Our Key Objections
Planning application 14/13247
The following Key Objections were read out to the Thursday 14 May Kingston Town Neighbourhood Committee meeting
and emailed to the Development Control Committee members.
We welcome new development but it is very clear that the proposal seeks to over-develop this sensitive site. It is too dense, too high and there is too little justification for the many and significant policy contraventions. Our Council should not lose sight of its obligation to existing and future residents and our local community, to protect and enhance our existing environment. This planning application in its current form should be rejected for the 9 reasons set out below:
The following Key Objections were read out to the Thursday 14 May Kingston Town Neighbourhood Committee meeting
and emailed to the Development Control Committee members.
We welcome new development but it is very clear that the proposal seeks to over-develop this sensitive site. It is too dense, too high and there is too little justification for the many and significant policy contraventions. Our Council should not lose sight of its obligation to existing and future residents and our local community, to protect and enhance our existing environment. This planning application in its current form should be rejected for the 9 reasons set out below:
1. Visual Impact & Conservation Areas
2. Affordable Housing 3. Height & Scale 4. Aesthetics, Architecture, & Heritage 5. Density |
6. Sustainability
7. Parking, Transport, Infrastructure and Services 8. Ineffective public consultation 9. Public Realm |
1. Visual Impact & Conservation Areas: The visual enjoyment of Kingston as a unique space with its surrounding conservation areas is a key consideration in any large development in or near the town centre. The inclusion of tall buildings in this development plan will have a significant visual impact on the Ancient Market and Fairfield Park.
For the revised proposal, with the lowering of Tower J and the changes to its massing, the negative impact is slightly reduced. However the updated Visual Impact and Built Heritage Assessment study is still disappointing in its interpretation and conclusions. It is less than impartial, playing down the impact in favour of the development. Dominance of trees in visualizations, on roof tops and "partially obscured by trees" statements all point to a lack of architectural merit. This is a general point that applies throughout the submission.
For the revised proposal, with the lowering of Tower J and the changes to its massing, the negative impact is slightly reduced. However the updated Visual Impact and Built Heritage Assessment study is still disappointing in its interpretation and conclusions. It is less than impartial, playing down the impact in favour of the development. Dominance of trees in visualizations, on roof tops and "partially obscured by trees" statements all point to a lack of architectural merit. This is a general point that applies throughout the submission.
The loss of a picture perfect ancient market square will have an adverse impact on this highly important and sensitive amenity. Policy 7.7 of the Area Action Plans states “Primary landmarks within the OTCA include the towers to All Saint’s Church and the Guildhall and Kingston Bridge, which need to be protected, along with the important views and vista towards and within the OTCA. Protection should be through sensitive control of height and massing of any new development. The images below show a clear infringement of this policy on a highly sensitive area, and the development risks taking away the historic sense of place, which makes Kingston Town Centre a unique shopping and tourist destination. We would note that in the photo below provided in the visual impact documents, the towering buildings can be seen clearly rising above listed and “townscape merit” buildings. This is, needless to say, visually out of character with the historic Market House and contrary to conservation principles.
From the vantage point of Fairfield Park (above), the development will have a significant and detrimental impact on the enjoyment of this open-spaced amenity. The view of the development toward the west from the Fairfield impinges upon the sense of open space which is such a valuable asset to the park. The National Planning Policy Guideline (NPPG) states that “Open space should be taken into account in planning for new development, which can take many forms and provide health and recreation benefits. Consistent with the NPPF, the NPPG notes that as well as being an important part of the landscape and setting of built development, open space is an important component in the achievement of sustainable development.” While loss of view is not typically a material consideration, the degradation of one of Kingston’s vital open spaces can certainly be considered as an important objection.
In defense the submission states it "will help draw focus away from poor quality tall buildings currently seen [from the Fairfield]" - Many things could have this effect which is not a measure of quality or improvement. One eye-sore can draw focus from another.
In defense the submission states it "will help draw focus away from poor quality tall buildings currently seen [from the Fairfield]" - Many things could have this effect which is not a measure of quality or improvement. One eye-sore can draw focus from another.
