Camley Street Neighbourhood Development Plan
October 2016
1
Table of Contents
Page
I. Introduction
3
i.
ii.
iii.
the area
vision 5
Sustainability Zone Proposals
3
5
II. Core Objectives
6
III. Policies
7
IV. References
18
2
I.
Introduction
The Camley Street Neighbourhood Forum was designated by the London Borough of
Camden in February 2013, following the Localism Act 2011. The Forum has since formed a
Community Land Trust, now constituted as a limited company called Camley Street
Sustainability Zone Limited. The Forum is in the process of developing the Camley Street
Neighbourhood Development Plan (CSNDP).
In support of the development of the CSNDP, an extensive survey was conducted in 2015 of
Elm Village residents and of businesses in the adjoining Cedar Way Industrial Estate (see
map and description below). The survey elicited residents’ and businesses’ comments on
the area as it stands now, and on their desires for its future. These comments constitute
part of the evidence base for the CSNDP, and have enabled the plan’s authors to identify the
core issues the community wishes to address. These issues can be summarised as follows:




i.
reinforcing the role of the area as a place of employment, with the current
range of businesses providing a core of established enterprises;
stitching into the area the social infrastructure required to improve well-being
and quality of life in the neighbourhood for residents;
the provision of a range of housing that is genuinely affordable to local people;
improvements to the quality and range of green infrastructure in the
neighbourhood.
The area
The core of the neighbourhood are residential and industrial enclaves sitting to east and
west of Camley Street respectively; the boundary is clearly defined as a result of major
infrastructure on two flanks, the Grand Union Canal and the railway lines coming in and out
of Kings Cross station and other neighbourhoods with strengthening identities close by:
Kings Cross to the south and Camden Town to the East.
3
4
ii.
vision
Our vision for the neighbourhood area is to be achieved principally through the redevelopment of the Cedar Way Industrial Estate and a number of adjoining parcels of land
(hereafter termed ‘the Sustainability Zone’):
‘to deliver a range of B1 and B2 industrial and commercial spaces, additional new
dwellings, commercial spaces and social infrastructure that satisfy the needs of the
current business occupiers, create additional space for new businesses, safeguard
present jobs plus create new ones, and provide residents with a minimum of 50%
affordable housing plus additional community facilities and services using the latest
thinking in building design and eco-friendly technology.’
Taken as a whole, the intention of the community (formed of residents, business owners
and their employees) is that the neighbourhood area should mature into a blend of land
uses, partially eroding the differentiation that exists currently between the Elm Village
residential area and the Sustainability Zone, delivering workplaces for existing and new
businesses that support proper security of tenure, and a step change to the quality of life of
residents by improving mobility, widening the range of goods and services available nearby,
integrating nature more widely into the built environment and providing housing suitable in
type and attainable in cost.
This vision maps onto policy through four overarching or ‘core’ objectives, which appear
below; these are broken down further into a number of sub-objectives. This in turn provides
a framework for policy.
iii.
Sustainability Zone proposals
A Summary of the Sustainability Zone proposals are set out below,
The emerging spatial framework that underpins the vision for the Sustainability Zone
envisages:



The replacement of all light industrial floorspace that currently exists on the site and
its upgrading such that it can be successfully integrated into and operate within new
mixed use buildings, which will include residential land uses (approximately
10,200sqm (GIA))
The provision of new light industrial and other flexible workspaces that are suitable
for a wide range of small and large companies, including affordable workspaces for a
range of small businesses, artists and makers at ground and first floors
(approximately 4,400 sqm (GIA)).
The provision of approximately 750 new dwellings that will provide affordable
homes for young single people and couples, families and older people.
5



II.
The delivery of a variety of shared communal spaces including gardens, kitchens,
laundries, libraries, bike parks, cafes/ restaurants and community spaces that will
encourage interaction and engender and sustain a sense of community.
The integration of environmental systems that will allow for the capture and reuse
of heat generated by the cluster of existing and new food production companies
that will exist on the site.
The adoption and integration of measures that ensure that the development is at
the forefront of sustainable design and which minimises resource consumption
through its operation.
Core Objectives
Core objective 1: Development will ensure the neighbourhood’s continued function as a
place of employment led by light industrial functions.
Sub-objectives



The Cedar Way Industrial Estate currently provides space for food production and
storage, serving the needs of the restaurant and hospitality industries across
London. This specialism performs a function of strategic importance at the regional
scale and should be safeguarded.
