John Walker
Director of Planning
Westminster City Hall
64 Victoria Street
London
SW1E 6QP
jwalker2@westminster.gov.uk
By Email
9th April 2015
Dear John Walker,
14/12215/FULL | Redevelopment of 154-158 Strand to form a new academic building
including facade retention of 152-153 Strand, alterations to the Strand building including
an extension to the rear and alterations to the entrance. Redevelopment of the Quadrangle
building including the creation of a new quadrangle courtyard to the King's Building and a
new link to Somerset House East Wing. Alterations to the embankment entrance and
associated works. | Kings College 160 Strand London WC2R 1JA
SAVE is writing to object to this planning application.
Historic Significance and Conservation Area Protection
The application falls within The Strand Conservation Area.
SAVE would like to draw the attention of the Planning Committee to the Conservation Area
description that notes:
“Within this conservation area there are areas of distinct character; the two main routes of the
Strand and the Victoria Embankment holding the area together. There are significant contrasts
in scale between the remaining smaller grain areas and the formal redevelopment around
Kingsway and the Aldwych, the substantial complexes of Somerset House and King’s College,
the Royal Courts of Justice and the London School of Economics.”
The buildings proposed for partial and total demolition are protected by this Conservation Area
description. Moreover, 152-3 is listed. Therefore this aspect of the planning application runs
counter to the NPPF.
In addition the Conservation Area Audit identifies the buildings at 154-158 Strand as Unlisted
Buildings of Merit, which contribute to the character and appearance of the Conservation Area.
The D&A Statement quotes Saved UDP Policies:
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Policy DES 9: Conservation Areas
“(B) Planning applications involving demolition in conservation areas
Buildings identified as of local architectural, historical or topographical interest in adopted
conservation area audits will enjoy a general presumption against demolition.”
It is therefore clear in this case that the buildings should ‘enjoy a general presumption against
demolition.’
SAVE agrees with many statements in the Design and Access Statement that describe the
character and history of this Conservation Area. The following describes well the development
of the area – both the significance of the route and of the narrow plots:
“Early maps of London indicate how the Strand has existed as a main route between London and
Westminster as far as records may be traced. The site is also within the curtilage of Ludenwic,
the Anglo-Saxon settlement that thrived close to the Thames after the fall of Rome, during which
time it is believed the Roman city was largely vacant. As the cities of Westminster and London
grew as centres of power and trade, the Strand became a commercial route, lined with inns,
dwellings ‘tenements’ and workshops. On the approximate location of the site of the King’s
campus, close to the position of the current Quadrangle, the precinct of the mediaeval church of
St Mary-le-Strand stood, including its associated burial ground. The development of the Strand
at this time may be characterised as a ‘ribbon’ of narrow-fronted gabled properties arranged in
linear order reflecting the linear growth of the commercial route between Westminster and
London.”
It is stated in the Pevsner for ‘London: Westminster’ by Simon Bradley and Nikolaus Pevsner:
‘Today the best things in the Strand are undoubtedly its churches and public buildings, together
with the Aldwych Cresecent. But in the connective tissue are many interesting buildings, and a
few outstanding ones.’
It is precisely this connective tissue that must be retained in order to retain the character of the
Conservation Area. In addition the Pevsner singles out the following for note:
‘Nos 152 and 153 are of c.1700, refronted; No 156 has curious pitted stucco detail, looking
c.1840.’
SAVE notes that the unlisted properties are treated as a single disposable entity in the D&A
Statement even though at present they comprise of four distinctive buildings, constructed on the
narrow plots so characteristic of medieval London. Although the buildings themselves are not
medieval, they retain the memory of medieval London in their narrow building plots.
Policy DES 9: Conservation Areas from the Saved UDP Policy is quoted in the Design and
Access Statement:
(F) Setting of conservation areas.
Development will not be permitted which, although not wholly or partly located within a
designated conservation area, might nevertheless have a visibly adverse effect on the area’s
recognised special character or appearance, including intrusiveness with respect to any
recognised and recorded familiar local views into, out of, within or across the area.”
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SAVE is in no doubt that the demolition of 154-158 will have a visibly adverse effect on the
area’s recognised special character and appearance. Views up and down the Strand will be
adversely affected.
