Memorandum by the Kensington Society (CAB
19)
EXECUTIVE SUMMARY
The Kensington Society has prepared this submission
based on its recent experience of the workings of CABE. This was
in the context of the proposed redevelopment of South Kensington
Underground Station in London which occupies a sensitive site,
serving a substantial residential area, great religious buildings,
a number of London's most famous museums and the Royal Albert
Hall.
Our direct experience in this case has shown
us that:
— CABE operates a secretive Design
Review process for major projects
— This process can lead to CABE preparing
"confidential" letters for development projects which
seek to influence the planning authority
— Such letters are not made available
to amenity societies like the Kensington Society on the basis
that the Design Review has taken place before a planning application
has been lodged
— CABE does not seek the opinions of
the local community or pay attention to them if submitted
— CABE Design Review panels lack expertise
in historic buildings and conservation practice and policy
— There is a potential for serious
conflicts of interest between those at CABE advising on schemes
and the promoters of schemes
INTRODUCTION
1. The Kensington Society, a registered
charity, was founded in 1953. As such, it is one of the oldest
amenity societies in the country. Its role is to seek to protect
and to enhance the amenities of Kensington by commenting on planning
applications and other such matters as streetscape, traffic and
licensing that affect the amenity of the area. It has a broad
membership covering the whole of Kensington. As well as numerous
individual members, many local amenity societies are affiliated
to it. The Kensington Society thus represents the voice of many
who live and work in the area and who care deeply about the quality
of the built environment.
2. The Society is highly respected by the
Royal Borough of Kensington and Chelsea and its views are regularly
taken into account in planning matters. The Society regularly
comments on the Council's Draft Statements and Supplementary Planning
Guidance documents. The Society played a key role in the shaping
of the Unitary Development Plan, the policy document which continues
to form the framework for decision making in the Borough.
3. The Society has expert advisors on matters
relating to architecture, planning and the historic environment
and its submissions on planning matters are authoritative and
well considered. The Society is not a preservationist group. The
perception of CABE and many in the development lobby that amenity
societies are universally against change, are backward-looking
and obsessed with the past is unfounded and unfair.
4. Kensington has seen a renaissance of
good new buildings and public realm initiatives in recent years.
Whilst the majority of the area does indeed comprise areas of
significant historic architecture—and 75% of the Borough
is now designated Conservation Area as a result—the opportunities
for high quality new buildings on appropriate sites are welcomed
by the Kensington Society. The Society has, for example, sought
solutions of architectural excellence for the Victoria and Albert
Museum and the South Kensington Station sites. Furthermore, the
Society warmly endorsed the public realm improvements recently
completed in Kensington High Street which are now regarded as
an exemplar. However, in an area as densely developed and of such
significant historic and architectural importance as Kensington
undoubtedly is, decisions to alter the built environment do need
to be well balanced, well considered and to take cognisance of
all the issues, most particularly that of context.
5. Sadly, in our view, CABE has so far failed
to demonstrate that it is capable of this because it lacks a wider
appreciation of what constitutes a quality built environment.
As an organisation is appears to believe that new development
must always be beneficial, the corollary being that older buildings
are readily dispensible. CABE fails to realise the importance
of protecting Conservation Areas. CABE's inappropriate response
to the controversial redevelopment proposals for South Kensington
Tube Station over the past two years serve to illustrate our concerns.
It is our involvement in this particular case that has led us
to the views about CABE which we submit to your Committee. We
suggest to your Committee that our experience over this case and
the impressions gained are likely to have echoes in much of the
work CABE does in respect of Design Review given that so many
schemes invariably involve new construction in areas of traditional
townscape.
CABE, DESIGN REVIEW
AND SOUTH
KENSINGTON UNDERGROUND
STATION
6. The whole area around South Kensington
Tube including the Tube Station itself is a designated Conservation
Area. There have been attempts to redevelop the station site in
the past going back to the 1970s but it is the most recent scheme—withdrawn
following a storm of protest in December last year—that
concerns us here.
7. By way of brief background, planning
permission was given in 1999 for a scheme designed by Farrell
& Partners. This was not implemented and a revised scheme,
very much larger in scale and incorporating a large office tower,
was brought forward last year by developers Stanhope and Hutchison
Wampoa on behalf of LUL. The developers argued that the earlier
scheme was not viable. The new scheme was, however, massively
larger and significantly in breach of the Borough's UDP.
