EDEN WALK - KRA CONCERNS
Planning application 15/13063
We have had some of these concerns for a while and have raised them in meetings with the developers. Like many - we thought it didn't look that bad earlier on. We hoped to be able to support it.
But concerns have deepened now the application is submitted. Now we can see the complete proposal, what it will be like from eye-level views such as from the street, from the parks and from the bridge.
We encourage everyone to look at the submission in pictures and make up their own mind.
It has become clear to us that in reality this is a massive over-development which we cannot support for the reasons below.
We are asking our council to REJECT this proposal in its current form.
Historic England does not support the proposal - you can read why here
OUR MAIN CONCERNS:
For this development:
1. SCALE & MASS
2. AFFORDABILITY STRUCTURE
3. NO COMMUNITY GIVE BACK
And the number of 3-or-more bed flats is too low at just 9% of the total. Policy requires 30%.
For this and all new developments:
COMBINED IMPACT ON LOCAL INFRASTRUCTURE
But concerns have deepened now the application is submitted. Now we can see the complete proposal, what it will be like from eye-level views such as from the street, from the parks and from the bridge.
We encourage everyone to look at the submission in pictures and make up their own mind.
It has become clear to us that in reality this is a massive over-development which we cannot support for the reasons below.
We are asking our council to REJECT this proposal in its current form.
Historic England does not support the proposal - you can read why here
OUR MAIN CONCERNS:
For this development:
1. SCALE & MASS
2. AFFORDABILITY STRUCTURE
3. NO COMMUNITY GIVE BACK
And the number of 3-or-more bed flats is too low at just 9% of the total. Policy requires 30%.
For this and all new developments:
COMBINED IMPACT ON LOCAL INFRASTRUCTURE
Our response to the Eden walk application, Nov 2015
Viv Evans
Head of Planning & Transport
Development Management
Guildhall 2, High Street
Kingston upon Thames
KT1 1EU
Email: [email protected]
Reference: 15/13063
Kingston Resident's Alliance
KingstonResidents.com
18th January 2016
Response from Kingston Resident's Alliance
Dear Sirs
In response to planning application 15/13063 at EDEN WALK SHOPPING CENTRE EDEN WALK KINGSTON UPON THAMES KT1 1RP.
These comments supersede any views we may have expressed previously.
Head of Planning & Transport
Development Management
Guildhall 2, High Street
Kingston upon Thames
KT1 1EU
Email: [email protected]
Reference: 15/13063
Kingston Resident's Alliance
KingstonResidents.com
18th January 2016
Response from Kingston Resident's Alliance
Dear Sirs
In response to planning application 15/13063 at EDEN WALK SHOPPING CENTRE EDEN WALK KINGSTON UPON THAMES KT1 1RP.
These comments supersede any views we may have expressed previously.
The rarity of this redevelopment opportunity and its importance to Kingston cannot be underestimated - a lot is at stake.
The developer has assembled a capable team and submitted an impressively detailed scheme. But what has been proposed is far too excessive and does not give Kingston a fair financial contribution.
Only after the plans were submitted did the full extent of the scheme become apparent. The multi-level retail / leisure offer combined with the massive residential blocks above makes the proposal truly huge and overwhelming as a whole. We are concerned about its mass and scale and its failure to meet the planning objectives and guidance for this site. It is incredulous that this £400 million development can offer no minimum payment towards Affordable Housing and no CIL payment.
We cannot support this application in its current form. We ask the Council to REFUSE this application for the reasons below.
1. SCALE & MASS
The developer has assembled a capable team and submitted an impressively detailed scheme. But what has been proposed is far too excessive and does not give Kingston a fair financial contribution.
Only after the plans were submitted did the full extent of the scheme become apparent. The multi-level retail / leisure offer combined with the massive residential blocks above makes the proposal truly huge and overwhelming as a whole. We are concerned about its mass and scale and its failure to meet the planning objectives and guidance for this site. It is incredulous that this £400 million development can offer no minimum payment towards Affordable Housing and no CIL payment.
