How to respond to Islington’s Pavilion proposal: Before Sunday 31st March!
Islington Council have submitted plans for the new park building at a cost of £1.7m.
At a public meeting on March 25, local residents decided these plans did not deliver enough for the local community and decided to attempt to engage with the planning process in order to help encourage the council to to improve its plans for the benefit of the local community.
We now have until March 31 to respond to the pavilion proposals. We urge you to write to the council and make your case for better plans.
What follows are some suggested complaints to make concerning these plans, but please see ‘reasons to say these things in your own words’ below.
To make a comment of complaint about these plans do this
- Via the council website, click “Add comments here” at the top of this page.
- Or email planning@islington.gov.uk
- Always quote Application Number P2024/0369/FUL
The below text provides a suggestion of the kinds of things you can comment on.
Reasons to say things in your own words
Please note that planning officers may give less weight to multiple responses that are exactly the same and will be interested in your own personal opinion on the impact of the proposal. Please modify the text to suit your views and include your own personal responses to the plans.
Do not forget to include your name, contact details, and the application number for these plans, which is Application Number P2024/0369/FUL.
Suggestions of what to say/comment on
Please use these as a basis for your own complaints. Do not forget to take note of any included policies our planning advisors consider the current plans could be criticised under.
Wray Crescent Pavilion, Planning Application comments (Application No. P2024/0369/FUL)
Sample preamble
The prospect of a new sports and community building on this site is extremely welcome by all residents and users of the park and has the potential to provide valuable facilities for the health and well-being of many people for many years to come.
Given the budget of between £1.4m and £1.7m public funding the current proposal is disappointing as it fails to meet requirements of council planning policy under the headline topics of the Islington Local Plan: Thriving Communities, Green Infrastructure and Sustainable Design.
This Planning Application should be refused for the following reasons. (Text in quotation marks is taken from the local planning policy, the Islington Local Plan).
Loss of Biodiversity.
No justification is given for this extent of biodiversity loss, which is not permitted by Islington policy, which states that loss of trees “will only be permitted where it is demonstrably unavoidable in order to meet other relevant policy requirements.” (as per Policy G4: Biodiversity, landscape design and trees).
The proposal would have a negative impact on the “amenity, ecological value and functionality of the space”. (Policy G2 B).
In the absence of a clear and defined build form for the equipment storage area, insufficient justification (as per Policy G4: Biodiversity, landscape design and trees) has been provided to outweigh the harm of removals that would result.
The ARBORICULTURAL IMPACT ASSESSMENT states the clearance of 6 trees, a tree/vegetation group, and hedgerow.
Impacts of removal
The value of trees and vegetation to the park are not only the taller tree line, but also areas of full vegetation to provide areas biodiversity and visual value.
Therefore, the justification that the largest trees are and the areas of larger vegetation shall be retained belies the value of the wider site and the need for dense vegetation along residential properties.
A condition shall be attached to provide the numeral value of trees lost to the northwest of the pavilion area as per the ARBORICULTURAL IMPACT ASSESSMENT
Whilst the green roof could provide elements of greenery, on a visual basis this would not be appreciable where the existing trees and vegetation are very much appreciable
Poor Security.
When considering development proposals, there are three important elements, which need to be achieved in layout and design to maximise security. These are: defensible space, natural surveillance and secure buildings. A successful design will combine all three elements to create safe buildings with enough mutual surveillance to provide significant social control.
The absence of a public facing entrance/access to the building, presents significant concern in those darker months where antisocial behaviour could take place in the absence of natural surveillance.
Maximising community benefit
A curfew of 9.00 pm is proposed for use of the community room, severely limiting its potential to host evening activities for local people. This should be increased to 10.30 pm, with operational requirements in place should neighbours experience nuisance from events later in the evening.
An Operational management plan could include local letter drop to residents – or on a gate outside – contact details if noise at an event – the current one does not. The current Operational Management Plan is very broad with no detail for community
The management plan should only be approved when it commits to a high level of community sports and other community activities, ensuring that commercial sports use is limited and does not dominate the use of the building or park during popular usage times.