Section 6.8 of the Area Action Plan reads: “Key views to landmarks and wider panoramas (Plan 6), together with local views, (Chapter 7 and Part C of this
AAP) contribute variety and interest to Kingston’s townscape, they reinforce its sense of place and are a valuable part of its built heritage." One of the key panoramas is that from the Kingston Bridge coming from the direction of Hampton Court with the view of All Saints Church, which presently dominates the skyline. The Old Post Office plan will drastically alter this view as seen in the picture (right) provided by the Visual Impact documents; the tower will become the dominant feature of the cityscape, drastically altering this historic panorama.
View of the Kingston skyline from Kingston Bridge.
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To read more about the Kingston Town Centre Area Action Plan, click here.
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An additional consideration is the impact of this development on the skyline from the vantage point of Richmond Park (below). It can be argued that this is a major change with an adverse penetration into a highly sensitive view, not “moderate” as stated in the Visual Impact documentation.
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Key views meant to be protected by the Council.
2. Affordable Housing: There is insufficient Affordable Housing and the CIL and S. 106 contributions are not specified.
St George’s affordable housing provision is currently 60 out of 360 homes within Scenario A. This amounts to just under 17% for the development - and falls well short of the guidelines laid out in Kingston Council’s Affordable Housing SPD. Policy DM15 on Affordable Housing states that “The delivery of affordable housing is a key priority and the Council will seek to maximise its provision. To achieve this the Council will work with partners to,… On sites of 10 or more units, require 50% of the units to be provided as affordable housing.”
The submissions Affordable housing Statement states in item 4.8 : "financial viability is key consideration in determining affordable housing and other financial obligations". - It is impossible to assess this due to the secrecy of the financial viability report. We are told that the listed building restoration costs are high, but there is great doubt that this can be used to fully justify the over-development of the site and the extent of its compliance failure.
Kingston Councils' Affordable Housing SPD states "The financial implications of complying with the affordable housing policy need to be factored into the land value when purchasing a site. If no regard is paid to these implications the resultant financial consequences will have to be borne by the developer."
The application has failed to provide sufficient affordable housing with this application, either within the development or elsewhere within the Borough. The development is therefore contrary to the Affordable Housing SPD on affordable housing provision. Again the proposal fails to comply by a large measure.
St George’s affordable housing provision is currently 60 out of 360 homes within Scenario A. This amounts to just under 17% for the development - and falls well short of the guidelines laid out in Kingston Council’s Affordable Housing SPD. Policy DM15 on Affordable Housing states that “The delivery of affordable housing is a key priority and the Council will seek to maximise its provision. To achieve this the Council will work with partners to,… On sites of 10 or more units, require 50% of the units to be provided as affordable housing.”
The submissions Affordable housing Statement states in item 4.8 : "financial viability is key consideration in determining affordable housing and other financial obligations". - It is impossible to assess this due to the secrecy of the financial viability report. We are told that the listed building restoration costs are high, but there is great doubt that this can be used to fully justify the over-development of the site and the extent of its compliance failure.
Kingston Councils' Affordable Housing SPD states "The financial implications of complying with the affordable housing policy need to be factored into the land value when purchasing a site. If no regard is paid to these implications the resultant financial consequences will have to be borne by the developer."
The application has failed to provide sufficient affordable housing with this application, either within the development or elsewhere within the Borough. The development is therefore contrary to the Affordable Housing SPD on affordable housing provision. Again the proposal fails to comply by a large measure.
3. Height & Scale: Due to its excessive, bulk, scale, height and massing, the proposal would:
- Produce a development which would dominate and fail to respond to the surrounding prevailing heights in its immediate context. At 61.6 m high, Tower J breaches current tall building heights in the vicinity (Unilever House approx 35m, Kingston College approx 51m). This is especially important as it will set a new height precedent for later planning submissions in the vicinity.
- Fail to meet the requirements for tall buildings in the London Plan. Policy 7.7 states "The impact of tall buildings proposed in sensitive locations should be given particular consideration. Such areas might include conservation areas, listed buildings and their settings, registered historic parks and gardens, scheduled monuments, battlefields, the edge of the Green Belt or Metropolitan Open Land, World Heritage Sites or other areas designated by boroughs as being sensitive or inappropriate for tall buildings."
