Picture

THE OLD POST OFFICE SITE 
Sept 2015: #3

THIS PAGE REFERS TO THE OLD SUBMISSION. 
Please click here for the latest, Jan 2016 submission

Planning application 14/13247 ( Sept 2015 )

REFUSED

On 5th November 2015 the Development Control Committee unanimously REFUSED this application.
Reasons: 
  1. The proposed 12 storey element of the scheme located between the two onsite Grade II Listed Buildings would cause harm to the setting of the former Exchange Listed Building due to its height, incongruous and unsympathetic form and design in this sensitive location.
  2. The proposed development does not provide a minimum of 30% of dwellings as 3 or more bedroom units and would not therefore provide an acceptable dwelling mix for the development. It has not been robustly demonstrated that it would be unsuitable or unviable to achieve this percentage on this site.
  3. The proposed 16 storey element of the scheme would not relate well to the form, proportion, composition, scale and character of surrounding buildings.

> Read more - news blog...
​

What happens next...

The two possible routes after a refusal are:

Call in: The mayor may 'call in' the application and may override the council decision. This now doesn't look likely, but we can be involved if it goes down this route.
-- OR --
Revise: The NPPF tells us the developer should explore with RBK Planning what changes would make it more acceptable and likely to gain planning permission.
Appeal the decision?
They may appeal the decision within 6 months as well as submitting amended plans. We can be involved if the developer appeals ( as happened successfully at Seething Wells ).
The Secretary of State can overrule a failed appeal.
A Judicial Review is the ultimate decision level, but is limited to just legality issues.

> Read more of NPPF's guidance on appealing against refusal of planning permission...

Time Line

​​
  • 9 - 11th September -  Press Notice published, Consultation letters sent out
Did the September changes go far enough?
We are on a journey with this application that has taken us from the 17 storey consultations in 2014; to the shock submission of the 21 storey 'fag packet'; and back to something seemingly not far from where we started. 

But it is important to only measure the current scheme against planning policy and what would be acceptable. Making comparisons to previous schemes is not relevant: if 'bad' is better than 'terrible' - that is no basis for saying 'yes'. The current scheme must stand on its own two feet. Let's not fall into the trap of saying it is better or worse than before when deciding if this should be granted or refused. 

While there are admirable things about the proposal such as saving listed buildings, we believe it remains essentially the same flawed scheme with the same core problems. It contradicts our Council's policies. This brutal, generic over-development would cause irreparable damage to Kingston. We must say no to this current scheme.

Key concerns - in summary

Our key concerns remain substantially unaddressed.
Here is a brief summary of why this scheme should be REFUSED:

1. Public consultation?

Q: Does it meet the Public consultation Requirements?:-
A: NO 

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.”

The consultation has not been real or effective throughout the life of this application. We have always pushed for open discussion while the design is in progress, not after the submission is made. The opposite has happened. At our latest meeting with St George and their architect they said they wont be changing the plans as a result of their consultation with us. Informing us about something already decided is not consultation.

> Read more on why the consultation has failed...
This is how NOT to do consultation.
2. Sustainable Development?

Q: Are tower blocks a sustainable way to build housing?
A: NO

Historic England did not believe the scheme meets the Government’s definition of sustainable development. There are at least four reasons why this proposal can not be described as sustainable development 

> Read more on why this fails on Sustainability

3. Visual Impact & Conservation Areas?

Q: Does it protect and enhance the World Heritage Sites?
A: NO, it is harmful their settings. Historic England, Historic Royal Palaces and Richmond Council have all raised, and continue to raise objections and concerns.

 “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."
​
Source: Kingston Town Centre Area Action Plan (2008).pdf

Q: Does it respect and fit within its context?
A: NO, due to its overall scale the scheme is surely alien.

Q: Being on the border of a conservation area, does it have a positive impact? 
A: NO. It harms the setting and views of the development from the nearby conservation areas can only be considered intrusive.

Q: What is the cumulative impact when other developments are taken into consideration?
A: We don't know.

> Read an opinion from us on the visual impact...
None of the cumulative images include the Eden Walk Redevelopment - so we dont know the combined effect
4. Height & Scale?

Q: Does it meet the Height & Scale Requirements?
A: NO, its tower designs do not justify exceeding 9 stories and it breaches heights across the site - as specified by the Eden Quarter SPD.