The setting of Somerset House and the local streetscape
The following buildings are listed in the Strand Campus:
King’s Old Building Grade I
Somerset House (East Wing) Grade I
‘Roman Bath’ Strand Lane Grade II
33 and 34 Surrey Street Grade II
St Clement’s Watch House Grade II
24-32 Surrey Street Grade II
152-153 Strand Grade II
Aldwych Underground Station Grade II
Several of these buildings would be affected by the proposed application, as would St Mary le
Strand.
These proposals will erode a significant element of Somerset House’s glory. Many people
walking along the Strand are not aware that such a palatial courtyard awaits them, set back from
the busy street. This is because Sir William Chambers had a very restricted street frontage along
the Strand and was obliged to design a compact entrance facade between the narrow frontages of
the Strand (and Fleet Street) which survive in significant degree to this day and contribute
greatly to the character of the Aldwych through their contrast to the monumental character of the
buildings across the road.
Sir William Chambers brilliantly resolved the lack of a grand entrance front by creating the
finest arched entrance passage in London with three parallel arched vaults supported on clusters
of columns. This provides a breathtaking view into the main courtyard where the splendour of
the architecture is there for all to see. This contrast between the narrow jostling fronts of
commercial premises and grander public buildings represents the very essence of London.
Wherever these narrow frontages survive, in the City or streets leading up to it such as the
Strand, it is vital that they are preserved. In this case they provide the frame for the picture within
and form an essential part of the townscape of one of London’s best known streets. This is one
of the most historic streets in the City of Westminster and must be safeguarded.
This streetscape has already been damaged by King’s College’s Brutalist building to the east of
Somerset House. No further encroachment of this kind should be allowed. The character of
central London depends on a balance between large institutional and commercial buildings and
smaller scale buildings on narrow plots. These buildings are in an important conservation area.
They contribute significantly to its specific character and must be retained.
Policy DES 9: Conservation Areas from the Saved UDP Policy:
(D) Setting of listed buildings
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Planning permission will not be granted where it would adversely affect: the immediate or wider
setting of a listed building, or
b) recognised and recorded views of a listed building or group of listed buildings, or the spacial
integrity or historic unity of the curtilage of a listed building.
At present this small group of fine-grained buildings serves as a welcome pause between the
monolithic 1960s New Building that was built with no consideration for its context, and
Somerset House. These buildings form a vital part of the setting of Somerset House.
The D&A Statement suggests that the New Building is out of context, and that by creating a
building of a bigger scale it will create a context - an argument for negative precedent, which
surely should not be applied when considering the future of a Conservation Area. “There is also
the demand in townscape terms to try and address the shift in scale of the Strand Building
immediately adjacent, a building that did not address any of the considerations of context or
grain in it’s design.” (6.3.1)
In addition, the new proposed building is higher than the present buildings, introducing a new
scale that will adversely affect the setting of Somerset House and St Mary Le Strand.
Sustainability and Design
Policy 25 from the Westminster City Plan Policies states the following:
“Recognising Westminster’s wider historic environment, its extensive heritage assets will be
conserved, including its listed buildings, conservation areas, Westminster’s World Heritage Site,
its historic parks including five Royal Parks, squares, gardens and other open spaces, their
settings, and its archaeological heritage. Historic and other important buildings should be
upgraded sensitively, to improve their environmental performance and make them easily
accessible.”
SAVE agrees that historic buildings can be upgraded in order to improve their environmental
performance, and make them more easily accessible. This is not, however, a justification for
demolition as is argued in this Design and Access Statement.
Research has shown that the demolition of buildings also represents a significant loss to the
environment - of the embodied energy required to construct the building, and the materials from
which it is made.
Regarding the New Academic Building - the D&A Statement is misleading, calling it only
demolition of the facades. It is in fact demolition of five buildings, and the retention of the
facade of only one 152-153.
Despite the claims of the D&A Statement, the narrow building plots are lost in the proposal for
the new building, because it is a single building. The new building is more similar in massing
and texture to the 1960s New Building.
Policy 28, relating to design, from the Westminster City Plan Policies states the following:
“Development must incorporate exemplary standards of sustainable and inclusive urban design
and architecture. In the correct context, imaginative modern architecture is encouraged
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provided that it respects Westminster’s heritage and local distinctiveness and enriches its worldclass city environment.”
