Former Gala Bingo Hall Richmond Road, Kingston Planning Statement

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1 Former Gala Bingo Hall Richmond Road, Kingston Planning Statement

2 Former Gala Bingo Hall Richmond Road, Kingston Planning Statement November 2013 Indigo Planning Indigo Planning Limited Swan Court Worple Road London SW19 4JS Tel: Fax: indigoplanning.com

3 Former Gala Bingo Hall Richmond Road, Kingston Planning Statement Contents Page 1. Introduction 1 Application Submission 1 Structure of Statement 2 2. Application Site and Surroundings 3 Application Site 3 Surrounding Area 3 Relevant Planning History 4 3. The Proposal 5 Accommodation Schedule 5 4. Planning Policy Framework 7 5. Key Planning Issues 10 Proposed Mix of Uses 10 Design, Scale and Massing 13 Heritage 14 Impact on Neighbouring Uses 15 Parking and Services 15 Sustainability 15 Archaeology 16 S106 Draft Heads of Terms Conclusions 17

4 Page 1 1. Introduction 1.1. This planning statement has been prepared on behalf of CNM Estates in support of a full planning application for a mixed-use development at the former Gala Bingo Hall, Richmond Road, Kingston ( the site ) The application follows detailed discussions with officers at the Royal Borough of Kingston upon Thames ( the council and RBK ); statutory consultees, such as English Heritage; local residents and businesses; interest groups, such as the Cinema Trust Association (CTA); and other local representatives. The planning application is submitted in conjunction with an application for listed building consent (LBC) in respect of various alterations to the building, which is Grade II listed The building has been largely vacant for a number of years since its closure as a bingo hall. CNM Estates entered into an agreement to purchase the building in October 2012 from the previous owner who had undertaken various unauthorised works to the listed building without the necessary consents. The building has also suffered from extensive water damage as a result of damage to window openings and to the roof of the fly-tower The application scheme proposes a mix of uses within the existing building and also new accommodation at roof level and at the rear of the property to help enable a viable development and allow the restoration works to take place. CNM Estates has, where possible, sought to reinstate the key features of heritage interest into the proposals so that future generations can enjoy the heritage value of the building. The previous owner sought to use the building as a music venue which led to a lot of opposition from local people. This current proposal does not include a music venue As set out in the accompanying Statement of Community Involvement, this application follows a period of rigorous public consultation. It also follows a series of positive preapplication meetings and discussions between the applicant and the council. Formal preapplication advice was issued in a letter dated 12 July 2013 (LPA ref: 13/12105/PRE) and the council expressed their general support for the scheme: I would start out by saying that we recognise the significant opportunity that this site presents and the significant number of constraints that you have to work with. This important listed building at a gateway to the town centre has been significantly run down by criminal damage and the council is therefore committed to working with you to restore this building which will necessitate intervention in the fabric of the building. Notwithstanding these challenges, we are confident that a successful scheme can be delivered on the site which can make a significant positive contribution to the listed building and the townscape and will also provide the enabling development required to secure its restoration into a viable mixed use scheme. Application Submission 1.6. The planning application comprises of the following: Completed application forms and ownership certificates; Application drawings, prepared by Conran and Partners; Design and Access Statement, prepared by Conran and Partners; Planning Statement, prepared by Indigo Planning; Heritage Statement, prepared by Indigo Planning; Statement of Community Involvement, prepared by Cratus; Financial Viability Assessment, prepared by GVA; Transport Statement, prepared by TTP Consulting;

