On 2nd June, we attempted to present this in the short time given. Here is the Full Text version.
Heritage
My name is Anthony Evans. I am representing the Kingston Society's Executive Committee tonight. As I have stated previously, I have been a member of the Society for over 45 years, I have worked in public authorities as an architect and planning officer for 20 years, and finally, as a conservation and design officer for an adjoining planning authority for 18 years until 2013.
Kingston Society is fundamentally opposed to the loss of character to Kingston town centre, the damaging impact upon a considerable number of heritage assets close to or on this site, and the detrimental visual impact it would have on the wider area of the town. When I made our presentation to the Kingston Town Centre Committee on 14 May, I talked about the NPPF and the words used in their and other guidance notes, the English Heritage Good Practice Guide and furthermore in the 1990 Listed Buildings' Act. I will state once again, slowly and clearly:
The Borough Council has an absolute duty when considering whether to approve or refuse such an application as this. It should not approve proposals which damage heritage assets. A scheme should aim to preserve and enhance the setting of such heritage assets. There are many heritage assets on or adjacent to this site — i.e. four listed buildings and three conservation areas. All Saints' Church is grade I-listed, the Market House is grade II*, and there are two more grade II-listed buildings on the site itself.
In addition, there are very substantial objections to this scheme from the Victorian Society, which objects in no uncertain terms to the damaging impact it would have on the two listed buildings and the three adjacent conservation areas. I'll quote briefly from their letter:
'We object to the proposed scheme, which would cause harm to the setting of the two listed buildings on the site and harm to the setting and character of the Kingston Old Town, and Fairfield and Knight’s Park Conservation Areas. The proposed new buildings would be damagingly large and out of scale with their surroundings. They would dramatically and detrimentally affect the setting of the listed buildings, the CGIs included in the application documents clearly demonstrate the startling and and negative impact the new buildings would have on this conservation area's setting, and views from within.’
They talk about the obtrusive scale of the new development, and it would have a similarly damaging on the setting and the character of the Old Town. Next, the Historic Royal Palaces is unconvinced by the developer's amended views of this scheme upon Hampton Court. They have, and I quote:
'…ongoing concerns about the visual impact of the proposed tower block.’
Now I turn to Historic England, the national body charged by Government to advise on national and local heritage—a body which all local authorities should respect, as they employ officers who are qualified and experienced in dealing with such heritage. Historic England have written eleven pages of considerable criticism about this scheme. I don't know if members here tonight have read all eleven pages; if they have, they can be in no doubt whatsoever as to the damaging impact that this development will have upon Kingston town centre and the wider residential areas around it, and upon the Royal Parks and Palace, which would be affected by it.
Historic England quote time and time again what is clearly stated by the NPPF, the London Plan, the council's own Eden Quarter SPD, and other approved national guidance documents. Paragraph after paragraph, throughout the eleven page letter, they highlight what a detrimental impact this scheme would have. I'd like to mention some of those important sentences from Historic England's letter:
'We consider that, in relation to the whole historic environment affected by the scheme, this proposal does not meet the Government's definition of sustainable development, set out in the NPPF. We note that it does not meet your detailed guidance for development on this site, the Eden Quarter SPD 2015, and so for these reasons we cannot support the application. Other buildings in the locality are listed at all grades, the site is adjacent to a number of conservation areas.' etc. etc.
The Royal Borough of Kingston is fortunate to sit within a unique cluster of the most highly graded landscapes in England. This Arcadian Thames landscape contains the Grade I-registered Richmond Park, Bushy Park and Hampton Court Park. These parks are also of great historic significance, bound up as they are with royal associations. Again, the proposals would be visible from Hampton Court Palace and would affect its setting. The importance of the setting of Hampton Court Palace and its environments cannot be over-emphasised. The Palace is a scheduled Ancient Monument and a complex of international importance. Historic England agrees with the assessment made in the Alan Baxter Associate's Heritage report of December 2014, that the impact on the settings of the two listed buildings on the site would harmful, due to the height and massing of the new proposals.
