Bloomsbury Association Objects to Camden Council proposal for Dedicated Fixed Site Needle Exchange at Tottenham Court Road Underpass

Backdated from previous BA website

Our comments in opposition to this proposal by Camden Council have been lodged with the Development Control Sub Committee (the planning committee) and read as follows: Latest news relating to this application are at the end of the document.


Application for planning permission: 2006/0100/P
The Bloomsbury Association object to this application and wish to make the following comments.

The proposal is located in an area that is acknowledged to be one of the foremost street markets in Class A drugs in London. This is exacerbated by Council policies which have sought to locate a concentration of London-wide facilities in the area to serve drug addicts, the lack, until recently, of cross-border co-ordinated policing between Camden and Westminster and a late-night entertainment industry that promotes drug culture. Drug related activity in the area ebbs and flows and the Police work hard with the community to address it but, at times, it is at a level that scarce Police resources have to be redeployed to control the situation.

Crucially, the problem is centred on the number of addicts who are housed locally in hostels. There are, on a conservative estimate, at least 500 drug users in hostels within Bloomsbury. In addition, there are many rough sleeping addicts attracted to the area because of this drugs market. This has
created a critical mass of drug addicts who act as a reference point for both dealers and on-resident users. They seem to meet regularly with their dealers and St Giles Circus is a favoured dealing location.

Data from the Bloomsbury CommunityAlert System• indicates the extent of the current problem in the immediate area. In the past 12 months there have been approximately 1200 drug related incident reports (300 in last quarter ending January 2006) recorded in and around Bloomsbury. Recently we have also seen an increase in reported drug related incident reports from Denmark Street, adjacent to the proposed needle exchange.

One recent incident is particularly potent. On 12 January, at 8:30 a drug user was begging with extreme aggression from young women waiting at the stop bus stop outside the Virgin Megastore on Tottenham Court Road. The user had recently had his legs amputated and, seated on a wheeled trolley, was manoeuvring himself so that he pressed the bloodied stump of a severed limb up against his victims. Using this ‘weapon’ he was demanding money. Needless to say, people were both sickened and terrified by his behaviour.
With a concentration of facilities for drug users around Centre Point, stories such as this may become commonplace and we ask of Council Members “Is this your vision of Camden?”

We are concerned that this current proposal will produce a public realm that further encourages the drug related crime that is already well established. It will create a further attraction that will inevitably be a target for drug dealers and drug addicts and further encourage anti-social behaviour. The consequent potential for crime and risk to community safety should be planned out, not planned in.


1. The proposal will have a serious and detrimental impact on local amenity, on local businesses, on retailers at the eastern end of Oxford Street and on local residents. It is significant that Tottenham Court Road Underground station is the principal arrival point for tourists visiting the British Museum and the proposal will also impact on tourism. It will stimulate further economic decline on Charing Cross Road and at the eastern end of Oxford Street, already blighted by indecision over Crossrail and the upgrading of Tottenham Court Road station ticket hall, and it will make business accommodation in the immediate area less attractive to occupiers. It is noted that in nearby Bedford Square, severely affected by drug dealing and open drug use, commercial rents have decreased by about 25% over the past 5 years and there are now several empty buildings.

2. This proposal will result in a distinct change to the public space of St Giles Circus, as drug users will queue up and loiter at the entrance to the Underground station. These are violent, aggressive and unpredictable people who daily rob, steal and aggressively beg to fund their addiction.
London Buses have stated that the area within 500 metres of Centre Point suffers 80% of all ticket machine crime and damage in London. Drug dealers will inevitably target the immediate and surrounding streets further encouraging open drug use, drug related acquisitive crime and anti-social behaviour.

3. The applicant states the needle exchange will be ‘policed’ by means of one Street Warden. This is inadequate provision to guarantee public safety. It should be noted that a nearby public space at Princes Circus has, after a recent refurbishment, been permanently closed by the Council.
Presumably this is because the space has become too great a risk to public safety, is too hazardous to maintain and cannot be effectively policed. We are sceptical that, if the Council is unable to manage this small area, it will be able to effectively manage and secure the proposed needle exchange.

4. The immediate surrounding area is one of intense public use and a busy transportation interchange. The proposal presents safety problems to passengers and the operators of Tottenham Court Underground station and of the buses that use the adjacent terminus on Andrew Borde Street. In particular, the proposed facility will effectively bar pedestrians from using the underpass, which is used by 2,400 people daily. They will then be displaced to the surface where there is no convenient alternative surface route to Tottenham Court Road Underground station from the eastern side of Charing Cross Road other than in the roadway in front Centre Point fountain, into the path of oncoming buses.

5. By virtue of its high levels of public transport accessibility, the facility will attract drug users and dealers from well beyond the immediate area and stimulate what is already becoming a Londonwide drugs market. The proposal will add to the concentration of London-wide facilities in the area to serve drug addicts when good land use planning would seek a dispersal of facilities closer to the catchments that they serve.

