PLANNING APPLICATIONS COMMITTEE

Date: Tuesday 20 April 2021

Time: 7.00 pm

Venue: Meeting to be held via Microsoft Teams – please click here

Copies of agendas, reports, minutes and other attachments for the Council’s meetings are available on the Lambeth website. www.lambeth.gov.uk/moderngov

Members of the Committee

Councillor Scarlett O'Hara, Councillor Ben Kind, Councillor Jessica Leigh, Councillor Mohammed Seedat, Councillor Joanne Simpson (Vice-Chair), Councillor Becca Thackray and Councillor Clair Wilcox (Chair)

Substitute Members

Councillor Scott Ainslie, Councillor Liz Atkins, Councillor Jennifer Brathwaite, Councillor Marcia Cameron, Councillor Malcolm Clark, Councillor Paul Gadsby, Councillor Nicole Griffiths, Councillor Nigel Haselden, Councillor Maria Kay, Councillor Marianna Masters, Councillor Iain Simpson, Councillor Timothy Windle and Councillor Sonia Winifred

Further Information

If you require any further information or have any queries please contact: Farah Hussain, Telephone: 020 7926 4201; Email: [email protected]

Published on: Thursday 8 April 2021

Queries on reports

Please contact report authors prior to the meeting if you have questions on the reports or wish to inspect the background documents used. The contact details of the report author are shown on the front page of each report.

@LBLdemocracy on Twitter http://twitter.com/LBLdemocracy or use #Lambeth

How to access the meeting

This meeting will be held in accordance with Section 78 of the Coronavirus Act 2020 and the related Regulations which details that members of the public and press be provided access to the meeting through remote means, such as video conferencing and live streaming as provided by the link provided above.

For elected Members of the Council

Councillors who are not members of the committee but wish to make representations at the meeting must inform Democratic Services by 12 noon on the last working day before the meeting. Please refer to the guidance which has been circulated separately by Democratic Services.

For Members of the Public

This is a Microsoft Teams Live Event meeting. If you are new to Microsoft Teams, clicking the link on the front page will take you to the meeting page where you will be prompted to download the app or watch on the web instead. Please follow the instructions to watch on the web instead. On doing so, you can join our live event anonymously.

Can I make representations at virtual PAC meetings?

You may speak in relation to planning applications and other applications that are to be decided by the Committee. Up to three supporters (including applicants), three objectors and the Ward Members can make representations to the meeting at the Committee’s discretion for a maximum of two minutes each.

If you would like to make representation, please contact the clerk (details on the front page of the agenda) or [email protected].

You must register your wish to make representations on any application, and importantly submit the necessary information, by 12 noon on the last working day before the meeting. You must supply a written statement outlining the points you wish to make to the committee. The written statement when read aloud must not take more than two minutes (approximately 300 words).

For further information please contact Democratic Services as soon as possible by telephoning 020 7926 2170 or emailing [email protected] .

Where the number of requests to address the committee exceeds three, and/or it is clear the interested parties wish to make similar points, the interested parties will be asked to liaise so that all the points can be raised succinctly.

Where the Committee is hearing a Pre-application Development Presentation, you will not be able to register to speak in connection with that presentation. Pre-application Development Presentations relate to proposals that are still at the pre-application stage. Pre-application Development Presentations (explained further below) do not involve the determination of an application by the Committee.

What are Pre-application Development Presentations?

These are presentations to the Committee on proposed developments which have not yet been submitted for planning approval. The purpose of the presentation is to make Committee members aware of the emerging proposal and to have an opportunity to ask questions of the developer and to highlight issues to the developer that may require further consideration. The Committee does not make any decision about the proposals. Any proposal that is presented to the Committee through a Pre-application Development Presentation will still require a planning application to be submitted and determined in the usual way.

What is the process for hearing Pre-application Development Presentations?

Items involving Pre-application Development Presentations will be identified in the agenda papers. If an officer report has been prepared it will be published as part of the agenda papers and at the start of the item, the officer will briefly summarise their report.

The developer will then give a presentation to the Committee. This may involve the use of slides or images, which will be made available to Committee members and which people watching or attending the meeting will also be able to see. Committee members will then be invited to ask questions of the developer and will have an opportunity to highlight issues that may require further consideration by the developer. The item will be included in the minutes of the meeting.

Representation

Ward Councillors (details via the website www.lambeth.gov.uk or phone 020 7926 2131) may be contacted at their surgeries or through Party Group offices to represent your views to the Council: (Conservatives 020 7926 2213) (Labour 020 7926 1166) (Greens 020 7926 2225).

Digital engagement

We encourage people to use Social Media and we normally tweet from most Council meetings. To get involved you can tweet us @LBLDemocracy.

Audio/Visual Recording of meetings

Everyone is welcome to record meetings of the Council and its Committees using whatever, non- disruptive, methods you think are suitable. If you have any questions about this please contact Democratic Services (members of the press please contact the Press Office). Please note that the Chair of the meeting has the discretion to halt any recording for a number of reasons including disruption caused by the filming or the nature of the business being conducted.

Persons making recordings are requested not to put undue restrictions on the material produced so that it can be reused and edited by all local people and organisations on a non-commercial basis.

AGENDA

PLEASE NOTE THAT THE ORDER OF THE AGENDA MAY BE CHANGED AT THE MEETING

Page

Nos. 1 Declaration of Pecuniary Interests Under Standing Order 4.4, where any councillor has a Disclosable Pecuniary Interest (as defined in the Members’ Code of Conduct (para. 4)) in any matter to be considered at a meeting of the Council, a committee, sub-committee or joint committee, they must withdraw from the meeting room during the whole of the consideration of that matter and must not participate in any vote on that matter unless a dispensation has been obtained from the Monitoring Officer.

Town & Country Planning Act (1990), The Planning & Compensations Act (1991), The Town & Country Planning (Control of Advertisement) Regulations (1992), The Planning (Listed Buildings and Conservation Areas) Act (1990), The Town & Country Planning General Regulations (1990), The Rush Common Act 1806 and related legislation: Applications For information on documents used in the preparation of the reports contact the Planning Advice Desk, Tel: 020 7926 1180.

2 10 Pascal Street (Oval) 20/02331/FUL 1 - 120 Officer Recommendations:

1. Resolve to grant conditional planning permission subject to the completion of an agreement under Section 106 of the Town and Country Planning Act 1990 (as amended) containing the planning obligations listed in this report and any direction as may be received following further referral to the Mayor of London.

2. Agree to delegate authority to the Director of Planning, Transport and Sustainability to:

a. Finalise the recommended conditions as set out in this report, addendums and/or PAC minutes; and b. Negotiate, agree and finalise the planning obligations as set out in this report, addendums and/or PAC minutes pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended).

3. In the event that the committee resolves to refuse planning permission and there is a subsequent appeal, delegated authority is given to the Director of Planning, Transport and Sustainability, having regard to the heads of terms set out in this report, addendums and/or PAC minutes, to negotiate and complete a document containing obligations pursuant to Section 106 of the

Town and Country Planning Act 1990 (as amended) in order to meet the requirement of the Planning Inspector.

4. In the event that the Section 106 Agreement is not completed within 6 months of committee, delegated authority is given to the Director of Planning, Transport and Sustainability to refuse planning permission for failure to enter into a section 106 agreement for the mitigating contributions identified in this report, addendums and/or the PAC minutes.

3 Clapham Common (Clapham Common/Clapham Town) 121 - 198 21/00180/RG3 Officer Recommendations:

1. Resolve to grant conditional planning permission.

2. Agree to delegate authority to the Director of Planning, Transport and Sustainability to finalise the recommended conditions as set out in this report, addendums and/or PAC minutes.

PLANNING APPLICATIONS COMMITTEE (PAC) FAQs - YOUR QUESTIONS ANSWERED

Who sits on the PAC? The Council has established a PAC, which consists of seven Councillors (elected Members).

Where and when do PAC meetings take place? As a result of the current public health emergency, meetings are being held virtually and the link to the meeting can be found on the committee agenda front sheet on the PAC page of the Council’s website. The meetings are normally held on a Tuesday evening at 7pm and are held 1 or 2 times a month and are listed on the Council’s calendar of meetings at: http://www.lambeth.gov.uk/moderngov/mgCalendarMonthView.asp?GL=1&bcr=1

Can I attend PAC meetings? All virtual PAC meetings are open to the press and public although on rare occasions the Committee may discuss a matter in private. The link to the meeting can be found on the PAC page of the Council’s website.

How can I get a copy of any reports to be considered by PAC? The officer reports on applications to be considered are circulated to PAC Members and published on the Council’s website a week before the meeting. Papers for meetings can be viewed at: http://www.lambeth.gov.uk/moderngov/ieListMeetings.aspx?CommitteeId=600

Can I make written representations to the PAC meeting? Yes. Written representations, including any letters, petitions or photos should be:  Sent to the relevant case officer listed on the front page of the officer report preferably by email; and,  Sent by 12 noon two clear working days before the meeting. Meetings are normally on a Tuesday, so the deadline would be 12 noon by the Thursday before the meeting.

Can I speak at PAC meetings? Yes. Up to three supporters (including applicants), three objectors and the Ward Members can make representations to the meeting at the Committee’s discretion for a maximum of two minutes each.

If you would like to make representation, please contact the clerk (details on the front page of the agenda) or [email protected].

You must register your wish to make representations on any application, and importantly submit the necessary information, by 12 noon on the last working day before the meeting. You must supply a written statement outlining the points you wish to make to the committee. The written statement when read aloud must not take more than two minutes (approximately 300 words).

For further information please contact Democratic Services as soon as possible by telephoning 020 7926 2170 or emailing [email protected].

Where the number of requests to address the committee exceeds three, and/or it is clear the interested parties wish to make similar points, the interested parties will be asked to liaise so that all the points can be raised succinctly.

Does the PAC consider applications in the order listed on the agenda? Not necessarily. The order of business is determined at the meeting taking into consideration:

1. Applications which are withdrawn, or which officers recommend should be deferred. 2. Applications where there are no notified interested parties wishing to address the committee and members have no questions to ask the applicant or officers. 3. Applications which have been deferred from a previous meeting or have been the subject of a site visit. 4. Applications for developments which would be in receipt of public funding and which are subject to deadlines affecting delivery and other applications subject to specific deadlines.

What is the process for considering an application at the meeting? Officers will introduce each application with a brief PowerPoint presentation which will usually include drawings and photographs of the application site. The Committee will then hear the representations from the interested parties. If the application is recommended for approval, then objectors’ representations will be heard first. This is reversed if the application is recommended for refusal. The merits of the application are considered taking into account the views of the interested parties and planning officers before the committee reaches a decision.

What time does the meeting come to an end? The meeting will be conducted in a business-like fashion and the Committee will endeavour to deal with reports as quickly as possible.

However, if there is a lot of outstanding business at 9.00pm the Chair will advise the meeting if and how the timetable for the meeting has to be revised, in order to deal with remaining business and finish the meeting at 10.00pm. At 10.00pm, if the meeting has not ended, the meeting will decide which business can be completed by 10.45pm and any business not reached by that time will be deferred to the next meeting.

What are site visits? The decision whether to have a site visit is made by the Chair of the Planning Applications Committee. Site visits are arranged by Planning Officers to allow the Committee and Ward Members to observe the site and gain a better understanding of the impact of the proposal. Where permission is needed to go on to private land, contact will be made with the owner by officers. Other than for reasons of access, the arrangements for site visits will not normally be publicised or made known to applicants, agents or third parties except in exceptional circumstances. In such circumstances, officers have discretion to invite one representative of the applicant to be present but only to answer any questions if Members require further context which the officer cannot provide. The applicant must notify the planning officer prior to the site visit who will be attending on their behalf.

Objectors are not to be invited, except in exceptional circumstances where the chair of the Committee agrees that there is information which cannot be provided by officers, and which it is necessary to receive on site and which is only likely to be able to be provided by an objector.

In circumstances where the public may need to be involved; for example, to gain access to a property to view a site from a particular vantage point, officers will arrange this. Members of the public shall be present only to grant access to premises and to answer factual questions.

A site visit is not a part of the formal determination of the planning application and therefore the public in attendance are not able to lobby councillors or to engage in discussing the merits of the proposal.

When do site visits take place? A site visit will normally take place on the Saturday morning immediately before the committee which will consider the matter. An alternative date of the preceding Friday morning could be arranged

If I am unable to attend the PAC meeting, how can I find out the decision? You are able to watch the meeting by clicking the link provided on the front page of the PAC agenda. Following the meeting, videos remain available to view for 180 days. Decisions will be posted on Twitter from @lbldemocracy immediately as the decision is taken. You can also contact Democratic Services by telephone or email. The minutes from the meeting will also be available on the Council’s website approximately five clear working days after the meeting. Planning officers will send the applicant and any interested parties who have made written representations formal notification of the Committee decision.

Where can I get further information or advice? If you would like further information or advice, please contact:  Town Planning Advice Desk: Tel: 020 7926 1180, Email: [email protected]  Town Planning Webpage: https://www.lambeth.gov.uk/planning-and-building-control  Democratic Services: Tel: 020 7926 4201, Email: [email protected]

Guide to Use Classes Order in England.

The table below is intended as a general guide. Reference needs to be made to the Town and Country Planning (Use Classes) Order 1987 (as amended) and the Town and Country Planning (General Permitted Development) (England) Order 2015 (as amended).

Class Summary of Use/Description Permitted Changes

Permitted change to or from a mixed use as A1 or A2 and up to 2 flats; Permitted change of A1 or mixed A1 and dwellinghouse to C3 (subject to Shops, post offices, hairdressers, sale prior approval, max 150m2); of tickets/travel agency, sale of cold Permitted change to A2; food for consumption off the premises, Permitted change to A3 (subject to Class A1 funeral directors, domestic hire shops, prior approval, max 150m2); Shops/Retail dry cleaners, internet café (where the Permitted change to D2 (subject to primary purpose is to provide facilities prior approval, max 200m2). to access the internet). Temporary permitted change (2 years) to A2, A3, B1 (interchangeable with notification to the Council, max 150m2).

Permitted change to A1 where there is a display window at ground floor level. Permitted change to or from a mixed use for any purpose within A2 and up to 2 flats and for A1 and up to 2 flats, where there is a display window at ground floor level. Class A2 Permitted change from A2 or mixed Banks, building societies, estate Financial and A2 and dwellinghouse to C3 (subject agents, employment agencies, Professional to prior approval, max 150m2) professional services. Services Permitted change to A3 (subject to prior approval, max 150m2) Permitted change to D2 (subject to prior approval, max 200m2).

Temporary permitted change (2 years) to A2, A3, B1 (interchangeable with notification to the Council, max 150m2). Permitted change to Class A1 and Class A2. Class A3 The sale of food and drink for Restaurants and consumption on the premises. Temporary permitted change (2 Cafes years) to A2, A3, B1 (interchangeable with notification to

Class Summary of Use/Description Permitted Changes

the Council, max 150m2).

Class A4 Permitted change to drinking Public House, wine bar or other Drinking establishment with expanded food drinking establishment. Establishments provision.

Permitted change to A1, or A2 or A3.

Class A5 The sale of hot food for consumption Temporary permitted change (2 Hot food takeaways off the premises. years) to A1, A2, B1 (interchangeable with notification to the council, max 150m2).

Permitted B1 change to B8 (max B1(a)- Office other than a use within 500m2). Class A2.

Temporary permitted change (2

years) to A1, A2, A3 Class B1 B1(b)- Research and development of (interchangeable with notification to Business products or processes. the council, max 150m2).

Permitted B1 change to state-funded B1(c)- Light industrial uses that can be school or registered nursery (subject carried out in residential areas. to prior approval).

B1(a) office permitted change to C3 Class B1(a) Office other than a use within Class (to be completed within a period of 3 Office A2. years from prior approval date).

Permitted change (from 1 October Light industrial uses that can be 2017 until 30 September 2020 only) Class B1(c) carried out in residential areas such as from B1(c) to C3 subject to prior Light Industrial joinery workshops, tailors, printworks, approval (max 500m2), completion commercial kitchen, workshops. within 3 years of prior approval date.

Class B2 Industrial process other than one Permitted change to B1 and B8 (max General Industrial falling within class B1. 500m2).

Permitted change to B1 (max 500m2) Class B8 Storage or as a distribution centre. Permitted change to C3 (subject to Storage/Distribution prior approval, max 500m2) until 15 April 2018.

Permitted change to state-funded Hotel or as a boarding/guest house Class C1 school or registered nursery (and here no significant element of care Hotels back to previous lawful use) (subject provided. to prior approval).

Class Summary of Use/Description Permitted Changes

Residential accommodation and care Permitted change to state-funded Class C2 to people in need of care (other than school or registered nursery (and Residential C3), hospital/nursing home, residential back to previous lawful use) (subject institutions school, college or training centre. to prior approval).

Prisons, young offenders’ institutions, Permitted change to state-funded Class C2A detention centres, custody centres, school or registered nursery (and Secure residential secure training centres, secure back to previous lawful use) (subject institutions hospitals, secure local authority to prior approval). accommodation, military barracks.

Dwellinghouse occupied by a single person or by people to be regarded as Class C3 a single household, not more than 6 Permitted change to C4. Dwellinghouses residents living together as a single household where care is provided or not provided (other than a use in C4).

Class C4 Use by not more than 6 residents as a Houses in multiple Permitted change to C3. HMO. occupation

Medical/health services, crèche, day nursery or day centre, provision of Temporary permitted change (2 Class D1 education, display of works of art, years) to A1, A2, A3, B1 Non-residential museum, public library, public (interchangeable with notification to institutions hall/exhibition hall, public worship or the Council, max 150m2). religious instruction, law court.

Permitted change to state-funded school or registered nursery (and Cinema, concert hall, bingo hall, dance back to previous lawful use)(subject Class D2 hall, swimming bath, skating rink, to prior approval). Assembly and gymnasium, area for indoor or outdoor Leisure sports or recreations (not involving Temporary permitted change (2 motor vehicles or firearms). years) to A1, A2, A3, B1 (interchangeable with notification to the council, max 150m2).

Includes large HMO, hostel, theatre, Casino to A2 (subject to prior amusement arcade/funfair, approval); Sui Generis launderette, sale of fuel for motor Casino to D2; Uses that do not fall vehicles, sale of motor vehicles, taxi Amusement centre of casino to C3 within a specified business/hire of motor vehicles, (subject to prior approval, max class scrapyard, waste disposal installation, 150m2); nightclub, casino, betting office, pay Betting office or payday loan shop to

Class Summary of Use/Description Permitted Changes

day loan shop. - A1 or mixed use A1 and up to 2 flats (if a display window at ground floor level), A2 or A2 mixed use and up to 2 flats, - A3 (max 150m2), - D2 (subject to prior approval, max 200m2), - C3 (subject to prior approval, max 150m2), or - mixed use betting office or pay day load shop and up to two flats.

Use as a betting office, pay day loan shop or launderette to C3 (subject to prior approval, max 150m2); Mixed use betting office, pay day load shop or launderette and dwellinghouse to C3 (subject to prior approval, max 150m2); Mixed use betting office and up to two flats to: - A1 (if a display window at ground floor level) - A2 or betting office or pay day loan shop Temporary permitted change (2 years, max 150m2) from betting office or pay day loan shop to A1, A2, A3, or B1.

Please note: Permitted development rights can be removed by an Article 4 Direction. Further details of Article 4 Directions can be found at https://www.lambeth.gov.uk/consultations/article-4-direction

Abbreviations

ADF Average Daylight Factor AQA Air Quality Assessment AQMA Air Quality Management Area BNPP BNP Paribas (Financial Viability Advisors) BRE British Research Establishment BREEAM Building Research Establishment Environmental Assessment Method BSPD Brixton Supplementary Planning Document CAS Conservation Area Statement CHP Combined Heat and Power CIL Community Infrastructure Levy CEMP Construction and Environmental Management Plan MHCLG Ministry of Housing, Communities and Local Government DD Daylight Distribution EIA Environmental Impact Assessment ES Environmental Statement ESP Employment and Skills Plan EVCP Electric Vehicle Charging Point HE Historic England FTE Full Time Equivalent FVA Financial Viability Assessment HSE Health and Safety Executive GLA Greater London Authority LLP Lambeth Local Plan 2015 LVMF London View Management Framework MALP London Plan 2016 (formerly Minor Alterations to The London Plan) NPPF National Planning Policy Framework NPPG National Planning Practice Guidance OAPF Opportunity Area Planning Framework PAC Planning Applications Committee PPA Planning Performance Agreement PTAL Public Transport Accessibility Level PV Photovoltaic RICS Royal Institute of Chartered Surveyors RSS Regulatory Support Service – Environmental Health advisors S106 Section 106 of the Town and Country Planning Act 1990 SPD Supplementary Planning Document SPG Supplementary Planning Guidance TA Transport Assessment TfL Transport for London TLRN Transport for London Road Network TVIA Townscape and Visual Impact Assessment VSC Vertical Sky Component VSPD Vauxhall Supplementary Planning Document WSPD Waterloo Supplementary Planning Document

Approach to Heritage Assets

Legislative Framework Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 (“PLBCAA”) provides that in considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.

Section 72(1) of the PLBCAA provides that in the exercise, with respect to any buildings or other land in a conservation area, of any functions under or by virtue of (amongst others) the planning Acts, special attention shall be paid to the desirability of preserving or enhancing the character or appearance of the conservation area.

The South Lakeland District Council v Secretary of State for the Environment case and the Barnwell Manor case (East Northamptonshire DC v SSCLG) establish that “preserving” in both s.66 and s.72 means “doing no harm”.

National Policy Paragraph 8 of the NPPF sets out three overarching objectives, contained within the planning system, in order to achieve sustainable development. These objectives are interdependent and need to be pursued in mutually supportive ways and include the following (with detail provided on the most relevant objective to this section): a) an economic objective; b) a social objective; and, c) an environmental objective –to contribute to protecting and enhancing our natural, built and historic environment.

The NPPF defines a “heritage asset” as:

“A building, monument, site place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest”.

The definition includes both designated heritage assets (of which, Listed Buildings and Conservation Areas are relevant here) and assets identified by the local planning authority (including local listing)

“Significance” is defined within the NPPF as being:

“the value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic. Significance derives from a heritage asset’s physical presence, but also from its “setting”.

Paragraph 190 of the NPPF requires local planning authorities to identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting its setting), taking account of the available evidence and any necessary expertise. That assessment should then be taken into account when considering the impact of the proposal on the heritage asset, to avoid or minimise conflict between the heritage asset’s conservation and any aspect of the proposal.

Paragraphs 192 to 194 of the NPPF provide as follows:

192. In determining planning applications, local planning authorities should take account of:

a. the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; b. the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and c. the desirability of new development making a positive contribution to local character and distinctiveness.

193. When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.

194. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting) should require clear and convincing justification. Substantial harm to or loss of: a) grade II listed buildings, or grade II registered parks or gardens, should be exceptional; b) assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.

Paragraph 195 of the NPPF deals with substantial harm to or total loss of significance of significance of a designated heritage asset.

Paragraph 196 of the NPPF provides that where a development proposal will lead to less than substantial harm to the significance of the designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.

Paragraph 197 of the NPPF deals with non-designated heritage assets as follows:

197. The effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect directly or indirectly non designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.

Paragraphs 200 and 201 of the NPPF are as follows:

200. Local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites, and within the setting of heritage assets, to enhance or better reveal their significance. Proposals that preserve those elements of the setting that make a positive contribution to the asset (or which better reveal its significance) should be treated favourably.

201. Not all elements of a Conservation Area or World Heritage Site will necessarily contribute to its significance. Loss of a building (or other element) which makes a positive contribution to the significance of the Conservation Area or World Heritage Site should be treated either as substantial harm under paragraph 195 or less than substantial harm under paragraph 196, as appropriate, taking into account the relative significance of the element affected and its contribution to the significance of the Conservation Area or World Heritage Site as a whole.

Officers have also had regard to the National Planning Practice Guidance in respect of conserving and enhancing the historic environment.

Approach to Daylight, Sunlight and Overshadowing Where a proposed development may impact upon the sunlight and daylight received by an adjoining property, planning applications are often accompanied by a Sunlight and Daylight Assessment. These should be undertaken following the guidelines published by the Building Research Establishment ‘Site Layout Planning for Daylight and Sunlight’ (BRE Guidelines). This is a good practice guide which provides advice on site layout for good natural lighting within a new development, safeguarding of daylight and sunlight within existing buildings nearby a development and the protection of daylighting of adjoining land for future development. The guide is advisory and whilst it provides numerical target values, these need also to be considered holistically with the needs of the development and its surrounding context.

Two methods of measurement are recommended be used to measure daylight impacts: (1) Vertical Sky Component (VSC); and (2) Daylight Distribution (DD). VSC assesses the quantum of skylight falling on a vertical window and DD (also referred to as No Sky Line) the distribution of direct skylight in a room space.

VSC is calculated from the centre of a window on the outward face and measures the amount of light available on a vertical wall or window following the introduction of visible barriers, such as buildings. The maximum VSC value is almost 40% for a completely unobstructed vertical wall or window. The BRE guidance suggests that if the VSC is greater than 27%, enough skylight should still be reaching the window of the existing building. Any reduction below this level should be kept to a minimum. Should the VSC with development be both less than 27% and less than 0.8 times its former value, occupants of the existing building shall notice a reduction in the amount of skylight they receive. The guide says: “the area lit by the window is likely to appear gloomier, and electric lighting will be needed more of the time”.

The DD method is a measure of the distribution of daylight at the ‘working plane’ within a room. For the DD assessment the ‘working plane’ means a horizontal ‘desktop’ plane 0.85m in height for residential properties. The DD divides those areas of the working plane which can receive direct sky light from those which cannot. If a significant area of the working plane receives no direct sky light, then the distribution of daylight in the room will be poor and supplementary electric lighting may be required. The BRE Guidelines state that if the area of a room that does receive direct sky light is reduced by more than 20% of its former value, then this would be noticeable to its occupants.

Typically, it is recommended that VSC and DD are utilised for consideration on daylight losses resulting from the proposal to existing neighbouring residential since it is a comparative test.

Sunlight is measured using Annual Probable Sunlight Hours (APSH). Sunlight is measured using a sun indicator which contains 100 spots, each representing 1% of APSH. Where no obstruction exists, the total APSH would amount to 1486 hours and therefore each spot equates to 14.86 hours (for London) of the total annual sunlight hours. The number of spots is calculated for the Baseline and Proposed Development scenarios during the whole year and also during the winter period and a comparison made between the two. This provides a percentage of APSH for each of the time periods for each window assessed.

The 2011 BRE Guidelines note that sunlight is valued in living rooms at any time of day but especially in the afternoon. It is viewed as less important in bedrooms and in kitchens (the latter where people prefer it in the morning rather than the afternoon. All main living rooms of dwellings…should be checked if they have a window facing within 90° of due south. If the main living room to a dwelling has a main window

facing within 90° of due north, but a secondary window facing within 90° of due south, sunlight to the secondary window should be checked.

With regard to existing surrounding receptors, the BRE Guidelines provide that a window may be adversely affected if a point at the centre of the window receives - Less than 25% of the APSH during the whole year, of which 5% APSH must be in the winter period; and - Receives less than 0.8 times its former sunlight hours in either time period; and - Has a reduction in sunlight for the whole year more than 4% APSH.

Overshadowing is assessed through transient overshadowing plots which comprise an illustrative tool showing the changing levels of direct sunlight received by amenity space throughout the day on the dates assessed. The BRE ‘test’ for a development’s overshadowing impacts relates to the area of an amenity space that receives more than two hours of sunlight on 21 March (the Spring Equinox). The guide states:

“…for it to appear adequately sunlit throughout the year, at least half of a garden or amenity area should receive at least two hours of sunlight on 21 March. If, as a result of new development, an existing garden or amenity area does not meet the above, and the area which can receive two hours of sun on 21 March is less than 0.8 times its former value, then the loss of sunlight is likely to be noticeable”.

Approach to Air Quality There is a Lambeth wide Air Quality Management Area (AQMA) and Lambeth is also covered by the Non-Road Mobile Machinery (NRMM) Low Emission Zone.

The NPPF states within paragraph 181:

“…decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement…Planning decisions should ensure that any new development in Air Quality Management Areas and Clean Air Zones is consistent with the local air quality action plan.”

London Plan policy 7.14 states that development proposals should minimise increased exposure to existing poor air quality and make provision to address local problems of air quality, promote sustainable design and construction to reduce emissions from the demolition and construction of buildings, be at least air quality neutral, ensure that where provision needs to be made to reduce emissions from a development, this is normally made on-site, and where the development requires a detailed air quality assessment and biomass boilers are included, the assessment should forecast pollutant concentrations.

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ADDRESS: 10 Pascal Street, London, Lambeth, SW8 4SH Application Number: 20/02331/FUL Case Officer: Magda Kotyza Ward: Oval Date Received: 13/07/2020 Proposal: Full 'slot-in' planning application for phased residential led mixed-use development above and surrounding Nine Elms Station, comprising three new residential buildings of 21 storeys, 16 storeys and 17 storeys providing a total of 479 homes (Use Class C3), plus small scale commercial floorspace of 108m2 (Expanded Use Classes A1-A4 and D1), works within the Nine Elms Station 'boxes', a new public square, and associated works.

Applicant: Connected Living London (Nine Agent: Avison Young Elms) Limited

RECOMMENDATION

1. Resolve to grant conditional planning permission subject to the completion of an agreement under Section 106 of the Town and Country Planning Act 1990 (as amended) containing the planning obligations listed in this report and any direction as may be received following further referral to the Mayor of London.

2. Agree to delegate authority to the Director of Planning, Transport and Sustainability to:

a. Finalise the recommended conditions as set out in this report, addendums and/or PAC minutes; and b. Negotiate, agree and finalise the planning obligations as set out in this report, addendums and/or PAC minutes pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended).

3. In the event that the committee resolves to refuse planning permission and there is a subsequent appeal, delegated authority is given to the Director of Planning, Transport and Sustainability, having regard to the heads of terms set out in this report, addendums and/or PAC minutes, to negotiate and complete a document containing obligations pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended) in order to meet the requirement of the Planning Inspector.

4. In the event that the Section 106 Agreement is not completed within 6 months of committee, delegated authority is given to the Director of Planning, Transport and Sustainability to refuse planning permission for failure to enter into a section 106 agreement for the mitigating contributions identified in this report, addendums and/or the PAC minutes.

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SITE DESIGNATIONS

Relevant site designations: Opportunity Area Vauxhall Opportunity Area Central Activities Zone Central Activities Zone Flood Risk Zone 3 CAA Helipad Safeguarding Zone CAA Helipad Safeguarding Zone Neighbourhood Planning Area Kennington Oval and Vauxhall Protected Vistas Brixton Panoramic Local View Brixton Historic Towers Local View London Distributor Roads Wandsworth Road

LAND USE DETAILS

Site area (ha): 0.65 hectares

NON-RESIDENTIAL DETAILS

Use Class Use Description Floorspace (m2) (Gross Internal Area) Existing* 0

Extant Consent* C3 Residential 35,782sqm (15/06216/FUL) Class B1a Office 4,811 Class D2** Gym 272 Class A1/A3/A4 Retail 580

Proposed* C3 Residential 39,695 A1/A2/A3/A4/D1 Flexible (Retail and 108 Community) * Does not include Nine Elms Station as this falls outside of the scope of this application. ** Gym for use by residents only

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RESIDENTIAL DETAILS

Residential No. of bedrooms per unit Total Type Habitable Rooms Studio 1 2 3 4 Total Existing Affordable n/a Private/Market n/a Total n/a

Extant Affordable 0 11 57 14 2 84 Consent (Intermediate Rent) Private/Market 0 150 98 0 0 248 Total 0 161 155 14 2 332

Proposed Intermediate 21 55 43 36 0 155 404 On-site Discount (32.4% (34.4% of Market Rent of all all hr) (DMR) units) (London Living Rent) Intermediate 0 0 16 5* 0 21 68 DMR (4.4% (5.8% of (Lambeth of all all hr) Tenancy units) Strategy (2020) Equivalents ) Private/Market 32 146 121 4 303 703 (Build to Rent) (63.2 (59.8%) %) Total 53 201 180 45 0 479 1175 (100%) (100%)

Proposed Affordable n/a Off-Site Rented Social Rented n/a Intermediate n/a Private/Market n/a Total n/a * The rents for 3-bedroom units set out in the Lambeth Tenancy Strategy (2020) are at target rent levels

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Amount (£)

Payment in Lieu of n/a Affordable Housing Details/Trigger Review Mechanism 1. Pre implementation: if not implemented within 24 months from vacant possession 2. Late Stage Review: triggered at 18 months from first of occupation of market units or 100% occupation of market units (whichever is the earliest)

ACCESSIBILITY

Number of C3 Units M4(2) Units 418 M4(3) Units 61

PARKING DETAILS

Car Parking Spaces Car Parking Spaces % of Bike Motor- (General) (Disabled) EVCP Spaces cycle Spaces Resi Commercial Visitor Resi Commercial Visitor Existing 0 0 0 0 0 0 0 0 0 Proposed 0 0 0 14 0 0 100 851 0

LEGAL SERVICES CLEARANCE

AUDIT TRAIL Consultation Name/Position Lambeth department Date Sent Date Report Comments Received Cleared in para: Susan Boucher Legal Services 29/03/21 30/03/21 31/03/21 Throughout Senior Lawyer

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EXECUTIVE SUMMARY

This application is for a residential-led development by Connected Living London (Nine Elms) Ltd (a joint venture partnership between TfL and Grainger Plc) of a site above the Nine Elms Underground Station which is currently under construction.

