How To Develop The Kingsgate Business Centre

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1 Kingsgate Business Centre Employment Report Introduction The subject property comprises serviced offices arranged over two floors within a building in the north side of Kingsgate Road. It is served by surface level parking and roof top parking. The building provides for 2,030m2 of floorspace. The building is under occupied with less than 70% of the work stations in use. The building provides poor quality space and is inefficiently designed. The approach to the loss of office use on the site was initially address in our Planning Statement. The text of this is set out in Appendix A. Appendix B is the Agents demand and supply report. Permitted Development The Councils approach to this site and office use within Kingston Town Centre has to be considered in the context of the change of legislation introduced in May This would subject to application to the Council as to whether prior approval is required allow for the change of use of the existing building from B1 to C3.

2 Therefore if this process were undertaken there would be no policy control over the loss of the existing floorspace. The proposal would enable a change of use from office floorspace. Kingston Action Area Plan K+20 (2008) Part C of the Plan deals with Character Areas and Proposal Site policies. Paragraph 12.3 states: Within the areas which have potential for significant change and improvement, this AAP identifies 20 Proposal Sites P1-P20 (Plan 15 and the Proposals Map). They are suitable for development to provide new or intensified town centre uses, to achieve the objectives set out for each character area and the vision and objectives for the town centre overall. Some are vacant and underused sites, with a poor quality environment, others have poor quality buildings, which would benefit from redevelopment and renewal. The subject site lies within Character Area 10 North Kingston on Plan 14 and Plan 15 identifies the Proposals Sites. The subject site forms part of the larger site allocation referred to as P19 in the adopted plan. Proposal site 19 is one of seven new sites in the plan. The plan advises that Policies for each Proposal Site identify appropriate uses and where applicable, the scale of development proposed on the sites. "The policies avoid being too explicit on the precise amount and mix of different uses, leaving flexibility in the development of proposals through the planning process. The Council will encourage more detailed assessment and site planning through negotiations with landowners and prospective developers as part of the development control process. It will expect applicants to demonstrate that they have considered and responded to the range of uses and site specific guidance identified in the Proposal Site policies in preparing their planning applications. Paragraph 12.6 states: For all Proposal Sites, planning applications for development will be determined in accordance with the provisions of the individual Proposal Site policy and all other relevant policies.

3 Plan 16 of the document provides an analysis of the built fabric and the existing building is considered to be of poor quality. Plan 18 identifies the building as having an unattractive frontage quality. The site is shown as the majority of Site 19c on the Character Area 10:Proposals Plan on page 149. Policy P19 deals with KINGSTON COLLEGE (19a) AND ADJOINING SITES (19b and 19e), KINGSGATE BUSINESS CENTRE AND PRINTING WORKS (19c) AND THE KINGSTON GAS HOLDER STATION (19d). It states: The Council will work with Kingston College and adjoining landowners to secure:.. The retention of the Kingsgate Business Centre and printing works 19c for employment use or their redevelopment for B1 business use or ground floor B1 use with managed student accommodation above (our emphasis). From careful reading of this policy it is clear that the options for the site are phrased in the alternative rather than in a sequential or hierarchy form. Therefore a scheme proposing a mixed B1 use on the ground floor with managed student accommodation is not dependent upon having considered the other options suggested for the site. Further from the analysis undertaken by the Council and identified on Plans 16 and 18 referred to above where the quality of both the building and frontage are considered poor and unattractive the retention of the existing building is not likely to be a favoured option. Accepting that the third option for the site only suggests ground floor B1 there is an acceptance of some loss of B1 space from the site. As indicated previously the plan explicated states that the policies avoid being too explicit on the precise amount of uses leaving flexibility in the development of proposals. The supporting text to the Policy at paragraph further states The Kingsgate Business Centre also offers potential for redevelopment and intensification to include replacement, upgraded B1 offices, with student accommodation above. In our view this suggests as expressed here that to provide for higher quality B1 on site the preferred option is for offices at ground floor with managed student accommodation above.