5 Page 2 Structural Report, prepared by Bradbook Consulting; Flood Risk Assessment, prepared by Bradbook Consulting; Archaeological Desk Based Assessment, prepared by CgMs; Daylight and Sunlight Report, prepared by GVA; Sustainability Statement, prepared by Cudd Bentley; Energy Statement, prepared by Cudd Bentley; Code for Sustainable Homes Pre-Assessment, prepared by Cudd Bentley; Environmental Noise Assessment Report, prepared by Aulos; and Completed Mayoral CIL forms These documents provide a full and detailed justification of the proposed development and its appropriateness against the Development Plan and other material considerations. Environmental Impact Assessment 1.8. The proposed development has been considered in respect of the EIA Regulations The proposed development falls within the category of an Urban Development Project as described within paragraph 10(b) of Schedule 2 of the Regulations. However, the site does not exceed the size threshold of 0.5 hectares (it is hectares in area) and does not lie within an environmentally sensitive area (it falls outside of the Thames Policy Area) Whilst the property is a Grade II listed building, listed buildings are not classed as sensitive sites under Regulation 2 of the EIA Regulations and therefore do not demand special consideration for the purposes of the EIA Regulations. The impact of the proposal on the designated heritage asset is fully considered in the Heritage Statement (which forms part of the planning and LBC applications) as it does not raise issues likely to give rise to any significant environmental effects For the above reasons, the council confirmed that a screening opinion was not necessary. Structure of Statement The structure of the planning statement is as follows: Section 2 considers the characteristics of the application site, and its context in the surrounding area. The planning history of the application site is also summarised; Section 3 explains the various elements of the proposed development; Section 4 outlines the relevant planning policy context of the site and the proposed development; Section 5 assesses the key planning issues arising from the proposed development and considers these against adopted / emerging Development Plan policy and other material considerations; and Section 6 provides an overall summary and conclusions.

6 Page 3 2. Application Site and Surroundings Application Site 2.1. The building is located in a prominent location on Richmond Road which is part of Kingston s main gyratory system. It is close to main public transport links, such as the town s train and bus stations, and is just within the north eastern boundary of the designated town centre The site effectively wraps around a recent residential led mixed use development to the north where Cowleaze Road meets Richmond Road. Canbury Business Park is to the east, Richmond Road to the west and Canbury Park Road to the south. To the north east is a children s nursery and small car park which are adjacent to the site service road. The application site area (including part of the adjacent school) is approximately 0.2ha The building comprises the former Gala Bingo Club (originally the Regal Cinema), and was statutorily listed Grade II in The list description, notes it as: an early and well-preserved example of an Art Deco cinema from the 1930s, and a good, rare example of the work of a major cinema architect, Robert Crombie 2.4. The building is largely brick built with extensive areas of white render, notably an extensive plinth on its main elevations. Its footprint is broadly rectangular with the main body of the building being the equivalent of five storeys in height with a higher fly tower towards the north end of the building. A chimney and boiler house is also situated on the flat roof of the building at its northern end. The southern and eastern elevations of the building feature numerous crittall windows from the first floor upwards Built in the early 1930s as a cinema, the building was converted to a bingo hall in the 1970s and has been largely vacant since The building is an early and well preserved example of an art-deco cinema by the architect Robert Crombie. Its height allows a double height auditorium hall with a large balcony. The building s south east corner also includes a dance studio at first floor level in the former tea rooms and film studios at ground floor level. Both are accessed from an entrance on Canbury Park Road. The existing dance studio is retained in the current proposals The listed building description refers to a number of notable external and internal features, including nine giant pilasters on the Richmond Road elevation and four iconic pilasters above the main entrance with wave and floral motifs between. Internally, there is a proscenium arch to the auditorium and full height fluting, art deco niches and original light fittings After being sold in 2010, the previous owner gutted much of the building s interior without listed building consent. Many of the building s internal period features have either been removed or damaged during this work The site is not within a conservation area and there are no other listed buildings or locally listed buildings in the vicinity The site lies within Flood Zone 2 with the extreme south west tip of the site falling within Flood Zone 3a. Surrounding Area The site is located within the town centre area, as defined within the Core Strategy (2012)

7 Page 4 and the K+20 - Kingston Town Centre Area Action Plan (2008). Richmond Road is a key approach to the town centre Richmond Road forms part of the gyratory system and allows traffic only to flow south past the application site, with no stopping Kingston is a main shopping destination and is well served by all the major retailers. In addition, Kingston has a wide variety of leisure facilities, including a theatre, cinema, health and fitness centres, restaurants, pubs and clubs. All of these facilities are within easy walking distance of the site The immediate area is characterised by a mix of uses, including residential, retail, public car parks, light industrial, office and vacant development sites (pending redevelopment). The built form within the immediate area also varies considerably in height, scale, materials and age This part of Richmond Road is secondary in retail terms and is characterised by a variety of unremarkable, mainly post-war architecture of two and three storeys Canbury Park Road is a long residential road. Its western end is bookended by a pub/bar which is two storeys in height and appears to date from the early twentieth century. A row of Edwardian terraced properties adjoin it on the south side of Canbury Park Road. Directly opposite is Mitre House, part of the Canbury Business Park. This development appears to date from the late 1990s or early 2000s, is the equivalent of four stories in height and is a fairly typical business estate design To the north, Richmond Road is characterised by a mix of Class A1, A3 and A4 uses and a variety of architectural styles To the south west of the site (across the gyratory) is a large flatted development which appears to date from the 1990s. It is approximately five storeys in height and includes a restaurant at ground floor level Further analysis of the surrounding area is provided in the Design and Access Statement and Heritage Statement. Relevant Planning History The building was originally a large cinema, built in 1931 and opened in February Council records for this site date from 1953 up to 2007 and show a large and varied number of planning applications (and latterly listed building consent applications) during that period for various internal and external works, including advertisement consent applications The records show the 1978 change of use from cinema to social and bingo club (LPA ref: 19856) It is understood that the previous owner considered an application to use the building as a music venue/nightclub (sui generis) but a formal planning application was never submitted and no discussion took place with officers.

