Camden's planning committee will be meeting on 15th June 2026, at 7:00pm at Council Chamber,
Camden Town Hall, Judd Street, London WC1H 9JE
We have made the following submission.
SUBMISSION TO THE LONDON BOROUGH OF CAMDEN PLANNING COMMITTEE
Meeting of 15 June 2026 — Agenda Items 8(1) and 8(2)
Land at Regis Road, London NW5 3EW — Applications 2025/4861/P and 2025/5084/L
On behalf of the residents of Kentish Town and surrounding areas, supported by a petition of more than 1,400 signatures (acknowledged at paragraph 5.99 of the officer report)
1. Introduction
1.1 We object to both applications and to this scheme. This submission addresses what the officer report does not resolve: governance, legal risk, and where responsibility will sit if Members grant permission on the basis of the papers before them.
2. Governance: a question the report leaves unanswered
2.1 The Council is the landowner of much of this site, which is being brought forward by the applicant under a land disposal agreement which was not put to public tender. Residents asked for a simple assurance: that no contractual arrangement constrains, incentivises or fetters the Council’s ability to determine these applications solely on their planning merits. The officer report records this concern (para 5.87) and responds only that the Council is “unable to respond to any mistrust in its governance” through the planning process. The question therefore stands unanswered on the eve of determination.
2.2 That answer is not available to Members. Each Member is personally responsible for ensuring the decision is taken — and is seen to be taken — on planning merits alone, free of predetermination and of any appearance of bias. The Committee’s own procedural papers in this agenda pack remind Members that bias and predetermination are grounds on which a decision may be challenged by judicial review. Where the authority’s financial interest as landowner and its duty as planning authority intersect, the safeguards separating the two functions must be demonstrated, not assumed.
2.3 Before determining these applications, Members should require, in public session: (a) a statement of the governance safeguards in place between the Council’s landowner/disposal function and its development management function for this application; and (b) confirmation of whether the disposal agreement contains any payment, overage, conditionality, indemnity or timetable obligation that is contingent on the grant of this permission. Without that on the record, no Member can be confident that the decision will withstand scrutiny.
3. Public safety: where liability will sit
3.1 Homes above a recycling facility. Application 2025/5084/L would place residential units directly above an enclosed recycling waste facility. Lithium-ion battery fires in waste streams are frequent, sudden and unpredictable; the fire at the Islington indoor recycling centre in December 2025 is a recent local illustration. The officer report defers this issue to the Building Control regime (para 5.96, officer response). But the land-use decision to stack homes above a waste facility is taken once, now, by this Committee — it cannot be undone at Building Safety Gateways 2 and 3, which can only mitigate a configuration that planning has already fixed. London Plan Policies D14 and SI8 make the compatibility of uses squarely a planning matter.
3.2 Basements opposite a primary school. Basements up to c.20 metres deep are proposed, including directly opposite the CFBL primary school on Holmes Road, past which roughly 700 children travel daily, some as young as 3 years old. The Basement Impact Assessment predicts damage to neighbouring buildings no greater than “very slight” (para 23.8); a prediction is not a guarantee, and it does not address years of HGV movements (more than 70,000 journeys by our calculations), dust, noise and vibration at a school entrance. These are foreseeable risks that Members are being asked personally to authorise.
3.3 If harm materialises — a fire above the recycling hall, structural damage to neighbouring homes, an injury on a construction route — the decision trail will lead back to this meeting. Members should be satisfied on evidence before them, not on deferral to other regulatory regimes, that these risks are acceptable. The papers as they stand do not provide that assurance.
4. Legal risk on the face of the Council’s own papers
4.1 Heritage. The report itself concludes (para 29.7) that the scheme causes less-than-substantial harm at a high level to the Grade II listed Kentish Town Police Station, including loss of historic fabric through partial demolition, with further harm to the settings of listed buildings and conservation areas, and harm to the protected LVMF panoramas from Parliament Hill and Kenwood towards the Grade I listed St Paul’s Cathedral. Historic England identified a significant impact on the Parliament Hill panorama and sought amendments or safeguards; the Dean and Chapter of St Paul’s raised concerns directly. Section 66(1) of the Listed Buildings Act 1990 and NPPF paragraph 215 require Members to give this harm considerable importance and great weight. Decisions that treat acknowledged heritage harm lightly are among the most commonly quashed on challenge (see Barnwell Manor Wind Energy Ltd v East Northamptonshire DC).
4.2 Height and policy. Buildings of up to 24 storeys (residential equivalent) are proposed in a context of around 3 storeys. The report's treatment of height is internally inconsistent: paragraph 10.8 describes the Regis Road Area Guidance as 'adopted', concedes the scheme exceeds its recommended height range of 4–16 storeys, and acknowledges conflict with London Plan Policy D9(B)(3) because the sites are not identified in the Local Plan for tall buildings; yet paragraph 5.88 dismisses the same guidance as 'not adopted policy', such that the heights involve no deviation. Members cannot rely on both characterisations, and a conceded conflict with the development plan requires clear and reasoned justification."
4.3 Greening. The site-wide Urban Greening Factor is 0.30 against the 0.4 target of London Plan Policy G5 (report para 18.15); the report reaches 0.40 only by excluding the access roads from the calculation. The GLA itself recorded that the UGF was below target and should be improved. Half of the on-site trees would be removed, and the deep basements constrain soil volumes for replacement canopy trees.
4.4 Environmental assessment. Residents objected that the Environmental Statement omits cumulative impacts with nearby schemes and the whole-life carbon of the extensive basements. The GLA’s consultation response recorded that an updated Whole Life Carbon Assessment was still required and that the energy statement did not yet comply with the London Plan. If the ES is deficient, any permission granted in reliance on it is vulnerable under the EIA Regulations 2017.
4.5 None of the above are residents’ assertions: each appears in the Committee’s own papers. A grant that does not visibly grapple with them invites legal challenge — with the costs, delay and reputational damage borne by the Council and the communities it serves.
5. What we ask the Committee to do
5.1 We urge Members to refuse both applications. In the alternative, we ask the Committee to defer determination pending:
(i) publication of the governance safeguards between the Council’s landowner and planning functions, and a summary of any provisions of the land disposal agreement bearing on this decision;
(ii) an independent fire-safety review of the residential-above-recycling configuration, addressing lithium-ion battery fire risk, and the congested surroundings that limits Fire Brigade access; and
(iii) reconsideration of height and massing against London Plan Policy D9, the Regis Road area guidance, and the statutory heritage duty.
5.2 More than 1,400 people have asked you to protect Kentish Town’s character, environment and quality of life. We ask each Member to satisfy themselves, on the record, that this decision is being made solely on its planning merits — and that the risks it authorises are ones this Council is prepared to answer for.
Respectfully submitted,
On behalf of the residents of Kentish Town and surrounding areas