We were a bit late in responding to the 2020 planning application unfortunately but in the spirit of better-late-than-never, and that WF will tell you that they will consider comments received even if late, we have submitted this letter.
We had responded to the original application back in 2017 (which is attached to our letter) and as this was approved, chose to only respond to the detailed elements that formed part of this new application; namely the changes to the public space and detailed information for the residential part of the proposals. (The original application was a hybrid one that sought only outline approval for this; we were not at all convinced about this approach given the scale of the proposals. )
So we suspect most notably we haven’t commented on the height, since this was effectively approved as part of the previous application. Clearly this is of significant concern to a lot of people, and we did have our own issues back in 2017. Fundamentally, it must be said, we tend not to object to height (although here it is very tall), providing it is justified for the location and the design is really good, but the very fact that it was an outline application meant that it could not be demonstrated. You will see from our letter that there are some fundamental attributes of the residential design that scream over-development and poor consideration, and maybe if the impact of the quantity of homes or floor space was properly understood earlier, then the proposals could be better and more sustainable.
We are very interested in the changing idea of what London’s suburban centres might be, which could not be seen more than in these proposals compared to the current low density, sprawling design of the shopping centre and open space that was conceived in the 1980’s. We remain frustrated at the lack of rigour that has been applied to the new more square-like square than the present ‘Town Square’, especially given the considerable loss of public space; owing to the lack of (at least any published) consideration of all sides of it, and the elephant-in-the-room building that contains the Natwest bank. We have asked persistently about this and have been told that it cannot be addressed as the bank has a long lease, but this seems extremely short sighted and lacking in vision.
For information and future reference, the applicant’s Design and Access Statement is here.
Homebase hadn’t really come up much before at our meetings until a couple of months ago. It turns out that quite a few of AE17 really quite like it, and visit regularly for paint, tools and miscelaneous garden assessories. We were collectively then quite sad to hear that the site had been sold, and our trips for DIY supplies and tools were going to take a bit longer, and probably a car ride rather than a walk to the sheds on the North Circular. Nevertheless, we could see how the site might be attractive for residential development, and we were keen to see what opportunities might be developed.
In our June 2020 meeting over Zoom we had a flick through the ‘consultation’ website and information available, keen of course to find out what might be planned for the site. To cut to the chase, our response we considered returning to the consultancy running the consultation and community engagement was “we think you’ve missed a few pages off”. There were some very informative pages concerning who was involved, what the planning policy context was, the usual references to William Morris, and a lot of stuff based on an observation that Forest Road links the Lea Valley and the less forest-y part of Epping Forest. We couldn’t help but find this somewhat of a stretched starting point, given the two green spaces, whilst they do indeed nicely define the urban limits of Walthamstow, are some 2 miles apart and don’t on the face of it have much to do with the site over any other location along the Forest Road. We could not help but think that this, and the lack of any further information about the built proposals that inevitably would have been developed quite far by June 2020 when a planning application was due in August, was therefore a rather thinly disguised ploy to hide the fact that that the proposals would be controversial. Consultation? (We could not help but be reminded of the consultation for the development of the Mall, which seemed to concentrate most of all on how the remains of the public space might be landscaped).
Sure enough a month later proposals were presented in an online event, and made available for public review, and these included some dense development and buildings across the site up to 20 storeys in height. It was not clear really how the comments that had been received from the initial consultation had impacted the design decisions of the proposals.
Anyway, we were up for reviewing what was presented and submit comments, and we submitted a response to the consultation that you can find here.
And now we await a formal planning application, which is not yet registered. There is this update, which shows a few changes; storeys lopped off here and there, and some additional information about landscapng design and wall art. The fundamental comments we had are not answered; and we eagerly await the planning application to be able to actually assess the architectural proposals.
A planning application has been made for redevelopment of the site at 19, Hoe Steet; the current location of a mothballed Texaco petrol station. (You might know this for it’s temporary use over recent years as a car wash).