The application site is located on the northern side of Pascal Street and corner of Wandsworth Road, approximately 800m to the southwest of Vauxhall Station. The site sits within the Vauxhall Nine Elms Battersea Opportunity Area (VNEB OA) and forms the southern boundary of the Central Activities Zone (CAZ), as identified by the London Plan (2020).

This application relates to the development above and surrounding the Nine Elms Station, but does not include the station itself or the external appearance of the station buildings. The site benefits from an extant planning permission (ref: 15/06216/FUL) for a residential led development including three residential towers above the station podium, providing 332 residential units and a new public square between the residential towers with a retail unit fronting it. The extant consent also includes a commercia/office building (Block D) to the north-west of the current application site.

The proposal seeks to ‘slot -in’ into the extant scheme (ref: 15/06216/FUL) and includes a residential led mixed-use development comprising three new residential buildings of 21 storeys (Block A), 16 storeys (Block B) and 17 storeys (Block C) providing a total of 479 homes including 40 per cent affordable housing which would replace the previously approved (ref: 15/06216/FUL) residential towers. This represents an overall increase of 147 residential units (44 per cent) when compared with the extant permission while the number of affordable units would increase by 92 (109 per cent). The proposed residential units are Built to Rent (BtR), which is purpose built housing that is typically 100 per cent rented out and managed by a single professional provider. The proposal also includes a public square (Pascal Square) with a small flexible commercial unit (Use Class A1-A4 and D1) facing the new Pascal Square and associated works. It is proposed to deliver the scheme in phases which would provide for the potential delivery of Block D under the extant consent together with the delivery of Blocks A, B and C as proposed in the current scheme.

The development would maximise housing delivery and provide much needed, good quality housing, including a high level of affordable housing, at a density that makes optimum use of the application site. The level of affordable housing at 40 per cent meets the policy requirement for a scheme on public sector land where a portfolio agreement with the Mayor of London is in place. However, the proposals were viability tested due to their reliance on grant funding and the non-policy compliant tenure split of the residential units. An independent review confirmed that the affordable housing offer is the maximum viable. During the application process extensive discussions with the GLA took place and the applicant secured an in principle additional, bespoke grant offer which enabled the scheme to reduce the originally offered rent levels. An early and a late stage review are recommended to ensure that the affordability of rents is further maximised should the viability improve.

The acceptability of provision of tall buildings has been established through the extant permission, and the proposed towers at 21, 16 and 17 storeys sit within the policy requirements and design aspirations of the London Plan, the Lambeth Local Plan and the emerging draft Lambeth Local Plan. Despite the constraints of the site laid down by the station building, the triangular building form and position of each block, the use of high quality materials, the junction between the station and the development above, and the creation of a significant area of new public realm provides a suitable and positive edge and gateway between the Vauxhall tall building cluster and the lower scale of development to the south. The proposed scheme would not result in harm to any heritage assets or their settings or affect local views from Brockwell Park. In addition, the development has been designed in conjunction with advice offered by the Metropolitan Police’s Design Officer seeking to minimise the opportunity for crime/terrorism.

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The development would provide a high quality residential environment for all future occupiers and would contribute significantly to meeting Lambeth’s and London’s housing targets. All of the new dwellings have been designed to meet relevant standards in terms of size, layout, aspect and adaptability. The proposed units will achieve reasonable levels of outlook, daylight and sunlight. In addition, the development is inclusive of generous on-site amenity (both private and communal), play space provision and the delivery of a significant new area of public realm.

The proposals would ensure that levels of privacy and outlook of adjoining residential uses is maintained and in some areas enhanced when compared with the existing situation. In terms of the impact on daylight and sunlight, the change from the ‘consented’ to ‘proposed’ application scheme, there is fairly limited effect in absolute terms upon neighbouring properties, with the isolated exception of daylight to three windows. However, these windows have inherent sensitivity to any massing change as each of these rooms have a balcony soffit above windows and consideration should be given to the context of the application site which is located within an opportunity area. Officers are satisfied that the impact of the proposal on daylight and sunlight of neighbouring properties is acceptable.

The development would have an acceptable impact on the highway and transport network. The development would be car free, with occupants of the commercial and residential units not eligible for parking permits. 14 on-site disabled parking spaces would be provided with a parking management plan secured by Section 106 Agreement. The scheme would provide a total of 851 cycle parking spaces, in accordance with the London Plan standards. The new public realm will serve to improve links throughout the area as well as provide an attractive and well-designed area for people to dwell. The development would also contribute to improvements to the Local Healthy Routes network. The development would be suitably mitigated in terms of its impact upon local infrastructure. Subject to conditions, the development would not impact unacceptably upon the function and safety of the highway network (both pedestrian and vehicular).

The principles of the Mayor’s energy hierarchy have been applied to the proposed development and the Energy Strategy demonstrates that a site-wide carbon emissions reduction of 56 per cent would be achieved over the Building Regulations Part L 2013 Baseline. A future financial contribution is required to offset all remaining regulated CO2 emissions to 100 per cent or “zero carbon emissions” will be secured through Section 106 Agreement.

Subject to conditions, the development would meet technical requirements in respect of sustainability, air quality, flood risk mitigation, wind conditions, waste and recycling and water infrastructure.

The development would provide an appropriate balance of uses including private and affordable homes, and commercial uses, and would improve the environment both in terms of linkages and new public realm. The application is therefore recommended for approval, subject to conditions and completion of a Section 106 Agreement, in accordance with the presumption in favour of sustainable development conferred upon Local Planning Authorities by the National Planning Policy Framework (NPPF).

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OFFICER REPORT

Reason for referral to PAC: The application is reported to the Planning Applications Committee in accordance with (1) (A) (a) (i) of the Committee’s terms of reference as it relates to a major application for the provision of more than 35 residential dwellings.

1 THE APPLICATION SITE AND SURROUNDING AREA

1.1 The application site is located on the northern side of Pascal Street and corner of Wandsworth Road, approximately 800m to the southwest of Vauxhall Station. The site sits within the Vauxhall Nine Elms Battersea Opportunity Area (VNEB OA) and forms the southern boundary of the Central Activities Zone (CAZ), as identified by the London Plan (2021). Figure 1 below shows the site and its surrounding context.

Figure 1: The site and its surrounding context (including borough boundary)

1.2 The 0.65ha application site is already under construction to deliver Nine Elms Underground Station. Nine Elms forms part of the Northern Line Extension from Kennington to Battersea, approved under a Transport and Works Act Order (TWAO) (ref. TWA 3/1/415). The Nine Elms Station does not form part of this application and the proposed development would be located above it.

1.3 Prior to this, the site accommodated a number of buildings/uses. The eastern part of the site formed part of the car park for the former Sainsbury’s supermarket to the north, while the western part comprised one and two storey buildings with offices for the Covent Garden Market Authority

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(CGMA), and offices/workshops for Banham Patent Locks. The CGMA office was relocated to within the remaining CGMA site to the west, while Banham’s relocated to new purpose-built premises in Wandsworth.

Adjoining Sites

1.4 The site is bounded to the north by the former Sainsbury’s supermarket site, which has been recently redeveloped to provide a new Sainsbury’s superstore and 737 residential dwellings (ref. 11/02326/OUT). Blocks C and D of the proposed Sainsbury’s scheme face directly onto the application site rising to a total height of 19 storeys with a commercial frontage at ground floor level.

1.5 To the west of the site is the existing car park for the CGMA site within LB Wandsworth. The market buildings are located approximately 170m to the southwest. This site is also subject to a future redevelopment proposal (ref. 2014/2810), with an outline planning consent for the ‘Apex Site’, which directly adjoins the application site. Further details are set out in Section 3 of this report.

1.6 On the southern side of Pascal Street, the area is predominantly residential in character, with a terrace of two storey homes fronting onto Pascal Street and running around Bramley Crescent to the south. Two, three storey flatted blocks (Charman House and Lockyer House) run perpendicular to the site, fronting onto Wandsworth Road and Bramley Crescent respectively.

1.7 The eastern side of Wandsworth Road is also largely residential in character. The residential units are predominantly contained in formal arrangements of slab blocks either fronting onto or running perpendicular to Wandsworth Road. These blocks range in height from four storeys on the Wyvil Estate in the north to the part five/part six storey Wilbraham House further south. Opposite the junction with Pascal Street is Wilcox Road, which contains a number of retail units and is formally designated in the Local Plan as Wilcox Road Local Retail Centre.

Policy designations, accessibility and constraints

1.8 In terms of policy designations, the site falls within the VNEB Opportunity Area and the Central Activities Zone. The site falls within two local viewing corridors from the east, known as Brixton Panoramic and Brixton Historic Towers respectively. The site is also within Flood Zones 2 and 3. The site is not located within or adjoining a Conservation Area and there are no listed structures on or surrounding the site.

1.9 The site is well served by public transport. Vauxhall Underground and mainline stations are within 800m and various bus routes serve Wandsworth Road. The site largely achieves a PTAL of 6a (very accessible), but there is a small part of the site to the west that drops to level 3. The accessibility will be further enhanced when the new station opens on site. In terms of parking, the site is within the Stockwell Controlled Parking Zone (CPZ).

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2 SITE PHOTOGRAPHS

2.1 Figure 2, below, shows aerial image of the application site.

Figure 2. View towards north (Source: Google maps)

Figure 3. (Source: Google maps)

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2.2 Figure 4, below, shows a range of views from around the site from October 2020.

Figure 4: Images of the site as of October 2020

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2.3 Figure 5, below, shows a range of longer views from around the site.

Figure 5: Views towards the application site (Source: Heritage Townscape and Visual Impact Assessment).

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3 PROPOSAL

3.1 Summary of the Proposal

3.2 The proposals seek to develop above and around the Nine Elms Station buildings to provide a ‘slot -in’ residential led mixed-use development comprising three new residential buildings (Use Class C3) of 21 storeys (Block A), 16 storeys (Block B) and 17 storeys (Block C) providing a total of 479 homes, and small scale commercial floorspace of 108m2 (Expanded Use Classes A1-A4 and D1), works within the Nine Elms station boxes, a new public square, and associated works. The proposal does not include the station or its appearance. Each element of the scheme is set out in further detail below.

Figure 6. Proposed site layout

3.3 The affordable housing would comprise 176 units in total (40 per cent by habitable room), all of which will be accommodated within Block A. The affordable housing is to be provided at discounted rent levels compared to open market rents as follows:

• 155 units (88 per cent by habitable rooms) at London Living Rent equivalents • 21 units (12 per cent by habitable rooms) at Lambeth Tenancy Strategy (2020) equivalents

3.4 The scheme forms part of TfL’s London-wide Build to Rent (BtR) portfolio which aims to deliver in excess of 3,000 new homes of which a minimum of 40 per cent will be affordable. The first phase of delivery includes six sites in total including Pascal Street (see below for the full list of first phase sites). Connected London Living (CLL) has been created as a joint venture between TfL and Grainger PLC (GPLC) to deliver and manage its BtR portfolio going forward. CLL will manage both private and affordable units on site noting that CLL has applied to become a Registered Provider.

Other Phase 1 Build to Rent sites are: • Montford Place, Lambeth - 139 homes (planning application ref: 20/01086/FUL with a resolution to grant permission on 15.12.2020) • Limmo Peninsula, Canning Town, Newham - with the potential for up to 1,500 homes • Southall Sidings , Ealing - with the potential for up to 400 homes • Cockfosters Tube station, Enfield - with the potential for up to 300 homes • Arnos Grove Tube station, Enfield - with the potential for up to 100 homes

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3.5 Detail of the Proposal

3.6 The application follows on, and ‘slots-in’ to the following extant planning permissions:

• Nine Elms Point (ref: 11/02326/OUT) relates to the site immediately to the north of the site and phase 2 of the scheme included the eastern part of the application site. This consent has been recently delivered by Barratt Homes Ltd. The approved scheme includes an underground car park which is to be provided from Pascal Street through the Nine Elms Station box. The relocation of affordable homes which were approved within the current application site to a site on the Fenwick Estate was approved in 2016 (ref: 15/05297/RG3).

• Nine Elms Station (ref: TWA 3/1/415): The station position, internal layout external appearance and associated landscaping has been approved through the Northern Line Extension Transport and Works Act Order (TWAO). This scheme is currently being constructed. Once complete, the two station boxes will provide ‘voids’ at ground and basement levels into which the proposed development will ‘slot-in, and a podium onto which the proposed blocks will sit upon. The station boxes and all subterranean works approved under the TWOA are expected to be carried out in full, while public realm landscape works are to be implemented in part only.

• Nine Elms Over Station Development (ref: 15/06216/FUL): Planning permission was granted in 2016 for a residential led mixed use development above and surrounding the proposed Nine Elms Station comprising four buildings between 5 and 20 storeys above the station podium, providing 332 residential units; 4,811sqm of workspace/office (B1); 272sqm of assembly and leisure (D2) and 580sqm of retail (falling within class A1/A3/A4), a new public square, amenity space, and associated works. The application site comprised the current application site and land to the north which accommodated commercial Block D. The developer (TfL) has advised that they are planning to deliver Block D under the extant consent. The current proposal is to replace the approved Blocks A, B and C and the majority of the ground level public realm.

3.7 Figure 7 below shows the application boundary in the context of the aforementioned extant or implemented schemes and the ‘slot-in’ plan (please also see larger image in Appendix 4).

Figure 7. Extant planning consent boundaries across the application site.

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Nine Elms Station 3.8 Although the station and its associated structures above ground level fall outside of the scope of this application, it is important to explain the extent of the station structures as this sets the context for the layout of the proposed scheme above. The station ‘box’ extends four levels below ground and projects two storeys above ground level. The above ground structure is split into two separate buildings, one to the east and one to the west of the application site (see Figure 7, above). The eastern building has a total footprint of 2,454sq.m, while the western building has a smaller footprint of 1,136sq.m. The two buildings are separated by Pascal Square.

3.9 The eastern building provides the main entrance to the new station fronting onto Wandsworth Road (see Figure 8 below), with residential and servicing cores along its northern façade. The western elevation is essentially a flank wall, while the southern elevation provides station access/egress points for maintenance and emergency, along with vehicular access to the basement parking level for this and the Sainsbury’s site.

Figure 8: An indicative image of the station entrance (along with the OSD proposal above) from Wilcox Street. 3.10 The western building of the Nine Elms station has been designed to provide an additional entrance to the station should the need arise in the future. The core to the residential units in Block A above will be located on the northern side of the building. Above ground level of the station both buildings are largely functional in appearance with the presence of ventilation louvers

Figure 9: An indicative image of the station buildings (along with the OSD proposal) facing northeast from Pascal Street.

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Basement Level

3.11 While the station structure comprises the majority of the sub-ground level, there is a basement area (see Fig. 10, below) that forms part of this application to provide 14 Blue Badge spaces along with provision of 363 cycle parking spaces to serve the residential element of the proposed development. This basement, accessed direct from Pascal Street, also provides shared access to the adjoining Sainsbury’s scheme residential car park. Basement level 1 would be used by residents from Block A and level 2 by residents of Blocks B and C.

Figure 10: Proposed basement layouts.

Blocks A, B and C

3.12 The proposed block layout follows that of the extant permission (ref:15/06216/FUL). Figure 11 shows the key differences which are the increase in height to blocks B and C and a series of pop outs to each of the blocks. The roof form has also been simplified with the removal of penthouse apartments. In addition, changes to structural strategy allow to increase in the number of residential units on each floor from eight to nine (Block A) and to 10 (Blocks B and C).

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Figure 11: Key design changes from extant consent (the image of the left shows increased heights and the image on the right shows the pop outs).

Block A

3.13 Block A is a residential tower that sits on top of the western station building. The tower is triangular in shape, with the diagonal edge facing southwest. The tower rises to a maximum height of 21 storeys (88.8m AOD) which is approximately 3m lower than the approved Block A (See Figure 17 and Appendix 4). Block A provides 176 residential units, comprising 21 studio flats, 55 one- bedroom flats, 59 two-bedroom flats and 41 three-bedroom flats all of which would be intermediate tenure. The standard floorplate shows nine units on each floor around a central core (see Figure12 below). All of the units would have private balconies.

Figure 12: A typical residential floor plate for Block A

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3.14 The podium (between the station and the residential units) provides a transfer area between the main access core serving the basement, ground floor and podium area to the residential core serving upper floors. The first floor level also includes communal external amenity space (incorporating play space), a residents’ lounge, plant rooms and refuse and cycle storage for 180 cycles (see Figure 13 below). In terms of separation distances, Block A sits 34m to the west of Block B, 15.7m from the proposed building on the Apex Site (CGMA); between 11m to 13m to the south of approved Block D and at least 17.4m from the residential properties on the southern side of Pascal Street.

Figure 13. First floor layout in Block A.

Block B 3.15 Block B is the middle residential tower sitting on top of the eastern station building overlooking Pascal Square. As with Block A the tower is triangular in shape with its main diagonal facade facing southeast. The tower rises to a maximum height 16 storeys (74.1m AOD) which is 1.1m higher than the approved Block B (See Figure 17 and Appendix 4). Block B provides 146 residential units, comprising 16 studio flats, 68 one-bedroom flats, 60 two-bedroom flats and 2 three-bedroom flats, all of which would be private tenure. The standard floor plate shows 10 units on each floor around a central core. Except for four units, all other units would have private balconies (see Figure 14, below).

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Figure 14. A typical residential floor plate for Block B

3.16 The podium (between the station and the residential units) is shared with Block C and provides access cores to the basement and first floor level with a concierge area, internal residential lounges with access to outdoor amenity space, cycle stores (for 264 cycles), refuse stores and plant areas (see figure 15, below). In terms of separation distances, Block B sits 13.2m to the south of the Sainsbury’s scheme (Block D), 34m to the east of Block A, 15.2m (at its closest point) from Block C and at least 20.5m from the residential properties on the southern side of Pascal Street.

Figure 15: First floor layout in Block B and C.

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Block C 3.17 Block C is the eastern-most residential tower also sitting above the eastern station building overlooking Wandsworth Road. The tower rises to a maximum height 17 storeys (77.3m AOD) which is 7.3m higher than the approved Block C (See Figure 17 and Appendix 4). Block C provides 157 residential units, comprising 16 studio flats, 78 one-bedroom flats, 61 two-bedroom flats and two three-bedroom flats 11, all of which would be private tenure. The standard floor plate shows 10 units on each floor around a central core. All units would have private balconies. A typical layout is shown in Figure 16, below. As explained above, blocks B and C share a podium level.

Figure 16: A typical residential floor plate for Block C

Figure 17: Proposed southern elevation compared with the extant scheme shown in blue (left to right – Blocks A, B and C)

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External appearance

3.18 The proposals use brick throughout with accent brickwork for detail and definition. The façades have been developed using primary and secondary piers, horizontal bands, grouped windows and expressed crowns.

Figure 18. Typical upper floor bay study.

Commercial unit in Pascal Square – Pavilion Building

3.19 The proposed retail units within the station structure do not form part of this proposal, but the scheme does propose a separate, free-standing two storey 108sq.m commercial unit (Use Class A1/A2/A3/A4 and D1) to adjoin the flank wall of the eastern station building. This pavilion building will extend approximately half the length of the eastern building facing onto Pascal Square (see figure 20, below).

Public Realm

3.20 The proposals create more than 2,240sqm of new public realm. This includes the creation of Pascal Square (between blocks A and B) (see Figure 19) and parts of Hebden Way (to the north of the station buildings linking with the public realm provided by the Sainsbury’s scheme). The public realm will be predominantly hard landscaped, with tree planting and areas of soft landscaping, incidental play space and seating. The public realm will accommodate a further 38 cycle parking spaces. Improvements to Pascal Street (outside of the red line) are to be secured to deliver a loading bay and possibly car club bays.

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Figure 19: Site layout showing proposed indicative public realm – Pascal Square

Figure 20: CGI showing Pascal Square view looking east towards Block B and the Pavilion Building.

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Phasing 3.21 It is proposed to implement the scheme in phases which seek to facilitate part-implementation of the extant consent (ref: 15/06216/FUL) in relation to the consented Block D. The phasing strategy, which would be secured through the Section 106 Agreement, is as follows:

Prior to commencement: the station ‘boxes’ approved pursuant to the TWAO will be completed and the associated public realm works built out. As the station is expected to be delivered in 2021, officers consider it appropriate to extend the normal three-year time period (as set out in Section 91(1)(a) of the TCPA) for the commencement of the current scheme to four years (i.e. three years beyond the intended station delivery) in accordance with part (b) of Section 91. This is reflected in proposed Condition 1 and would not itself be included in a phasing strategy; it is explained here as it provides the context for the rest of the proposed phasing strategy. The extended period for commencement of the scheme is recommended in order to provide for any potential delays to the delivery of the station and would enable the applicant to undertake the necessary procurement arrangements in order to deliver this scheme once the station is delivered.

Phase 1: Enabling works for Blocks A, B and C (including works at basement levels and temporary works such as erection of hoarding, hoist and cabins).

Phase 2: Main construction works for Block A, B and C; the pavilion building; public realm works to provide access to buildings and occupation of Blocks A, B and C.

Phase 3: Construction of Block D (implemented pursuant to the extant consent) to include associated public realm. Pascal Square area to be utilised as construction compound for Block D contractor.

Phase 4: Delivery of Pascal Square following dismantling of Block D construction compound.

3.22 In the event that there is an anticipated delay in the delivery of Block D, provision of temporary landscaping and access rights to Pascal Square following the practical completion of Blocks A, B and C will be required and secured through the S106 legal agreement. Furthermore, the S106 legal agreement will also secure the delivery of a permanent landscaping scheme should development of Block D not come forward within five years of first occupation of any residential unit. Officers acknowledge that should the development of Block D site come forward after that time, sections of Pascal Square may have to be temporarily closed to allow for construction access and compound for Block D and this will be secured through the S106 legal agreement.

Amendments

3.23 During the course of the application, the following amendments were made:

• Removal of A5 use from the flexible uses proposed in the commercial unit • Removal of 4 balconies in Block B to overcome overlooking issues • Incorporation of privacy mitigation measures including realignment of windows and obscured glazing to several windows • Revised design of Pascal Square to overcome transport and accessibility concerns • Updated description of development to include ‘phased’ for clarity

3.24 Due to the minor nature of the amendments it was not considered necessary to re- consult.

Planning Performance Agreement

3.25 The current proposals have been the subject of pre-application discussions (under a Planning Performance Agreement) which commenced in September 2019 and remains in force until the determination of the planning application. The consultation process has included at various stages councillors and officers from development management

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planning, transport, highways, heritage and design teams at Lambeth as well as the applicant and their consultant teams. The proposal was considered at the pre-application stage by the Council’s independent Design Review Panel (DRP) on 19 November 2019 where an initial steer was given.

3.26 The applicant has also conducted three separate public consultations events with the local community. The full details including dates and nature of comments made at each event and the applicant’s response to concerns are contained in the statement of community involvement prepared on behalf of the applicant by Cascade Communications Ltd and forms part of the formal submission information.

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4 RELEVANT PLANNING HISTORY

4.1 The application has a significant planning application history as part of its previous use as an employment site. However, it is not considered necessary or relevant to set this out in full in this report. Details of the site’s previous uses have already been set out in section 1 of this report.

Application site:

4.2 Sainsbury’s (Nine Elms Point) The eastern part of this site forms part of the original application site for the redevelopment of the Sainsbury’s site to the north. The original planning application (ref. 11/02326/OUT) was a hybrid submission comprising a full planning application for the Sainsbury’s site and an outline application for the site now subject to this application. The full description of development is as follows:

A part detailed and part outline planning application comprising: Full detailed planning permission for the demolition of the existing retail store and petrol station and the erection of a replacement retail store (7,432msq net trading floorspace (13,059msq gross internal floor area); children’s tutoring facility (298msq); lobby/circulation space (1,707msq); energy centre (779msq); flexible retail, community floorspace (787msq); office floorspace (1,860msq) and 645 residential units with ancillary gymnasium arranged in seven blocks including towers of 19, 28 and 37 storeys; 363 retail and 148 residential parking spaces; 882 cycle spaces together with associated open space, children’s play space, landscaping and public realm improvements along Wandsworth Road and a new route from Wandsworth Road to New Covent Garden;

Outline planning permission (with appearance, landscaping and access to be Reserved Matters) for 105msq of flexible A1, A2, A3, A4, D1 floorspace and 92 dwellings within 2 blocks [Blocks A and B]. In addition outline planning permission is also sought for a further 1736msq of flexible floorspace for use in association with the proposed Nine Elms Northern Line station or A1, A2, A3, A4, D1 use.

4.3 The application was approved on 06/11/2013. A number of variations to the original scheme have subsequently been made under Section 73 (ref. 14/05064/VOC, 15/05379/VOC and 17/00114/VOC). The image below shows how the Sainsbury’s scheme and this application relate. Blocks A and B sit within the Nine Elms OSD application site.

Figure 21: Sainsbury’s site and its relationship with the current application site

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4.4 The Section 106 Agreement for the Sainsbury’s application made provision for 92 of the 148 affordable homes which had originally been intended to be located within blocks A and B to be provided off-site. Following TfL’s acquisition of the site the obligation was transferred to the Fenwick Estate in Stockwell and the delivery of 55 affordable dwellings in this location instead. The planning application (ref. 15/05297/RG4) was approved by the Council’s Planning Applications Committee on 9th February 2016.

4.5 Transport and Works Act 1982 (ref. 3/1/415) An application was made by Transport for London under the above legislation for the London Underground (Northern Line Extension) Order. The proposal sought the extension of the Charing Cross Branch of the Northern Line from Kennington to a new station at Battersea Power Station, with an intermediate station at Nine Elms (this site).

4.6 Following a public inquiry (19/11/13 – 20/12/13) the Secretary of State approved the Order, th thereby giving deemed planning permission for the extension on 12 November 2014. This consent is currently being implemented.

4.7 Nine Elms Over Station Development (OSD) The majority of this site forms part of the original application for development above the Nine Elms Station (15/06216/FUL) which was approved in 2016. The full description of development is as follows: A residential led mixed use development above and surrounding the proposed Nine Elms Station comprising four buildings between 5 and 20 storeys above the station podium and ranging in height from 29m AOD to 92m AOD, providing 332 residential units (C3) comprising 1 bed, 2 bed, 3 bed and 4 bed apartments; 4,811sqm of workspace/office (B1); 272sqm of assembly and leisure (D2) and 580sqm of retail (falling within class A1/A3/A4), a new public square, amenity space, play space, pedestrian and cycle connections, cycle parking, disabled car parking and associated works.

4.8 An application (ref: 20/03950/NMC) for non-material amendments to planning permission ref: 15/06216/FUL relating to amendments to conditions 5 (Archaeology), 6 (Drainage), 8 (FRA), 10 (External Construction Detailing), 11 (external materials - sample panels), 15 (Crime Prevention Strategy), 17 (Landscaping), 21 (Cycle Parking), 23 (Car parking), 24 (Waste Management Strategy) , 28 (Sound Insulation), 32 (Code for Sustainable Homes), 35 (Photovoltaics) and 38 (Solar Glare) to facilitate phased delivery of the development is pending consideration.

4.9 An application (ref: 20/03994/S106) for a deed of variation to the s106 legal agreement for planning permission ref: 15/06216/FUL relating to amendments to schedules: 3 (Local Labour in Construction and General Employment and Skills contributions); 4 (Intermediate Rental Units); (Affordable Housing Review); 9 (Employment and Skills Plan); 10 (Final energy strategy and District Heating Network Statement) and 13 (Landscaping/Public Realm) to facilitate phased delivery of the development is pending consideration. The proposal seeks to adjust proportionally financial contributions and alter triggers to align with the intended phasing strategy. During the assessment, it was discovered that the public realm plan annexed to the legal agreement incorporated a small piece of land which forms part of the Apex site in LB of Wandsworth which is owned by the CGMA - a third party who was not bound by the legal agreement. This application also seeks to incorporate the correct plan in its place.

4.10 Environmental Impact Assessment (EIA) Screening Opinion A request for a screening opinion (ref: 19/04480/EIASCR) in respect of an Environmental Impact Assessment for the proposed residential-led mixed use development was made on 2nd December 2019. Officers considered the proposals in accordance with the regulations and concluded that an EIA was not required. This was communicated formally to the applicant on 13th January 2020.

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4.11 Covent Garden Market – Apex Site The Apex Site immediately adjoins the site to the west and forms part of the wider Covent Garden Market Authority (CGMA). This site is within the LB of Wandsworth and has an outline planning permission (ref. 2014/2810) for seven buildings (A1-A7) to provide a mix of uses including retail, offices, leisure and residential. Building A1 adjoins the application site and has an upper height limit of 86.2m AOD, which equates to approximately 20-25 storeys in height. The layout of the Apex Site in relation to this site is shown in Figure 22, below.

Figure 22: CGMA Apex site and its relationship with the current application.

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5. CONSULTATIONS

5.1 Statutory and External Consultees

5.1.1 Greater London Authority (GLA) Stage 1 Report (18/11/20) Proposal is generally supported in strategic planning terms, subject to the following: ▪ Strong support for optimisation of housing provision on site; ▪ Affordable housing: The scheme could be eligible for the Fast Track Route, subject to confirmation of the final tenure split. Further discussions are therefore necessary to confirm whether the proposed tenure split is appropriate, based on identified local need. The final rent level assumptions and income thresholds should be secured by the Council. Appropriate review mechanisms should also be secured in the s106 agreement. (Tenures are discussed in the ‘Affordable housing tenure and viability’ section and also see Head of Terms (HoT) of the S106 agreement in section 6.13 of this report.) ▪ The overall unit mix and residential quality is acceptable. ▪ Access to internal and external amenity spaces to be provided to all residents and play space provision to be secured in perpetuity (HoT) ▪ Support for the layout, height and massing, architectural detailing to be secured by conditions (10 and 11) ▪ The proposals would not cause harm to any designated views, heritage assets or their settings ▪ Conditions relating to fire safety (C51); M4(2) and M4(3) units (C13); provision of Legible London Signage (10); Travel Plan (C23 and HoT); Delivery and Servicing Plan (19) Construction Logistics Plan (3) ▪ Removal of on-street car parking rights, 3 year cycle hire membership for all units and a contribution of £20,000 towards 10 additional cycle hire stands to be secured through s106 (HoT) ▪ Cycle parking should accord with the London Cycle Design Standards. Further information was received during application process which is considered to be acceptable given site’s constraints and a condition (21) is recommended. ▪ Commitment to the Street Space for London Plan has been confirmed by the applicant during the application process and this is reflected in Condition 3. ▪ The energy strategy is generally compliant with the London Plan policies however, the applicant is required to submit the additional information, which has been requested below. - Re-modelling of ‘Be Lean’ stage for both uses. Further information was submitted during application process i and a condition is also recommended (7) - Minimisation of energy costs to occupiers – Further information was provided by the applicant to the GLA and considered acceptable - Evidence of correspondence with DHN providers – Further information was provided by the applicant to the GLA - Drawings demonstrating how the site is to be future-proofed for a connection to a District Heating Network and detailed drawings of centralised energy centre have been provided by the applicant and considered to be acceptable by the GLA. - Be green: additional information on the loop system; heat recovery from the tube and the proposed heat pumps has been provided and found acceptable buy the GLA - Increased provision of PV panels was investigated and further area on Block B identified. A condition (43) is recommended to ensure this is further investigated at detailed design stage. - Carbon off setting to be confirmed – further information has been provided to the GLA and the council’s sustainability consultant. The final contribution will be established through revised Energy Strategy (condition 7) and secured through the s106 agreement. ▪ Flood risk and sustainable drainage: recommended further flood resistance measures to

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ground floor areas (see Flood Risk section of this report) and a condition relating to a Flood Warning and Evacuation plan (Condition 9). Further information relating to drainage was provided during the application process and conditions recommended by Thames Water are recommended. ▪ Requested further details relating to water efficiency which are secured through conditions (37, 38 and 39) ▪ Urban greening to be maximised – the applicant submitted further information which were considered to be acceptable by the council’s biodiversity and sustainability advisors. ▪ (Officer comment: responses to the GLA comments are provided in each bullet point. Officers consider that the suggested conditions and HoT address matters raised in the GLA Stage 1 response).

5.1.2 Environment Agency (27/08/20) No objection or conditions recommended.

5.1.3 Historic England – Archaeology (20/10/20) No objection. No further assessments or conditions are required.

5.1.4 Historic England No comment

5.1.5 TfL Infrastructure Protection (26/08/20) No objection. The planning applicant is in communication with London Underground engineers with regard to the development above. Subject to the applicant fulfilling their obligations to London Underground and Transport for London under the legal requirements between ourselves and the promoter of the development we have no objection to make on this planning application. (officer comment: Informative 10 added))

5.1.6 Metropolitan Police - Designing Out Crime/Counter Terrorism (18/02/21) No objection in principle, subject to conditions to ensure that the development achieves Secured by Design Standards and the submission of a Counter Terrorism Strategy (officer comment: conditions 51, 52 and 53 are recommended)

5.1.7 Natural England (25/08/2020) No comment

5.1.8 Network Rail (21/10/2020) No objection subject to a requirement that the applicant/developer contacts Network Rail’s Asset Protection and Optimisation (ASPRO) team prior to works commencing and other informatives (officer comment: Informative 12 added).

