Registered charity 276264

Tite Street

                                                                                                   

The Society has been involved, along with Tite Street residents and the Cheyne Walk Trust, in a series of consultation meetings with London Square, a Middle East owned development company, about their proposals for the demolition and re-development of the former St Wilfrid’s Care Home. Our concerns have focussed on both the use and the design of the new building. Above is a computer-generated image of what the proposed building would look like, together with the existing buildings.

PLANNING APPLICATION PP/25/04989, 29 Tite Street: Objection by the Chelsea Society

The Chelsea Society has reviewed this application with particular care.  Tite Street is one of the most iconic streets in Chelsea.  It is unique not only because of its cultural, artistic and historic heritage, but also because of its distinctive architectural style. Few streets have such a concentration of Grade 2 and Grade 2* buildings.  It is a key part of the Royal Hospital Conservation Area.  The Planning (Listed Buildings and Conservation Areas) Act 1990 places à “higher duty” on the Council in the consideration of proposals in Conservation Areas to ensure that “special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area”.

 

In the Chelsea Society’s view this application falls significantly short of the quality required to meet this criterion.  We therefore urge the Council to reject the application in its present form and to require the applicants to make significant changes to it.

 

This reflects the advice which the applicants have already received from Council officers and from the Council’s Quality Review Panel.  We understand that there have been seven sets of pre-application advice from Council officers and two reports from the Quality Review Panel.  The pre-application advice letters of 27 January, 31 January and 24 February 2025 are of particular relevance.  Key elements of this advice have been ignored or inadequately implemented.

 

Our concerns relate to the use of the site, the scale and massing of the proposed building and the failure properly to preserve garden space and townscape gaps.

 

USE OF THE SITE

 

Both Council officers and the Quality Review Panel recommended that any new development should retain an element of care provision and should include some form of onsite community use.  The proposed building contains neither.  Officers’ advice reflected Local Plan 2024 Policy HO5 which requires that social and community use of the kind which St Wilfrid’s Care Home constituted must be protected  “unless the loss is to improve sub-standard accommodation or increase the existing provision on the site.”  There is an established need for such accommodation in Kensington and Chelsea as evidenced by the Local Housing Needs Assessment 2022.  We do not think it acceptable that the applicant can decline to consider any element of care provision simply on the basis that their own expertise is in residential property.

 

Nor do we accept that the requirement to maintain a significant element of social and community use can be discharged simply by the provision of more exhibition space to the National Army Museum site next door.  The Chelsea Society is supportive of the Museum’s wish to expand.  But we do not feel that on its own this expansion can constitute local social and community use.

 

This was also the view of Council officers who in their pre-planning advice letter of 27 January 2025 said:

 

“4.12.  The need for further social and community use floor space within the building itself is likely required.

 

4.15.  The need to provide social and community space is a requirement of the Local Plan 2024 Policies.  The extension of the NAM would not be considered a “public benefit” which could be utilised to outweigh other deviations from policy.”

 

AFFORDABLE HOUSING

 

It is a long-standing Council policy that when an element of affordable housing is required in à development (as it is in this case), it should be provided on site other than in very exceptional circumstances. Council officers reminded the applicants of this requirement in their pre-application advice letter of 27 January 2025 in which they stated:

 

“4.30. Community housing must be provided on site unless exceptional circumstances justified by robust evidence support the provision of off-site within the Borough or by providing a payment in lieu.

 

4.31. Payment in lieu will only be acceptable as a last resort where it is physically impractical to provide the Community housing on site or it is inappropriate in terms of the numbers that can be provided on site.”

 

The applicants have ignored this advice.   But they are proposing to demolish entirely the existing building.  They therefore have a blank canvas on which to design its replacement.  There is no practical reason why they could not have designed a building with 35% Community housing on site.  If the Council were to allow them to make a payment in lieu this would effectively make a mockery of the Council’s own policy and would exacerbate a trend where no, or hardly any, Community housing is included in new developments in the Chelsea part of the Borough.

 

SCALE, HEIGHT AND MASSING

 

We agree that the existing St Wilfrid’s building is mediocre in character and constitutes a “negative building” in the Buildings Audit.  We welcome its replacement with a building more in keeping with its surroundings.

 

But the mass, scale and height of what is proposed as its replacement would, in our view, give rise to substantial harm to the Conservation Area.  The proposed development would be above 21 metres in places (measured to parapet height) which even the applicants acknowledge is potentially in breach of Local Plan Policy CD8.  Figure 6.3 of the Local Plan clearly indicates that Tite Street is not an appropriate location for tall buildings.  This is confirmed in the comments by Council officers in their pre-application response of February 2024 at paragraph 4.33:

 

“Tall  buildings will only be acceptable within the locations that are identified for tall buildings ………… the site is not a site allocation and the site has not been identified as a suitable site for a tall building.  As such, the maximum height of the building should be below the 21m threshold.”

 

Council officers reiterated this point in paragraphs 4.3 – 4.6 of their pre-application letter of 31 January 2025.

