Eden Campus Views

Residents response to Eden Campus Planning Applications, December 2020 - Kingston upon Thames.

[ Our earlier presentation based on the October 2020 application is archived here ]

This is not a 'campus'
The three towers of “Eden Campus” with offices for 2000+, a car parking building and 16 storey residential tower with NO Affordable Housing is proposed for the Surrey House island site at Eden Street. All three towers would breach Kington’s adopted planning guidance and national rules on Tall Buildings, and would cause unnecessary, avoidable harm to our Historic Town.

December 2020 amendment:
Residents are being re-consulted in response to the December updates: 16 Storey residential tower instead of 22 and zero Affordable Housing instead of 35%. The amendments published on December 10th are summarized here

Alternative approach #4
In response we have rewritten this website to analyse the issues and harm of this current gargantuan proposal. We show that addressing these issues leads to a much more sensitive alternative approach.

Our video presentation is here:

Submit your comments online or by email, again: development.management@kingston.gov.uk
Read why we oppose
20/02495/FUL – 10 & 11 Storey Office Towers and Car parking Building
20/02499/OUT – 16 Storey Residential Tower

Compared to the existing buildings on the site the updated scheme would be truly massive:

The updated scheme is just as bad as the scheme thrown out at appeal in 2019 for its harm to the Ancient Market Place:

December 2020 changes

On 1 December the applicant submitted an addendum to the Outline application: the residential tower. The revised description of the development is:

"‘Outline planning application for the demolition of Lever House and the erection of a Residential (C3)
(Private) building not exceeding 16 storeys comprising of a maximum 115 dwellings, along with a
ground floor café/retail pod (Use Class -E(c))with all matters reserved except for access, layout and

The key changes can be summarised as:

• Reduction in the height of the residential Building D from 22 to 16 storeys;
• The total number of residential units has been reduced from 156 to 115.
• The removal of the Affordable Housing.

The updated applicants views are as follows:-

Our response to the Planning Applications

It is vital that we take the time to respond to these planning applications again. Please let your views be known! You can comment directly using the links below, or even better email your response to development.management@kingston.gov.uk.

20/02495/FUL– 10 & 11 Storey Office Towers and Carparking Building
20/02499/OUT – 16 Storey Residential Tower


Eden Campus is the 3rd major development to seek Planning Approval in the ‘Eden Quarter’ after Eden Walk and Royal Exchange (TOPO, The Old Post Office). The Eden Walk and Royal Exchange developments were obliged to comply with the planning guidelines in the Eden Quarter Development Brief Supplementary Planning Document 2015 -the ‘EQDB’ - The proposals for Eden Campus disregard these requirements and the scale of the development proposed is dramatically bigger than either Eden Walk or Royal Exchange - 64% bigger than Eden Walk and 40% bigger than Royal Exchange! This is over development in the extreme.

Previous proposals for the same site were thoroughly evaluated and rejected in a Planning Appeal in late 2019 and these new proposals are equally bad if not worse in their impact.

In spite of 84% public objections made at pre-planning consultation the scheme was submitted for Planning without amendment. Only now at the request of Historic England and RBK have there been any amendments. The reduction in height of the residential tower is meant to appease these objections BUT it is not based on any thoughtful response to the harm the proposals would cause. The harm remains whether it is 16 or 22 storeys.

Our Council should not lose sight of its obligation to existing and future residents and our local community, to protect and enhance our existing historic environment. This planning application in its current form should be rejected for the 10 reasons set out below:

1.Harm to Heritage Assets and their settings, Visual Impact & Conservation Areas

If permitted, the proposals for Eden Campus would have significant detrimental effects on Kingston’s multiple Heritage Assets and their settings as seen from various strategic points around the town, many of which are designated as Very Important Views and worthy of protection from harm. The current proposals are guilty of exactly the same harm to heritage assets (and more) as the scheme which was rejected at Appeal in 2019.

