Our response to the Sept 2015 scheme #3
Planning application 14/13247 ( Sept 2015 )
Viv Evans
Head of Planning & Transport
Development Management
Guildhall 2, High Street
Kingston upon Thames
KT1 1EU
Email: [email protected]
Reference: 14/13247
Kingston Resident's Alliance
KingstonResidents.com
8th October 2015
Response from Kingston Resident's Alliance
Dear Sir
In response to the September amendments received in relation to planning application 14/13247 at DEVELOPMENT SITE AT FORMER POST OFFICE, ASHDOWN ROAD, KINGSTON UPON THAMES
The Old Post Office site (TOPO) represents a rare opportunity. It is a prime location in important historic settings near the center of the historic market town of Royal Kingston Upon Thames.
It is our collective responsibility to ensure, through the planning system, that the site is developed in an appropriate and sustainable way, making best use this unique opportunity. For us residents TOPO is particularly important because it is presented to us as a strategic solution for delivering some of the key objectives of the Kingston Town Area Action Plan, including housing needs. Unfortunately residents have been given no context as to how this proposal will sit with the existing infrastructure, British Land's proposals for the Eden Walk Shopping Centre or the Eden Quarter Brief in general. This piecemeal approach to planning will cause irreparable damage to the nature of our town centre and must be stopped. We welcome the September 2015 changes, especially the reduction in height of the tower, but the changes don't go far enough to resolve the schemes many failings. We believe it remains essentially the same flawed scheme with the same core concerns we have previously identified. Since the first plans submitted in October 2014, Residents have made it clear, by an overwhelming majority, that they reject this type of dense, high-rise architecture, yet the applicant keeps returning with more of the same, with only peripheral amendments. They are evidently engaged in a war of attrition with the local community to force their inappropriate designs through. This represents an abuse of the process and a waste of council taxpayers' resources. This response should be read in addition to our previous objections. It fails to meet the development plan. It fails on affordable housing. It is not sustainable development. It is wrong for the context and there is too much of it. This brutal, generic over-development would irreversibly harm Kingston. We must say NO. It is important to note recent events which have a direct bearing on this planning decision and what would be acceptable: they amount to a clear shift away from the type of housing proposed in this scheme. 1) The residents backlash to the April scheme was robust, with the overcrowded Committee meeting on the 2nd of June where residents came in numbers, with more to say than they were allowed. 2) The Grove Ward by-elections highlighted the issues of over-development like this. 3) Unhappy Kingston residents were on BBC London News and in the Evening Standard about this proposal. 4) KRA ran a snap survey to ask residents what type of housing they would like to see. 5) In September 2015, a Grove Ward Councillor, who sat on a Kingston Town Centre Neighbourhood Committee in May 2015 and supported the plans by saying “I do not want to live in a museum’ has publicly apologized to his constituents: “We have to learn from the TOPO experience, I apologize if I appeared dismissive and will represent you better" 6) In September 2015, the State of the borough meeting was dominated by the need for better and affordable housing and the needs of the present and future residents of Kingston. 7) The London-wide housing debate has become a mayoral election issue, where it is widely accepted that towers are not the right answer. The Officers report was surprisingly positive and benevolent toward the developers April scheme. Not convinced, residents sought the opinion of top-rated Barrister, Matthew Horton Q.C specializing in Town planning law and practice in related areas. His opinion cast significant doubt over the reports approach and reliability. He said "a decision to grant permission in reliance on the report would be susceptible to judicial review". This scheme fails to comply with the development plan The National Planning Policy Framework (NPPF) states "Planning law requires that applications for planning permission must be determined in accordance with the development plan unless material considerations indicate otherwise." Yet as we have previously made clear, the scheme fails to comply with the Eden Quarter SPD (2015), with height breaches across the site and especially the harmful 12 storey Ashdown Road tower - which should lose 4-6 storeys to bring it within the SPD's 6-8 storey height requirement (or removed altogether); and the most harmful element, the corner tower, is not "exemplar design" and does not merit or justify exceeding 9 storeys. As previously stated it also fails to comply with the London plan on "The impact of tall buildings proposed in sensitive locations" This scheme fails to meet the HE/CABE guidance for tall buildings Developments with tall buildings should consider the following issues:
This scheme is not sustainable development. We agree with Historic England that the scheme does not meet the Government’s definition of sustainable development. This view remains unchallenged by any specialist advice. Further, in the opinion of our QC the Officers' report for the April scheme was "entirely inadequate" and "unlawful" in its judgement about the sustainability of the proposal. He said it "failed to apply the correct test set out in the NPPF... namely 'meeting the needs of the present without compromising the ability of future generations to meet their own needs' ". The NPPF states "There are three dimensions to sustainable development: economic, social and environmental." We believe the scheme falls short of the NPPF's requirements for sustainable development on these important measures: 1) Requiring good design 2) Promoting healthy communities 3) Conserving and enhancing the historic environment. 4) Conserving and enhancing the natural environment. 5) Ensuring that sufficient land of the right type is available 6) Requiring effective public consultation |
1) This scheme is not good design
