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29 Oct 2020

Response to public consultation on HMG white paper: Planning For The Future

Introduction & Background

I write on behalf of the Kingston Town Conservation Areas Advisory Committee or ‘CAAC’. It is one of three CAACs covering the 30 or so conservation areas in the Royal Borough of Kingston-upon-Thames. The Kingston Town CAAC, which I chair, is responsible for providing advice to councilors & officers on conservation matters affecting the nine conservation areas in Kingston Town. We are an independent non-statutory body comprising a small number of volunteer residents with experience of planning, architecture, archaeology & conservation. We meet monthly to review planning applications & infrastructure works in our conservation areas & to make recommendations on the designation of heritage assets.

Summary of Views

We support many of the aspirations of the White Paper: eg simplification & streamlining of the planning process; greater democracy & transparency in decision-making; much more use of digital technology; the importance of establishing & maintaining ‘beauty’ & ‘net gains’ in Protected Areas etc. We do, however, have concerns with a number of the proposals, as follows:

  1. National Development Management Policies, Zonal Guides & Codes vs Local Plans. We agree that Local Planning Authority (LPA) plans should be simplified (Proposal 2). Note that Kingston’s Core Strategy, last updated in 2012, runs to over 1,000 pages. Whilst we are not opposed in principle to National Policies & Design Guides/ Codes, they must reflect local neighbourhood involvement & priorities, particularly in Protected Areas. Otherwise they could become too generic in nature & therefore inappropriate to the circumstances of individual boroughs & sensitive areas within them. Developers must have enough incentive to continue to engage constructively with local communities on planning matters, which would unlikely be the case with a blanket one-size-fits-all approach to policy & guidance. We therefore agree that neighbourhood plans should be retained in the reformed planning system (Proposal 9) & that design guides & codes be prepared locally with community involvement (Proposal 11). In fact it may make more sense to have two rather than three zones: 1) Growth/ Renewal; & 2) Protected; with the criteria for each zone to be presented to & agreed by the public using eg VuCity. The critical challenge will be dealing with transition zones between these two polar points. This is where design managers & historic advisers should bring their skills & experience to bear. Transparency & good communication will be essential to gaining public confidence in the new system. An overriding challenge with all this will be who monitors developments? Whether in- or outsourced by LPAs we agree each should appoint a ‘champion’ for (good) design & place-making (Proposal 12). Furthermore, we think they should ensure a qualified heritage officer/ conservation architect is assigned to each Protected Area.

  2. Tall Buildings & Air Rights. These concepts may work effectively in global conurbations, like New York City, but they are inappropriate in suburban settings such as Kingston, with its historic centre & nearby Royal Parks. As a CAAC, we are already challenged by planning applications for high-rise towers (more than 12 storeys) in the Borough that we believe cause substantial harm to the character & appearance of its precious conservation areas.

  3. Conservation Areas. We consider it essential that all conservation areas are Protected Areas. The White Paper is not absolutely clear about this. It should be.

  4. ‘Harm’ Test. In principle we support the replacement of this test for development in conservation areas with a ‘net gain’ approach, providing it involves a higher hurdle for developers to overcome. In our experience aspects of the current test, such as the ‘less than substantial harm’ approach to managing development in or close to these areas, are not particularly helpful & can facilitate poor planning outcomes. This can be a real issue in transition zones. The integration of new with old requires skilled expertise in order to achieve a harmonious resolution.

  5. Listed Buildings. We are concerned by comments in the Paper (Proposal 17) that ‘experienced architectural specialists can have earned autonomy from routine listed building consents.’ No details are provided of how ‘routine’ is defined. Many works that may be considered ‘routine’ can have a serious impact on the architectural interest of a listed building, particularly if an architectural specialist is unfamiliar with its context & history. One example is re-roofing where roofing styles vary throughout Surrey County, from plain clay tiles in the South to pan-tile roofs closer to the River Thames. The same is also true of pointing & plastering work. In addition, there is a risk of architectural specialists benefitting financially from inappropriate work, in order to save their clients costs. We strongly believe there should be independent oversight of work to ensure no long-term harm is done to historic buildings & areas of special interest. Several conservation areas in Kingston Town have suffered from a range of substandard building extensions & modifications, facilitated by Permitted Development Rights & a lack of resources in LPAs, including Kingston, to control activity. In common with many other London boroughs, there is no Conservation Officer in Kingston nor has there been for some years. If Government is serious about conserving & enhancing our heritage, then it must work with LPAs & ensure adequate regulation & funding are in place to achieve these outcomes.

  6. Archaeological Interest. We would encourage the new system to give appropriate weight to proper archaeological excavation & study in the development management process.

I hope you find these comments helpful. My colleagues & I look forward to seeing details of the next stage in this review process.

Mr N T Hiscock
Chair, Kingston Town Conservation Areas Advisory Committee