8 Page 5 3. The Proposal 3.1. The application seeks planning permission for: Change of use to provide Class A3, B1, D1 and D2 uses including cinema, restaurant, children s play centre and business centre incubator; demolition of rear element and its rebuild to provide Class B1 and C1 uses including office and serviced apartments; erection of three additional floors to provide 14 Class C3 residential units and associated ancillary development including basement car park; and provision of a new classroom and new playground enclosure at Educare Small School The proposed development involves the sensitive conversion and restoration of the existing building to provide a range of uses including: restaurant; children's play centre; three-screen cinema; dance hall; serviced offices and ancillary space related to the residential development The development would also involve the creation of three additional storeys of residential accommodation (14 flats) set above the existing building. The residential element is vital to the viability of the overall scheme (enabling development) The proposals include the removal of a later rear addition to the north-east of the site. This will be replaced with a new five storey element which will contain offices and serviced apartments (aparthotel) The proposals also include a new flexible classroom/playground facility at Educare Small School which adjoins the site to the north-east. This will improve the facilities at the school and overcome potential overlooking from the new offices and aparthotel Beneath the site, a new basement level would be excavated, accommodating car parking, refuse storage areas and a plant room. Accommodation Schedule 3.1. The proposed development would be arranged as follows: Basement 18 car parking spaces Bin store and plant area Ground Floor Restaurant 241 m2 Restaurant (back of house) 166 m2 Children s play centre 485 m2 Cinema lobby 74 m2 Serviced office 22 m2 School classroom 69 m2 School play area 43 m2 67 secure cycle parking spaces First Floor Restaurant 144 m2 Existing dance hall 312 m2 New office 223 m2 Cinema 43 m2 Ancillary to residential 64 m2

9 Page 6 Second Floor Restaurant 126 m2 New office 223 m2 Ancillary to residential m2 Third Floor New office 223 m2 Cinema 588 m2 Serviced office 340 m2 Ancillary to residential 64 m2 Fourth Floor Serviced apartments 210 m2 Residential 974 m2 Fifth Floor Serviced apartments 210 m2 Residential 729 m2 Ancillary to residential 57 m2 Sixth Floor Residential 890 m2

10 Page 7 4. Planning Policy Framework 4.1. This section sets out the planning policy framework relevant to the application site and proposed development The Key Planning Issues section (Section 5) of this planning statement sets out how the proposal complies with, and is supported by, the relevant policies. National Planning Guidance National Planning Policy Framework (March 2012) 4.3. The National Planning Policy Framework (NPPF) introduces a presumption in favour of sustainable development. Paragraph 14 states that development proposals that accord with the development plan should be approved without delay In addition, the NPPF outlines 12 Core Planning Principles. In summary, they state that planning should: proactively drive and support sustainable economic development to deliver new homes and business units; seek to secure high quality design; support the transition to a low carbon future; encourage the use of previously developed land; promote mixed-use developments; focus significant development in sustainable locations; and deliver community and cultural facilities The NPPF also seeks to protect heritage assets and one of the Core Planning Principles is: conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations (paragraph 17) Paragraph 132 recognises that the degree of weight to be given to the conservation of heritage assets should be linked to their significance. Substantial harm to or loss of a Grade II listed building should be exceptional Paragraph 134 goes onto state that where development proposals lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use The NPPF is an important material consideration. The Development Plan 4.9. Section 38(6) of the Planning and Compulsory Purchase Act requires that planning applications are determined in accordance with the Development Plan unless material considerations indicate otherwise. The Development Plan for the site comprises: The London Plan (July 2011); RBK Core Strategy (April 2012); and Kingston Town Centre Area Action Plan (K+20 AAP) (July 2008) The site and immediate surroundings are affected by the following designations within the Core Strategy and K+20 AAP:

