Response to Application 20/02495/FUL – Surrey House site.

Part of our response to the “Eden Campus” Planning Applications

20/02495/FUL : Surrey House, 34 Eden Street NCP Car Park, St James Road Former Hippodrome, Eden Street And Bo Concept, The Roundhouse 20 Eden Street Kingston Upon Thames KT1 1ER

Full planning application for the Redevelopment of Surrey House (etc) to provide Office and Car Parking facilities (etc)

Planning Officer: Toby Feltham

Objection

This Society, which promotes high standards of planning, conservation and design, strongly objects to application 20/02495/FUL referred to henceforth as the current scheme, for the reasons set out below. We also object strongly to the second phase of the overall development submitted as application 20/02499/OUT (a residential tower) for which we have responded separately. For the sake of determining the applications I have summarised our conclusions here, followed by our reasoning:

Our main objections:  

  1. Harm to the settings and significance of designated historic assets.

The height, mass and bulk of the proposed buildings would dominate the settings of the adjacent and nearby United Reformed Church, the Old Post Office and Guildhall Grade II listed historic assets. It would intrude into the uninterrupted views above the roofline of the Market Place, disrupting its varied and traditional roofscape, diminishing the value and significance of the heritage assets therein.

This harm is equal or greater than that described in the Appeal Decision for the previous scheme. The Planning Inspectorate determined that  there were compelling reasons to dismiss the Appeal on the basis of “harm to the settings and significance of the following designated heritage assets alone: the Old Post Office, the United Reformed Church, the Guildhall listed buildings, the listed buildings on the east side of Market Place and the Kingston Old Town Conservation Area”. The Inspector considered this to be determinative in the Appeal on the basis of paragraph 11(d)(i) of the Framework and he needed to go no further.  To be consistent with the Appeal Decision of the Secretary of State for the previous scheme, Planning permission must be refused.

  1. Harm to character and appearance of the area.

The overall height, mass and bulk of the proposed development, consistently above the 6-8 storey guideline in the EQDB, would have a poor relationship with the smaller scale of the Old Town townscape and fail to achieve the graduation in heights, modulated roofscape and variety of architecture expected.

Due to its height, scale, massing and form the current scheme would cause harm to the character and appearance of the surrounding area.

  1. Conflict with tall building & public realm policies.

Tall Buildings are limited to three locations defined by the ‘Eden Quarter Development Brief EQDB’. This site isn’t one of them. The 2 office towers would encroach into important and protected views. The bow fronted north facade would dominate and repurpose Eden Square into its own forecourt while constricting at the corners – failing to deliver the aspirations for Eden Square. Changes to the Hogsmill area would blur the southern boundary, thereby claiming private ownership of this public space as the setting for the proposed tower.

Due to its design, height and location the current scheme would conflict with planning policies on the location and design of tall buildings and the treatment of the public realm.

The recent Appeal Decision

The recent appeal decision of 2019 by the Secretary of State is the starting point for evaluating these proposals. The site is the same, the location is within the settings of the same designated heritage assets and area, and much the same planning policies apply.

The reasons why the previous scheme was so robustly refused:

  1. In his Appeal Decision for the previous scheme the Secretary of State considered “the harm to the settings and significance of the designated heritage assets alone to be determinative in this appeal and on the basis of paragraph 11(d)(i) of the Framework I need go no further”.
  2. “However, I have found that the proposal would have a number of other adverse impacts. I have concluded that the design of the proposed development would cause significant harm to the character and appearance of the surrounding area, in terms of its height, massing, bulk and form and its overall impact on the public realm. Given the scale of harm I have identified, I attach significant weight to this as an adverse impact of the proposal.”
  3. It would “conflict with the design policies in the development plan, including Policies CS8, DM10 and DM11 of the Core Strategy and Policies 7.4,7.6 and 7.7 of the London Plan… Given the important role they play, together with the associated EQDB, in guiding the location and design of tall buildings in Kingston and in the treatment of the public realm, I attach significant weight to the proposal’s conflict with these policies and with the design expectations of paragraph 127 of the Framework”

Here below I set out the reasoning for our objections:

Reasoning for Objection 1. Harm to the settings and significance of designated historic assets