"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)." 

Source: Eden Quarter Development Brief SPD.pdf ('Eden Quarter SPD')

"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." 

Source: London Plan

The scheme is clearly NOT compliant with the Eden Quarter SPD 

> Read more on why this fails on Height & Scale
This is not an exemplar standard of design
5. Affordable Housing? 

Q: Does it meet the 50% Affordable Housing Requirements? 
A: NO, 15% is a long way short.

Just 49 of the 332 additional homes will be affordable housing, 19 of which are affordable rent, and 30 will be sold at a discount price. This amounts to just under 15% Affordable Housing.

Source: AFFORDABLE HOUSING STATEMENT.pdf

> Read more on why this fails on Affordable Housing 


6. Aesthetics, Architecture, & Heritage?

Q: Does it meet the Aesthetics, Architecture, & Heritage requirements?:-
A: NO, this is not sensitive to its context, nor is it outstanding or innovative design.

The National Planning Policy Framework (NPPF) requires developments to "respond to local character and history, and reflect the identity of local surroundings and materials"
It also 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 scheme achieves neither. It lacks design credibility: the design review panel expressed “concerns about the residential quality of the units which are indicative of too much development”

> Read more on why this fails on Aesthetics, Architecture, & Heritage


7. Density?

Q: Does it meet Density expectations & requirements?:-
A: NO
​
Q: Does the scheme contribute to the permeability of the site and the wider area ?
A: NO, most of the Site will be inaccessible to the public.

Q: Are the units of sufficient size?
A: NOT ALL

Too much is being asked of the site. The scheme seeks to over develop the site.

> Read more on why this fails on Density
This is not the style of development where Kingston residents aspire to live*
* KRA popup survey
​
8. Parking, Transport, Infrastructure and Services?

Q: Does it meet Parking, Transport, Infrastructure and Services requirements?
A: NO.

The RBK goal for parking provision is 0.75 parking spaces per home but this scheme only provides 0.39.

In terms of the relationship to transport infrastructure; while the site is reasonably close to Kingston Station commuter services are already seriously over crowded.

Suitable school places should be walkable from the scheme but there is a shortage.

The cumulative impact when other developments are taken into consideration has not been considered.

> Read more on why this fails on Parking, Transport, Infrastructure and Services


9. Public Realm?

Q: Is the public realm effective and truly public space?
A: NO, the public realm is just an extension of the commercial premises that adjoins it.

After accounting for commercial table spaces and circulation into the building entrances, what is left is just a corridor.  

The design will create unpleasant spaces in and around the site, over shadowed and windy.

> Read more on why this fails on Public Realm
Click these links for our latest thoughts and information on the proposal: 
> Our Post Vote Thoughts
> No time for triumphalism
> Officers report
> Our 14 October presentation
> A fresh look
> Why it is wrong
> Historic England response
> Kingston Residents' Alliance response
> Resident and notable opposition
> What could be acceptable
> Why some say yes
> Who will decide
> Other planning cases

Other links:
> Our news blog post
> RBK's Planning Portal
> RBK's update statement
> St George's Website 
> www.skyscrapernews.com

The submission in pictures

Picture
The public exhibition was on 18 & 19th Sept
Picture
An over-developed site
Picture
From College roundabout - an exemplar standard of design?
Picture
Wheatfield Way - overlooking the conservation area adjacent
Sad, brutal and monotonous... 
Picture
Height breaches across the site - Eden Quarter SPD non-compliance
Picture
Brutal, over-developed and over-shadowing
Picture
Harmful to views from the Ancient Market
Picture
Intrusion into the adjacent conservation area
Picture
Harmful to views from Kingston Bridge
Picture
Harmful to views from Richmond Park
Picture
Harmful to views from the Fairfield

Submission History


​Proposal 3
The September 2015 revision had 16 storey and 12 storey high-rises with 338 residential units.  
Click here for more info - news blog.     

​Proposal 2
The April 2015 revision had 19 storey and 13 storey high-rises with 360 residential units.
Click here for more info - news blog.          

​Proposal 1
The original December 2014 planning submission had 21 storey and 13 storey high-rises with 380 residential units.      
Click here for more info - news blog.
Click here for more images.

​Existing 
Page updated on 8 Jan 2016