IN A VERY COMPREHENSIVE DOCUMENT POSTED ON WESTMINSTER'S PLANNING PORTAL, TACHBROOK WARD COUNCILLORS JIM GLEN AND JAMES SPENCER HAVE SET OUT THE VERY STRONG OBJECTIONS OF THE LOCAL PIMLICO COMMUNITY TO WESTBROOK'S PLANS.
PLEASE REGISTER YOUR OWN OBJECTIONS ON THE PLANNING PORTAL. THE ADDRESS IS:-
https://tinyurl.com/savedolphinsquare
The application reference is:- 18/01099/FULL
THE COUNCILLORS' DOCUMENT STATES ALL THE RELEVANT PLANNING GROUNDS FOR THIS SCHEME TO BE REFUSED AND READS AS FOLLOWS:-
Dolphin Square – Ward Councillors’ Comments
As the local ward councillors, we have been listening to residents, taking on board their views about the wholescale redevelopment of Dolphin Square since the outset of this process. The applicant is to be commended for their excellent public consultations, carried out over a very long period. Our representation here, whilst also reflecting our own opinions, is illustrative of the views of our constituents.
We would like noted the considerable and almost total opposition to these proposals by residents, both those living in and around Dolphin Square.
We would like the following taken into consideration:
1. Demolition in a Conservation Area: The most obvious contention lies in the fact that the proposals involve demolishing the north side of Dolphin Square - Rodney House. The new building in this conservation area will have two new basement levels and be four stories higher than it currently stands. Dolphin Square is within its own conservation area, nestling between the listed properties in St George’s Square (in the Pimlico conservation area) and the listed Churchill Gardens Estate (in the Churchill Gardens Conservation area) and extending over the Grosvenor road to the river. According to policy, demolition within a conservation area should only be allowed if there is sufficient public benefit to the proposals. As we shall explain in the following points, we do not believe this is the case here.
The latest Westminster Area Conservation Audit (2008) lists Dolphin Square as "an unlisted building of merit" and saved Policy DES(9) B seeks to avoid the demolition of such buildings which contribute positively to the character and appearance of the conservation area.
From the ‘saved policies’ of the UDP: DES(9) (B) Planning applications involving demolition in conservation areas 1) Buildings identified as of local architectural, historical or topographical interest in adopted conservation area audits will enjoy a general presumption against demolition 2) Development proposals within conservation areas, involving the demolition of unlisted buildings, may be permitted a) If the building makes either a negative or insignificant contribution to the character or appearance of the area, and/or b) If the design quality of the proposed development is considered to result in an enhancement of the conservation area’s overall character or appearance, having regard to issues of economic viability, including the viability of retaining and repairing the existing building.
Dolphin Square is in-between the Churchill Gardens conservation area and the Pimlico conservation area. From DES(9) (F) Setting of conservation areas. Development will not be permitted which, although not wholly or partly located within a designated conservation area, might nevertheless have a visibly adverse effect upon the area’s recognised special character or appearance, including intrusiveness with respect to any recognised and recorded familiar local views into, out of, within or across the area.
2. Increased Hotel Use: Rodney House is currently used as ‘serviced apartments’, established as suitable for residential use under a Certificate of Lawfulness for Proposed Use or Development by the applicant in 1995(05/07439/CLOPUD). Their established use is stated in the application as C3 ‘temporary sleeping accommodation’. It is a nonsense to consider the activity in Rodney House as anything but a hotel. Indeed ‘Dolphin House Serviced Apartments’ at the time of writing ranks #382 out of 1089 Hotels in London according to Tripadvisor, just beating the Holiday Inn Express in Park Royal at #383. The list includes the Lanesborough, the Goring, the Savoy, the Ritz, various Travel lodges and Premier Inns etc – including all other hotels in Pimlico. Rooms are available for one night upwards and bookable online through all major hotel accommodation providers (including Tripadvisor, booking.com etc). If it looks like a duck, swims like a duck, and quacks like a duck, then it probably is a duck. Residential amenity is already compromised by the existing hotel use due to frequent comings and goings, the strain on weekend parking and large numbers of short-term visitors to this residential area.
