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Monday, 17 December 2018



Consultation on draft Hans Town Conservation Area Appraisal dated October 2018: response from Milner Street Area Residents’ Association to RBK&C

11 December 2018

The Milner Street Area Residents’ Association (MISARA) hereby submits its response to the above consultation. We have carefully reviewed the draft Appraisal and compared it with the existing Hans Town Conservation Area Proposals Statement adopted in January 2000. On almost all counts the draft Appraisal suffers by comparison with the Proposals Statement, and we call on the Council not to adopt the proposed draft.


By way of background, we note that the Proposals Statement was written with warmth and sensitivity by authors who plainly understood and appreciated the qualities of the area and the importance of protecting it from inappropriate development. By contrast, the draft Appraisal reads as a cold-blooded bureaucratic synopsis lacking in respect and affection for the area and downgrading the importance of its protection.

The defects of the draft Appraisal are summarised below.

1. Failure to follow Guidance from Historic England

Historic England refers to reviews of existing Conservation Area appraisals in its detailed Advice Note Conservation Area Designation, Appraisal and Management (February 2016). In Section 1.10 it states:

“The review might typically result in an addendum to the existing appraisal, recording: what has changed; confirming (or redefining) the special interest that warrants designation; setting out any new recommendations; and revising the management strategy.”

It would indeed be useful for the draft Appraisal to provide an addendum describing what has changed in the Conservation Area over the last 18 years and (more importantly) what new recommendations or policies have been made or are under consideration for its protection. But no such addendum has been provided. Instead, as the Council’s head of Spatial Planning, Mr Wade, has admitted to us (in an email of 23 October 2018): “The Hans Town CAA is a completely new document”. It has been written without reference to the Proposals Statement as if this document had never existed.

The justification given for this by Mr Wade is that the Proposals Statement “looks impressive but for decision making and for those putting applications in it is far too detailed and this rather defeats its purpose”. We believe, on the contrary, that the wealth of detail in the Proposals Statement is extremely useful and provides both (i) clearer guidance to applicants and (ii) a better basis for planning officers to resist applications which fail to preserve or enhance the character or appearance of the area. It not only looks impressive but it is impressive, and it fulfills its purpose far better than the draft Appraisal.

2. Removal of Important Objective

The Proposals Statement has three defined objectives, the second of which reads: “To provide guidance in respect of any proposed changes: (a) to owners on appropriate action to preserve or enhance their buildings, including advice on changes for which no planning application is required; and (b) on the Council’s likely response to applications for planning permission”.

Unfortunately, in the draft Appraisal this objective has been removed and replaced with a rather different aim to “assist applicants in making successful planning applications”. This might be considered to replicate (b) in part, though without the benefit of giving guidance on applications which are likely to be unsuccessful; but (a) has simply been dropped without replacement.

We believe that the second objective in the Proposals Statement should be restored in its entirety, and the draft Appraisal redrafted accordingly.

3. Failure to link to Local Plan Policies

Mr. Wade told us in his email of 23 October 2018 that the draft Appraisal “links to policies in the Local Plan”. This is a remarkable claim because the draft Appraisal does no such thing. Apart from a list of policy headings in an appendix on the final page, there is virtually no reference to any of the policies in the Local Plan in the main text of the document.

By contrast, the Proposals Statement has a very useful section 5, “Control of Physical Change”, with 11 pages of valuable detail on how the Council’s policies affect physical change in the Conservation Area. Most regrettably, this section has been removed in its entirety from the draft Appraisal and not replaced with anything.

There have been a number of inappropriate developments in the Conservation Area since the adoption of the Proposals Statement in 2000. These should be commented on in the new Appraisal, but do not necessitate a radical revision. What has changed, however, is the Council’s policies as presented in the Local Plan, together with the impact of ever wider permitted development rights made by successive governments under the General Purpose Development Order.

We, therefore, call for the reinstatement of section 5 of the Proposals Statement, updated accordingly to provide links to current policies.

4. Omission of Important Detail

Section 3 of the Proposals Statement contains 56 pages of detailed description of the Conservation Area, written with obvious affection and sensitivity and reflecting sound aesthetic judgment. A good deal of historical research must have employed, either by the authors of the document or the work of previous generations, and the result is an invaluable contribution to public understanding of the characteristics of the area and what makes it special. It is an extremely important part of the “evidence base” in the context of which decisions are made.