5.1.9 Thames Water (04/09/2020) No objection subject to conditions. During the application process the applicant submitted additional detailed information relating to foul and surface water and Thames Water subsequently confirmed that both surface and foul water discharge by gravity to the combined sewer in Wandsworth Road via a new combined connection. Due to site constraints, Thames Water agreed with LLFA, that surface water rates cannot be restricted any further due to loading above Nine Elms Underground Station. Requested conditions relating to potable water infrastructure (8) further water capacity analysis (40), piling method statement (condition 18) and informatives (11). (officer comment: conditions recommended as indicated in the brackets)

5.1.10 TfL Spatial Planning (11.20) No objection. In order to be fully compliant with the Mayor’s Transport Strategy and the PLP, further action required from the applicant is summarised below:

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• Design and access to cycle stores should accord with the London Cycling Design Standards. (officer comment: see assessment under transport section and condition 21) • A contribution of £20k towards the provision of 10 cycle hire docks should be secured (HoT) • A minimum of three years free membership of the Cycle Hire scheme for each dwelling should be provided (officer comment: see HoT)) • Conditions to secure: Car Parking Management Plan London signage, Travel Plan, Construction Logistics Plan and Delivery and Servicing Plan. (officer comment: conditions 22, 10, 23, 3 and 19)

5.1.11 London Borough of Wandsworth (29/11/2020) No objection, made the following comments: ▪ Stressed the importance of providing safe and attractive access from Nine Elms station including provision of active frontages wherever possible (officer comment: the proposals meet those objectives) ▪ Request that daylight/sunlight assessment in relation to Building A1 on the Apex site is undertaken and the internal daylight assessment considers the impact of the approved scheme. (officer comment: this has been received during the application process and is discussed in section 6.12 of this report) ▪ Distance of 15m should be maintained from the Apex site buildings (officer comment: the proposed building would be over 15m from the Apex building) ▪ Development should accord with the Nine Elms Strategy Board’s agreed Employment and Skills Framework (officer comment: the council’s Employment and Skills Team advised that this will be achieved by widening the definition of local resident in the legal agreement – see HoT)

5.1.12 London Fire Brigade (04/03/2021) – no comments.

5.2 Internal:

5.2.1 Parks and Open Spaces– No objection, mitigation measures identified within the Biodiversity Report to be secured through conditions (4 and 15), exterior lighting strategy acceptable; following review of further information received in relation to Urban Greening Factor recommended conditions (41, 42, 44).

5.2.2 Veolia – No objection following a review of additional information requested in relation to collection vehicle size and weight of compacted waste.

5.2.3 Urban Design - No objection subject to conditions (10, 11, 12, 14, 15). Satisfied with further information received relating to circulation space and revisions introduced during the application process.

5.2.4 Sustainability (Bioregional) – No objection subject to conditions relating to: - potential connection to decentralised networks (HoT); - SAP calculations (33); - A revised energy statement to investigate improvements to the be Lean stage and calculate carbon offset contribution (7); - BREEAM (34 and 35) - Overheating analysis (36) - Water efficiency (37, 38 and 39) - Green roofs specification (41) - Urban Greening Factor (44) - Net biodiversity (15)

5.2.5 Policy – No objection but requested that the following is investigated/secured: - Commercial uses acceptable in principle except for A5 use and uses to be regulated through

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conditions (46 and 47) (A5 use has been removed from the scheme) - Officers to verify loss of employment generating use (See para 6.1.10 of this report) - Support for increased housing provision on site including BtR, officers to be satisfied that second core option has been sufficiently explored and 25 year covenant should be sought if possible (see section 6.1 of this report) - BtR features to be secured through legal agreement (HoT) - The proposal to be viability tested and affordable housing and review mechanisms secured through legal agreement (See section 6.2 of this report and HoT) - The applicant should be asked to provide more family-sized units and fewer studio units (This was explored by officers and the unit mix is discussed in section 6.3 of this report)

5.2.6 Transport, Parking and Highways – No objection following the review of additional information submitted during the application process and conditions/planning obligations recommended in relation to: - Cycle parking details including lift details (21) - Delivery and Servicing Plan (19) - Construction Management Plan (3) - Electric Vehicle Charging Points (24) - Travel plan and monitoring fee (23 and HoT) - Car Parking Management Plan (22 and HoT) - Parking permit free (HoT) - Financial contribution towards 10 cycle hire docking stands on Hebden Place (HoT) - Three year membership of the Cycle Hire scheme for each dwelling (HoT) - Three year car club membership for each dwelling (HoT) - Two new on-street car club bays to be provided (HoT) - A Heathy Route Network contribution of £ £172,500 for Pascal Street improvements (HoT) - S278 agreement for highway works (HoT)

5.2.7 Travel Plan coordinator – No objections subject to a condition (24) and monitoring fee (HoT)

5.2.8 Building Control – No objection.

5.2.9 Regulatory Support Services (Environmental Health) – no objection subject to conditions: - CEMP (Condition 3) - Flues and extraction plant (Condition 28) - Noise and vibration attenuation of ventilation plant (Condition 29) - Environmental noise and vibration (Condition 6, 25 and 26) - Noise control management (Condition 27) - Commercial uses management (Condition 31) - Delivery and Servicing management plan (Condition 19) - Pedestrian Wind Microclimate (Condition 30) - External Lighting (Condition 32)

5.2.10 Lead Local Flood Officer – No objection . 5.2.11 Air quality – No objections subject to conditions (4 and 5)

5.2.12 Employment and Skills – No objections subject to legal agreement to secure Employment and Skills plans and a financial contribution of £280,961 (HoT)

5.2.13 Arboricultural Officer - No objections subject to conditions (15, 16, 41, 42, 44)

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5.3 Adjoining owners/occupiers

5.3.1 Letters were sent to all adjoining properties and wider neighbours (1031). In addition, site notices (x3) were displayed around the site from 7th September to 28th September 2020, and the application was advertised in the local paper (South London Press) on 25th August. In response to consultation seven letters of representation were received of which two were in support and five were in objection. It is noted that one objection (relating to the impact on the Apex site) was withdrawn following a review of additional information provided by the applicant during the application process. The table below summarises the key issues raised.

Summary of objections Response Land Use • There is no need for such dense The site is located in a designated development in this area or more opportunity area and the density of the ‘unaffordable’ homes in the area proposed development is considered to be • What will be done to prevent flats from acceptable. Please refer to section 6.3 of this being sold to investors who will keep them report. empty The scheme includes 179 affordable units which represents 40 per cent of all homes (by habitable room) which is a policy compliant percentage for the nature of the scheme. Please refer to section 6.2 of this report, The proposal includes ‘Built to Rent’ homes which means that they are expected to be rented out rather than sold. A covenant provides for a claw-back arrangement if the homes are sold out of the BtR tenure before the end of 15 years. Please refer to paragraphs 6.1.4 – 6.1.8 of this report.

• Concern that public ream which is said to The proposed Pascal Square would be be available for community use will not delivered as part of the scheme and be materialise accessible to the public. This is proposed to be secured through the s106 agreement. Please also refer to section 6.4.20 – 6.4.25 of this report.

Design - Scale and Massing

• The new buildings should not be allowed Annex 11 of the Draft Revised Lambeth Local at all because they do not fit withing the Plan identifies the application site (as cluster policy of the London and Lambeth appropriate for tall buildings up to 100m AOD Plans. This is because they are and the proposed scheme does not exceed significantly taller than the existing tall that height having a maximum height of buildings which comprise the cluster on to 88.82m AOD. Officers consider that the which they are to be appended. The policy proposal in terms of scale, massing and says that such buildings must become less external appearance creates an acceptable small away from the tallest building. transition in scale between the taller parts of the cluster to the north and east and the lower scale of residential development to the south; further taking into account the delivery of a new station on this site and the intensification opportunity this presents. Please refer to section 6.4 of this report.

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• The minimum distance between proposed The proposed Block A sits 15.7m from the Building A and the consented Building A1 proposed building on the Apex site which is on the Apex site should be no less than in no less than the extant consent. the consented scheme.

Amenity • Unacceptable loss of daylight and sunlight The applicant has undertaken a full daylight, sunlight and overshadowing study of the proposed development and all relevant existing uses adjoining the site. The study has been subject to independent assessment, which considers the change from the ‘consented’ to ‘proposed’ application scheme and there is fairly limited effect in absolute terms upon existing neighbouring properties, with the isolated exception of three rooms at low level in Block D at Nine Elms Point. The impact on sunlight and daylight received by neighbouring residential occupiers is considered to be acceptable. Please refer to section 6.7 of this report.

• The daylight and sunlight report relies on The BRE guide allows to consider an extant the allegedly approved scheme which will scheme as the baseline for daylight and have significant impact on light and this sunlight assessment and the methodology proposal will make it worse. adopted by the applicant has been found acceptable by the council’s independent advisor. Please refer to section 6.7 of this report.

• The Daylight and Sunlight Assessment A supplementary daylight submission was should be revised to include analysis on received during the application process and impact both to and from the consented reviewed by the council’s advisor. Please Apex scheme refer to section 6.7 of this report.

• Tall building will increase wind tunnels on The application is supported by a Micro- Wandsworth Road Climate Assessment which has been reviewed by the council’s wind expert. The proposal is considered to be acceptable in this respect. Please refer to paragraphs 6.11.18 – 6.11.20 of this report.

• Impact of construction activity including in The impact of construction has been the context of other developments in considered and found to be acceptable Wandsworth. subject to a condition relating to a full • Impact of noise from trucks and HGVs Construction Environment Management Plan. accessing the site It is also recommended that a participation in the Considerate Constructors Scheme and the Vauxhall Nine Elms Construction Charter is to be secured through a legal agreement. Noise related impacts associated with operational phase of the proposed scheme are considered to be acceptable. Please refer to paragraphs 6.7.36 – 6.7.38 of this report.

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• Improvements to the safety of pedestrians The assessment of the application is in Wandsworth Road would be welcome. informed by feedback from the TfL Spatial Planning Team and Lambeth Highways and Transport teams who do not consider that improvements to Wandsworth Road are required to make the scheme acceptable in planning terms. The proposal would deliver improvements to Pascal Street and publicly accessible areas within the application site.

Other • The impact on public services and The application is accompanied by an community facilities will be significant Education and Health Needs Assessment which shows that there is sufficient capacity in the area to accommodate demand for GP and educational services created by the proposed development. Summary of comments in support

• The development will provide more Noted.

housing opportunities and closer to TFL station • Planning and development should focus Noted. Biodiversity and air quality and related on the investment in more green spaces matters are discussed in sections 6.8.8-6.8.9 and improvements in air quality in the and 6.11.14 – 6.11.17 of this report. local area to offset the emissions from construction.

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5 POLICIES

5.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise. The development plan in Lambeth is the new London Plan (LP) (2021) and the Lambeth Local Plan (LLP) (September 2015). This application is also subject to the heritage statutory provisions as set out in the agenda pack and heritage analysis of the report.

5.2 The LLP is currently under partial review to ensure it complies with amendments to the National Planning Policy Framework (NPPF) and the new London Plan. The Draft Revised Lambeth Local Plan (DRLLP) underwent public consultation under Regulation 19 of the Town and Country Planning (Local Plans) (England) Regulations 2012 between 31 January and 13 March 2020 and was submitted to the Secretary of State for examination on 22 May 2020. The examination hearing took place between the 27 October and 13 November 2020. The Inspector’s proposed main modifications will be made available for public consultation between 15 February and 29 March 2021. Those draft policies that are unaffected by proposed main modifications can be considered to have significant weight at this point, with moderate weight afforded to those policies that are subject to proposed main modifications.

5.3 The site falls within Kennington, Oval and Vauxhall designated neighbourhood planning area. A draft Kennington, Oval and Vauxhall neighbourhood plan has undergone pre-submission consultation although no weight can be given to these policies at this stage in the neighbourhood planning process. Kennington, Oval and Vauxhall (KOV) Neighbourhood Forum’s designation as a neighbourhood planning forum expired on 13 July 2020. KOV have submitted an application to be re-designated as a neighbourhood planning forum and a decision is expected in due course.

5.4 The latest NPPF was published in 2018 and updated in 2019. This document sets out the Government’s planning policies for England including the presumption in favour of sustainable development and is a material consideration in the determination of all applications.

5.5 The current planning application has been considered against all relevant national, regional and local planning policies as well as any relevant guidance. A full list of relevant policies and guidance has been set out in Appendix 3 to this report.

6 PLANNING ASSESSMENT

6.1 Land Use

6.1.1 The proposed development is a residential-led mixed use scheme, comprising 479 new homes and a commercial unit above the new Nine Elms station, within the Vauxhall Nine Elms Battersea Opportunity Area (VNEB). The VNEB Opportunity Area Planning Framework (OAPF) identifies this area for high-density mixed-use development, including office, retail and residential intensification with a tall building cluster with heights up to 150m. As such, the LP states that at least 18,500 new homes and 18,500 new jobs shall be delivered in VNEB during the lifetime of the plan.

6.1.2 Lambeth recognises this opportunity and has adopted the Vauxhall Supplementary Planning Document (SPD), which sets out the key context in which new development will be delivered. The site is located within the Pascal Place Character Area, encompassing this site and the Sainsbury’s site to the north. In this area the SPD seeks to improve connections to and from the new station, access to the linear park, the river and development to the north. Active uses on Wandsworth Road and along Pascal Street are also encouraged. The SPD designates the area to the south

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and east of the railway (encompassing this site) as an area of tall building sensitivity. The greatest sensitivity is further away from this site, closer to Vauxhall Park and its surrounding conservation area. Annex 11 of the DRLLP identifies the application site (location V6) as appropriate for tall buildings up to 100m AOD. In light of the above strategy, the overall principle of development is considered acceptable. Each of the specific uses proposed are considered further in land use terms below.

6.1.3 Residential Use The application involves 479 self-contained residential units which is an uplift of 147 units when compared to the extant permission. This use is welcome in principle and helps to achieve the objectives of LLP policy H1 and DRLLP policy H1 around maximising housing growth, as well as LP policy H1 around optimising the potential for housing delivery on suitable and available sites. The proposed mix of uses is also consistent with the objectives of LLP policy PN2 and DRLLP policy PN2 relating to Vauxhall.

Built to Rent (BtR) 6.1.4 The residential element is proposed in the form of BtR units. For clarity, in terms of use class categorisation BtR uses remain undistinguished from traditional residential uses and therefore also fall in C3 use. These units will effectively replace the market sale housing and affordable intermediate rent units of the extant consent. It is considered that the change in residential product from market sale units and affordable intermediate rent to a wholly build to rent is acceptable in principle, subject to the requirements of current and emerging Built to Rent policies being met.

6.1.5 There is no policy specific to Build to Rent in the current LLP. However, there is policy H11 in the LP and emerging policy H12 in the DRLLP, both of which are material considerations. LP H11 has full weight while DRLLP policy H12 is unaffected by the proposed main modifications and can be afforded significant weight.

6.1.6 All proposals for BtR must meet the criteria set out in part B of policy H11 of the LP to qualify as BtR. The criteria and how the proposals comply is as follows:

(a) size of scheme – the proposed scheme provides 479 residential units in total which exceeds the minimum requirement of 50 units; (b) covenanted for at least 15 years - the proposed residential units would be covenanted for rental use for 15 years and will be secured by a S106 planning obligation; (c) clawback mechanism – a clawback mechanism is included to ensure there is no financial incentive to break the covenant. The mechanism will follow the Formula set out in the GLA’s Affordable Housing SPG (2017) and will also be secured as a S106 planning obligation. (d) self-containment and separate letting of units – all the residential units will be self- contained and will be let separately. (e) unified ownership and management of all tenures – the residential units will be held in unified ownership and will be professionally managed by CLL with daily on-site presence. (f) longer tenancies (three years or more) with break clauses – all tenants will be offered a tenancy of up to 5 years with break clauses allowing a tenant to give 1 months’ notice after 6 months. Both will be secured as a S106 planning obligation. (g) rent and service charge certainty - all rents will be inclusive of service charges. Rent certainty will be provided to tenants for the period of their tenancy by clearly setting out how annual rent increases will be calculated (formula-linked) within the tenancy agreement. This will be secured by a s106 planning obligation. (h) on-site management and fees - the proposed development will have an on-site management presence from 8am to 8pm to assist future residents, manage deliveries and resolve any issues. The development will also have a 24 hour security presence. (i) providers have a complaints procedure in place and are a member of a recognised

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ombudsman scheme - CLL is committed to having these procedures in place in line with its existing current practices. (j) providers do not charge up-front fees other than deposits – the applicant advises that there will be no upfront letting fees and deposits will be held securely in an appropriate Deposit Protection Scheme.

6.1.7 Policy H12 of DRLLP follows the policy approach set out in LP policy H11 but includes a number of additional requirements including a minimum covenant period of 25 years. It is noted that the applicant disputed this emerging policy through the examination process, but it is now given significant weight as the Inspector has not suggested any modifications to it. The Housing Delivery Statement submitted with the application argues that this requirement is onerous in the investment market, and effectively imposes a discount to the scheme’s investment value. The applicant considers that a 25 year covenant would have a severe impact on the viability and deliverability of the scheme. While this is not agreed by officers, the application was received in July 2020 which pre-dates this policy requirement which when combined with the fact the DRLLP H12 is not given full weight against the adopted LP policy H11 which requires a 15 year covenant period, is considered to be acceptable.

6.1.8 In principle, the proposed BtR units on this site are therefore supported by officers provided that appropriate planning obligations are secured to ensure compliance with the London Plan policy criteria above.

6.1.9 Ancillary Residential Uses The proposals include the provision of an internal shared residential amenity space which could include uses such as a cinema or games rooms. These facilities would only be available for use by all residents of Blocks A, B and C and not by members of the public. As such, the facilities would be ancillary to the C3 use and are considered acceptable in land use terms.

6.1.10 Employment Use Prior to clearance, the site accommodated approximately 4,200sq.m of employment floorspace. In the assessment of the application leading to the extant permission, it was acknowledged that the application under the TWAO addressed the loss of the previous employment floorspace through the relocation of the existing businesses to alternative sites. In addition, the extant permission includes provision of 4,811sq.m of new purpose-built office floorspace in Block D. It is expected that this would be delivered though the extant permission and the proposed phasing secured through the s106 agreement will allow for the implementation of Block D. Officers acknowledge that there is a possibility that Block D from the extant permission may not come forward. The assessment of the application under consideration does not rely on the delivery of Block D to make the current development acceptable. Overall, the proposals are considered to satisfy the requirements of Policy ED1 of DRLLP.

6.1.11 Commercial Use The proposed development seeks to provide a small (108sq.m) commercial unit falling within Use Classes A1-A4 and D1 which would be located within the Pavilion Building adjacent to the eastern station building and facing Pascal Square. The application is considered under the previous use class order due to the timing of its submission. The suitability of a small commercial unit is accepted through the extant permission and complies with policy ED6 of LLP and policy ED7 in DRLLP which support retail, service, leisure and recreation uses in the CAZ and therefore is supported. The originally proposed A5 use has been removed from the proposals due to the proximity of the site to a primary school. Condition (47) is recommended to ensure that the use of the Pavilion Building is not changed to other uses through permitted development rights.

6.1.12 Development phasing and build out

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The scheme is intended to be delivered in a phased approach. A detailed phasing plan will therefore be sought through the s106 agreement to confirm delivery timescales. This will allow for the delivery of Block D from the extant permission and ensure that public realm is delivered in a timely manner. As explained in paragraph 3.22, this will include the possibility that the delivery of Block D is delayed

6.1.13 Land Use Conclusion Officers have assessed each of the proposed land uses in relation to relevant policies and other material considerations. It is concluded that the proposed mix of uses would be an acceptable mix, according with the aspirations set out in the Opportunity Area Planning Framework, Local Plan and Vauxhall SPD.

6.2 Affordable housing

6.2.1 Part A of policy H11 of the LP allows for affordable housing to be provided entirely as Discount Market Rent (DMR) units managed by a Build to Rent provider and delivered without grant. In these circumstances a registered provider of affordable housing does not need to be involved. It is expected in relation to this application that the DMR units will be managed by a registered provided as the scheme relies on receipt of grant funding. The proposed DMR units are fully integrated within the development and will be designed to the same specification as the market units. DMR homes must be secured in perpetuity which will be secured through the s106 agreement.

6.2.2 DRLLP policy H12 which is given significant weight builds on the approach of the LP by adding a number of Lambeth-specific requirements which are as follows:

Part (A) of the policy states that, where a development proposal involving Build to Rent has potential to include more than one residential core and/or block, applicants should use this to provide low-cost rented housing to be managed independently by a registered provider of affordable housing.

Part (B) of the policy states that, where an applicant can demonstrate to the council’s satisfaction that it is not feasible in design terms to include a separate residential core and/or block, the council will accept the full affordable housing requirement for the scheme as DMR units managed alongside the market rent units in accordance with the requirements of London Plan policy.

6.2.3 Taking part A first, the applicant has demonstrated that although more than one residential core is being provided, it is not viable for one of these to be provided solely for low cost rent accommodation. The potential of mixing tenures via a single core has also been discounted by the applicant due to the need to accommodate separate servicing and management arrangements for Registered Providers (RPs) and the legal constraints concerning service charges and welfare payments to tenants.

6.2.4 The site’s unique circumstances, whereby the development would be located above the station box with only three access points at ground floor level available, means that it is not possible to introduce a true second core into any of the blocks as only one entrance to each block is available at ground floor level. This means that introduction of a second core would be possible only from the podium level upwards. The shared core and shared amenity spaces could impact on the willingness of RPs to manage affordable units in such circumstances. The applicant’s architect has reviewed the design feasibility of accommodating an additional core within Block A which would be introduced at first floor level and therefore share the main entrance core at ground floor level. They estimated that the additional weight of the second core is likely to result

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in a loss of two storeys and overall the introduction of the second core would result in a loss of 34 units and the overall affordable housing provision would be reduced to 34 per cent by habitable room. The two-core option could physically accommodate a 75:25 per cent tenure split with low cost rent and intermediate rent respectively. However, the viability review demonstrated that provision of low cost rent would not viable.

6.2.5 Given the above scheme constraints officers are satisfied that providing an additional separate core (including mixing tenures via a single core) will not be feasible. On this basis, officers would support in principle the provision of affordable housing as DMR units managed alongside the market units in accordance with policy H11 of the LP and part B of policy H12 of the DRLLP.

Quantum of affordable housing

6.2.6 LLP policy H2 states that it will seek the maximum reasonable amount of affordable housing where sites that are over 0.1 hectares or capable of accommodating more than 10 units required to provide at least 50 per cent of units as affordable where public subsidy is available or 40 per cent without public subsidy.

6.2.7 The threshold approach to affordable housing in the Mayor’s Affordable Housing and Viability SPG 2017 and in the LP is a material consideration with full weight. The LP policy H5 sets the affordable housing threshold at 50 per cent on public sector land where there is no portfolio agreement with the Mayor. Where there is a portfolio agreement in place to deliver at least 50 per cent across the portfolio of site, then the 35 per cent threshold should apply to individual sites.

6.2.8 To be eligible for the Fast Track route, a proposal must meet all four criteria set out in LP policy H5: 1) Meet and exceed the relevant threshold level of affordable housing on site without public subsidy 2) Be consistent with the relevant tenure split 3) Meet other relevant policy requirements and obligations to the satisfaction of the borough and the Mayor where relevant 4) Demonstrate that grant has been sought to increase the level of affordable housing

6.2.9 This approach is also cross-referred to in LP policy H11 on Build to Rent.

6.2.10 In the case of the application site, the land is in public sector ownership (TfL). TfL has a portfolio agreement with the Mayor. The BtR portfolio is required to deliver 40 per cent affordable homes on each site to help meet the wider 50 per cent requirement. Four times a year TfL is required to report to the ‘Homes for Londoners Board’ to provide an update on the delivery of new homes on its land (including the delivery of affordable housing). Chaired by the Mayor, this Board provides an extra level of scrutiny and accountability to ensure that TfL is achieving its 50 per cent portfolio wide requirement (that wider portfolio will include both BtR and non BtR schemes). Examples of recent schemes offering 100 per cent affordable housing include two sites in Harrow (Stanmore and Rayners Lane) which are currently under consideration by Harrow Council and overall include 405 affordable units. The proposed level of affordable housing in percentage terms meets the required proportion for a scheme on public sector land where a portfolio agreement is in place with the Mayor of London, as provided for by LP policies H4 and H5.

6.2.11 The proposed delivery of 40 per cent affordable housing is only achieved with housing grant (see point 1 in paragraph 6.2.8) and the borough’s own affordable tenure split set out in policy H12(b) of the DRLLP is also not met (see point 3 in paragraph 6.2.8). The proposed scheme is therefore subject to viability testing to ensure the maximum reasonable amount of affordable housing is being provided. This is discussed further in the following section.

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Affordable housing tenure and viability

6.2.12 LP policy H11 requires at least 30 per cent of the DMR homes in Build to Rent schemes to be provided at an equivalent to LLR with the remaining 70 per cent at a range of genuinely affordable discounts below market rent based on local need and to be agreed with the borough and Mayor where relevant (Section C of the policy and para 4.11.6). The rents are also subject to income and affordability caps regulated by the GLA. Boroughs are permitted to publish guidance setting out the proportion of DMR rental levels.

6.2.13 DRLLP policy H12 (b) confirms this position and adds that the range of genuinely affordable rents to meet priority housing need in Lambeth should be in accordance with the preferred approach set out in the Lambeth Tenancy Strategy (LTS).

6.2.14 The Council’s latest LTS, agreed May 2020, states that larger units should be charged at target rent levels (current £163 per week for a 3 bedroom unit), or equivalent, excluding service charges, to help affordability with families affected by the Benefit Cap. Smaller units (1 and 2 bedrooms) may be charged at up to £217 and £282 per week respectively inclusive of service charges (equivalent to LHA levels in 2019/20). These target levels are relevant in guiding the range of rents that the Council will normally seek in BtR schemes in accordance with LP policy H11 and DRLLP policy H12.

6.2.15 The originally proposed affordable housing tenures included 30 per cent of units at LLR and 70 per cent at DMR set at no more than 65 per cent of open market rent. Based on the expected private market rent values, the approximate rents levels would range from £285 per week for a 1 bedroom 1 person unit to £323 per week for 2 and a 3 bedroom units which is higher than the levels stipulated in the LTS.

6.2.16 Overall, the original proposed tenure split included tenures which did not align with the specified requirements of policy H12(b) of the DRLLP and therefore the scheme had to follow the Viability Tested Route.

6.2.17 Table 1 sets out the viability position at the submission, following independent review and the agreed position.

Input/Output At Submission Independent Final agreed Commentary (Avison Young) Review (BPS) position Cost of £144,005,000 £144,005,000 £144,005,000 Agreed between the construction (£305 per sq ft) (£305 per sq ft) (£305 per sq ft) respective QS’s

PRS delivery £2.9 million £2.9 million £2.9 million Agreed cost Finance costs 6.5% 6.5% 6.5% Not agreed, final £31.3 million £29 million £16.9 million calculation based on (sale at the end of (sale at the end (sale at practical revised BPS advice – stabilisation of 12 month completion) see narrative below. period) stabilisation period) Residential Additional evidence Rental Values: £8,715,036 9,451,200 £8,715,036 provided by the Private Market (£44.45 per sq ft) (£48.20 per sq (£44.45 per sq applicant; weakening ft) ft) of the market LLR – annual £626,646 £626,646 £626,646 Agreed net rental value (£20.72 per sq ft) (£20.72 per sq (£20.72 per sq ft) ft)

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DMR (at 65% of Linked to private market rent) – £1,577,522 £1,476,613 £1,577,522 market rental values annual net (£23.13 per sq ft) (£21.65 per sq (£23.13 per sq as agreed above; rental value ft) ft) changed by BPS due

to error in affordability calculation

Commercial Values (annual £37.50 per sq ft £37.50 per sq ft £37.50 per sq ft Agreed rental value) Commercial 6% 5.5% 6% Additional evidence Yield provided by the

applicant BTR Yield 3.6% 3.25% 3.25% – 3.51% Not agreed, final calculation based on a yield of 3.51% as recommended by BPS – see narrative below. Profit level Blended profit Blended profit Blended profit Overall blended rate (%GDV) target equating to target equating target equating of 12.51% 12.5% on the to 12.5% on the to 12.5% on the BTR element and BTR element; BTR element; 17.5% on the 6% on the 6% on the commercial affordable affordable element element and element and 15% on the 15% on the commercial commercial element element

BTR 16 months 12 months 16 months Additional evidence Stabilisation provided by the applicant Grant £28,000 per £45,000 per £28,000 per Clarification received availability affordable unit LLR unit and affordable unit from the applicant £70,000 per LAR unit Benchmark £29.3 million £11.1 million 13.9 million Not agreed, final Land Value position based on BPS revised calculation Deficit/Surplus -29,624,509 £28,955,483 -£163,792

Table 1: Summary of viability positions.

6.2.18 BPS reviewed the submitted Viability Appraisal and the costs were scrutinised by a quantity surveyor to inform this. Other development costs such as PRS delivery costs, professional fees, commercial marketing and letting fees, residential sales and disposal fees were found to be acceptable. With regards to finance costs, the applicant’s assessment assumed that the sale of the BtR investment is deferred until the end of the stabilisation period, which is when the development is expected to be fully occupied. This delay of 16 months after practical completion generates significant additional costs on finance. BPS noted in their addendum report that the relevant RICS guidance suggests that the valuation of BTR should be akin to commercial and include the sale of the units on practical completion and for shortfalls in income during stabilisation to be treated as a deduction and this approach has been subsequently applied in this case.

6.2.19 With regards to private market residential values, there was a disagreement on some

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comparables used as some were not BtR schemes and BPS also advised that the rental values on the agreed comparable schemes adopted by the applicant were lower than what would be expected. However, the applicant submitted updated evidence during the application process which indicates a downturn in the market caused by the COVID-19 pandemic, the effects of which have been noted over the last year and recent market reports suggest rents are down by approximately 12 per cent in prime central London. BPS revised their position given the new evidence, market trend and the fact that the review mechanism will capture any increased rents should the market improve. With regards to DMR values, these are linked to private market values and therefore the above difference in valuations impacted on DMR values too.

6.2.20 AY have adopted a BtR investment yield of 3.6 per cent while BPS originally considered a yield of 3.25 per cent to be more appropriate. BPS noted that the very significant majority of BtR schemes that are developed are forward sold at the point when planning consent is granted. In consequence, there is limited transactional evidence of completed schemes being sold from which to assess market yields as would arise from other investment classes. Following a review of evidence available and industry guidance, BPS advised that an appropriate yield would be likely to fall within a range of 3.25-3.5 percent. BPS acknowledged that the yield evidence inherently includes an element of ambiguity and in accordance with RICS mandatory guidance they have undertaken sensitivity analysis modelling which showed that a yield of 3.5 per cent would bring the scheme into an apparent deficit (approx. £2.5 million). Taking a 0.3 per cent margin being the difference between 3.25 per cent and 3.55 per cent (the effective yield range), it is apparent that a small change to the investment yield has a significant impact on the schemes ability to produce a deficit or surplus.

6.2.21 Where ambiguity exists the generally recognised method for addressing this is through the process of a late-stage viability review. With this approach in mind, BPS have analysed the current scheme based on BPS appraisal inputs and noted that a yield of 3.51 per cent would generate a break-even position. BPS recommended that the late stage review in this case should take place at a point of 18 months post first occupation or 100 per cent occupation rather than the usual 75 per cent of occupation. Adopting the GLA standard review formulas would entail comparison of the scheme GDV at application to GDV at review. Assuming GDV at application reflects the agreed rental income and BPS’ break-even yield, comparison would then be made to the actual rents generated and the market yield at the date of assessment or the actual sale value of the investment if this has occurred during this period. A similar comparison exercise with construction costs would also form part of the review.

6.2.22 The Benchmark Land Value is based on the Alternative Use Value (AUV) approach, based on the extant scheme. BPS queried inputs relating to affordable housing which were subsequently revised and other minor disputed inputs included retail values, commercial disposal fees, CIL and assumed sales period. The main area of disagreement relates to the value of private residential units. The extant scheme includes a number of unusually large penthouses and following a review of additional evidence provided by the applicant BPS increased values for the relevant units. On other unit types, the applicant’s values appeared be more closely linked to the achieved values at Prince of Wales Drive which BPS considered to be at a premium to the subject. BPS considered the most comparable scheme to be Nine Elms Point which adjoins the application site and officers agree with their recommendations.

6.2.23 Overall, the independent review concluded that using the inputs discussed above the scheme broadly achieves a break-even point with a small deficit of £163K. Officers acknowledge difficulties associated with BtR yield and agree with BPS that the proposed later review offers a fair and reasonable way forward to address inherent ambiguity with the yield assessment, whereby the applicant is not required to commit to further upfront delivery of affordable housing, but equally the prospect of a higher income/capitalisation yield remains to be proven by reference to the market as at the date of the review.

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Grant availability 6.2.24 The original viability appraisal is based on a grant of £28,000 per affordable unit from the GLA. During the application process, the applicant was asked to investigate further whether additional grant could be secured. As a result of extensive discussions with officers and the GLA, the applicant has secured an in-principal agreement from the GLA that the following higher grant levels would be available for the scheme: £45,000 per DMR unit at LLR equivalents and the Lambeth Tenancy Strategy (LTS) (2020) equivalents.

