Strange things are happening with the KALC Planning Application. In June the Council posted all the Planning Application documents on their website – a total of 105 documents – and it was a daunting task for the consultees to make sense of, and respond to, such a massive quantity of material. In recognition of this the Council found it necessary to extend the consultation period to give us all extra time to do the work at hand.
Sport England managed to respond fairly quickly, and submitted their comments in mid July. Planning Aid For London submitted theirs, on behalf of the Lancaster West community, on 7th August, and the local ward councillors submitted theirs on 13th August. The Kensington Society are still working on their response.
Meanwhile the Council, unknown to any of us, were feverishly working behind the scenes producing a large quantity of new documents, all categorised as ‘revision content’. They began posting these online on 10th August, but didn’t bother to inform any of the consultees of this. They posted a second major tranche on 17th August, and a third on 22nd August. The situation currently is that, in addition to the 105 documents posted originally, they have now posted a further 102 so-called revisions, and there are a total of 207 documents for consultees to study, compare and contrast, and to somehow compose some meaningful reponse to.
The first conclusion we would draw from this is that the application now submitted to the Planning Committee, based on these 207 documents, is not the planning application on which we were consulted, and to which most of us have already responded.
Let’s be clear about that for starters.
We’ve all worked very hard to make sense of the fine detail of what we were assured was the KALC Planning Application. We now discover that many of the documents we have been studying are obsolete, either because details have been changed, or because they contained incomplete information to start with. Many of the so-called revision documents are technical reports, including an acoustics study, a gelogical study, ecological studies, and reports on transport, energy, water and sewerage issues, all of which should have been made available when the Planning Application was first submitted, but apparently were not. Some of the new documents may be revisions, but others clearly are not, and the only way to tell the difference is by painstakingkly sifting through the entire archive to compare original documents with revised versions, and to assimilate new and complex technical reports to make sense of what is being proposed.
This is an impossible task which we have no intention of attempting, particularly at this late stage, and we strongly believe that it is unreasonable of the Council to expect this of us. In any case the so-called revision documents have all the appearance of final versions. Why else would the Council and its’ consultants have expended so much time and effort preparing and publishing them at the eleventh hour?
The archive is also strewn with errors, inaccuracies and inconsistencies. Some errors are apparently due to the haste with which the documents were drawn up. Others, including many inconsistencies, have arisen from the complex inter-relationship of so many documents, such that references to a certain issue in one document are contradicted in another, or sometimes in another part of the same document. One has to wonder – if the job of untangling this Gordian knot is too difficult for us to accomplish, how then can the Planning Committee be expected to do so? – assuming of course that the job of the Planning Committee will not simply be to rubber-stamp this appalling mess and approve the planning application on the nod, regardless of what it proposes.
A question arises – why would the Council publish such a large quantity of new documentation – enough to radically alter the detail of the planning application – without formally notifying its’ consultees of the existence, location and significance of these new documents, and what does this say about the quality of the consultation they have conducted?
On Friday 24th August, right at the start of the bank holiday weekend, local residents received by post a revised site notice, informing them that the residential element of the project had been reduced from 35 to 32 units and the on-street parking provision increased from 32 to 35 spaces. We were invited to comment on these two changes, and on only these two changes, and given until 5th September to do so. We were not informed of any other changes to the planning application, and were not informed that the Council had posted 102 new documents during the previous fortnight, all of which contained new information and proposals, or revised information and proposals.
This notification was grossly inadequate and grossly misleading.
The Planning Application now runs to a massive 207 documents, many of which are mutually contradictory, and some of which are self contradictory.
Under such circumstances it is very hard to see how the Council can claim any legitimacy for the consultation that they have conducted, and we can legitimately argue that the consultation is fatally flawed, as is the planning application itself.