KINGSTON AND NORTH KINGSTON NEIGHBOURHOOD
Conservation Areas Advisory Committee

PLANNING APPLICATION COMMENT FORM
DATE: 14 October 2020

CA25
 RBK ref:

20/02053/FUL 		Address: The Coigne 84 Lower Ham Road Kingston Upon Thames KT2 5BB

Planning Officer: Harsha Bhundia

Description of proposed works:

Demolition of existing three storey building, (previously converted into 2no.x flats), and erection of a four storey building comprising 7no. x flats with associated basement accommodation, car parking and reconfigured access.

APPRAISAL

By full committee on …… 14 October 2020 …… with …… 8 …… members present

Issued on 15 Oct 2020


1. Positive support
2. No objection
3. Objection
X
4. Objection unless revised as below
5. No comment/neutral
6. Lack of detail
7. Decision already issued



Reason for objection:

The applicant has retained the same scale, mass, density & design of the building but ‘pushed’ one of the five proposed accommodation floors into the basement, in place of the underground parking previously proposed. This gives his latest design a peculiar sunken appearance, unlike any other property on North Riverside. This would do harm to the character & appearance of the conservation area quite apart from being a flood risk – as conceded by the developer’s own flood report.

The proposal does not comply with guidance in the conservation section of the NPPF, the Historic Environment Good Practice Advice produced by Historic England, or Policy DM12 of the Council’s core plan in particular paragraphs b, e and f.

Previously the applicant did not submit a Heritage Impact Statement or provide any assessment of the impact of his proposals on heritage assets in his Design & Access Statement. He now does so but attempts to denigrate the significance of the property & its garden he would demolish to facilitate his scheme.

The Council’s own conservation area appraisal goes on to say that ‘the presence of a number of buildings of architectural interest….address the river and make a positive contribution to the character and appearance of the area. In particular, the large Victorian/ Edwardian house(s) at no. 84 Lower Ham Road….’ In other words, it would be a huge step to eradicate this heritage asset and there would have to be demonstrable public benefits from knocking it down. But there are none in this application. Therefore the existing building must be retained and cannot be demolished.

Section 4 of the core plan deals with neighbourhoods and refers to protecting & enhancing the quality of Thames Riverside, particularly nearby Canbury Gardens etc. We fail to see how this application meets that objective in any way.

Section 6 of the core plan sets out a number of thematic policies to provide a high quality environment with well-designed buildings & spaces and to protect & enhance the special character & environment along the Thames. We cannot see how this application satisfies those policies.

The Borough Character Study raises concerns about the conversion & redevelopment of large Victorian & Edwardian villas into blocks of flats. That is precisely what this application is seeking to do.

Policy DM7 on the environment states that ‘development proposals on riverside should preserve and/ or enhance the waterside character, heritage & setting….’ Yet this application would achieve no such thing.

Policy CS8 on design & heritage states ‘the Council will protect the primarily suburban character of the Borough, existing buildings & areas of high quality and historic interest from inappropriate development….It will ensure new development recognizes distinctive local features & character & has regard to the historic & natural environment…and relates well & connects to its surroundings’. How would that be the case here?

Policy DM10 on new developments states ‘development proposals are required to incorporate principles of good design….the character & local distinctiveness of a street or area should be respected, maintained & enhanced, eg in regard to
typology & density…scale, layout, height, form, massing…landscape setting & features…plot width & format including space between buildings….building line….typical details & features, eg roof forms, window format, materials, detailing etc.’
And yet this application fails on all these counts: 1) a proposed GEA of 1,300sqm would be more than three times the size of the existing property; 2) the proposed building would be twice the height of properties just a handful of metres away from it) &, with its roof-top lift housing & plant, still substantially taller than the existing flatted properties either side & the property it would replace. In fact despite the applicant’s modifications it would still be the tallest block on this stretch of Riverside, both a conservation area & adjacent to a strategic area of special character.

The applicant benchmarks the height of the proposed building to no.86-88 next door. That property includes a roof-top conservatory for which, from my research of your archive, I can find no planning consent. This is a cause for concern.

There are of course a number of flatted properties elsewhere on North Riverside but they all long predate the creation of the conservation area in 2004. Indeed we assume the conservation area was created to stop the building of any more of them. Even so, those that already exist are well-landscaped on generous plots which soften their impact. The proposed building would be crammed into its plot with virtually no landscaping or surrounding space (except car parking) at all.

Massing, overshadowing & overlooking are real concerns.

This application is in breach of London Suburban Policy & the Council’s SPD Policy Guidance 4, which set a maximum density limit of 75uph. The proposed density appears to be more than 30% greater at 98uph.

DM 10 says…’Development proposals should…have regard to the amenities of neighbours including their privacy, outlook, sunlight/ daylight, avoidance of visual intrusion, noise and disturbance…’. This development, however, would completely overshadow and overlook immediate neighbours, impair light, views, peace and privacy. The applicant has not bothered to update his deficient day/ sunlight study from 2017, merely stating now that a marginal reduction in height of his latest plans would improve the situation for neighbours.

Policy DM11 on design approach states…’New developments will be expected to have a contextual statement that demonstrates a clear understanding and analysis of the local area. The statement will also be expected to demonstrate how the new development will make a positive contribution to protecting and enhancing the local character of the area. The Council will resist any development that detrimentally affects the quality of the environment’. No such understanding or proper analysis is evident in this application.

For all the above reasons we reiterate our strong objection to this application and we trust officers will recommend refusal/Councillors will reject it.

As mentioned earlier, in our view the key to developing this site is sympathetic reinstatment of the existing heritage property into a family home, in keeping
with its original purpose, guidance in the NPPF and the Council’s own policies on maintaining the character & appearance of conservation areas.