6.2.25 The applicant has undertaken scenario testing to identify financially viable options which included:

1) 100 per cent of DMR at LLR levels 2) 80 per cent of DMR units at LLR levels and 20 per cent of DMR units at LTS levels which did not include any family sized units within the LTS units 3) 95 per cent of DMR units at LLR levels and 5 per cent of DMR units at LTS levels which consisted of 8 family sized units and no other unit types 4) 90 per cent of DMR units at LLR levels and 10 per cent of DMR units at LTS levels which included 14 two-bedroom units and five three-bedroom units

6.2.26 The first option was discounted by officers as it did not include any units at LTS levels to which DRLLP policy H12 specifically refers. Option 2 would allow to maximise the overall proportion of LTS units but did not include any family sized units. Option 3 focused purely on family sized units which means that only five per cent of units would be at LTS levels. As such, these options were discounted. Officers consider that the fourth option allows to maximise the number of units provided at genuinely affordable rents including a good mix of larger unit sizes including family sized units. As such, the applicant revised the proposals to incorporate the above rent levels. Subsequently, the applicant secured further grant (a total of £49,500 per unit) from the GLA for the units at LTS equivalents. This allowed an increase in the number of two-bedroom units at LTS equivalents to 16 which results in a split of 88 percent of LLR equivalents and 12 percent of LTS equivalents. The application is considered on this basis.

6.2.27 The proposed affordable units will remain as an intermediate Discount Market Rent product, albeit at reduced rents equivalent to 2021/2022 LLR rents and the LTS (2020) rent level. Rental levels will therefore be set out in the s106 agreement as a percentage of the expected market rents agreed through viability review. This is illustrated in Table 2 below. The Mayor’s Housing Strategy definition of ‘genuinely affordable’ confirms a DMR product can be considered genuinely affordable if it is affordable to households with an annual gross income of no more than £60,000 and applying a rent cap of £1,400 per month (including any applicable service charge but ignoring rent increases during the life of the tenancy). The rent cap is taken from the current London Plan AMR and the equivalent figure may be adjusted in future years. The figure of £1400 per month is calculated as 40 per cent of a net income of a household earning £60K gross (this corresponds to £42,000 net per year or £3,500 net per month, and £1,400 is 40 per cent of that net monthly amount). If the AMR figure of £1,400 per month were to be revised downward in the future, the rent cap would be retained at £1,400; if it were to be revised upwards, the increased AMR figure would be used as the rent cap.

6.2.28 The proposal is that for each size of unit, a market rent would be calculated and an agreed percentage discount applied to that market rent calculated using either the London Living Rent (LLR) or the Lambeth Tenancy Strategy (LTS) rent, depending on the size of unit. The relevant figures are shown in Table 2 (the rent figures given are weekly not monthly). For example, for a one bedroom one person unit, applying the current LLR figure to market rent would result in the discounted rent representing 68 per cent of market rent. For a three bedroom unit, applying the LTS figure, the discounted rent would represent 22 per cent of market rent. This discounted rent

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is then compared with the rent cap of £1,400 per month. If the discounted monthly rent is lower than the amount of the cap, the discounted rent figure would be used rather than £1,400. If the discounted monthly rent is higher than £1,400, then the rent cap of £1,400 would be applied. The discount percentages for each unit type will be rolled forward to subsequent lettings and will not change in the future. The only exercise to be carried out in relation to those subsequent lettings will be to compare the discounted rent (applying the fixed percentage discount to the market rent at the relevant time) with the applicable AMR figure at that time (or the fall-back monthly figure of £1,400 if the AMR is not increased) and then to take as the rent whichever amount is lower. During the period of a tenancy, rents will be increased annually on the basis of CPI+1% during the tenancy.

Table 2. Percentage discount market rent for LLR and LTS equivalents by unit type

Review mechanisms 6.2.29 In accordance with the Mayor’s Affordable Housing and Viability SPG 2017 and the Lambeth Development Viability SPD 2017, it is recommended that two review mechanisms are secured through the S106 agreement to be carried out at the following points which reflect the development’s specific circumstances: - If construction works have not commenced within 24 months of vacant possession of the site; and - At 18 months post first occupation of market units or 100 per cent of occupation of market units (whichever is the earliest)

6.2.30 Where a viability review demonstrates an improvement in the scheme’s viability, a percentage split of the increase in the scheme’s value would be split in accordance with the Lambeth Viability SPD (2017): 20 per cent of the increase in the scheme’s value to be returned to the developer and 80 per cent to the Council. The Council’s share of any surplus arising from the reviews would be applied by the developer to achieve a closer compliance with the rent levels required in a fully a policy compliant scheme which is 40 percent of DMR units at the following rent levels: • 70 per cent of those units subject to a percentage rent discount that results in the equivalent of rents at 2020 LTS levels (it is not anticipated that LTS rates will be revised in the near future and so the 2020 rate is being used); and • 30 per cent of those units subject to a discount that results in the equivalent of the LLR rental levels which are applicable at the point in time of the viability review.

6.2.31 Within the parameters set out above, provision of 3-bedroom units at the Lambeth Tenancy

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Strategy should also be maximised if possible. If there are unlet affordable homes at the point where a late stage review has been conducted, and if the review were to result in a surplus, the rent levels would be reduced at first let. In the event that all affordable homes are let at that point, discounts would be applied at second lettings with a provision that should there be any unallocated surplus 3 years from the late review date, a payment in lieu would apply and would be spent by the Council on provision of affordable housing elsewhere in the borough. Additional surplus profits, once full equivalence had been achieved with the rent levels of the 40 per cent of DMR units as set out above, would then be passed to the developer in their entirety. This mechanism will be secured via the s106 agreement.

Nomination rights and management

6.2.32 The Council also specifies how DMR units should be marketed to future tenants at paragraph 5.116 of the DRLLP. It expects that the 30 per cent element that is secured at rents equivalent to LLR should be advertised via the GLA Homes for Londoners portal and allocated in accordance with the criteria for eligibility for intermediate affordable housing set out in the LTS. The proposal would meet this requirement. In the case of the remaining 70 per cent of DMR units, these must be advertised via the Lambeth Private Sector Solutions service. If in the case a landlord is unable to find a suitable tenant through this process within six months, they will be free to market the properties more widely to other priority groups in the borough subject to income thresholds appropriate to the level of rent secured for the units (social tenants, local residents and those working in the borough).

6.2.33 The applicant has agreed to the principle of a bespoke nominations agreement, which would give letting priority to households who are on the Council’s housing waiting list subject to CLL’s standard tenancy requirements. The details would need to be worked up and agreed with Housing. The nominations agreement would be secured through a planning obligation. As the development relies on a grant from the GLA it is expected that the DMR units will be managed by a Registered Provider. Operational, management and monitoring of tenancies are matters that will be secured via the S106 planning obligation in the event planning permission is given.

6.3 Density and dwelling mix

Density 6.3.1 LP Policy D3 moves away from applying target densities and instead seeks to optimise density through good design. The design-led approach seeks the most appropriate form of development that responds to a site’s context and capacity for growth. Part A of the policy requires the development to make the best use of land and considers design options to determine the most appropriate form of development that responds to a site’s context and capacity for growth. In making a determination on whether a proposal is the most appropriate form of development, Part B of the policy takes the following into account:

• Form and layout (buildings and spaces which respond to locally distinctive forms, encouraging active travel and facilitating efficient servicing and delivery) (See sections 6.5 and 6.14 of this report) • Experience (good quality accommodation, safe and secure environments, and active frontages onto the public realm) (See sections 6.5 – 6.7 and 6.9 – 6.11 of this report) • Quality and character (respond to the existing character, high quality architecture and high sustainability standards) (see sections 6.5 - 6.7 and 6.15 of this report)

6.3.2 Overall, officers are satisfied that the proposal would optimise development on the site in a form which is appropriate and corresponds with the above requirements, which are assessed in further detail within the appropriate sections of this report.

Dwelling mix

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6.3.3 Policy H4 of the LLP states that the council will support proposals that offer a range of dwelling sizes and types to meet current and future housing needs. It requires in part (a)(i) that the affordable housing elements of residential developments (including conversions) should reflect the preferred borough-wide housing mix for social/affordable rented and intermediate housing as follows: 1 bed units - not more than 20% 2 bed units - 20-50% 3 bed units - 40%

6.3.4 The policy position is not as prescriptive for private market housing in that it states that a ‘balanced mix of unit sizes including family accommodation’ should be provided.

6.3.5 Policy H10 of the LP requires, for low-cost rent, boroughs to provide guidance on the size of units required (by number of bedrooms) to ensure affordable housing meets identified needs. In accordance with policy H10, policy H4 of the DRLLP requires the low cost rented element of residential developments to reflect the preferred borough-wide housing mix: 1-bed units Not more than 25% 2-bed units 25-60% 3-bed units Up to 30%

6.3.6 The preferred borough-wide size mix for affordable social rent has been amended in favour of a higher proportion of 2 bed units and there is no longer a specified mix for intermediate affordable housing. The DRLLP states that for market and intermediate housing, a balanced mix of unit sizes including family-sized accommodation should be provided.

6.3.7 The supporting text to LLP policy H4 states that to ensure mixed and balanced communities, a range of dwelling sizes including family-sized housing will be sought from all new developments. Family-sized accommodation is defined as having three or more bedrooms. In addition, the supporting text to the LP policy H4 also states that while developments are expected to reflect the preferred dwelling mix set out above, rigid application of these requirements may not be appropriate in all cases. When considering the mix of dwelling sizes appropriate to a development, the Council will have regard to individual site circumstances including location, site constraints, viability and the achievement of mixed and balanced communities. In all cases proposals will be expected to demonstrate that the provision of family-sized units has been maximised although it should be noted that the DRLLP requires proposals to demonstrate that the provision of family-sized units has been considered.

6.3.8 Table 3 below provides a breakdown of the proposed housing unit mix by tenure:

Table 3: Unit size mix

6.3.9 The affordable housing proposes a range of studios, 1, 2 and 3 bedroom units within Block A. The number of studios and 1 bedroom units would be higher than set out in LLP policy H4 while

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the number of 3-bedroom units would be lower. Although Policy H4 relates to units only, if this analysis against the adopted Local Plan were applied by habitable room this would result in a closer compliance with 1-bedroom units (including studios) at 29 per cent; 2-bedroom units at 37 per cent and 3-bedroom units at 34 per cent.

6.3.10 The proposed provision of 41 3-bedroom units (23 per cent) is an improvement on the extant scheme which included only 16 family sized units (19 per cent). Also, the mix of the proposed market rent housing, which includes studio flats and several 3-bedroom units, is more diverse than in the extant scheme which includes only 1- and 2-bedroom units. In the assessment of the extant scheme, it was recognised that the scheme had to be designed around the constraints set by the station structure below and the need to achieve a high residential quality in terms of daylight/sunlight, aspect and amenity. As such, the residential units have been arranged on the triangular floor plate which impacts on the unit mix and this is also valid for the current application.

6.3.11 It is argued in the Planning Statement that the proposed unit mix also accords with industry experience by Grainger/CLL that 1 and 2-bed units within BtR developments typically have a much higher demand than larger units. Furthermore, as recognised in the GLA Stage 1 response, the LP policy H10 acknowledges that a higher proportion of 1 and 2 bed units is generally more appropriate on sites close to a station and with higher levels of public transport accessibility. This being an entirely BtR proposal, to be delivered directly on top of a station box, the predominance of 1 and 2 bedroom units is acceptable.

6.3.12 Overall, given the unit mix approved in the extant permission, the site’s specific circumstances, the validation of the financial viability assessment and the relative balance in provision within the scheme as a whole, it is considered that this dwelling mix is appropriate in this instance and meets the requirements of policy H10 of LP, H4 of LLP and H4 of DRLLP.

6.4 Design and Conservation

6.4.1 Good design is central to all objectives of the LP and LLP planning policies. Policy D3 of the LP sets out a series of overarching design principles for development in London which seek to optimise site capacity through design-led approach. Policies D4 and D8, require that all new development be of high quality that responds to the surrounding context and enhances the character, legibility, permeability and accessibility of the surrounding neighbourhood. Policy D9 relates to the specific design issues associated with tall and large-scale buildings.

6.4.2 Policies Q5, Q6 and Q7 of the LLP seek to create high quality urban environments and state that proposals will be supported where the design of development is a response to positive aspects of the local context and historic character. Policies Q22 and Q23 of the LPP seek to protect the character and appearance of conservation areas and undesignated heritage assets on the local heritage list. LLP policy Q26 provides local level guidance on the location of tall buildings and their design, requiring them to: achieve design excellence; make a positive contribution to the townscape and skyline; be of the highest standard of architecture and design; and have no adverse impacts on the significance of strategic or local views or heritage assets including their settings.

6.4.3 The Council’s Urban Design and Conservation Team’s comments and those of the GLA have been incorporated into this section of the report.

Design - Layout, Scale, Views and Townscape

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6.4.4 Layout and Scale The site falls within the Vauxhall tall building cluster, as designated in the VNEB OAPF. Policy Q26 ‘Tall buildings’ of the DRLLP supports proposals for tall buildings where they are in locations identified as appropriate for tall buildings in Annex 11. Annex 11 of the DRLLP has been informed by the Vauxhall SPD and identifies the application site (location V6) as appropriate for tall buildings up to 100m AOD.

6.4.5 The consented scheme (15/06216/FUL) was deemed acceptable as the proposed heights were appropriate to the overall approach identified within the OAPF and SPD. The current proposal comprises an increase in height to Blocks B and C of 1 and 3 storeys respectively, Block C now becoming a more prominent marker on Wandsworth Road. This is a height increase which is relative to the surrounding and emerging tall building cluster.

6.4.6 The integration of the consented scheme into the tall building cluster and immediate context was an important consideration. The proposed site layout is similar to the consented in that it is predicated by the new London underground station, the over station buildings are triangular in plan and use the station structures as a podium. Between the two station buildings is a new public square. The over-station development thus begins at second floor level. The three towers sit on top of the two station buildings, Block A on the western building and Blocks B and C on the larger eastern building. The station site runs broadly east to west. The height rationale for the consented scheme comprised an approach whereby angled roofs stepped down in height from the west towards Wandsworth Road. This was to reflect a ‘spiralling down’ of taller buildings set by the context of the adjoining Nine Elms Point (Sainsbury’s scheme) and the approved CGMA scheme to the west and north. The angled roof profile of the previous consent has been omitted with the removal of penthouse apartments the roof profile has been remodelled and simplified to a flat roof. The proposed increase in height to Block C (see Fig 23 and 24 below) differs from the approved scheme however it is acknowledged that it is sited in a prominent location on Wandsworth Road providing a marker for the station.

Figure 23 Visual from the South along Wandsworth Road Figure 24. Sketch showing height increase (red outline indicates extant consent)

6.4.7 On the southern side of Pascal Street is a smaller scale of existing development, predominantly two and three storey houses and flatted blocks. Officers are satisfied that while there is a large variation in scale either side of Pascal Street, this point represents the edge of / gateway to the tall building cluster and the Central Activities Zone. The change in scale at this point also announces the presence of Nine Elms Underground Station with the buildings above being a

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marker for this transport node. The residential units to the south will benefit from improved accessibility, a better outlook towards new areas of public realm (as opposed to an industrial site and car park).

6.4.8 Block A is proposed at 21 storeys +88.82m AOD, Block B at 16 storeys +74.11m AOD and Block C at 17 storeys +77.26m (all to top of parapet). The height strategy is acceptable as it constitutes only a marginal increase on the consented scheme for Block B and C and a decrease for Block A and remains within the parameters deemed acceptable within the VNED OAPF and Vauxhall SPD. The proposed heights sit comfortably within the maximum height of +100m AOD stipulated in Annex 11 of the DRLLP.

6.4.9 Views and Townscape A Heritage Townscape and Visual Impact Assessment (HTVIA) has been submitted, and provides an evaluation of the impact of the proposal in terms of its height and form on strategic views, the surrounding context, on other tall buildings including the emerging cluster when perceived from all directions. It should be noted that the site does not sit within any designated strategic view corridors (London Panoramas, Linear Views or Townscape Views), but a range of River Prospects as defined in the London View Management Framework (LVMF) along with a range of other views have been considered. This includes the local viewing corridor Brixton Panoramic and Brixton Historic Towers.

6.4.10 The application site is located approximately 2km from the Westminster World Heritage Site (WHS). The HTVIA demonstrates that the development would be glimpsed in part from only very limited points within the WHS, beyond the existing and emerging cluster of tall buildings at Vauxhall and Nine Elms (see figure 25). The proposed development would not harm any elements of setting that contribute to the heritage significance or outstanding universal value of the WHS and this view is shared by the GLA. The proposal complies with policy Q19 of the LLP and policy HC2 of LP.

Figure 25: The cumulative view from Westminster Bridge (LVMF18A.2). The scheme is shown in green and other consented developments in yellow.

6.4.11 A range of other views (within 500m) and longer views have also been provided. When viewed from the north from Wandsworth Road (north of the viaduct) (View 1) the development is almost completely obscured by the Nine Elms Point scheme, with the exception of the upper floors of Block C. View 2 a bit further south shows Block C can be seen projecting partially above and to the side of the Nine Elms Point Block B on Wandsworth Road.

6.4.12 From the east, a view from Wilcox Road (View 3) shows the eastern elevation of Block C clearly although it would not be considered to be overbearing on the streetscene. A longer view from the

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east in Brockwell Park shows the blocks to the edge of the main cluster (see Figure 26, below). Officers are also satisfied that the proposal would have no impact on the Brixton Historic Towers local view due to the site’s location being away from the focus of this view.

Figure 26: Cumulative development view from Brockwell Park (scheme shown in green and consented developments in yellow)

6.4.13 Two views from the west have been provided from the opposite side of the river. The view from Pimlico Gardens (View 9) shows a very small part of the scheme siting to the side of but significantly lower than the American Embassy building. The view from Grosvenor Road (View 10) further south shows the development would be indiscernible in this view with only a small portion visible to the west of Nine Elms Point.

6.4.14 In the views from the south the proposal is clearly more visible in the skyline as it forms the southern edge of the emerging tall building cluster. View 4 (see Figure 27) from Wandsworth Road and view 5 (from the eastern side of Wandsworth Road towards Pascal Street) show the development would define the route of Wandsworth Road / Pascal Street and signpost the location of the new Nine Elms Station. However, the bulk is not considered overbearing by officers as a result of the varying form and architectural detailing which breaks up the perception of mass. View 7, further south around Bramley Crescent shows how the three blocks appear slender within the skyline by virtue of their footprint.

Figure 27: View towards north from Wandsworth

6.4.15 Overall the townscape visual impact assessment illustrates in views that the proposal would not affect any identified strategic or locally protected views and the impact on the townscape is considered acceptable. Officers are satisfied that where visible, the proposed development will be perceived as a high quality, contemporary built form in contextually appropriate materials

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which complements the existing and emerging urban fabric of the area and will contribute to establishing an enhanced character for the area in accordance with policies Q25 and Q26 of the LLP and DRLLP and policies HC2, HC3, HC4 and D9 of the LP.

Design and Conservation - Appearance and Materials

6.4.16 The external appearance has changed from the consented scheme, principally in that the materials and façade approach to the station podium is now fully integrated into the towers which is welcomed. A consistent architectural approach is proposed for all three blocks, creating an ordered and cohesive development, with its own distinct character. The overall materials approach using brick as a primary material is welcomed, with each block differentiated by different shades of similar brick tones ranging from pale buff to dark brown such that each block is defined yet together blocks appear as a cohesive group. As recommended by the DRP the proposal has been revised to include a calmer palette which is contextually appropriate. The DRP also recommended using a lighter brick on Block B which has been revised such that Block A comprises a primary dark brown brick with mid brown accent, Block B a primary pale buff brick with accent mid brown and Block C a primary mid brown brick with pale buff brick. Pale coloured reconstituted stone is used as an accent material across the development, with oxblood coloured and pale glazed bricks used to provide legibility.

6.4.17 Balconies have been designed to be either semi or fully recessed where possible to benefit from wind sheltering, especially crucial at upper levels. This strategy contributes to the simplified, sculptural form of each building. The buildings are positively grounded, with each tower brought down to meet the station box. The connection between the buildings and the station box is expressed through the use of an exaggerated shadow gap in dark grey metal. The link buildings between building B and C are distinguished through the use of reconstituted stone clad colonnades. A more open glazing pattern, proportionally similar to the station box identifies the non-residential spaces at first floor level, creating a legibility of uses (see Figure 28).

Figure 28. Bloc B and C façade detail immediately above the station boxes.

6.4.18 The general design approach to denoting entrances and way-finding is welcomed. Care is required to ensure residential entrances are clearly differentiated from the station entrance and full details of signage will be secured by condition together with other external construction detailing (conditions 10 and 15), and samples of materials (condition 11).

Pavilion Building in Pascal Square

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6.4.19 The pavilion is split in to three distinct sections. The north-east corner of the square was identified as prime location for the commercial element as it will receive high footfall once the station is opened and will also receive evening sunlight. The service lift is located at the centre, acting as a division between public and private uses and the plant spaces are located in the southern element, allowing access from Pascal Street. The largely glazed design of the commercial unit will provide activation to the public square and is supported.

Figure 29. The Pavilion Building facing Pascal Square.

Design and Conservation – Public Realm and Landscaping

6.4.20 The scheme proposes a new area of public realm (2,240m2) which broadly aligns with the extant consent, including new links through the site and a public square in the centre of the site (See Appendix 4). An indicative hard and soft landscape and public realm strategy has been provided as part of the application. The proposed public realm (Hebden Place) runs between Block D from the extant scheme and the western station building through to Wandsworth Road and linking into the public realm proposed as part of the Nine Elms Point scheme. The main square sits between the two station buildings measuring 28.7m by 47.5m (to Block D). Pascal Street and Hebden Place are designed to enable freedom of movement for residents, office/retail workers and those accessing the station, whilst Pascal Square seeks to provide larger seated areas for people to dwell for longer periods.

6.4.21 The public realm maximises the opportunity to link in with the wider aspirations to improve connectivity through the site to the west, with routes to the linear park (via CGMA) and the river in accordance with the Vauxhall SPD. Overall, the public realm proposals are welcomed and particularly the integration of landscaping and tree planting which was also commended by the DRP and is accordance policies Q9 and Q10.

6.4.22 High quality paving (predominantly granite), soft landscaping and lighting is proposed throughout the public spaces, with specific details secured via condition. The application is accompanied by details showing the public realm will meet the principles of inclusive design, desired pedestrian routes and access points both for the station and the development above. The potential for additional incidental play space within the public realm is also supported, subject to detail design. The Pavilion Building will also create active frontages along the public realm with potential for external seating.

6.4.23 Officers consider that the quality and quantity of the public realm is acceptable and provides relief to the visual massing of the buildings and the necessary and useable space to support surrounding activity and the level of movement associated with the station. Further details will be secured via condition in relation to the management of public realm.

6.4.24 Comments from the Council’s Parks and Open Spaces Officer support the overall thrust of the

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proposals and the balance between soft and hard landscaping, subject to further detail secured via condition. The Council’s Tree Officer also supports the proposals in principle, subject to ensuring that the soft landscaping scheme is deliverable (i.e. sufficient root depths) and has requested a more detail soft landscaping specification through conditions, including tree pits.

6.4.25 Design Conclusions In conclusion, officers consider that the proposals sit within the policy requirements and design aspirations of both the VNEB OAPF and Vauxhall SPD. The proposed over-station development is also considered to have been appropriately assessed and considered acceptable in terms of strategic and local views. The use of high quality materials and the creation of new public realm to support the new Underground Station forms a suitable transition between the Vauxhall tall building cluster and the area beyond. Subject to conditions indicated a, the proposal would comply with LLP policies Q5, Q6, Q7, Q8, Q9, Q16, Q25 and Q26 and LP policies D3, D4, D8, D9, HC2, HC3 and HC4.

Design and Conservation – Impact on Heritage Assets

6.4.26 The beginning of the Agenda Pack contains a summary of the legislative and national policy context for the assessment of the impact of a development proposal on the historic environment and its heritage assets. This is in addition to LLP and LP policies.

6.4.27 Turning to consider the application of the legislative and policy requirements referred to above, the first step is for the decision-maker to consider each of the designated heritage assets (referred to hereafter simply as “heritage assets”) which would be affected by the proposed development in turn and assess whether the proposed development would result in any harm to the heritage asset.

6.4.28 The decision of the Court of Appeal in Barnwell Manor confirms that the assessment of the degree of harm to the heritage asset is a matter for the planning judgement of the decision- maker.

6.4.29 However, where the decision-maker concludes that there would be some harm to the heritage asset, in deciding whether that harm would be outweighed by the advantages of the proposed development (in the course of undertaking the analysis required by s.38(6) PCPA 2004) the decision-maker is not free to give the harm such weight as the decision-maker thinks appropriate. Rather, Barnwell Manor establishes that a finding of harm to a heritage asset is a consideration to which the decision-maker must give considerable importance and weight in carrying out the balancing exercise.

6.4.30 There is therefore a “strong presumption” against granting planning permission for development which would harm a heritage asset. In the Forge Field case the High Court explained that the presumption is a statutory one. It is not irrebuttable. It can be outweighed by material considerations powerful enough to do so. But a local planning authority can only properly strike the balance between harm to a heritage asset on the one hand and planning benefits on the other if it is conscious of the statutory presumption in favour of preservation and if it demonstrably applies that presumption to the proposal it is considering.

6.4.31 The case-law also establishes that even where the harm identified is less than substantial (i.e. falls within paragraph 196 of the NPPF), that harm must still be given considerable importance and weight.

6.4.32 Where more than one heritage asset would be harmed by the proposed development, the decision-maker also needs to ensure that when the balancing exercise in undertaken, the cumulative effect of those several harms to individual assets is properly considered.

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Considerable importance and weight must be attached to each of the harms identified and to their cumulative effect.

6.4.33 What follows is an officer assessment of the extent of any harm which would result from the proposed development to the significance of the scoped heritage assets provided by the applicant as part of its submission. This includes Conservation Areas, and neighbouring Listed Buildings. Both an individual assessment against each heritage asset as well a cumulative assessment is provided. This is then followed by an assessment of the heritage benefits of the proposals.

6.4.34 The site is not within close proximity to heritage assets however the impact upon all heritage assets within a 500m radius has been assessed. Figure 30 below shows the site in the context of the nearest heritage assets.

Figure 30. Heritage assets nearest to the application site

Impact on heritage assets: conservation areas

6.4.35 The application site is located over 180m away from the Vauxhall Conservation Area. This is a large conservation area, comprising largely of 18th and 19th century development and is urban in character with a mix of residential and commercial uses. Vauxhall Park and Vauxhall Pleasure Gardens are significant, historic open spaces. The setting of this large conservation area, to the north-east of the site, has been transformed by the tall buildings emerging at Vauxhall and Nine Elms, including along Wandsworth Road, immediately north of the site. Considered in the round, the magnitude of change on the setting of the whole conservation area, will be negligible and the effect will be none. As such, there will be no harm to the setting of this conservation area.

6.4.36 The site is located over 260m from the Lansdowne Gardens Conservation Area. The conservation area is characterised by 19th century villas (detached, semi-detached or set in small terraces) with neo-classical or Italianate detailing, built for the middle class. The focal point of the

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conservation area is a formal ‘circus’ where the principal axial routes, including the north / south Lansdowne Gardens, meet. The site is located over 460m from the Wandsworth Road Conservation Area which lies to the south-west. This conservation area has a linear form and comprises mostly 19th century development, ranging from housing to commercial and industrial (the former Plough brewery) uses. The part closest to the site includes the Springfield Methodist church (locally listed) as well as some early 19th century villas (some listed grade II).

6.4.37 The setting of both these conservation areas (Lansdowne Gardens CA to the south-east and Wandsworth Road CA south of the site respectively) has changed since they were built, and the area between them and the site comprises interwar and post-war housing estates. If seen from these conservation areas, the proposed development will be experienced against the backdrop of existing and emerging tall buildings at Vauxhall and Nine Elms. In both cases the magnitude of change will be negligible and there will be no effect on the setting of these conservation areas. As such, there will be no harm to the settings of these conservation areas.

Impact on heritage assets: statutorily listed buildings

6.4.38 The nearest statutorily (grade II) listed building is the former congregational mission hall, at No 1 Wheatsheaf Lane, 215 m to the north-east. The development would be seen next to the recent towers on both sides of Wandsworth Road that lie north of the site, which have transformed the setting of this listed building to the north and west, and will simply appear as part of the cluster of towers at Vauxhall and Nine Elms. There will be no effect on any element of setting that contributes to its heritage significance.

6.4.39 Other listed buildings in the area around the site are located further away and are all listed grade II. They are predominantly residential villas and terraces from the 19th century. All are experienced today in the context of substantial post-war and later development typical of central London, not least the growing cluster of tall buildings at Vauxhall and Nine Elms. While the proposed development will be visible (mainly in glimpsed views) in the setting of some of these heritage assets, there would be no harm to their setting due to the distances and the location of the proposed development within a cluster of tall buildings.

Impact on heritage assets: locally listed buildings

6.4.40 The nearest locally listed building is the South Bank Club at 124 – 130 Wandsworth Road. This robust 20th century building lies on the busy Wandsworth Road. The proposed development will be visible in views north along Wandsworth Road (A3036), seen against a backdrop of the existing and emerging cluster of towers at Vauxhall and Nine Elms. There will be no effect on any elements of setting that contributes to its significance and overall there will be no harm to the setting of this locally listed building.

Impact on heritage assets: cumulative impact and summary

6.4.41 It is the view of officers that the proposal would not cause harm to the significance of any designated or non-designated heritage assets, including the WHS discussed in the earlier sections of this report. Officers have also carried out an assessment on the impact cumulatively. As discussed above, the proposal will be seen in a number of views including in some of the settings of heritage assets. The proposal will be generally seen in the context of the existing and growing cluster of tall buildings and its cumulative impact is considered to cause no harm to the setting of heritage assets. Officers consider that there would be no individual or cumulative harm and this view is shared by the GLA. The proposal would accord with LLP policies Q19, Q20, Q21 and Q22, LP policies HC1, HC2 HC3 and HC4 and the statutory obligations in the Listed Buildings and Conservation Areas Act 1990.

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Assessment of harm versus benefits 6.4.42 Officers consider that the development would not harm the significance of any designated or non-designated heritage assets and that an assessment of harm versus benefits is not required.

6.4.43 However, should Members come to a different view, they must consider the impact of the proposed development on the significance of each designated heritage asset. Great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance (as per paragraph 193 of the NPPF).

6.4.44 If Members come to a view that there would be substantial harm or total loss of the significance of a designated heritage asset, consent should be refused, unless it is demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh the identified harm or loss (as per paragraph 195 of the NPPF).

6.4.45 If Members come to a view that there would be less than substantial harm to the significance of a designated heritage asset, the identified harm must still be given considerable importance and weight when weighed against the public benefits of the proposal, including where appropriate, securing the heritage asset’s optimum viable use (as per paragraph 196 of the NPPF).

6.4.46 If Members consider harm to result to a non-designated heritage asset, para 197 of the NPPF states that ‘a balanced judgement will be required having regard to the scale of any harm of loss and the significance of the heritage asset’.

6.4.47 In this case, officers consider that the development provides the following public benefits:

• 479 new homes of which 176 would be affordable which represents an uplift from the extant scheme of 147 and 92 units respectively. • Up to 28 new permanent jobs, employment and training opportunities through the Employment and Skills Plan and a financial contribution secured via s106 • Benefits to local economy associated with new residents supporting local businesses • Enhancements to public realm and creation of active frontages on Pascal Square • Transport improvements including a contribution of £172,500 towards implementation of Healthy Route Networks • Improvements to biodiversity increase the biodiversity and urban greening on the site. • Optimising brownfield land

6.4.48 Officers consider that the above constitutes public benefits that would outweigh any harm to the significance of heritage assets.

6.5 Secured by Design

6.5.1 In accordance with LP policy D11 and LLP policy Q3 and as part of the pre- application process, the applicant has engaged the Metropolitan Police’s Designing Out Crime Officer and Counter Terrorism in an attempt to design out opportunities for crime wherever practicable. The scheme has incorporated a range of design principles in order to promote natural surveillance and ensure the scheme meets the principles of Secured by Design. It has also considered the levels of movement associated with the Underground Station underneath. In particular the scheme provides legible routes through the public realm that would benefit from natural surveillance and activity at different times of the day, which is supported.

6.5.2 In terms of the residential blocks the scheme will be required to install an access control system

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for each block along with secure residential foyers/secure access to lifts/stairs/vehicular access, including external lighting and CCTV where appropriate. In addition, the scheme would be required to install blast resistant measures for all glazing to reduce risk in the event of an incident. The applicant will be also required to investigate whether access to UK Power Networks switch rooms could be controlled by means such as gates which would be the preferred option.

6.5.3 In accordance with comments made by the Designing Out Crime and Counter Terrorism Officers the proposals are considered to be acceptable, subject to conditions to secure compliance with the principles of Secured by Design (condition 51 and 52) and the provision of a Counter Terrorism Strategy (condition 53).