NPPF 

The NPPF makes it clear that the Government attaches ‘great weight’ to the conservation of designated heritage assets, including their settings (paragraph 193 and 194), and ‘Good design is a key aspect of sustainable development’ (paragraph 124). The design policies in paragraphs 124 to 132 make several references to the importance of good design responding to local character and history, and integrating new buildings into the historic environment. In addition, the NPPF confirms that the significance of heritage assets derives not only from a heritage asset’s physical presence, but also from its setting (paragraph 194).  These principles are central to this application as they were in the Appeal decision for a previous application on this site. The Appeal Decision document (ref APP/Z5630/W/19/3223667)

At the Inquiry held over 7 days in June 2019, the applicants appeal was dismissed by the Secretary of State and planning permission was refused. The Appeal was for the previous scheme on this site and details the basis of the decision and provides an important basis for assessing the current scheme. It follows that if the harm is the equivalent or worse, then the same conclusion should be reached: that planning permission should be refused.

We conclude that the harm to the settings and significance of the designated heritage assets is equal or greater than the Appeal scheme, therefore planning permission must be refused.

In his Appeal Decision for the previous scheme the Secretary of State considered “(98)..the harm to the settings and significance of the designated heritage assets alone to be determinative in this appeal and on the basis of paragraph 11(d)(i) of the Framework I need go no further”.

The abbreviations below are the same as in the Appeal Decision document:

  1. OPO – Old Post Office
  2. URC –  United Reformed Church
  3. KOTCA – Kingston Old Town Conservation Area

Context:

“Kingston upon Thames was historically an important trading town dating back to the middle ages. Despite the number of large scale, post war developments in and around the town centre, Kingston retains its historic street pattern, with  a number of listed buildings and the largely intact KOTCA, which provide an important heritage context for the site and proposal. The site lies within the setting of a number of heritage assets. The Framework defines the setting of a heritage asset as the surroundings in which it is experienced and confirms that its setting may contribute to the significance of a heritage asset”

The Appeal Decision goes on to state “(27) ..the proposed development would affect the settings of the OPO and URC Grade II listed buildings which lie opposite the site’s main frontages; the KOTCA to the immediate west of the site; the Grade II listed Guildhall and the Grade I listed Clattern Bridge and Coronation Stone, located within the KOTCA to the west of the appeal site and in the context of which the proposed building would be seen in views to the east; the Grade II* listed Market House together with a number of listed and unlisted buildings of townscape merit on the east side of Market Place, from where the Appeal scheme would be visible above their rooflines in views to the east; and a number of non-designated heritage asset buildings along Eden Street, framing views at the entrance to the KOTCA, Market Place and Apple Market, which the proposed development would be seen within.”

“(28). Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 establishes that in exercising planning powers on behalf of the Secretary of State in this appeal, I must have special regard to the desirability of preserving a listed building or its setting. Whilst no statutory protection is afforded to the setting of Conservation Areas, paragraph 194 of the Framework confirms that the significance of a designated heritage asset can be harmed by development within its setting. Policy 7.8 of the London Plan also expects development affecting heritage assets and their settings to conserve their significance by being sympathetic to their form, scale, materials and architectural detail. In addition, Policy DM12 of the Core Strategy seeks to ensure that development will preserve or enhance locally distinctive heritage assets, allow alterations which preserve or enhance the interest of a heritage asset or its setting, and respect features of local importance through consideration of form, scale, layout and streetscape”

The Old Post Office (OPO) and United Reformed Church (URC) Grade II listed buildings 

The proposed facade at the North-east and north-west corners and along Eden street would in particular affect the settings of the OPO and URC Grade II listed buildings. While we acknowledge that the form of the upper storeys which are stepped back is very slightly mitigating, it remains true that the proposed buildings would partially obscure OPO & the sheer scale of the proposed development would have a harmful impact on the proud civic character of the OPO within its setting. Compared to the Appeal scheme the proposed buildings would be equally harmful to the setting of the OPO. 

The proposed buildings differ from the Appeal scheme at the north-west corner opposite the URC. The facade would now extend to the corner where a triangular open space was formerly proposed. This is shown vividly in outline in View 27. The applicant said this open space and public realm was to have “opened up views towards the church from St.James’s Road and increased the presence of the church on this junction”. This mitigation is gone from the current scheme which is more harmful as a result.

The URC would be dominated by the height, mass and bulk of the proposed buildings, thereby diminishing its value and significance as a heritage asset. It would harm the URCs prominent position in the town centre as a landmark and focal point for the community. The degree of harm compared to that of the Appeal scheme is increased by extending the facade into what was to be open space though it is slightly mitigated by the form of the upper storeys which are stepped back. The net change compared to the Appeal scheme is more harmful to the setting of the URC. 

