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| MONSTER CASINO SITE |
The public consultation ends today, but that friend of developers, Mr Bore is legally bound to accept objections UNTIL THE DAY OF DECISION.
These cannot, at this stage, be on licensing grounds.
Michael Bach's excellent letter to the planning dept provides a litany of reasons for objecting to this monster casino.
It is long, but well worth reading, as a masterwork in how to structure a cogent objection.
We should still continue to keep up the pressure by writing in with our objections to: daniel.massey@rbkc.gov.uk or planning@rbkc.gov.uk
Dear Mr Massey,
PP/14/08952: The Holiday Inn, Kensington Forum Hotel,
97-109 Cromwell Road, LONDON, SW7 4DN
Demolition of
existing structures and provision of a casino (Sui Generis Use) with ancillary
restaurant; facade improvements to hotel podium, associated landscaping, plant,
car/cycle parking and other works.
(MAJOR
DEVELOPMENT)
I am writing on behalf of the Kensington Society to object to this proposal develop a major
casino, with ancillary restaurant (2,345sqm NIA) on land that has been open
land for the last 40 years.
Our grounds for objecting are:
·
historic restrictions on site development
·
the loss of open space
·
the likely impact on parking and traffic
·
the impact of the casino on the surrounding area
·
the impact of the building on townscape
Historic restrictions
on site development:
The site is covered by the London Squares Preservation Act
1931, which seeks to protect London squares from development. London squares
are also part of the Borough’s legacy as heritage assets. Their preservation
has been supported by successive development plans at the London and Borough
levels. Currently this covered by the London Plan Policy 7.18B and Core
Strategy Policy CR5. The basic principle is that the loss of local protected
open spaces must be resisted unless equivalent or better provision is made.
The site was redeveloped for a major hotel following a
consent in June 1970 and an agreement was reached between the Royal Borough and
the developer on 1 February 1971 under the London Squares Preservation Act 1931
that the retained amount of open space, after swapping it around to enable the
development, was equivalent to the pre-existing space covered by the Act. In other words, the spaces were allowed
to be rearranged but the amount of open space was to be retained equal to the
Victorian open plan.
In November 1984 an application (TP/84/1585) for a 379sqm restaurant
extension into the existing garden was refused, because it would worsen the
appearance of the building, result in the loss of open area and increase
traffic congestion. This refusal was upheld on appeal on 15 August 1985.
In June 1987 a further application (TP/87/1233), including
the addition of a new banqueting suite and meeting rooms on the Cromwell Road
frontage with an area of 484sqm was refused on 5 January 1988, for the same
reasons as before. This appeal was also dismissed on 12 December 1988 because
of the further loss of open space and the effect this would have in increasing
the impact of the already very dominant building.
These two decisions confirmed that there was no scope for
further development of the remaining open space on this site as there was no
scope for equivalent replacement open space within the site.
Loss of open space:
The current proposal is significantly bigger than the two
previous applications – with a footprint of at least 1,400sqm - and, therefore,
would involve a considerably greater loss of garden land than either of the
previously-refused schemes, contrary to Section 3A of the London Squares Preservation
Act 1931. There is provision in the 1931 Act for exchange of land, equivalent
in area and amenity value, to offset any losses. It is impossible to find an equivalent
amount of open land to make good this further loss of protected open space. As
a result, this proposal would not meet the requirements of the London Squares
Preservation Act 1931.
In terms of the Core Strategy this loss of open space is
contrary to:
Core Strategy Policy
CR5: Parks, Gardens, Open Spaces and Waterways as adopted on 3 December
2014, which states that:
“The Council will:
a. resist the loss of existing … private
communal open space and private open
space where the space contributes to the character and appearance of the area;
and
c. resist development that has an adverse effect
on garden squares and communal gardens, including proposals for basement.”
Two previous schemes, which both involved a smaller loss of
open space than the current proposal, were refused and the appeals dismissed.
With a footprint of nearly three times the largest previous scheme, the loss of
garden space on this scale is totally unacceptable. The planning history of
this site more than demonstrates that this scheme should be refused.