- Have an adverse impact on the urban form in this part of the town. This development is inappropriate in that it would cause significant harm to short-range views and the related public realm by overbearing and dominating the surrounding streets and buildings, in particular the two listed buildings on the site, Ashdown Road, the site to the North of Ashdown Road, and the two storey Victorian conservation areas to the South and East. From a point of view of human scale, the perception could be overwhelming from ground level. The 13 storey tower on Ashdown Road will compromise the site to the North of Ashdown Road, in terms of overbearing, daylight, sunlight and overshadowing. The impact of the development on the daylight and sunlight received by other buildings or sites in the vicinity would be a substantial omission if it is not addressed by the Environmental Statement.
Due to its excessive bulk, scale, height and massing, the development would fail to meet the requirements as set out in the recently adopted Eden Quarter Development Brief SPD (the Brief) for this specific location. It should be noted that many considered this Supplementary Planning Document to be more than generous in it's height guidance.
Landmark tower: Section 4 identifies the south west corner as an opportunity for a landmark with "especially high quality design" and Section 3.5 gives a guidance of 9+ storeys for this landmark tower. The proposed submission has interpreted 9+ storeys to mean that there is effectively ‘no limit’ on height for this corner of the site. The Brief does not stipulate a storey ‘cap’ in words, but the section drawings of the suggested buildings and artists impressions throughout the Brief show nothing above 13 storeys. 13 is a reasonable interpretation of '9+ storeys'. The proposed 19 storeys - more than double '9 storeys' - is not a reasonable interpretation of '9+ storeys'. It is clear the development is disregarding the spirit of the Brief specific to this context. Ashdown Road tower: Section 3.5 in the Brief gives a guidance of 6-8 storeys across the rest of the site.
With the proposed 13 storey Ashdown Road tower, again the development would fail to meet the Brief's requirements on height - and again not just marginally. It would be 50% taller than the height specified by the Brief. This creates the additional problem of competing for prominence with the corner designated as 'landmark' by the Brief. |
Eden Quarter Development Brief SPD
Section 3.5 HEIGHTS, SCALE AND MASSING: "Heights generally range from one to eight storeys, with the exact scale informed by a number of factors including the generally low rise nature of the town centre, significant heritage assets, viewing corridors, building typology and enclosure of spaces. In specific places more significant height has been proposed.... The council will require an exemplar standard of design for taller buildings in order to justify taller editions to the skyline. Applicants should provide a clear justification and rationale for the position and design of tall buildings making reference to policy CS8 in the Core Strategy (2012)." |
The excessive, bulk, scale, height and massing would cause significant harm for the following reasons: harm to short, medium and long range views; harm to the setting of the listed buildings on the site, harm to to the conservation areas adjacent; harm to the skyline.
The Brief does not stipulate a storey ‘cap’ in words, but the section drawings of the proposed buildings and artists impressions show nothing above 13 storeys. The proposal is clearly at odds with the scale envisaged by the Brief.
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We agree with the South East Regional Design Panel (SERDP) report where they state "The 13 storey block...fails to meet the requirement of the height guidance Brief to be sensitive to the scale and material pallet of the listed buildings"
It is surprising to see no new basements in the scheme - only the existing old post office and Telegraph buildings will have basements. For neighbouring residents, an efficient use of the site would naturally include a basement. Indeed they would be refused planning permission to build upwards so expanding down into basements can be the only option. There is a strong perception that planning rules may not apply fairly to all when we see this proposal's 13 flouting the generous 6 - 8 storey provision given in the Brief - and without building below ground.
The proposed development must be modified to comply with the generous height guidance given by the Eden Quarter Development brief SPD. Landmark Tower J should be reduced to 9-13 storeys and the Ashdown Road Tower to 6-8 storeys.
The proposal fails to comply with the Brief by a large measure.
