21/00044/FUL
Tolworth Tower Tolworth Broadway Tolworth KT6 7EL
Change of use of the existing 3rd to 22nd floors in Tolworth Tower from office (Use Class B1) to residential (Use Class C3), change of use of the existing 2nd floor from office (Use Class B1) to ancillary amenity space, including a residents gymnasium and lounge (Use Class C3), change of use of existing 1st floor Car Park (sui generis) to create a flexible workspace unit (Dual Use Class C3/E), change of use of part of the existing ground floor undercroft from office (Use Class B1) to create freestanding retail kiosks (Use Class E) with associated external facade alterations and internal refurbishment works to Tolworth Tower; The demolition of the existing retail units fronting Tolworth Broad
The applicant has failed to demonstrate through the submission of accurate and consistent information that the scheme would be deliverable or that it would provide the maximum reasonable amount of affordable housing on-site, contrary to Policies H4 and H5 of the London Plan (2021), Policy DM15 of the Kingston Core Strategy (2012), the Mayor's Affordable Housing and Viability SPG (2017) and the NPPF (2019).
The applicant has failed to demonstrate through the submission of cogent and consistent evidence or robust justification that there is no quantitative or qualitative demand for the existing employment use of Tolworth Tower as offices, or for a range of alternative employment uses such as smaller and affordable offices. The scheme would also result in a net loss of ground floor commercial space and designated shopping frontages fronting Tolworth Broadway which could adversely impact the viability and vitality of the District Centre. The proposed development is therefore contrary to Policies CS12, DM17 and DM19 of the Kingston Core Strategy (2012) and Policies E1 and E9 of the London Plan (2021).
The applicant has failed to robustly demonstrate that the site is unsuitable to provide a minimum of 30% of dwellings as 3 or more bedroom units and no robust arguments or evidence has been submitted to demonstrate that a policy compliant provision of 3 or more bedroom units would be unviable. The proposed development would fail to contribute towards meeting the objectively assessed need within the Borough for 3 bedroom units. The proposed development is therefore contrary to Policy DM13 of the Kingston Core Strategy (2012).
The proposed tall buildings would conflict with the locational requirements of Policy D9(B) of the London Plan (2021) and the scale of the proposed tall buildings of the proposed design would compromise the comfort and enjoyment of the proposed private and communal open spaces within the proposed development contrary to Policy D9(3) of the London Plan (2021).
Through the submission of conflicting and insufficient information, the applicant has failed to demonstrate that the proposed development would provide sufficient levels of private and communal amenity space and child playspace. it has further not been robustly demonstrated that the proposed amenity space would be of a good quality given the incomplete assessment in relation to sunlight and overshadowing and the wind comfort levels of "standing" for areas of communal and private amenity space. The proposed development is therefore contrary to Policies DM10 and DM13 of the Kingston Core Strategy (2012), Policies D6 and S4 of the London Plan (2021) and the Kingston Residential Design SPD (2013).
Due to the identified inaccuracies with the submitted information in relation to car parking numbers across the site, Officers are unable to conclude that the proposed level of car parking is justified and that the proposed mitigation measures would be appropriate. No mechanism has been provided to secure the financial contribution towards the funding of a potential future Controlled Parking Zone (or to preclude residents from applying for car parking permits within any such designated zone) or Car Club membership for residents. It has therefore not been demonstrated that the proposed development would not increase on-street car parking stress and would not harm highway safety, contrary to paragraph 109 of the NPPF (2019) and Policies DM9 and DM10 of the Kingston Core Strategy (2012).
Insufficient information has been submitted to demonstrate that the proposed development would not increase flood risk on-site or elsewhere, contrary to the NPPF (2019), Policy SI 13 of the London Plan (2021) and Policy DM4 of the Kingston Core Strategy (2012).
The proposed development has failed to adopt a site wide approach towards heating and additional overheating measures and no legal agreement has been completed to secure the necessary net-zero carbon off-set payment. A robust Circular Economy Statement has not been submitted and the proposed development would fail to provide the minimum Urban Greening Factor score of 0.4. The proposed development would therefore be contrary to Policies SI2, SI7 and G5 of the London Plan (2021).
The applicant has failed to submit a robust Fire Statement which addresses the requirements of Policy D12 of the London Plan (2021) to the satisfaction of the Greater London Authority. It has therefore not been demonstrated that the proposed development would achieve the highest standards of fire safety, contrary to Policy D12 of the London Plan (2021).
No mechanism has been submitted by the applicant to secure the required financial contribution to mitigate the site specific primary healthcare requirements that would arise from the proposed development. The proposal is therefore contrary to Policies IMP 3 and CS13 of the Kingston Core Strategy (2012), the Planning Obligations SPD (2017) and Policy S2 of the London Plan (2021).