6.6 Standard of residential accommodation

Design and layout of accommodation 6.6.1 All units will meet or exceed the minimum space standards set out in the LP policy D6 and provide adequate room sizes, storage space and floor to ceiling height standards. As recommended by the DRP at pre-application stage, there have been amendments to layout of flats to improve efficiency of space. In terms of the internal layout design, core A would serve 9 units per floor and cores B and C would serve 10 units per floor. While this exceeds the recommended 8 units per floor stipulated in the LP Housing SPD, corridors would be 1.5m wide with enhanced width in front of lifts (1.8m). Furthermore, doors to individual flats would be clustered at the end of corridors to facilitate neighbour interaction and there would be clear wayfinding through use of accent materials.

6.6.2 182 units (38 per cent of the total) would be dual aspect and the remaining 297 units (62 per cent of the total) would be single aspect with views to the south, east or west. Over 72 per cent of the single aspect units (216) would have an enhanced aspect as a result of the angled design of the inset balconies. No north facing single aspect units are proposed. The typical location of single and enhanced outlook units is shown in figure 31 below. Officers consider the design approach adopted in this highly constrained location ensures that the residential accommodation in terms of outlook, light and ventilation is of the highest possible quality for future occupiers and exceptional circumstances have been demonstrated in terms of site constraints and the proportion of single aspect units in the extant scheme.

6.6.3 The proposals are also considered to be acceptable in terms of outlook and privacy. Within the development itself the separation distance between block A and B is over 30m. Between block B and C, the distances between windows are reduced to over 15m, however the internal layouts have been arranged so that this relationship is between bedrooms and living rooms, with living rooms benefiting from the main outlook in a different direction.

6.6.4 In terms of adjoining sites, Block A generally sits 13m to the south of the employment uses proposed in Block D in the extant consent with a pinch point of 11m. However, all of the units facing north would have aspects to the east and/or west in addition. Block A sits 15.7m from the proposed building on the Apex Site (CGMA) to the west, although there are no sole habitable windows that face directly onto this building as a result of the proposed footprint of Block A. Blocks B and C sit approximately 13m to the south of the Sainsbury’s scheme, but again all units offer additional views east and/or west. Furthermore, the positioning of windows has been designed to ensure sufficient privacy and a number of windows would be partially obscured. Finally, the proposed blocks would be at least 17m from the residential properties on the southern side of Pascal Street. The separation distances and outlook are highly comparable to the extant consent.

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Figure 31. Typical layouts and aspect (for Block B above fifth floor level)

6.6.5 12.7 per cent of the proposed dwellings (61) will be designed to comply with Building Regulations requirements Part M4(3) whilst the remaining 87.3 per cent will be designed to comply with part M4(2). This complies with LP policy D7 and will be secured by an appropriately worded planning condition (13). The M4(3) units are spread throughout the development and include a range of unit sizes.

6.6.6 Overall, officers consider that the proposed internal layout design of the residential accommodation in terms of the units per floor, unit sizes and aspect is acceptable and therefore will comply with policy D6 of the LP; policy H5(a) of the LLP and policy H5(a) of the DRLLP.

Daylight and sunlight 6.6.7 Policy Q2 of the LLP states that development will be supported if it would not have an unacceptable impact on levels of daylight and sunlight on the host property and adequate amenity space is provided free from oppressive overshadowing. Policy D6 of the LP states that the design of development should provide sufficient daylight and sunlight to new and surrounding housing that is appropriate for its context, whilst avoiding overheating, minimising overshadowing and maximising the usability of outside amenity space.

6.6.8 The provision of daylight and sunlight to the new development has been assessed in a Sunlight and Daylight Assessment prepared by Avison and Young which has been independently verified by the Council’s Sunlight and Daylight consultant.

6.6.9 In terms of daylight to the proposed new habitable rooms, consideration is often reviewed on an average daylight factor (ADF) basis, especially since the provision of daylight is targeted to the

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actual room use with a standard ADF targeted of 1 per cent bedrooms, 1.5 per cent living rooms and 2 per cent kitchens. In instances of any applicable open-plan arrangements of ‘living/kitchen/dining’ rooms, an alternative methodology to that of the BRE Guide (that simply seeks to apply the highest ADF for a given room use within a multiple-use room to that of the whole room), is that the ADF is based upon the predominant room use. This is more commonly applied within the industry since modern design now often places kitchens typically at the back of such open-plan arrangements and to achieve a 2 per cent ADF for the rear of room is unlikely. Furthermore, in reference to the BRE Guide, internal galley-type kitchens are permissible providing they are directly linked to a well daylit living room which for this scheme, would be the case in any event, albeit the design has typically not sought to isolate the kitchen area. Thus often analysis is on the basis of still including the kitchen area within the assessment (albeit we are then considering a target for the predominant room use of an ADF of 1.5 per cent for living room). Table 4 below provides a summary of ADF review for all habitable rooms.

Table 4. Summary of ADF review

6.6.10 The scheme achieves 92 per cent overall of habitable rooms meeting ADF target criteria which is considered reasonably good for the given context and density (opportunity area). The split between living rooms (including studios) and bedrooms not meeting the target is also similar.

6.6.11 For the respective room use consideration, for living/kitchen/dining rooms (LKD’s) 90 per cent achieved target ADF and in terms of those rooms not meeting target ADF, the actual levels achieved have also been considered. The split for those 48 living/kitchen/dining rooms not meeting target is 18 at an ADF of 1.3 per cent - 1.49 per cent (i.e. within 20 per cent of the target of ADF of 1.5 per cent), 30 at an ADF of 1 per cent - 1.29 per cent (effectively still above bedroom quality).

6.6.12 In respect of bedrooms, 93 per cent would achieve target ADF. For those rooms not achieving target 1 per cent ADF, these rooms are much more ranging, albeit daylight is considered less important to bedrooms. From the 46 bedrooms, the split for those not meeting is 17 at an ADF of 0.8 per cent - 0.99 per cent (i.e. within 20 per cent of the target of ADF of 1.0 per cent), 26 at an ADF of 0.5 per cent - 0.79 per cent (these achieving not less than half ADF target) and three isolated bedrooms at below half ADF target (within Block A – ADF of 0.45 per cent at 2nd floor room and ADF of 0.39 per cent at 3rd floor room ref. and within Block B – ADF of 0.47 per cent at 3rd floor room).

6.6.13 For sunlight review to habitable rooms, results have been provided for all habitable rooms with windows in applicable orientation (i.e. windows facing within 90° of South). For an ‘opportunity area’ scheme of relatively density and with focus on the living rooms, officers consider this multiple unit scheme achieves a reasonable amount of sunlight provision to habitable rooms with

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focus on living rooms.

6.6.14 Overall, the proposed design and layout is considered to have sought a balance between different requirements and will provide reasonable daylight and sunlight amenity for the enjoyment of future occupants in compliance with policy Q2 of the LLP.

Residential Amenity Space

6.6.15 The London Plan Housing SPG states that a minimum of 5 sqm of private outdoor space should be provided for 1-2 person residential units and an extra 1 sqm should be provided for each additional occupant. Policy H5 of the LLP similarly sets out requirements in respect of external amenity and children’s play space. For new flatted development, communal amenity space of at least 50 sqm per scheme should be provided, plus a further 10 sqm per individual flat provide either as a balcony/terrace/private garden or consolidated within the communal amenity space. Private amenity requirements under policy H5 of the DRLLP are again similar to the above insofar that provision for communal amenity space will only apply to developments of 10 units or more. The proposed development is therefore required to provide a minimum combined total of private and communal amenity space of 4,840 sqm.

6.6.16 In terms of private amenity, all but five flats (which have no balconies) would have at least 5m2 (plus 1m2 for each additional occupant as required by the LP) of private amenity space, in the form of balconies and/or terraces, equating to 3,936sqm in total. Across the scheme this represents an average provision of 8.3sqm per residential unit.

6.6.17 The external communal amenity provision is split across the two residential podiums and roof terraces and details are shown on Table 7 below. The overall external communal amenity space provision equates to a total of 1,340sqm. The external amenity is protected from wind and noise through the uses of glazed screens and an oversailing crown at roof level. The proposal also provides internal communal areas which are typical of build to rent developments and normally cater for a range of recreational needs of occupiers in addition to traditional open spaces/terraces. Details of the proposed internal amenity spaces are also shown in Table 5 (below) and amount to 849sqm.

External communal amenity space Block A – podium level 270sqm Block A – roof terrace 308sqm Block B and C – podium level 310sqm Block B roof terraces 200sqm Block C roof terrace 252sqm Total external 1,340sqm Internal communal amenity space Block A – 1st floor 152sqm Block B – 1st floor 231sqm Block B – roof terrace level 97sqm Block C – 1st floor 369sqm Total internal 849sqm Total combined 2,189sqm Table 5: Breakdown of external and internal communal spaces

6.6.18 Overall the proposed communal amenity areas (2,189sqm) and private amenity space (3,936sqm) equate to total provision of 6,125sqm which is a significant uplift (1,285sqm) on the minimum required by policy. Furthermore, the scheme will deliver new, publicly accessible open space of over 1,360sqm in the form of Pascal Square. The site is located in an identified area of

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open space deficiency and the development meets the requirement of Policy En1(d) which seeks the provision of on-site open space in such cases.

6.6.19 In terms of sunlight availability to the proposed main amenity areas, Avison Young have provided analysis review for the BRE Guide 2 hour sunlight availability test for main amenity areas. The analysis relates to three amenity areas, all of which will achieve the BRE target to receive two hours or more of sunlight on the 21st March to over half of the amenity. These three areas with actual percentages of area that can receive 2 hours or more of sunlight (on 21st March) relate to: • Ground floor amenity between Blocks A & B (Pascal Square) at 100 per cent, • The 1st floor podium to Block A at 58 per cent, • The 1st floor podium between Block B and C at 65 per cent.

6.6.20 No analysis has been provided for the roof terraces on the top of Blocks A, B and C but given their location and orientation, it is considered that suitable levels will also be achieved to these other areas.

6.6.21 Planning conditions are recommended to ensure the landscaping of the terraced spaces are provided to the high standards being proposed. S106 obligations are also recommended to ensure the communal spaces are provided on an inclusive basis to all its residents. Overall, the amount and quality of private, external and internal communal amenity is acceptable and complies with the aims and objectives of policy D6 of the LP; policy H5 of the LLP and policy H5 of the DRLLP.

Play Space

6.6.22 LP policy S4 that proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs. The Mayor’s Shaping Neighbourhoods: Play and Informal Recreation SPG (2012) sets out guidance to assist in this process and sets a minimum benchmark standard of 10sqm per child regardless of age.

6.6.23 Policy H5(d) of the LLP states that for developments of 10 or more units with at least one family- sized dwelling, children’s play space should be provided where appropriate to at least the levels set out in the London Plan Supplementary Planning Guidance ‘Shaping Neighbourhoods: Play and Informal Recreation’ 2012. Policy H5 has been amended within the DRLLP to state that the Council will follow the approach to play space set out in LP policy S4 and associated SPG.

6.6.24 Using the GLA’s Population Yield Calculator, it is anticipated that the proposed development would be occupied by 54 children based on an inner London location with a PTAL of 6a/6b. This is divided into three age ranges as follows: 28 under 5 year olds; 19 5-11 year old and seven 12+ year olds. This gives rise to a total child play space requirement of 542sqm. The applicant aimed to provide a higher level of play areas and therefore used a setting for the London wide area and PTAL level 3-4 and the breakdown is shown in the Table 6 below. It demonstrates that the proposed on-site play areas amounting to 852sqm significantly exceeds the required minimum of 542sqm and provision within each block also exceeds the minimum requirements which is welcomed.

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Table 6. Play space provision and GLA requirement (London wide, PTAL level 3-4)

6.6.25 The play space would be a made up of areas with prescriptive play and incidental play, ‘hand out’ zones for teenagers and areas to grow food and other plants. Figure 32 shows the indicative layout of the external amenity spaces. The proposal would adequately meet its requirements for children’s play space on-site. Details of the children’s play space shall be secured through Condition 14.

Figure 32. Indicative play areas at podium and roof level

6.6.26 Based on the above, the proposed development complies with the Mayor’s Shaping Neighbourhoods: Play and Informal Recreation SPG (2012), policy S4 of the LP and policies H5 of the LLP and the DRLLP.

Noise and vibration

6.6.27 LP policy D14 requires that development proposals manage noise by mitigating the existing and potential adverse impacts on noise. Policy D13 of the LP expects that planning decisions reflect the Agent of Change principle and take account of existing noise and other nuisance-generating uses in a sensitive manner when new development is proposed nearby. LLP policy Q2(v) states that proposals should ensure that any adverse impact in terms of noise should be reduced and minimised as far as possible to ensure the amenity of existing and future occupants is protected. Policy Q2(v) of the DRLLP repeats the same approach with reference to emerging DLP policy on noise.

6.6.28 To achieve an acceptable indoor ambient noise level in accordance with British Standard 8233:2014 (‘Guidance on sound insulation and noise reduction for buildings’) the applicant has proposed to use Mechanical Ventilation and Heat Recovery system for all residential dwellings. The applicant’s acoustic consultant has indicated that the façade system (including glazing, frames, seals, any insulated panels and ventilators/extracts) should be designed with sound insulation performance that would enable the recommended noise criteria to be met. Furthermore, noise associated with plant rooms and the ground borne noise and vibration generated by the operation of the underground railway line beneath the site is also a potential issue for the proposed dwellings. The Assessment assumes the adoption of high-level acoustic performance and a rail construction technique designed to address these issues. The consultant anticipates that subject to the detailed design stage considering the above factors, the recommended noise level criteria within residential habitable rooms would be achievable.

6.6.29 The council’s consultant acoustician has not objected to this approach and advises that a suitably worded planning conditions (6, 25 and 27) should be included to ensure that an acceptable noise environment for future occupiers is achieved.

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6.6.30 In terms of external amenity areas, the applicant predicts that noise levels on the main roof terraces will not exceed the upper guideline noise value of 55 dB LAeq and provide good quality of amenity. The noise levels on the podium level communal terraces would exceed the guideline levels, however it could be reduced to acceptable levels by use of screens placed at the boundaries of these areas. Therefore, a condition (26) is recommended to secure further details. In terms of noise levels on balconies, those facing Pascal Square and the area between Block B and C would be within the recommended guidelines.

6.6.31 Overall, the quality of communal amenity areas with regards to noise is considered to be acceptable and represents an improvement on the extant consent. This is the extant permission did not include rooftop communal terraces which meet the relevant guidelines or internal communal areas which are now proposed.

6.6.32 Subject to the above conditions that ensures suitable noise mitigation measures are incorporated, it is considered that the development would provide an acceptable noise environment for future residential occupiers having regard to its location. The proposals therefore comply with policy D14 of the LP; policy Q2 of the LLP and DRLLP.

6.7 Amenity for Neighbouring Occupiers

Daylight, Sunlight and Overshadowing

6.7.1 One of the core planning principles (paragraph 17) in the NPPF is that decisions should “always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings”. LP policy D6 states that in their neighbourhoods, people should have a good quality environment.

6.7.2 The beginning of the Agenda Pack contains broad contextual overview of the assessment framework within which BRE compliant sunlight and daylight studies are undertaken. This includes an explanation of the key terms and targets contained within the BRE guidance. The following assessment has been made in the context of this information.

6.7.3 In accordance with LLP policy Q2 (Amenity) the application has been accompanied by a Daylight and Sunlight Assessment prepared by Avison and Young including three supplementary notes received during the application process. The development has been assessed against the Building Research Establishment (BRE) guidance ‘Site Layout Planning for Daylight and Sunlight’. The Council has sought independent review of the report findings in respect of possible impacts of the new development on surrounding sites and within the development itself, undertaken by Schroeders Begg.

6.7.4 In reference to the BRE Guide and in relation to the extant planning permission, the BRE Guide appendix F2 states ‘In assessing the loss of light to existing windows nearby, a local authority may allow the vertical sky component (VSC) and annual probable sunlight hours (APSH) for the permitted scheme to be used as alternative benchmarks’. Accordingly, Avison Young have considered the shift change from the consented (extant permission) to the proposal, considering VSC and sunlight. For completeness, they have also considered the shift change to daylight distribution and sunlight to amenity. The council’s advisor considers this approach to be reasonable, however overall reductions and retained values of relevance were also considered.

6.7.5 In terms of properties analysed these are summarised as:

Existing properties:

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Broadly to the east of site (opposite side of Wandsworth Road); • Basil House • Adrian House • 2 Wilcox Road • Wilbraham House

Broadly to the south of site; • Lockyer House • Charman House • 39-55 Pascal Street (Apple Blossom Court) • 36-38 Bramley Crescent • 22-24 Bramley Crescent

Recent new-built properties:

Broadly to the north of site: Nine Elms Point (Sainsburys Nine Elms); • Block C • Block D • Block E • Block K

Consented but not yet built properties: To the west of the site: • New Covent Garden Market site – Apex Site

6.7.6 Figure 33 below shows the surrounding properties considered as part of the assessment with the site as proposed in green and Block D from the extant permission in red.

Figure 33. Proposed development and assessed properties.

6.7.7 The extent of neighbouring properties analysed is considered sufficient. It is noted that analysis

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has also been provided for David House and Conrad House but these are residential blocks that are further away than the similar blocks of Basil House and Adrian House and therefore are not discussed in more detail in this report.

Neighbouring Daylight analysis review

Existing properties

6.7.8 For existing residential properties, Table 7 below summarises the VSC changes (consented v proposed) as VSC averages for the property under consideration and associated loss (both as a percentage and ranges of loss). As can be seen in Table 7, there is fairly limited difference in absolute terms in the shift change from ‘consented’ to ‘proposed’ and, on that basis, the proposal has fairly limited increased effect when compared back to the consented scheme.

Table 7 Summary shift change in VSC (excludes new-builds)

6.7.9 In terms of Apple Blossom Court (39-55), this is a terrace row of maisonettes which appear to be one bedroom dwellings (6 units to the ground floor accessed directly and 6 units at first floor accessed from projecting staircase blocks). The retained VSC assessment results for the proposed development showed negligible differences, ranging between -7.37 per cent (i.e. a small gain) and 50 per cent, when compared to the consented VSC values. The higher percentage differences reflect very small actual changes of around 0.01 per cent VSC. This is due to the inherent design of this property, whereby daylight availability to some windows / rooms is already limited, due to such aspects features as; projecting staircase walls (reducing the availability of daylight from the dome of the sky to the main window elevation), ground floor maisonettes having projecting canopies and porches (which will also reduce the availability of daylight) and other features including projecting car-port structures and first floor window heads positioned directly beneath the projecting eaves which will reduce daylight flow to these windows / rooms. The key aspect in this instance is that impacts are still very similar to the consented

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scheme in absolute terms.

Recent new-build neighbouring properties

6.7.10 In terms of the recent new-build Nine Elms Point to the north, these properties will have been designed in reference to the average daylight factor (ADF) for context in an overall ‘opportunity area’ / cumulative massing with neighbouring redevelopment sites. It is apparent that some VSC values are relatively low, given the context of overall re-development density. Whilst VSC (along with daylight distribution) is the standard neighbouring test for occupied properties, Schroeders Begg considered in this particular instance and in reference to ‘masterplan’ / the successive development, to place the main focus in this particular instance on the effect of the shift change from ‘consented’ to ‘proposed’. Schroeders Begg considered ADF review was more meaningful, rather than seeking to gauge changes in VSC review when VSC levels are already limited / low in some particular instances.

6.7.11 From review of the recent new-build (‘Nine Elms Point’ / Sainsburys site) for neighbouring Blocks C, D, E & K, in terms of ADF review, it is evident that there is limited change to ADF to habitable rooms in these neighbouring blocks in consideration of ‘consented’ to ‘proposed’ and as such, the shift change in ADF (reductions being considered in this case), does not exceed an absolute reduction in ADF of 0.2 (considered minimal) with the isolated exception of three rooms within Block D.

6.7.12 The impact to these three rooms within Block D relates to living/kitchen/dining rooms and at lower floors within Block D. From more detailed consideration, it is evident that these three rooms have inherent sensitivity to any massing change as each of these rooms have a balcony soffit above their windows and the rooms at lower level are within a greater obstruction context. It is considered that these rooms rely on a degree of reflected daylight and accordingly, consideration to supplementary review has been given to a radiance study of the daylight factor within the room. From this review (which accounts for external reflected daylight within the room), it also determined that the shift change in the daylight factor to these rooms is limited and also equating to circa 0.2 in absolute terms shift change reduction in daylight factor.

6.7.13 It is also noted that, within this ‘masterplan’ development, there are already some similar isolated examples of sensitivity to ADF, especially at lower levels and in the given denser surrounding context and evident that external reflected daylight is of some importance.

6.7.14 In terms of daylight distribution (consideration also of daylight within the room), similar to the ADF review, there are some isolated instances of low daylight distribution that can be found in the consented context overall arrangement. Also similar to the ADF review, typically these are relatively limited changes in absolute terms from consideration of the shift change in analysis from ‘consented’ to ‘proposed’.

Consented but not yet built neighbouring properties – Apex Site

6.7.15 The Apex site to the west benefits from an extant outline permission which includes seven blocks with Block A1 closest to the application site. Given the absence of detailed design (and especially, that there are no definitive floor plans or fenestration details), it is appropriate to consider the availability of daylight across the facade of the proposed blocks forming the Apex Site. Accordingly, daylight VSC has been analysed across the external facades of the Apex site and this is presented within Avison Young’s supplementary daylight submission dated 18th January 2021.

6.7.16 The output of this review indicates some effect to the east facing elevation of Apex Block A1. However, for this elevation, it is evident that the majority of the façade would have a good VSC of

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circa 25 and towards the top of the façade, effectively the maximum VSC that could be achieved. Conversely, at the lower storeys, there are some limitations in available daylight VSC, some levels of VSC of circa 10 appearing applicable although in this respect, it is important to highlight that; • This area is quite limited in consideration of the overall ‘east’ facing façade. • That for the lowest floor, it is understood that such areas would be commercial thus daylight ordinarily not reviewed (as opposed to residential). • That this area is focused more towards the northern end of this façade i.e. towards the Apex and as such, it is anticipated that applicable residential use within this vicinity is likely to incorporate dual aspect units (potentially triple aspect) towards this apex corner. Accordingly, reasonable daylight provision within these proposed units (once designed), should readily be possible. • The proposed Block A which is closest to the Apex site is lower than the Block A in the extant permission

6.7.17 In summary, the proposed development is not considered to have any undue significant adverse effect upon the future daylighting within the proposed neighbouring Apex site. Whilst the Apex site may well have gained consent prior to the original consented 10 Pascal Street scheme (planning application 15/06216/FUL), it is reasonable for each site to seek only its fair share of daylight and for neither site to unreasonably constrain development upon each respective site; indeed, the proposed Block A is splayed on plan in order to seek to mitigate the massing closest to the Apex site. Given the review of self-testing within Block A and façade review undertaken on the Apex site (Block A1, especially), it is evident that with suitable detailed design in due course of Apex Block A1, suitable daylighting levels should be readily possible within this neighbouring Block A1. It should be noted that the reserved matters application for the Apex site is required to be supported by a detailed daylight sunlight assessment. Condition 56 of the CGMA planning permission then requires details of mitigation, including daylight, sunlight and overshadowing details, to be submitted for approval before the development commences.

Neighbouring sunlight analysis review

Existing properties

6.7.18 In terms of existing neighbouring residential properties, these are typically not needing to be assessed, as for those to the south of the proposal (generally opposite side of Pascal Street), their windows in the elevations facing the site are typically not facing within 90° of South / not applicable for review. Equally, the properties to the east (opposite side of the Wandsworth Road), for the elevations which front onto Wandsworth Road / facing the site (end elevation of Basil House & Adrian House), windows in these elevations are typically not facing within 90° of South (just north of west facing) so are not applicable for review. For the very few isolated windows that have been assessed, there is no meaningful change in sunlight provision.

Recent new-build neighbouring properties

6.7.19 For the recent new-build Blocks C, D, E & K at Nine Elms Point, habitable rooms have been reviewed for sunlight. From the analysis, Schroeders Begg have focused upon living rooms (including studios) as sunlight important and for those impacts where reductions become applicable for consideration (once below 25 per cent for Annual Probable Sunlight Hours). Given the consented context and density of redevelopment within this opportunity area, properties will typically have limited winter sunlight hours, especially at lower floors and therefore Schroeders Begg have not focused on winter hours.

6.7.20 A review of ‘consented’ versus ‘proposed’ for living rooms (including studios) and consideration of APSHs is summarised below:

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Block C 6.7.21 There would be an increased impact to ten living rooms/ LKDs /Studios at 1st to 5th floor. However, APSHs are already typically low to these rooms and in absolute terms, the shift change ranges 1 to 3 APSH percentage points which is considered minimal. Conversely, there are some isolated gains in APSH Sunlight relating to 5 No living rooms/ LKDs / Studios in APSHs.

Block D 6.7.22 There would be an increased impact to ten living rooms/ LKDs /Studios at 1st to 3rd floor. However, APSHs are already typically low to these rooms and in absolute terms, the shift change ranges 1 to 3 APSH percentage points which is considered minimal.

Block E 6.7.23 There would be an increased impact to eight living rooms/ LKDs /Studios at 1st to 6th floor. However, APSHs are already typically low to these rooms and in absolute terms, the shift change ranges 1 to 2 APSH percentage points which is considered minimal. There are some isolated gains in APSH Sunlight relating to 2 two living rooms/ LKDs / Studios in APSHs.

Block K 6.7.24 There would be an increased impact to ten living rooms/ LKDs /Studios at ground to 10th floor. However, APSHs are already typically low to these rooms and in absolute terms, the shift change ranges 1 to 2 APSH percentage points which is considered minimal. There are some isolated gains in APSH Sunlight relating to two living rooms/ LKDs / Studios in APSHs.

Consented but not yet built neighbouring properties – Apex Site

6.7.25 One of the three façades to Apex Block A1 faces the application site and is considered to just fall within 90° of South. However, it is inequitable to consider that all sunlight must be available to Apex Block A1 from the direction of the application site. As beneficial for the daylight provision to neighbouring Apex Block A1, the proposed Block A has been splayed to mitigate sunlight impacts as well. Notwithstanding these comments, a sunlight review across the façade of the Apex Block 1 has been submitted and, it is evident that the proposed scheme will have minimal effect upon the elevation of south/ south-west and whilst there may be some sunlight reduction to the east facing façade, it is considered that Apex Block A1 will still have reasonable access to sunlight provision overall to the whole block and positioning of sunlight important rooms will ordinarily seek to maximise the benefit of such areas.

Sunlight – Impact upon neighbouring amenity

6.7.26 Given the context of existing neighbouring residential properties, these do not need to be reviewed. In reference to the recent new-build Nine Elms Point development, the main amenity area has been reviewed and in the proposed scenario, this will still achieve in excess of half the amenity area (66 per cent of area) having the ability to receive 2 hours or more of sunlight at the 21st March thus meeting BRE Guide target criteria. In summary, for review to either previously existing neighbouring amenity areas or that within the recent new-build Nine Elms Point, there is no meaningful change to that compared to the consented 10 Pascal Street proposal (15/06216/FUL).

Daylight and sunlight conclusion 6.7.27 In consideration of the impact of daylight analysis of the shift change from the ‘consented’ to ‘proposed’ application scheme, there is fairly limited effect in absolute terms upon both existing neighbouring properties (VSC review) and the recent new-build Nine Elms Point (primarily ADF review)..

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6.7.28 It is also considered the proposal would not have a detrimental effect to the provision of daylight within the consented (but not yet built or detailed design considered in terms of floor plans and fenestration details), of the Apex site proposal upon the neighbouring New Covent Garden Market site redevelopment.

6.7.29 In terms of sunlight impacts, from the analysis considered, there would appear limited difference between the ‘consented’ to ‘proposed’ application and no meaningful shift change. On that basis, the impacts are considered acceptable. Overall, officers consider the proposals to be generally in accordance with LLP policy Q2 in respect of daylight and sunlight.

Privacy and Outlook

6.7.30 LLP policy Q2 (Amenity) also seeks to protect the amenity of existing neighbours and the visual amenity of the community as a whole. The proposed scheme layout has been arranged within the constraints of the station building to minimise its impact on neighbouring residential uses. The use of a triangular plan form minimises direct overlooking between habitable rooms over short distances. The LP Interim Housing SPG suggests that a separation between 18 – 21m between habitable rooms (as opposed to between balconies or terraces or between habitable rooms and balconies/terraces) is a useful benchmark, but should not be applied rigidly given the nature of development in urban areas. Only separation distances of less than 18m are therefore considered further in this report.

6.7.31 Block A sits 15.7m from the proposed building on the Apex Site (CGMA) to the west, although there are no habitable windows within Block A that face directly onto this building due to the proposed footprint of Block A. As such there are no issues in terms of outlook or privacy.

6.7.32 Blocks B and C sit approximately 13m to the south of the Sainsbury’s scheme (Blocks C and D). In the case of Block C the triangular footprint ensures that only one unit faces directly onto the Sainsbury’s scheme at this distance. While the Sainsbury’s scheme presents some small windows onto the elevation, the main windows front onto Wandsworth Road. The resulting relationship closely follows on that approved in the extant permission and officers consider this to be acceptable.

6.7.33 There is a proposed pop out element on the northern elevation of Block B which reduces the separation distance to approximately 10.5m. To avoid overlooking the pop out element has been positioned so that it is strategically located between the two buildings directly opposite. There was some potential for increased overlooking between other parts of the proposed Block B and Sainsbury’s Block C when compared with the extant consent. The proposals have been revised during the application process to include the removal of four balconies in Block B, changes to internal layouts of four flats and introduction of small changes to window alignments and the introduction of obscured glazing to some windows to ensure that the impact would be acceptable. Condition 10 is recommended to ensure that the privacy mitigation measures are timely implemented.

6.7.34 Finally, the proposed blocks (A, B and C) would be over 17m from the residential properties on the southern side of Pascal Street. Given that the residential units within the proposal will start above the level of the existing residential properties it is not considered that there will be direct overlooking between the two. As a result overlooking and privacy will not be compromised in respect of the existing or new dwellings.

6.7.35 In light of the above, officers therefore consider that the proposed scheme would have an acceptable impact in terms of privacy and outlook. In particular the scheme will enable views

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(both direct and oblique) from residential uses to the north and south to the new areas of public realm proposed by this scheme.

Noise and Vibration 6.7.36 LP policy D14 states that development proposals should avoid adverse noise impacts on health and quality of life as a result of new development. LLP policy Q2 requires development to reduce the adverse the impact of noise.

6.7.37 The Noise and Vibration Impact Assessment considers the impact of the proposed plant on neighbouring occupiers and makes recommendations relating to plant operation and installation of acoustic enclosures. This was found acceptable by the council’s acoustic consultant who recommended conditions (28 and 29) to ensure that noise from building services and plant is mitigated. It is not considered that the proposed external amenity spaces would result in any excessive noise or disturbance to neighbouring residents and are these amenity spaces are generally in-keeping with the character of the area.

6.7.38 The proposal includes a small commercial unit and it is recommended that that details relating to operating hours and a management plan are provided and assessed in compliance with LLP policy Q2 and ED7. A condition is suggested (31).

Construction impacts 6.7.39 Noise, disturbance and inconvenience during the construction period can be mitigated through the provision of a Construction Environment Management Plan (CEMP) which has been submitted with the application. However, further detail is required to ensure measures are taken to minimise impacts on the locality and a final CEMP would be secured through a condition (3). It shall include measures in terms of noise, waste and dust mitigation, the management of deliveries, station operation, access along Pascal Street and engagement with the local community (including a named contact point throughout). The developer will be expected to operate and be registered under the Considerate Constructors Scheme and sign up to the Vauxhall Nine Elms Construction Charter.

External Lighting 6.7.40 An Exterior Lighting Strategy details the design parameters for lighting both the tube station entrance, the new public realm, and the private amenity spaces. The report also notes that a high level of coordination will be required to ensure the lighting scheme co-ordinates with adjacent developments and land uses. The council’s environmental health advisor confirmed that the design principles as set out in the Exterior Lighting Strategy are appropriate and a condition (32) is proposed to secure further details.

6.8 Ecology, Trees and Landscaping

6.8.1 LLP policy Q10 states that new development should be designed positively to protect existing trees and as part of a wider soft landscaping scheme to include new trees where appropriate. LLP policy Q9 requires developments to provide landscaping that is fit for purpose, maximises opportunities for greening and makes use of appropriate plant species.

6.8.2 Areas of hard and soft landscaping are proposed across the site with a landscaped podium and roof terraces in all blocks. The landscape and public realm strategy provided in the DAS illustrates the intention to provide a mix of planting including trees and edible planting offering a substantial improvement for a site that currently has no formal landscaping. Indicative species have been chosen from an appropriate palette to match the anticipated micro-climate, clearly define spaces, soften the appearance of the development, promote sustainable drainage, help create variation in

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character, enhance ecological diversity and provide visual interest and colour throughout the seasons. The landscaping would incorporate high quality public realm including flexible seating areas. Figure 34 shows the proposed areas of soft landscaping including at roof level.

Figure 34: Proposed landscaping and green roof /terrace plans

6.8.3 The Council’s Arboricultural Officer has reviewed the proposals and raised no objections subject to appropriate conditions relating to the final landscaping scheme details and associated maintenance being secured by conditions (15 and 16). This will also need to consider amenity issues and a possible temporary landscaping scheme as discussed earlier in the report. As such the proposal complies with the requirements of policy Q9 and Q10 of the LLP.