It is surprising to see no new basements in the scheme - only the existing old post office and Telegraph buildings will have basements. For neighbouring residents, an efficient use of the site would naturally include a basement. Indeed they would be refused planning permission to build upwards so expanding down into basements can be the only option. There is a strong perception that planning rules may not apply fairly to all when we see this proposal's 13 flouting the generous 6 - 8 storey provision given in the Brief - and without building below ground.
The proposed development must be modified to comply with the generous height guidance given by the Eden Quarter Development brief SPD. Landmark Tower J should be reduced to 9-13 storeys and the Ashdown Road Tower to 6-8 storeys.
The proposal fails to comply with the Brief by a large measure.
The Old Post Office and Telephone Exchange buildings would be dwarfed by the 13 and 19-storey buildings. The scale is clearly out of proportion.
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The proposed development largely overshadows the Old Post Office and Telephone Exchange, and is clearly over-bearing and out of character with historic flavour of the town centre. The Council’s Policy DM 12 states clearly that it will “Allow alterations which preserve or enhance the established character and architectural interest of a heritage asset, its fabric or its setting.” We believe that the proposed development fails precisely to maintain the character of the setting of these old historic assets.
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4. Aesthetics, Architecture, & Heritage: While the architectural merits of any building can be said to be in the eyes of the beholder, it is clear that very few, if any, high-rise buildings in the Royal Borough of Kingston have added lasting historical, cultural, or architectural value. The use of materials proposed by St George in this development plan are not only unattractive and not at all reflective of the historical flavour of the town centre, but they will also likely fade over time and will in the long-term fail to add to the character and desirability of Kingston Town Centre. Paragraph 63 of the NPPF states that “In determining applications, great weight should be given to outstanding or innovative designs which help raise the standard of design more generally in the area.” Moreover the Eden Quarter Development Brief SPD calls for "especially high quality design" and "an exemplar standard of design for taller buildings" The design proposed by St George fails to meet this requirement. It lacks innovation and is visually similar to other existing, less unattractive buildings in the area.
The development is not designed by an architect known to be highly regarded, and a Design Review Panel was only engaged very late in the process. This latter point was made by the South East Regional Design Panel (SERDP) that was "engaged after the scheme was well advanced; been for public consultation and a full planning application had been submitted" and the amended design was well on its way. This points to insufficient commitment to visual design quality from the outset.
The development is not designed by an architect known to be highly regarded, and a Design Review Panel was only engaged very late in the process. This latter point was made by the South East Regional Design Panel (SERDP) that was "engaged after the scheme was well advanced; been for public consultation and a full planning application had been submitted" and the amended design was well on its way. This points to insufficient commitment to visual design quality from the outset.
Policy DM 12 states that the Council will also “Ensure that development proposals affecting historic assets will use high quality materials and design features which incorporate or complement those of the host building or the immediate area.” Furthermore, Policy Guidance 29 states that “Care should be taken to ensure the replication of detailing or materials present in the streetscene or local area represents an authentic synthesis of local architectural styles that compliment those of the host building or surrounding area. Development proposals which include the use of materials or detailing which is out of context or is lacking in imagination or character will not be encouraged.” We believe that the Old Post Office Development Plan proposal fails to incorporate materials and detailing features that complement the historic nature of the listed host buildings. The quality of materials proposed also raises a few questions as they do not largely reflect the traditional materials found in and around Kingston: stone, brick, tile hanging, exposed timber, slate, etc.
The elevations lack significant architectural distinction, quality and interest. The Planning Submission Addendum states in item 4.6: “tall buildings *can* make a positive contribution…” - but this doesn’t mean they *will*
The 21 storey version of the landmark tower - referred to by some as the 'fag packet' - is reduced in height and massing in this latest submission, but is it now an 'exemplar standard of design' worthy of its "skyline-breaking", precedent-making 19 storey height? No. Rather, it appears to have a confused identity and lack of confidence. It can be argued that the proposed buildings do not stand out in any innovative or imaginative way in comparison to the many unsuccessful buildings found throughout the borough. The attempt at making this a “landmark” building has clearly failed. Ideally Kingston should be purged of architectural mistakes, but this could be adding to them. It should be noted that policy 6.11 of the Area Action Plan states that “’Landmark’ status does not imply tall buildings, as can be seen from Kingston’s existing landmarks, which are all of modest scale.
