Tolworth Tower Development 2019 Application

Dec 18 – Proposed changes to the Tolworth Tower office block 18/16764


Comments on Application No 18/16764 – Proposed changes to the Tolworth Tower office block into mixed use mainly residential.

Comments made by RJ Ware on behalf of the executive members of the above Residents Association.

A] General Comments on Application

  1. We do not feel we are able to make meaningful appraisals on the proposals due to the manner in which the information has been presented in that only the existing Tower proposals have been made known.
  • According to our information there is to follow 2No additional tower blocks one 19 and the other 12 storeys high accommodating 242No flats and to make sure no space goes to waste the construction of a box? to provide space for a further 26No flats totalling 508No housing units. We have no idea where all these buildings are to be accommodated on such a limited site but we must not forget the 78No flats already there and finished under a previous permitted development, as Barton Willmot have conveniently done in their density calculation, which ups the total to a staggering 586 units.
  • We make the whole area of the site area, as the red outline plan presented to the DCC meeting of the 12th Jan ‘2016 for the CNM scheme, somewhere between 1.4 and 1.5 hectare. Applying the 1.5 hectare area makes the density some 391u/h or to put it in context it would make the Meyer Homes development look like a bit of a wilderness. This is Tolworth not Manhattan
  • We think Meadows better stop thinking about what was previously permitted on the basis it was never actually built but no doubt achieved its objective of substantially increasing the sites market value without doing any of the risky stuff like building it out. If the housing density limit has now been raised from 170u/h to 240u/h using as a guide the whole site area to be 1.5 hectare this would result in an additional 60 flat units that could be built before exceeding the 240 limit.  The proposals are for an additional 268 flat units
  • There is now something of a convention in the area of no high rise that is anything over 10 storeys. That was applied to Meyer Homes. Unfortunately as the Kingston Planning Officer and the Developer agreed to overstate the area by 20%, to reduce the excessive density figure, the 950 number of housing units could not actually be accommodated on the site in 10 storeys and less height blocks without not only being a design disaster but also with very severe breaches of the standards set out in Kingston’s SPD’s and the LP’s SPG’s. The resolution of this is still ongoing.
  • If we give the impression the locals are getting restless then that is exactly correct. The TAP was not passed on the basis that over the next 10 years housing stock in the area of Tolworth is predicted to rise by over 25%. As almost 50% of the area is either green belt or MOL, both of which are currently sacrosanct, the impact on the area remaining will be overwhelming and though the plans for intensification of housing is well underway absolutely no planning has been done on the infrastructure side to cope with it. With the parlous state of Government and LA finances we have every right to think it will end up a case of put up and shut up. We are not prepared to accept that.
  • We will pass comments on the Tower proposals but we strongly feel this should not be consented without a proper assessment and appraisal for the re-introduction of a provision for an  appropriate amount of office employment somewhere on the site.
  • It goes without saying that if our information on the balance of the works is as stated in Item 2 above we will object most rigorously to that part of the works.
  • It would have been nice if the North wing had been re clad in the same cladding as that proposed for the main tower.

B] Flats in North Wing

  1. These are referred to but we have no details. The information to Application 14/16878 has been removed from the Planning Portal.
  • We assume that for any density calculations these housing units will be included. We state this as the Planning Statement prepared by Barton Willmore LLP in working out the housing density for the 0.86 hectare area of the site has not included these. We would ask why? They are on the site, they are in the 0.86 area and their parking provision(see item 5 below) has been added to that for the tower significantly enhancing the parking per unit figure for this section of the works.
  • Could you confirm the red outline plan on page 8 of the Barton Willmore document designates the 0.86 hectare site area and the extent of the Tolworth Tower part of the works. We don’t want any disputes on red line areas again do we?
  • Could you advise where the amenity space for the 78 North Wing housing units is located?
  • Can you confirm that some of the 54 car parking spaces specifically allocated to service this wing, granted by a previous planning consent, can actually be subsequently switched to the main Tower tenants without tenants living in this wing objecting otherwise it will leave parking spaces short for the tenants of the main Tower.