This is not the residential accommodation for people who live and work in London which we so desperately need in Westminster and wider London. Please note these proposals make Rodney House more like a hotel than it already is, as rooms will be smaller and there will be more of them. (All will be studio flats, not the current mix of sizes: 29 studio flats, 79 one beds, 27 two beds and 8 three beds flats – for example, compare the existing and proposed 5th floor of Rodney house.) Rodney house was not built as a hotel, but as affordable accommodation for those that live and work in London. The increased hotel activity in this area of London is against the current City Plan Policy S23, Policy S10 and Policy S14.
POLICY S23 HOTELS AND CONFERENCE FACILITIES (p109) New hotels will be directed to the Paddington, Victoria and Tottenham Court Road Opportunity Areas, the Core Central Activities Zone, Named Streets, the Knightsbridge Strategic Cultural Area and the North Westminster Economic Development Area. Hotels are directed to those streets which do not have a predominantly residential character. New conference facilities will be directed to the Paddington, Victoria and Tottenham Court Road Opportunity Areas, and the Core Central Activities Zone. Existing hotels will be protected where they do not have significant adverse effects on residential amenity. Within Pimlico, Bayswater and Queensway the change of use of hotels to residential will be encouraged where the existing hotel is not purpose built and causing adverse effects on residential amenity. Proposals to improve the quality and range of hotels and will be encouraged.
Hotels are often not compatible with residential neighbourhoods because the amount of activity they generate can cause amenity problems. This approach also seeks to address the existing over‐concentration of hotels in Pimlico, Bayswater and Queensway.
Policy S14 Optimising Housing Delivery (p87 in the current City Plan) states Residential use is the priority across Westminster except where specifically stated.
Policy S10 Pimlico (p71) states ‘This area will be primarily for residential use with supporting retail, social and community and local arts and cultural provision. Retail and other appropriate town centre uses will be directed to the Warwick Way/Tachbrook Street CAZ Frontages and the Local Shopping Centres.’ In addition to the increased hotel use, the new shopping parade planned for Chichester Street is not compliant with this policy, the current Art-Deco parade has no street frontage and serves the residents of Dolphin Square.
3. Reduction in Family Sized Units Current and future policy as stated in the City Plan seeks to preserve a mix of different sized units for residential accommodation in Westminster, so families are not forced to move out as they expand. These plans for Dolphin Square propose 284 more studio flats, 21 fewer 1-bedroom flats and 33 fewer 2-bedroom or larger flats - including all the serviced apartments, the affordable offer and the new townhouses on the western carriageway. This is not the mix of housing needed to keep families in Westminster. This is contrary to Policies S15 and H5.
Saved UDP POLICY H5: PROVIDING A RANGE OF HOUSING SIZES (A) The City Council will ensure that an appropriate mix of unit sizes is achieved in all housing developments (B) The City Council will normally require 33% of housing units in housing developments to be family-sized and will require 5% of this family housing to have five or more habitable rooms
POLICY S15: MEETING HOUSING NEEDS (p90) ‘Residential developments will provide an appropriate mix of units in terms of size, type, and affordable housing provision to contribute towards meeting Westminster’s housing needs, and creating mixed communities’
4. Height, light and sense of enclosure: The majority of Dolphin Square is currently ground +9 stories. The proposed redevelopment would add a storey to make it ground +10, i.e. 11 stories high. Pimlico is an almost entirely low-rise area. Most of the housing is Victorian terraces built by Thomas Cubitt from 1850 on, predominantly ground +3 or +4 stories. The maximum height of these terraces is in the principal streets and squares which are ground +5 stories, occasionally with an extra mansard in the roof. Churchill Gardens to the West, Grade 2 listed and built in the 1950s, is mainly ground +7 stories rising to a maximum of ground +8 stories. There is simply nothing higher around already in its immediate vicinity. The proposals would just increase the dominance of this building within the three conservation areas which are the setting for many listed buildings within sight of the application site. Rodney House was built (and still is) lower, at ground +6 stories, built like that at the same time as the rest of the square specifically because the houses directly to the north would be over-shadowed and dominated by such a tall building so close to the south of them. Those houses were replaced after the war by a large secondary and (more recently) a primary school and the associated playgrounds, which are at basement level. The new building would tower over the playground by 12 stories over the whole width of the school site. This school deserves the same consideration that the original builders gave to the residential houses on Chichester St in 1937. The proposed increase in height of the internal projection of Rodney House from a single storey over the current gym and swimming pool to a 10-storey block will cause a great loss of light and sense of enclosure to many of the windows in the lower floors of Keyes and Duncan Houses facing into the square.
