Northern Site, New Covent Garden Market 2022/4809
The Battersea Society objects to these proposals in relation to: affordable housing proposals, poor daylight and sunlight measures, low BREEAM rating, the manner in which the entrance pavilion blocks the open space and the fact that despite major design changes no Design Review has taken place since an initial review by CABE in 2014.
Affordable Housing
Yet again the affordable housing is focussed on smaller units and segregated on the lower floors of two blocks, N1 and N2. Of the 94 units, 43 are studio or single bed with a further 42 two-bed and just 9 three-bed. We do not think this will lead to a balanced community and would be surprised if this met the Council’s housing needs assessment.
Daylight and Sunlight Proposals
The document states that 54-57% of all habitable rooms will meet or exceed the relevant ADF targets. Sadly 46-43% will not. We assume that the majority of the poorest measures will affect the affordable housing on the lower floors. The document states that these measures are based on 2011 standards which we assume have been upgraded by the 2022 guidelines due to a quite proper concern for the health and well-being of residents. GIA comment on p.18 that:
“It should be noted that the new methodologies for the assessment of internal daylight set out within the, the daylight quality of the proposed scheme is considered to be equivalent to the consented RMA, as is demonstrated by the estimated ranges of compliance with the ADF criterion (2011 BRE Guidelines). As such, a lower ratio of rooms meeting or exceeding current recommendations under the illuminance method (2022 BRE Guidelines) is not considered to be caused by a lower daylight quality, but rather reflect the changes in assessment methodology.”
BREEAM
While the development was originally designed to meet only an Excellent rating rather than Outstanding this aspiration is now reduced to Very Good “due to the nature of the shell design”. Is it disingenuous of us to suggest that the nature of the shell design should be changed?
Entrance Pavilion
It is clear from 2022/4793 that the stand alone and staffed reception space will be seen as the entrance to a gated courtyard - at least seen from the north. This change from a reception space within a building to a building blocking welcoming access to open space to other than residents is to be deplored.
Design Review
We have lost count of the number of changes made since the original application back in 2014 (2014/2810). These have been considerable, not least changes in height and the change in the placement of the buildings. At the same time there have been changes to the context in which these buildings sit, with most of the surrounding developments changing from their original design to a greater or lesser extent. It is just not feasible to suggest that meetings with CABE to review very different proposals some 9 years ago* obviate the need for a Design Review Panel to assess these latest proposals. Even if at that time CABE were satisfied with changes made, these are now irrelevant.
We urge Wandsworth Council to convene a Design Review Panel to help them assess these latest proposals
In conclusion, this is now an opportunity for Wandsworth Council to demonstrate their concern for good quality design throughout Nine Elms, built to the highest standard, and to reject this application as it stands.