C] Car Parking

  1. Developers usual modus operandi on this aspect is to initially try to achieve as higher housing density as possible and then work backwards to see what this leaves for on-site parking. Meadows through their transport consultant Velocity have not failed to disappoint by adopting exactly this approach.Therefore nothing to do with properly assessed realistic need levels but what can be fitted in without restricting maximum housing potential. Thus the priority is housing numbers and the stress, strain, aggravation and annoyance of residents in the surrounding communities, who’s roads are stacked out with nose to tail car parking by people who do not live in the road, who will have to put up with the consequences and possibly bear the cost of a CPZ to try to control it.
  1. We keep quoting the following which is very relevant but appears to be generally ignored particularly by TfL and developers as it does not suit their cause:- An update to the National Planning Policy Framework was announced by the Department for Communities and Local Government in March 2015.  The announcement focused on the need to ensure that adequate parking provision is provided within a development site.  The announcement noted that the: “imposition of maximum parking standards under the last administration lead to blocked and congested streets and pavement parking. Arbitrarily restricting new off-street parking spaces does not reduce car use, it just leads to parking misery. It is for this reason that the government abolished national maximum parking standards in 2011.” This is a comment from National level and the Secretary of State and thus outranks the London Plan
  • From Barton Willmore Planning Statement
    • Table 3: Appropriate(more like inappropriate) Parking Ratios
Unit Type No of Units Proposed Parking Rate Total Spaces
Studio / One Bedroom   162 0.06 10
Two-Bedroom 62 0.26 16
Three-bedroom 16 0.70 11
Totals 240 0.15 37
  • Six hundreds of a car for each one bedroom flat. How stupid is that
  • Table 4 : Surprise surprise 0.38 same as for the Meyer Homes development
Unit Type No of Units Proposed Parking Rate Total Spaces
Studio   63 0.2 13
 One Bedroom 99 0.3 30  
Two-Bedroom 62 0.5 31
Three-bedroom 16 1.0 16
Totals 240 0.38 90
  • It is inferred Table 4 “parking rates” were suggested by the Councils Traffic Officer. Poor chap gets blamed for a lot but to be quite honest he only says what he is told to say. Another case of start of with the answer you want, 0.38, and then fiddle with the “Parking Rates” on a spreadsheet until that figure is achieved.
  • 0.38 same as Meyer Homes but that site was capped. For 705 housing development 356 on-site parking provision(0.47 parking rate). For 950 development still only 356 on-site parking provision(0.37 parking rate).
  • 240 x .38 =  90  parking spaces see above Table 4