We cannot support this application in its current form. We ask the Council to REFUSE this application for the reasons below.
1. SCALE & MASS
Height and scale
385 housing units is a very large element on top of a major multi-level retail-led complex. It is more than was rejected on the adjacent Old Post Office site. As a result the scale is massive compared to familiar landmarks such as the Grade II listed United Reformed Church next to the site.
16 storeys (59m AOD) is very high by Kingston standards, and thus requires strong justification. The drawings show it is considerably higher than the nearest tall building: Combined House, and higher even than the riverside development - currently the tallest building in the much wider vicinity and considered to be excessively high and harmful to Kingston and surrounding views. This proposal is taller than even the wider existing landscape, yet we were promised by the Leader of the Council that "Nothing taller than the existing landscape is worth looking at" - Kevin Davis at the Kingston Conversation, Mayo Center, 10 September 2015
385 housing units is a very large element on top of a major multi-level retail-led complex. It is more than was rejected on the adjacent Old Post Office site. As a result the scale is massive compared to familiar landmarks such as the Grade II listed United Reformed Church next to the site.
16 storeys (59m AOD) is very high by Kingston standards, and thus requires strong justification. The drawings show it is considerably higher than the nearest tall building: Combined House, and higher even than the riverside development - currently the tallest building in the much wider vicinity and considered to be excessively high and harmful to Kingston and surrounding views. This proposal is taller than even the wider existing landscape, yet we were promised by the Leader of the Council that "Nothing taller than the existing landscape is worth looking at" - Kevin Davis at the Kingston Conversation, Mayo Center, 10 September 2015
Impact on the setting We are concerned about the harm some aspects of the scheme will have on the surrounding streetscape; on views into and out of the neighbouring areas, and especially on the settings and protected views and historic assets such as the Old Town, Ancient Market Square and the United Reformed Church. The impact on the view from the Fairfield is particularly devastating. The Union Terrace building impacts the setting of the memorial gardens and the Old Town edge. We question how appropriate its elevation design is for the Memorial Gardens setting. It is rather basic and appears neither sympathetic nor particularly contrasting in form and detail.
The view from “Thomas Cook Passage” presents a serious clash of scale and form between the proposed building and the Market Place. It is clearly too tall. The assessment focuses on routes but fails to address the enormity of this corner of the building and its invasion into the setting of the Market Place.
The Union Street elevation is an opportunity to unite the Eden Walk development with the existing Market buildings. But instead it is very flat and monolithic and out of scale with the smaller scale buildings of the nearby Apple Market area.
Generally the assessment and mitigation of the impact on the historic assets and their settings looks weaker than we may have hoped. We cannot believe "the assessment concludes that there is a minor, neutral impact on the Grade II listed United Reformed Church" - given the proposed scale of the development that will surround it. The elevation facing the URC church is far too high, dwarfing the historic church building. |
Public spaces The improved connection and use of Memorial Gardens is welcomed, almost as a no-brainer. Unfortunately the car ramp will interrupt the visual openness, but this is one of the many challenges of this site. With the increased number of residents and general scale of the proposal - are the public spaces really big enough in proportion to what is being proposed? Will public access to upper levels be managed after hours if required? The sunny courtyard next to the United Reformed Church is a missed opportunity. This open space could become a smaller version of the successful Apple Market, with its sunny aspect and enclosure. Could a significant piece of art or water feature contribute to this space?
