Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence


Memorandum by the Chelsea Society (CAB 08)

SUMMARY

(i)   The Chelsea Society

  The Chelsea Society is the leading amenity society in Chelsea a place which, because of its distinctive, attractive squares and the quality of many of its buildings, is largely covered by Conservation Areas. It is, in all but name, a World Conservation Site.

  The Society has on four occasions recently had direct experience of how CABE works and this experience, plus CABE publications, have been drawn upon in writing this memorandum.

(ii)   Design Review

  Respondents to the inquiry are asked for their views CABE's priorities for investment and development. This is not something on which the Chelsea Society feels qualified to comment. Suffice it to say that, with Britain still being blighted by inappropriate and often downright ugly developments, the Chelsea Society supports to continuation of CABE as a body charged by the government to promote excellence in architecture, civic design and master planning. The main focus of this memorandum is, therefore, on design review, a function of which the Society has experience and which it believes can and should be refined.

(iii)   Reviewing design not promoting development

  The work of CABE's design review panel has hitherto had two aspects: first, assessing the quality of architecture and civic design in a selection of schemes; and, second, the championing, following review, of what are regarded as good developments. In the Society's view the Commission's design review committee should confine its work to assessing schemes with a view to raising their quality.

  For CABE to champion commercial developments, however well designed, is not in the public interest. It is not for CABE to use design review to influence the decisions of local planning authorities but to raise the quality of what goes before planning committees.

(iv)   Tall buildings

  The ODPM (and its predecessors), CABE and English Heritage have, for several years, been seeking to resolve the problems raised by tall buildings. "Guidance on Tall Buildings" 2001, for instance, says: "Government policy is to get the right developments in the right places. It states that tall buildings should be of the highest architectural quality and designed in full cognisance of their likely impact on their immediate surroundings and the wider environment." The Chelsea Society applauds this guidance but suspects that the Design Review Panel has failed to digest its meaning.

  It is a fallacy to think that, if a tall building is well designed, it must be a good neighbour. To live in the shadow of tall buildings, to be overlooked by people living or working in tall buildings, to suffer the unavoidable wind blasts at the foot of tall buildings are all nuisances created by tall buildings good or bad. In its assessment of proposed towers in Chelsea and at South Kensington Station, it can only be concluded that CABE was not abiding by its own guidance.

  The Chelsea Society believes that CABE needs, in particular, to address the special problems created by building high close to streets of terrace houses or in the midst of conservation areas. The Society is not aware of a single instance of a tall office or residential tower that adds delight to streets of 19 century three or four storey houses. When CABE reviews a proposed tall building in a historic district or near a conservation area, its first questions should be: What would be the effect of this building on its context? And is this tower necessary or is it either pure commerce or a reflection of the egotism of its designer?"

  There is no evidence that this is what CABE does. At Lots Road Power Station, where every residents' association is against towers altogether, CABE suggested that two tall towers be replaced by one. At South Kensington Station CABE gave its support to "a civic marker" (a "gasometer" office tower) in the midst of one of the most famous residential districts in the world, one distinguished for its squares and crescents and its decorated brick and stucco terraces.

  CABE even sought to justify the "gasometer" on the grounds that it would contribute to regeneration. Such an argument could well be valid in Hackney or Hartlepool, but is there a place in Britain where regeneration is less relevant than in South Kensington?

(v)   Sustainability

  Current policy on "sustainability" provides, amongst other things, that buildings not needed for their original purpose should, if possible, be reused. This argument has been used in Chelsea at the Power House in Alpha Place to support the retention and expansion of a former electricity sub-station. How far should this policy be taken? Should buildings, however ugly and ill-formed, be retained in order to conserve resources? Notwithstanding repeated references in its literature to the need to take account of context (see "Building in Context, 2002"), CABE seems to place higher value on lively new architecture, whatever its scale or bulk, than on the relationship of buildings to their settings. CABE should review its approach to the reuse of buildings located in historic towns and conservation areas. In such places context merits being given the highest value.

(vi)   Bringing accountability to design review

  The Royal Hospital is the work of both Sir Christopher Wren and Sir John Soane and, as an architectural set piece, ranks in importance with Greenwich and Hampton Court. Following changes in care home legislation the hospital has been obliged to modernise its infirmary and plans are accordingly being drawn up to replace the present one which was built in the 1960s.