We consider that the assessment methodology adopted does not accord with the Historic Environment Good Practice advice in Planning Note 'The Setting of Heritage Assets', which was published earlier by Heritage England. The advice note sets out a five-step approach, of which only the first step has been covered by the TVIBH. The top of the proposed tower, notably the glazed upper storeys, would be particularly obtrusive after dusk, when it would appear as an internally illuminated beacon.
There are currently very limited intrusions to the historic skyline and the marketplace, the most notable, Kingston College, causes demonstrable harm to the setting of the conservation area and the Market House. This would be exacerbated and surpassed by the proposed development, with its highly glazed upper floors and its prominence beside the market house. This harm to setting would be replicated for the registered landscapes. They say: it would have a major impact on the setting of the Fairfield and Knight's Park Conservation Area, with the 19-storey tower becoming a prominent feature from many locations in the Conservation Area. Fairfield Park, where the development would be visually dominant, this would radically change the setting of the park and the Conservation Area.
Historic England has also concerns about the methodology employed in the TVIBH. Secondly, we do not agree with the applicants about the urban design and architectural merits of their proposals, which appear to the principal reason for it describing many of the impacts in a neutral or positive manner. When considering whether to grant Planning Permission, section 66 of the Listed Buildings & Conservation Areas Act 1990 places a duty on the authority to consider the impact of the development proposals upon listed buildings and their settings. The authority shall have 'special regard to the desirability of preserving the building or its setting, or any feature of special architectural or historic interest which it possesses.
The setting and the contribution it makes to significance have statutory protection, which the views affected by this development does not. Section 72 of the Act requires local authorities to have special regard to the desirability of preserving or enhancing the character or appearance of conservation areas.
And so it goes on and on and on... finally, on May 14th I made two other major criticisms of this proposal: one was about affordable housing, which my colleague on my right has already covered; the other was about the public realm.
The developers have made great play on this as being a great benefit, and we have considerably challenged this description. In reality, most of this so-called 'public realm' is a large area of paved and set-aside for restaurant customers, and on the opposite side access to all the new retail units and entrances to the flats. The amount of actual area available to the public to enjoy is relatively small. It has minimal landscaping for people to use, and furthermore it will be overshadowed by vey tall blocks and will receive low levels of sunlight, due to its north-facing position. We therefore challenge the developer's assertions about being a major benefit.
Thank you, Chairman.
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Kingston Society is fundamentally opposed to the loss of character to Kingston town centre, the damaging impact upon a considerable number of heritage assets close to or on this site, and the detrimental visual impact it would have on the wider area of the town. When I made our presentation to the Kingston Town Centre Committee on 14 May, I talked about the NPPF and the words used in their and other guidance notes, the English Heritage Good Practice Guide and furthermore in the 1990 Listed Buildings' Act. I will state once again, slowly and clearly:
The Borough Council has an absolute duty when considering whether to approve or refuse such an application as this. It should not approve proposals which damage heritage assets. A scheme should aim to preserve and enhance the setting of such heritage assets. There are many heritage assets on or adjacent to this site — i.e. four listed buildings and three conservation areas. All Saints' Church is grade I-listed, the Market House is grade II*, and there are two more grade II-listed buildings on the site itself.
In addition, there are very substantial objections to this scheme from the Victorian Society, which objects in no uncertain terms to the damaging impact it would have on the two listed buildings and the three adjacent conservation areas. I'll quote briefly from their letter:
'We object to the proposed scheme, which would cause harm to the setting of the two listed buildings on the site and harm to the setting and character of the Kingston Old Town, and Fairfield and Knight’s Park Conservation Areas. The proposed new buildings would be damagingly large and out of scale with their surroundings. They would dramatically and detrimentally affect the setting of the listed buildings, the CGIs included in the application documents clearly demonstrate the startling and and negative impact the new buildings would have on this conservation area's setting, and views from within.’
They talk about the obtrusive scale of the new development, and it would have a similarly damaging on the setting and the character of the Old Town. Next, the Historic Royal Palaces is unconvinced by the developer's amended views of this scheme upon Hampton Court. They have, and I quote:
'…ongoing concerns about the visual impact of the proposed tower block.’