11 Page 8 Key Area for Change; Area of Archaeological Significance; Key Views; Kingston Town Centre; and Neighbourhood Policy The policies, against which the development proposals are assessed at Section 5, are set out below. The London Plan (July 2011) The London Plan is the overall strategic plan for London setting out an integrated economic, environmental, transport and social framework for the development of London over the next years Kingston is identified as a Metropolitan Centre in Policy 2.15 (Town Centres) and Annex 2 of the Plan and, as such, will be the main foci beyond the Central Activities Zone for commercial development and intensification, including residential development. With regards to decision making, the policy states that development proposals in town centres accommodate economic and / or housing growth through intensification and selective expansion in appropriate locations The proposed development has also been considered against the following key London Plan policies: Policy 3.5 Quality and Design of Housing Developments; Policy 3.8 Housing Choice; Policy 4.5 London s Visitor Infrastructure; Policy 6.1 Strategic Approach; Policy 6.9 Cycling; Policy 7.4 Local Character; Policy 7.8 Heritage Assets and Archaeology; and Policy 7.9 Heritage-led Regeneration. Core Strategy (April 2012) The Core Strategy was adopted by the council in April The policies contained in the Core Strategy supersede the policies contained in the RBK Unitary Development Plan (UDP): First Alteration (2005). The Core Strategy includes both strategic and development management policy guidance. No separate Development Management Development Plan Document (DPD) is proposed by the council The proposed development has also been considered against the following key Core Strategy policies: Policy CS1 Climate Change Mitigation; Policy CS5 Reducing the Need to Travel; Policy CS6 Sustainable Travel; Policy CS8 Character, Design and Heritage; Policy CS10 Housing Delivery; Policy DM1 Sustainable Design and Construction Standards; Policy DM8 Sustainable Transport for New Development; Policy DM10 Design Requirements for New Development; Policy DM12 Development in Conservation Areas and Affecting Heritage Assets; Policy DM13 Housing Quality and Mix; and

12 Page 9 Policy DM18 New Employment Uses. K+20 The Kingston Town Centre Area Action Plan (July 2008) Kingston town centre is identified as a Key Area of Change in the Core Strategy (April 2012). The K+20 AAP is the key delivery mechanism for this Key Area of Change. The K+20 AAP provides guidance on the regeneration and enhancement of Kingston town centre up to The site is within Character Area 10 (North Kingston). One of the objectives of this character area is to retain and enhance the Gala Bingo Hall for leisure/entertainment use The part of Richmond Road in which the site sits is designated as Other Shopping Frontages Like the majority of Kingston town centre, the site also sits within the Panoramic View from Thatched House Lodge, Richmond Park towards the town centre and the Guildhall The proposed development has been considered against the following K+20 AAP policies: Policy K4 Employment Development within the Town Centre; Policy K6 Provision of facilities for arts, culture, tourism, entertainment, leisure, recreation, the community, faith and voluntary sectors and hotel accommodation; Policy K7 Housing; Policy K9 Design quality in the town centre; Policy K10 Town Centre Public Realm; and Policy K18 Cycling. Supplementary Planning Documents and Guidance The council has issued a number of Supplementary Planning Documents (SPDs) as part of the Local Development Framework (LDF) process. Those applicable to the proposed development are set out below. Sustainable Transport SPD (May 2013) This SPD provides guidance on the implementation of transport policies to encourage sustainable travel habits. The SPD offers guidance on the production of travel plans and transport assessments, as well as recommendations and requirements for cycle parking and facilities and car parking standards. Planning Obligations Strategy SPD (Revised, September 2011) This SPD provides guidance on the requirements and mechanisms for infrastructure contributions, and related social, environmental and economic provision (including school places, open space, transport, training, and community safety) through developments in the borough. Access for All SPD (July 2005) The purpose of this SPD is to highlight the design principles to create inclusive buildings which meet the needs of all users, including the disabled.