The Guildhall Grade II listed building 

The Appeal Decision states ”(37).The significance of the Guildhall lies in its historical, communal and aesthetic value. Built in the 1930s, its neo-Georgian design is a well-preserved example of monumental civic architecture of that period. The striking combination of its semi-circular frontage and tower also gives it a landmark status within the KOTCA. The Guildhall stands on its own, set back from the High Street, with gardens to the front and rear and the Hogsmill River to the south-west, forming its immediate setting. The open and landscaped character of these surroundings contribute to the civic status and heritage significance of the Guildhall in terms of its communal and aesthetic value.”

In the applicants TVIBHA Part 6 document, views 22 and 23 compare the Appeal scheme with the current. These were numbered 7 and 9 in the Appeal scheme.

The Appeal Decision states “(39). the proposed development would introduce a much more prominent building in the background and wider setting of the Guildhall. On the basis of the AVRs of the proposal for views 7 and 9, when seen from the High Street and the footpath alongside the Hogsmill River, the proposed building would rise above the parapet wall of the Guildhall on both the front and rear elevations. It would close up the space in which the Guildhall is experienced and present an imposing façade which would visually compete with the height, form and roofline of the Guildhall, causing harm to its setting and the contribution this makes to its heritage significance as described above.”

Views 22 and 23 clearly show the same applies to the proposed development. Therefore compared to the Appeal scheme the proposed buildings would be equally harmful to the setting of the Guildhall. 

Market House and Market Place

The Appeal Decision states “(41) The KOTCA Character Appraisal describes Market Place as the heart of Kingston, of historical importance as the focus for trade and hospitality since the Medieval period. The buildings which flank Market Place are of both historic and aesthetic value due to their variety of vernacular architecture dating from the 15th century. At its centre is Market House, a Grade II* listed building of historical importance, as the former town hall, and of aesthetic value, in its well preserved Italianate style architecture, dating from the early Victorian period.”

And “(42). The immediate setting of these buildings within Market Place is an important component of their heritage significance, but the wider setting also makes a positive contribution. Apart from the views of All Saints Church and the Guildhall to the north and south, development beyond the Market Place and Conservation Area does not noticeably intrude into views from within the space. This preserves the historical sense of enclosure created by the surrounding buildings and allows the varied roofscape which is so characteristic of Market Place and the Old Town to be appreciated against the open sky.”

And “(43) ..it would still create additional intrusion into the currently uninterrupted views above the roofline of the buildings on the eastern side of Market Place, disrupting its varied and traditional roofscape, in a different location to the EW and OPO schemes“

“(44) As such, the proposal would be cumulatively harmful to the setting of the buildings on the east side of Market Place, including both the listed buildings and the unlisted buildings of townscape merit which contribute to the character and appearance of the KOTCA. Therefore, it would be harmful to the significance of these heritage assets. However, any harm to the setting of Market House in these views would be limited by the fact that the proposed building would sit below its parapet, and would not visually compete with its corner roof pavilions.”

In the applicants TVIBHA Part 6 document, views 18 and 19 compare the Appeal scheme with the current scheme. It is clear that the intrusion is increased by both the proposed Eden Street building.

Compared to the Appeal scheme the proposed buildings would be more harmful to the settings of the buildings on the east side of Market Place. 

Kingston Old Town Conservation Area  

The Appeal Decision states “(45). The KOTCA Character Appraisal advises that the character and appearance of the Conservation Area could be affected by development beyond its boundary affecting views within the area or the settings and backdrops of buildings and views towards its principal landmarks. Policy CA1.5 of the Character Appraisal states that particular regard will be had to development proposals in locations immediately adjoining the KOTCA and defined as the Old Town CA Hinterland. The north-western quadrant of the appeal site sits within this hinterland”

And “(46). I have considered above the impact of the proposed development on the settings of the key heritage assets within and outside of the KOTCA. The harm to the setting and significance of the URC at the gateway to the KOTCA and of Market Place and the Guildhall within it would also result in harm to the setting and therefore the character and appearance of the KOTCA”

And “(47). In addition, the TVHA considers the effect of the proposal on the view out of the KOTCA along Eden Street from the corner of the Market Place, which is framed by the three storey high frontage on the south side of Eden Street. This gateway into and out of the KOTCA is characterised by a gradual transition in building heights and scale along Eden Street, including the existing buildings on the appeal site beyond the Conservation Area boundary, which respect the low rise character of the KOTCA. However, the AVRs and kinetic evidence show the proposed building rising steeply above the height of the buildings within the KOTCA on Eden Street. The abrupt increase in the height, mass and bulk of the buildings on the appeal site would have a dominating and overbearing impact on this gateway into and out of the KOTCA. It would cause harm to its setting and thereby result in further harm to its character and appearance at this point.”