      78              54  parking spaces donated from North Wing 78No flats

    318             144 = 0.45 average parking space per flat

  • For the previous CNM scheme for Tolworth Tower parking levels 0.79 spaces per flat consented Jan 2016. So in under 3 years the parking provision has been reduced by almost 43% based on 0.45 parking rate. Of course this is exactly in line with the traffic reductions in Tolworth all the local residents have noticed over the same period ???
  • With the risk of being called cynical we feel the severe reduction in the “parking rate” may have something to do with the fact that annual housing targets for Kingston have drastically risen from 643 in 2015 to 1,364 in 2017.
  • The recent “Transport Statistics Great Britain report” for 2017 states there are more cars covering more miles than ever on our roads. So the lifestyle and behavioural change needed to reduce car use has not yet kicked in with the general public. Thus TfL arbitrary encouragement to restrict on-site parking is not working particularly in Tolworth which has two main artery routes, meeting at the Tolworth interchange, allowing traffic to access from adjoining District and County Council areas, which the Mayor has little control over. The fact that confidence in public transport service is at an all time low whilst fares are at an all time high does not help either.
  • We feel the arrival of CrossRail 2 at Tolworth station will be severely delayed by the recent information coming out about CrossRail 1, late and over budget. Bad news of much the same ilk on HS2 with the final nails in the coffin being Brexit and the much predicted global economic slowdown. It’s arrival at Tolworth is still expected in the forties its which century that proving the problem.
  • The current London Plan advises a maximum of 0.75 spaces per housing unit.  There must be several hundred flats, mainly one and two bedroom units, along the Kingston and Ewell Roads both sides of the Tolworth interchange. These provide an ideal opportunity to do an actual current survey of car ownership and use for these flat owners/renters of people who live in the Tolworth areas. This is much overdue as the usual survey used is dated 2011 which will be 10 years out of date by the time this development is up and running. This will give a better reflective of the Tolworth area car use and this is especially needed in the light of the large scale developments currently proposed together with some additional 300-350 flats planned for the future down the Broadway as part of TAP. Let use science and facts to establish actual need. We are no longer prepared to accept so called experts using spin and tricks of the trade such as travel plans, modal shifts and computer models etc etc to justify totally inadequate and unachievable levels of on-site parking levels when we know all they are doing is working to the set agenda dictated by their paymasters of keeping parking provision down. If the survey is not done we would want actual successful working examples to be presented with site visit checks for developments of similar size and matching PTAL
  • We are not great believers in travel plans despite them being a LP requirement. They may have been formulated with good intentions but with little monitoring or meaningful enforcement and a limited shelf life we consider they are just a sop and an excuse in trying to justify an unjustifiably low level of on site parking provision.
  • Are charges to be applied for a car parking bay? If so how much?
  • The applicant himself may be able to reduce car numbers and reduce overspill into on-street parking by making a commitment to really incentivising tenants by offering discounted rents for those who genuinely do not own or use a car. Now that would make a real difference.
  • What is the “limited waiting parking” for notated for parts of the 1st and 2nd floor on-site parking.

D]  Family Housing

  1. Provision of 6.7% for family housing is greatly under the 30% normally required by Kingston for a project of this size. We do not know whether this is still a requirement but there is no constructional reason we can see why this cannot be achieved.
  • The objective of the development should be to provide housing which is sustainable and meets the needs of the local community. If this involves 30% 3 bed flats then so be it. This should take precedence over developer’s financial considerations.
  • Do not forget they already have 78No one and two bedroom flats located in the north wing.

E] Change of Use

  1. A considerable loss of office space but perhaps not such a large loss of office employment as it has only been partially occupied for many years. We concede that an office block of this size and capacity is no longer sustainable in Tolworth. On a personal view the writer would like the whole complex demolished allowing a new start to be made with a mixed use development tailored to meet modern living requirements. Had it been nearer to London then this is probably what would have happened. But it’s Tolworth and whilst the Tower remains it leaves the area exposed to further inappropriate tower block development which we trust our planners will resist. One mid sixties office block should not be used as an excuse to populate the area with more high rise residential tower blocks but look upon it for what it is a pragmatic one off conversion to make best use an underutilised asset.
  • However as it now looks like the site is to be predominately residential we feel there is still very much a need for an appropriate and agreed level of office accommodation to provide local employment within this development.
  • We concede the “Office Viability Report” makes a sound case for the Tower use having known for some time the structural floor heights do not sit well with modern office servicing requirements. If the existing tower is not an attractive option for any prospective business tenants then we feel it is pointless to prolong any further the underutilisation of this building.
  • We would suggest to compensate the construction of new modern separate office block of a size to suit current business needs and market requirements to be incorporated within the yet to be defined area of the development. We feel the marketing of an appropriately size new purpose built office would be far more successful than one almost 60years old. We would thus like to see the applicant and the Council come to an agreement to market test the interest in a suitably sized new office block which could be stand alone or mixed office, residential and retail. An Article 4 notice was applied to the tower by Kingston Council so they must have felt there was a place for office accommodation in Tolworth and this would help meet the stated aims and aspirations of the “Tolworth Area Plan” for a mixed use environment.