London is witnessing a shift from traditional office accommodation to more informal
workspaces, offering greater flexibility and opportunities for collaboration with
other organisations; this culture is compatible with our vision for Camley Street, and
such spaces will be included in the design.
Working from home is compatible with sustainable development on account of
reducing the demands on transport infrastructure at busy times and providing a
human presence in the community during the day. Residential units should
therefore be designed in such a way that working from home is a realistic choice.
Core objective 2: Development will encourage the strong community spirit that currently
exists through the provision of improved social infrastructure.
Sub-objective

We have a plan for a cohesive ‘community hub’ to come into existence that provides
a community hall, convenience retailing and space for ‘key services’.
Core objective 3: Development will support the growth of a blended community through
the provision of housing of different types.
Sub-objectives


Subject to the need to ensure viability, as many dwellings as possible should be
available for rent at affordable rent levels.
Housing suitable for families will be prioritised.
6

Seeking to limit the amount of additional purpose-built student blocks in the area.
Core objective 4: Development will facilitate improvements to the public realm in order to
make walking and cycling easier, offering easier access to local centres, given the long
distances from some parts of the neighbourhood.
Sub-objectives




Provide cycle infrastructure as part of new development.
Promote walking by reinforcing desire-lines through traffic-calming measures.
Make walking routes safer at all times of the day and early evening by encouraging
street activity, including ground-floor frontages activated by retail, civic and/or
commercial leisure uses, well designed street lighting, and a mix of transport modes
including vehicular traffic.
New residential developments should be car-free and should plan for the
emergence of self-driving vehicles.
Core objective 5: Development will increase the range and accessibility of green space in
the neighbourhood.
Sub-objectives


III.
Safeguard existing green space from development.
Provide a network of additional green infrastructure such as green verges, trees and
small pocket and linear parks.
Policies
Core Objective 1 – Employment (‘EM’ policies)
There is widespread support in the community for the continuation of Camley Street’s role
as a place of employment, with 70% of people in favour (1). More specifically, there is a
desire to preserve the current balance of industrial activity, that is to say distribution, retail
trade and food wholesaling, combined with a range of other activities including spaces that
support collaborative working practices, small-scale manufacturing and studio spaces for
artists and designer-makers (2). The vision is to create a mutually supportive group of
businesses involved in a diverse range of activities, building on Camden’s policy E1 but
introducing Camley Street’s own characteristics based on established competitive strengths
and a willingness to adapt to London’s changing economic landscape.
No business in London can now expect a free ride; each has to succeed in the city’s
competitive economy. Moreover, in an age of scarce land, employment uses have to
demonstrate their value first and foremost in economic terms. While there is pressure for
re-development of the Cedar Way Industrial Estate site for other uses such as housing,
student accommodation or offices, there is a strong case, supported by evidence, that light
and, where appropriate, general industrial uses should be safeguarded in the context of the
redevelopment of the site to deliver a broader mix of uses, commercial and residential.
7
Crucially, the B1 and B2 uses currently on site perform a strategic function within the wider
Camden and London economy, providing food wholesale, logistical and laundry services to
the cultural and leisure economy sited in London’s Central Activities Zone. This sector also
forms an important part of the economy of Camden (3). Together with the evidence from
the survey of the longevity of businesses in the area (all those questioned had been
operating from the site for more than 20 years [4]), this affirms the viability of the area as a
place of industrial activity. The policies set out in the CSNDP therefore build on Camden’s
Local Plan (5); moreover, evidence supports the designation of the Sustainability Zone as a
site of local significance based on its function as a key distribution centre (6).
This vision relies on a number of sources of evidence: in particular, findings set out in
Camden’s Employment Study 2014 showing the high cost of industrial locations in the
borough – a strong indication that supply is failing to keep up with demand (7). For this
reason, the London Plan defines Camden as ‘restricted’ in terms of opportunities to convert
employment land into other use classes where those sites fulfil a strategic function (8).
The significance of this is underlined by a review, commissioned by the GLA and produced by
Aecom, of the supply of industrial land in London and an assessment of the implications of a
restricted supply for the London economy in the future (9). Key findings of this study were,
firstly, that the trend rate of industrial land release is well over projections set out in the
GLA’s Supplementary Planning Guidance, and that this is particularly marked in the Central
sub-region. Secondly the study concludes there will be a case for switching from releasing
industrial land to retaining most of it, and that such policy decisions will depend on the value
placed on the commercial activities that take place on the remaining land (10). The
evidence we have complied for the CSNDP indicates that the industrial uses taking place
within the Plan area are of great strategic value at both a local and city-wide level.
