Development Management Royal Borough of Kingston upon Thames Guildhall II, High Street, Kingston upon Thames, KT1 1EU
10 January 2020
Dear Mr Feltham,
RE 20/02495/FUL – 10 & 11 Storey Office Towers and Car parking Building 20/02499/OUT (Dec 2020 Addendum)
KINGSTON RESIDENTS ALLIANCE RESPONSE
WHY WE BELIEVE BOTH APPLICATIONS (20/02495/FUL and 20/02499/OUT) SHOULD BE REFUSED:
Although we welcome the reduction in height of one of the towers, from 22 to 16 storeys, we believe the recent amendments do nothing to mitigate the issues previously raised with regard to such an oversized development. To make matter worse, there is now no provision for any Affordable Housing and an increase in density in other aspects of the plans. We therefore believe that both plans will harm the neighbourhood, the environment and the character of the place it is trying to shoehorn itself in to. It should therefore be treated as a gross over-development that is completely contrary to the Council’s own publicly stated planning guidelines.
It is worth emphasising that only 3 years ago, on the site next door to the proposed Eden Campus, Kingston residents fought very hard to reduce the height of that ONE so-called signature tower from 21 to 16 storeys. However, we were told unambiguously that would be the ONE and ONLY flagship tower. Planners and councillors should honour that promise and not allow developers to propose with further high-rise dream schemes without any public consultation or statutory policy documents. Providing a ‘pre-approval’ green light for 22 storeys in the spring of 2020 was a gross and unlawful mistake by the Council planning department. It is in now in your hands to stop this developer-led nonsense of a “Kingston Arc” and apply the statutory planning guidelines to all applications, not just to us ordinary taxpaying residents. To our knowledge, Kingston Planning guidelines and consultations have NEVER envisaged clusters of towers in our neighbourhood. How can the Council ignore its own planning policy, which was the outcome of extensive public consultation?
We are told that the London Plan – and its Tall Buildings Policy – will be adopted this month. We are encouraged by the fact that the new London Plan specifically mentions that “Tall buildings should only be developed in locations that are identified as suitable in Development Plans”. Given the number of extremely tall planning applications already in the pipeline, such as at Bittoms Car Park, Councillors and Planners should not rush these major applications through without getting the best return for the borough and its residents. Residents need to see clear tall buildings policies in place, in line with the London Plan. before the determination of this planning application and the others that will inevitably follow.
If there is a single overriding reason to refuse these plans it should be the fact that they provide no Affordable Housing. The new claim that, with the reduction in height, they aren't making the necessary profit to “afford” affordable homes anymore is laughable. Kingston Council’s own Affordable Housing SPD suggests that Kingston Council will seek to secure the provision of affordable housing in accordance with Policy DM15, through a planning obligation under Section 106 of the Town and Country Planning Act 1990. Residents are rightly questioning how such an obligation can be waived for what is potentially the highest density planning application ever seen in Kingston Town Centre. The argument of “the applicant is prioritising on-site delivery as a first principle” is an old, lazy excuse and legally outdated under the London Plan. Council Planners should take a robust stance with developers, and their secretive viability assessments, and ensure that every development delivers at least 30% affordable housing.
One of the main concerns raised by residents with this development is the environmental impact of this huge development to those of us living in the vicinity of the site, particularly the carbon emissions from construction. We are very encouraged to see the work of Kingston Society with a group of residents and their proposed alternative solutions with a much smaller carbon footprint. We would like to know if the Council is seeking the possibility of a win-win solution here? The developer’s potential tenant (Unilever) claims to take Environmental and Social Governance very seriously. Indeed, they have just announced plans to take their green agenda straight to shareholders and markets for approval! Kingston Council should see this as an opportunity. In different boroughs, planning permissions have been secured for 100% affordable net-zero-carbon housing schemes and we would like to know if the Council is seeking the best option from a carbon reduction perspective. Planners and Councillors should demand that the developers evaluate less harmful alternatives and not settle for the least attractive option of demolishing existing buildings in order to construct new buildings with the same function.