We agree with SERDP's statement that the tower must set a benchmark for architectural quality. But that "the architectural quality of the tallest tower is not yet sufficient to justify its very considerable prominence in the local and wider townscape"
The elevations lack significant architectural distinction, quality and interest. The Planning Submission Addendum states in item 4.6: “tall buildings *can* make a positive contribution…” - but this doesn’t mean they *will*
The 21 storey version of the landmark tower - referred to by some as the 'fag packet' - is reduced in height and massing in this latest submission, but is it now an 'exemplar standard of design' worthy of its "skyline-breaking", precedent-making 19 storey height? No. Rather, it appears to have a confused identity and lack of confidence. It can be argued that the proposed buildings do not stand out in any innovative or imaginative way in comparison to the many unsuccessful buildings found throughout the borough. The attempt at making this a “landmark” building has clearly failed. Ideally Kingston should be purged of architectural mistakes, but this could be adding to them. It should be noted that policy 6.11 of the Area Action Plan states that “’Landmark’ status does not imply tall buildings, as can be seen from Kingston’s existing landmarks, which are all of modest scale.
We agree with SERDP's statement that the tower must set a benchmark for architectural quality. But that "the architectural quality of the tallest tower is not yet sufficient to justify its very considerable prominence in the local and wider townscape"
We understand from the developers that no phone masts will be allowed on the roof and each lease will prohibit the ability of the residents to put a satellite dish on the building. Communal satellite dishes will not be visible. The taller buildings will be cleaned and maintained via an abseiling system and not through crane provision. These important facts should be included in the submission because both have a material effect on the ongoing quality and appearance of the development.
The quality of the proposals aesthetic design is insufficient given its prominence and the impact it would make in this sensitive context. This combined with the height and high density is a substantial concern for the community. |
The Wheatfield Way building to the left of the Telephone exchange has some unfortunate angles and side for such a prominent position.
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5. Density: The site is over developed.
A recent UK House of Commons report concluded that "The proposition that tall buildings are necessary to prevent suburban sprawl is impossible to sustain. They do not necessarily achieve higher densities than mid or low-rise development and in some cases are a less-efficient use of space than alternatives." The main reason that the Committee held an inquiry into tall buildings was to “identify the contribution which they can make to the urban renaissance. [They] found that contribution to be very limited.” In other words, these massive buildings are likely not the most efficient or optimal choices for development in Kingston.
The Planning Submission Addendum item 3.8 shows: The density exceeds the range given by the London Plan ( 650 - 1100 ). A reasonable development might aim for a mid-range figure of 875. However the development proposes 1170 habitable rooms per hectare. This is unacceptably high. The London Plan says "Development proposals which compromise this density policy should be resisted." So this development should be resisted.
A recent UK House of Commons report concluded that "The proposition that tall buildings are necessary to prevent suburban sprawl is impossible to sustain. They do not necessarily achieve higher densities than mid or low-rise development and in some cases are a less-efficient use of space than alternatives." The main reason that the Committee held an inquiry into tall buildings was to “identify the contribution which they can make to the urban renaissance. [They] found that contribution to be very limited.” In other words, these massive buildings are likely not the most efficient or optimal choices for development in Kingston.
The Planning Submission Addendum item 3.8 shows: The density exceeds the range given by the London Plan ( 650 - 1100 ). A reasonable development might aim for a mid-range figure of 875. However the development proposes 1170 habitable rooms per hectare. This is unacceptably high. The London Plan says "Development proposals which compromise this density policy should be resisted." So this development should be resisted.
The Mayor of London Housing SPG on pp54 - 55 indicates that the proposal falls short on size of habitable room sizes in some cases - this is more proof of over development and poor quality accommodation.
We agree with the SERDP report where they state "We are concerned... that too much is being asked of the site and consequently is being over developed...by the arrangement of the blocks, the quality of the accommodation they will provide and the way the development as a whole will fit in with its surroundings"
The proposal does not represent the high quality accommodation that the Council should be seeking for this central site. The implications of building sub-standard housing stock for future inhabitants and the existing community should be considered very carefully.