Ecology 6.8.4 LP policy G5 and LLP policy Q9 reflects the aims of policy EN1, promoting opportunities for greening as well as protection and enhancement of existing biodiversity. The site is located in an identified area of open space deficiency. Policy Q9 also supports the use of landscaping to provide strong boundary treatments, together with access routes and parking areas compliant with safety standards and minimum parking standards. LLP policy Q10 states that new development should be designed positively to protect existing trees and as part of a wider soft landscaping scheme to include new trees where appropriate.

6.8.5 The application is supported by a Biodiversity Report which demonstrates that the site is currently devoid of any vegetation and has an high existing level of disturbance (noise, vibration, visual, lighting) and is deemed to be of negligible ecological value. The desk-based review also highlights that prior to the site being cleared for the NLE construction that it was historically considered ‘a relatively habitat poor site’. The site therefore has a blank baseline when considering the site for the potential to achieve a Biodiversity Net Gain. The desk-based review also highlights there is no hydrological connectivity between the site and nearby watercourses, nor is the site within close proximity or to impact any Special Area of Conservation (SAC), Site of Special Scientific Interest (SSSI) or Site of Importance for Nature Conservation (SINC).

6.8.6 In accordance with LP policy G6, a range of measures should be undertaken to satisfy the requirement for ecological enhancement. The landscape design will include biodiversity enhancement measures such as planting using native species and species with biodiversity benefit; ecologically diverse green roofs and incorporation of bird and bat boxes and ‘bug hotels’ and small water features. The Draft CEMP includes measures to heighten awareness of the potential for ecological features such as nesting birds and invasive non-native species to be encountered during works and what to do in the event that they are present (e.g. through toolbox

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talks, compliance checks and, where required, the appointment of specialist ecological management contractors).

6.8.7 The Council’s biodiversity officer reviewed the submitted information and is satisfied subject to biodiversity measures set out in the reports being integrated in the final detailed design and mitigation measures secured in the final CEMP. This is secured by conditions (3, 15, 41 and 44). Subject to these conditions, the development would contribute positively to the biodiversity objectives of the above policies.

Urban Greening Factor 6.8.8 LP policy G5 requires proposals within boroughs to develop an Urban Greening Factor (UGF) to identify the appropriate amount of urban greening required within developments. For residential development this is an UGF of 0.4 and for non-residential schemes it is 0.3. The aforementioned green infrastructure and landscape design achieves UGF of 0.37 which is marginally below the recommended UGF of 0.4.

6.8.9 During the application process, the applicant undertook further investigations to verify if a score of 0.4 could be achieved. Deeper green roof substrates and green walls suggested by the GLA were discounted due to feasibility issues. Furthermore, additional soft landscaping was considered and a further 255sqm of planting would be required which is also not feasible as the provision of landscaping has been already maximised on this constrained site. The council’s sustainability advisor and open space officer are satisfied that the originally proposed measures are acceptable. To validate the measures at the as built stage a condition (44) is recommended that evidence is provided to demonstrate the development has achieved an UGF 0.37 or more.

6.9 Transport

6.9.1 LP policies T1, T3 and T4 and LLP Policies T1, T3 and T4 seek to ensure that the impacts of development in transport capacity and the transport network are fully assessed. Policies T3, T6, T7 and T8 of the LLP and policies T3, T7 and T8 of the DRLLP both seek to ensure that proposals for development will have a limited impact on the performance and safety of the highway network and that sufficient and appropriate car parking and cycle storage is provided whilst meeting objectives to encourage sustainable transport and to reduce dependence on the private car. If development will have an unacceptable transport impact, it should be refused in the absence of mitigation measures to make the development acceptable.

Site context 6.9.2 The site is located approximately 800m to the southwest of Vauxhall Station. Pascal Street is a dead-end road that will eventually connect to the CGMA site (pedestrians, cyclists and emergency vehicles only). The site is directly above the proposed Nine Elms Station which is due to open in autumn 2021. The current PTAL rating of 6a (excellent) will increase to 6b once the construction of the Nine Elms Station is complete. On-street parking was previously provided along the north side of Pascal Street with space for up to 14 vehicles and 5 powered two wheelers. This parking was subject to Pay & Display/Residents’ permit parking controls as the street is within the Stockwell ‘S’ Controlled Parking Zone, which operates Monday to Friday 08:30 – 17:30. A number of blue badge bays were provided here.

6.9.3 As the station construction site is now operational the formal on street parking arrangements are no longer in place but some parking may be re-provided there. The extant permission includes provision of two on-street Blue Badge parking spaces on Pascal Street for Block D which would be provided when Block D is delivered.

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6.9.4 The vehicular access to the site is via Pascal Street. The access ramp to the basement car park is already constructed and will be accessed via Pascal Street as per the extant permission. It is understood that this ramp is shared with residents of Nine Elms Point. Barrier controls will be in place at the shared entrance and at the entrance to the proposed development’s basement car park. Pedestrians and cyclists will access the development from Hebden Place apart from the retail/commercial unit accessed from Pascal Square.

Trip generation and Impacts 6.9.5 The Transport Assessment (TA) includes a comparison of the extant planning permission trip rates and the current proposals trips. The consented scheme resulted in 1,659 daily two-way person trips (or 191 during the AM peak), while the current proposals are expected to generate 2,393 daily trips (or 275 during the AM peak). The majority of these trips are undertaken by public transport (77 per cent by Underground, Train or Bus) and TfL confirmed that this can be accommodated on the strategic public transport network. The number of vehicular trips that would be generated by the proposed development is limited to disabled car drivers and servicing activity.

6.9.6 The application is supported by a Pedestrian Comfort Level (PCL) assessment of the footways in the vicinity which helps to understand the implications of the uplift in pedestrian activity. The findings suggest that there is expected to be little change in the PCL as a result of the proposed development. The lowest PCL rating is forecast to be A- which is considered ‘comfortable’ and is above the acceptable minimum PCL rating of B+.

Servicing 6.9.7 It is proposed that the vast majority of deliveries will be made from Pascal Street to the south of the site from two on-street loading bays. One bay is to be delivered as part of the S278 works associated with the Nine Elms Underground Station, whilst the western bay would be delivered as part of this scheme. A turning head is proposed in Pascal Square, as per the extant consent. The detailed layout of Pascal Square and associated turning head has been revised during the application process to address safety concerns raised by the transport officer. The revised layout is considered to be acceptable. An on-site loading bay is also proposed within the basement area which will be available by prior arrangement for maintenance vehicles and residents moving in/out.

6.9.8 A residential servicing trip generation assessment provided during the application process includes the worst-case scenario with a maximum of 51 deliveries per day, with the majority of these made by small to medium-sized vehicles. A parcel collection point is proposed as part of the concierge in Block B and C which should reduce the dwell time and number of deliveries per day as loads can be consolidated. The commercial element is estimated to generate two deliveries per day. The servicing requirements of the office space already consented in Block D have also been considered. Overall, it is anticipated that the demand for loading bays generated by the development and Block D would equate to approximately 53 per cent to 71 per cent of the service bay capacity which allows for spare capacity. The proposed draft servicing strategy is considered to be acceptable and the final Deliveries and Servicing Plan will be secured by a condition (19).

Car parking 6.9.9 The development would be secured as car permit free through a S106 agreement. It would provide 14 on-site disabled parking spaces which equates to three percent active provision for the residential use. While the need for additional disabled parking above the 14 spaces on-site is considered to be an unlikely event (particularly given the site’s location above a step-free station), the need for additional disabled parking (up to 7 per cent) would be monitored within the Parking Management Plan, and if additional disabled bays do need to be provided on-street, £10k per bay would be payable. The Parking Management Plan will be secured by s106

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agreement and will also ensure that car parking spaces are leased rather than sold and that the management of parking spaces will need to consider safe operation of adjacent cycle stores. All parking spaces will have electric charging facilities, which exceeds the LP requirement and this will be secured by condition (24).

Cycle parking 6.9.10 A total of 805 long-stay residential cycle parking spaces are proposed across the two levels of basement and the first floor of Blocks A, B and C. 25 per cent of these are proposed via Sheffield stands and 5per cent provided for non-standard bicycles, with the remainder via two- tier racks. A further 8 long-stay commercial cycle parking spaces are proposed within the Pavilion Building. A total of 38 short-stay visitor cycle parking spaces, by way of Sheffield stands, are proposed within the public realm for both residential and commercial visitors. The level of cycle parking and the mix of types proposed meets both the LP and the DRLLP requirements.

6.9.11 Cycle stores would be accessed by lifts and while they are expected to well serve the majority of cycles including some non-standard types, it is acknowledged that larger lifts are recommended for non-standard bikes. In this case, the size of the lifts is dictated by the space available within the station structure but there are potential options that can be explored with non-standard lift car sizes and this would require testing with construction details. It is recommended that a feasibility study of larger lift provision is secured through a condition (21). During the application process, additional information relating to the detailed layout and manufacturer’s specifications were provided. It is acknowledged that the indicative location of structural columns at basement level could impact on usability of four stands however these could be provided at podium level if required. The submitted details demonstrate that the proposed stands would be accessible and meet the manufacturer’s recommendations and it is recommended that the final design is secured through condition (21).

6.9.12 Due to fire separation requirements, access to cycle stores in the basement area includes travelling through three sets of doors. Given the site’s constraints, it considered acceptable subject to a condition ensuring automatic doors are provided. The cycle parking in the basement is also located close to disabled parking bays which is not ideal and other options were investigated. While the layout of the basement is restricted due to the built station structure and fire regulations, officers consider that sufficient measures can be secured through the Car Parking Management Plan to achieve an acceptable provision. This would include late allocation of the relevant Blue Badge spaces, appropriate signage, effective complaints procedure and monitoring of the basement area by 24h concierge desk via CTTV. This will be secured by condition (22). Overall, given the constraints of the site, the proposed cycle parking is considered to be acceptable and complies with policy T5 of the LP.

Refuse storage and collection 6.9.13 Residential bin stores would be located on the podium level of all three blocks and accessed from the main core areas with two dedicated bulky waste areas in Block A and B. A commercial bin store would be located within the back of house area of the commercial unit. The refuse stores are designed to meet the quantum of refuse stipulated in the Lambeth Guidance ‘Waste and Recycling Storage and Collection Requirements, Technical Specification for Architects and Developers. Furthermore, each residential bin store would house two in-bin compaction lever arm in a separate area to prevent the residents from accessing these areas. On collection day, the building operations staff will move the bins from the internal bin stores out to the presentation area in Pascal Square via the dedicated service lifts located adjacent to Pascal Square. Once the bins have been emptied, the building operations staff will return these bins to the presentation area from where the internal management team will return these bins to the designated bin stores of all blocks. The application is accompanied by an Operational Waste and Recycling Management Strategy which has been reviewed by Veolia and considered to be acceptable. Condition 20 is

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recommended to ensure the development is implemented in accordance with the approved details.

Construction 6.9.14 An outline Construction Environmental Management Plan (CEMP) has been submitted with the application. All construction traffic will use Wandsworth Road (south) to access the A3. The use of Vauxhall Cross gyratory has been avoided due to the construction of the improvements to the junction planned to occur between 2020 and 2021 which could overlap with the planned construction period of the development. However, it’s noted that a 4.72m height restriction is on place on the A3036 Wandsworth Road and if there are vehicles that are unable to use this route, they will use the A3 and Vauxhall gyratory to travel to/from the development site. The applicant will be expected to operate and be registered under the Considerate Constructors Scheme and sign up to the Vauxhall Nine Elms Construction Charter which will ensure that construction activities on nearby sites are also considered. This will be secured by s106. A full Construction Management Plan will be required for approval via condition (3).

Travel Plan 6.9.15 A draft Travel Plan has been submitted with the application and additional information was provided during the application process to take on board comments received from Lambeth’s Travel Plan Monitoring Officer. A full Travel Plan will be secured via a condition (23) and monitoring via s106.

Sustainable travel and mitigation 6.9.16 The development would secure the following sustainable travel measures: • The proposal includes high quality long-stay and short-stay cycle parking within the site. • EV charge points will also be provided for all on-site parking bays • A Travel Plan will be secured for the development. • The development will be secured parking permit-free • S106 contribution towards an additional 10 Cycle Hire docking stands to be located at the proposed Cycle Hire docking station on Hebden Place • A minimum of three years free membership of the Cycle Hire scheme for each dwelling, secured via S106. • The development will deliver an improved pedestrian experience by way of improved public realm and wider footways. • A contribution of £172,500 towards the delivery of improvements to walking and cycling on Pascal Street which forms part of the Healthy Routes Network • A minimum of three year’s Car Club membership to be provided for each residential unit. • 2 x new on-street Car Club bays to be provided on in the locality

6.9.17 No objection has been raised by the Council’s Transport and Highways Sections to the proposal. Subject to the above mitigation measures, the proposal would have an acceptable impact on the network and would encourage travel by sustainable means of transport be in accordance with LP policies T3, T4, T5, T6 and T7 and LLP Policies T1, T2, T3, T6, T7 and T8.

6.10 Sustainable Design and Construction

6.10.1 LP policies SI 2 and SI 4 state that development proposals should be net zero-carbon and minimise carbon dioxide emissions and manage heat risks. Policy SI3 expects major development proposals within Heat Network Priority areas to have a communal low-temperature heating system in line with LP hierarchy.

6.10.2 The LP also requires that the development follows an energy hierarchy when considering reducing CO2 emissions. The energy hierarchy must consider incorporation of energy efficiency

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measures including passive design, supplying energy efficiently (with a particular emphasis on de-centralised energy generation), using renewable energy technologies and monitoring energy performance.

6.10.3 Policy EN3 of the LLP and DRLLP requires development to utilise decentralized heating, cooling or power networks in the vicinity of the site, or future proof for planned energy networks.

6.10.4 In accordance with the principles of policies SI2 and SI3 of the LP, the applicant has submitted an Energy Statement which is generally compliant with the LP policies and Energy Assessment Guidance (2018) Energy Hierarchy.

Decentralised Energy 6.10.5 There are existing decentralized networks in the vicinity of the site. The operator of the US Embassy Quarters district heating network has been contacted by the applicant for further discussion. Whilst interest has been expressed in serving the site in the future, the Nine Elms site and district heating site are located on opposite sides of a railway track and connection is subject to the opening of a railway archway. Due to the many uncertainties surrounding the feasibility of a connection, the proposed development has progressed with a site-specific heating solution - a communal ambient water loop system, with provision for future connection to a single energy centre to serve the proposed development. As requested by the GLA, drawings demonstrating how the site is to be future-proofed for a connection to a district heating network have been provided.

6.10.6 The applicant has confirmed that operators of other District Heating Networks (DHN) in the area include Riverlight (SSE), Nine Elms Point (EON) and Pimlico District Heating Undertaking (Westminster council) have been contacted and as requested by the GLA evidence of this has been provided. The GLA requested further engagement with Engie including to establish possible timing for connection and this will be secured by condition (7). Future connection to a DHN would be secured by a legal agreement.

Minimising Carbon Dioxide Emissions 6.10.7 For the Be Lean stage, the applicant has demonstrated that improved energy efficiency measures for the residential element result in an improvement against the Part L 2013 Baseline for the Be Lean stage of nine per cent, which falls short of the recommendation of 10 per cent stated in the LP. Similarly, the non-residential element’s improvement against the Part L 2013 Baseline at one per cent would fall short of the 15 per cent LP target. In accordance with policy S12E the Energy Strategy includes calculations of unregulated emissions. The energy efficiency measures for the Be Lean stage include improved heat recovery technologies; glazing reduction designed to achieve a balance between daylighting and overheating; fabric performance savings including enhanced U-values and mitigation of thermal bridging, greater air tightness and optimisation of G- values. The applicant has investigated alternative passive measures, however, none of these were proven feasible at the time and would result in a significant impact on the shape and form of the buildings, the daylight factor and the overall facade design. A condition (7) is recommended to ensure that optimisation of the Be Lean stage is investigated further through a revised Energy Statement including a potential for waste-water heat recovery and a green lease agreement to ensure efficient fit-out of the non-residential unit.

6.10.8 For the Be Clean stage, as discussed above, the applicant provided a commitment that the development is designed to allow future connection to a DHN.

6.10.9 For the Be Green stage the proposals include ambient loop air source heat pumps for the provision of heating and domestic hot water. During the application process the applicant has provided information to demonstrate its combability with a future connection to DHN which satisfied the GLA’s request. The proposal also includes PV panels equating to circa 100sqm of

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net PV area and during the application process an area of possible further 100sqm has been identified which would not impact on the biodiverse roofs. The GLA requested further investigations and details will be secured by a condition (43). Utilisation of waste heat from the station was also considered but discounted due to feasibility issues associated with the design of the Nine Elms Station.

6.10.10 For the Be Seen stage, the Energy Assessment confirms that monitoring strategy will be devised to enable the end-user to assess the energy consumption and carbon emission. A central plantroom is proposed with metering for PV, ASHP and Electric Vehicle charging. For domestic unit-level smart metering will be provided. The s106 would include a requirement that the Be Seen guidance is submitted to the GLA’s portal at the appropriate reporting stages in line with the GLA’s request.

6.10.11 Overall, the Energy Assessment provides calculations with BRUKL and SAP reports to show that the development achieves 45 per cent reduction in non-domestic and 57 per cent in domestic carbon emissions over Part L(2013) . The development achieves a 56 per cent reduction in site- wide carbon emissions over Part L which exceeds the LP target of 35 per cent. It is recommended that a Finalised Energy Assessment is secured by a condition (7). A financial contribution which the applicant estimated to be £534,090 relating to the shortfall in carbon reductions would also be secured by s106 legal agreement.

Sustainable Design and Construction 6.10.12 The submitted Sustainability Statement is compliant with the LP policies relating to sustainable design and construction, including a Circular Economy Statement as requested by the GLA. The Sustainability Statement confirms that use of timber with FSC/PEFC certification and use of recycled materials where possible. The waste and water hierarchy will be implemented to manage site waste and water with procedures and work practices to be outlined in a Site Waste Management Plan. The Construction Environmental Management Plan confirms the use of sustainable materials and adherence to the GLA’s Responsible Procurement Policy, as well as making use of the Building Research Establishment’s Responsible Sourcing Standard BES6001. The Sustainability Statement also covers operational stage and confirms measures such as the provision of appropriate cooking ventilation, zero local emission (electric) cooking appliances and smart air quality monitors. Operational waste facilities will be provided to maximise waste recycling including food waste.

6.10.13 The applicant has provided a pre-assessment of non-residential development that a BREEAM rating Very Good (shell & core) would be achieved. It is recommended that this should be resubmitted upon consultation with the design team to confirm whether the improved Excellent rating (noted not unfeasible in the assessment) could be achieved. This will be secured by conditions (34 and 35) as recommended by the council’s sustainability consultant to ensure compliance with LLP policy EN4.

6.10.14 With regards to overheating and cooling for residential uses, the applicant’s assessment is based on windows remaining closed which is required to comply with acoustics and air quality assessments. Flats would be provided with internal blinds and active cooling system is proposed in areas such as gym and cinema rooms and the Pavilion Building. The ambient loop system is proposed to provide tempering of hot air to mitigate overheating risk within the flats. Guidance for the occupants to minimise overheating shall be included within the "Resident Welcome Pack". With regards to non-domestic areas, a condition (36) requesting that Overheating Analysis is submitted to and approved is recommended in line with the recommendations of the council’s sustainability consultant.

6.10.15 The applicant has confirmed the water consumption of the proposed development will meet the Optional Requirement of the Building Regulations, achieving mains water consumption of 105

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litres or less per head per day. However, no water efficiency information has been provided for the non-residential components of the development and the GLA noted that the developer should also consider water harvesting and reuse to reduce consumption of wholesome water across the entire development site. Conditions (37, 38 and 39) are recommended to ensure that further details including sanitaryware specification and the water demand per head of external maintenance and features are provided and the details implemented. This would ensure compliance with LP policy SI.5.

6.10.16 Policy SI2 F of the LP introduces a requirement to calculate the whole life-cycle emissions of the development through a nationally recognised Whole Life-Cycle Carbon Assessment (WLC). The WLC assessment includes not only the regulated emissions considered under current energy assessments but also the following: • Unregulated emissions, i.e. those associated with cooking and small appliances • Embodied emissions, i.e. those associated with raw material extraction, manufacture and transport of building materials and construction • Emissions associated with maintenance, repair and replacement as well as dismantling, demolition and eventual material disposal

6.10.17 The Mayor published draft guidance on the approach to WLC emissions assessments, including when they should take place, what they should contain and how information should be reported. The application pre-dated this policy requirement however an assessment was provided within the Sustainability Statement. The council’s sustainability advisor reviewed the submitted WLC and confirmed it complies with the reporting requirements of the GLA guidance. It has a limited scope, however this is understandable given the limited information available at this stage of design. The information provided for the superstructure shows a highly efficient structure with embodied carbon significantly lower than even aspirational targets. A condition (45) is recommended to ensure that appropriate targets are reached and demonstrated through a full post construction WLC.

6.10.18 LP policy S17 of the LP requires development referable applications to submit a Circular Economy Statement, and LP policy D3 requires development proposals to integrate circular economy principles as part of the design process. The GLA has released draft guidance for developers on how to prepare Circular Economy Statements and a ‘Design for a circular economy’ Primer that helps to explain the principles and benefits of circular economy projects. The applicant’s circular economy statement acknowledges that it was developed prior to issuing of this detailed guidance. Given this, the council’s sustainability advisor confirmed that it is reasonable to assess the submission against the core intent of the GLA guidance. The GLA welcomed the applicant’s commitment to reusing/recovering 95per cent of construction waste and requested commitment to achieve targets relating to recycled construction materials (20per cent), provision of notification of the likely destination of waste with suitable capacity and targets relating to municipal waste. The applicant confirmed their commitment to using reasonable endeavours to meet the relevant targets and this will be confirmed within post-completion circular economy statement (Condition 45).

6.10.19 Overall, the proposed development has been designed to be highly sustainable and maximise the potential carbon savings that can be achieved in accordance with the relevant policy and guidance. Therefore, the proposed scheme complies with polices SI2, SI3, SI4 of the LP and policy EN3 and EN4 of the LLP and DRLLP.

6.11 Other Environmental Matters

Flood Risk 6.11.1 The NPPF states that inappropriate development in areas at risk of flooding should be avoided by

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directing development away from areas at highest risk but, where development is necessary, making it safe without increasing flood risk elsewhere. LP policy SI.12 states that development proposals should ensure that flood risk is minimised and mitigated, and that residual risk is addressed. LLP Policy EN5 states that flooding in the borough will be minimised through applying a sequential, risk-based approach to the location of development to avoid flood risk to people and property. This general approach is designed to ensure that areas at little or no risk of flooding from any source are developed in preference to areas at higher risk. For all developments, it must be demonstrated that development will be safe, and where required it will reduce fluvial, tidal, surface run-off and groundwater floor risk through using appropriate flood risk measures, including the use of sustainable drainage systems.

6.11.2 A Flood Risk Assessment (FRA) has been submitted with the application to demonstrate that the development can be satisfactorily accommodated without worsening flood risk for the area and without placing the development itself at risk of flooding, as per national guidance provided within the NPPF and in accordance with LLP policy EN5.

6.11.3 The site is within Flood Risk Zone 3 (high) which means that there is a 1 per cent or greater annual probability of river flooding or 0.5 per cent annual probability of sea flooding. However, the actual risk is lowered significantly due to the presence of the Thames Tidal Defences. In this risk zone, all development must satisfy the sequential test for development set out in the NPPF and ‘more vulnerable’ uses, such as residential, must meet the Exception Test. For the Exception Test to be passed: • it must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared; and • a site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing food risk elsewhere, and, where possible, will reduce food risk overall.

6.11.4 In respect of the first point, the development would provide wider sustainability benefits to the community. It would redevelop a site above a station box to provide 479 new homes of which 40 per cent would be affordable and new public realm. Officers consider these benefits outweigh the flood risk.

6.11.5 For the second point, the submitted FRA notes that residential floor levels of the proposed over- station development are above the levels at risk of flooding, currently set at 7.55m AOD above the station building. This exceeds the levels of maximum flood level of 3.25mAOD. The FRA also proposes preparing a Flood Warning and Evacuation plan which is supported by officers and a condition (9) is recommend to secure this in line with the GLA request. The Environmental Agency noted that it was unclear from the FRA if the flood levels were determined using the most up to date data but raised no objections as the residential development being at first floor level would be above the 2100 breach flood level. The LLFA considered that the applicant appropriately assessed and managed the risk of flooding from surface water.

6.11.6 The GLA raised concerns that the FRA considers the risk of flooding from a range of sources but considered that it does not adequately address the residual risk of flooding due to a breach of River Thames and surface water overland flow. Flood resistance and resilience construction should be incorporated into the design to adequately address the residual risk. It advised that particular attention should be given to service rooms and generators on the ground floor to ensure a safe haven can be achieved on upper floors.

6.11.7 In response to the GLA concerns, the applicant advised that the UKPN substation and generator rooms at ground floor level is unavoidable due to the access and maintenance requirements of the service providers. These rooms also require very specific ventilation requirements with the vast

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majority of the doors/walls having specified louvers. As noted above, residential accommodation would be provided at first floor levels and above which would be safe from flooding and this includes fire alarm and emergency lighting back-up power provisions. The current proposal also follows on the principles accepted through the extent consent whereby the UKPN substation was also located at ground floor level and therefore the proposed scheme is considered to be acceptable in this respect.

6.11.8 The risk of increasing flood risk elsewhere would be mitigated with an appropriate drainage strategy, discussed below. The proposed development meets the above exception test and thereby complies with the NPPF, LP policy SI.12 and LLP policy EN5.

Sustainable Drainage 6.11.9 LLP policy EN6 require development to utilise sustainable urban drainage systems (SUDS) unless there are practical reasons for not doing so and should aim to achieve greenfield run-off rates and adequately manage surface water run-off. LP policy SI13 sets out a drainage hierarchy which should be followed.

6.11.10 The proposal would utilise the existing drainage system from the previously approved station box. Due to the site’s constraints associated with the station box it is not possible to provide for additional attenuation volume for water management system. The proposed discharge rate of 89.8l/s represents a reduction of 50 per cent from the existing rates. The drainage strategy demonstrates that the proposed surface water management system will effectively manage runoff within the site up to the 1per cent Annual Exceedance Probability (AEP) taking account of climate change. The LLFA noted that the proposed rate is higher than what would be normally expected however the site’s constraints have been acknowledged and the LLFA raised no objection to the proposed drainage strategy which incorporates tree pits with storage crates, rain gardens and a hydrobrake to facilitate attenuation within the network.

6.11.11 The GLA considered that the proposed drainage strategy does not give appropriate regard to the drainage hierarchy and greenfield runoff rate and requested further information. They requested that further details on how SuDS measures at the top of the drainage hierarchy will be included in the development, and how greenfield runoff rate will be achieved. Additional information explaining the site constraints has been provided by the applicant and will be formally considered by the GLA in their Stage 2 response.

6.11.12 In terms of water management, Thames Water raised no objections and advised that they are currently working with the developer to identify and deliver the off-site water infrastructure needs to serve the development. Conditions recommended by Thames Water (8, 18 and 40) are recommended.

6.11.13 Officers consider that subject to the above conditions being imposed, the proposals would satisfy policy requirements in reducing the risk of flooding both on-site and in the surrounding environment.

Air Quality 6.11.14 The whole borough is within an Air Quality Management Area (AQMA) in relation to a breach of nitrogen dioxide and particulate matters objectives as specified in the Air Quality Regulations 2000.

6.11.15 The LP policy SI1 recognise the need to reduce contributory factors to air pollution and improve the public’s exposure to pollution. It expects developments to at least be Air Quality Neutral and demonstrate how design solutions can address/minimise exposure of those most vulnerable, i.e. children and the elderly.

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6.11.16 The applicant has provided a detailed air quality report which assesses both the construction and operational impacts. A review of baseline air quality within the vicinity indicated that the proposed development is likely to be near to or above the AQS objectives at ground level. However, the proposed residential accommodation would be set back at least 7m horizontally and more than 14m vertically from Wandsworth Road and at these locations the modelled road contribution is small with concentrations more akin to urban background conditions as opposed to those typically observed at roadside locations. At this height, concentrations are expected to be below AQS objective levels and therefore the site is suitable for the introduction of residential use. It is noted that the location of proposed residential units is no closer to sources of air quality pollutants than the extant permission and all units would benefit from mechanical ventilation. The estimated transport and buildings emissions for this developed would be below the benchmark levels set by the GLA. As such, it could be considered to be ‘air quality neutral’.

6.11.17 With regards to construction phase, the qualitative assessment of dust effects predicts that there will be a high risk of dust creating nuisance and /or loss of amenity and of PM10 leading to adverse health effects without mitigation. Following the implementation of mitigation measures the impacts are predicted to be not significant. Accordingly, a full Air Quality and Dust Management Plan (AQDMP) would be required by condition (5) and it would need to follow the guidance for high-risk sites set out in the Control of Dust and Emissions During Construction and Demolition SPG (2014). In addition, automatic continuous PM10 monitoring and compliance of non-road mobile machinery with emissions regulations would be required by conditions (5 and 6). Overall, the proposed development is considered to comply with LP policy SI1.

Wind Microclimate 6.11.18 The application is supported by a Micro-Climate Assessment. A model of the proposed development was wind-tunnel tested in order to assess the resulting wind conditions and the impact on pedestrian comfort. The study assessed pedestrian level in the vicinity of the site, roof terraces and balconies. The safety criterium was satisfied at all measuring points and therefore no potential risk for pedestrians or cyclists according to the defined safety criterium was identified.

6.11.19 Nearly all investigated areas at the ground and podium levels and on the roof terraces are wind sheltered or comparable to the wind situation at site without any buildings. A good pedestrian comfort is expected during the summer period with many areas suitable for frequent and occasional sitting. It was identified that the proposed landscape concept with its planting at the ground level has a positive effect on the pedestrian wind comfort and the design of the glass balustrade at roof top levels also has significant impact on the wind comfort levels.

6.11.20 Due to the more wind intensive winter period the wind situation is consequently predicted to be less favourable compared to the summer (still expected to be better than or comparable with the reference situation at the site without any buildings). The majority of the measured locations on the balconies will have a good wind comfort during the more important summer period with most of the balconies being identified as suitable for long-term sitting. Overall the local wind conditions are predicted to be acceptable with no areas requiring any mitigation for pedestrian comfort issues. The council’s consultant wind expert has recommended to include a planning condition (30) to ensure that any future amendment to the current external configuration is assessed from wind - tunnel perspective. The development would be in compliance with LP policy D9 and LLP policy Q26.

Solar Glare 6.11.21 Due to the dominance of non-reflective materials on the exterior of the development there would be little risk of harmful solar glare.

Ground Contamination 6.11.22 In accordance with LLP policy EN4 proposals should include an assessment of existing ground

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conditions and identify appropriate remedial measures for any contaminated land prior to development commencing. This aspect has already been covered through the TWAO consent (Condition 9) and as the proposed scheme would be constructed above the station no further conditions are required.

Fire Strategy

6.11.23 LP policy D3 (Inclusive design) requires proposals to set out how access and inclusion will be maintained and managed, including fire evacuation procedures. LP policy D12 (Fire safety) states that all development proposals must achieve the highest standards of fire safety. Whilst fire safety is currently dealt with under Building Control legislation, the planning process acts as a ‘gateway’ to the consideration of the issue and we seek to ensure that appropriate consideration has been given.

6.11.24 The fire statement submitted with the application includes details of construction methods, products and materials; the means of escape including a lift with enhanced facilities for evacuation in each block; access for fire service personnel, equipment and fire appliances. The strategy also incorporates features which reduce the risk to life such as sprinklers, 24/7 management with fire control centre and emergency voice communication devices at each stair core. The Council’s Building Control officer has reviewed the submitted fire strategy and access and consider the approach to be reasonable and achievable. The proposal would be subject to a final assessment of compliance which would be completed when the Building Regulations application is submitted to the nominated Building Control body. This would entail the submission of the final version fire strategy and any amended plans and specifications etc and subject to further consultation with London Fire Brigade. The scheme thereby complies with LP policy D12.

6.12 Employment and Skills

6.12.1 Policy ED14 of the LLP and policy ED15 of DRLLP state that planning obligations should be used to secure employment opportunities and apprenticeships arising from major developments, so that local residents are given access to the right skills training so that they can take advantage of opportunities created by new development.

6.12.2 The development is estimated to support up to 7 permanent full-time jobs through the commercial unit, and further 21 on-site roles associated with BtR management and maintenance roles. The demolition and construction phase could also generate approximately 75 full time equivalent jobs directly and 113 off site jobs indirectly.

6.12.3 The SPD on Employment and Skills (2018) sets out a ‘headline’ target of 25 per cent of jobs generated by developments as being for local residents. In this case, as the application site adjoins a boundary with LB of Wandsworth, the definition of local residents would be broadened to include Wandsworth residents. The council’s Employment and Skills Team confirmed that this would meet the request raised by LB Wandsworth. The SPD envisages that an applicant will be asked to work towards delivery of that target through the carrying out of an approved employment and skills plan, which would be designed so as to include the intended target numbers and types of job opportunities. The SPD envisages an element of flexibility in how an applicant may agree to work towards delivery of employment and skills obligations, for example as regards the target mix of jobs, apprenticeships and/or bespoke employment training and support arrangements. The employment and skills plan should also set out how an applicant will aim to deliver young people’s training and careers initiatives.