The Hogsmill tributary flows along the boundary of the proposed site. It is home to a variety of species and an important site for biodiversity in Kingston. It is also the home of the protected European eel. If unchallenged, the developer’s landscaping ideas may negatively impact on wildlife and kill off the river as one of the spawning routes for the European eel. We would like to know why there is no mention of the Kingston University project, conducted in collaboration with ZSL, to monitor biodiversity every summer. The River Monitoring Initiative (RMI) is a national scheme for monitoring the health of rivers and they are working with Kingston University. We do not believe developers have spent enough time understanding the intricacies of this fragile tributary of the River Thames and planners should demand a far more detailed study before they damage this important part of natural life of the borough.
As we pointed out in our previous objections, this has been a disaster of a consultation and the Covid pandemic has been used as a convenient, but unconvincing, excuse at every stage. Both consultations lacked verified key views. In particular, the absence of a tall buildings angle was notable in the limited number of visuals provided. This was demonstrably misleading, as it gave no clarity as to how these buildings will be seen in context. The proposals dwarf the scale and massing of the Royal Exchange and Eden Walk schemes. The applicants did not display their plans anywhere in the town. They simply expected everyone to be able to read small architectural visuals on a digital device and assumed everyone has the means to access their pitiful presentation online. There were no hard copies for anyone who was not able to view the materials in this way, despite our requests. Planners should never have allowed such a poor consultation for such an impactful application and must insist on adequate consultation with residents and stakeholders as required by law.
Our letter of 4th November contained numerous other significant concerns, such as the potential impact on local traffic, parking, transport links, infrastructure and services, as well as sustainability and public realm issues. It is unfortunate, but not unexpected, that the current amendments do not address any of our questions. We also mentioned Eden Walk and the Royal Exchange developments largely comply with the prevailing Planning Policy, the Eden Quarter Development Brief Supplementary Planning Document 2015 (EQDB), the current amended proposals for Eden Campus do not.
For the reasons above we feel very strongly that the applicants should not be allowed to proceed with the plans currently presented and we want you to ask developers to work with the local community to secure the best results for both themselves and Kingston residents. Until they commit to engage with this and produce acceptable and lawful proposals, the application must be refused.
END/
10 January 2020
Dear Mr Feltham,
RE 20/02495/FUL – 10 & 11 Storey Office Towers and Car parking Building 20/02499/OUT (Dec 2020 Addendum)
KINGSTON RESIDENTS ALLIANCE RESPONSE
WHY WE BELIEVE BOTH APPLICATIONS (20/02495/FUL and 20/02499/OUT) SHOULD BE REFUSED:
Although we welcome the reduction in height of one of the towers, from 22 to 16 storeys, we believe the recent amendments do nothing to mitigate the issues previously raised with regard to such an oversized development. To make matter worse, there is now no provision for any Affordable Housing and an increase in density in other aspects of the plans. We therefore believe that both plans will harm the neighbourhood, the environment and the character of the place it is trying to shoehorn itself in to. It should therefore be treated as a gross over-development that is completely contrary to the Council’s own publicly stated planning guidelines.
It is worth emphasising that only 3 years ago, on the site next door to the proposed Eden Campus, Kingston residents fought very hard to reduce the height of that ONE so-called signature tower from 21 to 16 storeys. However, we were told unambiguously that would be the ONE and ONLY flagship tower. Planners and councillors should honour that promise and not allow developers to propose with further high-rise dream schemes without any public consultation or statutory policy documents. Providing a ‘pre-approval’ green light for 22 storeys in the spring of 2020 was a gross and unlawful mistake by the Council planning department. It is in now in your hands to stop this developer-led nonsense of a “Kingston Arc” and apply the statutory planning guidelines to all applications, not just to us ordinary taxpaying residents. To our knowledge, Kingston Planning guidelines and consultations have NEVER envisaged clusters of towers in our neighbourhood. How can the Council ignore its own planning policy, which was the outcome of extensive public consultation?