We have submitted this response to the application.
The applicant’s Design and Access Statement can be found here.
The application is reference 201240 and can be seen in full and commented on at the LBWF website.
A comparative analysis of recently completed developments in Walthamstow
Written by Alastair Crocket & Philip Nicolas, members of AE17
During the summer of 2018, we became aware of two active construction sites close to one another at the northern end of Hoe Street. The sites are 48 Hoe Street, E17 4PG and 66-68 Hoe Street, returning to 2 Gaywood Road, E17 4QA. The brief for these sites were similar, however the more that we examined the two projects, the more contrasting they became. Both had the challenge of a corner plot, both involved commercial and residential use, both used brickwork with a massing that presented three storeys to Hoe Street and lower elevations on to the side streets. Through this short article, we shall appraise these two projects and consider the clearly contrasting outcomes.
We began our comparison with a review of the information that had been submitted to Waltham Forest to deliver the planning consent for the projects.
48 Hoe Street (163726) provided a concise 14 page Design / Access / Sustainability Statement for a commercial unit (Class A1) and 4no. flats of 3 x 1bed, 1 x 2bed (Class C3), alongside 13 drawings up to 1:100 scale. The document includes no visual material to describe the proposals beyond the two-dimensional elevational drawings that are duplicated from within the drawing set.
66-68 Hoe Street (160314) provided a detailed 67 page Design & Access Statement showing commercial unit/s and 7no. residential units of 2 x 1bed, 2 x 2bed, 3 x 3bed in fully coloured and material textured images alongside 16 drawings up to 1:50 scale. This was complimented with a flood risk assessment, daylight and sunlight assessment, air quality assessment and environmental statement.
The proposals varied on their retention against new build intentions.
The 48 Hoe Street site was smaller and was supposed to be an extension of an existing building with an extra storey and larger rear addition whilst the larger site at 66-68 Hoe St was a complete new-build. We understand that, due to some structural issues, the existing building at 48 was demolished and a completely new building was built with the proposed extension. This was going to be a more challenging project as you start with compromise from the outset.
The no. 48 Hoe St proposals stuck closely to the existing built footprint, taking cues from the neighbouring buildings.
The no. 66-68 Hoe Street proposals were more expressive, allowing a curve at the corner of the two streets.
Both schemes have similar contextual environments; a busy road to the front, two storey pitched roof neighbours along the terrace with ground floor commercial usage, a primary south easterly aspect and a more residential character to their side return streets. In terms of their response, the no. 48 development drops dramatically from three storeys to one on Hawthorne Road whilst the no. 66-68 project steps gradually in a similar manner to the neighbouring houses on Gaywood Road before turning in to a terrace house where it joins the existing.
Flat design and layout
Both have designed flats in compliance with the London Housing Design Guide, and claim to have LifeTime Homes compliance (since replaced by the Mayor of London’s Housing SPG standards), but the no. 66-68 development has gone beyond this including careful consideration of how spaces could be used by those with mobility issues. The no. 48 development provides no evidence to substantiate the claim. The layouts within the 48 project include lots of oddly shaped and proportioned rooms with a considerable footprint lost to circulation space. Kitchens have been positioned at the back of living spaces and will suffer from poor daylight to worksurfaces. The incomplete furniture layouts shown within the plans raise concerns that these rooms may not be easily furnished. All but one of the bedrooms open directly on to the street. Within no. 66-68, the layouts have a rigour and clear consideration of how the spaces are to be used with full and logical furniture positions shown. The majority of bedrooms are rectilinear and kitchens have glazing nearby. The challenges of the plot have also limited non-street facing bedrooms at no. 66-68, however they have cleverly included secondary side windows to ground floor windows to improve privacy.
Two of the flats within no. 48 have private amenity space annotated on plans, although it is difficult to see how this can be used when one is dominated by gas meter boxes and the other is access to a riser directly from the pavement. They claim to be providing 52.5sqm of communal amenity, however during our recent visit it appeared that only around half of the planned roof terrace was accessible and so we doubt this has been delivered as promised.
