Town and Country Planning Act 1990

Appeal by Starbones Ltd

Summary proof of Evidence of Philip Grover BA (Hons), BTP, DIP ARCH (CONS), MRTPI, IHBC

relating to

Design and Heritage matters

on behalf of

London Borough of

Planning application Reference: 00505/EY/P18 & 00505/EY/AD22 Appeal Reference: APP/F5540/W/17/3180962 & APP/F5540/Z/17/3173208

May 2018

1.0 Witness details

1.1 My name is Philip Russell Grover and I am a Director of Grover Lewis Associates Limited, a specialist town planning and built heritage consultancy. I have over 35 years’ experience as a built heritage professional dealing with all aspects of development in the historic environment, including issues related to integration of new development within sensitive historic contexts.

1.2 I hold an Honours Degree (BA) in Architecture from Oxford School of Architecture (now Oxford Brookes University), a Bachelor’s Degree in Town Planning from South Bank Polytechnic (now South Bank University) and a Postgraduate Diploma in Architectural Conservation from the University of Bristol. I am a member of the Royal Town Planning Institute (RTPI) and a founder member of the Institute of Historic Building Conservation (IHBC).

1.3 The evidence that I have prepared and provide for this appeal, Ref. APP/F5540/W/17/3180962 & APP/F5540/Z/17/3173208 in this proof of evidence, is true and has been prepared and is given in accordance with the guidance of my professional institution, the Royal Town Planning Institute. I confirm that the opinions expressed are my true and professional opinions.

Planning appeal: Curve © Grover Lewis Associates Ltd. Summary PoE: Philip Grover – Design & Heritage matters May 2018 1

2.0 Appeal background and scope of evidence

Appeal details

2.1 The appeal is in respect of the refusal of an application for full planning permission by the London Borough of Hounslow for the redevelopment of land adjacent to the Chiswick Roundabout, Great West Road, London W4 for a 32- storey building, plus two basement levels, comprising 327 residential units and office, retail/restaurants uses (LPA Ref: 00505/EY/P18), and refusal of an associated application for advertisement consent for three internally illuminated signage panels to the proposed building (LPA Ref: 00505/EY/AD22).

Scope and nature of evidence

2.2 My evidence is given on behalf of the London Borough of Hounslow. Grover Lewis Associates was appointed by the Council in January 2018. I have been engaged as an independent expert witness to assess the scheme and to provide specialist design and heritage evidence. I have not previously advised the Council with regard to the application for planning permission.

2.3 My evidence deals solely with those aspects of the Council’s reasons for refusal that relate to design and heritage, namely matters cited in Reasons for Refusal 1 and 2 of the planning application and Reason 1 and 2 of the application for advertisement consent. I should emphasise that my evidence does not seek to weigh any harm against the wider public benefits claimed the proposals. This aspect of the case is addressed by Mr. Baker who deals with the overall planning balance.

2.4 My evidence is informed by relevant published guidance, professional experience, and a critique of assessments made by others. I have made myself familiar with the case and carried out fieldwork and research between January and April 2018.

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3.0 Decision-making context

3.1 My evidence takes account of relevant legislation as well as both the national and local heritage policy context. It also has regard to relevant national guidance relating to design and heritage matters.

3.2 Statutory duties relating to proposals affecting listed buildings and conservation areas are contained in the Planning (Listed Buildings and Conservation Areas) Act 1990 (CDH.01).

3.3 Central Government planning policy is set out in the National Planning Policy Framework (NPPF) (CDC.01), published in March 2012. Of particular relevance to my evidence are policies relating to the need for good design and policies relating to the conservation and enhancement of the historic environment. These matters are dealt with in section 7 and section 12 of the NPPF respectively, and I summarise the key policies in my main proof of evidence. Interpretation of the policies in the NPPF is provided by the on-line National Planning Practice Guidance (NPPG) (CDC.02) (March 2014). I summarise the relevant content of the NPPG in my main proof of evidence.