8. Some eight months before the planning
application was lodged with the local authority, CABE considered
the scheme at Design Review. A very supportive letter (Appendix
I) was then sent in confidence by CABE to the Royal Borough of
Kensington and Chelsea and copied to the developers, Stanhope,
and to their professional advisors. Our Society was not given
an opportunity to consider the scheme at this stage and could
therefore not make our views known.
9. The CABE letter offered "warm support"
for what it described as this "long awaited scheme".
The letter went on to write off the existing station as offering
"limited facilities and amenity for residents and visitors".
It stated that the station does "very little to enhance the
image of this significant destination".
10. South Kensington Station is, however,
extremely historic being amongst one of the earliest underground
railway stations in the world. It is also of considerable architectural
and historic interest and has quite correctly since been spot-listed
by the Secretary of State for Culture, Media and Sport.
11. At Appendix II is the submission our
Society made together with the Brompton Association and the Chelsea
Society in February this year requesting spot-listing. We would
draw your attention to the section on the history of the station
about which CABE, in reaching its view unquestionably in support
of redevelopment, was quite clearly wholly ignorant. How could
it be otherwise when CABE's Design Review panel does not have
architectural historians to give appropriate advice or experts
in the conservation of historic buildings to add balance to the
preponderance of architects and other construction industry professionals
closely involved in new development?
12. The reason the station does little "to
enhance the image" of South Kensington at present is because
the building is looking shabby following some 30 years of planning
blight. CABE did not acknowledge this. The possibility that the
station could be imaginatively refurbished was not even considered.
In this connection, we attach at Appendix III a copy of the booklet,
A Solution for South Kensington, which the Brompton
Association published with our support in April which illustrates
this point well. In terms of generating a high quality urban environment—which
CABE is charged by government with promoting—the solution
outlined in this booklet is far more likely to achieve this and
to be appreciated and valued by ordinary people, be they visitors
or residents, than a large and damaging comprehensive redevelopment
being pushed by developers. There is no question but that development
on the scale proposed, which CABE endorsed, would have seriously
damaged the South Kensington Conservation Area.
13. It appears to us that both at Commissioner
level and on the Design Review panel there is an over-abundance
of individuals actively engaged with the construction industry
who are likely to see new development as a panacea and to regard
older buildings as expendable. These were the attitudes that predominated
in the 1960s when so many terrible mistakes were made in towns
and cities throughout the UK. The "gasometer", as the
proposed tower at South Kensington was nicknamed in the press,
would undoubtedly have been a mistake.
14. Yet the CABE letter goes on to support
the creation of a large office tower as an "important civic
marker". What role or need is there for an office in an area
that is essentially residential and the gateway to London's cultural
quarter at Albertopolis? The area is already densely developed.
The tower would have added nothing; rather its height and bulk
would have dominated what is otherwise a very attractive historic
skyline. To go on to support the tower on the basis that "government
thinking on the value of development at locations highly accessible
by public transport" begs the question of value to whom?
To those developing the site, certainly; to the public, definitely
not. South Kensington is not a commercial hub and its village
character of small specialist shops and nineteenth century terraces
is no place for a major commercial development reminiscent of
the City of London. We are concerned that CABE does not view schemes
in the round and consider context. Consideration of context is
wholly absent from the CABE letter on South Kensington.
15. In the next paragraph, CABE implies
that the scheme should be supported because it overcomes "a
difficult set of engineering constraints". CABE should, in
our view, have questioned why it was ever considered necessary
or desirable to deck over the existing tracks knowing, as CABE
surely does, that in order to make a decked scheme viable, the
economics are such that the entire site would need to be built
over to a minimum height of seven stories. Again, a complete lack
of understanding of context was evident here. The fundamental
question, namely, was this scale of development necessary in order
to improve the station, was never asked or addressed.
16. Further support for the scheme comes
in the next paragraph when CABE states that "taken in the
round, this is a convincing proposal". But CABE did not consider
the scheme in the round—or in context. On the contrary,
it considered the new building in isolation.