Now I turn to Historic England, the national body charged by Government to advise on national and local heritage—a body which all local authorities should respect, as they employ officers who are qualified and experienced in dealing with such heritage. Historic England have written eleven pages of considerable criticism about this scheme. I don't know if members here tonight have read all eleven pages; if they have, they can be in no doubt whatsoever as to the damaging impact that this development will have upon Kingston town centre and the wider residential areas around it, and upon the Royal Parks and Palace, which would be affected by it.
Historic England quote time and time again what is clearly stated by the NPPF, the London Plan, the council's own Eden Quarter SPD, and other approved national guidance documents. Paragraph after paragraph, throughout the eleven page letter, they highlight what a detrimental impact this scheme would have. I'd like to mention some of those important sentences from Historic England's letter:
'We consider that, in relation to the whole historic environment affected by the scheme, this proposal does not meet the Government's definition of sustainable development, set out in the NPPF. We note that it does not meet your detailed guidance for development on this site, the Eden Quarter SPD 2015, and so for these reasons we cannot support the application. Other buildings in the locality are listed at all grades, the site is adjacent to a number of conservation areas.' etc. etc.
The Royal Borough of Kingston is fortunate to sit within a unique cluster of the most highly graded landscapes in England. This Arcadian Thames landscape contains the Grade I-registered Richmond Park, Bushy Park and Hampton Court Park. These parks are also of great historic significance, bound up as they are with royal associations. Again, the proposals would be visible from Hampton Court Palace and would affect its setting. The importance of the setting of Hampton Court Palace and its environments cannot be over-emphasised. The Palace is a scheduled Ancient Monument and a complex of international importance. Historic England agrees with the assessment made in the Alan Baxter Associate's Heritage report of December 2014, that the impact on the settings of the two listed buildings on the site would harmful, due to the height and massing of the new proposals.
We consider that the assessment methodology adopted does not accord with the Historic Environment Good Practice advice in Planning Note 'The Setting of Heritage Assets', which was published earlier by Heritage England. The advice note sets out a five-step approach, of which only the first step has been covered by the TVIBH. The top of the proposed tower, notably the glazed upper storeys, would be particularly obtrusive after dusk, when it would appear as an internally illuminated beacon.
There are currently very limited intrusions to the historic skyline and the marketplace, the most notable, Kingston College, causes demonstrable harm to the setting of the conservation area and the Market House. This would be exacerbated and surpassed by the proposed development, with its highly glazed upper floors and its prominence beside the market house. This harm to setting would be replicated for the registered landscapes. They say: it would have a major impact on the setting of the Fairfield and Knight's Park Conservation Area, with the 19-storey tower becoming a prominent feature from many locations in the Conservation Area. Fairfield Park, where the development would be visually dominant, this would radically change the setting of the park and the Conservation Area.
Historic England has also concerns about the methodology employed in the TVIBH. Secondly, we do not agree with the applicants about the urban design and architectural merits of their proposals, which appear to the principal reason for it describing many of the impacts in a neutral or positive manner. When considering whether to grant Planning Permission, section 66 of the Listed Buildings & Conservation Areas Act 1990 places a duty on the authority to consider the impact of the development proposals upon listed buildings and their settings. The authority shall have 'special regard to the desirability of preserving the building or its setting, or any feature of special architectural or historic interest which it possesses.
The setting and the contribution it makes to significance have statutory protection, which the views affected by this development does not. Section 72 of the Act requires local authorities to have special regard to the desirability of preserving or enhancing the character or appearance of conservation areas.
And so it goes on and on and on... finally, on May 14th I made two other major criticisms of this proposal: one was about affordable housing, which my colleague on my right has already covered; the other was about the public realm.
The developers have made great play on this as being a great benefit, and we have considerably challenged this description. In reality, most of this so-called 'public realm' is a large area of paved and set-aside for restaurant customers, and on the opposite side access to all the new retail units and entrances to the flats. The amount of actual area available to the public to enjoy is relatively small. It has minimal landscaping for people to use, and furthermore it will be overshadowed by vey tall blocks and will receive low levels of sunlight, due to its north-facing position. We therefore challenge the developer's assertions about being a major benefit.
Thank you, Chairman.
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