  Plans have yet to be submitted to the local planning authority but, so sensitive is the project in design terms, that three firms of architects have already been involved. Yet there is a serious risk that, even now, the new infirmary will be no better than lacklustre. CABE has been involved behind the scenes in pressing for design of the highest quality but the Society only knows about this involvement via Councillors and residents close to the hospital. Is this for the best?

  Where controversial proposals of this kind are involved, would it not be better for CABE to bring them out into the open and make them the subject of public debate? Civic societies and residents, instead of being kept in the dark, could be enabled to play a greater part in shaping their environments. It is also the case that, as a general rule, CABE needs to listen to people who will be affected by the schemes which it reviews. Had this been done in the case of the Royal Hospital, current uncertainties might have been avoided.

  The Society believes that ways must be found to make the design review process more open. Public debate about the quality of architecture and public places promises to create a better informed public. CABE should, for instance, consider holding open debates at places where controversial buildings are proposed.

(vii)   Membership of the Panel

  CABE's design review panel embraces modernist and neo-classical architects but it is still too narrowly based. Even though English Heritage is represented at review meetings, the panel is lacking in conservation expertise and in understanding of the role of development control. Additional expertise is needed in architectural history and town planning and in the design and management of the public realm. There should, above all, be a balance between members directly involved in the commerce of development and construction and those who are not.

  The Society urges the inclusion in the design review panel of more expertise in architectural history, town planning and the public realm. Members from civic societies with experience of working in historic places are needed too. Above all a balance needs to be struck between those with commercial interests and those with nothing to gain from development. Unless a balance is struck the judgements of the design review panel will lack objectivity.

1.  INTRODUCTION

  The Chelsea Society has about 1,600 members and is the leading civic society in its district. The Society plays a vigorous role in public life, holds regular exhibitions, lectures and meetings and, with the Kensington Society, has periodic, formal meetings with the Leader of the Royal Borough. Many informal contacts are made with residents, businesses, Councillors and Council staff. The Society has a standing sub-committee which exists to vet all planning applications and, where appropriate, makes representations on them to the Council and other relevant bodies.

  Chelsea is, of course, a world famous address that is notable for the richness of its historical and architectural endowment. It is predominantly covered by Conservation Areas and is, in all but name, a World Heritage Site.

  Within the last three years four applications on which CABE has made observations have come to the notice of the Society:

    —  Lots Road Power Station

    —  The Power House, Alpha Place

    —  South Kensington Underground Station*

    —  The proposed infirmary, Chelsea Royal Hospital

*  The Underground Station is, of course, in South Kensington and not in Chelsea but, as the tower proposed for the top of it would have been widely visible from Chelsea, the Society took a keen interest in the case and worked closely with the Brompton Association and the Kensington Society.

  The Society's experience of CABE as gained through these applications will inform much of this memorandum. Reference will also be made to such CABE publications as "Design Review: Guidance . . . ", "Design Reviewed: Issue 1, February 2004", letters from CABE's Head of Design Review to scheme architects, and the Commission's website www.cabe.org.uk.

2.  CABE'S OVERALL PRIORITIES FOR INVESTMENT AND DEVELOPMENT

  The ODPM Committee asks respondents first to consider CABE's "overall priorities for investment and development". This issue is beyond the Chelsea Society's experience but it does prompt the question whether or not there is a role for a national body charged with being, as CABE is, a "champion for better places". (Design Review, Page 2.)

  A case can no doubt be made for abolishing CABE, but since thoughtless and ugly new development is all too common all over Britain, and since the Society has worked tirelessly since 1927 to avert such ugliness in its own patch, it would be contradictory to argue against a national body with similar aims.

  We therefore warmly support CABE in its efforts to raise standards in architecture, civic design and master planning. We recognise too, that this difficult task requires dedicated and often unnoticed diplomatic skills. The main focus of this memorandum is, therefore, on design review, a function of which the Society has experience and which it believes can and should be refined.

3.  DESIGN REVIEW

  Design review should be an objective analysis of quality in buildings, spaces and places. Too often it appears to be a matter of tastes and, as is well known, taste varies from period to period and person to person. Taste is affected too by fashion and by competing ideologies. This means that, at any given time, there will be competing views about what is and what is not "good design". It is important for CABE to be frank about this and to avoid partiality in judgements that flow from design review.