3.4 The development plan policy context that is relevant to this appeal comprises both the strategic policies set out the London Plan (2016) (CDC.04) and the local development plan policies set out in the London Borough of Hounslow Local Plan (September 2015) (CDD.01). I summarise the development plan policies that are particularly relevant to the design and heritage aspects appeal proposals in my main proof of evidence.

3.5 In my main proof of evidence, I summarise other relevant guidance, namely Historic England publications: Managing Significance in Decision-Taking in the Historic Environment (GPA2) (March 2015) (CDF.12 The Setting of Heritage Assets (December 2017) (GPA3) (CDF.13) and Tall Buildings (GPA 4) (CDF.14).

3.6 I have had regard to the above statutory duties, planning policies, and guidance, in my assessment of the impact and effects of the appeal proposal on the surrounding areas including designated heritage assets. In reaching my conclusions I have also had regard to relevant case law relating to impacts on heritage assets, namely Barnwell Manor (CDH.05), Bedford (CDH.04) and Irving (CDH.06).

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4.0 The appeal site and proposals

The appeal site

4.1 I describe the appeal site and its wider context in my main proof of evidence. I summarise the main aspects below.

4.2 The appeal site is located to the north-west of the Chiswick Roundabout, which forms the busy traffic intersection at the junction of the A4 Great West Road, the A406 ( Road), the A205 South Circular Road, the A315 Chiswick High Road, with elevated passing overhead. The site and its immediate surroundings are dominated by traffic routes that converge at this point, and in particular by the elevated section of the M4. Currently, the site has advertising hoardings around its perimeter, including three large advertisements on each of its three corners.

The appeal building

4.3 The appeal proposals comprise a building formed of three connected volumes of curved plan form; an east tower rising to a maximum of 32 storeys (120.29m AOD), a west tower rising to 98.57m AOD) and a 17-storey linking element. From its narrow base the building flares out gradually over the first five storeys, then rises up vertically from that point. The first six floors of the proposed 32- storey building would be used for offices, retail and/or café space and amenity space. A public atrium is proposed on the ground floor. The floors above would contain 327 residential units. Two basement levels would provide motorcycle and cycle parking, space for refuse, plant, substations and switch rooms.

4.4 The external envelope of the building predominantly comprises clear glass curtain walling and will have a reflective appearance. The elevations are proposed to be articulated by horizontal and vertical fins of anodised aluminium, ‘wedged balconies’ and coloured panels.

Advertisements

4.5 The appeal proposals, as amended, incorporate illuminated LED digital advertisements at three locations on the lower parts of the façade to maximise viewing exposure on the principal roads that converge at the Chiswick Roundabout.

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5.0 Heritage assets and impacts

Background

5.1 The appeal site does not fall within a conservation area and there are no statutorily or locally designated heritage assets within the site. Likewise, the immediate context of the appeal site in the vicinity of the Chiswick Roundabout is not sensitive from a heritage standpoint. However, given the very large bulk and height of the appeal proposal, there are a great many heritage assets beyond the immediate vicinity of the site that could potentially be impacted upon by the appeal proposal.

5.2 A number of important area-based heritage assets, each containing individually designated and non-designated heritage assets, are located in relatively close proximity to the site and would be impacted upon by the appeal proposal. Most notably these include the Royal Botanical Gardens, Kew, which is inscribed as a World Heritage Site as well as being designated as a grade I Registered Park and Garden and a conservation area. Part the World Heritage Site also lies within the Kew Green Conservation Area. Also notable is the grade II* Registered Park and Garden at (which is located within the Gunnersbury Park Conservation Area). In addition to the designated historic landscapes referred to above, a number of conservation areas would be impacted upon by the appeal proposals

5.3 In my main proof of evidence, I set out the significance of each of the area- based heritage assets (including where appropriate the individual designated assets within them). I highlight the contribution that setting makes to their significance. I then discuss the impacts that the appeal proposals would have on the setting and significance of heritage assets most affected by the appeal proposal. I summarise the impacts below.