The proposed design does not respect Westminster’s heritage and local distinctiveness - it
replaces a group of buildings with distinctive façades and replaces them with something
terrifically bland.
The UDP policy goes on to say
2) Development proposals within conservation areas, involving the demolition of unlisted
buildings, may be permitted
a) If the building makes either a negative or insignificant contribution to the character or
appearance of the area, and/or
b) If the design quality of the proposed development is considered to result in an enhancement of
the conservation area’s overall character or appearance, having regard to issues of economic
viability, including the viability of retaining and repairing the existing building”
As has been demonstrated, the buildings make neither a negative, nor insignificant contribution
to the character and appearance of the area. The design quality of the proposed development does
not result in the enhancement of the Conservation Area’s overall character or appearance. There
is no evidence within the planning application regarding retaining and repairing the existing
buildings, rather there are general comments in the D&A Statement.
There are concerns in the D&A Statement regarding accessibility:
“due to the very narrow constrained plots, and numerous upper levels and changes of level. As a
consequence, there is difficulty with circulation and several barriers to movement currently exist
between the current Old Law Building and the rest of the Strand Campus.”
Circulation generally is constrained between the buildings as they were all developed at
different times as distinct buildings; the campus is made up of a series of discrete buildings
which have been inadequately linked in piecemeal fashion to facilitate a very minimal,
unsatisfactory set of connections.”
SAVE considers that in this case the design solutions should concentrate on making these
connections work. This is not a justification for demolition.
“The environmental performance of the buildings is poor due to outdated services, the roofs and
windows are in poor condition, and opening the windows for natural ventilation incurs noise
pollution because of the heavy traffic on The Strand.”
There are many solutions in existence for double-glazing on historic buildings to allow for the
reduction of noise, and air conditioning to allow for the circulation of air. This is not a
justification for demolition.
“In some areas, e.g on the fourth floor of Nos. 154 and 156, office accommodation areas suffer
from damp.”
Maintenance and repair are the solutions for damp; this is not a justification for demolition.
“In terms of the relative significance of the individual buildings, Nos. 152- 153 are of the highest
significance, primarily due to some remaining fragments of the eighteenth century fabric of the
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party walls, façade and shopfront installed by Thresher & Glenny c1930. However, almost
nothing of aesthetic significance survives inside apart from the window shutters and panelling to
the Strand. Accordingly the significance of 152 - 153 is almost entirely associated with the
remaining façade.”
Retention of entire historic buildings as opposed to just façades is not down to whether internal
details survive or not - these can be replaced - it is about layout, interior spaces, and the
preservation of a historic building as a whole.
The proposed new building
SAVE does not agree that: “The New Academic Building is therefore conceived as a single
building, but one that expresses articulation of plot-widths similar to those of the original Strand
plots.”
The D&A Statement outlines the ‘design evolution’ of the New Academic Building, that appears
to go from aspiring to reflect the narrow plots of the buildings it is going to replace to being a
‘background building’ for St Mary le Strand and Somerset House. The concept of a background
building is unsatisfactory - like background music, the idea is of something that attracts no
attention to itself. However, the existing buildings do something better than this: thanks to their
variety and narrow plots, they provide an excellent setting to the surrounding listed buildings:
they manage to be distinctive without being overbearing.
Regarding circulation and a street presence for the university: at present the university has a
street presence in the form of the long Kings Building. In addition it is possible to create more of
a street presence in all of the buildings in question. Again this is a question of working with the
grain of the historic buildings in question, rather than doing away with them.
“The current campus could be characterised as a collection of individual, poorly linked
buildings, clustered together to provide university accommodation.”
This is what most historic universities consist of - we strongly urge Westminster Council to think
long-term and encourage the university to perceive these buildings as assets and not hindrances
to progress.
“The ground floor of the less significant buildings on the Strand have typically developed into
full width shopfronts over the years (exemplified at 152-153, the Strand, which was originally
two narrower shops with separate shopfronts; the shops were combined by Thresher and Denny
in the 1840s, operating with 2 separate shopfronts until the 1930s when the shopfronts were
combined by the same company into a single modern shopfront with plate glass).”