The CSNDP also sets out a vision for playing a role in the emerging ‘knowledge quarter’ of
Kings Cross by providing flexible employment space suited to start-up enterprises. This is
space designed to support collaborative working and social interaction. In addition, the plan
envisages providing affordable workspaces for artists and designer-makers (‘affordable
workspace’ is defined as 50% of the average market rent for B1 & B2 space in Camden and
that may be occupied by way of a monthly licence); this group will enrich the civic culture
and will be in harmony with the progressive vision for the neighbourhood.
The intention is to deliver a mix of uses within the Sustainability Zone; one of the most
environmentally sustainable and increasingly popular places of work is the home. The plan
envisages types of residence that support this activity, as well as specifically live/work land
uses. This will embed adaptability into the scheme and address civic concerns about petty
crime and anti-social activity by providing an active human presence in the neighbourhood
by day as well as by night.
Policy Template
Policy EM1
Theme Employment
Intention Development in the Camley Street area should provide high
quality business premises to accommodate the enterprises
already established in the area as well as those wishing to move
8
there.
Policy options
Development of commercial and mixed use schemes
a) must ensure, in the case of the redevelopment of existing
employment sites, the amount of employment floorspace
reserved for B1 and B2 uses is maintained or increased
b) will maintain or increase employment densities currently
achieved on existing employment sites
c) provide space suitable for small and medium sized
enterprises and suited to a range of uses, where
appropriate
d) provide affordable workspace where ‘affordable’ is
defined as 50% of the cost of accommodation in Camden
falling into the same land-use classification and
comparable in size and specification.
Conformity
Local Plan: E1, a, b, d, e, g (i), g (ii) and I; E2 (Employment
Local Plan premises and sites)
NPPF NPPF: 19, 20, 21 (bullets 3, 4 and 5)
London Plan London Plan: 4.1 a1, d,; 4.4
The Forum sees the area’s employment uses as fundamental to the identity of the area and
it’s continuation as a flourishing commercial enclave is a core aspect of their vision. When
assessing development proposals consideration must be given to whether it will enrich or
erode this aspect of the site. Development proposals, regardless of scale, within the area
identified as the Sustainability Zone must satisfy EM1 a) and b) as an absolute requirement;
addressing c) and d) will be accorded significant weight in arriving at an overall judgement as
to the desirability of the proposal.
CO2 - Social infrastructure (‘SI’ policies)
In community consultation, a large minority of residents (48%) reported being dissatisfied
with the range of goods and services in the area; this is unsurprising given that many people
have to make a long walk to the main local centre, Camden Town. This lack produces a
requirement for improved provision of retail and social infrastructure of both a commercial
(cafes, restaurants and pubs) and non-commercial nature (community hall) within the
neighbourhood area.
Moreover, the Camley Street neighbourhood lacks venues for community events and places
that facilitate social interaction between people. For example, in surveys, large numbers of
people reported finding it difficult to make friends in the neighbourhood. There is a heavy
reliance on The Constitution pub; if it were to close it would deal a body blow to the
area(the closure a few years ago of a community centre in Elm Village was cited in the
consultation as a serious loss to the neighbourhood). As a result of the shortage of places to
9
meet, people tend to go outside the neighbourhood to socialise, for example to Camden
Town or to the pubs around Royal College Street and St. Pancras Way.
All this points to an imbalance of land uses in the Camley Street area, with the area failing to
provide the social infrastructure necessary for well-being, and falling short of the definition
of lifetime neighbourhoods described in the London Plan (11). In addition, the arrival of
more residents as part of any new development will exert even greater pressure on the
existing facilities, making a strong case for new social infrastructure to be provided as part of
development brought forward in the area covered by the CSNDP.
The intention of our policy is to turn an area with a narrow range of land uses (employment
and residential) into one with a richer mix. This will create improved linkages between
different parts of the area, and satisfy residents’ need for improved services on their
doorstep.
Policy Template
Policy SI1
Theme Social infrastructure
The Forum wishes to support residents’ quality of life by
addressing the shortcomings in social infrastructure. Useful
Intention additions to the area include café and restaurant uses.