The current Eden Walk square is somewhat successful as a place to stop and rest: ergonomically and environmentally if not visually. But the proposal would harm this space because:
Eden street 'wall'
At street level the creation of a great monolith would harm the existing grain of the old town center, characterized by small individual plots and vertical variation in street views. The scheme has not responded in kind. Instead we agree with CABEs September 2015 statement: "The three-storey horizontal band that is the base of this [ Eden Street] block creates a datum that emphasizes the enormity of the built form. Overall, the tall building and the adjoining lower elements create an unduly imposing ‘wall’ onto Eden Street; a more successful approach would be to create individual buildings whose verticality is expressed more clearly." |
Eden Quarter Brief non-compliance A key objective of the Brief is: "To respect existing historic assets and character. New buildings must be appropriate in scale, materials and grain to their context." Height guidance in the Brief is 1-5 stories and 6-8, with one location to be 9+ stories. We are concerned that height guidance is not being adhered to across the entire site. It is between 2 and 5 stories too high throughout. The Neville Yard Winter Garden in particular is 50% higher than the guidance at 12 stories instead of 6-8. |
The 'landmark' location of 9+ storeys has for a long time been designated for this location by the Area Action Plan. However even at an excessive 16 stories, its effectiveness as a way-finding townscape marker is compromised by its crowding by the rest of the scheme. As a result the overall scale and height of the entire scheme loses its justification and becomes unacceptable. The Neville Yard Winter Garden is particularly obscuring when viewed from the Eden Street - Clarence Street corner.
Complying with the height guidance would go a long way to resolve this issue. |
2. NO AFFORDABLE HOUSING / NO CIL PAYMENT - a 'have your cake and eat it' deal
Affordable housing: No minimum amount of affordable housing and none provided on site.
"Given the high costs and risks associated with the redevelopment of an occupied center, the profitability of this scheme is very hard to predict five years before it is completed. The Partnership proposes an independently assessed financial review upon completion of the new Eden Walk, based on actual costs and revenues. This assessment would determine the size of the affordable housing contribution. This review mechanism could secure a contribution up to the equivalent of 50% affordable housing if the actual profitability of the scheme allows." - source: Letter to Officer - pdf
At the moment there is a risk that the development will do little or nothing to help provide desperately needed affordable housing for the borough and given that it is perhaps the largest single development In the borough for decades, this is not right. We recognise the risks associated with retail development but feel that the developer should factor a contribution to affordable housing (and / or CIL) within their business plan. At present their returns are protected and community benefits are entirely at risk, this seems completely unbalanced. If the council believes that housing can be delivered more effectively offsite then it should be possible for a proportionate contribution to housing / CIL to be provided for ANY profit on the project (following independently audited open book accounts). Given that BL's risk is substantially covered (ie no profit no payments) then the percentage contribution should increase progressively with % returns at the project. These payments should continue until a contribution equivalent to 50% affordable housing provision is reached. Once a minimum threshold is reached then over half of the profits should go to CIL / housing payments enabling the borough to benefit proportionately from one of its key and one off development opportunities.
WHY NO CIL payment?
The developer is not expecting to contribute money towards health, education etc as part of the new CIL : Community Infrastructure Levy (formerly s106). Normally a development of this scale would contribute millions of pounds towards improving the local infrastructure. As with affordable housing, they are claiming poverty via the Viability Report.
"A Viability Report forms part of the application. This Report assesses the viability of the scheme and its ability to make a contribution under the recently adopted Kingston CIL Charging Schedule.
If the Councils Independent Valuer accepts the conclusions of the Viability Report, and in the event planning permission is granted, the Partnership would make a claim in accordance with regulation 55 of the Community Infrastructure Levy Regulations 2010 for Exceptional Circumstances Relief from the Kingston CIL." - source: Letter to Officer - pdf
We believe any evaluation of the viability of CIL / housing contributions should take into account the skills, experience and size of BL. This means that their ability to manage risks and to raise capital at low costs (remembering that Bank of England base rates are still 0.5%) should be such that a target return of 20% or higher may not be appropriate. There is a massive difference between a SME builder developing 10 homes and one of the top 5 developers in the country delivering billion's of pounds worth of projects like this every year.
