Planning application no 15/01718/FUL and LBC – Bridge Street car park
Staines Town Society strongly objects to these proposals as gross over-development.
1. The buildings are much too high. The height and bulk are out of scale with their neighbours in the Conservation Area and with the town as a whole, contrary to Local Plan Policy EN1 clauses a) and c) on design of new development, and EN6 c) on Conservation Areas. They are entirely out of character with this modest riverside town. Anyone coming along Clarence Street or entering Spelthorne by Staines Bridge will be appalled at the sight of a concrete tower block looming at the end of the bridge. Residents of the Hythe will have it in their faces all the time, and the adverse impact on the Hythe Conservation Area is admitted in para 4.03 of the Heritage Statement. The view from the bridge of St Mary’s church tower and the historic and decorative brewery tower, which was specifically protected when the car park was built, will be blocked; the Planning Statement admits this but claims it is outweighed by other benefits to the Conservation Area. We cannot think of any such benefits.
Permission was given in 2009 for a scheme of 143 flats, itself overlarge. We appreciate that it would be hard to sustain an objection to a new scheme of 143 units, but urge the Planning Committee to refuse the extension to 205 units. Removing the extra 62 units could be done by taking 6 floors off the tower and one intermediate floor from each of the other blocks. The result would still be too large, but not so monstrously out of scale, and residents would be spared the truly awful eyesore currently proposed.
2. The buildings are too close together. They are crammed in so close that the flats overlook each other. To comply with requirements on overlooking, it is proposed that some windows will have obscure glass and others will have projecting side panels to restrict the occupants view out and prevent them looking into other people’s balconies. (Design & Access statement, p 56). If the buildings were at a civilised separation it would not be necessary to blinker the occupiers.
The closeness and height of the buildings also makes the central courtyard and the passages leading to it dank and dreary, receiving little sunlight. Apart from one flowerbed in the centre of the courtyard, all the planting in these areas is of shade-tolerant species like ferns and grasses, not flowers: necessary, no doubt, but glum. Even the curious rectangular troughs on the public route through the site will contain herbs, grasses and shrubs, not cheerful flowers, according to the landscaping plan.
3. The accommodation is of a poor standard, with most of the units barely over the minimum size requirements, and a significant number below them. The Planning Statement claims that they all have balconies, but this is not true. The 23 ‘studios’ are in fact substandard 1-bedroom flats, all under the standard 50 sq.m., 13 of them under 40 sq.m., the smallest being 38.4 sq.m. They are awkwardly shaped, with little natural light, and none of them have balconies. The 49 1-bedroom flats are mostly just over 50 sq.m., but 33 of the 100 2-bedroom flats are below the standard of 70 sq.m., the smallest being only 66.4 sq.m. The developer’s claim that these flats are for only 3 people is irrelevant as there is no way to know who will buy them. Some units seem to be larger, but turn out to be duplexes, on 2 floors with an internal staircase taking up space, apparently to save providing access to alternate floors in block C2. Only the two largest penthouses have separate kitchens; the other 203 units have kitchen units at the side of the living room.
Only 23 of the flats are ‘adaptable’, but not adapted, for wheelchair users. The other 182 are not adaptable, probably because they are too small.
Service charges are going to be high (Planning Statement para 5.33) despite the poor quality of the accommodation.
4. This proposal does nothing to meet Spelthorne’s housing need. The Design & Access statement says explicitly that it is targeted at young professionals looking to relocate out of London. There is no affordable housing whatsoever, contrary to Policy HO3 of the Local Plan.
5. The proposed materials are disappointing. Pre-cast concrete panels made to imitate Portland Stone are a poor choice for a ‘high-quality’ building.
6. National Planning Policy Guidance (PPG) section 7, on flood risk, says that residential development should not be permitted in flood zone 3b.
Spelthorne Local Plan Policy LO1 forbids any development in flood zone 3b, and forbids residential development in flood zone 3a as well.
This site is in flood zone 3b, apart from the northern edge at Bridge Close, which is 3a. It was extensively flooded in 2014, so the flood risk is better known than in 2009. It should not be developed.
The plans propose arrangements to evacuate the car park, and to store and pump excess water, and claim that the basement CHP boiler and the electrical works will be protected from flood. Disabled residents will be stranded when the car park floods. These are all consequences of building on an unsuitable site.