Policy options
New development that increases the living and working
population of the Plan area should address the community’s need
for improved social facilities. The ability of any new development
to provide new social infrastructure, such as café, restaurant,
nursery, crèche, day-centre will be treated as a benefit of
significant weight.
Conformity
C1 (health & well-being), C2 (community facilities), C3 (cultural
Local Plan and leisure facilities), C6 (Access for all)
NPPF Paragraph 17 (core principles), 70 (first and last bullets)
3.7 (Large residential developments), 3.16 (protection and
enhancement of social infrastructure), 7.1 (Lifetime
London Plan neighbourhoods)
All proposed developments should demonstrate how they are contributing to the collective
well-being of the neighbourhood; this may be by showing how their design will help foster
interaction between neighbours and the wider community. In the case of larger schemes
(100 units +) the specific delivery of an item of social infrastructure either within the
curtilage of the development, or by building a new facility off-site or by making a
contribution to the refurbishment costs of an existing facility within 400m of the site taken
from the list set out in policy SI1 will be seen as a significant benefit and contribute
substantially to the overall acceptability.
CO3 – Housing (‘HO’ policies)
10
The aspiration is to provide a balance of types of housing, and a particular priority is family
housing. Moreover, the Forum is determined that a maximum proportion practicable of new
development within the Plan Area should be set aside for long-term affordable rent.
The vision for the CSNDP builds on Camden’s policy H1; this states that the supply of housing
in the borough will be maximised ‘where sites are underused or vacant, expecting the
maximum reasonable provision of housing that is compatible with any other uses needed on
the site’ (12).
We see housing as a key use in the development sites available and, building on policy H2
(13), our aim is that not less than 50% of all additional floor space be allocated to selfcontained housing, integrated with other uses to achieve sustainable, mixed-use
development. Moreover, subject to preserving viability as defined by the NPPF, our aim is
that 100% of this additional residential floor-space be available for rent at affordable levels.
Policy 3.10 of the London Plan (14) provides a definition of affordable housing drawn from
the national policy (15). The London Plan establishes eligibility through local incomes and
house prices. Development in the Area should, where viability is demonstrated, require the
maximum number of dwellings that fall into the range of affordable product types as
defined by national policy be provided.
We believe the housing policies set out in this document are in conformity with national
policy; this is demonstrated by two viability assessments prepared on behalf of CSSZ by its
professional advisor (Minerva Smart Cities Ltd). The first of these uses a land value based on
existing use value (EUV); the second establishes a current market residual land value (based
on the proposed planning use desired by the neighbourhood of 70% residential and 30%
B1,B2 workspace). Both assessments show that a willing developer seeking to bring forward
a scheme of development that includes 100 or more dwellings would be able to achieve a
competitive return on capital employed while allocating 100% of all residential floor-space
(70% of the whole) to housing whose rental levels would be within the reasonable budget of
a person earning an average wage (and in that sense affordable).
It is not possible to specify or predict the scale of development proposals submitted to the
LB Camden; however, given the content of the viability assessments created by a willing
developer, the Council should require development proposals of all scales to fulfil the
housing policies set out in this document.
The Forum recognises the validity of blended communities of people of different ages and
income levels, and feels that a properly apportioned ratio of social and intermediate
products should be arrived at through a process of negotiation with council officers (16),
taking as a starting point the 60:40 split set out in policy H4 (17). This includes the notion of
providing accommodation for middle-income households who are in danger of being
squeezed out of Camden (18). The CSNDP concurs with the Local Plan (19) that any sort of
owner occupation, including shared ownership, is likely to be beyond the means of the vast
majority of residents. For this reason, we propose to retain as high a proportion as possible
of new housing for social and intermediate rent, with a clearly state goal of 100%.