NPPF paragraph 56 states "The Government attaches great importance to the design of the built environment. Good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making places better for people." Being a residential lead development, special consideration should be given to what constitutes good and popular residential design, and what is an appropriate density for living. When asked, both Londoners and Kingston residents agree that conventional mid-rise terrace or mansion flats with a good street relationship and connection constitutes good and popular residential design. This is well supported by research. Most people want to live somewhere fairly normal on a normal street. Nearly all of us aspire to the physical attributes of an old fashioned street, the pub, you can pop over the road, a strong neigbourhood. This scheme is not considered to be good or popular design because it is comprised of blocks and towers; it fails to give its residents a healthy relationship to the street. The design review panel stated: "It was not clear where the main street entrances to many of the apartments would be, particularly for those units deep in the centre of the plan...It was also not clear how a visitor might find their way from the car park to a particular apartment without the use of extensive signage. Residents should be able to give clear and simple directions to their visitors. The depth of plan means that internal corridors will have little or no daylight." NPPF paragraph 62 states "In assessing applications, local planning authorities should have regard to the recommendations from the design review panel." The design review panel were critical. They had concerns over "the arrangement of the blocks, the quality of accommodation they will provide... the single aspect flats facing Wheatfield Road and deep north facing units elsewhere, with the consequent problems of aspect or daylight... There was little differentiation in the layout, size, balcony space or terrace of the units regardless of whether they faced in or out, north or south. Some units appear to straddle the discrete building components, giving the sense that the building's exterior is simply wrapped around an efficient layout, rather than responding genuinely to its context." NPPF paragraph 58 states "planning decisions should ensure that developments establish a strong sense of place, using streetscapes and buildings to create attractive and comfortable places to live, work and visit; ... respond to local character and history, and reflect the identity of local surroundings ... while not preventing or discouraging appropriate innovation; ... seek to promote or reinforce local distinctiveness." This scheme fails completely on these points. Residents have protested in the strongest way they know how - against not just the height and scale of the scheme, but the generic could-be-anywhere aesthetic design which was present in this proposal from day 1 and has barely evolved. It does not "reinforce local distinctiveness." nor "respond to local character and history, and reflect the identity of local surroundings" as required by the NPPF. It will do the opposite. Its generic bland facades can be seen in hundreds of developments across London. Kingston is a market town. Much has already been said about the proposed schemes far reaching negative consequences for the future character of Kingston; its identity and sense of place. If it were allowed to go ahead it will not maintain or sustain Kingston's market town character, it will destroy it. It fails as a sustainable development by its inappropriate aesthetic design which is alien to this sensitive context. 2) This scheme does not promote healthy communities At best, this is not the type of housing Kingston residents aspire to live in, but the darker problem is the potential for social isolation. It has been shown in as many as 60 sociological studies that people living in poorly designed large blocks suffer more from isolation, depression and crime. This would be particularly true for anyone living in those units deep in the centre of the plan, where there is a loss of connection with the street, and thus the wider neighbourhood. The social role of sustainable development, the NPPF tells us, is in "supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations" This scheme of blocks, towers and corridors fails to promote community, connection and personal relevance. It is overlooking and confronting at its edge and isolating at its core. The knock-on effect of these social failings on the economic aspects is easy to see. Residents, possibly elderly residents, would be at greater risk of isolation in these apartments - adding in turn to the strain on our social care system - the largest cost within our shrinking Council budget. The risk to economic sustainability over the life of this development is clear. This fails to be sustainable development in economic terms as well. 3) This scheme does not conserve and enhance the historic environment. Historic England, Historic Royal Palaces and Richmond Council have all raised, and continue to raise objections and concerns. As previously stated we agree with Historic England who state that "the development would detract from the setting of the Kingston Old Town Conservation Area and the Fairfield/Knight's Park Conservation Areas, failing to meet the statutory test to preserve and enhance the character and appearance of locally and nationally designated heritage assets. It would also cause unnecessary and undesirable harm to the setting of Richmond Park, Bushy Park and Hampton Court Park and Hampton Court Palace which is of international significance, by increasing the prominence of built form of Kingston town centre and reducing the sense of openness of these historic landscapes. The harm has not been justified." 4) This scheme does not conserve and enhance the natural environment as much as it should As we stated before, by targeting a lesser BREEAM rating the development falls short on the environmental standards of sustainable development. 5) This scheme will compromise the supply of other available land in the right place. The 12 storey Ashdown Road tower will overshadow and block light from the adjacent land to its north. Land which is earmarked in the Eden Quarter SPD for development. This scheme then will compromise the supply of well located brownfield land coming forward for development. This is not economic sustainable development. 6) Public Consultation has failed. NPPF paragraph 66 states "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 clearly not happened.
|
To conclude
To conclude, a sensitive and desirable scheme on this site could do much to contribute to housing solutions, unlocking family homes as people feel able to downsize into attractive apartments; helping people to afford somewhere great to live.
But this proposal doesn't. Instead it is tragic that, given all of the talent available and the time that has passed, we are again looking at just another iteration of the same flawed scheme that we strongly oppose.
Had consultation been effective and real, we would not be looking at essentially the same scheme with the same issues. We must REFUSE this scheme. Kingston will not solve its housing crisis with bad developments.
To conclude, a sensitive and desirable scheme on this site could do much to contribute to housing solutions, unlocking family homes as people feel able to downsize into attractive apartments; helping people to afford somewhere great to live.
But this proposal doesn't. Instead it is tragic that, given all of the talent available and the time that has passed, we are again looking at just another iteration of the same flawed scheme that we strongly oppose.
Had consultation been effective and real, we would not be looking at essentially the same scheme with the same issues. We must REFUSE this scheme. Kingston will not solve its housing crisis with bad developments.
Page updated on 8 Oct 2015