  Design review is therefore about quality and in CABE's hands its purpose, like assessment in other professional fields, is to reduce the risk of mistakes and to raise standards. More precisely it is about informing architects and planners about ways to improve the quality of their schemes and fit them better to their surroundings. In the Society's view the Commission's design review committee should confine its work to assessing schemes with a view to raising their quality.

  For CABE to champion commercial developments, however well designed, is not in the public interest. It is not for CABE to use design review to influence the decisions of local planning authorities but to raise the quality of what goes before planning committees.

  The Chelsea Society will now use its direct experience of CABE's work to respond to the issues raised by the ODPM Committee under the heading of "the work of the design review panel".

4.  THE CHELSEA SOCIETY'S EXPERIENCE OF CABE

(a)   Lots Road Power Station

  This is a very large, Thames-side development designed by Terry Farrell & Partners for Circadian and Hutchinson Whampoa. The mixed use scheme, which lies partly in Fulham and partly in Chelsea, is to a very high residential density. At 667 habitable rooms per hectare it is two to three times the highest density recommended in their plans by both Hammersmith and Fulham and Kensington and Chelsea Councils.

  For the Chelsea Society, and other local societies, it is objectionable for this very high density and for two very tall blocks of flats—now somewhat reduced to 37 and 25 floors. The site, it should be noted, is far from the Underground (both Kensington and Hammsermith and Fulham Councils locate it in their lowest level for "public transport accessibility"). Furthermore, as the two towers were absent from Sir Terry Farrell's earliest scheme, it appears that the development would be commercially viable without them. The towers appeared only after Councillor Barry Phelps of RBK&C and Mayor Livingstone spoke in favour of tall buildings.

  Sir Terry in due course took his scheme to CABE before submitting it formally to the two planning authorities. It then went through various permutations and as there is no summary report about it on the Website, the Society is relying on letters by CABE to the architects which were copied to the Royal Borough of Kensington and Chelsea and are on file in the Town Hall.

  CABE's first letter (31 January 2001) contains the following points:

    "we would like to see the scheme go ahead"

    "we are not convinced about the form of the two `gateway' residential towers"

    "it would be better for there to be a single tall building . . . a tall building on this prominent site needs to be of the highest quality in terms of design and materials".

  A second letter, when the scheme was still pre-planning, (10 April 2001) says:

    "We consider that the analysis which has led to the proposal for two towers appears sound, and the juxtaposition of the towers in their current form has the potential to create an interesting and refreshing composition."

  A third letter (19 November 2001) says:

    "The committee continues to offer general support and enthusiasm . . . "

    Apropos the towers it says: "Although we think a mainly a stainless steel and glass cladding could have been developed successfully, we think that terracotta has the potential to provide a more attractive alternative . . . "

    " in some views of the scheme from the other side of the river. the composition . . . creates considerable pressure on the secondary building . . . "

    "We are pleased that extensive wind studies are being carried out . . . (to) . . . address problems we feel might arise in the area between the towers and along the riverside."

  A final letter (13 December 2002) says:

    "we welcome the changes that have been made to the scheme . . . "

    "We think that the relative heights and locations of the towers work well."

  Examination of the letters reveals CABE to be strongly pro-development. Furthermore it is notable that the towers, whether one or more, are generally seen as distant objects by the river rather than as slabs that would dominate the nearby streets and houses of West Chelsea and intrude on the southern skyline of the Grade II listed Brompton Cemetery.

  The review shows no awareness of:

    (a)  the absence of towers in the earliest and presumably equally viable scheme,

    (b)  shortcomings in the design of the riverside walkway which, as a broad, bland, mini-motorway is, except where it crosses Chelsea Creek, without variety, drama or incident,

    (c)  that wind studies, though they can enable wind speeds to be estimated and gusts to be deflected, by detailed design, from the doors of tall buildings, cannot eliminate the acceleration of air currents that always occurs near towers, and

    (d)  the strong objections to the towers of local amenity societies and residents.

  "Guidance on Tall Buildings" 2001, a joint CABE and English Heritage report, says: "Government policy is to get the right developments in the right places. It states that tall buildings should be of the highest architectural quality and designed in full cognisance of their likely impact on their immediate surroundings and the wider environment."