6.12.4 The Employment and Skills SPD also seeks a monetary contribution to help support those sections of the Lambeth workforce that are furthest from employment, having been out of work for a long period of time and/or having low levels of skills. The financial contributions are used by the council to

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fund training and support to enable access to newly created employment opportunities arising from development. For this development the financial contribution would be £280,961 based on the formula set out in the SPD.

6.12.5 Overall, it is considered that the proposal meets the requirements of LLP policy ED14, DRLLP policy ED15 and the SPD on Employment and Skills.

6.13 Planning Obligations and CIL

6.13.1 The LLP policy D4 and Annex 10 sets out the Council’s policy in relation to seeking planning obligations and the charging approaches for various types of obligation. For contributions that are not covered by Annex 10, the Council’s approach to calculating contributions is guided by the Development Viability SPD (adopted 2017) and the Employment and Skills SPD (adopted 2018).

6.13.2 The planning obligations that are proposed are considered necessary to make the development acceptable in planning terms, are directly related to the development and are fairly and reasonably related in kind and in scale to the development. They are therefore compliant with the requirements of Regulation 122 of the Community Infrastructure Levy Regulations 2010.

6.13.3 The proposed obligations to be secured through the S106 Agreement are as follows:

Item Details Build to rent (BtR) housing • Covenant clause (15 years) and claw back mechanism following the Formula set out in the GLA’s Affordable Housing SPG (2017) which will include a formula for calculating clawback per unit • Provision for unified ownership • Provision for residential management plan (to include minimum tenancy agreement lengths and break clauses, rent and service charge security, management arrangements, complaints procedures) Affordable housing – on site • 40% of units by habitable rooms to be affordable (DMR) provision in perpetuity • The % discount in relation to market rent to be fixed by unit size and to follow the %s in Table 2 of the report. • 12% of DMR units (21 units including 5 x 3 bedroom and 16 x 2 bedroom) to be subject to a % discount that results in a starting rent that is the equivalent to Lambeth Tenancy Strategy 2020 levels and thereafter at the appropriate % discount, subject throughout to a rent cap as explained in paragraphs 6.27-6.28 of the report. • 88% of the DMR units (155 units) to be subject to a % discount that results in a starting rent that is the equivalent of 2021/22 LLR levels and thereafter at the appropriate % discount, subject throughout to a rent cap as explained in paragraphs 6.27-6.28 of the report. • Provision for rent to increase annual during the life of tenancies by CPI + 1%.

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• Eligibility and affordability criteria to be specified (including a household gross income cap of £60K per annum) and arrangements for marketing of units to be specified (including through portals: Homes for Londoners for LLR and Lambeth Private Sector Solutions for LTS) and a bespoke nominations agreement provided for all DMR units

Review mechanisms: • Early Stage Viability Review will be triggered if the scheme is not implemented within two years from vacant possession. • Late stage review will be triggered at 18 months post first occupation of market housing or at occupation of 100% of market units (whichever is the earliest) • Where a viability review demonstrates an improvement in a scheme’s viability, a percentage split of the increase in the scheme’s value (the surplus) will be shared between the developer (20%) and the Council (80%) up to a cap which would achieve the equivalent of a fully policy compliant level of affordable housing as set out in paragraph 6.2.30 of the report • The Council’s share of the surplus to be applied by the developer towards reducing the rents of the DMR units to levels that bring the scheme closer to the ‘targets’ set out in paragraph 6.2.30 of the report, using an agreed mechanism to ‘allocate’ that surplus to rent reductions for different sizes of unit and providing for a payment in lieu (to be applied to the provision of affordable housing more generally) if rent reductions are not feasible because all affected units are already rented out. Communal/Children • Secure in perpetuity and access rights to all residents Play space including a Communal Amenity Management Plan.

Public • Delivery of public realm improvements as set out in the realm/Phasing approved plans • Management strategy and public access to public realm with rights for temporary closure in permitted circumstances (as in the extant permission). • Phasing strategy to facilitate delivery of Block D and/or temporary landscaping strategy if required for up to 5 years from first occupation of residential units. • Provision for limiting access to and/or temporary use of parts of Pascal Square in order for it to be used as a site compound and access for construction of Block D.

Transport • Car parking permit free designation for all residential units - – except in instances where additional on-street blue badge parking spaces are required. • Car parking permit free for all non-residential uses • Car club membership for each initial resident for a period of 3 years from first occupation. • Car Park Design and Management Plan (including provision of off-site Blue Badge spaces at £10,000 per

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space) and car spaces to be leased not sold. • TFL Cycle Hire Memberships: 1x fob to be provided for each initial resident for a period of min. 3 years from first occupation. • A contribution of £20k towards the provision of 10 cycle hire docks on Hebden Place. • Two new on-street car club bays to be provided in the locality. • Lambeth Healthy Routes contribution of £172,500 towards improvements on Pascal Street. • Travel Plan – 5 year monitoring contribution of £5,300 • Considerate Constructors Scheme • Nine Elms Construction Charter • Enter into a s278 agreement for highways works agreement with regards to works that will affect the highway including improvements to access points, pedestrian footways and carriageway, reinstatement works and provision of a loading bay on Pascal Street - – such works to be shown on a plan and will be separate to the highway works required for Block D (separate s.278 agreement) Employment and • Employment and Skills Plan to cover reasonable Skills endeavours to secure 25 per cent of jobs created by the development during construction and end-use phases in accordance with the SPD on Employment and Skills (2018) including for Wandsworth residents. • Financial contribution of £280,961 to be used towards vocational training and employment support

Carbon Offset • Carbon off-set contribution (approximately £534,090) • Submission of further details relating to future energy network connection, monitoring (Be Seen stage) and to identify the value of final carbon off-setting contribution

Other • Monitoring fee of 5% of total financial obligations.

Community Infrastructure Levy (CIL)

6.13.4 If the application is approved and the development is implemented, a liability to pay the Lambeth Community Infrastructure Levy (CIL) will arise.

6.13.5 Expenditure of the majority of a future CIL receipt will be applied towards Borough infrastructure needs in accordance with the applicable policies and procedures relating to expenditure decisions.

6.13.6 Allocation of CIL monies to particular infrastructure projects is not a matter for consideration in the determination of planning applications. Separate governance arrangements are being put in place for Borough Infrastructure needs.

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7 CONCLUSION

7.1 The proposals result in development of a key site, above and surrounding the new Nine Elms Station for residential led-mixed use purposes. The proposal seeks to develop above and around the Nine Elms Station buildings to provide a ‘slot -in’ residential led mixed-use development comprising three new residential buildings of 21 storeys (Block A), 16 storeys (Block B) and 17 storeys (Block C) providing a total of 479 homes including 40 per cent affordable housing which would replace the previously approved residential towers. This represents an overall increase of 147 residential units (44 per cent) when compared with the extant permission while the number of affordable units would increase by 92 (109 per cent). The proposal also includes a public square with a small flexible commercial unit (Use Class A1-A4 and D1) facing the new Pascal Square and associated works. It is proposed to implement the scheme in phases which incorporates part-implementation of the extant consent (Block D).

7.2 The development would maximise housing delivery and provide much needed, good quality housing, including a high level of affordable housing, at a density that makes optimum use of the site. The level of affordable housing at 40 per cent meets policy requirement for schemes on public sector land where a portfolio agreement with the Mayor of London is in place. However the proposals were viability tested due to their reliance on grant funding and the non-policy compliant tenure split of the residential units. An independent review confirmed that the affordable housing offer is the maximum viable. During the application process extensive discussions with the GLA took place and the applicant secured an in principle additional, bespoke grant offer which enabled the scheme to reduce the originally offered rent levels. An early and a late stage review are recommended to ensure that the affordability of rents is further maximised should the viability improve.

7.3 The acceptability of tall buildings on this site has been established through the extant permission, and the proposed towers at 21, 16 and 17 storeys sit within the policy requirements and design aspirations of the London Plan, the Lambeth Local Plan and the emerging draft Lambeth Local Plan. Despite the constraints of the site laid down by the station building, the triangular building form and position of each block, the use of high quality materials, the junction between the station and the development above, and the creation of a significant area of new public realm provides a suitable and positive edge and gateway between the Vauxhall tall building cluster and the lower scale of development to the south. The proposed scheme would not result in harm to any heritage assets or their settings or affect local views from Brockwell Park. In addition, the development has been designed in conjunction with advice offered by the Metropolitan Police’s Design Officer so as to minimise the opportunity for crime/terrorism as far as is practicable.

7.4 The development would provide a high quality residential environment for all future occupiers and would contribute significantly to meeting Lambeth’s and London’s housing targets. All of the new dwellings have been designed to meet relevant standards in terms of size, layout, aspect and adaptability. The proposed units will achieve reasonable levels of outlook, daylight and sunlight. In addition, the development is inclusive of generous on-site amenity (both private and communal), play space provision and the delivery of a significant new area of public realm.

7.5 The proposals would ensure that levels of privacy and outlook of adjoining residential uses is maintained and in some areas enhanced when compared to the existing situation. In terms of the impact on daylight and sunlight and the shift change from the ‘consented’ to ‘proposed’ application scheme, there is fairly limited effect in absolute terms upon both neighbouring properties, with the isolated exception of daylight to three windows. However, consideration should be given to the context of the application site which is located within an opportunity area. Officers are satisfied that the impact of the proposal on daylight and sunlight of neighbouring properties is acceptable.

7.6 The development would have an acceptable impact on the highway and transport network. The

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development would be car free, with occupants of the commercial and residential units not eligible for parking permits. 14 on-site disabled parking spaces would be provided with a parking management plan secured by s106 agreement. The scheme would provide a total of 851 cycle parking spaces, in accordance with the London Plan standards. The new public realm will serve to improve links throughout the area as well as provide an attractive and well-designed area for people to dwell. The development would also contribute to improvements to the Local Healthy Routes network and would be suitably mitigated in terms of its impact upon local infrastructure. Subject to conditions, the development would not impact unacceptably upon the function and safety of the highway network (both pedestrian and vehicular).

7.7 The principles of the Mayor’s energy hierarchy have been applied to the proposed development and the Energy Strategy submitted in support of the application demonstrates that a site-wide carbon emissions reduction of 56 per cent would be achieved over the Building Regulations Part L 2013 Baseline. A future financial contribution is required to offset all remaining regulated CO2 emissions to 100 per cent or “zero carbon emissions” will be secured through s106 agreement.

7.8 Subject to conditions, the development would meet technical requirements in respect of sustainability, flood risk mitigation, wind conditions, waste and recycling, air quality and water infrastructure.

7.9 The development would provide an appropriate balance of uses including private and affordable homes, and commercial uses and would improve the environment both in terms of linkages and new public realm. The application is therefore recommended for approval, subject to conditions and completion of a s106 Agreement in accordance with the presumption in favour of sustainable development conferred upon Local Planning Authorities by the National Planning Policy Framework.

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8 PROCEDURAL MATTERS

8.1 The application is referrable to the Mayor under the provisions of the Town and Country Planning (Mayor of London) Order 2008. The application has been referred to the Mayor at ‘Stage 1’. Before Lambeth can issue a decision on this application it will need to refer the application again to the Mayor at Stage 2; at which point the Mayor will have the opportunity to elect to become determining authority, direct refusal, or allow Lambeth to proceed and issue the decision in line with its resolution.

9 EQUALITY DUTY AND HUMAN RIGHTS

9.1 In line with the Public Sector Equality Duty the council must have due regard to the need to eliminate discrimination and advance equality of opportunity, as set out in section 149 of the Equality Act 2010. In making this recommendation, regard has been given to the Public Sector Equality Duty and the relevant protected characteristics (age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation).

9.2 In line with the Human Rights Act 1998, it is unlawful for a public authority to act in a way which is incompatible with a Convention right, as per the European Convention on Human Rights. The human rights impact has been considered, with particular reference to Article 1 of the First Protocol (Protection of property), Article 8 (Right to respect for private and family life) and Article 14 (Prohibition of discrimination) of the Convention.

9.3 The Human Rights Act 1998 does not impair the right of the state to make decisions and enforce laws as deemed necessary in the public interest. The recommendation is considered appropriate in upholding the council's adopted and emerging policies and is not outweighed by any engaged rights.

10 RECOMMENDATION

1. Resolve to grant conditional planning permission subject to the completion of an agreement under Section 106 of the Town and Country Planning Act 1990 (as amended) containing the planning obligations listed in this report and any direction as may be received following further referral to the Mayor of London.

2. Agree to delegate authority to the Director of Planning, Transport and Sustainability to: • Finalise the recommended conditions as set out in this report, addendums and/or PAC minutes; and • Negotiate, agree and finalise the planning obligations as set out in this report, addendums and/or PAC minutes pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended).

3. In the event that the committee resolves to refuse planning permission and there is a subsequent appeal, delegated authority is given to the Director of Planning, Transport and Sustainability, having regard to the heads of terms set out in this report, addendums and/or PAC minutes, to negotiate and complete a document containing obligations pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended) in order to meet the requirement of the Planning Inspector.

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4. In the event that the Section 106 Agreement is not completed within 6 months of committee, delegated authority is given to the Director of Planning, Transport and Sustainability to refuse planning permission for failure to enter into a section 106 agreement for the mitigating contributions identified in this report, addendums and/or the PAC minutes.

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APPENDICES

Appendix 1: Draft Decision Notice

Your Ref: Our Ref: 20/02331/FUL

DRAFT DECISION NOTICE

Dear Connected Living London (Nine Elms) Ltd

TOWN AND COUNTRY PLANNING ACT 1990.

PERMISSION FOR DEVELOPMENT

The London Borough of Lambeth hereby permits under the above mentioned Acts and associated orders the development referred to in the schedule set out below subject to any conditions imposed therein and in accordance with the plans submitted, save in so far as may otherwise be required by the said conditions.

In accordance with the statutory provisions your attention is drawn to the statement of Applicant’s Rights and General Information attached.

Application Number: 20/02331/FUL Date of Application: 13.07.2020 Date of Decision:

Proposed Development At: 10 Pascal Street London SW8 4SH

For: Full 'slot-in' planning application for phased, residential led mixed-use development above and surrounding Nine Elms Station, comprising three new residential buildings of 21 storeys, 16 storeys and 17 storeys providing a total of 479 homes (Use Class C3), plus small scale commercial floorspace of 108m2 (Expanded Use Classes A1-A4 and D1), works within the Nine Elms Station 'boxes', a new public square, and associated works.

Approved Plans CLL-NE1 OSD-AA-XX-ZZ-DR-A-0175 Site Location Plan P1; CLL-NE2 OSD-AA-XX-ZZ-DR-A-0177 Proposed Site Plan P1; CLL-NE3.1 OSD-AA-XX-ZZ-DR-A-0176 Existing Site Plan P1; CLL-NE3.2 OSD-AA- XX-B1-DR-A-0100 Existing Basement Level 1 Floor P1; CLL-NE3.3 OSD-AA-XX-01-DR-A-0103 Existing Ground Floor Plan P1; CLL-NE3.4 OSD-AA-XX-0M-DR-A-0102 Existing Mezzanine Floor Plan P1; CLL- NE3.5 OSD-AA-XX-01-DR-A-0103 Existing Roof Plan P1; CLL-NE3.6 OSD-AA-XX-ZZ-DR-A-0104 Existing Site Wide South Elevation P1; CLL-NE3.7 OSD-AA-XX-ZZ-DR-A-0105 Existing Site Wide North Elevation P1; CLL-NE3.8 OSD-AA-XX-ZZ-DR-A-0106 Existing Building A West Elevation P1; CLL-NE3.9 OSD-AA-XX- ZZ-DR-A-0107 Existing Building A East Elevation P1; CLL-NE3.10 OSD-AA-XX-ZZ-DR-A-0108 Existing Building B West Elevation P1; CLL-NE3.11 OSD-AA-XX-ZZ-DR-A-0109 Existing Building C East Elevation P1; CLL-NE3.12 OSD-AA-XX-ZZ-DR-A-0110 Existing Site Wide Section AA P1; CLL-NE3.13 OSD-AA-XX- ZZ-DR-A-0111 Existing Site Wie Section BB P1; CLL-NE3.14 OSD-AA-XX-ZZ-DR-A-0112 Existing Building A Short Section P1; CLL-NE3.15 OSD-AA-XX-ZZ-DR-A-0113 Existing Building B Short Section P1; CLL-

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NE3.16 OSD-AA-XX-ZZ-DR-A-0114 Existing Building C Short Section P1; CLL-NE3.17 OSD-AA-XX-B2-DR- A-0199 Proposed Basement Level 2 Plan P1; CLL-NE3.18 OSD-AA-XX-B1-DR-A-0200 Proposed Basement Level 1 Plan P1; CLL-NE3.19 OSD-AA-XX-00-DR-A-0201 Proposed Ground Floor Plan P2; CLL-NE3.20 OSD-AA-XX-0M-DR-A-0202 Proposed Mezzanine Floor Plan P2; CLL-NE3.21 OSD-AA-XX-01-DR-A-0203 Proposed First Floor Plan P2; CLL-NE3.22 OSD-AA-XX-02-DR-A-0204 Proposed Second Floor Plan P2; CLL-NE3.23 OSD-AA-XX-03-DR-A-0205 Proposed Third to Fifth Floor Plan P2; CLL-NE3.59 OSD-AA-XX- 06-DR-A-0208 Proposed Sixth to Fifteenth Floor Plan P1; CLL-NE3.24 OSD-AA-XX-16-DR-A-0218 Proposed Sixteenth Floor Plan P2; CLL-NE3.25 OSD-AA-XX-17-DR-A-0219 Proposed Seventeenth Floor Plan P2; CLL-NE3.26 OSD-AA-XX-18-DR-A-0220 Proposed Eighteenth Floor Plan P1; CLL-NE3.27 OSD- AA-XX-19-DR-A-0221 Proposed Nineteenth & Twentieth Floor Plan P1; CLL-NE3.28 OSD-AA-XX-21-DR-A- 0223 Proposed Twenty First Floor Plan P1; CLL-NE3.29 OSD-AA-XX-22-DR-A-0224 Proposed Roof Plan P2; CLL-NE3.30 OSD-AA-BLA-02-DR-A-0251 Proposed Building A Buttress Internal Layouts P1; CLL- NE3.31 OSD-AA-BLA-03-DR-A-0252 Proposed Building A Typical Internal Layouts P1 CLL-NE3.32 OSD- AA-BLA-21-DR-A-0253 Proposed Building A Outrigger Internal Layouts P1 CLL-NE3.33 OSD-AA-BLB-02- DR-A-0254 Proposed Building B Buttress Internal Layouts P2; CLL-NE3.60 OSD-AA-BLB-03-DR-A-0260 Proposed Building B Third to Fifth Internal Layouts P1; CLL-NE3.34 OSD-AA-BLB-03-DR-A-0255 Proposed Building B Typical Internal Layouts P2 CLL-NE3.35 OSD-AA-BLB-16-DR-A-0256 Proposed Building B Outrigger Internal Layouts P1; CLL-NE3.36 OSD-AA-BLC-02-DR-A-0257 Proposed Building C Buttress Internal Layouts P2; CLL-NE3.37 OSD-AA-BLC-03-DR-A-0258 Proposed Building C Typical Internal Layouts P2; CLL-NE3.38 OSD-AA-BLC-17-DR-A-0259 Proposed Building C Outrigger Internal Layouts P2 ; CLL- NE3.39 OSD-AA-XX-ZZ-DR-A-0301 Proposed Site Wide Section AA P1; CLL-NE3.40 OSD-AA-XX-ZZ-DR- A-0302 Proposed Site Wide Section BB P1; CLL-NE3.41 OSD-AA-XX-ZZ-DR-A-0303 Proposed Building A Short Section P1; CLL-NE3.42 SD-AA-XX-ZZ-DR-A-0304 Proposed Building B Short Section P1; CLL- NE3.43 OSD-AA-XX-ZZ-DR-A-0305 Proposed Building C Short Section P1; CLL-NE3.44 OSD-AA-XX-ZZ- DR-A-0350 Proposed Ladder sections through juliette & projecting balconies P1; CLL-NE3.45 OSD-AA-XX- ZZ-DR-A-0351 Proposed Ladder sections through inset & semi-inset balconies P1; CLL-NE3.46 OSD-AA- XX-ZZ-DR-A-0352 Proposed Ladder sections through amenity & entrance P1; CLL-NE3.47 OSD-AA-XX- ZZ-DR-A-0401 Proposed Site Wide South Elevation P1; CLL-NE3.48 OSD-AA-XX-ZZ-DR-A-0402 Proposed Site Wide North Elevation P2; CLL-NE3.49 OSD-AA-XX-ZZ-DR-A-0403 Proposed Building A West Elevation P1; CLL-NE3.50 OSD-AA-XX-ZZ-DR-A-0404 Proposed Building A East Elevation P1; CLL- NE3.51 OSD-AA-XX-ZZ-DR-A-0405 Proposed Building B West Elevation P2; CLL-NE3.52 OSD-AA-XX- ZZ-DR-A-0406 Proposed Building C East Elevation P1; CLL-NE3.53 OSD-AA-XX-ZZ-DR-A-0407 Proposed Hypotenuse Elevations P1; CLL-NE3.54 Rev D General arrangement plan - ground floor; CLL-NE3.55 rev F – Detailed Plan – Pascal Square; CLL-NE4 OSD-AA-ZZ-ZZ-SH-A-0701 Detailed Schedule of Accommodation P11; OSD-AA-XX-06-DR-A-0208 P1 Proposed Sixth to Fifteenth Floor Plan P1; OSD-AA- BLB-03-DR-A-0260 P1 Proposed Building B Third to Fifth Internal Layouts P1; OSD-AA-XX-ZZ-DR-A-0935 P1 Proposed Site Plan with consented context. Reports and other supporting documents: CLL-NE22 Construction Environmental Management Plan by Atkins; Design and Access Statement CLL-NE7 by Assael; Planning Statement CLL-NE8 by Avison and Young; Statement of Community Involvement CLL-NE9 by Casacde; Transport Assessment CLL-NE10 by Aecom; Framework Travel Plan CLL-NE11 by Aecom; Affordable Housing Viability Assessment CLL-NE12 by Avison and Young; Housing Delivery Statement CLL- NE13 by Quod; Daylight, Sunlight and Overshadowing Report CLL-NE14 by Avison and Young; Biodiversity Report CLL-NE15 by Atkins; Air Quality Assessment CLL-NE16 by Atkins; Energy Assessment CLL-NE17 by Atkins; Sustainability Statement CLL-NE18 by Atkins; Flood Risk Assessment and Drainage Strategy CLL- NE19 by Atkins; Utilities Strategy Report CLL-NE20 by Atkins; Noise and Vibration Impact Assessment CLL- NE21 by Atkins; Heritage Townscape Visual Impact Appraisal CLL-NE23 by Arc; Micro-Climate Assessment CLL-NE24 by Wacker; Fire Statement CLL-NE25 by Hoare Lea; Exterior Lighting Strategy CLL-NE7 by Atkins; DAS addendum Design and Access Statement Addendum P1; External lighting Strategy Addendum by Atkins; Micro Climate Study Addendum Latter by Wacker ; Socio-Economic Impact Assessment by Avison Young; Operational Waste and Recycling Management Strategy by AECOM revised 02.03.21; Drawing: OSD-AA-XX-01-DR-A-0936 R1 Proposed non standard cycles in lifts; Transport Assessment Addendum February 2021 by AECOM ; Email from AY dated 17.12.20 with cycle parking clarifications; Email from AY dated 26/02/21 confirming commitment to Streetscape for London; Josta 2-tier High Capacity Racks details; Daylight an sunlight letter from Avison Young dated 18.01.2021; Daylight and Sunlight analysis results 12.03.2020; Daylight and Sunlight Post submission Queries 03.21; Technical Note ‘Optimisations for Domestic and Non-Domestic areas for GLA's 'Be Lean' targets’ by Atkins; Summary of Ambient Loop DEN Connections by Danfloss; Technical Submittal Heat Exchanger Substations by Danfloss x 3 (500kW, 100kW and 2000kW); General Principle of ambient loop ASHP on each building by Atkins; OSD-AA-XX-00-DR-A- 0201 R10 District Heating Network proposed route; Technical Note GLA District Heating Energy queries clarification by Atkins; Technical Note Surface Water Drainage by Atkins.

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Conditions

Standard Conditions

Time Limit

1. The development hereby permitted shall begin before the expiration of four years from the date of this permission.

Reason: To comply with Section 91 of the Town and Country Planning Act 1990 (As Amended).

Approved Drawings

2. The development hereby permitted shall be carried out in complete accordance with the approved plans listed in this decision notice, other than where those details are altered pursuant to the requirements of the conditions of this planning permission.

Reason: For the avoidance of doubt and in the interests of proper planning.

Pre-commencement conditions

Construction and Environmental Management Plan (CEMP)

3. For each phase, no development shall commence until a Construction and Environmental Management Plan (CEMP) relating to that phase has been submitted to and approved in writing by the local planning authority in consultation with TfL. The CEMP shall include details of the following relevant measures:

a) An introduction consisting of construction phase environmental management plan, definitions and abbreviations and project description and location; b) A description of management responsibilities; c) A description of the construction and demolition programme which identifies activities likely to cause high levels of noise or dust; d) Site working hours and a named person for residents to contact; e) Detailed Site logistics arrangements; f) Details regarding parking, deliveries, and storage; g) Details regarding dust and noise mitigation measures to be deployed including identification of sensitive receptors, together with arrangements for ongoing continuous monitoring and provision of monitoring results to the Local Planning Authority; h) Details of measures to prevent the deposit of mud and debris on the public highway; i) Any measures to mitigate the impact of demolition and construction upon the function and safety of the surrounding area for cyclists; j) Any other measures to mitigate the impact of demolition and construction upon the amenity of the area and the function and safety of the highway network. k) Details of a temporary lighting strategy, including details of temporary lighting of all public areas and buildings showing acceptable positioning and levels of glare l) measures to heighten awareness of the potential for ecological features as set out in the herby approved Biodiversity Report and m) Communication procedures with the LBL and local community regarding key construction issues – newsletters, fliers etc. n) Details demonstrating that Street Space for London Plan guidance informed the CEMP (where relevant/feasible) The demolition and construction shall thereafter be carried out in accordance with the details and measures approved in the CEMP for the related phase, unless the written consent of the Local Planning Authority is received for any variation.

Reason: This is required prior to construction to avoid hazard and obstruction being caused to users of the public highway and to safeguard residential amenity and biodiversity value of the site during the whole of the construction period. (Policies T6, EN1 and Q2 of the Lambeth Local Plan (2015)).

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Non-road mobile machinery (NRMM)

4. If Non Road Mobile Machinery (NRMM) of net power of 37kW and up to and including 560kW is required on site during the course of demolition, site preparation and construction phases, it must comply with the emission standards set out in chapter 7 of the GLA’s supplementary planning guidance “Control of Dust and Emissions During Construction and Demolition” dated July 2014 (SPG), or subsequent guidance. Unless it complies with the standards set out in the SPG, no NRMM shall be on site, at any time, whether in use or not, without the prior written consent of the local planning authority. The developer must register all NRMM at https://nrmm.london/user- nrmm/register prior to bringing it on to site and shall keep the register up to date by listing all NRMM used during the demolition, site preparation and construction phases of the development

Reason: To ensure that air quality is not adversely affected by the development (Policy SI 1 of the London Plan (2021))

Air quality impacts (construction stage)

5. No development shall commence until full details of the proposed mitigation measures for impact on air quality and dust emissions, in the form of an Air Quality and Dust Management Plan (AQDMP), have been submitted to and approved in writing by the local planning authority. In preparing the AQMDP the applicant should follow the guidance on mitigation measures for high risk sites (as a minimum) set out in Appendix 7 of the Control of Dust and Emissions during Construction and Demolition SPG 2014 for demolition, earthworks, construction and trackout. Both ‘highly recommended’ and ‘desirable’ measures should be included. The AQDMP can form part of the Construction Environmental Management Plan (CEMP). The AQDMP shall include the following for each relevant phase of work (demolition, earthworks, construction and trackout): o A summary of work to be carried out; o Proposed haul routes, location of site equipment including supply of water for damping down, source of water, drainage and enclosed areas to prevent contaminated water leaving the site; o Inventory and timetable of all dust and NOx air pollutant generating activities; o List of all dust and emission control methods to be employed and how they relate to the Air Quality (Dust) Risk Assessment; o Details of any fuel stored on-site; o Details of a trained and responsible person on-site for air quality (with knowledge of pollution monitoring and control methods, and vehicle emissions);

The AQDMP must also include details of automatic continuous PM10 monitoring which should be carried out on site. Baseline monitoring must commence at least three months before the commencement of the enabling works. If baseline monitoring can not begin during this time frame, PM10 data for this 3 month advance period from monitors already in place at the site may be submitted, subject to approval of details (monitor locations and specifications) by the LPA. Monitors must then be installed on-site at locations indicative of exposure of sensitive receptors to dust emitted from works from commencement of phase 1 and should continue throughout all construction phases. Details of: o the equipment to be used o its exact positioning o trigger levels above which construction works must stop until the source of emissions can be identified o additional mitigation to be employed during high pollution episodes must be included and approved by the council prior to use. If proposed trigger level is above 190 µg/m3 this must be justified and approved by the LPA. A monthly summary report of continuous monitoring data should be provided to the council for the duration of the development, and monitoring data should be available for download by the local authority on request at any time. Reports of exceedances of trigger levels with details of the source of exceedances, mitigation measures applied and future preventative measures to be taken should be submitted to the local authority by the next working day.

No demolition or development shall commence until all necessary pre-commencement measures described in the AQDMP have been put in place and set out on site. The demolition and development shall thereafter be carried out and monitored in accordance with the details and measures approved in the AQDMP.

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Reason: Development must not commence before this condition is discharged to manage and mitigate the impact of the development on the air quality and dust emissions in the area and London as a whole, and to avoid irreversible and unacceptable damage to the environment (London Plan (2021) Policy SI 1, and the London Plan SPGs for Sustainable Design and Construction and Control of Dust and Emissions during Construction and Demolition).

Environmental Noise and Vibration

6. Prior to commencement of the development hereby permitted, a scheme of noise and vibration attenuation and ventilation sufficient to prevent overheating and maintain thermal comfort shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall achieve the habitable room standards as detailed in BS8233:2014 and must include details of post construction validation. Thereafter the development shall be carried out in accordance with the approved details and a separate validation report shall be submitted to and approved in writing by the Local Planning Authority within 3 months of first occupation. All work must be carried out by a suitably qualified person and the approved noise, vibration attenuation and ventilation measures shall thereafter be retained and maintained in working order for the lifetime of the development in accordance with the approved details.

Reason: To protect the amenities of future residential occupiers (Policy Q2 of the Lambeth Local Plan (2015)).

Energy Statement

7. Prior to the commencement of the development hereby permitted, Energy Statement details shall be submitted to and approved in writing by the Local Planning Authority which confirms the residential and non-residential on-site reductions over Part L 2013 baseline achieved through energy efficiency measures (Be Lean), based on the Energy Hierarchy in the GLA’s Energy Assessment Guidance (2018). This shall include a feasibility study for water heat recovery and a green lease agreement details. Where the reduction of 10 per cent for residential spaces and 15 per cent reduction for non- residential spaces cannot be met, justification should be provided. The Energy Statement shall demonstrate that the development will achieve a reduction in carbon emissions of 35 per cent over that required by Part L of the Building Regulations 2013 and include the calculations for carbon offset payment, using the carbon price of £95 per tonne for 30 years

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions (Policy S12 of the London Plan (2021) and Policy EN3 of the Lambeth Local Plan (2015)).

Water Infrastructure

8. No construction shall take place within 5m of the water main. Prior to commencement of the development hereby approved, information detailing how the developer intends to divert the asset / align the development, so as to prevent the potential for damage to subsurface potable water infrastructure, must be submitted to and approved in writing by the local planning authority in consultation with Thames Water. Any construction must be undertaken in accordance with the terms of the approved information. Unrestricted access must be available at all times for the maintenance and repair of the asset during and after the construction works.

Reason: The proposed works will be in close proximity to underground strategic water main, utility infrastructure. The works has the potential to impact on local underground water utility infrastructure (Policy SI 4 of the London Plan (2021))

Flood emergency and evacuation

9. No development shall commence until the applicant has submitted to and had approved in writing by the Local Planning Authority a Flood Warning and Evacuation Plan (FEP). This Plan shall include the following information:

During Construction Process

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- command & control (decision making process and communications to ensure activation of FEP); - training and exercising of personnel on site (H& S records of to whom and when); - flood warning procedures (in terms of receipt and transmission of information and to whom); - site evacuation procedures and routes; and, - provision for identified safe refuges (who goes there and resources to sustain them).

During Occupation of Development - occupant awareness of the likely frequency and duration of flood events; - safe access to and from the development; - subscription details to Environment Agency flood warning system, 'Flood Warning Direct'.

The flood evacuation plan shall be implemented during the use of the development hereby approved and maintained in operation for the lifetime of the development.

Reason: In order to mitigate the impact of a flood event on users of the development (Policy SI 12 of the London Plan (2021)) and EN5 of Lambeth Local Plan Policy (2015)).

Design and Appearance

Detailed drawings

10. Notwithstanding any indication on the drawings hereby approved, prior to commencement of the development beyond the superstructure of the development hereby permitted drawings showing all external construction detailing of all relevant building/block has been submitted to and approved by the Local Planning Authority in writing.