Summary of heritage impacts

Royal Botanical Gardens, Kew

5.4 Contrary to the Appellant’s claims, I consider that the appeal proposal would form a harmful and intrusive feature from a number of positions within the Royal Botanical Gardens and in some cases would be visible in juxtaposition with listed buildings located within the designated area. I consider that the appeal proposals would cause a high level of harm to the World Heritage Site, the grade I Registered Park and Garden and the conservation area at the Royal Botanical Gardens. In respect of the former it would harm the Outstanding Universal Value identified by UNESCO. I consider the level of harm to be less

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than substantial in the terms of the NPPF, but at the higher level of the scale of less than substantial harm.

Gunnersbury Park Conservation Area and RPG

5.5 The appeal proposal would intrude harmfully into a large number of views in a southerly direction from both the RPG and the wider conservation area, which includes a number of listed buildings, the Gunnersbury/Kensington Cemetery and residential development around the margins of Gunnersbury Park. I consider that the level of harm caused to the significance of the Gunnersbury Park Conservation Area and grade II* Registered Park and Garden would be very serious. I would place the level of harm at the highest level of less than substantial harm in the terms of the NPPF.

Kew Green Conservation Area

5.6 The appeal proposal would have a particularly adverse visual impact on views in the northern direction from a multitude of viewpoints within the large open grassed areas of the Kew Green Conservation Area, to either side of the South Circular Road. The proposed tower would loom above the highly consistent scale of the low-rise buildings that define and enclose the northern side of the open areas. The tower would appear as a highly intrusive, incongruous and alien feature that would be visible in almost all northward views from the open grassed areas. The appeal proposal would also cause very serious harm to the highly sensitive riverside environment of Kew Green Conservation Area. For these reasons I consider that the damage caused by the appeal proposal would be so serious that it would result in substantial harm to the significance of the Kew Green Conservation Area in the terms of the NPPF.

Strand on the Green Conservation Area

5.7 The appeal proposal would appear as a large, bulky and incongruous addition to an otherwise largely unbroken skyline of traditional buildings at Strand on the Green Conservation Area. The assertiveness of the appeal building would be in stark contrast to the understated small-scale traditional architecture of the waterfront. It would be an incongruous addition to the skyline that would cause serious damage to a key element contributing to the significance of the Strand on the Green Conservation Area, as well as harming the setting of the listed buildings (including the grade II* Zofany House) that form a cohesive and modestly-scaled frontage to the riverside, both individually and collectively. The tower would become a new and unwelcome focus to a cherished skyline It would also appear large and incongruous in high-level public views experienced by rail travellers crossing the Thames on the grade II listed Kew Railway Bridge at the eastern side of the conservation area. The appeal

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building would also appear as a large and incongruous intrusion to boaters using of the river itself. Additionally, the appeal proposal would be visible as a large and incongruous intrusion from positions within some of the streets of Strand on the Green Conservation Area and would sit unhappily with the small domestic scale of the traditional townscape. For these reasons I consider that the damage caused by the appeal proposal would be so serious that it would result in substantial harm to the significance of the Strand on the Green Conservation Area in the terms of the NPPF.

Wellesley Road Conservation Area

5.8 The appeal proposal would be highly visible as a large and dominant intrusion into the setting of the Wellesley Road Conservation Area, appearing as an incongruous element that is out of scale with the predominantly domestic scale of this high-quality, well-preserved suburban area. In my view the appeal proposals would be at odds with the low-rise suburban character of the conservation area. I consider that the level of harm caused to the setting and significance of the Wellesley Road Conservation Area would be serious, but in the terms of the NPPF less than substantial.

