As ward councillors we have been determined to oppose this development believing it to be out of scale for the site. It will now be subject to a public enquiry. We support having an enquiry and will be giving evidence.
For those who would like to know the detail of our objections here they are as presented back in December to Lambeth’s planning committee by Cllr. Simpson:
8 Albert Embankment: Representation from Cllr Joanne Simpson – Prince’s ward Councillor
Dear Committee colleagues,
I have stood down from Planning Committee this evening as despite my best efforts, I have inevitably had some involvement with this application on a ward Councillor level and do not feel I can approach the decision with an open mind.
I am aware that my ward colleague, Cllr Jon Davies, has submitted a representation on behalf of residents that he and Cllr David Amos, have been working with throughout the lifetime of the most recent application for this site. I would like to raise with you my concerns that I have with my ‘planning committee’ hat on, and would be grateful if you could give the below points/concerns/questions due consideration as part of your deliberations this evening.
Land Use / Principle of Development:
Lack of marketing evidence
I am concerned that the use of the site is being classed as sui generis, despite being a designated KIBA. KIBAs are designated to ensure the retention of employment use, and in particular, industrial and business use, on a site. The site is portrayed as under-utilised, but no reasons have been given for why this is the case. My opinion is that it is not currently in use because the LFB has for many years failed to market it adequately. Were the land considered a Use Class B, the applicant would be required, as per Local Plan policy, to provide marketing evidence to demonstrate that there is no market appetite for its continuation. Whilst I appreciate that the scheme will result in an uplift in employment space, the introduction of residential in the KIBA is a departure from policy, unless it can be demonstrated that there are exceptional reasons for the delivery of an acceptable scheme. I believe that marketing evidence ought to have been submitted, in order to support the applicant’s claim that the residential use is required.
Affordable housing mix
It is totally unacceptable that there are no family sized dwellings in the affordable housing offer (note by this I mean affordable rented and social rented, not shared ownership which is not genuinely affordable in North Lambeth). There are only one-bed units offered for social rented (housing this area badly needs) and one and two-bed properties in affordable rented. Two points on this below:
- The report states that according to the Strategic Housing Market Assessment (SHMA), family-sized homes are not a priority in this area. This is not borne out in my Councillor surgeries, where every month I meet dozens of families living in desperate, crowded and unsatisfactory housing conditions. This development is right in the heart of Whitgift Estate, a Lambeth estate, and next door to Vauxhall Garden’s Estate, the largest Council estate in the Borough. There are very real, existing communities living here in Council blocks, many of whom require rehousing. Prince’s ward is absolutely no different to any other area of Lambeth in this respect.
- The report states that two-bed properties can be considered family-sized. Why then, when I recently objected to a planning application on Vauxhall Gardens Estate which proposed the conversion of a two-bed flat into two units, on the grounds it would result in the loss of a family-sized dwelling, was a told that this concern could not be considered because two-bed properties are not treated as family units when assessing the acceptability of conversions – only 3+ bedrooms were. Policy is policy and its application must be consistent, otherwise the Council is in danger of cherry picking.
Affordable Housing offer
Policy requires 50% per unit and yet 39% is included. Given the need to justify the introduction of residential in the KIBA, this ought to be 50%. Whilst it may be true that the viability assessment demonstrates that the scheme cannot deliver more, this is a separate point that in order to justify the introduction of residential in the KIBA and the departure from the tall buildings restriction in the site allocation, this scheme needs to over-deliver on this, not under-deliver.
This D1 use is neither industrial/business or even residential, and therefore there is no justification for it being in the KIBA. There is a perfectly good gym round the corner on Black Prince Road at the Black Prince Hub. What is the policy justification for its inclusion in the scheme, in particular, within the KIBA?