In the equivalent sections of the draft Appraisal, however, this has been slashed by more than half, for no reason given other than that the officers consider the Proposals Statement to be “too detailed”.

We assume that if the draft Appraisal were to be adopted, the Proposals Statement would be removed from the Council’s website – as has happened following the adoption of previous Appraisals - and would no longer be available to assist in public understanding or in the making of planning applications and decisions. Copies of the document would become collector’s items, gathering dust in the archives or on the shelves of disillusioned residents.

We believe that tossing a large part of the evidence base out of the window indicates a disrespectful attitude by Council officers to the authors of the discarded material and to the Conservation Area and its residents, both present and future.

5. Omission of Important Advice

The Proposals Statement contains a wealth of useful advice on a wide range of matters such as the repointing of brickwork, the cleaning of terracotta, the preservation of stonework, the maintenance and repair of windows, the restoration of damaged paving and so forth.

All of this is omitted from the draft Appraisal. Why? In and amongst the discarded advice are some clear and important statements, e.g.:

“The removal of original windows and their replacement with inappropriate ones is often one of the most damaging forms of alterations within a conservation area”.

“Traditionally, York stone slabs were laid in formal, regular linear courses and such a paving layout should always be retained and new work married in to match”.

The failure to replicate explicitly statements such as this in the draft Appraisal suggests a general lowering of standards which we believe should not be accepted.

6. Failure to consider Article 4 Directions to restrict Permitted Development

MISARA and the Chelsea Society have both called on the Council to issue Article 4 Directions to remove permitted development rights in all our conservation areas, thus enabling the Council to refuse applications which fail to preserve or enhance the character or appearance of the conservation area. On 14 October 2018 the Chelsea Society wrote to Cllr Pascall to request this, but we understand that no reply has yet been received.

The Advice Note from Historic England mentioned in (1) above states:

“The specific requirement on local authorities under section 69 of the Planning (Listed Buildings and Conservation Areas) Act 1990 to carry out a conservation area appraisal provides a robust evidence base on which to assess the need for and scope of an Article 4 direction. Ideally a conservation area management plan developed from a conservation area appraisal may identify areas where removal of ‘permitted development rights’ is necessary to prevent the loss of characteristic architectural detailing or gradual erosion of the character and appearance of the conservation area through inappropriate development.”

The absence of a management plan puts the onus on the Appraisal to identify “areas where the removal of permitted development rights is necessary”; but the draft Appraisal fails to do this. In fact the draft Appraisal does not even mention permitted development rights or their impact on the area or the possibility of introducing Article 4 Directions to remove them. Since the ever growing extension of permitted development rights constitutes the main threat to the area, this is a remarkable omission. It should be rectified.

7. Improper Tampering with the Evidence Base

The Proposals Statement gives a 7 page description of Sloane Street, the most important street in the Hans Town Conservation Area. On p. 45 it says:

“Sloane Street branches off southwards from Knightsbridge in a long uninterrupted vista line towards Sloane Square. The most characteristic visual element of the street is the long expanse of the mature gardens of Cadogan Place on its east side. In addition, the sense of openness of the street is established by the generous pavement and road widths. Sympathetic tree planting is effective in nullifying the overpowering effect of the imposing buildings which line the thoroughfare and help minimise the disruptive effect of the incessant through traffic.”

And on p. 47 it says:

“With the exception of a handful of buildings… the individual facades express a clear sense of vertical emphasis which contribute to a sense of compact rhythm to the terrace”.

The vertical emphasis of the buildings in the street has been severely disrupted by the Cadogan Estate’s recent construction of George House at 127-135 Sloane Street, a massive and ugly horizontal lump completely out of scale with neighbouring buildings. The Chelsea Society protested at this, but to no avail. In our view this building should never have been granted planning permission, and the above extract from the Proposals Statement could and should have been used to refuse the application.

But in the draft Appraisal we see to our surprise that the section on Sloane Street has been reduced to a handful of paragraphs, that all references to long green vistas and generous pavement widths have been removed, and that the importance of the vertical emphasis of the buildings has also been removed. Instead, we find this extraordinary statement:

“The 21st century block at nos. 127-135 [i.e. George House] has successfully captured the spirit and form of the terracotta and red brick buildings of Hans Town in its sandstone modelled front elevation”.

