1. Visual Impact & Conservation Areas
1.1 There is no doubt the massing and tall buildings on this site will have an impact on short-range, medium-range and long-range views in the setting and within the vicinity of historic cultural assets, sensitive royal park views and protected conservation areas.
For this latest scheme, with the lowering of tower "J" and the changes to its massing, the negative impact is slightly reduced. However the updated Visual Impact and Built Heritage Assessment study is still disappointing in its interpretation and conclusions. It is less than impartial, playing down the impact in favour of the development. Dominance of trees in visualizations, on roof tops and "partially obscured by trees" statements all point to a lack of architectural merit. This is a general point that applies throughout the submission.
1.3 An important long-range view consideration is the impact on the skyline from the vantage point of Richmond Park. It can be argued that this this is a major change with an adverse penetration into a highly sensitive view, not “moderate” as stated in the Visual Impact documentation. This and similar comments indicate a rather cavalier attitude to the sensitivity of the views which would be affected in the Borough.
The visual impact is significant in such a sensitive context.
2. Height & Scale:
2.1 Due to its excessive, bulk, scale, height and massing, the proposal would produce a development which would dominate and fail to respond to the surrounding prevailing heights in its immediate context. At 61.6 m high, tower ‘J’ breaches current tall building heights in the vicinity (Unilever House approx 35m, Kingston College approx 51m). This is especially important as it will set a height precedent for later planning submissions in the vicinity.
2.2 Due to its excessive, bulk, scale, height and massing, the proposal would the development would fail to
meet the requirements for tall buildings in the London Plan. Policy 7.7 states "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."
2.3 The excessive, bulk, scale, height and massing would have an adverse impact on the urban form in this part of the town. This development is inappropriate in that it would cause significant harm to short-range views and the related public realm by overbearing and dominating the surrounding streets and buildings, in particular the two listed buildings on the site, Ashdown Road, the site to the North of Ashdown Road, and the two storey Victorian conservation areas to the South and East. From a point of view of human scale, the perception could be overwhelming from ground level. The 13 storey tower on Ashdown Road will compromise the site to the North of Ashdown Road, in terms of overbearing, daylight, sunlight and overshadowing. The impact of the development on the daylight and sunlight received by other buildings or sites in the vicinity would be a substantial omission if it is not addressed by the Environmental Statement.
2.4 Due to its excessive bulk, scale, height and massing, the development would fail to meet the requirements as set out in the recently adopted Eden Quarter Development Brief SPD for this specific location. It should be noted that many considered this SPD to be more than generous in it's height guidance.
Item 3.16 in the SPD gives a guidance of 9+ storeys for a landmark building on the South West corner. With the proposed landmark tower the submission has interpreted 9+ storeys to mean that there is effectively ‘no limit’ on height for this corner of the site. The SPD does not stipulate a storey ‘cap’ in words, but the section drawings of the proposed buildings and artists impressions show nothing above 13 storeys. 13 is a reasonable interpretation of "9+ storeys". The proposed 19 storeys - more than double '9 storeys' - is not a reasonable interpretation of "9+ storeys". It is clear the development is disregarding the spirit of the SPD specific to this context.
Item 3.16 in the SPD gives a guidance of 6 - 8 storeys across the rest of the site. With the proposed 13 storey Ashdown Road tower, again the development would fail to meet the requirements SPD on height - and again not just marginally. It would be 50% taller than the height specified by the SPD. This presents the additional problem of competing for prominence with the corner which is designated as 'landmark' by the SPD.
Significant harm would be caused for the following reasons:
harm to short, medium and long range views;
harm to the setting of the listed buildings on the site,
harm to to the conservation areas adjacent;
harm to the skyline.
We agree with the South East Regional Design Panel (SERDP) report where they state "The 13 storey block...fails to meet the requirement of the SPD to be sensitive to the scale and material pallet of the listed buildings"
2.5 It is surprising to see no new basements in the scheme - only the existing old post office and Telegraph buildings will have basements. For neighbouring residents, an efficient use of the site would naturally include a basement. Indeed they would be refused planning permission to build upwards so expanding down into basements can be the only option. There is a strong perception that planning rules may not apply fairly to all when we see this proposal's 13 storeys flouting the generous 6 - 8 storey provision given in the Supplementary Planning Document.
The proposed development must be modified to comply with the generous height guidance given by the Eden Quarter Development brief SPD. Landmark Tower J should be reduced to 9-13 storeys and the Ashdown Road Tower to 6-8 storeys.
The proposal fails to comply with the SPD by a large measure.
The site is over developed.
The Planning Submission Addendum states:
The proposal does not represent the high quality of accommodation that the Council should be seeking for this central site The implications of building sub-standard housing stock on future inhabitants and the existing community should be considered carefully.
The proposal fails to comply with standards on density specified by the London Plan.
Page updated on 5th May 2015
5. Viability and contributions to Affordable Housing and infrastructure:
5.1 There is insufficient Affordable Housing and the CIL and S. 106 contributions not specified.
The Affordable housing Statement states:
The Affordable Housing SPD states "The financial implications of complying with the affordable housing policy need to be factored into the land value when purchasing a site. If no regard is paid to these implications the resultant financial consequences will have to be borne by the developer."
The application has failed to provide sufficient affordable housing with this application, either within the development or elsewhere within the Borough. The development is therefore contrary to the Affordable Housing SPD on affordable housing provision. Again the proposal fails to comply by a large measure.
6. Parking, Transport, Infrastructure and Services:
6.1 The submission incorrectly down-plays the need for and impact on parking, transport, infrastructure and local services.
The Planning submission Addendum states:
7. Ineffective public consultation
7.1 The submission lists who, how and how much consultation was carried out. While this looks impressive, we are not however convinced of it's effectiveness.
It should be noted that none of the documentation (neither consultations nor exhibitions) make explicit mention of the possibility of a 21 storey building, and because of this significant exclusion we believe the public consultation has been misleading. We continue to note the large proportion of residents and visitors we are reaching, who remain unaware of the proposed scale and impact. Their main surprise and alarm is the bulk, scale, height and massing. This was not well conveyed by glossy perspective illustrations that emphasize the space around the Old Post Office building while being less informative on the scheme as a whole.
7.2 How effective is the feedback from consultation? We don’t know to what extent feedback has been considered and acted upon.
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.” This has not happened in regards to concerns over height.
8. Public Realm
8.1 The new Post Office square features heavily in selling the proposal, yet there are doubts as to how suitable and use-able it will be. Unlike the intimate, sunny south facing Apple market bounded by characterful 2 storey buildings - the new Post Office square will be overwelmed by tall buildings to the south, casting almost permanent shade over what could become quite a hostile wind swept and damp thoroughfare. We agree with SERDP's conclusion that they were not convinced of the Apple Market example for this space - for example the orientation of the space and the effect of sunlight and overshadowing from the taller buildings to the south.
8.2 We see little consideration to mitigate any wind speed or turbulence or overshadowing effects such as through the use of podiums at lower levels. It is not obvious that the environmental study indicates environmental problems in the public realm but there was no wind tunnel testing using a scale model of the development to counter this negative expectation.
8.3 Planning obligations sometimes encourage public art to be supplied at 1% of total construction costs. It is disappointing to see no provision of public art.
8.4 It is proposed that this development will have the tallest building in the vicinity. Public access to new tall buildings can promote their use at different times of the day, fostering a more positive perception of the building and allowing the community and visitors to make effective use of it. It is disappointing to see no provision of managed public access to upper floors in the proposal.