4 The application proposal is for the potential for ground floor B1 use with managed student accommodation above ; is a redevelopment ; an intensification ; potential for upgraded B1 offices ; and student accommodation above. The application proposal is therefore a precise fit to the adopted and extant policy and supporting text. The plan advises that proposals should be determined in accordance with the provisions of the individual Proposal Site policy and having regard to their relevance of policies. Given the Site policy accepts the loss of B1 space from the site to a degree the direct relevance of the Councils other policies on office use are in our view diluted. Notwithstanding that view we consider the policies in the following paragraphs. Policy K4 of the AAP states: EMPLOYMENT DEVELOPMENT WITHIN THE TOWN CENTRE The Council will promote the town centre as an office and business centre and improve the quality and range of office and business accommodation by encouraging and supporting: development proposals that incorporate high specification B1 office space, in a range of unit sizes, especially in the vicinity of Kingston Station (Proposal Site P10); the redevelopment and improvement of the existing office stock; the provision of workshop, studio, exhibition space and offices suited to the needs of the creative industries sector. Development proposals resulting in a net loss of B1 office floorspace will only be acceptable if office floorspace is re-provided as part of mixed-use development of the site, or the loss of the office floorspace is outweighed by the achievement of other AAP objectives through the proposed development. The Council will achieve these policy aims through promoting the development of the Proposal Sites identified in Part C of this Plan, and through the consideration of planning applications for the development of these and other sites in the town centre. The Council will play an active role with partner organisations to increase the number of jobs and maintain a wide range of employment opportunities and to identify and address skill and training needs for town centre businesses. The application proposal is compliant with the adopted policy in a number of respects: it will incorporate space capable of providing for high specification office space; it will provide for the redevelopment of outdated office space;

5 the proposed space will be suitable for office space for creative sector; the proposal will result in a net loss of office floorspace but re-provides for potential office floorspace as part of a mixed use scheme and the proposal contributes to other AAP objectives and is in accordance with the development of the Proposal Sites identified in Part C of this Plan. Core Strategy (April 2012) The Core Strategy (CS) was adopted more recently than the AAP, but does not replace the AAP. The CS indicates that in respect of Kingston Town Centre one of the Key Challenges is to Improve the Town Centre's status as an office centre but also to Improve poor approaches/gateways to the Town Centre. Figure 13 provides an Extract from Kingston Town Centre Area Action Plan that shows the proposals sites including Proposal Site 19. The vision for the area includes High quality new development will maximise the potential of vacant, outmoded and underused sites. The application site in our view is such a site. In respect of delivery the CS states: 5.12 The strategy for delivering the objectives for Kingston Town Centre is detailed in the Town Centre Area Action Plan (K+20) Overall, the delivery of the Area Action Plan (AAP) is dependent upon the development of proposal sites and other windfall sites, together with an integrated approach to the public realm and access improvements. It is clear therefore that the strategy for Proposal Site P19 and the application site remains that as set out in the AAP and as discussed above. Indeed the delivery of the vision of the town centre is partially dependent upon the delivery of Site 19 as proposed in the application proposal, given its compliance with the AAP. The broad scope for the town centre includes the provision of new and upgraded offices, including small business space. The application proposal makes provision for the potential for new and better quality offices on the site.

6 Policy CS11 states: Economy and Employment With its partners the Council will: a. build on the economic strengths of the Borough by promoting the development of a diverse and flourishing economy and ensuring that land and premises are available for both traditional industrial and office based employment activities (B1, B2 and B8 uses) b. promote the redevelopment, renewal and modernisation of existing office stock (which may include integrating office space and residential uses into mixed use developments). And Policy DM17 states: Policy DM 17 Protecting Existing Employment Land and Premises The Council will protect all employment land and premises in the following broad locations: A. KINGSTON TOWN CENTRE - to develop its role as a successful, sustainable Metropolitan Centre through the implementation of the Kingston Town Centre Area Action Plan (K+20)... E. OTHER EMPLOYMENT LOCATIONS - all employment premises not set out in A-D above will be protected for employment uses to meet business needs and provide employment. Alternative uses will not be acceptable within the areas A-E above unless it has been demonstrated by sound evidence and rigorous marketing over a number of years (up to two years) that there is no quantitative or qualitative need for a range of employment uses. Further detail on this issue can be found in the GLA's Industrial Capacity SPG (2008) para Mixed use development schemes should not result in a net loss of employment capacity (floorspace and/or land) and should not compromise the viability of the site and/or its surroundings for employment purposes.

