The Riverside Residents Association registered our strongly held objections to the revised planning applications 20/02495/FUL and 20/02499/OUT
This letter of objection is submitted by the Riverside Residents Association (RRA) in response to changes made to outline application – 20/02499/OUT, namely the reduction in height of the tower from 22 to 16 storeys which removes the affordable housing element.
We previously submitted objections by letter dated 1st December 2020 to both the applications referenced above, and this letter supplements those objections. Our objections to 20/02495/FUL remain as set out in our 1st December objection letter.
In summary, the amended outline application is still very much contrary to policy, constitutes an unacceptable departure from the Development Plan and should be refused. We continue to object to the outline application because:
- The reduction in height is not so significant as to fundamentally alter the reasons for objection set out in our letter of 1st December 2020 – the residential tower (and the office buildings) remains totally inappropriate in scale given its local context and the provisions of the statutory Development Plan as it relates to the protection of heritage assets.
- The revision adds further reason for the Council to reject the scheme – the total lack of affordable housing provision.
It is very relevant to note that the reasons the previous Surrey House scheme (18/12119/FUL) was dismissed at Appeal were adverse impact on the setting of nearby heritage assets and the surrounding area, and inadequate provision of affordable and family housing. This is very relevant given the current scheme is bigger in scale and therefore even more damaging, and now offers zero public benefit in terms of affordable housing.
To this we would add that we have not seen any firm commitment from Unilever for the other element of public benefit – jobs, but in this regard we wish to make it absolutely clear that we, local residents do not see the provision of jobs as a price worth paying when they stand to cause huge damage by virtue of the scale, height and mass to our town centre heritage. We know there is the potential for a ‘win win’ – alternative schemes that will not damage our heritage (with less height) that can still deliver the jobs. We urge you to refuse this deeply damaging and unacceptable scheme, and advise the promoter to pursue policy compliant alternatives.
From 22 to 16 storeys
The policy position on tall buildings is very clear as set out in London Plan D9, Core Strategy CS8 and indeed the Secretary of State’s recent interventions in the London Plan. While the 2010’s delivered a lot of change, including a lot of development in Kingston in the period since the Core Strategy and Area Action Plan were adopted, the policies protecting and enhancing the historic environment and managing tall buildings remain as relevant now as they ever were.
In future policy documents Kingston’s policies in respect to tall buildings and protecting and enhancing heritage assets will continue. We know this because we have the Mayor’s intend to publish version of the London Plan with D9 strengthened by the Secretary of State for the Environment (SoS). We also have the Council and GLA’s joint vision for Kingston setting out where planning policy goes next – the Direction of Travel document.
The 2016 Kingston Direction of Travel document, jointly prepared by Kingston and the GLA promotes new homes, jobs and investment in the Borough. It presents what is referred to as a balanced approach of how development in the Borough should come forward. It is very relevant to note that it refers on pages 26/27 to what selective redevelopment could achieve, and this includes: “Continuing protection of Kingston’s historic environment (Listed Buildings, Buildings of Townscape Merit and Conservation Areas)”
And it concludes by stating: “We recognise that new growth must be balanced with the unique heritage and character of the borough. “
We, residents of the Borough, whole-heartedly agree and endorse these sentiments. Sentiments that we want to underpin how the next iteration of policy is formulated.
This balanced approach is a long running thread through Kingston’s planning policy, and must be maintained. The 2019 Local Plan Early Engagement document, the follow-on stage to the Direction of Travel does indeed continue this thread. As stated in the Administration’s foreword “The Local Plan is the document that sets out our long term vision for the required growth, whilst at the same time protecting the rich character, heritage and culture for future generations to enjoy.” We would add that it is right to optimise development opportunities, where development can take place without injurious harm to heritage, character etc. This is all well and good but, where these assets are found, a balanced approach is required to protect the things that make Kingston special. As the very first words of the foreword state “Many residents and visitors are attracted to the borough because of its rich history and character.” This is why we have planning policies, to allow development to come forward without damaging the very things that make ‘place’, and that need protecting from developers with myopic vision.
A balanced approach also reflects the requirements of the Planning and Listed Buildings Act (Planning statute) that requires special regard to be given to preserving listed buildings and their settings. This is the approach of the Borough and the GLA’s planning policies, which we respectfully point out need to be upheld.
We are concerned by some of the things we see, hear and read from the current Administration and Borough officers (such as pre-application advice and suggestions that all policies are out of date) that ignore the Borough’s/Mayor’s statutory development plan. We hear of a new vision for Kingston developed by consultants that may be influencing the Administration, but we see no evidence of the promised public engagement in preparing this, and indeed we don’t see the new vision. All highly undemocratic given this seems to be influencing how the Surrey/Lever House applications are being considered by the Council. As we say earlier, the policies addressing tall buildings and the protection and enhancement of our heritage assets are timeless, and the values underpinning them are just as relevant now as ever. The Council should not seek or allow these policies to be devalued.
In respect of the chopping of 6 storeys we note that Darling, the architects of this scheme in their submission openly acknowledge that what they originally proposed was totally unacceptable. They state in support of 16 storeys “the residential building remains visible but no longer overwhelms the view.” Very honest, “overwhelms the view”, but a very sad indictment of their and Unilever’s approach – and a very calculating and disdainful modus operandi – come in with something nobody (except the Council) is going to like, take the flack and chop all the affordable housing out. However, the issue remains one of the fundamental point – the Surrey House /Lever House site is not identified for buildings above eight storeys, and this is the position in the Borough’s adopted Plan, was comprehensively upheld by a Planning Inspector in 2019, is maintained by the Mayor of London’s new Plan and indeed a position reinforced by the SoS.
Thus, chopping six storeys is neither here nor there when it comes to the fundamental principles – 16 storeys plus the two tall office towers (12 and 9) creating a cluster of tall buildings is contrary to policy because i) they are not plan-led as required in policy and ii) individually and the group will be highly visible and loom over the heritage assets (as shown in the CGIs), destroying the value of these assets, and ruining the experience of Kingston town centre for us and generations to come – refuse. The Council must advise the promoter to come back with a policy compliant scheme, or seek to promote the scheme through the Local Plan review, which is the appropriate route.
Core Strategy policy DM15 seeks schemes such as this to provide an element of affordable housing. It is simply not credible for the promoter to expect the Council and local community to accept that such a dense scheme in the heart of Kingston cannot deliver any affordable housing at all. We are not able to interrogate the promoter’s viability case to disprove the numbers, and urge the Council to review the promoter’s costs to determine where they are not being fully transparent.
It remains firmly our view that these applications are so damaging and unacceptable, contrary to Core Strategy Policy CS8 and London Plan Policy D9 that no material consideration can possibly outweigh the harm that would result to our heritage assets, and both applications must be refused. We are resolute in our desire not to degrade our heritage assets through the Council permitting such inappropriate development. We would find it totally unacceptable were the Administration to approve these applications, and would support others in the pursuit of over-turning any such decision through the Courts or by other means.
We see the desirability of redevelopment and improvement of the Surrey House site, and we urge the Council to make clear to the promoter and Unilever that their scheme is unacceptable and they need to consider alternatives that balance the need for new growth with respecting local character and distinctiveness in accordance with the statutory Plans and the guidance from Historic England.
Robin Catlin FRICS
Vice Chair, and Chair of Planning and Development Sub Group
Riverside Residents Association