In the applicants TVIBHA Part 6 document, view 24 compares the Appeal scheme with the current at this location. It is clear that although the form of the proposed building is stepped back at the upper floors, this does not successfully mitigate against its impact as described in the Appeal Decision, rather the height and bulk of the upper part of the building is increased in this view.

Compared to the Appeal scheme the proposed buildings would be more harmful to the setting and therefore the character and appearance of the KOTCA.

Conclusion

The harm the proposed buildings would cause to the settings and significance of the designated heritage assets is equal or greater than that described in the Appeal Decision for the previous scheme.

Therefore for the reasons stated in the Appeal Decision there are compelling reasons to dismiss the appeal on the basis of harm to the settings and significance of the following designated heritage assets alone: the Old Post Office, the United Reformed Church, the Guildhall listed buildings, the listed buildings on the east side of Market Place and the Kingston Old Town Conservation Area. The Planning Inspector considered this to be determinative in the Appeal on the basis of paragraph 11(d)(i) of the Framework and he need go no further.

To be consistent with the Appeal Decision of the Secretary of State for the previous scheme, Planning permission must be refused.

Reasoning for Objection 2. Harm to character and appearance of the area

Harmful visual impact on the old townscape. 

In the Appeal decision the Inspector states “10. In addition, the EQDB provides guidance on the heights, scale and massing considered appropriate for new development within the area5. It specifies a range of heights from 1-8 storeys, which have been informed by the generally low rise nature of the town centre, significant heritage assets, viewing corridors and building typology.”

Of the consented Eden Walk Scheme he says  (13)“..On the Union Street frontage, however, closest to the low rise townscape of the KOTCA, the building heights of the EW scheme range from 4-6 storeys broadly in line with the guidance. Where building heights do notably exceed those anticipated in the EQDB, such as on the Eden Street frontage of the EW scheme opposite the appeal site, the roofline is substantially modulated and stepped down, ranging from a 4 storey podium, at just under 15 metres high, to 10 and 11 st²orey elements, of 33 and 36 metres in height. The varied architecture and use of materials on both of these emerging schemes, also helps to break up the mass of the buildings”

In contrast the current schemes’ Eden Street frontage closest to the low rise townscape of the KOTCA would be 6 storeys, some 32 meters high before it is set back. This form would create an abrupt change of height at the Eden Street and St James Road corner where it meets the low rise nature of the town centre. The alien ‘eighties’ wrap around glazed office design worsens the visual impact of the overall height, mass and bulk of the building on the streetscape in Eden Street and St James Road and intensifies its poor relationship with the smaller scale and varied architecture of the old townscape. This can be clearly seen in outline in view 27:Union Street.

Bulk and height would overwhelm and overshadow Eden street 

The Appeal Decision states (21) “The lack of a set-back on Eden Street would also result in a poor relationship between the increased height and bulk of the proposed building and the proportions of the future pedestrian environment along Eden Street. A continuous 9 storey and 31 metre frontage along the north facing side of the building would be likely to overwhelm and overshadow a pedestrian environment confined to the existing pavement widths along Eden Street. Indeed, the Daylight, Sunlight and Overshadowing Report submitted with the application indicates the extent to which the proposal would overshadow the public realm in Eden Street for large parts of the day throughout the year.”

The proposed buildings’ 6 storeys, 32 meters high frontage to Eden street would similarly overwhelm and overshadow Eden Street.

Reasoning for Objection 3. Conflict with tall building & public realm policies

Location and design of tall buildings where there should be none.

The two proposed office towers would be above 30 meters in height and therefore classed as tall buildings.

Policy C8 of the Kingston Core Strategy 2012 states that “tall buildings may be appropriate within the Borough’s town centres but that some parts will be inappropriate or too sensitive for such buildings.” It provides that SPDs will provide further guidance on this matter AND that applications will be determined based on the criteria in the English Heritage/Cabe Guidance on Tall Buildings (July 2007) and the London Plan.