We are told that the London Plan – and its Tall Buildings Policy – will be adopted this month. We are encouraged by the fact that the new London Plan specifically mentions that “Tall buildings should only be developed in locations that are identified as suitable in Development Plans”. Given the number of extremely tall planning applications already in the pipeline, such as at Bittoms Car Park, Councillors and Planners should not rush these major applications through without getting the best return for the borough and its residents. Residents need to see clear tall buildings policies in place, in line with the London Plan. before the determination of this planning application and the others that will inevitably follow.
If there is a single overriding reason to refuse these plans it should be the fact that they provide no Affordable Housing. The new claim that, with the reduction in height, they aren't making the necessary profit to “afford” affordable homes anymore is laughable. Kingston Council’s own Affordable Housing SPD suggests that Kingston Council will seek to secure the provision of affordable housing in accordance with Policy DM15, through a planning obligation under Section 106 of the Town and Country Planning Act 1990. Residents are rightly questioning how such an obligation can be waived for what is potentially the highest density planning application ever seen in Kingston Town Centre. The argument of “the applicant is prioritising on-site delivery as a first principle” is an old, lazy excuse and legally outdated under the London Plan. Council Planners should take a robust stance with developers, and their secretive viability assessments, and ensure that every development delivers at least 30% affordable housing.
One of the main concerns raised by residents with this development is the environmental impact of this huge development to those of us living in the vicinity of the site, particularly the carbon emissions from construction. We are very encouraged to see the work of Kingston Society with a group of residents and their proposed alternative solutions with a much smaller carbon footprint. We would like to know if the Council is seeking the possibility of a win-win solution here? The developer’s potential tenant (Unilever) claims to take Environmental and Social Governance very seriously. Indeed, they have just announced plans to take their green agenda straight to shareholders and markets for approval! Kingston Council should see this as an opportunity. In different boroughs, planning permissions have been secured for 100% affordable net-zero-carbon housing schemes and we would like to know if the Council is seeking the best option from a carbon reduction perspective. Planners and Councillors should demand that the developers evaluate less harmful alternatives and not settle for the least attractive option of demolishing existing buildings in order to construct new buildings with the same function.
The Hogsmill tributary flows along the boundary of the proposed site. It is home to a variety of species and an important site for biodiversity in Kingston. It is also the home of the protected European eel. If unchallenged, the developer’s landscaping ideas may negatively impact on wildlife and kill off the river as one of the spawning routes for the European eel. We would like to know why there is no mention of the Kingston University project, conducted in collaboration with ZSL, to monitor biodiversity every summer. The River Monitoring Initiative (RMI) is a national scheme for monitoring the health of rivers and they are working with Kingston University. We do not believe developers have spent enough time understanding the intricacies of this fragile tributary of the River Thames and planners should demand a far more detailed study before they damage this important part of natural life of the borough.
As we pointed out in our previous objections, this has been a disaster of a consultation and the Covid pandemic has been used as a convenient, but unconvincing, excuse at every stage. Both consultations lacked verified key views. In particular, the absence of a tall buildings angle was notable in the limited number of visuals provided. This was demonstrably misleading, as it gave no clarity as to how these buildings will be seen in context. The proposals dwarf the scale and massing of the Royal Exchange and Eden Walk schemes. The applicants did not display their plans anywhere in the town. They simply expected everyone to be able to read small architectural visuals on a digital device and assumed everyone has the means to access their pitiful presentation online. There were no hard copies for anyone who was not able to view the materials in this way, despite our requests. Planners should never have allowed such a poor consultation for such an impactful application and must insist on adequate consultation with residents and stakeholders as required by law.
Our letter of 4th November contained numerous other significant concerns, such as the potential impact on local traffic, parking, transport links, infrastructure and services, as well as sustainability and public realm issues. It is unfortunate, but not unexpected, that the current amendments do not address any of our questions. We also mentioned Eden Walk and the Royal Exchange developments largely comply with the prevailing Planning Policy, the Eden Quarter Development Brief Supplementary Planning Document 2015 (EQDB), the current amended proposals for Eden Campus do not.
For the reasons above we feel very strongly that the applicants should not be allowed to proceed with the plans currently presented and we want you to ask developers to work with the local community to secure the best results for both themselves and Kingston residents. Until they commit to engage with this and produce acceptable and lawful proposals, the application must be refused.
END/