 would sign the death knell for Fitzrovia.
c). In addition we have identified the area around Great Portland Street Underground Station as one where improvements and traffic calming could be made. A lot of people live in this northern sector and there are two hospitals (Portland Hospital and The Royal Orthopedic Clinic) both of which require good pedestrian access)
We would hope that in deciding on new access streets for public transport and taxis something can be done to close down the Great Portland Street tube gyratory, thereby reducing the conflict between pedestrians and traffic turning south into Fitzrovia.
- Impact on congestion and road safety
Fitzrovia has a much higher population density than other parts of the West End. There are over 4000 people living in very dense flats in FitzWest alone. We understand this represents approximately half of the population of the West End Our population is not dominated by West End Wealthy, but by ordinary people, many of whom have lived in the area for years, whose children attend the local schools and who work in local businesses. Many people live in social housing, or housing for the elderly. They cannot choose to move out of the area if it becomes even more devastated by traffic and pollution.
This week’s announcement that pedestrianisation in Oxford Street shall go ahead leads us to fear the implications for our area, especially Mortimer Street and Newman Street. While the cross rail project has gone ahead we have had several long term bus diversions through our area, along Mortimer and Newman Street. This has resulted in lines of jammed busses belching out exhaust. I enclose a photograph of Newman Street, taken during one of those diversions, to indicate how unpleasant those short term diversions were
If the pedestrianisation of Oxford Street results in a permanent diversion of taxis, delivery vehicles and bus routes along these streets it would be devastating for the area.
- Servicing the West End
There is a growing problem in this area associated with deliveries, development vehicles, servicing, rubbish collection and public transport. For example rubbish collections have collapsed, the amount of uncontrolled rubbish bags and dumped rubbish has become embarrassing. If we are also to suffer more service traffic the continual degradation of our pavements will be exacerbated. Despite this our streets are already choked with rubbish collection vehicles, white vans, motorcycle messengers and cycle delivery. This is all completely unmanaged and unplanned. Night time deliveries are not the answer in our area because of the prevalence of residential buildings right down to the boundary of Oxford Street.
- Impact on local movements (occasioned by reduction/redirection of buses)
Despite many of us who complained about the proposed reduction in bus services, especially the C2, these have gone ahead, unaltered. Further pedestrianisation will further reduce bus services. Cross rail does NOT take the place of local cross West End trips. We do not support the reduction of bus services in the West End. People who live and work here use buses to get about the West End. We use the bus to do our food shopping, to take our children to the doctors and to hospital appointments, to go to work and to visit our Council Offices on Victoria Street. We need hop-on, hop-off services which cannot be supplied by tube or Crossrail. Tourists need this even more than locals.
We have a high proportion of elderly and disabled people living round here and they cannot use the underground so easily (if at all). Local bus services are equally important for visitors to the area. No-one in their right minds would entertain a journey for example from Tottenham Court Road to John Lewis by underground. So we need some form of local bus system along Oxford Street.
We support the hopper fares and we support the intention to electrify (de-carbonise) Central London buses and taxis.
- Pollution
We think a diffuse public transport system could work very well, as long as buses are smaller and less polluting (which means changing engines and wheel formats to reduce both NO2 and particulate pollution.) Trams, guided by rails are, we understand less likely to cause accidents – pedestrians know where they are! A light rail system running from one end of Oxford Street to the other – running along Oxford Street is the no-brainer solution. For public transport to work it must be able to deliver passengers closer to the destination than they can travel by private car. By pushing the busses out and by reducing their number the effect would be counterproductive. It would mean that a visit to the West End would become more convenient by private car – not less so! This is especially true as the Congestion Charge (and parking fees) do not apply on late night shopping nights, or throughout the weekends. Thus during late nights and on Sundays there is nothing limiting private car trips into the West End, for shopping or any other function.