The relevant SPD in this context is The Eden Quarter Development Brief 2015 (EQDB) and as such should be considered as an integral part of the Kingston Development Plan.  Only three sites are identified in the EQDB as suitable for tall buildings in the Eden Quarter.

The EQDB states “In specific places more significant height has been proposed. These building heights have only been proposed in locations where it is considered to be appropriate, either due to lower impact of the beneficial impact of establishing a landmark.” Landmark towers have already been approved at such locations for Royal Exchange and Eden Walk.

The proposal in this full application for two tall buildings does not comply in any way with this expectation.

None of the approved “tall” building locations identified in the EQDB are situated in the Development site which states heights are to be limited to 6-8 storeys ie below 30m.

Furthermore LonP Policy 7.8 makes it clear that development affecting heritage assets and their settings should conserve their significance, by being sympathetic to their form, scale, materials and architectural detail.  Importantly,  as there is no reference to balancing harm with public benefits in policy 7.8 of the London Plan, which states that development affecting heritage assets and their settings should conserve their significance. The proposal are inherently in conflict with that policy.

Emerging Plan 

The emerging plan comprises the Intend to Publish London Plan (IDLP) 2019 (including Policy D9 (tall buildings) is directed by the Secretary of State to carry significant weight in any current applications and should therefore be considered in the context of these applications.

IDLP Policy D9 specifies that Boroughs should determine (i) if there are locations where tall buildings may be an appropriate form of development, subject to meeting the other requirements of the Plan; (ii) Any such locations and appropriate tall building heights should be identified on maps in Development Plans; and (iii) Tall buildings should only be developed in locations that are identified in Development Plans.

These provisions confirm the core principle of LonP that the location of “tall” buildings must be controlled and therefore reinforces the continued relevance of C8 and the EQDB in evaluating the current applications.

Policy D9 IDLP further requires that  “Proposals (for “tall” buildings) should take account of, and avoid harm to, the significance of London’s heritage assets and their settings.

Proposals resulting in harm will require 

  • clear and convincing justification, 
  • demonstrating that alternatives have been explored; and
  • that there are clear public benefits that outweigh that harm. 

There is no clear and convincing justification for the proposals put forward by the Applicant primarily it would appear because they do not accept the harm that would be caused to heritage assets. Nor is it demonstrated that any alternatives have been explored which would deliver on the expectations of the EQDB and avoid harm to heritage assets . Again the justification for not doing so appears to be the Applicants contention that there is no harm to Heritage Assets and the assertion by the Applicant that the EQDB is not policy. We do not believe either of these assertions to be correct.

The harm to multiple heritage assets is clearly articulated in the abovementioned Planning Inspectorate Appeal decision and the same rationale is equally applicable to the current proposals.

HISTORIC ENGLAND 

Historic England (HE) is the Government’s expert adviser on the historic environment.  HE issued Tall Buildings Advice Note 4 in December 2015 which updates the previous guidance by English Heritage and CABE referred to in C8 above.

This Advice note 4 is therefore a material consideration for all planning applications involving Tall Buildings.

Two of the buildings which are the subject of this FULL application constitute tall buildings as they are over 30 metres in height. The HE guidance note is therefore applicable to these buildings in addition to the residential building the subject of 20/02499/OUT

The HE Advice note 4 requires that “when considering any proposal that has an adverse impact on a designated heritage asset through development within its setting, ‘great weight should be given to the asset’s conservation’, with any harm requiring a ‘clear and convincing justification’ (NPPF paragraph 194). In assessing this justification, and in weighing any public benefits offered by a tall building proposal, local planning authorities will need to pay particular regard to the policies in paragraphs 8 and 9 of the NPPF that state that economic, social and environmental gains are to be sought jointly and simultaneously in order to deliver positive improvements in the quality of the built, natural and historic environment. This may involve the examination of alternative designs or schemes that might be more sustainable because they can deliver public benefits alongside positive improvement in the local environment… There may be good planning reasons to seek an increased development density in an area, but tall buildings represent only one possible model for delivering higher density development. Alternative forms may relate more successfully to the local context.”

The Advice note goes on to make it clear that “If a tall building is harmful to the historic environment, then without a careful examination of the worth of any public benefits that the proposed tall building is said to deliver and of the alternative means of delivering them, the planning authority is unlikely to be able to find a clear and convincing justification for the cumulative harm.”

In the case of the current application it does not appear that the applicant has been required to explore and report on “any alternative designs or schemes that might be more sustainable because they can deliver public benefits alongside positive improvement in the local environment” . Indeed the applicants appear merely to understate and dismiss the harm caused to Heritage assets and their settings and accordingly fail to provide the justifications and analysis required.

