Camley Street Neighbourhood Development Plan

Pre-submission version May 2017

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Table of Contents Page

I. Introduction 3

i. the area 3ii. vision 5

iii. Sustainability Zone Proposals 5

II. Core Objectives 6

III. Policies 7

IV. References 18

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I. Introduction

1. The Camley Street Neighbourhood Forum (CSNF) 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).

2. 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:

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.

i. The area

3. 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.

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ii. vision

4. Our vision for the neighbourhood area is to be achieved principally through the re-development 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.’

5. 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.

6. 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

7. A Summary of the Sustainability Zone proposals are set out below,

8. 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.

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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.

II. Core Objectives

9. Core objective 1: Development will ensure the neighbourhood’s continued function as a place of employment led by light industrial functions.

10. 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.

11. Core objective 2: Development will encourage the strong community spirit that currently exists through the provision of improved social infrastructure.

12. 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’.

13. Core objective 3: Development will support the growth of a blended community through the provision of housing of different types.

14. 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. Seeking to limit the amount of additional purpose-built student blocks in the area.

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15. 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.

16. 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.

17. Core objective 5: Development will increase the range and accessibility of green space in the neighbourhood.

18. Sub-objectives Safeguard existing green space from development. Provide a network of additional green infrastructure such as green verges, trees and

small pocket and linear parks.

III. Policies

Core Objective 1 – Employment (‘EM’ policies)

19. 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.

20. 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.

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21. 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).

22. 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).

23. 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.

24. 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.

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25. 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 EM1Theme 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 there.

Policy optionsDevelopment of commercial and mixed use schemes

a) must ensure, in the case of the redevelopment of existing employment sites, the amount of employment floor-space 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 PlanLocal Plan: E1, a, b, d, e, g (i), g (ii) and I; E2 (Employment premises and sites)

NPPF NPPF: 19, 20, 21 (bullets 3, 4 and 5)London Plan London Plan: 4.1 a1, d,; 4.4

26. 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)

27. 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

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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.

28. 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 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.

29. 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.

30. 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 SI1Theme Social infrastructure

Intention

The Forum wishes to support residents’ quality of life by addressing the shortcomings in social infrastructure. Useful additions to the area include café and restaurant uses.

Policy optionsNew 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

Local PlanC1 (health & well-being), C2 (community facilities), C3 (cultural and leisure facilities), C6 (Access for all)

NPPF Paragraph 17 (core principles), 70 (first and last bullets)London Plan 3.7 (Large residential developments), 3.16 (protection and

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enhancement of social infrastructure), 7.1 (Lifetime neighbourhoods)

31. 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)

32. 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 dwellings people can afford.

33. 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).

34. 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 self-contained 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.

35. 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%.

36. Policy 3.10 of the London Plan (14) provides a definition of affordable housing drawn from the national policy (15). Development in the Area should, where viability is

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demonstrated, seek to deliver the maximum number of dwellings that fall into the range of affordable housing types as defined by national policy.

37. We believe the housing policies set out in this document are in conformity with national policy. This is demonstrated by two viability assessments, the first prepared on behalf of CSNF by Minerva Smart Cities Ltd, and the second prepared by AECOM.

38. The Minerva assessment uses a current market residual land value (based on the proposed planning use desired by the neighbourhood of 70% residential and 30% B1,B2 workspace) whereas the AECOM document uses a land value based on existing use value (EUV).

39. The Minerva document shows conclusively 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).

40. The AECOM assessment, based upon the Planning Practice Guidance and ‘Viability Testing Local Plans’, shows that a fully policy compliant scheme of 50% affordable housing (of which 60% is social rent and 40% is intermediate) is viable based upon today’s costs and values providing competitive returns to both the landowner and developer. The findings demonstrate that if a lower developer’s profit was assumed upfront a higher proportion of affordable would be viable based upon an alternative longer term delivery model not predated on a simple residual based appraisal methodology.

41. 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).

42. 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

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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).

Policy Template Policy HO1Theme Housing

IntentionIn the view of the forum, there is an imbalance in the existing 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 optionsProposals to redevelop commercial areas into mixed use should

a) Maximise 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) Provide a minimum of 50% affordable housing;c) Provide a range of different unit sizes, including three and

four bedroom homes suitable for families, where appropriate.

Conformity

Local Plan

Policy H1 (Maximising the housing supply) d; H2 (Miximising the supply of self-contained housing from mixed use schemes); H4, (Maximising the supply of affordable housing

NPPF Paras 47 and 173

London Plan

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 private residential and mixed use schemes)

43. 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 the Council should require development proposals of all scales to fulfil the housing policies set out in this document.

44. 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.

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Policy Template Policy HO2Theme Housing

Policy Objective

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 optionsStudent 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.

ConformityLocal Plan

NPPF

London PlanPolicy 3.8 (Housing choice), 3.9 (Mixed and balanced communities)

45. 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 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)

46. 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

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borough as a whole. This analysis supports the frequent calls for improvements to open space provision in community surveys.

47. 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 PRGI1Theme 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 optionsDevelopment 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.

Conformity

Local PlanPolicy A2 (Open Space) k, n, o, p, q; Policy A3 (Biodiversity) e, f; Policy CC2 (Adapting to climate change) a, b

NPPF Para 69, third bullet; 76 (Local Green Space)

London PlanPolicy 7.1 (Lifetime Neighbourhoods) B, C; Policy 5.10 (Urban Greening) A, C

48. 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).

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The Forum recognises the chosen route may respond to the purpose, design and/or location of the development.

Policy Template PRGI2Theme Public Realm and Green Infrastructure

Policy Objective

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 Area and Camley Street Natural Park

Policy optionsThe 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 Areab. Camley Street Natural Park

ConformityLocal Plan Policy A2 (Open Space) e and h

NPPF Para 76,77 (Local Green Space designation)London Plan

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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

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

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27. Evidence Base, VII Public Realm, page 64

28. Camden Open Space, Sport and Recreation Study, 2014, page 162

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