Officers Report - Eden Walk
Planning application 15/13063
The Officers report was published on 15 March 2016.
As expected the recommendation is to approve.
We of course disagree and will have 5 minutes to explain why at the Decision meeting on 23rd March.
- The proposal would result in the net loss of 1,364sqm of office floor space.( EQDB says It will be important for the Eden Quarter to maintain the existing quantum of office space within this part of the town centre.")
- Proposal exceeds GLA's upper range for density by 20%! That's 20% too dense
- Our QC advice on referring to the Barnwell Manor case is included - we should send them the bill.
- It is admitted that the proposal's height and mass would cause harm.
- Just 11% will be 3 bed flats: ( but we say like TOPO the reasons are insufficient and same arguments should apply.)
- Parking: no mention of preventing residents from using on-street parking. This must be added as a condition - same as agreed for TOPO: no on-street parking permits will be provided for residents.
- The CIL liability for this scheme would be £5.6 million. ( but they intend to claim poverty and pay nothing)
- Thanks partly to pressure from us there is now a list of S106 offerings including £1.6 million on commencement of development for off site affordable housing.
- Daylight figures are included for the public spaces. Grim reading.
- Cumulative effect of this and other developments like TOPO is a material consideration - for infrastructure impact
Overall there are holes in the arguments and the mass, density, scale, quantum, harm to heritage settings and Eden Brief height breeches are all said to be ok because of the benefits this would bring. Historic England disagrees. So do we.
Quotes of interest from the report
- and comments
168 letters of objection have been received
18 letters of support
Page A33. In their Stage 1 response the GLA "Raise concerns regarding poor quality north facing single aspect rooms and excessively deep flats." But "During the course of the application minor amendments have been received which has reduced the number of units from 385 to 380 and involved internal rearrangements to increase the liveability of the units in line with GLA advice."(ppA37 11)
- comment: This could cause some to question what confidence should we have in the overall design?
12. "Adjacent to the Old Town Conservation Area, the Union Terrace building area begins the transition of both density and height across the Site. The Union Terrace building is located between two churches, the Everyday Church to the The building is pulled back from the Everyday Church to create a new area of north, and the listed United Reformed Church to the south."
- comment: Some text has been cut from this paragraph. Even so from this we expect to see a building in-keeping with its context - not what is being proposed! (EQDB says: "Union Street should be fronted with buildings of consistent scale to the existing street.")
139. "The elevation along Union Street makes a positive contribution to the streetscape through thoughtful selection of materials and facade design. The scale and design of the fenestration across the this elevation gives the design a human scale and picks up the proportionality and rhythm of the adjacent conservation area and deemed appropriate in terms of DM10. The use of bronze cladding, frames and spandrel panels offers a muted colour palette that does not overwhelm the setting of the adjacent conservation area. The residential entrances are well designed and sufficiently pronounced."
- comment : we wish this were so. Sadly the opposite is true
14. "A second new public space – United Reformed Square – is framed by the United Reformed Church, with the south elevation of the Union Terrace building looking over and opening out onto this new south facing space on Eden Street."
- comment: This is not a new space, it already exists, but this scheme doesn't maximize its potential. And second? where is the first 'new space' ?
( CABE quote: "The area around the United Reform Church could be exploited to a greater extent as it may well provide better conditions for a significant new public space, given its aspect and position in the wider movement network.)
92."The proposal would result in the net loss of 1,364sqm of office floor space. (B1(a)) "
( EQDB quote: "3.4...It will be important for the Eden Quarter to maintain the existing quantum of office space within this part of the town centre." )
Impact on Character of Area
115. "The Eden Quarter Development Brief (EQDB) states that one of the characteristics of Kingston is its varied roofscape which creates attractive townscape. New development schemes will be expected to achieve modulated and articulated rooflines to reflect this character."
- comment: as the horizontal podium sweeps past the old post Office - it doesnt.
Scale and Height
119. "The Eden Quarter Development Brief (EQDB) provides guidance on heights that are likely to be considered appropriate across the sites. It also identifies areas where tall buildings could be located to improve legibility and wayfinding. The application site is one of the areas where a building of 9 storey or higher is supported."
120. "As a Supplementary Planning Document (SPD) the [EQDB] document is not Policy and does not form part of the Development Plan it is however a material consideration in any planning decision and afforded significant weight. Figure 8 in the EQDB sets out guidance on building heights within the Eden Quarter."