F] Amenity Space

  1. Extent needs checking for compliance and we would like an explanation of the following abstracts from the Barton Willmore Planning Statement:-
  • Item 7.224 The proposed development provides 2,568 sq.m of dedicated residential amenity space –(how is this built up?) which is in excess of the communal amenity space required by Policy Guidance 19 which is 2,526 sq.m – (how is this built up?) which includes the areas of shortfall from the private amenity space.
  • Are the gym and workspace facilities to be charged for tenants use? If so can these be deemed part of the amenity space?
  • Is the 22nd  floor perimeter balcony areas included in any amenity space?
  • Have any sunlight level been established for the amenity space particularly the areas to the east of the North Wing

G] Overlooking/Privacy Issues

  1. Are there any privacy measures to be put in place where amenity space is located directly outside tenant’s flats and hotel room windows?
  2. Are there any overlooking/privacy issues between the main and north tower accommodation units.?

H] Traffic Impact

  1. A VISSIM traffic model has been done and it includes the following local developments :-
    1. Lidl
    1. 950 Meyer Homes
    1. Premier Inn
    1. Tolworth Tower
  2. The summary was that TfL advised they had devised a cunning plan that would allegedly   enable the Tolworth Interchange to cater for the additional traffic generated by these developments. These changes would only increase capacity to the extent that the additional traffic generated would be accommodated at the current levels, that is congestion and tailbacks would be no worse.
  • Thus the statement that the change of the tower from office to residential would reduce the daily car trips in the area by over a thousand is wrong and irrelevant and it was a pointless exercise in modelling it on a fully occupied Tolworth Tower which has not been the case for years. The Vissim model is based on a fully occupied CNM proposal which means that this revised scheme needs checking with TfL to ensure it does not adversely affect their modelling. The Tolworth interchange is virtually at 100% capacity and the line between excessive tailbacks and total grid lock is a fine one.

I] Housing Density

  1.  We refer you to the following drawings:-
  2. Red outline plan from Planning Officers report for application 18/16764 dated 12/01/2016.
  3. Barton Willmore report red outline plan
  4. Landscape Report Part 1 red outline plan
  5. Ditto Part 5 ditto
  6. Drwgs (20) – 0001 to 0005 all showing red outline plans
  • What red line boundaries are relevant?
  • An abstract from Barton Willmot :-Item 7.197 There are two different density calculations that can be used based on paragraphs 1.13.14 and 1.3.47 of the Mayor or London’s Housing SPD. The first method requires the calculation of dividing the number of units by the Site area (0.86 ha) which results in 279 u/ha.
  • But the 0.86 area also includes the 78No one and two bedroom flats as Application – 14/16878. Add these into the equation and the density becomes 370u/ha
  • Barton Willmore 7.201 –  Draft London Plan 2018 Policy D6 seeks to replace the adopted SRQ density matrix of 70-170 u/h with a PTAL density based approach. It sets a density range of 240 u/h(a density range of one figure???) in areas of PTAL 2 to 3. So the new density range level of 240u/h is with us and already 16.25% above this based on 279u/h which ignors the north wing flats  but on the 370u/h with them in it is over 54% up.

I] Affordable Housing Subsidy

  1. It appears a 10% of Discounted Market Rents (DMR) is being offered for the flats located on the 3rd and 4th floor of the development, which is 10% of the total number of flats, for key workers.
  • Kingston requirement would for affordable homes is 50%
  • A degree of segregation as social tenants would all be located on the bottom two floors.
  • Rents tend to rise as you move up. Better light and views.
  • Our take on the “Financial Viability Assessments” is that it is a flawed process and usually it’s the developer who hold all the aces. They have control over all the cost information and how it’s presented. Councils do not have the expertise and the experts they call in to check the viability assessment are all in the same club as the experts who prepare the assessment. Don’t ruffle feathers as next time round the rolls might be reversed.   
  • Our only comment on the “Viability Assessment” is the financing cost. As Meadows are a fund manager we would assume the finance will already be in place from those who have invested in the BtR fund.

J]     Build for Rent

  1. This obviously does not provide the mixed tenure favoured by most Councils.
  • It would be helpful to know exactly the tenant demographic that Meadows are looking for.
  • Is flat maintenance included or just an option
  • 2 bedroom flats with two on suit toilets, rented workspace and gym facility would infer rental levels will be at the upper end of the market for Tolworth and targeted at the upwardly mobile. Is there a Kingston housing need for that?
  • Is this type of tenure helpful to the London housing needs?