The Market Place is Kingston’s crown jewel, and the damage to it would be irreparable if these proposals are permitted. The Market Place and its medieval street pattern is noted as one of the best-preserved examples in outer London. When we as residents and visitors enjoy the ambience in the Market Place it is largely untouched by any modern buildings encroaching on the views. The skyline has remained unchanged for centuries. These proposals would ruin this unique experience and be dominated by an unwelcome and overbearing series of huge modern buildings totally at odds with the medieval skyline.

The site sits amidst multiple historic assets and conservation areas in Kingston Old Town Centre. In particular the Old Post Office and United Reformed Church. It shows no deference to any of these nor does it make any attempt to blend in. The buildings are completely out of scale and out of context for the site conflicting with the low-rise character of the historic town centre and the adjacent residential Conservation Areas. The village-like form of the Kingston Old Town would be dominated by this urbanizing group of structures completely alien to the adjoining streetscape and townscape surroundings.

The EQDB* specifies that the height of ALL buildings on this site should be limited to 6-8 storeys. This was for good reason, to protect the settings of heritage assets within the adjacent areas.
The buildings proposed for Eden Campus are so high that they harm the settings of all the heritage assets in the same ways identified by the Planning Inspector in the 2019 Appeal.

2. Height & Scale

If it goes ahead this development will have THREE buildings which are classified as TALL buildings and controlled by the London Plan. The London Plan says that buildings like this are not to be proposed unless the Local Plan has “designated” a location for a tall building. Why is that? The reason is the higher a building is, the more its impact is felt over a wider area. Some areas are NOT suitable for Tall Buildings because of the harm they cause to what is around them. This site is one of those areas NOT suitable for Tall buildings..

There is only meant to be ONE tower that marks the southern entry into Kingston, This is the one at Royal Exchange (TOPO). This is clear from the EQDB which is an integral part of the Kingston Development Plan.

Kingston residents fought hard to limit the height of that ONE signature tower to 16 storeys (it had been proposed at 21 storeys). For the developer next door to propose a 22 storey tower - now reduced to 16 storeys (sound familiar?) is a cynical attempt to dupe the planning department. Coupled with an 11 storey tower in the complex and justified as a “cluster” makes a complete mockery of Kingston’s Planning Guides AND of the residents' hard fought previous campaigns. There has been no Public Consultation which could justify any changes to the principles set out in the EQDB limiting Tall buildings which was adopted after due process and consultation with residents.

The 16-storey tower destroys the view of the Guildhall from where the Hogsmill River meets the Thames. This view is one of only 13 designated to be protected as a “ Very Highly Important View” by the Council in 2018! It is beyond comprehension why the Planners did not make it clear to the developer that NO building taller than the existing Lever House would be contemplated on the strength of this view alone. To allow this would be a dereliction of duty on the part of our elected Councillors.

Moreover, the 16 storey tower would overlook and overshadow the whole neighbourhood of the adjacent residential Conservation Area. It would loom over many individual houses and residential streets with negative impacts on privacy and amenity. It would cast a shadow over a significant part of the residential area compared to the current situation with Lever House.

The very high Office Block on Eden Street would overcrowd and obscure the views and appreciation of the Grade II Listed United Reformed Church and the Old Post Office and create an unwelcome barrier between the residential Conservation areas and the Kingston Old Town Centre - If approved the impermeability of the new layout will destroy Council’s new pedestrian linkages.
The height of the block on Brook Street would create a cavernous street completely alien to anything anywhere else in Kingston and more akin to the City of London not our Historic town.

3. Affordable Housing

The developer is claiming ‘poverty’ and intends to provide zero affordable housing. This cannot be right for a scheme of this scale.