13 Page Key Planning Issues Proposed Mix of Uses 5.1. The building has been largely vacant for a number of years. Formerly a cinema, this use became un-viable in the 1970s and the venue changed to a bingo hall. This use was also eventually found to be not commercially viable. The building s poor state of repair and the relatively inferior pedestrian environment around the site are factors affecting the building s marketability Given its history, it is apparent that retaining a single D2 assembly and leisure use in a building of this size and in this location is no longer a realistic proposition. A mixed use approach to redevelopment proposals offers the best way of securing the site s future and, importantly, is required to guard against the continued physical deterioration of the building. A mixed use approach offers an economically viable reuse of the building. Bringing this building back into use complies with intentions of the NPPF. It will make a positive contribution to Kingston town centre and ensure the future conservation of this designated heritage asset The Core Strategy states that the development of Kingston town centre is a key objective of the K+20 AAP and that this area should provide for business and employment needs as well as a wide arrange of town centre activities (retail, business, education, culture, public services, leisure, and entertainment) The proposed cinema, restaurant, children s play centre, offices, flats and serviced apartments are all appropriate town centre uses Through pre-application discussion with officers, it is clear that the proposed mix of uses on this site is acceptable in policy terms. Officers also accept that there needs to be flexibility in their approach to this site, to ensure that a viable solution can be delivered, which will ultimately lead to the improvement of this part of the town. Leisure and Restaurant Uses 5.6. The proposed development incorporates the existing dance studio and a new three-screen cinema (Class D2 uses), as well as a restaurant K+20 AAP s Character Area 10 states that one of its objectives is the retention and enhancement of the listed Gala Bingo Hall for leisure/entertainment use. Likewise, Policy K6 of the K+20 AAP seeks to enhance or diversify the range of arts, culture, entertainment, leisure and recreational facilities. This policy also directs the refusal of planning permission for proposals involving the loss of such uses, unless replacement facilities are provided. As the council s pre-application advice letter (dated 12 July 2013) notes: Given that a new cinema is proposed, together with the retention of the dance studio and provision of new uses appropriate to the town centre, there is no objection to the loss of the existing use in land use terms The applicant is in advanced discussions with an independent cinema operator. As RBK set out in their pre-application advice, the introduction of a cinema use is welcomed as it will reinstate the original use of the building. Such development meets the objectives for Character Area 10 (North Kingston) of the K+20 AAP, which seeks the retention and enhancement of the former bingo hall for leisure/entertainment use The proposed restaurant is considered appropriate in land use terms, as confirmed in the

14 Page 11 council s pre-application advice letter This use is supported by local, regional and national planning policy, and particularly accords with the aims of K+20 AAP Policy K6 to enhance or diversify the range of arts, culture, entertainment, leisure and recreational facilities. Residential Use The residential element of the scheme is required as enabling development Policy K7 of the K+20 AAP affords provision for around 1000 new homes to be built in the town centre over the plan period. Under the London Plan (July 2011), the council is expected to deliver at least 3,750 net additional homes during the period 2011 to 2021, or 375 net new homes per annum. In their draft North Kingston Development Brief, RBK recognises that their housing delivery has been well below target in recent years Core Strategy Policy CS10 states that the council will take full advantage of opportunities to deliver new housing. The policy identifies Kingston Town Centre (as well as areas with the greatest Public Transport Accessibility Level (PTAL) and areas in need of improvement or renewal), as a preferred location for new housing The former Gala Bingo Hall is well-sited in terms of public transport links and access to the amenities of the town centre. The site offers a highly sustainable location for housing and accords with the provisions of Core Strategy Policy CS10. As the council struggles to satisfy its housing requirements, this development will contribute to achieving housing targets. Mix of Units The proposals include 14 residential units spread over three floors above the existing building. The units are aimed at the top end of the housing market and are intended to deliver a different housing offer to the residents of Kingston, in accordance with Policy 3.8 of the London Plan The K+20 AAP acknowledges that the majority of recently built housing in the town centre comprises one and two bedroom flats. It notes and that a wider mix of flat sizes, and particularly larger flats, are required. Policy DM13 of the Core Strategy requires that new residential development incorporates a mix of unit sizes and types with a minimum of 30% of dwellings being three or more bedrooms, unless it can be demonstrated that this is unsuitable or unviable The proposed development comprises the following mix of residential units: One x 1-bed; Ten x 2-bed; Two x 3-bed; and One x 6-bed A total of three units are proposed to be three or more bedrooms. This yields a total proportion of 21% which falls short of the 30% requirement set out in Policy DM13. Given the sensitive nature of the development site and the economic resources required to sensitively restore this Grade II listed building and safeguard its future, the scheme s viability dictates that no more larger units can be provided. Please refer to the Financial Viability Assessment which accompanies this submission for further details Viability considerations are central to this scheme due to the level of expenditure required to bring back a listed building into beneficial use to safeguard its long term future. As such, the proposed development does not include any affordable housing. The public benefit in securing the long term future of a deteriorating designated heritage asset (that is in danger of being classed as at-risk ) outweighs the lack of affordable provision.

