TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Site visit made on 2 September 2025 by N Kempton BAHons, PGDip, MA, IHBC, MRTPI an Inspector appointed by the Secretary of State Decision date: 14 November 2025 Appeal A Ref: APP/X5210/W/25/3367116 Pavement Opposite, 35 Red Lion Square, Drake Street, London WC1R 4SG • The appeal is made under section 78 of the Town and Country Planning Act 1990 (as amended) against a refusal to grant planning permission. • The appeal is made by Mr Nathan Still of In Focus Public Networks Limited against the decision of the Council of the London Borough of Camden. • The application Ref is 2025/1326/P. • The development proposed is described as ‘upgrade of existing telephone call box with affixed advertisement display’. Appeal B Ref: APP/X5210/H/25/3367118 Pavement Opposite, 35 Red Lion Square, Drake Street, London WC1R 4SG • The appeal is made under Regulation 17 of the Town and Country Planning (Control of Advertisements) (England) Regulations 2007 (as amended) against a refusal to grant express consent. • The appeal is made by Mr Nathan Still of In Focus Public Networks Limited against the decision of the Council of the London Borough of Camden. • The application Ref is 2025/1453/A.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions • The advertisement proposed is described as ‘upgrade of existing telephone call box with affixed advertisement display’. Decision 1. Appeal A - The appeal is dismissed. 2. Appeal B - The appeal is dismissed. Preliminary Matters 3. In the banner headings above, I have taken the description of development from the original application forms, respectively. The pair of appeals relate to the same overall proposal. They differ only in that Appeal A is for planning permission to upgrade the telephone box, by replacing it with a more contemporary version incorporating a digital panel, which would be mounted on the pavement. Appeal B is for advertisement consent for the display of a single illuminated and sequential portrait display integrated within the replacement telephone box. I have considered each part of the proposal on its individual merits. However, to avoid duplication I have dealt with the two parts of the proposal together, except where otherwise indicated. 4. In respect of Appeal B the Town and Country Planning (Control of Advertisements) (England) Regulations 2007 (the Regulations) require that applications for the display of advertisements are considered only in the interests of amenity and public safety.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions In my determination of Appeal B I have had regard to the development plan policies cited on the Council’s decision notice where material. https://www.gov.uk/planning-inspectorate

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions In my determination of Appeal B I have had regard to the development plan policies cited on the Council’s decision notice where material. https://www.gov.uk/planning-inspectorate

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Appeal Decisions APP/X5210/W/25/3367116, APP/X5210/H/25/3367118 However, I am not obliged to determine the application in accordance with them in the same way as for Appeal A. Main Issues 5. The main issues in relation to Appeal A are: the effect of the proposal on the character and appearance of the street scene, with particular regard to the setting of the Bloomsbury and Kingsway Conservation Areas; the effect on highway safety and pedestrians; whether the proposal would increase opportunities for crime and anti-social behaviour; and whether appropriate provision is made for maintenance. 6. The main issue in relation to appeal B are the effect of the proposal on the amenity of the street scene; and the effect on public safety. Reasons Character and appearance and amenity (Appeals A and B) 7. Red Lion Square is a historic garden square in Holborn. It is a central public garden with mature trees, benches and paths. It is a peaceful oasis amid the busy, vibrant Holborn area. The square is enclosed on three sides by Georgian and Victorian architecture, with elegant facades, which shape its visual and cultural significance and positively contribute to its historic character.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Surrounded by commercial offices, educational institutions and residential buildings, the character of the area is both residential and professional. 8. Drake Street, which is opposite and connects to Red Lion Square, is shorter and more utilitarian in appearance. It is primarily lined with civic buildings, early to mid- century office buildings and service entrances. Drake Street forms part of the Holborn gyratory and is a busy road for both vehicular and pedestrian traffic. It is a local bus stop served by several routes within a dense transport corridor. 9. The appeal site is located adjacent to, but beyond, the boundaries of both the Bloomsbury and Kingsway Conservation Areas (CAs). The significance of the Bloomsbury CA primarily derives from its architectural and historic interest, containing garden squares (including Red Lion Square) and iconic buildings reflecting a strong classical and Georgian influence. The appeal site features in longer views towards this CA and therefore lies within its setting. The significance of Kingsway CA is mainly attributable to its ambitious Edwardian urban planning, its architectural grandeur and coherence, and historical transformation of central London.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions The configuration of Red Lion Square and Drake Street, as outlined above, contributes to the area’s civic character, heritage value and evolving public realm, and provide a setting which serves to reinforce important qualities of these CAs. 10. There is an existing telephone kiosk located at the appeal site. Sited near to the surfaced pavement edge, the existing kiosk has an advertising window to one side, with a paper advert, which requires manual updating. 11. My observations of the existing kiosk and immediate surroundings were that it, together with other nearby digital advertisements, bus stops, road signage, cycle storage and assorted street furniture, cumulatively amounted to negative aspects in the street scene. Their number, varied placement and styles give an incoherent impression, distracting from the architectural coherence, ordered public realm and legibility of the street scape. As such, the appeal site presently weakens the https://www.gov.uk/planning-inspectorate 2