Kingston Councils' Affordable Housing SPD states "The financial implications of complying with the affordable housing policy need to be factored into the land value when purchasing a site. If no regard is paid to these implications the resultant financial consequences will have to be borne by the developer."
Therefore this should have been evaluated on the basis of the extant planning policies including the EQDB. It is unacceptable for the developer to contend - as they have- that the residential tower needed to be 22 storeys to “fit in” the Affordable Homes in their validation but now that its reduced to 16 storeys that is no longer viable. The developer is creating a huge amount of prime office on the site. It is frankly inconceivable that this alone does not pay for the entire development.
Housing is an extremely strong concern for residents but is always used as a weapon against residents by developers. In our experience, residents rarely say no to truly affordable housing. No sane person believes that Kingston’s housing needs will be addressed by more luxury developments with prices far in excess of those which most residents could truly afford. Why doesn’t the council just get on with developing the Cattle Market - where we could get considerably more homes on a site we own rather than allowing the developer here to provide zero Affordable Homes but allow them to profit from 115 UNaffordable flats all at the expense of the historic town centre.

4. Density

Due to its excessive bulk, scale, height and massing, the development would fail to meet the requirements as set out in the EQDB which remains a material consideration for ALL planning applications It should be noted that many during the consultation process considered this Supplementary Planning Document to be more than generous in it's height guidance so it is unacceptable for these constraints to now be ignored.

5. Sustainability

The developer’s claim that the proposal is the most sustainable option is disingenuous when they plan to demolish a perfectly good office and multi storey car park only to rebuild them both with buildings with exactly the same functions. This is unconscionable in the current climate. These buildings could be retained and refurbished this is the ONLY sustainable approach. We can and should Recycle Buildings- not just bags! We should be upgrading existing buildings for extended use as a more carbon efficient alternative to demolition and new build whenever there is a viable choice.
Put simply the greenest building is the one already built - they should not pretend otherwise.

While the project may meet some sustainability requirements, small landscape adjustments and creating a slightly better river bank will not be enough to offset the damage created by demolishing two existing concrete buildings.

6. Parking, Transport, Infrastructure and Services

The submission largely underestimates the need for and impact on parking, transport, infrastructure and local services. This is already a busy and congested island and the additional office cars and residential drop off will exacerbate the traffic congestion- which incidentally will make the so called Hogsmill Park even more unpleasant.

7. Ineffective public consultation

The submission lists who and how much consultation was carried out but belittles voluntary community involvement and work took place during the consultation. Despite the applicant’s protestations regarding a single site, the overwhelming response from the community is inaccessibility of information and clear answers from developers. Some issues listed below:

The period between the two consultations was too close for them to have considered feedback and make any meaningful adjustment to plans. (The first started on 29th June, the second on 3rd August, barely 4 working weeks between them.) This was just paying lip service to the process. The consultations were pointless and people who reserved their comments for the final exhibition were very disappointed with the lack of progress. This is the real reason why most reserved their opinions in the first one and opposed the proposals in the second consultation.

In terms of usability, the exhibition website designed for the consultation was very poor. The image carousel did not work or was too slow on some handheld devices. The comments page did not work on some phones. Most downloaded PDF version in order to “view” the site but probably did not try to comment via email. People did not spend more than 2 minutes and 55 seconds (according to the Applicant’s report) because there was really not much to see.

Both consultations lacked verified key views. In particular, the absence of tall buildings angle was notable in the limited number of visuals provided. This was demonstrably misleading as it gave no clarity of how these buildings will be seen in context. The proposals dwarf the scale and massing of Royal Exchange and Eden Walk.

There were no hard copies for anyone who was not able to view and/or download materials on line.

There were no webinar or Zoom-type arrangements for residents to “meet the Architect/Developer”. The text-based “chat” facility was useful but this should not have been the only means for Q&As. It is not something that all residents would use comfortably and showed a lack of awareness of the needs of different demographic groups in the community. The developers do not seem to have made any real effort to involve the community but rather have seen it just as a hurdle to overcome at the last minute.

Covid has been used as an excuse. The applicant did not display their plans anywhere in the town. Expecting everyone to be able to read small architectural visuals or on the same digital footing in terms of accessing the online presentation fully was frustrating for some.

