Historic England (Built Environment) September response
Planning application 14/13247 ( Sept 2015 )
Historic England responded to both previous submissions with their concerns. They noted amendments made to the scheme, but remained concerned about the impacts on the settings of heritage assets.
They recognize this application is of great importance as it will signal both the determination of the council to provide an effective framework and will set the benchmark for the quality of future development over the next few years.
About Historic England
Historic England, formerly English Heritage, is the UK government's statutory adviser and a statutory consultee on all aspects of the historic environment and its heritage assets
Applications for planning permission are required to consult or notify Historic England where the development would affect the setting of a Grade I or Grade II listed building among other reasons.
Historic England's statutory remit is the impact of development proposals on the historic environment.
Historic England's concerns
This letter should be read as an addendum to Historic England's previous 11 page advice > Click here for the April response
The methodology for assessing the impact of the proposals on the setting of heritage assets was flawed ( and remains flawed )
Furthermore, in the analysis of the impacts (paras. 194-211), the report focuses on the impact on townscape views from fixed location points, without considering:
Historic England considers that the two tower elements, now proposed at 16 and 12 stories tall, are too high and are the principal causes of harm to the setting of heritage assets. The lower tower requires a reduction of 4-6 storeys to comply with the recently adopted SPD.
"In order to avoid harmful impacts on the setting of nationally and locally important heritage assets, the taller building also needs to be further reduced. The revised Townscape, Heritage and Visual Impact Assessment correctly notes that the town centre suffers from the impacts of several insensitive post-war developments (para. 17.5). These, it goes on to say, have ‘undue dominance on Kingston’s skyline in near and distant views’. Unfortunately, the current proposals still seek to match the height and prominence of these developments, outweighing efforts to draw on the positive elements of the site’s context to inform the design."
"It is disappointing that the latest proposals will not be taken back to the design review panel to provide an impartial assessment of the design quality. In our view, while the revised proposal would have a better relationship to its context than the previous designs, we consider that it would still fail to meet the advice in the Tall Buildings guidance due to the height, bulk and elements of the design, which do not preserve or enhance the setting of surrounding heritage assets."
In Historic England's view, the proposals would still cause harm to the setting of the listed buildings on the site, and detract from the setting of the Market House. Historic England considers that the development would detract from the Kingston Old Town Conservation Area and the Fairfield/Knight’s Park Conservation Areas, failing to meet the statutory test to preserve or enhance the character and appearance of locally and nationally designated heritage assets. The harm to the setting of Richmond Park, Bushy Park and Hampton Court Park and Hampton Court Palace is still perceptible and still lacks a convincing justification.
Historic England believes that whilst improved this scheme could do much more to respect its context and the unique identity of Kingston.