Furthermore, the development also immensely overbears and overshadows a group of Victorian properties immediately to the south and east of the site on Wheatfield Way, which are identified by the local authority as buildings of townscape merit. The proposed development creates a frontage which is not an appropriate setting for the local conservation area; the design would greatly dwarf the two storey Victorian dwellings. Kingston Council’s website on conservation areas states that “Centuries of growth has created distinctive local identities and each conservation area’s ‘special character.” The ‘distinctive local identity’ of the Fairfield/Knights Park Conservation Area is threatened by this dense development on its borders.
The proposal fails to comply with standards on density specified by the London Plan.
6. Sustainability: The Council has committed to the following sustainability practices:
Large buildings come with a huge environmental cost, despite our best efforts to offset CO2 and use more environmentally-friendly materials. While the project may meet sustainability code requirements, Kingston could be missing out on an opportunity to truly become a city of the future. Sustainability is not only that we lessen our ecological impacts, but also that we create the urban and cultural frameworks in which we can attain full humanity, in contact with self, others, and nature. This is true sustainability, and the resilience of our town centre depends more upon residents’ commitment to and connection with the place as their own. The tower buildings counteract the real human scale of Kingston, and we urge the Council and Planning Officers to consider the impact that this shift in building scale will have on the look and feel of our beloved Kingston. This is especially important considering the precedent it will set for large-scale buildings in the future.
We agree with the SERDP report where they state "We are concerned... that too much is being asked of the site and consequently is being over developed...by the arrangement of the blocks, the quality of the accommodation they will provide and the way the development as a whole will fit in with its surroundings"
The proposal does not represent the high quality accommodation that the Council should be seeking for this central site. The implications of building sub-standard housing stock for future inhabitants and the existing community should be considered very carefully.
Furthermore, the development also immensely overbears and overshadows a group of Victorian properties immediately to the south and east of the site on Wheatfield Way, which are identified by the local authority as buildings of townscape merit. The proposed development creates a frontage which is not an appropriate setting for the local conservation area; the design would greatly dwarf the two storey Victorian dwellings. Kingston Council’s website on conservation areas states that “Centuries of growth has created distinctive local identities and each conservation area’s ‘special character.” The ‘distinctive local identity’ of the Fairfield/Knights Park Conservation Area is threatened by this dense development on its borders.
The proposal fails to comply with standards on density specified by the London Plan.
6. Sustainability: The Council has committed to the following sustainability practices:
- “Major developments should meet Code Level 5 from 2013”
- “From 2013 onwards: BREEAM ‘Outstanding’ “
Large buildings come with a huge environmental cost, despite our best efforts to offset CO2 and use more environmentally-friendly materials. While the project may meet sustainability code requirements, Kingston could be missing out on an opportunity to truly become a city of the future. Sustainability is not only that we lessen our ecological impacts, but also that we create the urban and cultural frameworks in which we can attain full humanity, in contact with self, others, and nature. This is true sustainability, and the resilience of our town centre depends more upon residents’ commitment to and connection with the place as their own. The tower buildings counteract the real human scale of Kingston, and we urge the Council and Planning Officers to consider the impact that this shift in building scale will have on the look and feel of our beloved Kingston. This is especially important considering the precedent it will set for large-scale buildings in the future.
7. Parking, Transport, Infrastructure and Services: The submission largely underestimates the need for and impact on parking, transport, infrastructure and local services.
- The planning submission addendum item 3.10 states the proportion of parking spaces is 0.37 per dwelling -‐ this does not meet the London Plan figures.
- The submissions Transport Assessment states that "there is no need for junction assessment." This assumption raises many serious questions, and we feel that arguments for discouraging using cars and public transport fail to address the real strain that over-development will have on infrastructure already in place. It should be noted that access through to the A3 road from the site has not been resolved.
- The planning application also states that “The loss of 152 parking spaces on this site is negligible.” In this vicinity it is very significant as parking is already significantly strained. It appears that the “average numbers” are being incorrectly used for this specific location and should require further testing. The Car Park Management Plan Item 3.38 also makes questionable claims and we have concerns over tenants finding a way to obtain on-street permits.