Residents wanted to find out more about what the “Corporate Campus” would look like and explore the issues around the permeability to the town centre and from neighbouring residential areas. None of these could be explored in their image carousel. A large 3D model or printouts could have improved the legibility of the plans.

8. Public Realm

In the published EQDB the Council promised us a public square in front of the United Reformed Church and Old Post Office Building. This was meant to be a new public space to balance the market place and be an area to meet and enjoy the heritage assets whilst shopping. What happened to that promise? What is created in the drawings is a space purely for the occupiers of the building . The curve of the building denotes the movement of the street it does not create a space. A stepped entry to the building is hardly a public square by any leap of the imagination.
The view of the Old Post Office and United Reformed Church facades are obscured from entry points to the “square” by the corners of the building. The developer is desperately trying to persuade us that the works to the Hogsmill River is for the public benefit, but this IS already PUBLIC LAND. It is clearly being purloined into the grounds of the 16 storey tower to add value to their asset and provide views for the residents. The tower is damaging and harming the value of the towns Heritage Assets, - protected views of listed buildings and effectively appropriating publicly-owned land – to add value to their own. To add insult to injury, the main terrace overlooking the Hogsmill will be private.
Clearly the public are not welcome in the ‘Woodland Walk’ in the centre of the development. There is no way to see a way out through the space and it offers no short cut. The entrance by the tower will be gated and is very narrow and at the other end there is a service yard- hardly somewhere pedestrians will want to walk through or to. It is obvious, and by design, that the public is not meant to come into this space, gate or no gate.
The Woodland Walk is the same shape and size as the Apple Market but with 3 huge buildings and a 16 storey tower the space will see practically NO sun at any time of year. The developer shows pretty, sundrenched perspectives but their own daylight study shows this is far from the truth. Even in the height of summer this area will be in perpetual shade apart from a tiny bit at the entrance to the office for an hour or so ….It doesn’t sound very attractive.

9. Kingston ‘Arc’ Question

If the Eden Campus Towers are approved this would create a very dangerous precedent which will be used by developers for ALL new sites surrounding Kingston’s Historic Centre. We have already seen the developers of Surrey County Hall point to Eden Campus as justification for proposing one and possibly two 17 storey towers as part of development “Arc” round Kingston. This is unacceptable, there is only meant to be ONE tower that marks the southern entry into Kingston, the one at Royal Exchange (TOPO). Eden Campus developers seek to justify their tower on the basis that there are tall buildings next door and so it goes on!
To our knowledge Kingston Planning guides and consultations NEVER envisaged clusters of towers. The Government’s own advisor, Historic England, says clearly that just because there may be one tall building in a location does not justify others to be proposed to make a “cluster”. How can the council ignore not only its own planning guides which were the subject of extensive public consultation but also the clear directives of the London Plan and Historic England? To allow this would be a dereliction of duty on the part of our elected Councillors.
We feel very strongly that this dangerous precedent MUST NOT be allowed to go ahead especially as

Our alternative approach #4

The current proposal would have 16 storeys of residential instead of 22. This new quantum brings the opportunity for a new alternative approach to developing the site. We present alternative approach #4, supported by our design development in later chapters.

With this new approach we aim to fix the current proposals' problems:

We commissioned a further alternative approach to be :-

And if Lever House were to be demolished, any replacement should NOT be more harmful

Our Alternative Approach would SATISFY (i) Less Harm (ii) Similar Density to Eden Walk and Royal Exchange …AND (iii) Sustainability

Harm to Settings of Heritage Assets

Proposing a tower of 16-storeys rather than 22 would be less bad, but 3 buildings would remain ‘cumulatively harmful’ to the settings of multiple heritage assets - in the Ancient Market Place, the Guildhall, the Old Post Office and United Reformed Church and beyond

Harm would be caused across the whole of the Kingston Town Conservation Area affecting the settings of numerous Heritage assets and Conservation Areas

3 Buildings proposed at Eden Campus would still be MORE HARMFUL than the proposal rejected at Appeal by the Secretary of State in 2019

The offending proposed buildings are clearly identified using Vu City and by comparing the bulk and overbearing massing towards Union Street, the United Reformed Church (URC) and the Ancient Market Place

Heights above Ground marked in red identify which parts of the proposed development would cause harm to settings in the Ancient Market Place

The reduced Height Tower would STILL cause harm to the setting of Grade II listed Guildhall identified as Very Highly Important View in the RBK View Study Report 2018 and to the Grade 1 listed All Saints Church by competing on the skyline and obscuring the Signature Tower at Royal Exchange.

