From: James Kirby, Twickenham Embankment
re: Sensitive Conservation Area 27 February 2002

Open letter to the Development Control Committee, Richmond Council
c.c. Twickenham Online

Dear Sirs,

Further to my letter to you dated 20 February 2002, and the release of the planning officer's report to your committee, I write again to remind us all of their conclusions. Before I do so, may I say that I know you have a wealth of material to deal with in relation to this, and I thank you for taking the time to deal with these submissions whilst serving on this vital committee.

The report points out that in a sensitive conservation area, the most important consideration is that the Design, Scale and Massing of any proposed development must "preserve or enhance the domestic scale and character of the conservation area or its riverside setting": The report points out that
(i) The Strategic Planning Guide RPG3B/9B requires that the "special character of the Thames" be protected (p.5, para 1)
(ii) Section 72 of the Planning Act 1990 imposes a duty on the Council to preserve and enhance the character of the area (para 3)
(iii) The report summarises local policy review T1 ("the most relevant proposal"… "of great significance to this application") as demanding development "in harmony with the small scale and domestic aspects of the conservation area… and to make a significant contribution to achieving the Thames Landscape strategy" (para 7)
(iv) The UDP states that the Council should NOT allow buildings "which are significantly higher than the surrounding area" (p.6, para 1)
(v) In conclusion, the report reiterates that "the main issue is… how its scale and character would affect the special qualities the Twickenham Riverside Conservation Area"(p.26)

However, despite an apparent attempt to approve of this proposal, the planning officers cannot avoid the conclusion that this new proposal is undeniably NOT "in harmony with the small scale and domestic aspects of the conservation area": They admit that

• "A significant proportion of the development, including parts coming closest to the river, is of a scale which exceeds existing development along the riverside" (p.26, para 6).
  
• It "does not relate to the domestic scale and character of the waterfront/landscape" (p.18 para 4)
• It is "significantly higher than the surrounding area" (e.g. nearly 300% higher than the new houses in Water Lane; 50% higher than the old baths, themselves "not commensurate", see below)
• The local "domestic scale could still be eroded by the quantum of the development" (para 6)

Further, it does NOT "make a significant contribution to achieving the Thames Landscape strategy":

• English Heritage conclude that it fails the most important test of "appropriateness", being too large in scale and size, and has a "curiously dated town centre redevelopment character".
• The Conservation Area Advisory Group found the proposal to be too high and bulky to "harmonise with the scale of the surrounding conservation area".
• Moreover, high curved roofs, "finished in aluminium, could create an alien form" (p.11).
• There is no provision for a landing stage, despite specific reference to such a marine element in the Unitary Development Review T1, proposal T14 (p.5). This development "could be located anywhere" (p.19, see below).

The 1991 "Marks & Spencer" proposal, which included 19 flats, also failed to "preserve or enhance the domestic scale and character of the conservation area or its riverside setting". It was rejected by the Secretary of State in 1991.

This new proposal includes more than twice as many flats (42), and even compares unfavourably with the existing pool building. That existing building stands at between 8m and 10m in height, which height "is not commensurate with the historical evolution of the centre's development" (p.17, para 5). But at least that height is mitigated by the fact that it is not a deep building, and there is therefore a "perception of space around it".

The new proposal however is for a very much deeper building, half as high again, with the roof standing at up to 15m high. Page 18 paragraph 3 concedes that the proposal "does not relate to the domestic scale and character of the waterfront/landscape". It is in fact almost 3 times the height of the adjacent houses.

The 1991 public inquiry (whose report the planning officers now consider "a seminal document") found that this site needs to be considered not in isolation but in the context of the wider river scene. In that context, the officers now concede that "heights of 15m are not a common site on the riverside" (p.18, para 4).

Given the myriad failings of this proposal to fulfil the statutory requirements of development in a conservation area, the developers have now prepared photomontages that show the proposals favourably from a distance if viewed at an angle (p.19). However, the officers concede (p.19, para 2) that the applicant has pointedly not provided an impression of the development from the opposite bank. They also admit that it seems

• "the development will have more than just a limited impact on its wider context";
• "it will be of a greater scale than the boat sheds on Eel Pie Island"; and
  maintaining the same design and material throughout merely adds to the "perception of mass and bulk";
• the scheme could be "located anywhere, rather than purpose designed for this site" (p.19).

I hope the preceding paragraphs demonstrate that architecturally this proposal significantly fails to comply with the vital requirements of T1, of section 72 of the Planning Act 1990, of the UDP, and with the conclusions of English Heritage and The Conservation Area Advisory Group. It clearly fails to preserve let alone enhance the character of the conservation area and should be rejected, especially as the "benefits" are negligible or non-existent (see below).

Other objections:

The Council has received 146 letters, and petitions from a further 27 individuals, objecting to the proposal. It has received detailed objections from 15 local organisations, residents associations, business groups, as well as English Heritage and The Conservation Area Advisory Group. Those objections must represent the views of hundreds of local people, well informed and locally involved. [Admittedly, three people have written in to support the proposals.]

I respectfully suggest that such a scale of local resistance and informed objection should not democratically be ignored.

Other considerations:

Proposal T1 expects developments to "provide the community with leisure uses" (p.5, para 7). This proposal excludes rather than includes the local community: It offers far more detriment than benefit to the local community:

• The auditorium/cinema space will NOT be available for public use, except for one-ninth of the time. (1 out of the 3 halls, for one third of the year: 14 weeks out of 52): 11% usage by the public.
• The swimming pool will NOT be available for public use during the evening or at weekends, except for 1 afternoon;
• The landscaped terraces above the retail units will NOT be open to the public (p.9)
• None of the "leisure benefits" (restaurants, cinema, private health club) relate to the river or the location at all. In fact, the latter 2 especially could be situated anywhere, and are nowadays more often to be found on reclaimed industrial land (see e.g. Feltham Cineworld);
• There is NO firm provision to provide parking for the local community. Rather, there is a net loss of 31 parking spaces for those already resident.
• There is NOT an adequate provision for low-cost housing as required by the Unitary Development Plan. The report admits that the 40% threshold of affordable housing has not been met, and "this has been raised with the applicant…(but) if affordable housing was introduced… more development would be required to pay for it" (p16, para 5). It then fudges its conclusion by stating that "the current mix meets… the general approach".
• The officers conclude that the service road is just about viable as a one-way street if it is NOT reduced in width (p.22, para 4). However, this proposal seeks to "narrow the road" in order to make the pedestrian access across that road safer (the M&S Inspector observed that it was unsafe: p.22, para 4) Those 2 requirements are incompatible.
• The applicants have undertaken a traffic assessment and concluded that restaurants, cinemas and a health club will generate a mere 1-2% growth in traffic. The planning officers "do not fully agree with the way" that assessment "has been undertaken", and state that "although the peak hour traffic is currently problematic, additional movements will add to this harm" (p.20, para 5). The officers are more realistic and admit that the "commercial elements generate upwards of 200" extra cars a night (p.21 para. 1).

I hope these cumulative points speak for themselves: Architecturally, the proposed building is far too big for the context, is "curiously dated" and "alien" in design, will have "will have more than just a limited impact" on the local environment, and could be "located anywhere, rather than purpose designed for this site". The traffic impact is not accurate nor adequately dealt with; there is little if any leisure benefit for the local population.

Once more, I thank you for taking the time to deal with these submissions, and trust that all members can feel free to vote according to their own principles.

Yours sincerely

JAMES KIRBY