We have to ask this question: has this tampering with the evidence base been made so as to facilitate approval of the Cadogan Estate’s unwelcome scheme to widen the pavements in the street, based on the ludicrous assertion that the pavements are not of “generous width” but “too narrow”? It is hard to avoid any other conclusion.

Conclusions and Recommendation

The draft Appraisal is a poor quality document which fails adequately to recognise the qualities of the Conservation Area or to provide material consideration for refusing inappropriate development. By contrast the existing Proposals Statement is a high quality document with valuable detail which should be retained. The draft Appraisal should be abandoned and replaced with a new document based on the Proposals Statement, amended as necessary to bring it up to date.

We can imagine that the planning officers may seek to impose the draft by saying that it follows the precedent of other new Appraisals, but this would be not so much a reason as an excuse. It may be too late to rectify the damage which has already been caused, but it is not too late to stand up in defence of the Hans Town Conservation Area.

We request that this response be placed on RBK&C’s planning website without redaction or reformatting.

Lord Grantley 

Chairman, Milner Street Area Residents’ Association

Sunday, 9 December 2018



It seems that Graham Stallwood is claiming credit for getting Newcombe House called in by the Sec of State.

Odd when you think it was he that recommended the committee grant consent and that it was the Hillgate Village Resident's Association, supported by Cllr Robert Freeman, that persuaded the committee to reject the application.

Still, as one influential resident observed, "it's good news if at last Mr. Stallwood is taking the side of residents".

Dear Councillors, (copied relevant officers)

After the Mayor of London resolved to grant planning permission, you might recall I wrote to the Secretary of State for Housing, Communities and Local Govt asking him to ‘call in’ the case and decide it himself and to make what is called a ’holding direction’ in the meantime to stop the Mayor granting permission.

I have found out this morning that the Sec of State issued a ‘holding direction’ on 29 November which stops the Mayor from granting permission at the moment.  Don’t get your hopes up just yet – it could just be that the department is busy and hasn’t had time to look into it properly.  But I thought it worth letting you know the Sec of State has at least gone so far as to be interested. The holding direction is not time limited, so it will stay in place until either the Sec of State withdraws it, or decides he wants to take over the application himself.

Friday, 7 December 2018


Stanley Davis was just three months old when he died from
catastrophic injuries inflicted by those supposed to be caring for him.
The little boy had been in and out of hospital suffering from broken bones and a brain bleed. 
Despite this, the parents were allowed to keep him prolonging his agony. 
Death must have been a release.

Derek Benson, chairman of the Hampshire Safeguarding Children Board, has confirmed that a review is being carried out of the handling of the child's care by the authorities. 

A person of interest in this tragedy is Benson himself.
In his LinkedIn entry, this retired policeman boasts that "he balances being independent chair of three Children Safeguarding Boards...Worcestershire, Hampshire and the Isle of Wight."
The dullard also advises Key6 Group recently slammed as being unfit for purpose by Ofsted.LINK
Looking after vulnerable children is the most important role a council can perform but Benson boasts that he's performing a balancing act as if he's some sort of juggler!

He's unfit to chair one board let alone three.

Tuesday, 27 November 2018


The Dame was watching her old friend Adam 'Tubby' Boulton on Sky the other day.
To her surprise, up popped Charlie 'the Shrink' Tannock, our noble MEP who represents us for a mere PITTANCE
In dirty raincoat
At one time the entire Tannock family (plus dog) were working for him so the circa £30,000 a month the EU paid will be much missed.

Small wonder he whines to anyone who will listen that Brexit is bad for business-he must be talking about his 'family business.' 

Anyway, Charlie refuses to attend any of the Dame's political gatherings just because she tipped off the Sunday Times about his massive shrinking FRACKING OPTION DEAL

You seem in such a state maybe it's a case of 'Shrink, heal thyself'.

Saturday, 24 November 2018


If you live in or near Kensington Square....beware.

The developers behind the demolition of Heythrop College are back with a plan supported by an odd little lobbying company, Cratus, run by ex-leader Sir Merrick Pooter-Cockell and his little chum, 'lil Bob Neill, MP. 
Interestingly, the funders of this development come from Jo'burg where the Pooter-Cockell clan hail from!
Pooter, 'lil Bob and Johnny Sandelson(also behind Thamesbrook) have had many hours of pre-planning advice from Mr. Stallwood's team so why do residents get a miserly 6 minutes.
So much for the Council 'listening to residents'. There is no law that states 6 minutes as the optimum. 
A through demolition of this dreadful plan needs, de minimus, 20 minutes.



