… Planning Applications

May 4, 2011 at 5:43 pm 2 comments

Today I’ve been working my way through the supporting documents for the new public toilets for Oxford Street. (My previous blog post about them is here and the planning documents are here, at the time of writing.)

My response to the planning proposal is here (pdf). I made 4 points, about Gender Ratios, Signs, ‘Changing Places’ and Benches.

It wasn’t easy to comment on a planning application. Here’s why…

1 – I had to know about it.

  • As part of my research I met a man at Westminster Council in 2009 who told me they were hoping to build a public toilet pavillion on this site (between John Lewis and House of Fraser).
  • In 2010 I heard that there was something in a London paper about the department stores objecting because it would draw people away from their stores!
  • Finally, the developers of the toilets contacted my Supervisor as they were looking for some researchers to count nearby toilets (tempting, but not what we do).

So I kept an eye out.

In December 2010 I went on Westminster’s planning website and searched for Old Cavendish Street. Nothing.

I made a shortcut to the site and put it on my desktop so I could check it occasionally.  I did so again at least once in Jan and Feb, but not religiously as this could go on for months. Or years.

When shopping for fun over Easter, specifically to House of Fraser next to the site, I happened to see a planning notice on a traffic light.

I sometimes look at planning notices, but they’re hardly inviting. Why is a sign in open space for the public’s attention written in size 12 font? Why is 50% of the notice irrelevant? I’m guessing if you stood on Oxford Street all day the number of people looking at the notice would be in single figures. None of them would be interested in toilets.

A few days later I remembered to go on the planning site, and saw that the decision on the proposal had been due 3 days ago.


What more could I have done?

2 – I have to understand the proposal

Although the decision was due, no decision was listed, so unperturbed I decided to comment once I’d read the proposal. In this case there are 22 supporting documents, and I had an advantage because we were sent parts when they contacted us last year, so I knew there was something in there worth objecting to.

If you were just a member of public and had, unbelievably, made it this far, where would you start with 22 documents?

All the documents are pdf so I can open them, apart from the two that, well, don’t.

The scale drawings are not dimensioned so I can’t tell if the cubicles are an adequate size or not. I could print them to scale, perhaps, and use a ruler and a calculator, but that assumes the pdf is to scale (might be). In any case it would be completely inaccurate at this scale, and frankly bordering on OCD.

3 – I have to write something clever 

I don’t want to look silly. There are lots of little things that I could object to regarding the proposals but they’d be (Highly Pertinent) design quibbles, but not reasons on which to base planning decisions. On what grounds can you object to someone getting planning permission? Do I even want to object? I just want a few things raised and hopefully changed, not to ruin someone’s day.

In the end I stuck to 4 points that I felt might be relevant at this stage and left it to the planners to decipher what’s a valid reason and what’s not. I can’t be expected, as a member of the public, to understand planning rules.

However, as I decided to comment as a researcher into public toilets I stuck to professional views and tried to explain it from an expert (*cough*) perspective. The first point that I made about male/female toilet ratios is stupidly important and it is definitely (in my view) something that planners should be made aware of.

(Basically, although the use of the toilets is expected to be 57% men and 43% women, they have provided both genders with 4 places to pee. As women take twice as long to use the loo, a 50:50 use facility should have twice as many toilets for the ladies. Anything else is sexist (or a less-loaded word that amounts to the same thing). 

Hilariously, Atkins pedestrian modelling (submitted as part of the Planning Application) agrees, showing that queues form “particularly in the ladies”:

Atkins pedestrian modelling (worst case). These women at the back are already queueing for a toilet that doesn't exist yet.

Now of course usage fluctuates and you cannot provide toilets for every eventuality – sometimes, likely at Christmas, Oxford Street will be busy and we will have to queue. But in those cases there should be queues forming for both sexes. Women should not be condemned to queue, just because they’re women!

And Finally…

One thing I noticed in the planning docs was the incredible amount of public consultation that the contractors had already done. It says that they met with the New West End Company Community Forum 3 times in 2010 and once in 2011. It lists 14 groups (Residents’ Associations, Councillors, Church Groups, Societies etc) who attended on one or more occasions (apparently ‘groups’, rather than ‘people’, attend this sort of thing..).

Well if they’ve done all that consultation what could I possibly have to object to?

It summarises:

 the applicant has undertaken considerable consultation to inform the development proposals and has demonstrated a commitment to engaging with the public and key stakeholders throughout the pre-application process. The consultation has generally been positive and has identified significant support for the redevelopment proposals.

That’s it.

“We spoke to lots of organisations, and all in all they’re pretty much OK…”

Surely they had more opinions than that?  What are the issues? What were the discussions? How did you resolve them?

Were the attendees of the Community Forum informed of the planning application? Have they had the opportunity to comment on it? Not necessarily to object; support the application that they helped to develop?

I guess they don’t have to share this information in the Supporting Documents, though they clearly had to provide evidence of ‘having ‘done’ public consultation’.

I love (the idea of) public consultations. For all I know this one was excellent.

However without any evidence I’m always going to (sadly) suspect this was a box-ticking exercise.

I wrote a blog post about Planning before – more about how to get more public toilets built through the planning process (e.g. Section 106 agreements). It was long and dull (the blog post, not the planning process) but you can find it here all the same.)


Entry filed under: Urban Design. Tags: , , , , , .

… Ordnance Survey’s Reply … Inclusive Design

2 Comments Add your own

  • 1. michelle ann  |  May 5, 2011 at 7:38 am

    Gail, One thing that is relevant to planning is equality. Under the Equality Act, all public bodies have a legal duty to try and ensure equality in their business. They have actually proved here that they are not providing equal service!

  • 2. Blogs and Blogging « We Love Local Government  |  May 20, 2011 at 7:27 am

    […] In addition, this post about the problems of responding to a planning application perfectly sums up the frailties of the way councils engage with members of the public about planning applications. Really well worth a read (even if you’re not interested in toilets):  […]


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