A front door from the street to access the community room should be added to allow visible, safe and easy access, which is especially relevant when the park is closed or sporting activities are taking place, to “maximise shared use of the facility, particularly for sports, recreational and community uses” as required by Islington policy. (SC1)
The layout would be more effective in meeting the needs of the intended occupants with a series of small adjustments:
- The kitchen should be enlarged and an external access door added, to allow flexible operation independent of the community room and sports use, maximising shared use.
- The need for 2 external WC’s and an ‘official’s room’ has not been demonstrated and will be excessive for much of the time. The cost and space take of the official’s room can be avoided by dedicating one of the outdoor WC’s for use by officials when required.
- The external toilet should be moved away from the café hatch for privacy of users and to create a better external café amenity space (also planting should be moved away from this area to create a community café space).
- The large storage room protruding into the community room should be omitted and storage cupboards added along one side of the room, making a larger, more practical space.
Consultation
The planning documents confirm that Initial consultation came in the form of two Zoom meetings during Covid and an online system. Those documents do not mention the online petition signed by over 400 people against the plans at that time. Nor do they mention the smaller petition that was submitted on LBI’s own petitions website. In other words, the consultation documents do not include all the feedback provided by the community to these plans.
Consultation also failed because:
- It took place on Zoom, automatically excluding certain low income, sick and elderly groups without access to such technology from participating in the decision about a place they use, their local park.
- The focus on tech served to exclude valuable sections of our diverse community. This automatically made for a non-inclusive process.
- Now the Covid threat has allegedly receded, no attempt at a wider and more inclusive consultation on these plans has been made.
That means that – as required by the National Planning Policy Framework 2012, “Early and meaningful engagement and collaboration with neighbourhoods, local organisations, and businesses” did not take place. It also means a “Wide section of the community” was not “proactively engaged” so local plans reflected “collective vision”.
We are not in lock down any more, and rather than try to expand its consultation, for example through subsequent public meetings LBI has simply moved directly into the planning process.
This does not seem to match LBI, London, or national policy on meaningful community engagement, as two years have passed since initial discussion took place, meaning there has been ample time to engage in a more effective, more inclusive and more expansive consultation on these plans.
It is also clear that online responses received by the online form were not defined by location, meaning we willl never know how many positive responses were submitted by people with a vested interest in the project who were based outside of the local area, or indeed outside of Islington.
As such, these plans should be rejected pending a more robust consultation in line with Islington’s own commitments to community engagement and the national Planning Policy Framework cited above.
Appearance.
The street facing facade is inviting with only a prickly hedge and no way in.
In any application for a replacement pavilion on this site the security measures need to be clearly illustrated and demonstrate an attractive building than contributes positively to the streetscape on the edge of a conservation area. While the existing structure is equally unsightly, this proposed building will appear equally uninviting for the majority of the year.
Environmental responsibility.
For such a lightly occupied building, the systems are overly complex, over-designed and expensive to install and maintain. A 24-hour heating system is proposed, the ventilation is over specified and air conditioning is proposed.
Islington policy S6 paragraph 6.92 states that “Full-building mechanical ventilation and active cooling systems must only be considered as a last resort.” and “The use of mechanical ventilation or active cooling will only be acceptable where best practice energy efficiency standards have been achieved”. These features are included in the design but the need for them is not demonstrated or justified.
The proposal gives no details of green demolition or construction. As required by Islington policy S4, paragraph 6.93, “a whole life-cycle approach must be adopted” which “captures its embodied emissions (i.e. those associated with raw material extraction, manufacture and transport of building materials, and construction)”.
Also, Islington policy S10 F requires that “All development must minimise the environmental impact of materials through the use of sustainably sourced, low impact and recycled materials, using local suppliers where feasible.” These requirements should be clearly demonstrated in the proposal. Through this approach, and potentially maximising the use of renewable materials such as timber, the council could be delivering their first net zero carbon construction.
No facilities are shown for recycling or even waste storage – the building should designed with correct facilities to maximise recycling.
If you are available to attend the planning meeting for these plans – which we have been told may be as soon as April, you may also want to add:
I confirm that I would like to speak at the Planning Committee for this application.