7. The plans show 133 units with 2 or more bedrooms, defined in para 9.12 of the Local Plan as family housing. The Design & Access statement claims that this is not family housing, but the Planning Statement says in paras 3.20 and 5.26 that the 2 and 3 bed units are suitable for smaller and larger families. This is obviously true: those units designated for 3, 4, 5 or 6 will not be occupied by unrelated groups. Even young London professionals have the normal reproductive urges. There will be many children living here.
There is no public space at all designated as children’s play areas, far less the 0.4 ha required by Local Plan Policy CO3. A park at the Lammas, reached by an unprotected riverside path, is not an acceptable substitute for proper safe play areas on site. This is a blatant disregard of Local Plan policy, and of the needs of children.
The provision of open space on the site is wretchedly deficient, about one fifth of the standard set in SBC planning document on design of new development. The public space is essentially the route through the site, to which residents may add the small dark communal garden.
8. SBC Parking Standards require 313 car spaces for this number and mix of units, but only 134 will be provided. The over-spill parking from the development will cause widespread nuisance. If the development is included in the Conservation Area residents’ parking zone then the benefits of the zone will be wiped out. If not, up to 150 cars belonging to residents of the development, plus all those who used to use the Bridge Street car park, will be fighting for space and displacing other residents over a wide area. We may wish that occupiers of town centre properties would not have cars, but in reality they will, and permitting such a parking shortfall is simply irresponsible. It wouldn’t be so bad if there was a nearby car park, but of course you are removing that!
9. The proposal is in breach of the Equalities Act and of Local Plan Policy EN1 c). There is no adequate access for disabled visitors, or for disabled residents without parking spaces. There is no visitor access to the car park, which has a barrier, and no parking nearby. Even if the person with mobility problems manages to reach the site, (s)he faces a long walk to access the desired unit while avoiding steps. Access from the river path is impossible.
The disabled parking in the existing car park will not be re-provided, so in future there will be no facilities for people with physical disabilities to access the development or anywhere else at this end of the town.
10. The scheme is so cramped that it has no room for delivery vans. They may use a lay-by in Bridge Close, but those delivering to the front of the site, and the bin lorry collecting from the tower, will have to park on the Bridge Street pavement directly in front of the restaurant tables, adding more noise and pollution to the ambience for customers.
11. Noise levels around the site are too high. Occupants of the lower flats facing Bridge Street will be worst affected, with noise levels of 63 dB by day and 59 dB at night, significantly higher than the approved standard (BS8233) of 35 dB by day and 30 dB at night. Even if noise insulation of the building is improved, residents will suffer if they open windows or sit on their balconies.
12. The Air Quality Assessment admits (5.9) that levels of NO2 at the site are above the annual recommended limit.
13. An Environment Agency engineer has explained that only a third of the water in the Thames (and other rivers) is visible. The rest flows through the ground below and to either side of the visible channel. Is it wise to build a 12 storey tower on such an uncertain foundation?
We ask you to consider also the following points:-
a) There are no seats anywhere in the plans. Proper seats with backs should be provided rather than expecting people to sit on cold hard concrete retaining walls.
b) The surface of the riverside path is to be changed from tarmac to gravel, and the new western path is also to be gravel. This is a retrograde step. Tarmac or paving are much better safer surfaces than gravel for walking or cycling. Gravel is less steady to walk on: children and older people are more likely to fall, and will then get gravel in the wounds. Gravel gets muddy in rain, and washes away in flood. The theory that gravel slows cyclists is erroneous, as gravel loose enough to impede cyclists would be much too hazardous for walkers. The western path may not be much used, as it doesn’t seem to go anywhere useful, but the riverside path is well used and should not be spoiled.
We hope the Environment Agency will not agree to strip the river bank bare of vegetation and reduce it to a plain grass slope.
Incidentally, the idea that there is a desire line through the site from Bridge Street to the ‘emerging riverside quarter’ is somewhat fanciful – if there is a riverside quarter it is downstream from here and has many more direct links to the town centre – but harmless. The surface of this diagonal passage is stated as ‘Yorkstone’. We hope this means York stone and not some imitation.
c) The tree near the tower and the gym is described as a mature Dawn Redwood. A mature Dawn Redwood is 50 m tall, higher than the tower. It is a very large conifer with a pyramidal shape, like a Christmas tree, 8 m wide at the base, filling and shadowing all that lawn. It can grow to 35 m in 30 years, so even if a spindly young tree is planted it may soon outgrow its surroundings. It is not in the least like the poplar-type tree in the illustrations, and is entirely unsuitable for a cramped urban development. We suggest that a suitable native British tree be planted instead.
Thank you for taking the time to read our submission.
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