Unfortunately it is not just Oxford Street that subjects the population of Fitzrovia to life threatening pollution. The diagram below (taken from the Kings College Model commissioned, as I understand it, by the GLA) identifies Mortimer Street and New Cavendish Street as highly polluted as well. This pollution is exacerbated in the centre of London because of the urban heat island effect, which can trap a bubble of polluted air, stopping it dissipating, as it might do in greener parts of the capital. I am sure that enlightened traffic engineers in the GLA have already considered these limitations and are proposing alternatives. For example a bus hub at Tottenham Court Road and a further hub at Hyde Park Corner would be well supported by our community. (As long as there is some way of getting to them)
We are especially concerend that All Soul’s Primary School, our excellent local primary school, which lies only yards from the Mortimer Street/Newman Street junction. The prospect of diverting transport onto a minor road and increasing pollution levels so close to an area where children are taught, is not worthy of the new GLA administration.
by Julia Haythorn | Mar 31, 2017 | Consultations, Environment, Our Neighbourhood
Westminster City Council has launched a wide-ranging public consultation to identify the best way forward to manage the future growth of Westminster entitled, ‘Building height: Getting the right kind of growth for Westminster is seeking the views of all those that live, work and visit the City.’
The feedback received during the course of the consultation, which will run for eight weeks, will help inform Westminster City Council’s future plans for the City which will be set out during the statutory consultation on the City Plan later this year. As part of this consultation there will be a series of public events taking place across the City.
There is a questionnaire on the internet which we encourage members and friends to complete.
Here is FitzWest response to the consultation:
Dear Sirs,
Thank you for giving us the opportunity to respond to your consultation regarding building heights. We welcome the fact that you publish a wide ranging consultation before bringing out a draft policy.
- We do not think that Fitzrovia, in fact any part of the Central Activities Zone, can or should be expected to support major growth in heights or bulk.
- We consider it a fallacy to suggest that economic growth goes hand in hand with increased density and/or height.
- In fact we consider the opposite is true – that small businesses are the life-blood of the central London economy and would only be damaged by whole scale redevelopment or intensification.
- We should seek an intensification of quality not quantity.
- We should respect the height, scale and massing of the conservation areas.
- We should respect the amenity and qualities of living that current business and residents possess. It should not be made worse by bulky overshadowing buildings.
- That the complexity of servicing and managing such diverse uses as exist here is already beyond the capacity of Westminster City Council (in their current economic travails) and that no intensification should be considered, because it is not serviceable.
- That high rise buildings are not environmentally sustainable.
The premise that growth and tall buildings are one and the same
Economic growth is often equated to growth in construction or density. Yet in the centre of a capital city there is no evidence to suggest that this is so. In fact cities like Bangkok, that have undergone uncontrolled growth in recent years, have seen a dramatic fall in economic activity as environmental quality has plummeted. What happens is that instead of the city thriving, it starts to die. People decide to re-locate to greener and more pleasant suburbs.(i)
Westminster, being located almost entirely in the Central Activities Zone, should not be seen as a place for construction growth, but instead as a place for economic growth. Economic growth will not occur if Westminster becomes overcrowded with unnecessarily tall and over-bulky buildings.
Pollution in Bangkok Source Bangkokscoop.com
Function of the Central Activities Zone (CAZ) and its Core
The Core CAZ, in general and Fitzrovia in particular, are areas of extraordinary diversity. Planning policy tends to have seen the Core CAZ as simply a retail hub. It is not now and given the rise in internet shopping, it is unlikely to become so in the foreseeable future.
It is this diversity that contributes to the economic dynamism of The City of Westminster and to London as a whole. The diversity includes institutions, educational establishments, smaller offices, hi-tech businesses, residential, specialist retail and cafes. Most of these uses would leave if the area were redeveloped to a larger scale.
Westminster’s own study (ii) indicate that a majority of Westminster’s businesses are small businesses, with 85% of VAT registered businesses having less than ten employees (IDBR, 2010). These small businesses are the life-blood of Fitzrovia.
The Centre for Cities states in a recent report;
Small firms trading with other firms in London, nationally and internationally (small B2B firms), are concentrated in two areas: London’s core and to the west, near Heathrow and national motorway links. These firms account for just 18 per cent of all London’s small firms but have the greatest potential to make a significant contribution to future jobs growth. (iii)
A growth policy should be aimed at retaining and supporting this cohort of small businesses. They do not require tall buildings, or large floor-plates. In fact, such businesses rarely locate to new buildings, which they cannot afford. They are far more likely to seek space within the buildings that Fitzrovia already possesses. They locate to be near one-another – so redevelopment has a negative effect in forcing out small business and bringing into the area larger, less economically dynamic business.