There is an abundance of hotels in North Lambeth, in Vauxhall and Waterloo in particular, so much so that officers are proposing in the draft Revised Local Plan to ‘not allow further hotel developments in Waterloo and set a cap on new hotel bedspaces in Vauxhall’. The application site is located between Waterloo and Vauxhall, where it is recognised that there is an existing over-saturation of hotels. The draft London Plan also states that the Council proposes ‘encourage new hotels to locate in appropriate town centres elsewhere in Lambeth [i.e. not Vauxhall or Waterloo]’ and ‘require hotel developers to assess the impact of their proposal on local services and neighbours’ and ‘not restrict the supply of land needed for new housing’. Some points below:
- The delivers a below-policy requirement of affordable housing, and so land needed for new housing is being restricted.
- The hotel has an unacceptable impact on the local area, with regards to traffic impact, noise and air pollution, as discussed in more detail in sections below.
- The report states that policy officers raise no objection. Why then is hotel development to be restricted in the revised Local Plan? In order for a Local Plan to be considered sound by the Secretary of State, evidence must be required to justify policies. There is therefore evidence that it is damaging and undesired allow additional hotel development in North Lambeth.
Recently PAC considered a scheme at nearby Westminster Tower, also on 8 Albert Embankment, which proposed the conversion of office space into residential. Officers recommended approval on the grounds that its location, in between both Vauxhall and Westminster tubes but not close enough to either, meant that there was no demand for office space in this location, and that the market wanted office space in Vauxhall town centre instead. This application site is in the same area. What evidence has been provided to demonstrate that the officer advice given to PAC members recently no longer applies?
Para 8.2.7 of the report states that the Council’s Design and Conservation Team’s comments and those of the GLA and Historic England have been incorporated into the report. I would ask that it is made clear at Committee which consultee said what about each particular aspect, otherwise there might a risk of cherry picking in order to present the ‘expert advice’ as more unified and positive than it necessarily is.
Point iv of the Site 10 Allocation in the Local Plan is very clear about the non-acceptability of tall buildings in this site: ‘the heritage sensitivity of the site makes it inappropriate for tall building development’. Further to this, though not as imperative as the Site Allocation, the Vauxhall SPD area falls within a location identified as being ‘sensitive’ to tall buildings’. Some points below:
- The Site Allocation was included in the most recently-adopted Local Plan and as far as I am aware, there are no proposals to amend it in emerging revised Plan. The current Plan was assessed by the Planning Inspector/ Secretary of State and found to be sound. This assessment was undertaken after the area was designated a CAZ and part of the VNEB (where tall buildings are encouraged), and so the inclusion of a restriction on tall buildings on this particular site was done so for good reason.
- Last month I joined some of you in the assessment of the Lambeth College site, where a 20-storey tower was approved, despite it being taller than the existing building form of the locality. Please note, however, that whilst this site is also in the VNEB, it differs from the College scheme in that a) there is a significant number of heritage assets within the immediate and surrounding vicinity, b) there are strategically important views to consider, and c) the Site Allocation specifically states that tall buildings are not acceptable (for reasons a and b).
Rear of the Fire HQ
The rear of this building has architectural and historic interest in that it still boasts largely intact features such as tiered balconies and viewing platforms, which formed an integral part of the operational use of the building at the time. I object to the proposed extension at the rear which would remove these features and replace them with a uniform and ugly building which fails to appear a proportionate or subordinate addition to the host building; neither does it respect the original form or its historic interest which is mentioned in its listing.
New public realm
Little information is provided regarding the conditions of the proposed public realm, with regards levels of sunlight/daylight receives, noise ambience and wind levels, given the height and massing of the buildings proposed on site. New public realm that is not of an excellent and attractive quality, ought not to be presented as a public benefit of a scheme, where in reality spaces are not well-used, such as the dark and windy ‘public spaces’ at St Georges Wharf, Vauxhall.