At 66-68, balcony spaces are generous and well planned as spill-out spaces from living areas. The generous rear garden can form excellent communal amenity, although it was not yet finished at the time of our visit.
The no. 48 approach to the street at ground level is a relatively modest commercial frontage. We are unclear if occupied, however the rolled down shutters do not provide an enlivening aspect to Hoe Street. 66-68 has excelled in addressing the street, with heavily glazed elevations including a clearly expensive curved glass corner. Now occupied by a popular and buzzy looking hair salon, it acts as as a real beacon amongst the existing retail offer.
The materials at no. 48 are somewhere between modest and shoddy. The brickwork is clearly a cheap product and the efforts to enliven it with the odd dark or light brick give it an uneasy patchwork. The pointing is poor and there are areas where it unexpectedly changes. The uPVC windows are cheap with chunky frames and heavy trickle vents which are disappointing to see in a prominent new build. The roofing tiles are an imitation slate, which are too shiny and smooth, particularly when paired unsympathetically with a thick grey concrete ridge tile. The parapet to the neighbour is odd, particularly as it doesn’t appear on the planning drawings at all. Use of leadwork to cover the brick is a novel approach to resolving the issue.
At no. 66-68, materials have been developed from the planning drawings and use a modern approach to brick cladding. This has allowed them to achieve the interesting and expressive facades of dark brown and white brickwork. Header bricks define the floor positions, and occasional stacked columns provide borders to chequerboard infill. The parapet is a slim metal edge to allow the feeling of a continuous brick volume. On the side return to the neighbour, standing seam cladding forms a sharp party wall. Bespoke metalwork forms juliette balconies. At ground level, hard-wearing steel defines the retail units and has been used to deal with the dirt and everyday challenges that occur at the bottom of buildings. The entire composition is unique and successfully dresses this corner plot, particularly on the curve.
Considering the windows within no. 48, the first impression is that they are proportionally too small for the scale of the building. Their position relative to the brickwork is not defined sufficiently, producing a flat dullness.
The windows at no. 66-68 have a satisfying depth, by that of a brick which gives the building a certain weight and implies that it is made of solid stuff. The glazing sizes are generously full height and you imagine that they contain well lit and ventilated spaces. Finished in anodized aluminium, these are built to last maintaining their finish. Practically, the inward opening windows allow the flat owner to clean from the inside.
We hope that you have enjoyed our comparison between these two projects, which we have used to demonstrate the spectrum of newly built accommodation in Walthamstow. We welcome the reader to draw their own conclusion on the relative successes of these projects, but note the correlation between the drawn and submitted application materials, and resulting built forms.
Our fifth Pecha Kucha event is happening this coming October! We have had some fantastic evenings for our previous events over the last few years and we are really looking forward to this again. We return to Wild Card on Ravenswood Industrial Estate on Thursday 17 October.
Walthamstow, what’s next?
After a year of the first London Borough of Culture, and as redevelopment of our environment continues apace, what does the future hold? As Brexit and the climate emergency loom, as the housing crisis continues to impact, how do we develop sustainably and imaginatively? Our esteemed guest speakers discuss….
LB Waltham Forest are asking for feedback on their 2019 consultation draft of a new Local Plan. We are looking at this ourselves, and suggest that anyone with an interest in developments in WF take a look and provide commentary. These strategic documents form the backbone for planning policy and how planning applications are dealt with for 15 years, so are significant.
AE17 was to a large extent born off the back of the approval of the Travelodge tower at Walthamstow Central almost six years ago. As architects and others working in the built environment, we naturally get excited about new things and well considered, rigorously designed buildings and infrastructure, and so it wasn’t so much the idea of a tall building at this location per se that got us down, it was just the mediocrity, the lack of vision and apparent disregard for the views of the local community in having it pushed through, seemingly as development for development sake. It was boring and uninspiring, and if you’re going to have a new focal point at a town centre and city nodal point, it is here more than any place that it should be trailblazing and setting the standard for the future development and regeneration it was touted to encourage.