( EQDB quote: 3.5: "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...schemes will be expected to achieve a modulated and articulated roof line to reflect this character, rather than being built out to the maximum permissible height.")
142. "It is noted that the tallest building was reduced to take account of Historic England’s comments however the slenderness and distinctiveness of the tallest building is lost somewhat by the cumulative scale, mass and height of the adjacent buildings in this block as seen in earlier design iterations."
- comment: The Neville Yard building breaches the EQDB height guidance by 50%. It obscures the 9+ storey element that is supposed to improve legibility and wayfinding - when making the important approach from the “Station Quarter”.
Why have a wayfinding townscape marker at 16 storeys if you cant see it ?
146. "The scheme proposes a triple height space on the corner of Eden Street and the eastern entrance (Boots). This represents a significant step up in height and scale of retail frontage along this elevation. This is however mitigated by the amendments to the fenestration and introduction of Bris Soleil. The elevation along Eden Street at level 1 and 2 is broken up by random, buff panels. This creates visual interest along this elevation and is at a legible, human scale. It also establishes a visually distinct area for offices."
- comment: confronted by 3 storeys of glass - this is the opposite of human scale. The people in the visual images at this corner look like ants compared to the overwhelming sheer wall of glass.
147. "The facade around the corner, on the northern elevation, is considerably larger than the neighbouring townscape and the repetitive use of GRC panels is stark, however after physical visual inspection of the palette of materials does give confidence of differentiation. The corner element, with floor to ceiling curtain wall glazing also provides some relief to massing."
-comment: yes it is quite wrong isnt it.
148. "The design of all the buildings and the proposed materials are all of a high quality. All the buildings are of a different design to add interest across the site and to ensure that each building responds to its individual context. The design of the buildings proposed would deliver substantial visual improvements to the area in accordance with the AAP and Policy DM10 of Council’s adopted core strategy."
- comment: hardly surprising that a new building should be an improvement on the indistinct and tired buildings it would replace. Stating the obvious?
149. Too dense: "Policy 3.4 of the London Plan seeks to optimize housing density, taking into account local context, character and public transport capacity. The site is classed as ‘Central’ in the Sustainable Residential Quality (SRQ) density matrix within the London Plan which states a density range of 650 - 1,100...The proposed development will provide approximately 1,315 habitable rooms hr/ha"
150. "The scheme is therefore above the range stated in Policy 3.4."
- comment: this exceeds GLA's upper range by 20%! That's 20% too dense.
161. "In making each of these assessments consideration has been given to relevant case law, and in particular the decision in the Barnwell Manor case."
- comment: this consideration is now included thanks to the QC advice paid for by concerned residents. We will send you the bill!
163. "Policy CS8 states that the Council will seek to ensure that new development recognises distinctive local features and character; has regard to the historic and natural environment and helps enhance locally distinctive places of high architectural and urban design quality."
- comment: It doesnt help to enhance locally distinctive places. For example the obsession with horizontal bands in the Eden street near TOPO instead of vertical variation as suggested by CABE.
171. "The interface between the frontage on Union Street will be intensified. The double height colonnade is a departure in scale from the ground level street scene on the other side of the street. The bulkiness of the four storeys above the colonnade, together with the colonnade itself, would vary from the scale, massing and fine grain of the town centre. The public realm from the market place into the proposed scheme is made up of narrow, medieval streets. It can therefore be said that the interface at this point will have an impact on the setting of the conservation area."
-comment: yes thank you: this is what we have been saying all along
172. "...the harm caused by height and mass of Union Terrace as it adjoins the Old Town Conservation Area".
- comment: it is confirmed that the proposal's height and mass would cause harm
From the Fairfield
184. "The proposed scheme is visible from numerous locations around the CA. When viewed from Fairfield it dominates the skyline on the eastern edge of the park. Visually however, it does follow the existing building line of the Premier Inn. The development will also be seen adjacent to the recently approved Old Post Office Scheme. It is considered that the skyline along the edge of the the Conservation Area is currently defined by two tall buildings the College Building and the Premier Inn Hotel which denote the start of the town centre. The addition of the Eden Walk development would reinforce this edge and whilst the development would affect views from the Conservation Area it is not considered to be detrimental to its character."
- comment: this is just plainly wrong.