Impact on Daylight/Sunlight/Outlook
The Council’s own housing department has formally objected to the proposal on the grounds of impact to Lambeth Council homes including impact on light, green spaces, increase in traffic and health and safety concerns. I may have missed it, but I cannot recall in my 6 years sitting PAC seeing an objection from Lambeth Housing. These concerns ought to be given serious consideration. Residents, together with Cllr Davies, have highlighted the main issues, but I did want to raise some further points/questions below:
- I understand from Cllrs Amos and Davies, who accompanied residents on a door-knocking exercise of Whitgift House, that the internal layout of this block is very different to that of Arne House, which the Inspector considered as part of the Graphite Square Appeal scheme, Prince’s ward. Unlike Arne House, it is living rooms, i.e. primary habitable rooms, which face the proposal site, and not galley kitchens and/or secondary bedrooms. The Inspector’s comment therefore need to be read with this in mind and be considered in this context.
- Much is made about the BRE assessment of light levels; however, it should be remembered that the assessment of outlook and a sense of enclosure caused by a development is somewhat different. The sheer height of the proposals and the intense density of the sight combined will lead to an undue sense of enclosure and unacceptable loss of outlook for residents.
- Para 8.3.17 of the report states that ‘[t]he noise impact on residents of the development are considered to acceptable subject to mitigation’. This is in reference to new residents in the proposed blocks. If the noise levels would only be acceptable subject to mitigation, why is it also claimed in the same report that noise levels for existing residents would be acceptable? It cannot be both.
- Point vi of the Site 10 Allocation in the Local Plan states that the Council will support development on this site that ‘makes sure both existing and new residential amenity is protected’. This is not the case.
I have previously enquired at the latest technical briefing about the impact of the proposal on Beaconsfield Gallery, which is an art gallery and exhibition spaces which immediately adjoins the East Site. There is no mention of this in the report. Whilst I appreciate that it is not residential, the Planning Inspector for the recent Graphite Square Appeal did consider the impact of the proposal on Walkers Books publishers, even visiting inside the premises as part of his site visit, and concluded in his Decision that it was a material planning consideration, despite not being residential.
How many of the proposed units are genuinely dual aspect, as defined in Lambeth’s policy?
That there is a complete lack of provision for playspace for older children demonstrates that the application is over dense. Time and time again this is justified by officers by way of a financial contribution to nearby parks. This is not sustainable.
Impact of the hotel
A hotel of 200 bedrooms will result in a substantial increase in vehicular traffic, both in terms of servicing and taxi usage. Some points below:
- The report estimates that the proposal will generate a total of 803 2-way (therefore 1,606 in total) trips in the am peak with 879 2-way (1,758 in total) in the pm peak hour. That is huge.
- Lambeth High Street is a very narrow street, and there is an existing problem of bottlenecks at the junction with Black Prince Road, which is a danger in particular to cyclists. This problem will only increase. I understand that a Servicing/Traffic Management Plan is suggested via condition. However, this does not in itself guarantee that an acceptable solution or situation is possible. An area with narrow streets serving a highly dense housing estate is simply not appropriate for a hotel.
- Hotel users invariable use taxis. Remember that this area was advised by officers as being inappropriate for office space (during the consideration of the Westminster Tower scheme) on account of it not being near a tube. Whilst the PTAL is excellent, this tool is arbitrary and hotel users will not want travel on local buses with their luggage. They will use taxis. The report states that thete are taxi ranks within approx.. 200m of the site. Googlemaps states that this distance is 9 minute walk. It is therefore unlikely that hotel customers will walk to taxi rank and will instead call an uber. Where will these ubers park and has this been factored into the transport assessment? I see no mention of it.
- Point x of the Site 10 Allocation in the Local Plan states that the Council will support development on this site that would ‘reduce traffic dominance and promote walking and cycling’. I feel to see how this can realistically be achieved; indeed the problems with traffic will only become worse to an unacceptable level.
Para. 8.9.10 refers to the ‘limited traffic’ generated by the proposal. I would suggest that this will not be the case, particularly given the proposed hotel, and that not only will levels of daylight and outlook be unacceptability compromised for existing residents, but so too will their levels of clean air.
Thank you for your consideration.
Cllr Joanne Simpson
Labour Councillor for Prince’s ward