We’ve posted previously our comments to the applicant after a discussion about the proposals in February 2017, and our response to the formal application in July. It is clear that there is similar discontent about the proposals in all parts of the community. This is not unusual with large development schemes, and as practicing professionals we are used to this, even like here where it can be established that there is decent scope for improvement on the existing condition. However what grates fundamentally is a loss of opportunity to achieve something really special, given a private investor who wants to spend money and the not over-stated need to provide housing and improved town centre facilities.
A number of concerns linger, and once again these are generally concerning due process rather than the detail. The idea of building at height here is not necessarily a problem, and good tall buildings going up both in central and outer London show that it can be acceptable if done well, and the implications carefully considered. Whilst not to everybody’s taste, Croydon is successfully delivering a cluster of tall buildings that has been thoroughly tested through urban capacity studies. Sutton, not too dissimilar to Walthamstow in terms of scale has devised its own Tall Building Strategy that is being carefully scrutinised through the Local Plan process as we speak. Brent has been through a similar process in Wembley. No need in Walthamstow. We just put them up and decide how they look afterwards.
We have fundamental issues about the idea of an outline application for the residential towers. Outline means just that. A concept without detail. The developers have submitted a “design code” but a development of this scale should undoubtedly include the most intricate level of detail for its impact to be properly discussed and understood. What cornerns us equally is that this is funadentally about delivering new housing. However the outline element is effectively a second phase that may never get delivered if it is fraught with viability issues associated with developing over a busy operational shopping centre, which itself sits over the Victoria line. So what are we left with? About a third of our public square eaten away by multi-national chain retailers?
We followed The Mall public consultation events, staged by the applicant’s skilled team. There did seem to be some genuine space for input into the design of the public space, but to questions about the legitimacy of such a loss of public space to retail use, and strategic proposal of residential high rise? Nothing. That the only thing stopping the towers going higher are technical servicing and structural practicalities, and that therefore there is no contextual analysis leading what the height and massing might be, and this determining the design? Nope.
Of course, this decision is already made by the time such consultation is carried out, and as far as these kind of consultation exercises is concerned, can only be merely tinkering at the edges. It was hard for us to tell what exactly was significantly changed as a result of the consultation; surface materials of the public space, design of the landscaping? Maybe, but this hardly makes this proper consultation with the community about how they think their urban environment might develop. Ask around and many are sympathetic with the need to increase housing supply, but not at the expense of a loss of what local residents understand as being important about the place they live in.
Sadly, it is the same apparent disregard for process when it comes to the council’s CABE run Design Review Panel. It was with some interest and hope that we were happy to see the council set this up, with CABE last year. It is a concept that we as individual professionals in the group have lots of experience in other boroughs and understand how effective they can be, both on panels and the other side of the table. A team of architects, landscape and urban designers, working most often on a pro-bono basis (although not CABE run panels), advise applicants from an independent perspective on behalf of the council, addressing general design, strategic moves, and probably most importantly, questioning developers briefs to their design team. When used most effectively the panel is an asset to a council, and often a planning department is not prepared to put a project to the planning committee until the review panel gives its approval, often after multiple reviews over months of design development.
At the Mall development the last DRP review took place in March 2017. The report clearly shows that they still have considerable misgivings about the design, but the planners seem to be content to accept minor to modest changes to proposals as a result of the process, and the applicant’s response to the panel. CABE review comments are carefully considered, and this report is seriously damning, make no mistake. It is not just asking for a few changes around the edges, it is suspect about major aspects of the design; they do not believe the design to be exemplorary and request a fresh start with more response to the existing context, have issues with loss of public space, over-devlopment, and nature of the outline application. It’s a back-to-the-drawing-board response, and no doubt sits frustratingly after three review panel sessions where their comments have not been taken seriously. In other boroughs a developer and his team would be sent away to think again before further design reviews.