Impact on parking,
traffic and access
The current proposal for a major casino of 2,345 sqm
(2,787sqm in some documents) spread over two floors, designed to handle 1,500
customers per 24-hour day, 365 days a year, and employing 120 people. No matter
what the applicant’s consultant says, this proposal would be likely to generate
additional traffic and, therefore, increased problems in terms of congestion
and parking. This development is significantly larger than previous schemes in
the 1980s – 379sqm and 484sqm respectively – which were considered to result in
an unacceptable increase in parking stress.
The whole of this part of Courtfield Ward suffers from
parking stress – more than 90% of the residents’ parking spaces occupied - and
in the evenings, when single yellow lines and pay-and-display parking are
available for anyone to park from 6.30pm, almost all available space is
occupied. Residents’ parking spaces are exclusively for residents until 10pm
and from 8.30am the following morning. Despite the very apparent parking
stress, the “opportunity” to park would fail to discourage people seeking local
on-street parking spaces.
The area cannot accommodate an additional traffic-generating
use of this scale. Whilst the ability to
find on-street parking would be constrained by the limited availability of such
spaces, it would increase the competition with residents returning home after
10pm and increase the congestion and amount of driving in search of car parking
spaces.
The submitted Parking Management Plan (para 4.8) suggests
that on-site parking at the hotel (20 spaces) and at the Millennium Hotel (50
spaces if available) could provide off-street parking for a significant
proportion of valet parking, but that 30% of cars would be self-parked in the
locality. The proposals for staff parking, given the high proportion working
“unsocial” hours, are totally unrealistic – expecting them to park in
off-street car parks, when they may well seek free on-street parking in the
neighbourhood. Whilst the number might be reduced by the Travel Plan for staff,
not the casino clients – say from 20% to 10% - that could still leave as many
as 15 cars of staff members looking for spaces on-street, if they could find
them!
The bottom line, if the Parking Management Plan is to be
believed, is that this development, as a result of 30% of customers and staff
coming by car seeking on-street parking spaces, would cause exacerbate an
already difficult situation – absolutely no evidence is provided of the existing
levels of “parking stress” in the neighbourhood; it is promised once the casino
opens!
The
Core Strategy, the Transport Supplementary Planning Document and the
saved UDP policies support our objection:
Policy CT 1: Improving alternatives to car use
The Council will ensure that there are better alternatives to car use by making it easier and more attractive to walk, cycle and use public transport and by managing traffic congestion and the supply of car parking.
To deliver this the Council will:
b. require it to be demonstrated that development will not result in any material increase in traffic congestion or on-street parking pressure;
The Council will ensure that there are better alternatives to car use by making it easier and more attractive to walk, cycle and use public transport and by managing traffic congestion and the supply of car parking.
To deliver this the Council will:
b. require it to be demonstrated that development will not result in any material increase in traffic congestion or on-street parking pressure;
Policy CL 5: Amenity
The Council will require new buildings, extensions and modifications and small-scale alterations and additions, to achieve high standards of amenity.
To deliver this the Council will:
d. require that there is no significant impact on the use of buildings and spaces due to increases in traffic, parking, noise, odours or vibration.
The Council will require new buildings, extensions and modifications and small-scale alterations and additions, to achieve high standards of amenity.
To deliver this the Council will:
d. require that there is no significant impact on the use of buildings and spaces due to increases in traffic, parking, noise, odours or vibration.
Access:
The
restaurant entrance and the separate casino entrance face Cromwell Road, one of
the busiest roads in the Borough. A taxi
or a valet driven car stopping on this road would add further to the already
existing congestion. We understand that
the casino is positioning itself as a venue for hen and stag nights, office
parties, etc– and where are the coaches going to disgorge the revellers?
We
also understand that the applicant has applied for a taxi rack on Ashburn
Gardens. How the truth comes out. The applicant has realised that there will be
an increase need for taxis. Ashburn
Gardens and Courtfield Road are residential blocks. The casino is to operate 24 hours which means
these taxis will be constantly starting and stopping, often in cold weather
leaving their engines running, people telling the taxi driver where to go
before entering the taxi then slamming doors.