Furthermore, we wish to bring to colleagues’ attention the most recent conservation area audit (2008) which has weight under the current saved policies of the Unitary Development Plan: From paragraph 4.27 “Due to the detailed design, size and height of the Dolphin Square complex, which is already considerably larger than surrounding buildings, the development represents the type of building where roof extensions would be difficult to accommodate. It is therefore unlikely it would be suitable for upward roof extension.”
From the Saved UDP policies: POLICY DES 3: HIGH BUILDINGS (A) High buildings (defined as being that which is significantly higher than its surroundings) will not be permitted where the development : 1) would intrude upon strategic views (as defined by Policy DES 14) or upon the setting of the Palace of Westminster or upon the Westminster Abbey World Heritage Site 2) would have an adverse impact upon the character and appearance of designated conservation areas (DES 9) or upon listed buildings and their settings (DES 10) or upon the views (DES 15) obtained from the following areas: (a) the London Squares (b) the Royal Parks (c) the Grand Union Canal (d) Regent’s Canal (e) the Thames Special Policy Area 3) would be incongruous with respect to the prevailing character of the area within which it would be located.
POLICY S26 VIEWS (p116) The strategic views will be protected from inappropriate development, including any breaches of the viewing corridors. Similarly, local views, including those of metropolitan significance, will be protected from intrusive or insensitive development. Where important views are adversely affected by large scale development in other boroughs, the council will raise formal objections. Westminster is not generally appropriate for tall buildings.
5. Density: In simple terms Dolphin Square already has far more density than any of its surrounding neighbours. A 2018 report by the LSE for the GLA about high density living in London (‘Residents’ Experience of high-density housing in London’ LSE London/ LSE Cities report for the GLA dated June 2018 by Scanlon, White and Blanc) quotes both Lillington Gardens and the Tachbrook Estate (both in Tachbrook ward) as being examples of high density living in central London. It quotes Lillington as having 777 residential units in 4 hectares and the Tachbrook estate as having 427 units in 1.9 hectares and is complimentary about both for their high-density design. Churchill gardens, the nearest neighbour to Dolphin Square, has approximately 1500 homes on 15 hectares.
Dolphin Square currently has 1250 residential units. The proposals would increase this to 1455 units in just 3.7 hectares
In policy terms the DP9, acting on behalf of the applicant, did the density calculations and got 972 habitable rooms per hectare (hr/ha) currently, rising to 990 (hr/ha) after the proposals, which is surprisingly only a 2% uplift, despite the 20% increase in the number of residential units. The ‘saved’ policies of the Unitary Development Plan, in policy H11, sets the density limits for zone 2 (this area) as 250 – 500 Hr/ha. The more recent London Plan (from the GLA) sets a range of density in policy 3.4 ‘Optimising Housing Potential’ in a density matrix for an ‘urban area’ with the best possible transport links – which residential Pimlico clearly is, of 200 – 700 hr/ha. The current scheme would never have been permitted in this location after the post world war one development boom when it was built. To propose increasing the density here, in one of the most densely built urban schemes in Westminster, in one of the most densely built areas of the London is worrying. There is a strain on the public realm and infrastructure around, with many complaining about parking and over-use of St George’s Square. This is exacerbated by the use of a large portion of Dolphin Square as short term lets, with all the problems that come with a high turnover of transient population. Even Thames Water have questioned whether the current sewage and mains water infrastructure will be sufficient to cope with an even higher density of people. More housing is needed in central London – but there are better places to build it, even in Westminster.
6. Affordable Housing: We welcome the proposal to provide 57 ‘affordable’ units, however we are disappointed that only 23 of these units are social housing over and that the remaining ‘intermediate’ units are all one-bedroom flats, this is not the affordable housing our residents need.