It's time controversial applications were not sneaked in during holiday periods.....especially when Mr. Stallwood's planning team are recommending it-as in this case.

Laduree has applied for permission to intensify its restaurant operation with the creation of a new restaurant with 90 covers and hours extending close to midnight.
If granted noisy customers will pour on to the streets late at night creating even more noise pollution for residents. See the application HERE
How Harrods ever were able to buy the expanse of payment forming the public highway is a mystery. Did massive amounts of money change hands? Obviously.
Residents already endure the noise and nuisance from Harry's Bar and this expansion just exacerbates the problems.

There already over 10 objections so why on earth are planning officers running roughshod over the wishes of residents by recommending it? 
Have they been offered free pastries?

Town and Country Planning Act 1990 (as amended) Variation of conditions Nos. 3 (Limit on Hours), 4 (Number of Covers), 5 (Management Plan), 8 (Tables and Chairs) of planning permission PP/18/00907 (Change of use of internal area of Laduree Restaurant to create Restaurant B, an independent restaurant accommodating up to 90 covers at one time and providing an evening dinner service with extended hours of operation - until 23.30pm daily) for extension of morning opening hours from 7.00am. Harrods, 87-135 Brompton Road, LONDON,
The meeting will start at 6.30pm on 4th December
Committee Room 1, at the Town Hall in Hornton Street
LONDON, W8 7NX. The recommendation is to grant consent

Everybody should go and a speaker setting
out residents' objections appointed.

Friday, 23 November 2018


Last night, His Excellency, Koji Tsuruoka, the Japanese ambassador to the UK, welcomed guests to an important occasion marking an award to one of the Royal Borough's longest-serving and most popular councillors.

The award, The Foreign Minister's Commendation, was given to Cllr Robert Freeman for his outstanding support and advice in the development of Japan House in High Street Kensington.

Had Freeman not grasped the nettle we could easily have seen Westminster take this prized building.

Tsuruoka made an interesting observation saying the mark of an adept politician is the ability to achieve an objective without a lot of fuss. 
In that aside he summed up Robert Freeman. 
We must not forget the role played by Victoria Borwick in working with the Embassy.

Tuesday, 20 November 2018


Buddy and business partner of the horrendous, Sir 'Phil' Green, Richard Caring, become a billionaire by not caring much about others. 
His Caprice Holdings owns Harry's Dolce Vita in Basil St and has been a thorn in the flesh of residents since he opened the bar. Worse, certain council officers have been blatantly complicit in allowing him to get away with breaking every rule in the planning and licensing book. 
Free storage on our pavements!
Fatty Green and Caring

The Dame's planning expert explains Caring clever ploy and says residents need  to urgently OBJECT and get their friends and neighbours to do likewise....

Originally there were just 20 small tables to seat diners were tables so a total of 40 seats  
Now, they want to swop the 20 small tables to 12 large tables
INCREASING seating by more!.....Very devious.

Caring Takeover
with plastic sheeting saying 'I own the pavement'!
Caring is trying this on because he has a problem with his large tables which breach planning consent by extending beyond the 1.6 meters allowed. 
This means there is no footway left for mothers with prams or the disabled with wheelchairs or even pedestrians and after 5.00 pm and on busy weekends pedestrians and others have to battle their way through a forest of bags.
His street furniture!

So, it's urgent that we click here and OBJECT  by demanding the Council agree: 

  • only 12 tables provided  they are small and seat a maximum of per table to ensure no extension beyond 1.6 meters so as not to encroach on the footpath
  • Agree to 1 only Waiting Station. Dirty flatware and crockery with food leftovers in the open is unhygienic and unhealthy and attracts pigeons aka 'flying rats' as well as presenting a very unsightly, unattractive streetscape
  • Permanently remove the plastic sheets hanging from the ceiling. They are in breach and ruin the streetscape in a Conservation Area
  • Remove all blankets strewn all over tables and chairs which add to the risk of passers-by tripping over them
  • Remove ALL tables and chairs after closing and store with the restaurant...currently, they litter the street; risk injury to passers-by and ruin the appearance of an elegant and historic area.