15 Page Policy 3.5 of the London Plan seeks to ensure the quality of housing developments and table 3.3 in the London Plan sets the minimum space standards for new residential development. All of the proposed residential units comfortably exceed these standards and therefore the units comply with London Plan policy in terms of dwelling size. Adequate private amenity space is provided in alignment with Core Strategy Policy DM10. The residences will also be built to Lifetime Homes standards, as required by Policy 3.8 of the London Plan and K7 of the K+20 AAP New homes in this accessible town centre location are supported by local, regional and national planning policy and will contribute to the council s housing targets. Serviced Apartments The proposed development includes 12 serviced apartments, or apart-hotels. The need for this form of visitor accommodation is recognised at the regional level and specifically in Policy 4.5 of the London Plan Policy K6 of the K+20 AAP broadly encourages bringing forward hotels in appropriate locations. Significantly, the council s Hotels Feasibility Study (2007) confirms that Kingston requires additional quality hotels in the town centre to provide accommodation for business and leisure visitors Although not explicitly endorsed in local level policy, the presence of serviced apartments would go some way to satisfying the council s need for visitor accommodation. It would also benefit the city of London more widely. Office Use There are two distinct elements to the proposed Class B1 office use at the site. The first element would be located within the newly built section to the north-east of the site. This area would offer typical leasable office accommodation. The applicant already has an agreement in place to let future office space here The second element, located within the main existing building, would offer serviced office space for small, start-up businesses. This business incubator will foster new local business Policy DM18 of the Core Strategy states that the council will support applications for new employment development (of an appropriate scale) in designated employment locations. Kingston town centre is amongst a number of designated employment locations. The Core Strategy (at paragraph 6.114), is explicit in stating that it is the council s aim to redevelop, renew and modernise office stock and integrate office space and residential uses into mixed use developments More specifically, Policy K4 of the K+20 AAP states that the council will encourage and support development proposals that incorporate high specification B1 office space, in a range of sizes and particularly within the vicinity of Kingston Station. The proposed development meets all three of the criteria Policy K4 also offers support to the provision of workshops, studios and offices suited to the needs of the creative industries sector. The development of a business incubator is supported by this policy Offices are appropriate town centre uses and therefore this element of the scheme is supported by local, regional and national planning policy. Other Uses The proposals also include a children s play centre which is considered appropriate in land

16 Page 13 use terms, as confirmed in the council s pre-application advice letter. Design, Scale and Massing The proposed development consists of two main physical interventions to the exterior of the original building the rooftop extension and the complete rebuilding of the side element fronting Cowleaze Road. Other minor external alterations, such as new openings and windows, are proposed on all elevations The rebuilding of the side element fronting Cowleaze Road was considered acceptable by officers during pre-application discussions, given its limited architectural or heritage value The three storey extension proposed to the roof constitutes the scheme s enabling development which underpins the viability of this mixed-use scheme and is essential to the successful restoration of this Grade II listed building During pre-application discussions, the council recognised the requirement for enabling development at the site. The council however raised concerns regarding the impacts of massing from three additional residential storeys to the roof, maintaining the view that only two additional floors would be acceptable in townscape terms The quantum of enabling development determines the need for an additional three storeys of residential development at the site. The applicant has responded to officer s concerns by greatly reducing the footprint of the third additional storey. The design effectively stepsback the top floor, such that it is barely noticeable when viewed from Richmond Road looking north-eastwards (please refer to the accompanying Design and Access Statement for CGI imagery) Policy 7.4 of the London Plan calls for a high quality design response which is human in scale and ensures that buildings create a positive relationship with street level activity. At street level, the presence of the third floor will go largely unnoticed. As such, there will not appear to be an inappropriate level of massing. The residential development will be sympathetic to the form and scale of this heritage asset, in accordance with London Plan Policy Policy K9 of the K+20 AAP is the key local planning policy for assessing design quality in Kingston town centre. This policy requires the highest standard of design in all new development. According to this policy, proposals should respect and enhance the town centre s distinctive character and historic environment. Proposals should respond to the local context, scale and character in terms of siting, density, massing and height. Similar sentiment is set out in Policy CS8 and Policy DM10 of the Core Strategy All three additional rooftop storeys are stepped back from the edge of this listed building. As mentioned, the top storey is further stepped back. By setting all the new rooftop development back, the site will not become too top heavy and the heritage asset will retain its prominence within the streetscene. The lightweight contemporary design will appear very much as ancillary to the existing building, in accordance with the provisions of Policy K Whilst the resulting height of the development is greater than surrounding buildings, it is akin to the height of other buildings within the vicinity, particularly to the west of the site. The proposed development will ensure that the site becomes an effective gateway to Kingston town centre from the north. This will contribute to the aims of Policy K10 of the K+20 AAP, which seeks the creation of attractive gateways to the town centre from the five main approaches More design detail is included in the Design and Access Statement. The proposed design, scale and massing of the extensions are appropriate for this prominent site and sit comfortably with the listed building, in accordance with local, regional and national planning policy.

