AE17 response to South Grove site application (ref. 2013/1252)

We have finally completed our response to the South Grove (Morrisons) application ( which is as below.

Re. ‘South Grove Site’ Ref. 2013/1252; Demolition of the existing buildings and comprehensive mixed-use redevelopment comprising a supermarket (Class A1), non-food retail units (Class A1), flexible floorspace for Classes A1/A2/A3/D1, and 248 residential units (Class C3); together with associated car and cycle parking, highway works, public realm, amenity space, landscaping, plant and servicing arrangement.

We are writing regarding the above proposals for the site at South Grove, Walthamstow. We have the following comments that we would like to be considered.

1 Principle of development

1.1  We agree the site is in need of redevelopment and offers a great opportunity to extend uses in the town centre, bring investment, and promote regeneration.

1.2  The NPPF has a presumption in favour of ‘sustainable’ development. We do not however, find this proposal to be a sustainable proposal; there are many aspects of the design that are poor and compromised.

1.3  At the request of LBWF the applicant presented the previous consultation scheme to a CABE Design Review Panel. The council should consider their comments carefully and not only assess the applicant’s response to the review but the quality of the changes that have been made. The council should ask that CABE review the application scheme.

1.4  We have some serious doubts as to the suitability of the supermarket use on this site. If the council are minded to approve the proposed retail use then there should be adequate evidence provided to show that this will not have a detrimental affect on the nearby High Street, existing shops and the market.

1.5  The Town Centre AAP suggests for the site 90 to 250 residential units and that it should be ‘retail led’. It is unclear how this upper residential limit was produced but the application proposal is at the upper limit of this range. Together with this the AAP suggests an area of 5000 to 7000sqm of retail use. At 12,400sqm (as well as the 248 residential units) this proposal represents overdevelopment in terms of this policy.

1.6  The artists impressions are poor and do not accurately represent the proposals. We suggest that the council ask the applicant to provide Verified Views in order to be able to fully understand the designs.

2 Scale & massing

2.1  The mass over the whole site is a poor urban design strategy and not respectful of existing urban topography. The Princes Trust Walthamstow masterplan envisaged urban blocks here, which seems like a more appropriate starting point.

2.2  The CABE design review requested more respect to adjacent buildings and townscape. This seems to have resulted in the removal of 2 storeys but the relocating of these units to lower floors, therefore increasing the apparent bulk. The proposal is still 33.5m tall – the equivalent of up to 12 residential floors. (The tallest buildings nearby are the residential flats opposite – 4 storeys with pitched roof). Because of the design approach (with supermarket under) these bulky masses are located right on the street.

2.3  One of the reasons for accepting the tower at Walthamstow Central station was that it was a gateway site at the entrance to the town centre. If buildings of significant scale are accepted elsewhere in the town centre then a precedent is set and the reason for accepting the station tower is seriously undermined.

2.4   The Town Centre AAP (policy 7.13) refers to the London Plan policy 7.7 which requires tall and large buildings to be part of a strategic approach to changing or developing an area and should not have an unacceptable or harmful impact on their surroundings; an Urban Design Analysis is required. It is not clear if such has been provided by the applicant.

3 General design

3.1  The approach to design does not respond to the existing context.

3.2  The ‘Elevation Proportional Design Strategy’ has no relationship to context and is poorly thought through. Even if believable it is hard to see how an approach based on ‘Georgian principles’ is relevant in a context that is predominantly Victorian suburb.

3.3  The applicant should provide details of how the balconies will be designed. They are ‘stuck – on’ balconies and the design of them will fundamentally affect how the building is perceived. The ‘artists impressions’ indicate lightweight, probably all glazed sides

3.4  There has been some attempt in the application proposals to relate to existing context with the use of brickwork (as well as rainscreen cladding). Rainscreen cladding (even if ‘copper coloured’) is a cheap method of construction and often aesthetically of poor quality if not detailed with thought. Details should be requested & panels should be secret fixed.

3.5  The Town Centre AAP (policy 7.7) requires developments to respond to local character and history, and reflect identity of local surroundings; other than the use of brickwork this policy is not met by the proposals.

4 Layout /distribution of uses

4.1  Street level activity is slightly improved in the application scheme compared to consultation proposals but the inherent problem is the car park at ground level. This should be in a basement.

4.2  Residential use is poorly distributed on the site because it is led by the supermarket that (in order to facilitate cheap construction) requires – we are told – column-free space.

4.3  We support the fact that the block currently assigned to be social housing is the one that has the best views at high level.

4.4  The residential entrances are straight off-street with no semi-private space. The applicant should submit more detailed information to show how these are dealt with & that they are not just vacant ill considered glazed spaces.

5 Residential Density

5.1  We are not averse to dense residential development when handled well and with adequate service and amenity provision; it is accepted that a higher level of density than existing Victorian terraced streets that are adjacent will be feasible on this site.

5.2  We have calculated the residential density of the development to be 441hr/h (671 rooms over 1.52ha). An interesting comparison can be made with the recent Hammond Court development for East Thames Housing Group on Blackhorse Road, to the north of this site; this is a carefully done (responding well to the existing context and offering high quality residential units) and has a density of 533hr/h over four storeys. It is understood that the council has a clear objective to increase housing supply in the borough but a natural conclusion would be that the approach to the site here is actually decreasing the potential of good quality housing.

5.3  Provided the proposed retail use can be shown not to compromise the existing retail on the High Street, we would be interested to see an approach that places the car parking into a basement and then splits the site up above ground level, with public space through the centre and residential uses above each of the resulting urban blocks.