The current shopfronts may have doubled in width but the building plots, extending over their
full height, remain their original narrow plots.
The protection of conservation areas: recent precedents.
The recent Public Inquiry into the Western Market Buildings in Smithfield General Market is
relevant to this case as it underlines the protection afforded to buildings in a conservation area.
The Secretary of State concluded that demolition of the built fabric of the interior of the
buildings was not justified, let alone the exterior.
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Both the Inspector and the Secretary of State were emphatic about the importance of the historic
environment and historic character of the area. Even though the Western Market Buildings are
not listed, the fact that they are part of the Smithfield Conservation Area was enough to afford
them protection.
While it is a different part of London, SAVE considers that this part of the Strand Conservation
Area would be substantially harmed by the total loss of four buildings and the retention of only
the façade of a fifth.
Optimum Viable Use
NPPF, paras 133 and 134 state:
Where a proposed development will lead to substantial harm to or total loss of significance of a
designated heritage asset, local planning authorities should refuse consent, unless it can be
demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits
that outweigh that harm or loss, or all of the following apply:
● the nature of the heritage asset prevents all reasonable uses of the site; and
● no viable use of the heritage asset itself can be found in the medium term through appropriate
marketing that will enable its conservation; and
● conservation by grant-funding or some form of charitable or public ownership is demonstrably
not possible; and
● the harm or loss is outweighed by the benefit of bringing the site back into use.
Where a development proposal will 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.
SAVE considers that in the case of the designated heritage assets in question, the nature of the
heritage assets does not prevent all reasonable uses of the site. Nos 152-158 are buildings that
can be used by the university even if they are not ideal for the university, need some maintenance
and the issue of connecting them to the other university buildings needs to be resolved. SAVE
considers that the harm and loss that will be caused by the demolition of Nos 154-158 will not be
outweighed by the benefit of bringing the site back into use by building a new block.
SAVE considers that the application does not prove that the optimum viable use is one of
demolition and replacement with a new building. Equally there is not sufficient justification for
replacing 152-153 with a new building leaving only the façade.
In 2013, SAVE Britain’s Heritage and the Victorian Society challenged Sheffield University in a
Judicial Review regarding the proposed demolition of a designated heritage asset – Jessops
Hospital, Grade 2 listed. This case established the need to test other uses in order to demonstrate
optimum viable use. SAVE lost the case but, crucially, the judge agreed with our interpretation
of para 134, which consisted of asking whether the council had considered if demolition was
necessary in order to achieve public benefit. Did they ask the question – what is the public
benefit to be had from the non-demolition options versus the demolition option?
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SAVE does not consider that these questions have been asked in this case. There has not been
enough demonstration of other options, and therefore this course of action is not justified in
planning law.
Conclusion
Most historic universities of great reputation and age, such as Kings, have part of their
accommodation in historic buildings. We believe that historic buildings are an asset to a
university rather than a hindrance as is presented in this application regarding Nos. 152-158 The
Strand.
SAVE welcomes the improvements that Kings is minded to make to its campus but considers it
to be of utmost importance that these are not used as justification for the demolition of the
buildings in question – this would not be a correct interpretation of planning law.
SAVE considers that these are historic buildings of great charm on one of London’s most
historic and central thoroughfares. This is part of the historic procession route from St Paul’s
Cathedral to Buckingham Palace. The existing buildings are of a scale that contrast happily with
the brutalist main building of the college, and they also provide a setting for the Grade 1 listed
Somerset House and St Mary Le Strand.
SAVE considers that these buildings are protected by both national and local planning policy as
designated heritage assets: Nos 152-153 are listed and part of a conservation area; 154-158
Strand are identified as Unlisted Buildings of Merit, which contribute to the character and
appearance of the Conservation Area.
SAVE calls on the University and Westminster Council to reconsider entirely their plans for 152158 The Strand. As an important national institution, we believe that Kings College must lead
the way in observing planning law and retaining the historic character of its campus and the
conservation area in which it is situated.
SAVE challenges the very idea that these buildings need to be demolished. We call on this
planning application to be refused. SAVE considers that in the light of their own policies for the
site, and of national policies for the protection of designated heritage assets, there would be
strong grounds for challenge if the council is minded to grant planning permission.
Yours Sincerely,
Clementine Cecil
Director
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