3. NO COMMUNITY GIVE BACK
The Eden Walk regeneration is the largest single development in the borough for decades. What does this proposed development say about Kingston’s future character, aspirations and identity? What is it giving back to existing community?
“A destination for more shops?” Is that all there is?
We again note the Eden Quarter Development Brief to developers which says:
“Kingston Town Centre has a unique heritage and character and it is important that any new development enhances and reinforces this sense of place.” EQDB, p15
A regeneration project as big as Eden Walk should have addressed what kind of urban identity BL / USS is offering to Kingston’s residents, not just to visiting shoppers. For Kingston residents, Eden Walk is a kind of high street. It is their community space. Locals go there and ‘spend time,’ not just ‘shop’. Why is there no room for music, art, a children’s play area or even a little a space for Kingston University graduates to showcase their skills, etc. Nothing holistic is on offer. Just better shopping facilities, together with a massive housing development with no homes made affordable for local residents, not even a shelter for the town centre homeless.
Are the developers forgetting yet another objective of the Eden Quarter Development brief? to us this omission also signifies a lack of something more serious. It is fine and good if the Council want to improve the shopping experience and bring more trade (and revenue) to town, but this is also a once in a life time opportunity for developers, policy makers and residents to add a new layer of meaning to the rich tapestry of Kingston as a place to live for future generations. Otherwise in five years all we will get is a New Mecca for shoppers, more traffic and less of a community feel.
4) IMPACT ON INFRASTRUCTURE
We are very concerned over the cumulative effect of this proposal together with other recent and planned developments on our creaking and over burdened infrastructure.
"the net increase in population is projected to be 634. This is approximately an 5.8% increase in the population of Grove, and a 0.4% increase in the population of Kingston." - source: Document - pdf
The massive Eden Walk Regeneration plans are in addition to :
1 Eden Street Redevelopment
2 The Old Post Office (TOPO) redevelopment,
3 The Cattle Market Redevelopment,
4 New student block opposite Wilko,
5 Sury Basin Redevelopment opposite Sainsburys,
6 Thames Side Wharf thing behind John Lewis,
7 Earmarked redevelopment of the Hippodrome.
8 Gough House
9 Swan House,
10 The Dairy Crest Site
Residents have asked for a CUMULATIVE INFRASTRUCTURE IMPACT assessment from the council. We are still waiting for evidence that decision makers, developers and planners have been assessing the rising need for school, health and transport provisions as the multitude of developments come to fruition and are occupied.
We cannot accept all these massive developments including this Eden Walk Regeneration without better improvements in infrastructure and appropriate consultation with the community on their cumulative impact as a whole.
Affordable housing: No minimum amount of affordable housing and none provided on site.
"Given the high costs and risks associated with the redevelopment of an occupied center, the profitability of this scheme is very hard to predict five years before it is completed. The Partnership proposes an independently assessed financial review upon completion of the new Eden Walk, based on actual costs and revenues. This assessment would determine the size of the affordable housing contribution. This review mechanism could secure a contribution up to the equivalent of 50% affordable housing if the actual profitability of the scheme allows." - source: Letter to Officer - pdf
At the moment there is a risk that the development will do little or nothing to help provide desperately needed affordable housing for the borough and given that it is perhaps the largest single development In the borough for decades, this is not right. We recognise the risks associated with retail development but feel that the developer should factor a contribution to affordable housing (and / or CIL) within their business plan. At present their returns are protected and community benefits are entirely at risk, this seems completely unbalanced. If the council believes that housing can be delivered more effectively offsite then it should be possible for a proportionate contribution to housing / CIL to be provided for ANY profit on the project (following independently audited open book accounts). Given that BL's risk is substantially covered (ie no profit no payments) then the percentage contribution should increase progressively with % returns at the project. These payments should continue until a contribution equivalent to 50% affordable housing provision is reached. Once a minimum threshold is reached then over half of the profits should go to CIL / housing payments enabling the borough to benefit proportionately from one of its key and one off development opportunities.