- The Environmental Statement Addendum non technical summary states that “there is a surplus of school places in the vicinity” though no evidence is provided to prove this claim. Upon further research it is easy enough to discover that placement applications versus availability figures tell a completely different story; there is a serious shortage of places.
- Additionally, the statement that 607 additional residents will have negligible impact on local GP surgeries seems improbable. This also needs to be tested further to discover the impact in real terms for GPs in the vicinity.
Considering these numerous questions, it is clear that the development will fail to provide a comprehensive strategic transport solution. The downplaying and dismissal of impacts on infrastructure, school and GP places should be challenged in the interests of all current and future Kingston residents.
8. Ineffective public consultation: The submission lists who and how much consultation was carried out. While this looks impressive, we are not however convinced of it's effectiveness. Nor are we convinced that feedback has been effectively considered or acted upon.
When asked for any further factors St George should consider before submitting a planning application, the three most cited matters from the community were: height, transport, and architecture. The inclusion of 13 and 21 storey buildings clearly demonstrated that the residents’ views had not been taken into consideration; “Reduction in height along Wheatfield Way, Brook Street and Ashdown Road” will not be achieved with high-rise buildings. It should be noted that none of the documentation (neither consultations nor exhibitions) make explicit mention of the possibility of a 21 storey building, and because of this significant exclusion we believe has been misleading. |
The exhibitions provided by St George make no mention of high-rises. This exhibition is one example of many misrepresentations of the visual impact of the high-rise blocks in the public consultation; note the absence of tall buildings in the computer- generated image, which can be construed as misleading.
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We continue to note the large proportion of residents and visitors we are reaching, who remain unaware of the proposed scale and impact. Their main surprise and alarm is the scale, height and bulk. Clearly this has not been well conveyed by glossy perspective illustrations that emphasize the space around the Old Post Office building while being less informative on the scheme as a whole.
Paragraph 66 of the National Planning Policy Framework (NPPF) states that “Applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.” This has not happened in regards to concerns over height.
Paragraph 66 of the National Planning Policy Framework (NPPF) states that “Applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.” This has not happened in regards to concerns over height.
9. Public Realm : The new Post Office Square features heavily in selling the proposal, yet there are doubts as to how suitable and use-able it will be. Unlike the intimate, sunny south facing Apple Market bounded by characterful 2 storey buildings - the new Post Office Square will be overwelmed by tall buildings to the south, casting almost permanent shade over what could become quite a hostile wind swept and damp thoroughfare. We agree with SERDP's conclusion that they were not convinced of the Apple Market example for this space - for example the orientation of the space and the effect of sunlight and overshadowing from the taller buildings to the south. We also understand that, as a private estate, the 'high quality public open space' grants no right of assembly.
We also see little consideration to mitigate any wind speed or turbulence or overshadowing effects such as through the use of podiums at lower levels. It is not obvious that the environmental study indicates environmental problems in the public realm but there was no wind tunnel testing using a scale model of the development to counter this negative expectation.
Planning obligations sometimes encourage public art to be supplied at 1% of total construction costs. It is disappointing to see no provision of public art.
It is proposed that this development will have the tallest building in the vicinity. Public access to new tall buildings can promote their use at different times of the day, fostering a more positive perception of the building and allowing the community and visitors to make effective use of it. It is disappointing to see no provision of managed public access to upper floors in the proposal.
We also see little consideration to mitigate any wind speed or turbulence or overshadowing effects such as through the use of podiums at lower levels. It is not obvious that the environmental study indicates environmental problems in the public realm but there was no wind tunnel testing using a scale model of the development to counter this negative expectation.
Planning obligations sometimes encourage public art to be supplied at 1% of total construction costs. It is disappointing to see no provision of public art.
It is proposed that this development will have the tallest building in the vicinity. Public access to new tall buildings can promote their use at different times of the day, fostering a more positive perception of the building and allowing the community and visitors to make effective use of it. It is disappointing to see no provision of managed public access to upper floors in the proposal.
Page updated on 13th May 2015