Thorney Hedge Conservation Area

5.9 The appeal proposal would be clearly visible as a large and incongruous feature in views from the Chiswick High Road section of the conservation area, close to . It would also be visible above the rooflines of housing at the hairpin junction of Thorney Hedge Road and Silver Crescent where it would have an overbearing impact. For these reasons I consider that the level of harm caused to the significance of the Thorney Hedge Conservation Area would be serious, but in the terms of the NPPF less than substantial.

Kew Bridge Conservation Area

5.10 The appeal proposal would appear as a large and incongruous element in views from the grade II listed Kew Bridge. The appeal proposal would be very prominent in views from the junction of Kew Bridge and Kew Road. I am of the view that, in approaches to the pumping station further along Kew Bridge Road to the west, and in views from the much-used ‘Heritage Walk’ pedestrian footway that runs parallel to Kew Bridge Road to the north, the impact of the appeal proposal on the listed building and conservation areas would be considerably more marked and harmful to the setting of the listed pumping station complex and the conservation area. For these reasons I consider that the level of harm caused to the significance of the Kew Bridge Conservation Area would be serious, but in the terms of the NPPF less than substantial.

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Grove Park Conservation Area

5.11 The appeal proposal would intrude incongruously into important views over the conservation area from the grade II listed Chiswick Bridge, half of which falls within the conservation area. In these views the appeal proposal would appear as a dominant, alien feature, towering above the modest scale of the riverside of Grove Park Conservation Area. For this reason, I consider that harm will be caused to the significance of the Grove Park Conservation Area. In the terms of the NPPF this harm would be less than substantial.

Chiswick House Conservation Area

5.12 The appeal building would be visible in views looking north-west along . It would also be visible from a number of other locations above the rooflines within the residential streets in the conservation area, including, for example, in views looking north-west along Sutton Court Road, close to Chiswick Railway Station. In these views the appeal proposal would intrude into a townscape that is otherwise largely unaffected by inappropriately scaled development in its wider setting. As such it would, where visible, be at odds with the low-rise suburban character of the conservation area. For these reasons I consider that harm would be caused to the significance of the Conservation Area. In the terms of the NPPF the harm would be less than substantial.

5.13 In summary, I am of the view that, by virtue of its location, scale and design, the appeal proposal would cause harm to a range of designated heritage assets including the Royal Botanic Gardens Kew World Heritage Site, the grade II* listed registered Gunnersbury, a number of conservation areas and individual listed buildings within them through harm to their settings. I do not consider the appeal proposal to be of outstanding design that would make a beneficial addition to heritage assets in the surrounding area, nor that it would justify the degree of harm caused. I am of the view that the appeal proposal would conflict with the development plan policies outlined in my main proof of evidence and with the objectives of the NPPF.

Heritage impact of the proposed advertisements

5.14 I am of the view that the proposed advertisement panels would, by virtue of size, location and illumination, cause harm to the setting of heritage assets in the vicinity of the appeal proposal. Whilst I would rate this harm to be less than substantial in the terms of the NPPF, it should be weighed in the planning balance. In my view the proposed advertisements would conflict with local planning policies outlined in my main proof of evidence.

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6.0 Design issues

Scale and form

6.1 In my opinion, the proposed development would be of dominant scale and form, and would appear as an overpowering mass, protruding into the skyline, unrelated to any other existing or planned building. The two related concepts of scale and form are taken together as the excessive height and bulk of the proposed design clearly derives from the attempt to fit such a large amount of accommodation onto the relatively small appeal site.

Inelegance

6.2 In my opinion, the form of the proposed development would be inelegant. The inelegance of the design relates to its proposed bulk and mass. In particular, the inelegance derives from the way the proposed mass widens over the lower storeys, and then rises as one before dividing into two towers, creating a clumsy, bottom-heavy form with a narrow base. As the conjoined base-bulk constitutes over half the height of the building, the two towers appear as stubby protrusions rising from an enormous solid rather than elegant/slender forms. In many views, the two protruding towers would merge into one, forming a single, ungainly bulk.