6 Supermarket use

6.1  The main roads adjacent the site and further afield in the town centre already struggle to cope with the existing traffic flows and there is doubt over how they will cope with the additional visitors to this development.

6.2  We are concerned that there will be a negative impact on the High Street.

6.3  The employment offered at the site will be retail employment, of mainly low skill, low wage jobs, and we question whether other employment uses should not be prioritised.  The council should be encouraging more wide-ranging uses in the town centre.

6.4  The Town Centre AAP (policy 6.16) highlights the need to capture the spend of higher earners in the borough that is currently spent elsewhere, through attracting higher end retail operators. The supermarket proposal here compounds the problem of a prominent focus on the lower and discount end of the market.

7 Sustainability

7.1  This is an unambitious proposal from a sustainability point of view; Code for Sustainable Homes level 4 is becoming fairly standard.

7.2  As the site is being sold by the council it should be used to demonstrate how important the council considers sustainable design – the proposal should be exemplary.

7.3  No alternative energy sources seem to be proposed; there are no solar thermal or photovoltaic panels, turbines etc, or rainwater harvesting.

7.4  Lack of priority for pedestrians or cyclists; there should be covered cycle storage for visitors and shoppers.

7.5  There is no connection to the TFL ‘air quality corridor’ on Selborne Road. We understand there are to be cycle routes constructed here and these should be linked with these proposals.

7.6  How does the applicant deal with increase in pollution from the scheme?

8 Quality of the residential units

8.1  The quality of the internal arrangements of the flats is poor; irregular rooms in flats result from the shoehorning of spaces into the shape of the building. (External form is leading the layouts & the effects of this are not well resolved.)

8.2  Two thirds of units are single aspect (162 out of 248).

8.3  The majority of the communal space does not have natural light, but long, dark corridors. This is a requirement of the London Residential Design Guide.

8.4  There is overlooking of habitable rooms toward the east end of the building; inward looking flats in the ‘boomerang’ section have very poor aspect.

8.5  Wheelchair units do not have space for storage of electric carriers.

8.6  The refuse strategy involves dragging many bins across the shared garden. Whilst this might be well managed by the building management organisation, there is concern about the practicality of this and the disruption and noise this would create.

9 Transport

9.1  We support car free schemes very close to a transport interchange, although have concerns about the sustainability of very large car free proposals and especially where units are provided that are intended to be occupied by families.

9.2  There should at least be parking allocated to family units.

9.3  Three disabled spaces for the residential units is insufficient.

9.4  If existing local CPZs need extending, the council needs to carry out any consultation to see if residents approve.

10 Social infrastructure

10.1  Sufficient contribution (section 106 or other) needs to be provided to improve local amenities that are already oversubscribed

10.2  Is there sufficient physical space available at local schools?

11 CABE Design Review

We have reviewed planning application proposal against the CABE review of the consultation scheme and comment as follows.

11.1 CABE believe that the proposals will have “a significant impact on the town centre and the development needs to set a benchmark for good design”, however they found the reviewed proposals did not meet these expectations. The amended development will still have a significant impact and as the design has changed greatly since the CABE review, it should be reviewed by them again.

11.2  The form of the building is a complex curved shape, but due to cost issues this is facetted with straight lines. CABE recommend either simplifying the form or omission of the curved design. The overall approach remains curved in form, and is facetted, against the advice of CABE. (It is worth noting that the sketch views supplied do not show the affect of this.)

11.3  The impact of height, massing and materiality on the surrounding context are not fully tested. An alternative approach is required to better relate to the existing context.

11.4  Clearer high quality pedestrian routes are required to the existing town centre. The applicant is proposing investment in connections to the town centre the other side of the railway line, which is welcomed.

11.5  An active ground floor is required to provide animation to the street. Larger residential entrances at ground floor would better connect the residential development to the street. An active ground floor is somewhat achieved by the addition of small shops and post rooms. however we feel this is a token gesture. Most of the perimeter is still made up of access and service space. The CABE suggestion of parking being placed half a level down would be much more beneficial – or we consider, the car park should be in a full basement. This would mean complete street frontage use and a much higher chance of long term success, and achieve CABE’s requirement of better connecting the residential uses above, to street level.

11.6  “Floor plans should be reconsidered in order to provide high quality homes; they require major revision to meet the requirements of the Mayor’s London Housing Design Guide for providing dual aspect units, usable balconies, avoiding north aspect units and long corridors.” The residential units proposed are still of poor layout and we think it would be helpful for CABE to review the new scheme. Two thirds of the units are single aspect and there are long internal corridors with no natural light, contrary to the requirements of the London Housing Design Guide.

11.7  The massing of the building should better relate to the wider townscape around the development; the block layout is questioned and CABE suggest reconsideration of earlier options for the residential blocks to help provide dual aspect units, create a larger south facing shared garden, and respond better to the context. As above it is apparent that the applicant has responded to CABE’s criticism of the overall design by removing two storeys and adding the flats removed to lower floors. The application proposal still wraps the residential blocks around the south of the site so the shared amenity space still faces north, and the increased massing at lower levels will make the north facing space feel more enclosed and less well naturally lit. As the blocks remain around the perimeter of the site, the changes make no effort to better relate to the existing wider townscape, as explicitly requested in the CABE response. We contend that CABEs comments here are not being fulfilled with this proposal.

11.8  The shared amenity space needs more consideration in terms of use and design across the two levels. The shared garden would appear to have had serious consideration since the CABE review, which is positive. However if the council are minded to approve the scheme the implementation of the proposals should be carefully conditioned. We are however concerned about the refuse strategy, as above.

We hope that these comments are helpful in your consideration of the application.

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