Furthermore as HE states “A rigorous process of analysis and justification will be needed in each case. Nor will an existing single tall building naturally justify further tall buildings so as to form a cluster.” The only justification for the cluster of tall buildings put forward by the applicant is the fact there are tall buildings at Royal Exchange and Eden Walk, both of which were specifically permitted by the Development Plan, and Kingston University building which pre-existed the Development Plan. These are not legitimate justifications.

Failure to enhance Eden Street and deliver Eden Square

The Appeal Decision sets out the contributions to key projects and improvements which  the EQDB expects from the development of this site: (9) “The enhancement of Eden Street with shops, leisure and restaurants as an extension of the retail circuit in the town centre; creation of a new public space at Eden Square with the Eden Street frontage of the appeal site set back from the existing building line to improve the view of the OPO building”

And “The EQDB shows development on the appeal site set back along its northern frontage on Eden Street providing room for the creation of Eden Square along a widened Eden Street. It expects the square to be of generous proportions to help balance the height of the surrounding buildings and provide space for pedestrians beyond the carriageway width.”

There is no significant setback at the corners of the proposed building on Eden Street, however the front appears to offer public realm to Eden street due to its concave front. However this is not the case as its use is clearly designed to serve the proposed building. The steps and changes in pavement levels are for the purpose of gaining entry into the building, and this together with the concave form and overhang of the floors above declare this is not public realm. Rather than positively contributing to the creation of a new public space at Eden Square, the proposed building has a negative impact by in effect absorbing Eden Street into its own private realm. What remains of Eden Square would be subservient to the needs of the grand entrance to the Office building at the center of its bow fronted facade. “the absence of a set-back along the Eden Street frontage would effectively prevent the delivery of Eden Square as intended“

The proposed building would not provide a set back from the existing building line to improve the setting and views of the OPO building which would remain partly concealed when seen from the western corner of the site. This is completely at odds with the stated aims of the EQDB which is  for the Post Office building to  “stand alone. as a ‘gem’ sitting within high quality public realm.”

As stated above the set back in the centre concave front of the building  is rendered meaningless in terms of public realm by the lack of set back at the corners. If the set back was continuous AND the corners were chamfered there would be negligible impact on the office space, but would bring huge benefit to the public realm and realise a core design goal to create an Eden Square as a destination not simply a continuation of Eden Street.

Cavernous Inner courtyard enclosed by private buildings is not public realm

The applicant attempts to give the impression that they are creating a space in between the office buildings which is to be enjoyed by the public and to create permeability through the site. There are a number of reasons why what they present does not make this a reality.

  1. The entrance to the “Woodland Walk” is very narrow and provides the pedestrian with no clear perspective of any way out/through the space. Indeed the other side of the “Woodland Walk” is a service area so this should not be described as a route through the site for the general public. It is effectively two entrances to the Office building and no more.
  2. The space created between the office buildings is therefore in reality the courtyard entrance or uncovered atrium to these private buildings and the public is not truly being invited into this space and as such it is inappropriate to describe this as contributing to the public realm.
  3. It is a misnomer to describe this space as a “Woodland Walk”. There do not appear to be many trees and the space will be almost always in perpetual shadow – even in the height of summer-  because it is surrounded by towers on three sides and a multi storey car park on the other.
  4. The logical permeability route for the site is from east to west – from the Royal Exchange to the Old Town. That route is blocked by the main entrance to the Office Building. And yet there is another main entrance in the Eden Street facade, which, as stated above, also detracts from the public realm space.
  5. The developer should be asked  to open up the space between the 2 office buildings on Eden Street and Brook Street to the public. This would make it more inviting and useful and contribute to the linkages being created by the council across Wheatfield way. A more meaningful route through the site like the Bloomberg office in London would be a useful addition. The Office linkage could then be limited to upper floors.

Hogsmill River space becomes setting for the residential tower

The applicant clarifies in the documents submitted that they do not own the land around the Hogsmill although it is included in their planning application for outline planning permission. This land is already in public ownership. The improvements to the Hogsmill and its setting in this small area are to be welcomed however the incorporation of the Hogsmill area into the site would blur the southern boundary, thereby ‘claiming’ private ownership of this public space as the setting for their proposed residential tower.

In conclusion the Society objects to this Application which should be robustly refused, using all the arguments put forward above.