17 Page 14 Key Views The site sits within the panoramic view from Thatched House Lodge, Richmond Park, towards Kingston town centre and the Guildhall. This view is safeguarded through the provisions of Policy K9 of the K+20 AAP The majority of Kingston town centre features in this view and buildings of a similar height have been permitted by the council elsewhere in the centre The proposed development only adds a further three storeys to the existing built form. Similarly, the orientation of the site is such that it is only viewed obliquely end on. As such it occupies a relatively narrow form when viewed from this position The proposed development would not have an appreciable impact on this protected key view. Heritage Paragraph 128 of the NPPF requires applicants to describe the significance of any heritage assets affected by a proposal, including its setting. The level of detail should be proportionate to the asset s importance and sufficient to understand the impact of a proposal on its significance. Given that the site is statutorily listed as Grade II, a full Heritage Statement accompanies the application submission The building is considered a good example of a cinema of its time and of sufficient special interest to merit statutory protection. The accompanying Heritage Statement sets out that the main interest of the building lies in its main auditorium, entrance foyer, balcony, proscenium arch, and stage. The spatial arrangement of these is key to this interest, with the Art Deco decoration an additional factor adding to its significance. However, the loss of its ground floor and much of the proscenium arch and stage has had a major impact on its significance. The removal of much of this internal arrangement has severely affected the completeness of the interior and reduced the interest of the building Through pre-application discussions with the council, it has been accepted that a single use at the site is no longer financially viable and therefore sub-division of the building and a mix of uses are necessary to ensure the longer term future of this heritage asset. Under these proposals the original designated use (cinema) would be retained in the heart of the building, within the balcony space Whilst the proposed interventions in the building (to accommodate the uses proposed) would result in some harm to the significance of the building it would be less than substantial harm. This harm, however, would be outweighed by the introduction of a scheme which provides the optimum solution for revitalising this semi-derelict listed building and ensuring its long term retention as a key landmark feature on one of the main entrances into Kingston The principle of heritage-led regeneration is supported through the provisions of London Plan Policy 7.9. In terms of local planning policy, Policy DM12 of the K+20 AAP sets out policy applicable to developments that will affect heritage assets. This policy seeks to preserve of enhance the borough s existing heritage assets through the promotion of high quality design and a focus on heritage-led regeneration. This policy also stipulates that the council will allow alterations which would preserve or enhance the established character and architectural interest of a heritage asset, its fabric or its setting In accordance with this policy, the proposed development would see the sensitive restoration and protection of this statutorily listed heritage asset. Leaving the building as it currently stands, risks undermining the longevity of the asset and special qualities of the architecture through neglect. The proposed scheme would see the building not only preserved, but enhanced, through sensitive restoration and on-going maintenance.

