Harm to heritage
Planning application 14/13247 ( Sept 2015 )
What we said at the presentation DC meeting on the 14th of October 2015
What we said at the presentation DC meeting on the 14th of October 2015
My name is Tessa Kind, a resident of Mill Street.
I have been asked by Anthony Evans to read this on behalf of the Kingston Society’s Executive Committee tonight. You will have a copy in your pack.
Anthony has been a member of the Society for over 45 years, he has 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.
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THE OLD POST OFFICE SITE KINGSTON:
HERITAGE CONSIDERATIONS & IMPACTS
The Glossary to the National Planning Policy Framework (NPPF) document has very clear advice about what Local Planning Authorities should consider when deciding Planning Applications affecting Listed Buildings & Conservation Areas.
Listed Buildings & Conservation Areas are to be described as “heritage assets”.
There are specific statutory provisions, which Local Authorities MUST follow when considering the impact of any proposed development, such as the Application under consideration.
Section 66[1] of the Planning [Listed Buildings & Conservation Areas] Act 1990 states
“…that in considering whether to grant permission for development which affects a Listed Building or its setting, the Local planning Authority …shall have special regard to the desirability of preserving the building & its setting….”
And In Section 72[1] of the same Act
“..Special attention shall be paid to … preserving the character or enhancing the character of the area..”
This Application does neither.
In fact it positively destroys the settings etc. by proposing so called ‘bookend buildings’ of some 8 & 12 storey heights, which would harm both the setting & the intrinsic historic character of these Listed Buildings.
As the Fairfield & the Knights Park Conservation Areas immediately adjoin this site, & a third – the ancient Market Place which is within a matter of yards, these MUST also be taken into account & their setting has to be either preserved or enhanced.
The Application does neither.
It would dwarf the 2 storey Victorian houses opposite on Wheatfield Way, those in Knights Park, Fairfield South, Grove Crescent and Palmer Crescent, leaving their setting completely ruined, & being visible from far across both Conservation Areas.
Paragraph 129 in the NPPF states that Planning Authorities should undertake an assessment of ANY heritage asset i.e. - a Conservation Area- which identifies their particular significance and this MUST be taken into account when considering an Application, so as to avoid or minimise the conflict between the heritage asset & ANY aspect of the plans.
This has clearly not been done in this case, as the plans make no attempt whatsoever to minimise the harmful impact that two blocks of 8 & 12 storeys high would have on the two Listed Buildings – they would dwarf them both significantly, nor the visual damage done to the 2 adjacent Conservation Areas & the wider town centre including the Market Place which sits in yet another Conservation Area.
Para 132 of the NPPF states that
”…great weight should be given to the conservation of the heritage asset. The more important the asset, the greater weight should be given. Significance can be harmed or lost through alteration or destruction of the asset, or development within its setting…”
Nobody could possibly argue that the setting of the 2 Conservation Areas & the 2 Listed ‘Buildings at Risk’ will not be greatly harmed and damaged by the St. George’s plans under consideration.
In terms of the London Plan, Policy 7.7 has as specific policy relating to tall & large buildings
“..should NOT impact on local or strategic views adversely..”
Policy 7.7E states that such an impact should be given particular consideration. Such areas might include Conservation Areas, Listed Buildings or their settings, registered Historic Parks & Gardens etc etc..”
You will read evidence from Historic England, amongst other several highly reputable bodies, that the highest parts of this development will be seen from Hampton Court & Richmond Park, both of national importance, and this alone should provide the Council with yet another reason for refusal.
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It is abundantly clear that the Officer’s earlier report has not taken sufficient notice of the nationally accepted guidance contained in both the London Plan & particularly the paragraphs in the NPPF & its associated guidance. Failure to take such guidance into account & a recommendation to approve the St. George plans could lead to Judicial Review being sought.
I would strongly suggest that the Development Control Committee MUST take particular account of the various Policies that have been quoted above and refuse this Application.
Anthony Evans
12.10 2015
I have been asked by Anthony Evans to read this on behalf of the Kingston Society’s Executive Committee tonight. You will have a copy in your pack.
Anthony has been a member of the Society for over 45 years, he has 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.
>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>
THE OLD POST OFFICE SITE KINGSTON:
HERITAGE CONSIDERATIONS & IMPACTS
The Glossary to the National Planning Policy Framework (NPPF) document has very clear advice about what Local Planning Authorities should consider when deciding Planning Applications affecting Listed Buildings & Conservation Areas.
Listed Buildings & Conservation Areas are to be described as “heritage assets”.
There are specific statutory provisions, which Local Authorities MUST follow when considering the impact of any proposed development, such as the Application under consideration.
Section 66[1] of the Planning [Listed Buildings & Conservation Areas] Act 1990 states
“…that in considering whether to grant permission for development which affects a Listed Building or its setting, the Local planning Authority …shall have special regard to the desirability of preserving the building & its setting….”
And In Section 72[1] of the same Act
“..Special attention shall be paid to … preserving the character or enhancing the character of the area..”
This Application does neither.
In fact it positively destroys the settings etc. by proposing so called ‘bookend buildings’ of some 8 & 12 storey heights, which would harm both the setting & the intrinsic historic character of these Listed Buildings.
As the Fairfield & the Knights Park Conservation Areas immediately adjoin this site, & a third – the ancient Market Place which is within a matter of yards, these MUST also be taken into account & their setting has to be either preserved or enhanced.
The Application does neither.
It would dwarf the 2 storey Victorian houses opposite on Wheatfield Way, those in Knights Park, Fairfield South, Grove Crescent and Palmer Crescent, leaving their setting completely ruined, & being visible from far across both Conservation Areas.
Paragraph 129 in the NPPF states that Planning Authorities should undertake an assessment of ANY heritage asset i.e. - a Conservation Area- which identifies their particular significance and this MUST be taken into account when considering an Application, so as to avoid or minimise the conflict between the heritage asset & ANY aspect of the plans.
This has clearly not been done in this case, as the plans make no attempt whatsoever to minimise the harmful impact that two blocks of 8 & 12 storeys high would have on the two Listed Buildings – they would dwarf them both significantly, nor the visual damage done to the 2 adjacent Conservation Areas & the wider town centre including the Market Place which sits in yet another Conservation Area.
Para 132 of the NPPF states that
”…great weight should be given to the conservation of the heritage asset. The more important the asset, the greater weight should be given. Significance can be harmed or lost through alteration or destruction of the asset, or development within its setting…”
Nobody could possibly argue that the setting of the 2 Conservation Areas & the 2 Listed ‘Buildings at Risk’ will not be greatly harmed and damaged by the St. George’s plans under consideration.
In terms of the London Plan, Policy 7.7 has as specific policy relating to tall & large buildings
“..should NOT impact on local or strategic views adversely..”
Policy 7.7E states that such an impact should be given particular consideration. Such areas might include Conservation Areas, Listed Buildings or their settings, registered Historic Parks & Gardens etc etc..”
You will read evidence from Historic England, amongst other several highly reputable bodies, that the highest parts of this development will be seen from Hampton Court & Richmond Park, both of national importance, and this alone should provide the Council with yet another reason for refusal.
>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>
It is abundantly clear that the Officer’s earlier report has not taken sufficient notice of the nationally accepted guidance contained in both the London Plan & particularly the paragraphs in the NPPF & its associated guidance. Failure to take such guidance into account & a recommendation to approve the St. George plans could lead to Judicial Review being sought.
I would strongly suggest that the Development Control Committee MUST take particular account of the various Policies that have been quoted above and refuse this Application.
Anthony Evans
12.10 2015