  It is not clear that the review panel has read its own guidance. It seems to believe that if a tall building is well designed that makes it acceptable on all counts. The panel shows no awareness that to live in the shadow of tall buildings, to be overlooked by people living or working in tall buildings, to suffer wind blasts at the foot of tall buildings are all nuisances created by tall buildings be they well-designed or not. In its assessment of proposed towers in Chelsea and at South Kensington Station (see below), it can only be concluded that CABE was not abiding by its own guidance.

(b)   South Kensington Underground Station

  This proposal, by Farrell and Partners for Stanhope plc, involved decking over of the District and Circle Line platforms, reconstructing the booking hall and topping the site with a 10 storey "gasometer" office tower. Shops and flats were included too. As the Committee will no doubt know CABE's favourable review of the Farrell design led to accusations of conflicts of interest within CABE, an audit by the DCMS, the resignation of CABE's chairman and the withdrawal by Stanhope of their scheme. The Society believes that this was the right outcome to a serious issue and will now focus on design issues.

  In this case, unlike the others which have come before us, CABE has put a summary of its analysis of the development on its website. (www.cabe.org.uk/review/reports.asp?id=183) This helpful note, surprising for being so partial to the development, contains the following statements:

  "The committee offers its warm support for this long awaited scheme. The present station offers limited facilities and amenity for residents and visitors and does very little to enhance the image of this significant destination. Given the large numbers of people using the station it is an embarrassment to the capital. We accept the architect's argument for creating an important civic marker at this location. Development of the type proposed is, in our view, consistent with government thinking on the value of development at locations highly accessible by public transport." (Page 1. Para 2.)

  "We think that, taken in the round, this is a convincing proposal that successfully balances the needs of London Underground and the management of large numbers of people, with the creation of a viable mix of uses and a new civic space." (Page 2. Para 3.)

  Is it the role of CABE's Design Review panel to offer "warm support for this long awaited scheme"? Is this design analysis or a signal to the local planning authority to give permission to the development?

  CABE then condemns the station's lack of amenities and poor "image". The subsequent listing of the station by the Secretary of State at DCMS makes it clear that, although the station may suffer from neglect, beneath the surface lie Victorian engineering and an Edwardian arcade of "special architectural and historical interest" that are co-eval with, and of the highest relevance to, Prince Albert's great cultural quarter. Why was CABE blind to these aspects of the station? And why, in the final paragraph of its review (not quoted above), did CABE seek to belittle the views of residents by stressing the need to ascertain the views of visitors?

  CABE then gives its support to Sir Terry Farrell's proposed "civic marker". The justification is government advice about the appropriateness of higher density development at points of high accessibility by public transport. CABE's judgement may be questioned on two grounds.

  First, is a civic marker in the form of a routine office block appropriate in the heart of one of the most architecturally distinguished residential quarters in London? Does an outstanding townscape of terraces topped by the cupolas and spires of great national institutions have to be topped too by a commercial tower? Do people in their houses and flats have to be looked down at by office workers?

  Second, are there no limits to density? The residential density of Kensington is already the highest in Britain. Is it in tight-packed places such as this that densities should be raised still higher? Such action may well be appropriate at Paddington or London Bridge but surely not in high density inner city residential districts?

  The "civic space" to which this paragraph refers is one wider pavement and a new booking hall intended to replace the historic, and now listed shopping arcade. But what about the traffic dominated streets that form an ugly and dangerous "moat" around the station? Here, in the heart of residential South Kensington, one would surely expect to see more than a down-sized spaghetti junction. Yet of this gross lack of amenity, this abnegation of civic space, CABE makes no mention. For a body devoted to championing "better places and spaces", this seems, to say the least, remiss.

  The Chelsea Society concludes that CABE, instead of subjecting Sir Terry's design to careful scrutiny, was seeking to give a boost to a piece of "modern" architecture while giving scant attention to its context. In so doing the Commission was riding roughshod over the strictures in its own handbook " . . . analysis should go beyond the view from the site boundary. The site's context includes the neighbourhood and the town of city as well as the street." (Design Review, Page 5.)

  Furthermore, all this assessment of the Farrell design went on before the scheme was in the public domain and without any input from those who would have to live with it. And, as if to add injury to insult, CABE sought to justify the scheme on regeneration grounds. Is there anywhere in Britain where regeneration is needed less than amongst the houses of millionaires in South Kensington?