 

The proposed building would result in an increased canyonisation effect in this part of Tite Street as a result of the excessive height of the building itself and the loss of a significant part of the current townscape gap.  This would be harmful to the character of Tite Street and of the surrounding Conservation Area and would worsen the outlook from the houses opposite.  Council officers emphasised this in paragraphs 4.5 and 4.6 of their pre-application letter of 31 January 2025:

 

“The proposed height of the building in combination with the design and massing results in a dominant built form.  The mansard style design of the roof results in a horizontal emphasis with no break of massing, emphasising the impression of height, mass, and sits in sharp contrast with the roof profiles along Tite Street.  The height of the proposed building should be reduced and should sit no more than between 6 and 5 storeys, with the higher storey not continuing the length of the street”.

 

It is important therefore that any new building on the site should be below 21 metres in height; and that the height over the Tite Street gap/garden where the existing Convent Chapel is located, should be no higher than the current height of the Chapel.

 

The west side of Tite Street is marked by a variety of building heights.  This was deliberately intended from the very beginnings of development in the street, with buildings being commissioned for their individuality.  It is a feature which should be replicated in any building on the other side of the street.  The building proposed in this application does not reflect this.  It is too uniform and slab-like and is over-dominant in relation with the properties on the other side of the street.

 

TOWNSCAPE GAPS AND GARDENS

 

The current Conservation Area Statement for the Royal Hospital Conservation Area (March 2016) emphasises the importance of the Townscape Gaps in Tite Street as an important breathing space in the dense urban environment.  Any change to these gaps would therefore be in direct conflict with RBKC’s Local Plan 2024 Policies CD2, CD3 and CD4.  The gaps, particularly the “garden” gap at the southern end of the site, should therefore be preserved as they stand.

 

The current application fails to do this.  It would involve the encroachment of new build of up to 5 storeys (about 20 metres in height) over at least 50% of the existing townscape gap.  This would vitiate much of the benefit of the proposed green space (which in any case would be significantly smaller than the existing garden) and would erode this gap to the detriment of the street and to the character and appearance of this part of the Conservation Area.

 

Paragraphs 3.10 and 3.11 of the Council’s pre-application letter of 24 February 2025 emphasise this point and indicate the unacceptability of the proposed intrusion into the Tite Street gap.  It notes that the existing Chapel is effectively single storey and that a 5 storey structure over the whole of this part of the gap would be harmful to the Conservation Area in general and to the settings of two Grade II listed buildings,  ie 44 and 46 Tite Street in particular.  The advice states at 3.10:

 

“As previously identified, it is recommended that development is pulled back to the established building in line with the Chapel.  The existing building line does intrude into important gap 1, which does establish a base line for development, albeit the built form in this location is primarily single storey.  Development within the gap should therefore need to further reduce the overall height proposed where it intrudes into important gap 1.  This should offer the opportunity to create an architecturally distinct building(s) to sit aside the main proposed mansion block.  Such an alteration will also aid in addressing the grain of the proposed built form, being more responsive to the existing grain along Tite Street”.

 

The applicants have failed to follow this advice.  The Council should insist that they do so.

 

A further consequence of the overbearing nature of the proposed building would be a damaging impact on the light enjoyed by the historic listed studio apartments on Tite Street, in particular nos 34, 44 and 46.  The townscape gap and St Wilfrid’s garden are intrinsic to the wider context and setting of these houses and to their architectural and historic heritage.  This was noted by Council officers in their pre-application letter of February 2024:

 

“This gap provides a relief and breathing space in the dense urban environment, as well as allowing glimpses of the open spaces and the tops of the buildings behind the site. It is also an established part of the setting of the neighbouring listed buildings”.

 

The importance of the artists’ studios in Tite Street, and their relationship to the townscape gap and garden is recognised in paragraph 6.17 of the Local Plan and Policy CD1 (context and character).   In their pre-application letter of 31 January 2025, paragraphs 3.18 and 3.19, Council officers noted:

 

“the impact of the proposed built form with nos 44 and 46 should be carefully considered and the height may need to be reduced to ensure its significance is preserved ……… the impact on no 44 in particular is of concern.  Currently the overall height appears to exceed the terminus of those buildings on Tite Street, which in combination with the horizontal massing proposed, does appear overly dominated. The height should be reduced and the massing broken up to reflect the vertical emphasis of the listed buildings on Tite Street.”

 

Again the applicants have failed to follow this advice.  We urge the Council to insist that the unique characteristics of the current buildings in Tite Street are not compromised by the redevelopment of St Wilfrid’s.  What the applicants are currently proposing is not, in the view of the Chelsea Society, compatible with this important part of Chelsea’s heritage.

 

I would be grateful if you would record the Chelsea Society as the author of these comments when you publish them on the planning website.

 

Paul Lever

Chairman of the Planning Committee

The Chelsea Society

If members of the Society want to comment on the application a link is available on the RBKC planning website under reference PP/25/04989. The website of the Tite Steet Association (https://friendsoftitestreet.co.uk) sets out the concerns of local residents about what is proposed.

 

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