WHY NO CIL payment?
The developer is not expecting to contribute money towards health, education etc as part of the new CIL : Community Infrastructure Levy (formerly s106). Normally a development of this scale would contribute millions of pounds towards improving the local infrastructure. As with affordable housing, they are claiming poverty via the Viability Report.
"A Viability Report forms part of the application. This Report assesses the viability of the scheme and its ability to make a contribution under the recently adopted Kingston CIL Charging Schedule.
If the Councils Independent Valuer accepts the conclusions of the Viability Report, and in the event planning permission is granted, the Partnership would make a claim in accordance with regulation 55 of the Community Infrastructure Levy Regulations 2010 for Exceptional Circumstances Relief from the Kingston CIL." - source: Letter to Officer - pdf
We believe any evaluation of the viability of CIL / housing contributions should take into account the skills, experience and size of BL. This means that their ability to manage risks and to raise capital at low costs (remembering that Bank of England base rates are still 0.5%) should be such that a target return of 20% or higher may not be appropriate. There is a massive difference between a SME builder developing 10 homes and one of the top 5 developers in the country delivering billion's of pounds worth of projects like this every year.
3. NO COMMUNITY GIVE BACK
The Eden Walk regeneration is the largest single development in the borough for decades. What does this proposed development say about Kingston’s future character, aspirations and identity? What is it giving back to existing community?
“A destination for more shops?” Is that all there is?
We again note the Eden Quarter Development Brief to developers which says:
“Kingston Town Centre has a unique heritage and character and it is important that any new development enhances and reinforces this sense of place.” EQDB, p15
A regeneration project as big as Eden Walk should have addressed what kind of urban identity BL / USS is offering to Kingston’s residents, not just to visiting shoppers. For Kingston residents, Eden Walk is a kind of high street. It is their community space. Locals go there and ‘spend time,’ not just ‘shop’. Why is there no room for music, art, a children’s play area or even a little a space for Kingston University graduates to showcase their skills, etc. Nothing holistic is on offer. Just better shopping facilities, together with a massive housing development with no homes made affordable for local residents, not even a shelter for the town centre homeless.
Are the developers forgetting yet another objective of the Eden Quarter Development brief? to us this omission also signifies a lack of something more serious. It is fine and good if the Council want to improve the shopping experience and bring more trade (and revenue) to town, but this is also a once in a life time opportunity for developers, policy makers and residents to add a new layer of meaning to the rich tapestry of Kingston as a place to live for future generations. Otherwise in five years all we will get is a New Mecca for shoppers, more traffic and less of a community feel.
4) IMPACT ON INFRASTRUCTURE
We are very concerned over the cumulative effect of this proposal together with other recent and planned developments on our creaking and over burdened infrastructure.
"the net increase in population is projected to be 634. This is approximately an 5.8% increase in the population of Grove, and a 0.4% increase in the population of Kingston." - source: Document - pdf
The massive Eden Walk Regeneration plans are in addition to :
1 Eden Street Redevelopment
2 The Old Post Office (TOPO) redevelopment,
3 The Cattle Market Redevelopment,
4 New student block opposite Wilko,
5 Sury Basin Redevelopment opposite Sainsburys,
6 Thames Side Wharf thing behind John Lewis,
7 Earmarked redevelopment of the Hippodrome.
8 Gough House
9 Swan House,
10 The Dairy Crest Site
Residents have asked for a CUMULATIVE INFRASTRUCTURE IMPACT assessment from the council. We are still waiting for evidence that decision makers, developers and planners have been assessing the rising need for school, health and transport provisions as the multitude of developments come to fruition and are occupied.
We cannot accept all these massive developments including this Eden Walk Regeneration without better improvements in infrastructure and appropriate consultation with the community on their cumulative impact as a whole.
Page updated on 26 Jan 2016