11
The desire to see improved provision of housing for families stems in part from a wider
recognition that the area would benefit from a more family-orientated mood, and that,
while the area does have houses, these are generally small and therefore not suited to
growing households. This is picked up in the 2011 census data, showing the neighbourhood
area as having a lower proportion of ‘married or same-sex civil partnership couples’ than in
Camden generally and there being a significant problem with overcrowding, with 16% of
households registering an occupancy rating of -1 or less (The Census 2011 definition of
overcrowding is based on the notion of the ‘bedroom standard’. The ‘bedroom standard’
sets the appropriate number of bedrooms in a given dwelling, depending on the number of
occupants and their relationship with one another. This number is subtracted from the
number of bedrooms that actually exist to obtain the ‘occupancy rating’. An occupancy
rating of -1 implies that a household has one fewer bedroom than required, whereas +1
implies that they have one more bedroom than the standard requirement). For this reason,
the CSNDP builds on policy 3.8 in the London Plan, which treats the provision of affordable
housing as a strategic priority (20), and supports findings in Camden’s Strategic Market
Housing Assessment. These identify, in the context of a mix of dwelling sizes, two- and
three-bedroom homes followed by homes with four bedrooms or more as being housing
types for which there is the greatest need (21).
Both local (22) and regional policy (23) recognise the difficulties created by significant
concentrations of students in a given area, and how this can create communities that are
out of balance. Given that, at the time of the 2011 census, 17.2% of residents were full-time
students (a proportion that is likely to have increased substantially as a result of the new
student blocks that have been completed in Camley Street over the last five years),
compared with 12.3% and 7.3% in Camden and London respectively (24), the CSNDP
believes that the Camley Street neighbourhood would be brought into a state of severe
imbalance if more large purpose-built student halls of residence were permitted within or
on sites adjacent to the area.
Policy Template
Policy HO1
Theme Housing
In the view of the forum, there is an imbalance in the existing
Intention housing provision that makes the area less attractive to families
than it could be; moreover, they wish to maximise the amount of
housing for rent that is affordable to people living on average
Camden incomes.
Policy options
Residential development will provide a range of housing types
(depending on the scale of the development) to meet the needs
of the community. This will be achieved by
a) Maximising the amount of affordable housing with an
aspiration to achieve 100% where viability assessments,
which must be placed in the public domain for scrutiny,
demonstrate this is achievable
b) Provision of affordable housing within new development
that include more than 25 units of not less than 50% of all
12
dwellings
c) The provision of a range of different unit sizes, including
three and four bedroom homes suitable for families,
where appropriate.
Conformity
Policy H1 (Maximising the housing supply) d; H2 (Miximising the
supply of self-contained housing from mixed use schemes); H4,
Local Plan (Maximising the supply of affordable housing
NPPF Paras 47 and 173
Policy 3.3 (Increasing housing supply) 3.8 (Housing choice) 3.10
(Definition of Affordable Housing) 3.11 (Affordable housing
targets), 3.12 (Negotiating affordable housing on individual
London Plan private residential and mixed use schemes)
Policy Template
Policy HO2
Theme Housing
The neighbourhood forum welcomes student accommodation to
the area as part of building a blended socio-economic
demographic. The single use block (for example, 103 Camley
Street) does not add anything to community vitality however. The
Forum therefore wishes to prevent any additional student housing
in the Plan area where this is designed for their exclusive use.
Policy Objective
Policy options
Student accommodation integrated into mixed use development
that includes accommodation for occupiers of other kinds will be
supported but mono-use student blocks will not. New
developments that include any accommodation designed
specifically for students must conform with the following criteria,
a) no more than 50% of the residential floorspace will be
offer student accommodation;
b) no one development will include more than 15 units
designed spacifically for students
c) the remaining residential floorspace conforms with Policy
HO1.
Conformity
Local Plan
NPPF
Policy 3.8 (Housing choice), 3.9 (Mixed and balanced
London Plan communities)
In bringing forward proposals that seek to increase the amount of student accommodation,
regard must be given to the desire on the part of the community to build a strong civic
culture. Mono-use student housing is unlikely to inspire their tenants to get involved in the
wider life of the community. In considering proposals for development that include student
13
housing, care must be taken in assessing whether, on account of the mix of adjacent
typologies and overall design, -these schemes are likely to contribute to community life. The
criteria in the policy are designed to ensure encourage such integration. Those that do not,
on account on mono-use, must not be supported.
CO4 - Public realm and green infrastructure (‘PRGI’ policies)
Moreover, an assessment of the open spaces inside the Plan area revealed many cases
where it is poorly maintained and not fulfilling its potential. (In the assessment of open
spaces set out in the evidence base, none apart from the Camley Street Natural Park and
Elm Village Open Space scores more than 60 out of 90 [27]). This points to a deteriorating
condition that will be exacerbated as the population of the neighbourhood increases
naturally in line with growth across the borough as a whole. This analysis supports the
frequent calls for improvements to open space provision in community surveys.