We are also disappointed that these 57 units are based purely as a percentage of the new build. The committee should be aware that if they grant permission the owners will be sitting on 1400 market-rate properties. As the development involves remodelling large parts of the building and transformation of the existing floorplan, we would argue that significantly more affordable housing should be required from the developer.
Saved Policy H4 of the UDP states that when more than 80 additional residential units are proposed in a scheme 50% of the new units should be affordable, 205 new units are proposed here.
POLICY S15 MEETING HOUSING NEEDS (p90) ‘Residential developments will provide an appropriate mix of units in terms of size, type, and affordable housing provision to contribute towards meeting Westminster’s housing needs, and creating mixed communities’
POLICY S16 AFFORDABLE HOUSING (p91) Affordable housing and floorspace that is used or was last used as affordable housing will be protected. This should apply to all the ‘Option B’ flats including those recently vacated.
7. Destruction of a Listed Garden: The gardens of Dolphin Square have been recently recognised as being an exceptional survivor of a currently unfashionable era of design and were listed as grade II in 2018 by Historic England. They were designed shortly after 1937 by Richard Sudell, a president of the Institute of Landscape architects.
His design is registered at Grade II, for the following principal reasons (from Historic England):
· Design interest: as a high-quality landscaping scheme providing a series of garden environments, where small-scale intimate spaces contrast with open lawns, with an emphasis on geometry and balance, carefully integrated with the surrounding building;
· Rarity: one of few surviving substantial interwar landscaping schemes to a private housing estate;
· Historic interest: one of a limited number of schemes known to survive by Richard Sudell, an important and influential figure in the development of mid-C20 landscape design, and a pioneering theorist, writer, and advocate of the profession;
· Representative of Sudell’s design philosophy, and illustrative of the principles set out in his significant 1933 book, Landscape Gardening;
· Illustrating the fashion of the period for themed gardens, incorporating designs inspired by several nations’ landscaping traditions;
· Degree of survival: the overall structural layout survives very well, notwithstanding the reconfiguration of the former Spanish/Mexican garden and one of the western recessed gardens.
We draw the committees’ attention to these points made by Historic England. ‘Degree of survival’, ‘Rarity’, ‘Historic Interest’: The garden is only original once. The currently proposed scheme would tear up Sudell’s rare and protected original design entirely and replace it with a twenty first century garden. However faithful this new design is to ‘Sudell’s vision’, it will no longer be his original work. This would be a terrible loss, not only for Pimlico but also for Westminster and garden design more widely.
POLICY S25 HERITAGE (p114) Recognising Westminster’s wider historic environment, its extensive heritage assets will be conserved, including its listed buildings, conservation areas, Westminster’s World Heritage Site, its historic parks including five Royal Parks, squares, gardens and other open spaces, their settings, and its archaeological heritage. Historic and other important buildings should be upgraded sensitively, to improve their environmental performance and make them easily accessible.
Protection for existing Residents including ‘option B’ tenants
However, were the committee to grant this application, we would ask that the many promises to the residents of Dolphin Square be secured by a strong section 106 agreement, especially the promises made to the long-term elderly ‘option B’ tenants. This is necessary to guard against the possibility of the applicant, as would be their legal right, securing the planning permission and then selling their interest to a less reputable developer.
Conclusion
Dolphin Square is one of the most well-known addresses in Westminster and indeed Britain. The residents have included some of the most famous, and infamous, characters of the 20th and 21st Centuries, from Princess Anne to Christine Keeler via Charles De Gaulle. Even though the Square is not listed, Dolphin Square is a very important and historically significant building, recognised by its status as a one-building conservation area.
It is quite possible that, each taken on its own, none of these considerations would be sufficient to recommend refusal, however when taken together we contend that a different picture emerges.
We ask the committee: What is the point of conservation areas, accepted Council policy, London wide policy and even the listing process if not to protect exceptional buildings and gardens from unwarranted and unwanted over-development by their current owners?
We would like to register our desire to speak at the planning committee.
Cllr Jim Glen
Member for Tachbrook Ward
Cllr James Spencer
Member for Tachbrook Ward
1 March 2019