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Ten Key Planning concerns for the Native Land / TfL redevelopment proposal

Our planning consultant and our heritage consultant have confirmed that this scheme breaches a dizzying number of established RBKC planning policies.

Not only would these breaches be detrimental to South Kensington, but permitting them would give developers a green light for large-scale demolition and rebuilding with extra floors in all of the Conservation Areas in RBKC.

1. The demolition of the Bullnose and its replacement by a looming building

This will:

  • Result in the entire loss of the distinctive Bullnose corner of shops.

  • Harm the setting of the listed tube Station Arcade with its recently restored clear glazed roof, by casting it into shadow and blocking out views of the sky from within the Arcade.

  • Block key protected views of the Natural History Museum towers, as well as views of the V&A cupola.

  • Dwarf the listed Station entrance and Arcade.

  • Change the pattern and form of development from individual shop units to uniform, corporate frontage.

  • Fail to respect the human scale and segmented layout of the existing Bullnose.

  • Result in the loss of the distinctive low level urban form and modest character of the original Bullnose and Arcade which historically has formed the centre of South Kensington and which gives it a unique sense of space and openness that fully complements the pedestrian open spaces and human scale to the north and south of the Station.

  • Dominate and enclose the public realm to its detriment.

2. The unjustified demolition of the 20-34 Thurloe Street terrace, a heritage asset acknowledged to make a positive contribution to the Conservation Area

(all but the front facade of the terrace will be lost). This will result in the:

  • Loss of historic examples of interdependent residential and retail units, from basement to attic.

  • Loss of attractive individual doorways to residential accommodation and entrance features.


  • Loss of original architectural rhythm of ground floor with shops and residential entrances alternating in a specific pattern.


  • Loss of opportunity to restore original shopfront design including lights to original individual shop basements (as at Medici).


  • Demolition of the Thurloe Street terrace does not generate public benefits relative to refurbishment.


  • Loss of the highly distinctive brick rear elevation of the Thurloe Street terrace which sits attractively within the Conservation Area and complements the near contemporary period buildings of the Station itself. This Victorian rear façade is visible from the Station platforms and in views across the Arcade from the south and south west. Its proposed replacement with an overtly modern design will seriously damage the Victorian character of the Conservation Area.


  • Create a massive basement retail space across entire length of terrace, wholly out of keeping with small shop units which characterize this terrace and area north of the Station.

3. The addition of a mansard storey on the roof of the Thurloe Street terrace with large lift shafts and engineering plant above it

This will:

  • Dwarf the adjacent listed terrace, harming its setting.


  • Be highly visible in protected views down Exhibition Road.


  • Destroy the original roof structure which currently complements the neighbouring listed terrace--which does not have a mansard.

4. The formation of a 5 storey development plus additional 2.95m high services part- floor on Thurloe Bridge

This will:

  • Seriously harm the setting of Grade II* listed buildings on Pelham Place in terms of inappropriate scale, massing and design.


  • Produce a scale of development based erroneously on that of Thurloe Square.


  • Prevent opportunities to improve the public realm on a prominent corner site.


  • Prevent improvements to pavement width and pedestrian safety on a busy traffic corner where many pedestrians cross.


  • Result in the loss of an important “gap” and the sense of openness and space on the corner of Pelham Street and Thurloe Bridge.

5. The development of a four storey block in Pelham Street with an additional fifth storey at the Station end of the street.

This will:

  • Block daylight to residential properties on Pelham Street.


  • Create a “canyon effect” along Pelham Street (in the applicant’s technical advisor’s own words) and an oppressive sense of enclosure for residents and pedestrians.


  • Breach building proximity guidelines, causing loss of privacy to existing homes.


  • Seriously harm the character and appearance of the Conservation Area as  scale and massing fails to respect the historic townscape character of the street.


  • Harm the setting of the Grade II * listed Pelham Place due to both excessive mass and height, and the discordant style of architecture.


  • Create servicing and delivery problems which will cause noise and disturbance for existing and future residents.


  • Create servicing and delivery problems hazardous to highway safety on a narrow road.


  • Block views of the landmark V&A cupola between 2-12 Pelham Street.


  • Block views of open space across the Station towards trees and greenery.


  • Prevent opportunities to improve the public realm (eg widen pavement/road).

6. The inappropriate standard of design of the whole development

The scheme fails to respond to the key characteristics of good design set out in the October 2019 National Design Guide. The development’s design makes no reference to its context, local vernacular, or the heritage of this historic Station, or the wider character of the Conservation Area.  This will:

  • Be harmful to the key qualities, character and appearance of the Conservation Area.


  • Undermine the unique heritage assets associated with the Station site.


  • Harm the setting of listed buildings.


  • Create an oppressive, overbearing development which fails to integrate with the grain and scale of existing built development.

7. The wholly inadequate and badly sited refuse, servicing and loading facilities in Pelham Street

Refuse storage is very limited and remote from both residential and commercial premises. Servicing and loading areas are off site and inadequate.  This will:

  • Result in unauthorised dumping of waste on street.


  • Force residents and collection agents to trolley waste along the pavement of Pelham St to temporary stores.


  • Create noise and disturbance for all residents as large volumes of waste is removed from the central waste stores in Pelham Street.


  • Cause disposal vehicles to block the highway for long periods whilst  removing high volumes of waste from the central stores.


  • Create hazardous highway safety conditions with loading and unloading on double yellow lines.


  • Require goods to be trolleyed along the length of Pelham St from the remote loading bay.


  • Result in the loss of public open space to the south of the Station to create a lorry loading bay.


  • Result in a lorry bay hazardous for pedestrians within the public space and those crossing the roads around it.


  • Harm the appearance of this focal point within the recently redesigned and improved public realm.


  • Reduce the area of public space in a prime location.


  • Create, with the refuse storage facility down Pelham Street, a visually unattractive and inappropriate facility to the residential units overlooking it, representing serious loss of amenity.

8. The inappropriate introduction of retail units on Pelham Street

This will:

  • Lead to an oversupply in retail space.


  • Prevent opportunities to provide office space instead.


  • Endanger pedestrian safety - A recent planning appeal found that the pavements along Pelham Street were of insufficient width to accommodate retail development along their frontage. Reference: APP/K5600/W/16/3144714.

9. The failure to make any improvements to pedestrian and highway facilities

within the vicinity of the site.  The development will significantly increase pedestrian flows around the Station and along Pelham Street. This will:


  • Fail to improve, or provide new pedestrian crossing points, particularly at the Bullnose and at the Station end of Pelham Street;


  • Fail to increase the pavement as required to accommodate retail frontages;


  • Fail to increase road width to allow two HGVs to pass in Pelham Street without mounting the pavement. 

10. The failure to deliver an appropriate level of public benefits:

• Step free access is a public benefit but is a London Underground operational requirement which should be delivered independently of the ASD.


• The 35% by floor space minimum target for community housing is not met—the scheme delivers 27% by floor space. All of the 27% is intermediary housing rather affordable.

Please Note:  The list above is not exhaustive. For example, the full breakdown of the number of residential units proposed and the floor area and mix of retail / commercial uses is not yet known.  These and other points may present further areas for concern.