The Glassmill 1 Battersea Bridge Road SW11 3BZ (2024/1322)

The Battersea Society objects strongly to the revised application for a ground floor plus 28-storey tower on a small but very prominent site facing the River Thames next to Battersea Bridge. We acknowledge that the revised proposals involve significant changes from those submitted in April; and that they aim to meet some of the Government’s, the Mayor’s and Wandsworth Council’s key objectives of building more housing, particularly housing for social rent. Nevertheless, the developers’ successive briefs to the architects have resulted in designs for the wrong building in the wrong place: one that fails to respond adequately or effectively to the key points made by the Design Review Panel.

Moreover, the proposal will do substantial harm to many nearby heritage assets of the highest national significance including:

• grade I and II* listed buildings, and grade I and II* registered parks and gardens;

• a very large number of grade 2 listed buildings, locally-listed buildings, and conservation areas both in Battersea and on the north bank of the river in Chelsea.

It is therefore impossible to reconcile the proposals with the provisions set out in Section 16 of the National Planning Policy Framework (NPPF) on conserving and enhancing the historic environment, including the protection of heritage assets. The Government is retaining these provisions in the revisions to the NPPF proposed in July. The proposals are also incompatible with Policy HC1 of the London Plan, and with Policies LP3 and LP4 of Wandsworth’s Local Plan. We outline the substantially harmful impacts further below.

The case put forward by the developers for their proposal is summarised in five text boxes on page 31 of the Design and Access Statement, with the title “Optimising the Opportunity”. But as set out below the case is flawed both in logic and in substance.

Development capacity

The developers agreed to purchase this small site for £45m based on the “probability” that planning permission would be granted. They did so in full knowledge, as they admit explicitly in their application, that it has " limited development capacity”. But instead of accepting the obvious limitations of a small site, the developers argue that an unprecedentedly-tall building is required to “optimise the opportunity”. That is absurd. One might as well argue that any of the two and three-storey houses that cover vast areas of Battersea have “limited development capacity”, and that they should therefore be knocked down one by one and tower blocks built to replace them. A key purpose of the planning regime in this country, including the Local Plan, is precisely to avoid such unacceptable developments.

Site Capacity

The developers’ second claim is that optimising the site capacity provides more housing; and they have now amended their proposal fundamentally in that regard. The total number of units has been reduced from 142 to 110, but now includes 50% of habitable rooms for social rent. Additional housing for social rent is of course a priority for the Government, the Mayor and Wandsworth Council, and we support that priority. But it would be nonsensical to claim that this remarkably small site represents a unique or even a rare opportunity to build more housing for social rent in Battersea or in Wandsworth more widely. Indeed, the Local Plan identifies a wide range of sites for such housing, sufficient to meet its current targets, and it is to be expected that other small sites will come forward for development. It should also be noted that the housing proposed here for social rent is stated to be “subject to viability”. There is no guarantee that it will be provided, and no indication that a registered provider has been identified to purchase it.

Tall buildings

The London Plan and the Local Plan are both very clear about tall buildings:

• they will be appropriate only in the tall building zones it identifies;

• in their visual impact they must respect and respond to the local context including key views from strategic locations and heritage assets, and avoid creating substantial visual interruptions

• they should be proportionate to the local environment

• near the River Thames in particular, they should not impede the outlook or amenity of occupiers of existing buildings.

The proposals do not meet any of these criteria. The developers claim that although the site is not in a tall building zone, that does not preclude building a tall tower. That may be true: planning is always a matter of weighing harms and benefits. But the developers need to show why it is appropriate to build a 29-storey tower (which would be equivalent in height to 34 storeys since the height of each storey is greater than the standard three metres) and when the site is shown in the Local Plan for buildings of five to six storeys. There is no reference to the tall buildings policy D9 in the London Plan, and its requirements that tall buildings must make a positive contribution to the skyline or the local townscape, and that they should be proportionate to and reinforce the spatial hierarchy of the local and wider context. Nor does the proposal provide any explanation as to why Local Plan Policies LP 2 and LP4 should be set aside, with their requirements to:

• avoid adverse impacts on the amenity of occupiers of neighbouring buildings, including daylight and sunlight

• respect key views, strategic landmarks and heritage assets, which in this instance include

• grade I and II* listed buildings, and grade I and II* registered parks and gardens including the Royal Hospital and its Gardens, Chelsea Physic Garden, Battersea Park, and at least 10 buildings so listed facing the river on the north bank;

• well over a hundred grade 2 listed buildings and locally-listed buildings on both sides of the river;

• four bridges, most notably Battersea Bridge itself and;

• conservation areas - most notably Battersea Park and Westbridge Road conservation areas but also Battersea Square and Three Sisters in Battersea - and many more on the north bank of the river in Chelsea;

• respect spatial hierarchies and the need for tall buildings to be proportionate to the local environment and to avoid creating an overbearing impact on the local context; and

• take account of the Thames frontage and the Thames Policy Area where lower-height thresholds for referable planning applications apply; and of the need to avoid impeding the outlook and amenity of residents of existing buildings as well as users of public spaces and the river frontage.