*Very Highly Important View, RBK View Study Report 2018

The proposed insufficient set back of the block on Eden Street would prevent Eden Square from being formed and the Old Post Office (OPO) façade would not be revealed as envisaged in Eden Quarter Development Brief (EQDB). The URC would be dwarfed by the gargantuan and alien architecture proposed

Any building replacing Lever House SHOULD BE NO HIGHER to enable a transition between the 16-storey tower at Royal Exchange and the adjacent 2-3 storey residential Conservation Area AS POLICY D9 OF THE ITP LONDON PLAN

Gross and unnecessary Overdevelopment

Gross overdevelopment of Eden Campus proposals are confirmed by Plot Ratio figures - Eden Campus would be 64% more dense than Eden Walk development, and 40% more dense than Royal Exchange.

Why is this important ? Put simply Plot Ratio means how much is built up on a site and therefore impacts its value $$

The current office proposal appears to be more than Unilever require according to data provided so could be scaled back to eliminate unnecessary and unjustified harm - without threat to jobs - especially in a post Covid world

Reducing Bulk of Current Proposal to Lessen Harm

The height, form and massing of existing proposals would need to be reduced as shown below to lessen (not eliminate) cumulative harm

This would result in a more acceptable scale of development based on analysis of impact of cumulative harm to settings of various Heritage Assets

The setting back of the Eden Street Office Block as per the EQDB and setting back 5th Level would dramatically reduce the bulk and would be more respectful of the OPO and URC Heritage assets.

The reduced bulk at the corner of Eden Street / Union Street / St James Road would vastly improve streetscape at this key junction - compared to the current scheme

Vu City reveals there would be a huge lessening of harm to the settings of heritage assets, but massing would be at the upper limit

Even an 11-storey (38m) residential tower would arguably STILL BE TOO HIGH because of its impact on the Knight’s Park/ Fairfield Park Conservation Area compared to the current 7-storey office Lever House (35m)

Making the reductions in massing described above would solve items 1 and 2 BUT would not address sustainability issues - The need to solve for ALL these important criteria has led to the development of the alternative presented in part 4

There is no justification to demolish and rebuild an office building and multi storey car park on the same site. Buildings-in-use efficiencies will never offset the harm incurred at the outset during construction.

The Most Sustainable AND Least Harmful Approach

Unilever takes ESG (Environmental, Social and Governance) very seriously. Indeed they have just announced plans to take their green agenda straight to shareholders and markets, for approval!
This must include emissions from construction in this equation.

SUSTAINABLE APPROACH DEVELOPED: Addressing these key issues with seriousness and integrity could result in a meaningful piece of Architecture that Kingston could be proud of, not one that destroys the settings of so many key Historic assets

The Scheme we have presented would function better at the Ground Floor with:-
Public space where it is most usefulEden Square created as the destination as envisaged in the EQDBOptimal positions for commercial, retail and residential componentsBetter connectivity for people and vehicles

The Scheme we have presented would provide more than enough space for the 2,000 anchor staff and could support 2,500 – 3,000 i.e. more jobs, and no North facing residential units.

We believe this approach can guide the development proposals towards a less harmful, less dense and more sustainable solution that would work for all stakeholders who wish to invest in, work in, live in and visit Kingston.


What can I do?