Finally, drawing on Camden’s Open Space study prepared by Atkins, we would support the
study’s recommendation (28) that an additional pocket park (a type of open space
measuring around .4ha) be provided in the St. Pancras and Somers Town ward.
Policy Template
Policy PRGI1
Theme Public realm and green infrastructure
Policy Objective The forum is concerned there is an emerging deficiency of
green/open space in the Area, particularly in light of proposed
new development. This condition is exacerbated by the relatively
poor state of maintenance of existing sites.
Policy options
Development shall protect and improve existing green/open
space. Development that increases the demand for recreation or
amenity shall provide for new green/open space. This shall by
achieved by:
a) The appropriate provision (relative to the size of the
development) of new green/open space, or contributing
towards over-coming the poor quality of many open
spaces in the Plan Area
b) Appropriate contributions to the maintenance and
enhancement of existing and new green/open space to
ensure they are able to provide a high level of
environmental and social value in perpetuity
c) The use of Sustainable Drainage Systems in all
development, unless there are practical or viability
reasons for not doing so
d) The provision of outdoor leisure facilities - such as
playgrounds, gyms and recreational spaces - and their
maintenance, where appropriate
e) The establishment of a high quality pocket park within the
St. Pancras and Somers Town Ward.
14
Conformity
Policy A2 (Open Space) k, n, o, p, q; Policy A3 (Biodiversity) e, f;
Local Plan Policy CC2 (Adapting to climate change) a, b
NPPF Para 69, third bullet; 76 (Local Green Space)
Policy 7.1 (Lifetime Neighbourhoods) B, C; Policy 5.10 (Urban
London Plan Greening) A, C
All development proposals must include an integrated open space plan showing how the
scheme will satisfy PRGI1 b), to be signed off by the appropriate authority. Schemes must
also demonstrate how they fulfil one of sub-clauses c), d), e) and f). The Forum recognises
the chosen route may respond to the purpose, design and/or location of the development.
Policy Template
PRGI2
Theme Public Realm and Green Infrastructure
Given the pressure for development in the neighbourhood area
the forum wishes to make use of provisions set out in the NPPF to
safeguard existing areas of Open Space that are key to community
health and wellbeing, these are Elm Village Open Space and Play
Policy Objective Area and Camley Street Natural Park
Policy options
The sites in the Area listed below (a-b) and identified on Map (see
overpage) are all designated as Local Green Space:
a. Elm Village Open Space and Play Area
b. Camley Street Natural Park
Conformity
Local Plan Policy A2 (Open Space) e and h
NPPF Para 76,77 (Local Green Space designation)
London Plan
15
IV.
References
. Camley Street Evidence Base, IV development, page 39
2. Evidence Base, IV development, page 38
3. Camden draft Local Plan 2015, Economy & Jobs, section 5.1
4. Evidence Base, V place of work, page 48
5. Camden draft Local Plan 2015, Economy & Jobs, section 5.33
6. The London Plan March 2015, chapter 4 London’s Economy, section 4.20
7. Camden draft Local Plan 2015, Economy & Jobs, section 5.33
8. The London Plan March 2015, chapter 4 London’s Economy, section 4.21
9. Aecom IE UK, London Industrial Land Supply & Economy Study 2015, page 1
10. Aecom IE UK, London Industrial Land Supply & Economy Study 2015, page 14
11. Social Infrastructure SPD, May 2015, London Plan 2015 Implementation Framework,
pages 10, 38
12. Local Plan Submission draft 2016, page 44
13. Local Plan Submission draft 2016, page 53
14. London Plan, chapter 3, London’s People, page 127
15. National Planning Policy Framework page, glossary, page 50
16. Camden Planning Guidance, Housing, page 17
17. Local Plan Submission draft 2016, page 64
18. Local Plan Submission draft 2016, page 85
19. Local Plan Submission draft 2016, page 69
20. London Plan, chapter 3, London’s People, page 119
21. Local Plan Submission draft 2016, page 93
16
22. Local Plan Submission draft 2016, pages 87, 113, 114
23. London Plan, chapter 3, London’s People, page 123
24. Evidence Base, Employment, page 58
25. Camden Open Space, Sport and Recreation Study, 2014, page 162
26. Camden Open Space, Sport and Recreation Study, 2014, page 170
27. Evidence Base, VII Public Realm, page 64
28. Camden Open Space, Sport and Recreation Study, 2014, page 162
17