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Appeal Decisions APP/X5210/W/25/3367116, APP/X5210/H/25/3367118 character and appearance of the area. Although relatively small, it nevertheless, represents a harmful distraction in views on the approach to both CAs, traversing the short space between them, as well as in some views from Red Lion Square itself. 12. The proposed kiosk would replace the existing telephone kiosk. The illuminated and sequential display would be integrated within the proposed kiosk and sited close to the outer edge of the paved footway. This would result in the kiosk appearing conspicuous and unduly prominent within the street scene and more readily apparent in longer views in both directions along Drake Street, and in views from Red Lion Square. It would therefore give greater emphasis to the negative attributes I have identified arising from the present kiosk. 13. As such, the proposed kiosk would exacerbate the level of street clutter in the immediate vicinity. It would lead to an over concentration of street furniture and visual clutter that would erode the quality of the public realm. Consequently, it would have an unacceptable effect on the street scene, and the setting of the nearby CAs. 14.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions I accept that the proposed luminance levels would accord with industry recommendations and that this could be secured by a condition. Additional limitations relating to static images and the timing of sequential images would further restrict the visual impact of the advertisements. Notwithstanding this, the appeal proposal would, as a result of the internal illumination and moving images associated with the panel, and its pronounced position in the public realm, create a discordant feature within the street scene. It would add visual clutter, which would intrude into vistas, framed streetscapes and historic facades. Hence, the proposed kiosk would distract the eye and detract from the visual amenity of the historic environment. 15. In relation to Appeal A, I find that this would result in unacceptable harm to the significance of both CAs owing to the harm arising through development within the setting of these designated heritage assets. In both cases, this would be less than substantial harm at the lower end of the scale. 16.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Paragraph 215 of the National Planning Policy Framework (the Framework) states that where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use. In relation to Appeal A, the removal of the existing kiosk would be a benefit that would attract modest weight. The provision of free services to the public such as phone charging, free calls, internet access and a defibrillator also weigh in favour of the proposal. However, even if taken together, the public benefits before me are not sufficient to outweigh the harm identified. The harm must be considered in the context of paragraph 212 of the Framework, which establishes that great weight should be given to the conservation of each designated heritage asset. 17. Therefore, Appeal A would conflict with the following policies of the London Borough of Camden Local Plan (CLP) 2017: Policy D1 Design, which amongst other things seeks high quality design that integrates well with surrounding streets and safeguards the historic environment.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions In addition, Policy D2 Heritage, which focusses on protecting and enhancing the borough’s rich heritage assets and their settings, ensuring that development proposals respect Camden’s historic https://www.gov.uk/planning-inspectorate 3

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions In addition, Policy D2 Heritage, which focusses on protecting and enhancing the borough’s rich heritage assets and their settings, ensuring that development proposals respect Camden’s historic https://www.gov.uk/planning-inspectorate 3 Appeal Decisions APP/X5210/W/25/3367116, APP/X5210/H/25/3367118 environment and contribute positively to its character. This policy aims to resist development outside a conservation area that causes harm to the character or appearance of a conservation area. 18. For similar reasons, I find Appeal B would result in unacceptable harm to the amenity of the area. Highway, pedestrian and public safety (Appeals A and B) 19. Drake Street is a bus route and a busy road for vehicular and pedestrian traffic, with pedestrians accessing the commercial premises which front onto the pavement and the road’s bus stops and nearby underground (tube) station. 20. The siting of the proposed kiosk would restrict the width of useable and unobstructed pavement, thereby impeding pedestrian flow. However, the proposed kiosk would replace the existing kiosk and occupy the same site. No pedestrian count data has been provided by either party in support of their case.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Whilst the proposal site lies within the civic corridor and on a busy commercial street where pedestrian volumes are likely to be high, the evidence before me does not show that the existing kiosk has negatively impacted upon highway, pedestrian or public safety, or demonstrate that the proposed kiosk would exacerbate safety concerns. 21. Nevertheless, Policy T1 Prioritising Walking, Cycling and Public Transport of the CLP requires development proposals to improve the pedestrian environment by supporting high quality public realm improvement works. The development in respect of Appeal A does not demonstrate how it would improve the pedestrian environment, rather it would remain an obstacle to it. 22. As such, in relation to Appeal A, the proposed kiosk would not comply with the following policies of the CLP, which together seek to ensure that development proposals are of a high quality and improve the pedestrian environment, amongst other things: Policy T1 Prioritising Walking, Cycling and Public Transport; Policy G1 Delivery and Location of Growth; Policy A1 Managing the Impact of Development; Policy C6 Access for All.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions The Council also cites Policy D8 Public Realm of the CLP on the decision notice for Appeal A (refusal reason 2). However, the evidence before me does not show that the CLP has a policy D8, and no other documentation relating to such a policy is put to me. As such, I do not find a conflict with the CLP in this respect. 23. In relation to Appeal B, as indicated above, although inconvenient, it has not been shown that the advertisement would represent such a physical hindrance that it would undermine the public safety of pedestrians. However, the Council raised an additional concern regarding the proximity of the proposed kiosk to a busy pedestrian crossing and junctions controlled by traffic lights to the north. Given the likely volume of traffic, this is a location where particular care is required by all road users and pedestrians. Nevertheless, subject to controls to luminance levels and the timing of sequential images, the risks of introducing an unwarranted distraction to road uses at this location could be mitigated to avoid a harmful effect to public safety. Crime and anti-social behaviour (Appeal A) 24.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Whilst mostly glazed, one of the sides of the proposed kiosk, facing along the corresponding pavement, is solid and displays an illuminated advert to the outside https://www.gov.uk/planning-inspectorate 4