In most cities large floor-plate and high rise offices are located on the outskirts and useful transport hubs. Compare Montparnasse in Paris and Paddington in Westminster.
Tottenham Court Road (within Westminster and within Fitzrovia) is not a tabula rasa. Its is not a blank canvas onto which high-rise can or should be foisted. It is in fact one of the most historic parts of the City of Westminster, being very ancient indeed and thus should be a candidate for conservation, not annihilation.
Housing in Fitzrovia
There may be some individual sites, on the boundaries of Fitzrovia where higher rise housing is relevant and can be built to redress the gathering imbalance of housing types and tenures in our city centre. We have identified sites in our emerging Neighbourhood Plan. But because there is densely packed housing here already the capacity of sites to come forward that would not overshadow and over-bear existing dwelling is extremely limited.
The population of Westminster is said by Westminster City Council to have been underestimated at the last census by 10%. It is not satisfactory to say (as has been argued in recent planning applications) that people who live in the centre of a city should put up with increasing density, even if their habitable windows are obliterated from daylight.
Conservation Areas
The majority of Fitzrovia West (and in fact the whole of the central core) is located within a series of conservation areas. It already has a very high residential population, made higher by the inclusion of a very rich mix of activities. The general building height of 60ft in residential buildings and 80ft in ‘factories’, which comes from the London Building Acts of the 1880s and 90s, is still valid in this area and should not be compromised.
View across the rooftops of Great Titchfield Street looking towards Soho and Mayfair. The consistency of roof-line is remarkable.
Most historic urban centres have a cap to heights. Oxford is one example. Paris is another. Westminster should have its own height cap. This should not be seen as a restriction to growth, but in fact one of the reasons why the historic centre will always be more attractive than the outskirts. Dynamic, highly profitable, discerning businesses wish to locate here.
Access
The perceived wisdom is that areas of high public transport provision should be the location of high-rise. That is how Centre Point received planning permission originally. But in Central London that logic is wrong. It is a fallacy, because it assumes that there is capacity on the ground already. But in Central London we would question whether the imminent improvements in public transport are not simply running to catch up. That the new Cross Rail stations, balanced by reduction in private car trips and bus services may only just cover the current needs, let alone natural growth. What evidence do we have that such systems will have capacity to support major growth in residential or working populations in the centre?
In addition there is already a lack of cycle parking and disabled parking. How could large intensive uses occasioned by high rise be supported unless there was large areas of cycle parking and disabled parking around them?
The Servicing of Taller Buildings
The consultation paper does not consider the servicing of taller buildings. The centre of Westminster can not cope with the servicing it already has. Rubbish collection, deliveries and street cleaning have all failed in this area. The level of vermin and mess is embarrassing.
Servicing of tall buildings requires far more hinterland and larger carriageways than is possible in Fitzrovia. It requires large service bays and a regular stream of heavy vehicles. We do not think it is appropriate in central London and in Fitzrovia in particular where the densities are already extremely high.
Emergency Servicing
Since the Kings Cross disaster, when the fire brigade is called in Fitzrovia, regardless of the scale of the fire, four fire engines turn up, from two different locations. That is because of the impossibility of ensuring a traffic free access for emergency vehicles. Yet the potential for emergency access to larger buildings is never considered in planning policy. It is taken for granted that the city can cope. We don’t think that Fitzrovia (or other parts of the core CAZ) can cope. Any further increase in the critical mass of servicing in this part of the centre of London is not sustainable. This has impacts on the pleasantness of our streets but in these times of terrorism could contribute to a major disaster if left unresolved.
Environmentally Sustainability
High rise buildings are expensive to heat, cool and service. They use powered systems that are alien to the essentially Georgian structure of our current city, that does not need gas guzzling, air conditioning or complex heating systems. Any increase in carbon emissions or heat supply from building exhausts will turn an already polluted area into a danger zone. Unless a large building can show a reduction in such impacts it should not be considered.
