Planning Applicaion Reference: 14/01377/FUL – Site Comprising Old Telephone Exchange and Masonic Lodge, Elmsleigh Road, Staines

November 2014

Staines Town Society objects to this application as a gross overdevelopment.

Housing, hotel, mixed retail/commercial, and Masonic Lodge re-provision are all acceptable uses for this site in principle, though we wonder if demand for hotel rooms and retail or office space is sufficient.

However, the proposed scheme is vastly too large, three times as high as neighbouring buildings, and completely out of character with this modest riverside town. An enormous phallic symbol sticking up out of the town, unrelated to its surroundings, within 1.1m of the aircraft safety height limit, is contrary to Local Plan policy objective 11, that new development should be appropriate to its setting and contribute to an improvement in the appearance of the environment.

It breaches Policy EN1 a), that new developments should respect and make a positive contribution to the street scene and the character of the area in which they are situated, paying due regard to the scale, height, proportions, building lines, layout, materials and other characteristics of adjoining buildings and land; and EN1 b), that new developments should achieve a satisfactory relationship to adjoining properties avoiding significant harmful impact in terms of . . . overbearing effect due to bulk and proximity or outlook.

Policy EN9 states that in considering development proposals the Council will at para b) seek to protect and enhance existing views of the river Thames and its tributaries, and at para c) pay special attention to the design of development located in riverside settings to ensure that it respects and makes a positive contribution to the setting of the rivers. This policy lays a duty on the Council to refuse the application.

The proposal includes 92 x 2-bed flats, defined in paragraph 9.12 of the Local Plan as family housing. Policy CO3 states that in new housing developments of 30 or more family dwellings the Council will require a minimum of 0.1 ha of open space to provide for a children’s play area. Such provision is to be increased proportionally according to the size of the scheme. A development of 92 family dwellings thus requires 0.3 ha of open space. This whole site is only 0.3 ha and there is no open space for a children’s play area.

Policy HO5 at para d) states that development in Staines town centre should generally be of a density at or above 75 dwellings/ha. This development of 140 flats on 0.3 ha is a density of 467 dwellings/ha; and if the hotel part of the site is excluded, then it is 140 flats on 0.2 ha is a density of 700 dwellings/ha. Policy HO5 cannot be stretched that far. Nor does the last paragraph of HO5 apply, as this development does not comply with Policy EN1.

Some of the 1-bed flats are only 46.4 sq. m. in floor area, which is below the SBC agreed minimum of 50 sq. m. stated in Appendix 4 of the SPD Design of Residential Extensions and New Residential development. Most of the 1-bed flats are barely over 50 sq. m., and most of the 2-bed flats are barely over the 2-bed minimum standard of 70 sq. m.

These tiny flats, which would be shoehorned into an inadequate site, with no open space, almost no landscaping, and views of the backyards of other town centre premises, will be substandard housing and a poor environment for our residents and their children.

A much smaller development, of say 5 floors to respect the scale of Thames Street, would be in scale with its surroundings and would not require the installation of lifts. The provision of lifts would increase the service charge per flat by at least £2K p.a. and therefore price the flats beyond many people’s reach. Most of the blocks of flats along Thameside do not have lifts, for this reason.

The Preliminary Ecological Appraisal of the site states that there are 7 substantial mature Sycamore trees, which contribute significantly to greening the town centre. Too many trees have been lost in Staines centre in recent years, and we object to the removal of these ones. The proposed landscaping is a mere token of some small silver birches in the courtyard and a plant trellis beside the service ramp, contrary to Policy EN1 d) which states that proposals for new development should demonstrate that they will incorporate landscaping to enhance the setting of the development, including the retention of any trees of amenity value . . and provide for suitable boundary treatment.

The same impressive Preliminary Ecological Appraisal recommends that further survey work be undertaken in regard to the bat population, bats being fully protected Conservation of Habitat and Species (Amendment) Regulations 2012. This means it is illegal to intentionally or deliberately kill, injure, disturb or capture these species or damage, destroy or obstruct access to any structure, breeding or resting place used by them. Bats are considered to be of regional conservation importance. It was recommended that the survey should take place prior to construction between May and September. The Planning Application as far as we can see, makes no commitment for this to take place.

Providing no parking for a development of 140 flats and a large hotel is unrealistic. The plan assumes that the residents will use the Tothill car park, for a fee (it is mentioned as income generation for SBC), further increasing their living costs. But the reason that the Tothill car park is often not full is that people don’t like it. Instead they will attempt to park in the already full residential roads nearby, causing mayhem until the residents ask for a CPZ.

We also note from a comment by the Developers in their Design and Access document 4, that there have clearly been serious discussion with the Council about a potential phase two development on the adjacent site involving the removal of the Tothill Carpark, the relocation of the Library and the building of a number of high rise blocks possibly more flats and offices as well as further retail units. If that is the case, where will flat owners and hotel guest park then? Surely the Planning Committee should have knowledge of the proposed phase two and take it into account in considering this planning application. The construction of such a high-rise hotel and accommodation blocks could set precedence for the future for this area.

The site is encircled by the entrance and exit of the multi-storey car park. The Transport Report’s possibly conservative estimate is that the development will add about 115 vehicles per hour in peak periods to the already busy Thames Street. This is judged to be ‘not a material impact’, by people who don’t live here and don’t have to breathe the air. Staines Town centre already suffers from traffic congestion and significantly poor air quality, which should not be made worse. Strategic objective 3 in the Local Plan is to secure an improvement in the Borough’s air quality.

Provision of only 3 disabled parking spaces is inadequate, and they are all too far from the affordable housing block entrance. It is not clear how many flats and how many hotel rooms will be fully wheelchair accessible. However we commend the intention to build flats to Lifetime standards, and the provision of two platform lifts up to the plinth.

The elevation details are restrained but interesting, and would be acceptable on a much smaller building. Steel-edged glass balconies like these are preferable to the wire mesh ones seen in other applications.

We are not against the development of this central site, but it has to be appropriate and in keeping with the environment and buildings remaining in the area and of course the river.