Again, the proposal meets none of these requirements. Residents and everyone who visits a wide area north and south of the river, including many of the most important heritage assets set out above, will also be affected by the casting of shadows, which will be large and widespread for many months of the year.

To consent to a proposal for a building of effectively 34 storeys in height, on a site specified in the Local Plan as suitable for five to six storeys, and one so contrary to the other requirements of the Local Plan, would call into question the validity and status of that Plan. In short, we can see no reason why the Council should not apply the Local Plan Policy LP4 C: that the Council will “seek to restrict proposals for tall buildings outside the identified tall building zones”.

Metropolitan marker

The developers’ fourth claim is that the site “provides an opportunity for a Metropolitan Marker” on the bend of the Thames, “marking the gateway into the Ransome’s Dock Focal Point of Activity” (which stretches from Albert Bridge to Battersea Bridge; elsewhere there is reference to a gateway into Battersea). The application provides no evidence why such a “marker” is needed, nor what value it will provide. The claim that nearly every other bridge over the Thames has a marker building at its foot is simply untrue, as anyone who is familiar with Albert or Chelsea bridges can see. The suggested need for a marker amounts to no more than that a 29-storey tower on a prominent site will be extremely prominent.

Public Realm

The developers’ fifth claim is that there will be improvements to the public realm. and a thriving area in line with the Local Plan vision for the riverside. But it is unclear that there is any addition to the public realm in the revised proposal, since the new building takes up the whole footprint of the existing one. Indeed, there are several references in the Design and Access Statement (DAS) to the constraints of the site and its small footprint, which raises the question why it is thought suitable for such a large and over-ambitious building. The improvements to the Thames Path are minimal, and they do not meet the Local Plan Policy LP52, which requires that the path should be 6 metres wide. And as the Royal College of Art has noted, the space provided for commercial and/or cultural uses is very small.

Other issues: housing standards and employment space

We note that drawings indicate that half of the units for social rent will be single aspect, because of the admitted constraints of the site. This is not compliant with London Plan Guidance and Local Plan Policy LP 27 B and provides further evidence that what is proposed is the wrong building on the wrong site.

We note also that the proposal would result in the loss of well over 4000 sq mtrs of employment space as compared to the current building, contrary to Local Plan Policy LP33.

Consultation and engagement

We expressed concern in our objection dated 17 June 2024 about the form and nature of consultation undertaken. This concern has grown through the development of the revised proposals. In particular we are concerned by online and other media pressure together with leafletting and canvassing aimed at gaining blind support ‘for affordable housing on a brownfield site’ with little or no reference to the precise location and height of the building.

The formal exhibition and online presentations on 12 and 14 October respectively were badly managed with queueing required at times for entry to the exhibition and display boards providing limited information. Material routinely showed the lower portion of the tower only. The online session offered no real opportunity for discussion, no indication of who the reported 65 online participants were nor whether the questions they raised were reflected in the supposed response given by the developers' panel. The DAS merely says that “A predominant theme is the height of the proposed building and its relationship with the surrounding context”. The principles and spirit of community engagement set out in the borough's guidance Raising the Bar were not met, and we regard the developer’s actions as shameful.

Conclusion

For all the reasons outlined above, we believe that the case put forward for the proposed building is fundamentally flawed; the claims made for ‘optimising the opportunity’ for a small site that the developers admit has ‘limited development capacity’ are for the most part absurd and illogical.

• it is impossible to reconcile the proposal with the provisions of Section 16 of the NPPF on conserving and enhancing the historic environment, including the protection of heritage assets

• the proposal is wholly incompatible with both the London Plan and key strategic policies in the Local Plan with regard both to the historic environment (LP3) and to tall buildings (LP4) • the design of the housing for social rent contravenes London Plan Guidance and Local Plan Policy LP 27

• the loss of well over 4000 sq mtrs of employment space as compared to the current building is contrary to Local Plan Policy LP33.

We acknowledge that development management must always be a matter of weighing harms and benefits; and that the provision of more housing, particularly housing for social rent, is at the very least highly desirable. But in this case, the contraventions of policies set at national, regional and local level are so major that approval would call into question the validity of those policies, and the status of the Local Plan as the basis for decision-making. We therefore trust that the proposal will be rejected.