Greening
There is a suggestion that a few extra floors on any building might be tolerable. But we would maintain that the flat rooves of many of the buildings in this area should be used as amenity space. That means planted and accessible roofs. Modest increases may be acceptable if such an increase provides much needed public or semi-public amenity space.
i) ‘The increasing density of population (due to population growth and migration) and disorderly urban settlements and together with the rapid economic development have brought an exceeding demand of infrastructure, public utilities and public services, which is unfortunately beyond the capacity of the Bangkok Metropolitan Administration (BMA), the city administration of Bangkok, to handle alone. This results in the deterioration of urban environment, urban services and also urban quality of life.’ Report by Suganya Boonprasirt, Policy and Planning Department, Bangkok Metropolitan Administration, City Hall of Bangkok Metropolis. http://www.gef.or.jp/20club/E/bangkok.htm
ii) Westminster’s Economy Developing Westminster’s City Plan, file:///C:/Users/Wendy%20Shillam/Downloads/westminster’s%20economy%20CM%20Version1.pdf
iii) The Centre for Cities, Size matters: The importance of small firms in London’s economy Rachel Smith, Dmitry Sivaev and Paul Swinney December 2012 ize matters: The importance of small firms in London’s economy Rachel Smith, Dmitry Sivaev and Paul Swinney December
by Julia Haythorn | Mar 13, 2017 | Archive
ARCHIVE
Press Release:
We are pleased to announce that a draft of the Fitzrovia West Neighbourhood Plan has been published today. Deadline for comments 30 April 2017
Wendy Shillam, Chair of the Executive Committee says,
‘We have worked very hard to get together a coherent document, that addresses the issues discussed in our consultation meetings and the exhibition we held last year. We have tried to reflect diverse and sometimes contradictory views, balancing different visions where necessary. Now it is time for the community, our residents, those who visit, run businesses and work in the area to tell us whether we have the correct balance.
At the back of our minds, as we wrote policies was the prospect of increased access to our area from Crossrail 1 and 2 and HS2, all of which will bring further pressure of development to our area. This wealth of excellent public transport can be seen as a blessing, but also a challenge.
We’d like to thank everyone who has contributed to this document so far. It is the work of more than one person, so please point out any inconsistencies that you find. It is not yet ready for formal presentation to Westminster City Council. Over the next few weeks we wish to hold informal discussions with the Forum, the Council, our Ward Members, officers and Portfolio Holders. We also wish to update GLA and other stakeholders who may wish to make comment. In addition we are now working with the other four West End Neighborhoods in order to rationalise some policies, where we have very similar objectives.’
Nothing in the plan is cast in stone. We’d like people to go to the comment page on the website that will allow your views to be made public. Alternatively contact us directly at info@fitzwest.org
Deadline for comments 30 April 2017
by Julia Haythorn | Jan 13, 2017 | Consultations
RECEIVED TODAY FROM WESTMINSTER CITY COUNCIL
WSP | Parsons Brinckerhoff is the agent acting on behalf of Westminster City Council for a traffic management scheme affecting Berwick Street. In accordance with the consultation procedure, we would draw your attention to the effects of the proposed Traffic Orders of which further details are given in the enclosed documents: showing the existing and proposed layouts; and information regarding single and double yellow lines. WSP | Parsons Brinckerhoff would be pleased to receive any observations or comments you may wish to make on the proposals, in writing, by 3 rd February 2017, quoting the reference 7185/LH in any response.
At the end of the consultation period, all responses received by this date will be forwarded to the City Council for consideration. The City Council will then decide whether to proceed with, modify, or abandon the proposals. The City Council is keen that you discuss your kerbside delivery needs with your delivery and courier companies to ensure that their needs are fully understood and conveyed to the City Council when you respond to this consultation. Also if your business regularly receives guests from taxis, private hire vehicles and coaches, then please also advise us of this information in your response.
A public drop-in session, where you will be able to view plans and ask questions about this consultation or the scheme in general, will be held in the upstairs room at The Blue Posts, 22 Berwick Street, London, W1F 0QA on Thursday, 26th January 2017 between 2.00 p.m. and 4.00 p.m. and between 5.30 p.m. and 7.30 p.m. If you should require any further information please contact me on (020) 3116 5996.
Laura Harris WSP/Parsons Brinckerhoff
Link to PDF Berwick Street North Consultation Documents
