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

Memorandum by the Kensington Society (CAB 19)


  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


  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.


  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

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2004
Prepared 27 October 2004