From Richmond Park
241. From much of the park the proposed development would not be visible. However, where the scheme is visible it is not deemed to diminish the setting as it is reasonable to have this type of development within the existing townscape of Kingston. The views of the rural hills beyond London are unaffected. In many respects it is an improvement on the setting as the existing built form has little variation and the scheme would provide welcome
variation to the existing datum level.
-comment: not what CPRE London say.
251." Having carried out this weighing exercise and had full regard to all of the relevant issues, it is concluded that the public benefits to be delivered by the proposal are considerable and outweigh the less than substantial harm caused by the proposed development. The development is therefore considered acceptable in accordance with paragraphs 132, 133 and 134 of the NPPF and Policy DM12 of the Council’s Core Strategy Adopted 2012."
- comment: Historic England disagrees: "The NPPF requires that harm to the historic environment requires clear and convincing justification and is necessary to achieve substantial public benefits that outweigh the harm. We accept that the proposals will deliver some urban design and public realm improvements, but we are not convinced that these are so significant as to outweigh the harm identified above."
255. "View 15 is from Wood Street looking over Memorial Gardens towards the existing multistorey car park. In this view the development is visible in the townscape but is not dominant."
- comment: No it is clearly dominant, and obscures the wayfinding tower.
264. "The development is of a scale, mass, design and density that is considered appropriate in a town centre. The design of the building mitigates many of the impacts that a building of this scale could have on the surrounding area and designated heritage assets where some harm is identified this this balanced against the need for development on this site to come forward and the public benefits that have been set out elsewhere in this report. Accordingly the development is not considered to have an adverse affect on the character appearance of the area and would preserve the setting of adjacent heritage assets and views into and and out of adjacent conservation areas."
- comment: it is already established that the proposal would be too dense, 20% above GLAs upper limit; harms heritage settings; and this is alien to the existing character of vertical variation, variation in roof lines, scale. This statement is wishful thinking to the joy of the developer but to the dismay of the ordinary resident in the street.
267. Just 11% will be 3 bed flats
- comment: like TOPO the reasons are insufficient and same arguments apply.
311. "There is a reduction in the current parking provision. The Transport Assessment demonstrates that excess demand for the car park can be accommodated by alternative public car parks within Kingston Town Centre. An outline Car Park Management Plan is submitted in support of this application to demonstrate how this loss will be mitigated."
- comments: no mention of preventing residents from using on-street parking. This must be added as a condition - same as agreed for TOPO: no on-street parking permits will be provided for residents.
328. "In terms of daylight and sunlight there are a number of tests, the first being the hours of at the Spring Equinox (March 21st) and the second at the Summer Equinox (June 21st). Memorial Gardens will receive at an average of 4 hours of sun at the Spring Equinox and up to 8 hours at the Summer Equinox. United Reform Square will receive 4 hours of sun at the Spring Equinox and up to 8 hours and the Summer Equinox. Eden Circus will however receive very little sun
at the Spring Equinox with only 6% of the space receiving at least 2 hours of sun. At the Summer Equinox the majority of the space will receive around 4 hours of sun. Whilst the level of sun to Eden Circus will be limited it should be remembered that this spaces is designed as attractive public realm for people to pass through and not designed as an area which people would want to sit for long periods in winter and spring as United Reform Square and Memorial
Gardens provide better locations."
- comment: It is perfectly ok to sit there at the moment. This is an admission that it this space will be harmed by this development.
384. "The CIL liability for this scheme is approximately £5.6 million."
BUT 387. "they intend to apply for Exceptional Circumstances Relief from Kingston CIL in accordance with Regulation 55 of the Community Infrastructure Regulations 2010"
- comment: This is confirmation of how much contribution to local infrastructure like education and health that we WILL NOT receive from this development
386. "In relation to the S106 agreement for the site the developer is offering the following
● £1.6 million on commencement of development for off site affordable housing..."
- comment: This is an improvement from before!
410. Cumulative Impact: "In terms of impact on social infrastructure (education and health) all the developments are calculated to generate an additional 2,381 residents which would have an impact on health and education provision. All the developments have however been required to pay S106 monies or Local CIL towards these services and therefore the impacts are mitigated."
- comment: but we don't expect any CIL contribution from this development, and paying money is not the same as creating a funded strategy to provide infrastructure improvements. Crossrail2 wont be here for many years after this would be occupied.