All Kingston residents are urged to view the submitted planning applications for the proposed redevelopment of the Eden Campus for themselves via these links:-

20/02495/FUL– 10 & 11 Storey Office Towers and Car parking Building
20/02499/OUT – 16 Storey Residential Tower

It is vital that we take a moment to respond again to these planning applications. You can comment directly using the links below, or even better email your response to development.management@kingston.gov.uk. Especially when the site can crash quite frequently.

Online comments have reopened until 10th January 2021, OR you can email your comments to the planning department address: development.management@kingston.gov.uk

Please do not lose this opportunity to let your views be known to both the developers and to your local councillors (contact details below). Our message to the Council is that the requirements of the EQDB MUST be followed – FULL STOP..... and they should send the Developers back to the drawing board

Also Good:
Email your MPs & Councillors:

Your MPs
The Leader of Kingston Council
Director, Growth
Development Committee Members
Cllr Roy.Arora@kingston.gov.ukCllr Kim.Bailey@kingston.gov.ukCllr Mark.Beynon@kingston.gov.ukCllr David.Cunningham@kingston.gov.ukCllr Lorraine.Dunstone@kingston.gov.ukCllr Simon.Edwards@kingston.gov.ukCllr Lesley.Heap@kingston.gov.ukCllr Rebekah.Moll@kingston.gov.ukCllr Malcolm.Self@kingston.gov.ukCllr Stephanie.Archer@kingston.gov.ukCllr Dave.Ryder-Mills@kingston.gov.uk
Grove Ward Cllrs
Jon.Tolley@kingston.gov.ukFiona.Boult@kingston.gov.ukCllr Rebekah.Moll@kingston.gov.ukContact your Councillor

Other Cllrs & Other
Cllr Kevin.Davis@kingston.gov.ukCllr Sharron.Sumner@kingston.greenparty.org.ukLaurie@kingstonlabour.com


There are some healthy debates on issues raised by this proposal and by development in general. Here are some points we would like to add to this conversation.

1) Are Unilever definitely moving to Kingston?

Unilever have been a tenant on this site since 1973 and their lease runs for 99 years.
In addition there is talk of Unilever moving their desks from other locations to consolidate their UK HQ in Kingston, but this is far from certain. On October 2nd Unilever announced plans to “bring together around 2,000 employees from five existing sites in London and Surrey” There was no mention of an “HQ”.
Corporate relocation plans are subject to many considerations and are difficult to predict so we wouldn’t want to put any certainty on it. In any case this is a red herring because this is not a planning consideration.

2) Is what they are proposing actually a campus?

No. Calling the development “Eden Campus” creates a number of misleading impressions, Campus is “the grounds and buildings of a university or college.” - this proposal is neither. It gives the impression that the architecture reflects the needs of modern offices and residents – which it does not.

3) Is this proposal environmentally sustainable?

No. Demolishing and rebuilding concrete structures on the site will never be sustainable. Adding green walls and solar panels will never offset this huge initial environmental cost.

4) Is this cluster of towers part of the town plan?

No. Tall Buildings are limited to three locations defined by the ‘Eden Quarter Development Brief EQDB’. This site is not one of them.

5) Is their proposed landscaped public space at the Hogsmill significant?

No. The area at the Hogsmill river which appears in their drawings as a landscaped public realm is not under their ownership. According to the title deeds for the site, ownership ends at a fence line a few feet north of Lever House. Perhaps Kingston Council should make this boundary issue clear with the developers.

6) Post pandemic, Kingstons' high street is dying. Shops are empty. Why don't we welcome this as progress?

We are not against development on this site, on the contrary we actively encourage Council and owners of the site to do the best they can and bring more investment and revenue to our town. However are luxury Tolworth Tower blocks with unaffordable residences the answer?

This is a rare opportunity and we need to make the most of it. Unfortunately with the current design we are on course to end up with a poor solution that would be far more harmful than it needs to be. We can get the same benefits for the town without the harm and we openly offer alternative ways forward here.


Please contact us via kingstonresidentsalliance@gmail.com
or use the form below

Thank you

We appreciate your support.