Relationship to the immediate surroundings

6.3 The Appeal Site is a relatively small plot to accommodate such an enormous building. It is located within a gyratory traffic system. It is currently difficult, unpleasant and dangerous passing through this area on foot or as a cyclist. The proposed development retains narrow footways around the perimeter of the site, albeit reconfigured. Whilst a central thoroughfare is proposed, it is highly likely that this would become a private controlled space as it does not contain sufficient commercial space to draw pedestrians to this hostile area.

6.4 Residential users of the dwellings above are likely to primarily access the building directly from the surrounding streets, so may not use the atrium, which would further reduce the likelihood of vibrant use of the proposed internal public space. As a result, I am of the view that it is highly likely that the atrium would be little used. In order to safeguard against anti-social behavior access to the atrium would inevitably have to be controlled and it would almost certainly become a private space. In my view, access alongside the North Circular Road would be only marginally less unpleasant than the existing arrangement.

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Access for pedestrians along the north-western side of the building abutting Larch Drive would become even more inconvenient, unpleasant and dangerous than the existing arrangements, due to the presence of the proposed car-park entrance and a service/loading bay, which extends along approximately half of the Larch Drive frontage.

6.5 The Appellant’s claim that the proposed development is designed to maximise active street frontages cannot, in my view, be justified. The majority of the exterior of the building at ground floor level is taken up with such elements as the refuse holding area, the car-park entrance, the car-park smoke vent shaft, the bike lobby, residential lobbies, and the HV intake area, all of which constitute dead-frontage. In my opinion the only elements that have any potential to be correctly described as active frontage are the two small A1/A3 units and these are not designed with shop fronts addressing the exterior.

6.6 The proposed landscaping proposals within the application site, external to the building, are limited to modest planting proposals around the narrow margins. Whilst planting along these margins would be welcome, it may be difficult to establish planting as proposed in such hostile environmental conditions. Even if such planting could be established, it would do little more than minor softening of the edges of the enormous bulk of the proposed building.

6.7 The landscaping proposals put forward are very modest, amounting to little more than minor enhancement of the underpass area below the M4 and improvements to two pedestrian road crossings. The more substantial landscaping enhancements illustrated in the DAS, such as planting on the Chiswick Roundabout, semi mature tree planting on the central reservation of the North Circular Road, and highway enhancements to Larch Drive, are described as aspirational public realm works that could be delivered by utilising community infrastructure levy contributions from developments. Consequently, the sketch illustration on page 162 of the DAS is somewhat misleading and the claim that “a major offering of the proposals is to enhance the public realm” is not supported by the facts.

Relationship to the wider surroundings

6.8 The part of west London that would be affected by the proposed tower is primarily low-rise in character. There are some tall buildings in the vicinity of the proposal, which are for the most part clustered in a zone to the west of the appeal site. None are of the scale of the proposed building. Nor are any other consented schemes in the area. In my opinion, the proposed building, by virtue of its enormous scale and bulk, would be inherently incongruous in this predominantly low-rise part of west London. The proposal would be

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significantly taller than any other building in that wider context and would stand distinct and visually isolated from other larger buildings in the skyline. In short, it is quite simply in the wrong location. As a result, it would constitute an alien and incongruous intrusion as perceived from its wider surroundings.

Materials

6.9 The proposed materials would be reflective, in contrast to almost all other buildings in the surrounding area, which will make the building stand out from, rather than harmonise with, its surroundings.

6.10 I do not criticise the architect’s attempt to add interest to the exterior of the building by the introduction of a fine-grained pattern of multi-coloured cladding panels and fins. However, I consider that the subtleties of this architectural approach will only be appreciated at a relatively close range, and not be discerned from the range where the appeal building impacts on the most sensitive heritage assets. The reflective nature of the proposed cladding materials will inevitably make the building contrast with and stand out from other buildings in the area. In combination with the height and bulk of the structure, this reflective characteristic would reinforce the prominence of the proposed building in views from the surrounding area.