  No issue in architectural assessment raises more difficulties than the relationship between tall towers and streets of terraced houses. CABE's design review makes no effort to address it. Is there a single instance of a tall office or residential tower that adds delight to streets of three or four storey houses in a conservation area? The Society is not aware of it. This problem needs to be addressed. When CABE reviews a proposed tall building in a historic district or near a conservation area, its first questions should be: What would be the effect of this building on its context? And is this tower necessary or is it either pure commerce or a reflection of the egotism of its designer?"

(c)   The Power House, Alpha Place

  This development, designed by Piers Gough or CZWG Architects, involved the conversion of a 1930s electricity transformer station into apartments. The building itself is a bleak "functional" block of irregular form that bears no relationship in form to any of its surroundings—mostly decorated, red brick Edwardian terraced houses and mansion blocks. Piers Gough, having decided to retain and expand the industrial boiling so as to achieve a very high density, took it to CABE. In this case only the chairman of design review, advised by staff, considered drawings supplied by the architects. There was no local input.

  Again the Society is relying on a letter to the architect (20 November 2003) which was copied to Kensington Town Hall. It says:

  "This development appears to us to both appropriate and welcome on a number of grounds . . . " These include:

  "reuse of a redundant building . . . relatively high (but acceptable) density . . . a welcome element of affordable housing . . . (and because) it responds satisfactorily to the variety of scales which form the character of the immediate and wider Chelsea area . . . "

  This is undoubtedly a complex case. Sustainability policy coupled with the presence of a small number of taller 1930s buildings, are used to justify retaining and expanding an ugly industrial building surrounded by very extensive Cheyne and Royal Hospital Conservation Areas.

  CABE seems, furthermore, to have taken no cognisance of the outlook of those who will have to live with an overweening neighbour, or of building to a very high density in a Borough that is already higher in density than any other in Britain.

  Notwithstanding repeated references in its literature to the need to take account of context (see "Building in Context, 2002"), CABE seems to place higher value on lively new architecture, whatever its scale or bulk, than on the relationship of buildings to their settings. CABE should review its approach to the reuse of buildings in historic towns and conservation areas. In such places context merits being given the highest value.

(d)   Chelsea Royal Hospital—The Infirmary

  This development has yet to be submitted to the local planning authority and, as a result the Society only knows about CABE's involvement via Councillors, Council officers and Chelsea residents close to the hospital. Is this for the best?

  The Royal Hospital is the work of both Sir Christopher Wren and Sir John Soane and is an architectural set piece of national importance. It ranks with Greenwich and Hampton Court yet there is a serious risk that, even now after three different firms of architects have been involved, the new infirmary will be no better than lacklustre. Should all this be going on behind closed doors? Should not CABE be bringing the issue out into the open?

  In this and in other developments, CABE needs to help civic societies and residents to play a greater part in shaping their environments. It also needs to listen to them. Where controversial proposals are involved, would it not be better for CABE to bring them out into the open and make them the subject of public debate? Had this been done over the Royal Hospital, current uncertainties might have been avoided.

  The Society believes that ways must be found to make the design review process more open. Public debate about the quality of architecture and public places promises to create a better informed public. CABE should, for instance, consider holding open debates at places where controversial buildings are proposed.

5.  MEMBERSHIP OF THE DESIGN REVIEW PANEL

  One issue that emerges again and again in the Society's review of CABE's work in Chelsea is the very special conditions that obtain in places that are richly endowed with the architecture and streetscapes of previous centuries.

  And in reviewing CABE's observations on developments proposed for Chelsea and South Kensington, it is hard to avoid coming to the conclusion that, consciously or subconsciously, if a well-known architect and a large commercial development are involved, CABE is reluctant to ask fundamental questions about the rightness of what is proposed.

  CABE's design review panel embraces modernist and neo-classical architects but it is otherwise narrowly based. Even though English Heritage is represented at review meetings, the panel is lacking in conservation expertise and in understanding of the role of development control. Additional expertise is needed in architectural history and town planning and in the design and management of the public realm. There should, above all, be a balance between members directly involved in the commerce of development and contraction and those who are not.

  The Society urges the inclusion in the design review panel of more expertise in architectural history, town planning and the public realm. Members from civic societies with experience of working in historic places are needed too. Above all a balance needs to be struck between those with commercial interests and those with nothing to gain from development. Unless a balance is struck the judgements of the design review panel will lack objectivity.





 
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