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Whilst mostly glazed, one of the sides of the proposed kiosk, facing along the corresponding pavement, is solid and displays an illuminated advert to the outside https://www.gov.uk/planning-inspectorate 4 Appeal Decisions APP/X5210/W/25/3367116, APP/X5210/H/25/3367118 face. This advert panel is broad. The elevation that faces the road is partly solid for its full height to provide a surface for the phone unit. The kiosk is enclosed by a roof. It thus provides an area where persons could loiter and be relatively hidden from passers-by, thereby increasing the potential to commit crime. 25. The Metropolitan Police has advised that the appeal site falls within the policing ward of Holborn and Covent Garden, an area that suffers with higher-than-average crime rates. The kiosk’s configuration is likely to aggravate existing concerns regarding opportunistic crime and anti-social behaviour, to the detriment of community safety and security. This is further heightened by the absence of active surveillance from the adjacent ground floor premises, which might otherwise serve as a natural deterrent. This could discourage some pavement users from using the nearby pavement, which would harmfully diminish its function. 26.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Due to its siting and design, it would therefore increase opportunities for crime and anti-social behaviour and consequently fails to accord with CLP Policy C5 Safety and Security, which states that the design of streets needs to be accessible, safe and uncluttered with careful consideration given to the design and location of street furniture. This policy promotes safer streets and public places and the development of pedestrian friendly spaces. Maintenance (Appeal A) 27. The Council’s reasons for refusal for Appeal A refer to the absence of a legal agreement to secure a maintenance plan. The Council is of the view that in the event that the appeals are allowed, a legal agreement is necessary to secure future management and maintenance. 28. The appellant has submitted a Unit Management Plan which includes a cleaning and repair regime. It is not convincingly explained why the Council find a planning condition to ensure that the development was carried out in accordance with that plan would be deficient. Planning Practice Guidance indicates that conditions should be used in preference to legal agreements where appropriate. That would be the case here. 29.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Moreover, in relation to Appeal B standard condition 3, set out in Schedule 2 of the Regulations, requires that an advertisement displayed, and any site used for the display of advertisements, shall be maintained in a condition that does not impair the visual amenity of the area. For these reasons, it is not demonstrated why it would be necessary to secure maintenance through a legal agreement. Conclusions 30. I conclude that in respect of Appeal A the development would be detrimental to the character and appearance of the street scene, with particular regard to the setting of the Bloomsbury and Kingsway Conservation Areas; it would be detrimental to pedestrian movement and increase opportunities for crime and anti-social behaviour. It would conflict with the development plan in these respects. Planning law requires that applications for planning permission be determined in accordance with the development plan unless material considerations indicate otherwise. I do not find material considerations in this case that would justify departing from the relevant development plan policies. https://www.gov.uk/planning-inspectorate 5

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — Appeal Decisions Appeal Decisions APP/X5210/W/25/3367116, APP/X5210/H/25/3367118 31. I conclude that in respect of Appeal B the proposed digital advertising panel would be harmful to amenity of the street scene. 32. For the reasons given above, I conclude that both appeals should be dismissed.

TELEPHONE CALL BOX OPPOSITE , 35 RED LION SQUARE , LONDON, WC1R 4SG — London Borough of Camden — N Kempton INSPECTOR https://www.gov.uk/planning-inspectorate 6