6. We do not believe that there is any justification for such an expensive proposal which does not offer any service which cannot be adequately, if not more effectively, be served from existing facilities. We support the consensus of community groups and other parties on the West End Drug Partnership, which calls for a dispersed and mixed provision of clean needles to prevent
blood-borne disease, i.e. not all concentrated in Camden, not all concentrated in Bloomsbury and not all concentrated around Centre Point.. So, rather than a stand-alone Needle Exchange, which would be a magnet to users, there should be more diffused provision through clinics, pharmacies, and hostels. Any fixed-site needle exchange should only be part of a Health Service facility, where there would be greater control and supervision, and opportunities (and pressures) to go into treatment to get off addiction.

7. The loss of public toilet facilities (allegedly because of security problems around drug abuse) is a facility that is under provided and in chronic shortage in our area. Indeed, the underpass is used as an open urinal and has the reputation of being the ‘worst underpass in Britain’.

8. The proposal will introduce a use that will detract from the character or appearance of the Denmark Street Conservation Area, within which it is located, and will damage the setting of Centre Point which is a Grade II listed building.

For the specific reasons given above, the proposal fails to satisfy the following policies of the Council’s Unitary Development Plan:

The Council seeks to conserve and strengthen the role, character and diversity of the Central London Area, balancing the demand for business and commercial development and for new cultural, retail and tourism uses with the interests of conservation and the protection of residential amenity and the objective of increasing housing provision.

The Council will seek to conserve and strengthen the strategic and international economic role of parts of Central London, promoting local and London-wide linkages and fostering wherever possible a reduction in the need for resources.

The Council will encourage an improvement in the quality of the general shopping environment and the facilities provided within it for the benefit of all users and traders and, in particular, for people with disabilities.

When considering applications for… other sui generis, non-retail uses found in shopping areas (such as sauna or massage establishments), the Council will seek to ensure that the proposal does not have an adverse impact on local environment or amenity or on the character and functioning of the centre.

The Council will seek to improve the quality of the physical environment.
The Council will protect and enhance the Borough’s heritage of townscape, buildings, landscape, archaeology and strategic and local views.

The Council will seek to ensure that developments will not have an adverse impact on the amenity of the surrounding area and the quality of the wider environment in the short- and long-term. In particular, the Council will need to be satisfied that developments, whether buildings or changes of use, protect or improve the physical environment, including the Borough’s living and working conditions, and its visual amenity.

The Council will seek to ensure that all public spaces and buildings create an attractive environment that promotes personal and collective safety and offers a high quality of design.

The Council will encourage a sensitive design approach to the built environment, which aims at reducing the opportunities for threatening and criminal behaviour and which promotes personal safety and the security of property.

The Council will resist development bordering public and private open spaces which is detrimental to their integrity, appearance and setting in terms of site, scale or massing or which, in terms of its use, is likely to intrude on the public enjoyment of those spaces.

Within predominantly residential and mixed use areas, the Council will (provided there is loss of residential floor space of amenity) encourage the provision of additional social and community facilities, open spaces and local services which provide support for residential communities. Wherever possible, the Council will resist the loss of local services and facilities which support residential communities and contribute towards the character and amenity of the residential environment.

The Council will seek to ensure that development in conservation areas preserves or enhances their special character or appearance, and is of high quality in terms of design, materials and execution.
The Council would be failing in its statutory duty as planning authority if it did not uphold the policies of its own adopted development plan.

For these reasons we urge the Council not to approve the application.
The Bloomsbury Association
28 January 2006

UPDATE – 09 Feb 2006.

We have further serious concerns that the statutory planning notices were not displayed correctly and for the correct duration plus the fact that neighbouring businesses have not been consulted to date.  Incredibly it seems that the owner of one of the businesses within the underpass has not been consulted even though this proposal, if it goes ahead will wipe out his business.

We also have concerns about apparent Conflict of Interest of Camden Executive members that promoted and drove the submission of the planning application and who also sit on the planning sub committee that will make the judgment. We have made our concerns knows to the Camden Borough Solicitor, Alison Lowton today (09.02.2006)

UPDATE 10 FEB 2006
We have been informed by the Drug and Alcohol Leader at Camden Council that they are awaiting official confirmation that TfL intend to take possession of the underpass (and needle exchange site) in mid 2007 in order to commence works in connection with Crossrail and underground works at Tottenham Court Road.

Comment:  What a complete waste of time and effort by very many people, not to mention public money, and the work by many local government agencies and officials, and the 2 years of argument on the West End Drugs Partnership!
It is a disgrace!  All caused by the incompetence and short-sightedness of the Camden DAT.  We want to see an end to this now!
Are you happy now MG?

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