7 The supporting text advises that The Council's aim to redevelop, renew and modernise existing office stock and integrate office space and residential uses into mixed use developments is consistent with the sentiments of the London Plan (2011). Employment generating developments will be brought forward in the following ways: by redevelopment, renewal and modernisation of premises within designated employment areas and within District Centres on sites within the Kingston Town Centre Area Action Plan (K+20) development on scattered employment sites (our emphasis) An option for Site 19c in the AAP is for the mixed use development of the site with only ground floor B1 office. This therefore accepts the net loss of B1 floorspace is in accordance with the development plan as it will deliver better quality space and also because of the wider benefits. Therefore the Councils policies for the Site are consistent with the more recent development plan that clearly envisages a mixed use development, a net loss of employment floorspace and no need for extended marketing. North Kingston Development Brief Consultation 2013 The draft Brief was published in September 2013 and due to be considered by Committee later this month. This proposes three options for development of the site. Two of the three options for the site propose Employment and/or education on the lower levels with residential and/or student accommodation on the upper levels. The third option proposes a school on the site. In respect of the objective of the Brief this advises that The North Kingston Development Brief (NKDB) is underpinned by the Kingston Town Centre Area Action Plan K+20, adopted in July The policy context refers to the Core Strategy but does not refer to any of the employment policies as relevant. Under the heading of intensification the Brief advises that Residential accommodation can sit above retail, education, community, and employment space located at the street level (our emphasis). In respect of Land Use the Brief advises Whilst not designated as an employment area, employment uses are currently located within the site. The Borough has a relatively

8 limited supply of industrial/business land and studies have demonstrated the need to retain such land in business and industrial use. The Council therefore seeks to ensure the employment uses are re-provided as part of a mixed use proposal. If re-provision is to be made at street level as the Brief suggests then this accepts some loss of employment floorspace. Further the specific suggestion in Options 1 and 2 for the site is similar to the development plan designation in the adopted and extant Action Area Plan, that the planning application accords with. Whilst we have raised as part of our representations an issue that the Brief cannot lawfully overwrite the adopted development plan should Option 3 be chosen this accepts the full loss of employment use form the site. Although policies in the adopted Core Strategy are clearly relevant, the Brief does not rely upon those that relate to employment in setting out its aspirations for these particular development parcels. CgMs Limited November 2013

9 Appendix A 4.5 Kingsgate House, a serviced office space, is currently entirely in B1a Office use comprising a total of 2,030m2. The application proposes the loss of the majority of this quantum of employment of floorspace with the re-provision of up to 500m2 commercial floorspace to be re-provided at ground floor in the redevelopment proposals. 4.6 Recent changes in the permitted development legislation would potentially allow for the change of use of the floorspace from office to residential, only subject to the prior approval process. 4.7 The loss of this floorspace is primarily considered acceptable due to Policy P19c of the Kingston Town Centre Area Action Plan (K+20) which as noted above promotes the site either for retention of the Kingsgate Business centre and printing works for employment use or their redevelopment for B1 business use or ground floor B1 use with managed student accommodation above. Of the three choices outlined by Policy P19, the latter is favoured. This policy therefore allows the loss of much of the B1 floorspace. 4.8 Core Strategy Policy DM 17 Protecting Existing Employment Land and Premises, with regard to Kingston Town Centre, notes that the policies pertaining to the loss of employment uses are contained in the Kingston Town Centre AAP. It does however note that in usual cases, two years marketing is required for the loss of employment uses and mixed use development schemes should not result in the net loss of employment capacity. 4.9 The aim of Core Strategy Policy DM 17 is reflected in Kingston Town Centre Area Action Plan Policy K4: Employment Development Within the Town Centre, if not somewhat reduced. Initially it states that it will encourage and support the redevelopment and improvement of the existing office stock. It also states: development proposals resulting in a net loss of B1 office floorspace will only be acceptable if office floorspace is re-provided as part of mixed use development of the site, or the loss of the office floorspace is outweighed by the achievement of other AAP objectives through the proposed development. In this case there is the re-provision of some office floorspace in the development. In addition, the loss of the quantum of office floorspace is also in line with a stated objective of the AAP by developing the site in line with its specific designation in the AAP.

10 4.10 The objective referred to in the section above is outlined in Policy P19: Kingston College (19a) and adjoining sites (19b and 19e), Kingsgate Business Centre and Printing Works (19c) and The Kingston Gas Holder Station (19d) as noted previously. This policy clearly outlines the preferred development options for the sites listed in the policy title. In relation to the application site, it states: The Council will work with Kingston College and adjoining landowners to secure: The retention of the Kingsgate Business Centre and printing works 19c for employment use or their redevelopment for B1 business use or ground floor B1 use with managed student accommodation above It is also noted that that the footprint of the proposed building has been reduced and it is proposed that part of the eastern end of the site will provide an open space accessible to the public in line with the Councils more recent but as yet unpublished wider aspirations for this area of the town. This reduction of the available site further justifies the reduced provision of commercial uses It is clear that the policies outlined above, and in particular those outlined from the Kingston Town Centre Area Action Plan support the reduction of office floorspace at the site.

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