17. CABE goes on to state that the demolition
of the nineteenth century terrace on Thurloe Street is "acceptable".
This comment was clearly designed to marginalize the view of English
Heritage (a statutory consultee) which had long made it known
that, in its opinion, this significant terrace should not be demolished
as it made a significant positive contribution to the character
of the Conservation Area—a view wholly endorsed by this
Society.
18. CABE's role in terms of Design Review
as set out by DETR is to encourage good quality design, not to
promote developments. The very first mention of design comes as
far down as paragraph 5 when CABE makes a suggestion in relation
to the design of the housing block proposed for the Pelham Street
frontage. Curiously, for an organisation charged with promoting
and improving the quality of design, this is the only attempt
made in the whole letter which addresses detailed issues of design.
19. The letter gives support to the "civic
space" being provided at the bull-nose end of the site. To
anyone who had studied the proposals in detail it was evident
that this would be no civic space at all but an enlarged pavement
surrounded by traffic. The idea that this could ever have been
an attractive place for people to meet, sit and enjoy is frankly
naive. CABE fails to identify the key problem facing South Kensington
and the reason why the urban realm is not as attractive as it
might be namely, the gyratory one way traffic systems around the
station and the two island sites nearby. The solution here is
not redevelopment of the station, but for the local authority
to commission a comprehensive study of the urban realm to resolve
the traffic problems—as it is currently doing as part of
the much trumpeted Exhibition Road Project. Returning streets
to two-way traffic, restricting traffic and putting the pedestrian
environment first is what is needed. There are models for this
approach—for example the recent improvements in Clerkenwell.
Why did CABE's Design Review panel not address this vital issue?
20. Instead of focussing on the key problems
facing the site, the CABE letter goes on to suggest that a clock
or some other feature be placed as a "marker". This
focus on small details at the expense of missing the key issues
is typical of the whole letter. It demonstrates that those giving
the advice are not as familiar as they should be with the site
itself nor inclined to approach Design Review with sufficient
independence and rigour. In the last analysis, the CABE letter
is superficial.
21. It is, however, the last sentence of
the letter that gives us greatest cause for concern. In effect,
this is designed to encourage the local authority to ignore the
views of local residents and amenity societies in favour of unnamed
"visitors and tourists". This reference is presumably
in the letter because those promoting the scheme suggested to
the Design Review panel that local people might well object. They
did, but not for NIMBY reasons. The scheme was fundamentally flawed
and CABE should have been equipped to identify its shortcomings.
It is perhaps revealing that nowhere in the CABE letter does CABE
state that it considers the development a fine piece of contemporary
architecture; it is just pro-redevelopment.
22. All in all, it is hard to see how, if
CABE had abided by its own guidance as set out in its own documents
such as Building in Context, Design Review and the guidance on
Tall Buildings it could have come to the views it did on South
Kensington. Because CABE has too many panel members with an interest
in development, their views are likely to be, on balance, in favour
of development. This is scarcely inclusive or democratic.
23. What, however, is so worrying about
CABE's approach to all of this is that this letter was submitted
in confidence to the local authority and then used by the promoters
of the scheme to encourage support and deter and deflect criticism
from those with a legitimate interest in planning matters and
detailed local knowledge and experience. We attach at Appendix
IV the letter we wrote to the Minister for Media and Heritage
in March this year, and which we copied to the independent auditor,
on the subject of Conflicts of Interest. The contents are self
explanatory.
24. We were never given an opportunity to
comment or to make our views known to CABE's Design Review Panel
on South Kensington. We have a sinking feeling that had we done
so our views would have been ignored anyway. We are left with
the impression that CABE does not want the views of local groups
and that it regards such groups as being ultra-conservative, fuddy-duddy
and representative only of a self-interested point of view. Yet
it is voluntary groups such as ours comprising knowledgeable people
who give up their time disinterestedly to advise on matters that
affect their local environment who are the ones that have the
quality of the built environment at the heart of their agenda.
25. The role of civic amenity societies
in this country is a demonstration of responsible citizenship—engaged,
inclusive and caring. CABE should be prepared to listen to such
groups and to invite them to participate positively in its decision
making on Design Review. CABE should regard civic amenity societies
as stakeholders in the built environment.
Robin Price
Chairman, Kensington Society
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