Commenting on Kelbourne Street

There was a significant amount of interest in a revised planning application for the development site beside the Happy Park at Kelbourne Street (23/03108/FUL). A number of residents brought their concerns to the January meeting of the Community Council, and it was agreed that the Community Council would supplement individual objections with their own response summarising all comments sent into them.

UPDATE: We submitted the following comments in response to the planning application on 1 February 2024.

We have been approached by a number of local residents who have raised concerns about this planning application. Areas of concern, and the Community Council’s objections, are noted below.

There have been a series of previous applications for this development site prior to the introduction of National Planning Framework 4. (NPF4)

The GCC website advises:

“This means that all applications are being assessed, including in some cases retrospectively, to ensure their compliance with NFP4 policies. Where a conflict with an NPF4 policy is identified this will, where necessary, involve re-assessment of the proposal and may require new engagement with applicants to address”

We have therefore drawn attention to NPF4 policies where relevant.

1: Consequences for the play park
Residents have very clearly communicated their concerns about the impact of this new development on the adjacent play park. The Happy Park is one of only two play areas with good quality play equipment within the North Kelvin Community Council Area. There are no equivalent play areas to the north at Wyndford, Ruchill and North Maryhill. It is therefore an important and well used resource.

Comments from residents received by the Community Council include:

“a particularly important and valued part of our local life for families.””

“I cannot emphasise enough how well used the Happy Park is and what a special role it plays in the childhoods of many local children. It is a social hub where families connect with one another and friendships blossom as children explore, play and develop. The current proposal risks undermining all of this and negatively impacting on the area and its community.”

“As local residents, we can only make a plea that the needs and protection of the community, particularly its youngest members, forms part of the planning and decision making is not entirely driven by financial gain.”

The daylighting assessment excludes any illustrations of the impact of overshadowing in the winter. Section 7 of the assessment advises

“The sunlight hours on the winter solstice indicate that the Proposed Development will limit the amount of sunlight reaching the park given the low sun angles.”

In other words, sunlight will be restricted during the winter, and it is likely that the area of the playpark to the north of the new building designated for older children will be significantly overshadowed at a time when sunshine is most important. Tree removal, and reinstatement of trees in an area of potentially deep shadow is unlikely to be successful.

A further concern relates to the period when building is in process. Having a building site in such close proximity to a children’s play park is extremely unsafe and might prohibit access to the park altogether for an extended period.

The development detracts from this important local amenity and does not align with NPF4 Policy 14 (c) “Development proposals that are poorly designed, detrimental to the amenity of the surrounding area or inconsistent with the six qualities of successful places, will not be supported.”

Nor does it align with NPF4 Policy 21 (b) which states “Development proposals that result in the quantitative and/or qualitative loss of children’s outdoor play provision, will only be supported where it can be demonstrated that there is no ongoing or future demand or the existing play provision will be replaced by a newly created, or improved existing asset, that is better quality or more appropriate.”

2: Overdevelopment
There is concern about the number of students who will be accommodated on the site.

1. The applicant’s Purpose Built Student Accommodation Need Assessment advises that students already comprise 27% of the population within a 400 metre radius of Kelbourne Street with  1,175 students currently housed at the Murano Street Student Village (which  is 391 metres away from Kelbourne Street, measured on Google Maps.)

2. On completion, the development at Kelbourne Street will shift the proportion of students to 29%, nearly a third of the total population in the area around Kelbourne Street. It is obvious that there is no shortage of student accommodation in the area.

3. Accommodation for 134 students, accessed from Kelbourne Street,  is also overdevelopment in terms of its immediate environment (the equivalent of 33 four bedroom flats, or 4 blocks of tenemental flats) and there is no outdoor space for students to use other than the children’s play park.

4. Residents have noted that there is already an increase in noise and litter from students accessing Murano accommodation along Queen Margaret Drive. This will increase significantly with 134 student flats.

5. The developer stated they were targeting “older students” however, this is not backed up by any guarantee.

6. There are concerns about rubbish collection and littering.

3: The scale of the proposed building
There is concern about the scale and height of the proposed building:

7. At seven stories tall, the height of the proposed building is significantly greater than that of the adjacent tenements at Kelbourne Street, which are four stories tall.

8. There are many historic (pre 1919)  buildings  in the area and this development will have a serious impact on their setting and character, weakening a sense of place and local distinctiveness.

9. It would occupy the entire space with no outside space of its own, other than a dubious plan for a “roof garden”. This means it would effectively impose on to public space on all sides in what is already a densely populated area.

The Community Council reiterates comments made in our response to previous planning applications – comparing the height of a flat-roofed building with the highest point of an adjacent pitched roof is not comparing like with like.

The scale of the development – occupying the whole site with very little greenspace – does not minimise potential adverse impacts on biodiversity.

(Refer to NPF4 Policy 3 (d) “Any potential adverse impacts, including cumulative impacts, of development proposals on biodiversity, nature networks and the natural environment will be minimised through careful planning and design.”)

4. Loss of amenity for residents
The development will adversely affect the quality of residential amenity in this area – it will overshadow other buildings and spaces, causing a loss of daylight to other people and places. It will also mean a loss of privacy for residents and tenants.

5: The planning process

Residents advise:

10. There have been no notices posted on adjacent lampposts or at the entrances to the children’s playparks (which would be so badly affected by this proposal)

11. Although the posting on the Planning website does refer to the previous applications for this site, the way that they are listed is not clear and it is difficult for members of the public to find their way to the page where they are listed.

12. The 23/03108/FUL application is presented as a “new” application.  But within the details it refers to the previous 20/00062/LOCAL, claiming that since that was passed – albeit by appeal – this new application “already has approval” for the form outline of the building.  Either this is a new application to be assessed from scratch, or it is a change of use application – it cannot be both.

6: Safety of the proposed building and the existing surrounding buildings
Concerns have been expressed about the impact of construction work on adjacent buildings and the potential for subsidence. This concern has been amplified by the unacceptable noise and vibration caused by construction work at recently constructed flats at Wilton Street. A long, protracted period of construction is likely to be involved causing disproportionate disturbance not only to residents but to all users of Queen Margaret Drive.

There are also concerns about the robustness of the flood risk assessment, and we reiterate the concerns of GCC’s Flood Risk Management Department who note that the recent National Planning Framework 4 states that development proposals must not increase the risk of surface water flooding to others and that the proposals have the potential to displace floodwater elsewhere.

7: Traffic management
There is concern about fast moving traffic in the area and the impact of extra traffic caused by drop off to the new development.

There is no parking proposed and there are concerns that students will park illegally, making it more difficult for residents to park their own cars.

8. Impact on Glasgow West Conservation area
The development site is directly beside the Glasgow West Conservation area and the scale, massing and height of the proposed building will

13. Detract from the area’s historic character.

14. Differ from the density, built form and layout of the conservation area

15. Deviate from the materials, siting and quality of design of buildings in the conservation area

Refer to NPF4 Policy 7 (d) “Development proposals in or affecting conservation areas will only be supported where the character and appearance of the conservation area and its setting is preserved or enhanced. Relevant considerations include the: i. architectural and historic character of the area; ii. existing density, built form and layout; and iii. context and siting, quality of design and suitable materials.”