Detracting nature of the proposed advertisements

6.11 In my opinion, the presence of large-scale, illuminated advertisements on the lower parts of the proposed tower, significantly degrade any claimed aesthetic qualities that the proposed building might have. Such advertisements inherently commercialise and debase the appearance and aesthetic intentions of the design.

Summary

6.12 In my view the appeal building, by virtue of its location, scale, mass and design would not constitute the very highest, outstanding quality of design required for a tall building in this location and would cause harm to the character of the wider area around the site and the skyline. As such it would conflict with both development plan policies and the relevant objectives of the NPPF outlined in my main proof of evidence. Similarly, I consider that the proposed advertisement panels would have a seriously detrimental impact on the environmental amenity and townscape character of the immediately surrounding area to the north and west of the proposed development.

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7.0 Conclusions

7.1 In arriving at my conclusions, I have taken account of the relevant decision- making context in which the appeal must be determined, including the national and local design and heritage policy. It has also taken into account the scale, massing and disposition of the appeal proposal within its surrounding physical context, including the significance of heritage assets, and the particular contribution that setting makes to significance. This has informed conclusions with regard to the impact that the appeal proposals would have on the character.

7.2 I consider that that the appeal proposal would cause harm to the setting and significance of a number of heritage assets in the vicinity of the appeal site. In relation to the Strand on the Green Conservation Area and the Kew Green Conservation Area I consider that the level of harm caused would be substantial in the terms of the NPPF. This is due to the fact that, in both cases, very serious harm would be caused to a key element of significance of the conservation area. In the case of the other heritage assets I have cited in the proof of evidence I consider the harm to be less than substantial, but nevertheless in a number of instances serious, such that it should be taken into account in weighing the planning balance. In the case of Gunnersbury Conservation Area and Registered Park, and the Royal Botanical Gardens, Kew World Heritage Site, I consider that the level harm would be towards the upper end of the scale of less than substantial harm.

7.3 I do not agree with the Appellant’s assertions in the THVIA that, due to the high design quality of the appeal proposal, there would be beneficial effects, and that in consequence no harm would be caused and so, by extension, it is unnecessary to weigh harm against the public benefits of the proposal as required by paragraphs 133 and 134 of the NPPF.

7.4 The appeal building would be considerably taller than any other existing or consented building in the Borough of Hounslow, and if allowed would be totally out of scale with the generally low-rise nature of its surroundings. The proposed tower would also be of bulky and inelegant form. In my opinion the building does not relate well to its surroundings. It would therefore cause harm the character of the wider area around the site and the skyline. Likewise, I consider that the proposed advertisement panels would have a seriously detrimental impact on the setting of designated heritage assets and the environmental amenity and townscape character of the immediately surrounding area.

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7.5 For all of these reasons I consider the appeal proposal to be in conflict with relevant design and heritage policies in the London Plan and the Hounslow Local Plan and the design and heritage policy objectives of the NPPF.

7.6 Clearly, in making a decision on the planning balance, the Inspector must, in accordance with the provisions of s66, give considerable importance and weight to the desirability of preserving listed buildings and their settings, as well as having regard to the relevant policies in the NPPF. I am of the view that the appeal proposals will fail to preserve the setting of the listed buildings I have cited in this proof of evidence.

7.7 I am of the view that if the important designated heritage assets that I have highlighted in this proof of evidence are to have meaning, and the policies that are intended to protect them are to have their intended effect, then it is precisely developments such as the appeal proposal that the planning system is intended to prevent.

7.8 In conclusion, I note that, in assessing the overall planning balance, Mr. Baker’s evidence demonstrates that the harmful effect resulting from the appeal proposals would not be outweighed by the public benefits that the appellant claims for the proposals.

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