With some fanfare and laudable if very broad objectives, Waltham Forest launched a “Design Charter” in 2016. Surely the method of enforcing this is via their own DRP? Here then, the set-up unfortunately seems to be a bit of sham. Some advice, where possible to integrate easily, has been taken on board, but the role of a DRP, on behalf of the council, should be able to fundamentally question very basic strategy, not comment on the choice of wallpaper, colour of paint, or twiddly bits on roofs. Sadly, this might be what WF think ‘architecture’ is.
And so we come to the planning committee meeting, where the poor planning committee, at the end of several years of discussion and negotiation between the applicant and team, and the planing and regeneration departments, are supposed to understand the full extent of the proposals sufficiently to agree to their planning officer’s recommendation to approve them. With public interest high, no doubt the hall will be busy, rightly, with very vocal aggrieved residents and voters. Whatever the decision made, here is the knife-edge summit of the process that works for no-one; input from the community is too late for the council to process, and too late for the applicant, who, having been guided by the council officers over years of development, and spent hundreds of thousands of pounds on consultants guided by their collaboration, might have it all turned on its head by the councillors whose very leaders direct their officers. What a mess.
It seems to be a numbers game only unfortunately; it’s about getting housing built, without any real masterplanning or the council, as representatives of their community, taking the upper hand directing private investment in strategic, joined-up, sustainable and contextual development. This week is about getting a decision made as far in advance of next year’s local elections as possible, and pleasing the developers the council are dancing with.
Towers could be ok, the whole of the Mall could be rebuilt with housing above to a modest 5/6 storeys with some accented height, the public space could be designed with properly considered perimeter buildings, even a design destination and something of local pride. It could be a public space integrated into the existing context, somewhere really ‘Walthamstow’, whilst still appreciating the need to intensify London’s outer centres and developed idea of what public spaces in these locations might be. At least there could have been something tall and beautiful that might make take your eye off the Travelodge.
Following our mid-June blog entry where we made you aware of the planning submission by Capital & Regional, representatives of AE17 met to consider a formal response to the plans.
The group support the fundamental concept of the redevelopment and strengthening of The Mall as a major retail destination in the Town Centre. In principle, the group support the redesign and improvement to the public realm around Town Square. Finally, in principle we also support the provision of high density new housing development (particularly affordable housing) in an accessible location close to major public transport nodes. However, AE17 has decided to register its objection to the application on a number of grounds.
The objection has been issued to London Borough of Waltham Forest today and a copy of the letter can be viewed here:
The long awaited planing application has finally been submitted to LB Waltham Forest. The detailed part of the application is for part demolition of The Mall, and its replacement and extension by an additional 8,769 sqm to be used for shops, food and drink and leisure, creation of 42 residential units up to a maximum height of 49 metres, redesign of Town Square, including new children’s play space, landscaping and lighting. A further element of the application in in outline. Permission is sought for up to 460 residential units within two “low” buildings and two “tall” buildings above the podium of The Ball. The tall buildings could rise up to 132.5m.
You may recall back in March, AE17 wrote to the developers Capital & Regional following the public consultation event, expressing its concerns over the form of the application (specifically an outline application for the residential towers) as well as providing some commentary regarding the design, layout and appearance of the proposals. As a reminder, our previous blog on the plans, which includes our letter to Capital & Regional, can be found here:
The group will now be considering a formal representation to the plans at its next meeting on 29th June. Our initial view is that we are disappointed that very little appears to have changed since the public consultation. In particular, Capital & Regional has not taken on board our suggestion that a full detailed application should have been submitted. In the meantime, to save you the pain of navigating WF’s website, the key documentation has been downloaded at the links below. Please be patient when downloading as the file sizes are substantial.