18 Page By bringing this heritage asset back into viable use, the future of the heritage asset can be secured, which is encouraged by all levels of planning policy. Impact on Neighbouring Uses In the council s letter of pre-application advice, officers advised that a daylight/sunlight assessment should address the impact on all surrounding residential premises, including those on Canbury Park Road, Cowleaze Road, the opposite sides of Richmond Road and the units within the attached building of Richmond Road The Daylight/Sunlight report which accompanies this application indicates that neighbouring properties are expected to continue receiving adequate levels of daylight/sunlight The redevelopment of the site has also been assessed in relation to the neighbouring Educare Small School. The primary issues relate to overlooking and the applicant has been in discussions with the school throughout the scheme s evolution The application proposes a new classroom and playground enclosure at the school. This will have the dual effect of mitigating any potential impacts related to overlooking and also improve the facilities offered to pupils at the school The proposed uses are appropriate in this town centre location and would sit comfortably with the surrounding neighbours. Transport, Parking and Services As the accompanying Transport Statement confirms, in accordance with policy, the development proposals include the provision of 18 car parking spaces at basement level The proposals also include 67 secure, integrated and accessible cycle parking spaces, in accordance with London Plan Policy 6.9 and K+20 AAP Policy K A Framework Travel Plan has been included in this planning application submission, in line with the requirements of Core Strategy Policy DM8, which obliges all new significant development to develop and implement a robust and effective Travel Plan In addition, an area for refuse and recycling and the necessary plant room are also to be provided in a new basement beneath the existing building. Sustainability The proposed development is inherently sustainable and satisfies the primary aim of the Core Strategy Policy CS1. Policy CS1 states that the council will direct new development, including housing, employment, services and leisure, to previously developed sites in accessible locations such as Kingston town centre The proposals involve bringing a vacant brownfield site back into beneficial use, whilst safeguarding the long-term future of a designated heritage asset This scheme locates a mixture of appropriate town centre uses to a readily accessible town centre site. The proposed development will reduce the need to travel, in accordance with Core Strategy Policy CS5 and London Plan Policy 6.1. Its proximity to public transport (diagonally opposite the train station and a minute s walk from the bus station) and walking and cycling networks, accords with the requirements of Policy CS As the accompanying Code for Sustainable Homes Pre-Assessment shows, and in accordance with the provisions of Core Strategy Policy DM1, the residential development (including the serviced apartments) achieves Code for Sustainable Homes Level 4. The highest possible Code for Sustainable Homes standards have been sought without

19 Page 16 compromising the integrity of this Grade II listed building The accompanying Sustainability Statement confirms that along with achieving Code for Sustainable Homes level 4, the proposed development will also achieve BREEAM Excellent rating for the commercial elements of the scheme The Sustainability Statement concludes that the incorporation of the proposed sustainability measures will allow for the development to be deemed sustainable and compliant with local and national policy. Archaeology The Archaeological Assessment report which accompanies this submission concludes that the site has a moderate potential for residual finds of prehistoric and Roman date, but a low potential for in situ remains dating to all past period of human activity. Past brickearth quarrying at the site however, is likely to have removed any archaeological potential of the site prior to the 17th to 19th century The report states that due to the low archaeological potential of the site, development proposals are unlikely to impact on significant archaeological remains. As such, no further archaeological mitigation measures are recommended. S106 Draft Heads of Terms Due to the significant costs that are associated with retaining and reinstating this statutorily listed heritage asset along with the Mayoral CIL, the additional burden of S106 payments would render the development proposals completely unviable. As such, no S106 financial contributions are proposed as part of this planning application Other non-financial S106 head of terms can be discussed as part of the progression of the planning application.

20 Page Conclusions 6.1. The former Gala bingo building is Grade II listed which has been largely vacant for a number of years following its closure as a bingo hall (because this use was no longer viable) It is in a deteriorating condition due to its lack of use and damage by the previous owner and it is in need of considerable expenditure to secure its repair and restoration Retaining a single D2 assembly and leisure use in a building of this size and condition is no longer a realistic proposition. The proposed mixed use redevelopment of the site; with a range of appropriate town centre uses (including its original use as a cinema within the heart of the building) will provide the optimum solution to revitalise the building and secure its longterm retention Whilst the proposed interventions in the building to accommodate the uses proposed would result in the some harm to the significance of the building, this would be outweighed by significant benefits arising from its restoration into a viable mixed use scheme The three additional storeys are required to deliver the significant planning benefits. The accompanying Design and Access Statement and CGI s demonstrates that the proposed, height scale and massing of the extension are appropriate for this prominent site and sit comfortably with the listed building Overall, the proposed accords with all levels of planning policy and therefore planning permission and listed building consent should be granted.

21 indigoplanning.com

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