To allow a taxi rack to serve late night – and early morning – casino
clients will disturb the peace and quiet of the evening and early mornings, and
is objectionable.
Impact on the
townscape of the surrounding area:
The proposal is to build a two-storey block filling all of
the Cromwell Road frontage garden area to form a podium round the existing
hotel.
Impact on the
openness:
The pavement along Cromwell Road is wide allowing both the
pedestrians clear passage and space for the bus stop and numerous telephone
booths, all of which are benefits to the public. The applicant’s statement says “The
open area of pavement and limited landscaping at the Cromwell Road frontage
provides little benefit in terms of amenity. The Cromwell Road is extremely busy
(being 4 lanes) and noisy and is certainly not an environment where one might
wish to loiter or seek solitude”. This obviously misses the point of what open
spaces provide –it is not always a place to sit or even loiter. It is a visual amenity, a
relief from congestion and a place for planting
which reduces carbon dioxide. The solid face of a building set forward of
the other buildings adjoining the site will give no relief – it will be a solid
mass – a bunker - creating a tunnel effect.
Loss of amenity:
This application seeks to slip in further changes to the
remaining garden to the south of the hotel. The existing area along Courtfield
Road and Ashburn Gardens has a line of London Plane trees with a fence
separating the open area with a paved path from the street. The plan of the existing within the
application is false – it does not show the pavement along Ashburn Gardens and
appears that the open area is only on Courtfield Road. It is not economical with the truth – it is
bold lie, a falsehood which should not be allowed. The pavement area under the Plane trees on
both the roads has been used by the public from the time when the hotel was
built. The original plan was to allow
the garden area open to the public though over time both the area have been
reduced by the encroachment of paved café areas and access reduced. The landscape plan within the application
furthers this erosion to the point that the existing and much used and loved
pavement is incorporated into the enclosed area – the future is evident – the
public will be restricted from free access.
This is a major loss of a public amenity. This alone is a deal breaker.
Building
The
height of the building would be 10.8m and would extend from corner to corner of
the site covering the entire existing open garden area. It is presented as two-storey building but it
would, in fact, be taller than a three-This storey building. It would dominate the street, all feeling
openness would be lost as well as the garden.
As noted the pavement along Cromwell Road will be reduced considerably.
The artist’s impression of the building facing Cromwell Road is also economical
with the truth – the two entrances, the signage, the bus stop and multiple
telephone booths are all gone – but where?
There is no mention of a new bus stop on Cromwell Road. If the bus stop and telephone booths were to
remain the pavement would be too narrow. What is presented in the artist’s impression
is not what is proposed on the plans and is not what would be built if
approved. Do not be fooled by the gloss
of the artist impression.
The
proposed building sits uncomfortably on the site, and would be much too large
for the site and for the area. It would
dominate visually and this would be compounded by the strident cladding of fake
stone and oversized glazing. The long street façade has no reference to the
area or the heritage of the site. It
appears as bunker. The cheap, illegible
entrances would cause are lost in the façade and will require signage to be
found. There is no mention of the
signage but one can envision LED flashing lights for both the restaurant and
casino entrances.
This
massive, mean building would not enhance the area or improve the host
building. Perhaps the only aspect going
for the existing building is that it is set back from Cromwell Road and,
therefore, is not “in your face”. This
proposal would bring the building out flat against the narrowed pavement and
contrary to the claim, would emphasise the unfortunate host building. The applicant presents the design as a
solution to what they themselves call “an eyesore”. This instead is a carbuncle attached to an
eyesore.
Summary
This application has all the shortcomings of two previously
refused applications whose appeals were both dismissed on the basis of:
·
the loss of open space protected under the
London Squares Preservation Act 1931 and the development plan – London Plan and
the Core policy to resist the loss of open space;
·
their impact on parking and traffic; and
·
their impact on the townscape and public
amenity.
However, this application is much bigger, would result in a
much larger loss of garden area, generate more traffic and parking problems and
have an adverse impact on the character and appearance of the area.
The Kensington Society urges the Council to refuse this application.
Michael Bach
Chairman: Planning Committee
Kensington Society