The drawings shall include details of: a) the façade of the building including details of ground and first floor. b) main entrances (including service entrances) and how they will be named and numbered permanently including canopies c) balconies and terraces including balustrades d) boundary treatments e) soffits, screens, vents and copings f) roof treatments, cills and parapets including detailed design of plant and associated screening g) windows and doors (including technical details, elevations, reveal depths, plans and cross sections) h) commercial unit shopfront and security details i) building signage strategy and Legible London Signage k) mail boxes l) acoustic screens/barriers for external communal amenity terraces (where required) m) overlooking mitigation measures to relevant windows,

The details set out above shall be provided at 1:10 scale (including sections) or 1:20 elevational studies whichever is most suitable for the detail in question. The development shall not be carried out otherwise than in accordance with the details and drawings thus approved and shall thereafter be retained for the lifetime of the development.

Reason: To ensure that the external appearance of the building is satisfactory, does not detract from the character and visual amenity of the area and that the amenities of neighbouring occupiers are protected. (Policies Q2, Q5, Q6, Q7, Q8, Q15, Q17 and Q26 of the Lambeth Local Plan (2015) and Policies D4, D8 and D9 of the London Plan (2021)).

Materials

11. Notwithstanding any indication on the drawings hereby approved, prior to commencement of the development beyond the superstructure of the development hereby permitted, the following details of all materials to be used in the external elevations of each block/building/public realm shall be provided to and approved in writing by the local planning authority:

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a. a technical specification schedule of the materials

b. a sample panel to be provided on site

c. a photographic record of the sample panels, taken on site at midday

The development shall not be carried out otherwise than in accordance with the samples thus approved.

Reason: To ensure that the external appearance of the building is satisfactory, does not detract from the character and visual amenity of the area (Policies Q2, Q5, Q6, Q7, Q8, Q15, Q17 and Q26 of the Lambeth Local Plan (2015) and Policies D4, D8 and D9 of the London Plan (2021)).

Plumbing

12. No vents, plumbing or pipes, other than those approved, shall be fixed to the external faces of any building for the lifetime of the development unless otherwise agreed in writing by the local planning authority.

Reason: To ensure an appropriate standard of design (Policies Q6, Q8 and Q26 of the Lambeth Local Plan 2015).

Adaptable and adapted housing

13. Units annotated as ‘WCH’ on the hereby approved plans shall be constructed to comply with Part M4 (3) of the Building Regulations. Any communal areas and accesses serving the M4 (3) compliant Wheelchair User Dwellings should also comply with Part M4 (3). All other residential units, communal areas and accesses hereby permitted shall be constructed to comply with Part M4 (2) of the Building Regulations.

Reason: To secure appropriate access for disabled people, older people and others with mobility constraints (Policy D7 of the London Plan (2021) and Q1 of the London Borough of Lambeth Local Plan (2015) and the guidance in the London Plan Housing SPG (2012)).

Landscaping and playspace

Playspace

14. Notwithstanding details shown on the approved plans, no occupation of the residential parts of the development shall commence until full details of the children's play space provisions (including layout, equipment specification, and phasing of delivery) have been submitted to and approved in writing by the local planning authority and the development has been implemented in accordance with the approved details and agreed phasing. The children's play areas shall be maintained for the duration of the development and available for all occupiers irrespective of tenure.

Reason: To ensure appropriate provision for children's play on site. (Policy S4 of the London Plan (2021) and Policy H5 of the Lambeth Local Plan (2015)).

Landscaping details and Net Biodiversity Gain

15. Notwithstanding the details on the drawings and documents hereby approved, prior to commencement of the development beyond the superstructure of the development hereby permitted, a hard and soft landscaping scheme shall be submitted to and approved in writing by the local planning authority. All tree, shrub and hedge planting included within the above scheme shall accord with BS3936:1992, BS4043:1989 and BS4428:1989 (or subsequent superseding equivalent) and current Arboricultural best practice. The details shall demonstrate that net biodiversity has been achieved. The details shall include:

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a) The treatment of all parts of the site not covered by buildings including walls and boundary features b) The treatment of the communal residential podium/roof terraces c) The quantity, size, species, position and the proposed time of planting of all trees and shrubs to be planted including details of appropriate infrastructure to support long-term survival d) An indication of how all trees and shrubs will integrate with the proposal in the long term with regard to their mature size and anticipated routine maintenance and protection including irrigation systems e) Details of infrastructure to maximise rooting capacity and optimize rooting conditions; f) All shrubs and hedges to be planted that are intended to achieve a significant size and presence in the landscape shall be similarly specified; g) All hard landscaping including all ground surfaces, planters, seating, refuse disposal points, cycle parking facilities, bollards, vehicle crossovers/access points; h) Biodiversity mitigation and enhancement measures as set out in the herby approved Biodiversity Report

The development hereby permitted shall be thereafter carried out in accordance with the approved details within 6 months of the date of occupation of any part of the site unless an alternative temporary landscaping and phasing scheme has otherwise been submitted to and agreed by the Local Planning Authority. Reason: In order to introduce high quality landscaping in and around the site in the interests of the ecological value of the site and to ensure a satisfactory landscaping of the site in the interests of visual amenity and to ensure high quality of housing. (Policy EN1, Q2, Q6, Q9, Q10 and H5 of the Lambeth Local Plan ( 2015) and Policy G6 of the London Plan 2020)).

Landscaping – First Planting

16. All planting, seeding or turfing comprised in the approved landscaping scheme shall be carried out in the first planting and seeding season following the occupation of the development hereby permitted or the substantial completion of the development, whichever is the sooner. Any trees, hedgerows or shrubs forming part of the approved landscaping scheme which within a period of five years from the occupation or substantial completion of the development die, are removed or become seriously damaged or diseased shall be replaced in the next planting season with others of similar size and species, unless the Local Planning Authority gives written consent to any variation.

Reasons: In order to introduce high quality soft landscaping in and around the site in the interests of the ecological value of the site and to ensure a satisfactory landscaping of the site in the interests of visual amenity (Policy EN1, Q2, Q9 , Q10 and H5 of the Lambeth Local Plan (2015) and Policy G6 of the London Plan 2020)).

Environmental Management

SuDS Maintenance

17. No development shall be brought in to use/occupied until a management and maintenance plan of the sustainable drainage scheme for the site has been submitted to and approved by the Local Planning Authority. The plan must consider the management and maintenance for the lifetime of the development which shall include the arrangements made to secure the operation of the scheme. The approved plan shall be implemented in full in accordance with the agreed terms and conditions.

Reason: To manage the water environment of the development and mitigate the impact on flood risk, water quality, habitat and amenity value. (Policies EN5 and EN6 of the Lambeth Local Plan (2015) and Policy SI12 of the London Plan (2021)).

Piling method statement

18. No piling shall take place until a piling method statement (detailing the depth and type of piling to be undertaken and the methodology by which such piling will be carried out, including measures to prevent

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and minimise the potential for damage to subsurface water infrastructure, and the programme for the works) has been submitted to and approved in writing by the local planning authority in consultation with Thames Water. Any piling must be undertaken in accordance with the terms of the approved piling method statement.

Reason: To ensure that the development does not harm groundwater resources in line with the National Planning Policy Framework (NPPF) (Paragraph 170). The proposed works will be in close proximity to underground water utility infrastructure. Piling has the potential to impact on local underground water utility infrastructure. (Policy SI 5 of London Plan (2021)).

Transport & Highways . Delivery and Servicing Management Plan

19. The residential and commercial uses hereby permitted shall not commence until a servicing management plan for the relevant use has been submitted and approved in writing by the local planning authority in consultation with TfL. The uses hereby permitted shall thereafter be operated in accordance with the approved details. The submitted details must include the following:

a) estimated frequency of deliveries to the site for each use; b) frequency of other servicing vehicles such as refuse collections; c) dimensions of delivery and servicing vehicles; d) proposed loading and delivery locations; and e) a strategy to manage vehicles servicing the site.

Reason: To protect the amenities of adjoining occupiers and the surrounding area and to limit the effects of the increase in travel movements (Policy Q2 and T8 of the London Borough of Lambeth Local Plan (2015) and Policies T4 and T9 of the London Plan (2021)).

Waste management 20. The waste and recycling storage shown on the approved plans shall be provided prior to the commencement of the use hereby permitted, and shall thereafter be retained solely for its designated use. The uses hereby permitted shall thereafter be operated in accordance with the hereby approved Operational Waste and Recycling Management Strategy.

Reason: To ensure suitable provision for the occupiers of the development, to encourage the sustainable management of waste and to safeguard the visual amenities of the area (Policies Q2 and Q12 of the London Borough of Lambeth Local Plan (2015)).

Cycle Parking Details

21. Prior to commencement of the residential and commercial uses hereby permitted, full details of the short and long-term cycle parking provision for the relevant use shall be submitted to and approved in writing by the Local Planning Authority. The details shall include: - Floor plans and detailed construction drawings (where relevant) - Specification of cycle stands including manufacturer’s details - Details of lifts to accommodate non-standard cycles (unless it is has been demonstrated that it is not technically feasible) - Details of automatic doors - Phasing of delivery of short-term cycle parking (including temporary provision if relevant)

The long-term cycle parking shall thereafter be implemented in full in accordance with the approved details before the relevant use hereby permitted commences and shall thereafter be retained solely for its designated use. The short-term cycle parking shall thereafter be implemented in full in accordance with the approved details and the phasing plan and shall thereafter be retained solely for its designated use Reason: To ensure adequate cycle parking is available on site and to promote sustainable modes of transport (policies T1, T3 and Q13 of the London Borough of Lambeth Local Plan (2015) and Policy T5 of the London Plan (2021).

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Car Parking Management Plan

22. No part of the development hereby permitted shall be occupied until a Parking Management Plan for the development has been submitted to and approved in writing by the Local Planning Authority. This shall include details of: - the monitoring of demand for and implementation of additional disabled parking spaces, - details of how the proposed vehicular ramp will be managed, secured and operated to avoid vehicle conflict. - details of how the proposed car parking will be managed to avoid conflict with users of the cycle stores

The provision of car parking shall thereafter be managed solely in accordance with the approved details.

Reason: To prevent the parking areas becoming obstructed, to ensure that pedestrian and vehicular safety is not prejudiced and that sufficient Disabled parking spaces are provided (policies T1, T3, T6 and T7 of the London Borough of Lambeth Local Plan (2015) and Policy D7, T5 and T6 of the London Plan (2021)).

Travel Plan

23. The residential uses hereby permitted shall not commence until a Full Travel Pan for the residential use has been submitted and approved in writing by the local planning authority. The measures approved in the Full Travel Plan which are required to be implemented before occupation shall so be implemented prior to the residential use commencing and shall be so maintained for the duration of the use, unless the prior written approval of the Local Planning Authority is obtained to any variation. Reason: To ensure that the travel arrangements to the site are appropriate and to limit the effects of the increase in travel movements (Policy T1 and T4 of the London Plan (2021) and Policies T1 and T6 of the Lambeth Local Plan (2015)).

Electric Vehicle Charging Points 24. 100% of the vehicular parking spaces to be provided within the development hereby permitted shall be provided with electrical charging points for electric vehicles. Reason: To encourage the uptake of electric vehicles (Policy T6 and T6.1 of the London Plan (2021)).

Amenity

Environmental Noise and Vibration

25. All residential units shall achieve the LUL ground borne noise criteria of 35dBLAFMax in the centre of all habitable rooms and shall not exceed ground borne vibration criteria set out in BS6472 of VDVday 0.4ms-1.75 and VDVnight 0.2ms-1.75. A separate validation report shall be submitted to and approved in writing by the Local Planning Authority within 3 months of first occupation.

Reason: To protect the amenities of future residential occupiers (Policy Q2 of the Lambeth Local Plan (2015) and D14 of the London Plan (2021)).

Environmental Noise – Residential external amenity spaces

26. Prior to commencement of the development beyond the superstructure of the development hereby permitted, a scheme of measures to ensure that all residential units have access to amenity space within the development where noise levels do not exceed 55dB LAEQ(16 hour) shall be submitted to and approved in writing by the Local Planning Authority. This shall include the podium level external communal amenity areas (unless it has been demonstrated that it is not technically feasible or would have an unacceptable impact on the appearance of the

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building). The scheme shall include details of post construction validation. Thereafter the development shall be carried out in accordance with the approved details and a separate validation report shall be submitted to and approved in writing by the Local Planning Authority within 3 months of occupation.

Reason: To protect the amenities of future residential occupiers (Policy Q2 of the Lambeth Local Plan (2015) and D14 of the London Plan (2021)).

Noise Control & Management

27. Prior to commencement of the development beyond the superstructure of the development hereby permitted, a scheme of noise and vibration attenuation to the plant rooms and commercial areas shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall ensure noise breakout from the proposed plant rooms and commercial uses is properly controlled and as a minimum shall achieve NR25 in adjoining residential rooms. A post installation validation report confirming full installation of the approved scheme and demonstrating compliance with the standards approved shall be submitted by a suitably qualified person and approved in writing by the local planning authority. The approved noise and vibration attenuation measures shall thereafter be retained and maintained in working order for the lifetime of the development in accordance with the approved details.

Reason: To protect the amenities of future residential occupiers (Policy Q2 of the Lambeth Local Plan (2015) and D14 of the London Plan (2021)).

Flues and extraction plant

28. The uses hereby permitted shall not commence until details and full specifications of flues extraction and filtration equipment, and ongoing maintenance plan (including elevational drawings) have been submitted to and approved in writing by the local planning authority. The uses hereby permitted shall not commence until the approved details are fully implemented. The approved flues, extraction and filtration equipment shall thereafter be retained and maintained in working order for the duration of the use in accordance with the approved details.

Reason: To protect the amenities of future residential occupiers (Policy Q2 of the Lambeth Local Plan (2015) and D14 of the London Plan (2021)).

Noise and vibration attenuation of plant (to be submitted)

29. The uses hereby permitted, or the operation of any building services plant, shall not commence until an assessment of the acoustic impact arising from the operation of all internally and externally located plant has been submitted to and approved in writing by the local planning authority.

The assessment of the acoustic impact shall be undertaken in accordance with BS 4142: 2014 (or subsequent superseding equivalent) and current best practice and shall include a scheme of attenuation measures to ensure the rating level of noise emitted from the proposed building services plant is 5dB less than background.

The use hereby permitted, or the operation of any building services plant, shall not commence until a post-installation noise assessment has been carried out to confirm compliance with the noise criteria. The scheme shall be implemented in accordance with the approved details and attenuation measures, and they shall be permanently retained and maintained in working order for the duration of the use and their operation.

Reason: To protect the amenities of adjoining occupiers and the surrounding area (Policy Q2 of the Lambeth Local Plan (2015) and D14 of the London Plan (2021)).

Pedestrian wind microclimate

30. Any variation to the external envelope of the development shall be accompanied by a suitable Wind Microclimate Assessment which details any additional identified adverse wind microclimate impacts. Any additional steps required to mitigate these impacts shall be detailed and implemented, as

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necessary. The revised assessment shall be submitted to and approved by the Local Planning Authority and the details as approved shall thereafter be permanently retained.

Reason: To avoid unacceptable detriment of the amenities of future occupiers or of the area generally (Policy Q2 of the Lambeth Local Plan (2015) and Policy D9 of the London Plan (2021)).

Commercial Uses Management plan (to be submitted)

31. The A1-4 and D1 uses herby permitted shall not commence until a management plan has been submitted to and approved in writing for each use by the local planning authority. This should include but not be limited to, hours of operation, management responsibilities during all operating hours, measures to control noise from live and amplified music (including the screening of sporting events and public address systems). The use hereby permitted shall thereafter be operated in accordance with the approved details.

Reason: To protect the amenities of adjoining occupiers and the surrounding area (policy Q2 of the London Borough of Lambeth Local Plan (2015)).

External Lighting Scheme

32. Prior to occupation of each phase a lighting scheme for the relevant phase must be submitted for the approval of the Local Planning Authority in accordance with the Institute of Lighting Professional’s Guidance notes for the reduction of obstructive light and the design principles set out in the Exterior Lighting Strategy reference DAS CLL-NE7and dated 13thMarch 2020. The scheme must be designed by a suitably qualified person in accordance with the recommendations for environmental zoneE4in the ILP document “Guidance Notes for the Reduction of Obtrusive Light GN01:2020. Before commencement of operation of the approved lighting scheme the applicant shall appoint a suitably qualified member of the institute of lighting professionals (ILP) to validate that the lighting scheme as installed conforms to the recommendations for environmental zoneE4in the ILP document “Guidance Notes for the Reduction of Obtrusive Light GN01:2020

Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally (Policy Q2 of the Lambeth Local Plan (2015))

Sustainability and energy

Reduction in carbon emissions

33. Prior to first occupation of the development As Built SAP and SBEM calculations with a Block Compliance worksheet as an output of the National Calculation Method should be submitted to and approved in writing by the Local Planning Authority demonstrating that the development has achieved a 35% reduction in carbon emissions over that required by Part L of the Building Regulations 2013, in line with the approved Energy Statement.

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions (Policy SI 2 and SI 3 of the London Plan (2021) and Policy EN3 of the Lambeth Local Plan (2015)).

BREEAM – non residential (design stage)

34. Within six months of work starting onsite, a BREEAM Design Stage certificate and summary score sheet shall be submitted to and approved in writing by the Local Planning Authority demonstrating that a rating of ‘Excellent’ has been achieved (unless it is has been demonstrated that it is not technically feasible or viable to do so, in which case the development should demonstrate a ‘Very Good’ rating with a minimum score of 63 per cent).

Reason: To ensure that the development has an acceptable level of sustainability (Policy EN4 of the Lambeth Local Plan (2015) and Policy SI 2 of the London Plan (2021)).

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BREEAM – non residential (post occupation)

35. Within six months of first occupation, a BREEAM Post Construction certificate and summary score sheet should be submitted to and approved in writing by the Local Planning Authority demonstrating that a rating of ‘Excellent’ has been achieved (unless it is has been demonstrated that it is not technically feasible or viable to do so, in which case the development should demonstrate a ‘Very Good’ rating with a minimum score of 63 per cent).

Reason: To ensure that the development has an acceptable level of sustainability (Policy EN4 of the Lambeth Local Plan (2015) and Policy SI 2 of the London Plan (2021)).

Overheating and cooling – commercial

36. Prior to occupation of the non-residential spaces, an Overheating Analysis should be submitted to and approved in writing by the Local Planning Authority to demonstrate that: the non-domestic spaces have been analysed for overheating; that the cooling hierarchy has been followed and that reliance on cooling in has been reduced; that CIBSE TM49 has been considered; and that CIBSE TM52 compliance has been achieved. The mitigation measures shall thereafter be retained for the lifetime of the development. Evidence should demonstrate that the cooling hierarchy has been followed and the reliance on active cooling has been minimized.

Reason: To ensure the design of the development reduces (as far as is possible) the potential for overheating and reliance on air conditioning systems (Policy SI 2 and SI 4 of the London Plan (2021)).

Water efficiency

37. Prior to prior to commencement of the development beyond the superstructure of the development hereby permitted , manufacturers’ datasheets with a corresponding water efficiency calculator for the proposed fixtures and fittings shall be submitted to and approved in writing by the Local Planning Authority to demonstrate that the internal water consumption will not exceed 105 litres/person/day in line with The Water Efficiency Calculator for New Dwellings from the Department of Communities and Local Government.

Reason: Occupation must not commence prior to these details being discharged in order to ensure the development would achieve an acceptable standard of water efficiency (Policy SI 5 of the London Plan (2021)).

Water efficiency – post-occupation

38. Prior to first occupation of the development, manufacturers’ datasheets with a corresponding water efficiency calculator for the installed fixtures and fittings shall be submitted to and approved in writing by the Local Planning Authority to demonstrate that the internal water consumption will not exceed 105 litres/person/day in line with The Water Efficiency Calculator for new dwellings from the Department of Communities and Local Government. The scheme shall be carried out in accordance with the approved details and shall thereafter be retained for the lifetime of the development.

Reason: Occupation must not commence prior to these details being discharged in order to ensure the development would achieve an acceptable standard of water efficiency (Policy SI 5 of the London Plan (2021)).

Water efficiency – non residential 39. Prior to occupation of the non-domestic element of the development herby approved, evidence shall be submitted to and approved in writing by the Local Planning Authority demonstrating that the BREEAM Excellent Standard has been met for the Wat 01 category(12.5% improvement over the defined baseline. Evidence should include manufacturers datasheets and the BREEAM Wat 01 calculator tool.

Reason: Occupation must not commence prior to these details being discharged in order to ensure the development would achieve an acceptable standard of water efficiency (Policy SI 5 of the London Plan (2021)).

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Water network connection – Surface Water

40. There shall be no occupation beyond the 99th dwelling until , a Water Network Upgrade Confirmation Statement has be submitted to and approved in writing by the Local Planning Authority (in consultation with Thames Water), providing either:

a) all water network upgrades required to accommodate the additional flows to serve the development have been completed; or b) a development and infrastructure phasing plan has been agreed with Thames Water to allow additional development to be occupied.

Where a development and infrastructure phasing plan is agreed no occupation of those additional dwellings shall take place other than in accordance with the agreed development and infrastructure phasing plan.

Reason - The development may low / no water pressures and network reinforcement works are anticipated to be necessary to ensure that sufficient capacity is made available to accommodate additional demand anticipated from the new development. Any necessary reinforcement works will be necessary in order to avoid low / no water pressure issues. (Policy SI 5 of the London Plan (2021) and Policy EN6 (vii) of the Lambeth Local Plan (2015)).

Green Roofs

41. Prior to commencement of the development beyond the superstructure of the development hereby permitted, a detailed specification of the green roofs shall be submitted to and approved in writing by the Local Planning Authority. The specification shall include details of the quantity, size, species, position and the proposed time of planting of all elements of the green roofs, together with details of their anticipated routine maintenance and protection. The green roofs shall be thereafter maintained in accordance with the approved details for the lifetime of the development, as per Lambeth Local Plan Policy EN4 and Draft London Plan Policy G1.

Reason: In order to promote biodiversity and rainwater attenuation on the site. (Policy G1, G5, SI 2 and SI 13 of the London Plan (2021) and Policy EN1, EN4, EN5, EN6 and Q9 of the Lambeth Local Plan (2015)).

Green roof maintenance

42. If within 5 years of the installation of the green roof any planting forming part of the green roof shall die, be removed, or become seriously damaged or diseased, then this planting shall be replaced in the next planting season with planting of a similar size and species.

Reason: To safeguard the visual amenities of the area and to ensure that the development has an acceptable level of sustainability and biodiversity and to mitigate the impact on flood risk (Policy G1, G5, SI 2 and SI 13 of the London Plan (2021) and Policy EN1, EN4, EN5, EN6 and Q9 of the Lambeth Local Plan (2015)).

Photovoltaic panels

43. Prior to the commencement of development beyond the superstructure, a scheme showing that the provision of photovoltaic panels has been maximised including the siting, size, number and design of the photovoltaic array including cross sections of the roof of each building showing the panels in-situ shall be submitted to and approved in writing by the Local Planning Authority. The development shall thereafter be completed in strict accordance with the approved details and permanently retained as such for the duration of use, unless otherwise agreed in writing by the local planning authority.

Reason: To safeguard the appearance of the completed development and to ensure that the development has an acceptable level of sustainability (Policy SI 2 of the London Plan (2021) and Policy Q2, Q7, Q8 and EN4 of the Lambeth Local Plan (2015)).

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Urban Greening Factor

44. Prior to first occupation of the dwellings hereby permitted, evidence shall be submitted to and approved in writing by the local planning authority to validate the measures at the as built stage to demonstrate that an Urban Greening Factor of 0.37 or more has been achieved.

Reason: To ensure that the urban greening factor has been achieved on site (Policy G5 and G6 of the London Plan (2021).

45. Whole Life Carbon Assessment

Within 3 months of first occupation of any of the residential units hereby approved, a post construction whole life carbon assessment shall be submitted to and approved in writing to the local planning authority confirming whether the total product stage (A1 – A5) target of 450kg CO2/m2 has been achieved (in line with approved whole life carbon assessment, Faithful & Gould, March 2020).

Reason: To ensure that the development reduces life-cycle emissions (Policy SI2 of the London Plan (2021).

Circular Economy Statement

46. Within 3 months of first occupation of any of the residential units hereby approved, a post construction statement shall be submitted to and approved in writing to the local planning authority. This shall include the quantification of measures and detail of how circular economy proposals have been achieved in line with approved statement (Atkins, March 2020) and including: - strategies to utilise at least 20% of the value of construction materials to be comprised of recycled and reused content (unless it is has been demonstrated that it is not technically feasible or viable to do so); and - strategies to meet the Mayor's 65% target for municipal waste recycling as part of the long-term operation of the development (unless it is has been demonstrated that it is not technically feasible or viable to do so); and - details of the likely destination of all waste streams and a confirmation that the destination landfill(s) has/ have the capacity to receive waste.

Reason: To ensure that the proposal promotes circular economy outcomes (Policy SI 7 of the London Plan (2021).

Control of uses

Removal of PD rights

47. Notwithstanding the provisions of the Town and Country Planning (General Permitted Development) Order 2015 (or any order revoking and re-enacting that Order with or without modification), the floorspace shown on the approved plans to be used as flexible commercial unit within Class A1, A2, A3, A4 and D1 (the Pavilion Building) shall be used as such and for no other purpose in Class A1, A2, A3, A4 and D1 of the Town and Country (Use Classes) Order 1987 or any provision equivalent to those Classes in any statutory instrument revoking and re- enacting that Order with or without modification.

Reason: To enable the LPA to retain control of the use and to ensure that introduction of other uses such as those falling within Use Class A5 or D1 are not introduced without further assessment (Policy ED6, ED7, S2 and T6 of the Lambeth Local Plan (2015)).

Residents Gym /Amenity Area (Ancillary to Residential)

48. The residents gym/ internal amenity areas shall be used only for purposes ancillary to the hereby approved residential use. The spaces shall at no time be occupied and or operated independently of the residential use including any purpose in Class D2 of the Schedule to the Town and Country Planning (Amendment) (England) Regulations 2020 or in any provision equivalent to that Class in any statutory instrument revoking and re-enacting that Order with or without modification.

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Reason: In order to ensure that the use remains ancillary to the C3 use and in the interest of amenity and protection of residential floorspace (Lambeth Local Plan (2015) Policies S2, Q2, H3 and H5).

Site management

49. Notwithstanding the provisions of the Town and Country Planning (General Permitted Development) (Amendment) (No.2) (England) Order 2008 (or any Order revoking or re- enacting that Order with or without modification), no aerials, antennae, satellite dishes or related telecommunications equipment shall be erected on any part of the development hereby permitted, without planning permission first being granted.

Reason: to ensure that the visual impact of telecommunication equipment upon the surrounding area can be considered. (Policies T10, Q6 and Q22 of the Lambeth Local Plan, (2015)).

Other

Fire Statement

50. The development hereby permitted shall be implemented in accordance with the terms and provisions of the Fire Statement by Hoare Lea prior to the first occupation of any part of the development.

Reason: In the interests of public safety (Policy D12 of the London Plan (2021)).

Secured by design – construction

51. Prior to commencement of the development beyond the superstructure of the development hereby permitted, an application for Secured by Design Certification shall be made for the development hereby approved.

Reason: To ensure that satisfactory attention is given to security and community safety (Policy GC6 of the London Plan (2021) and Policy Q3 of the Lambeth Local Plan (2015)).

Secured by design – certification

52. Prior to the first occupation of any part of the development, evidence of the development having achieved Secure by Design certification shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall thereafter be maintained in accordance with the measures required to achieve certification for the lifetime of the development. Reason: To ensure that satisfactory attention is given to security and community safety (Policy GC6 of the London Plan (2021) and Policy Q3 of the Lambeth Local Plan (2015)).

Counter Terrorism strategy

53. Notwithstanding the details of the application hereby approved, prior to commencement of the development beyond the superstructure of the development hereby permitted, a confidential Counter Terrorism Strategy shall be submitted to and approved in writing by the Local Planning Authority in consultation with the Metropolitan Police. The strategy should show how the development mitigates any terrorism risks including details of blast resistant measures and investigation of feasibility of a gated access to the UKPN switch rooms. The development shall be implemented and managed in accordance with the approved details.

Reason: To ensure that satisfactory attention is given to security and community safety (Policy GC6 of the London Plan (2021) and Policy Q3 of the Lambeth Local Plan (2015)).

Informatives:

1. This decision letter does not convey an approval or consent which may be required under any enactment, by-law, order or regulation, other than Section 57 of the Town and Country Planning Act 1990.

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2. You are advised that this consent is without prejudice to any rights which may be enjoyed by any tenants/occupiers of the premises.

3. Your attention is drawn to the provisions of the Building Regulations, and related legislation which must be complied with to the satisfaction of the Council's Building Control Officer.

4. Your attention is drawn to Sections 4 and 7 of the Chronically Sick and Disabled Persons Act 1970 and the Code of Practice for Access for the Disabled to Buildings (B.S. 5810:1979) regarding the provision of means of access, parking facilities and sanitary conveniences for the needs of persons visiting, using or employed at the building or premises who are disabled.

5. You are advised of the necessity to consult the Council's Streetcare team within the Public Protection Division with regard to the provision of refuse storage and collection facilities.

6. You are advised that this permission does not authorise the display of advertisements at the premises and separate consent may be required from the Local Planning Authority under the Town and Country Planning (Control of Advertisements) Regulations 1992.

7. As soon as building work starts on the development, you must contact the Street Naming and Numbering Officer if you need to do the following: 1. name a new street 2. name a new or existing building 3. apply new street numbers to a new or existing building This will ensure that any changes are agreed with Lambeth Council before use, in accordance with the London Buildings Acts (Amendment) Act 1939 and the Local Government Act 1985. Although it is not essential, we also advise you to contact the Street Naming and Numbering Officer before applying new names or numbers to internal flats or units. Contact details are listed below. Street Naming and Numbering Officer e-mail: [email protected] tel: 020 7926 2283 fax: 020 7926 9104

8. You are advised of the necessity to consult the Transport and Highways team within the Transport Division of the Directorate of Environmental Services, with regard to any alterations affecting the public footway.

9. You are advised of the necessity to consult the Council’s Highways team prior to the commencement of construction on 020 7926 9000 in order to obtain necessary approvals and licences prior to undertaking any works within the Public Highway including Scaffolding, Temporary/Permanent Crossovers, Oversailing/Undersailing of the Highway, Drainage/Sewer Connections, Hoarding, Excavations (including adjacent to the highway such as basements, etc), Temporary Full/Part Road Closures, Craneage Licences etc.

10 Infrastructure protection TfL:

The applicant is reminded about fulfilling their obligations to London Underground and Transport for London under the legal requirements between the applicant and Infrastructure Protection TfL.

11. Thames water

The applicant is advised to read Thames Water guide ‘working near our assets’ to ensure your workings will be in line with the necessary processes you need to follow if you’re considering working above or near our pipes or other structures. https://developers.thameswater.co.uk/Developing-a-large-site/Planning-your- development/Working-near-or-diverting-our-pipes Should you require further information please contact Thames Water. Email: [email protected].

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Thames Water – pilling condition Please read our guide ‘working near our assets’ to ensure your workings will be in line with the necessary processes you need to follow if you’re considering working above or near our pipes or other structures. https://developers.thameswater.co.uk/Developing-a-large-site/Planning-your-development/Working-near-or- diverting-our-pipes. Should you require further information please contact Thames Water. Email:[email protected]

The proposed development is located within 15m of Thames Waters underground assets, as such the development could cause the assets to fail if appropriate measures are not taken. Please read our guide ‘working near our assets’ to ensure your workings are in line with the necessary processes you need to follow if you’re considering working above or near our pipes or other structures. https://developers.thameswater.co.uk/Developing-a-large-site/Planning-your-development/Working-near-or- diverting-our-pipes. Should you require further information please contact Thames Water. Email: [email protected] The applicant is advised that their development boundary falls within a Source Protection Zone for groundwater abstraction. These zones may be at particular risk from polluting activities on or below the land surface. To prevent pollution, the Environment Agency and Thames Water (or other local water undertaker) will use a tiered, risk-based approach to regulate activities that may impact groundwater resources. The applicant is encouraged to read the Environment Agency’s approach to groundwater protection (available at https://www.gov.uk/government/publications/groundwater-protection- position-statements) and may wish to discuss the implication for their development with a suitably qualified environmental consultant.

12. Network Rail:

Due to the close proximity of the proposed works to Network Rail’s land and the operational railway, Network Rail requests (if they have not done so already) that the applicant / developer contacts Network Rail’s Asset Protection and Optimisation (ASPRO) team via [email protected] prior to works commencing. The ASPRO team will ensure the works can be completed without posing a risk to Network Rail’s infrastructure. The applicant / developer may be required to enter into an Asset Protection Agreement to get the required resource and expertise on-board to enable approval of detailed works. More information can also be obtained from our website https://www.networkrail.co.uk/running-the-railway/looking- after-the-railway/asset-protection-and-optimisation/. As well as contacting Network Rail’s ASPRO Team, the applicant / developer must also follow the attached Asset Protection informatives (compliance with the informatives does not remove the need to contact ASPRO).

Asset Protection Informatives for works in close proximity to Network Rail’s infrastructure

The developer must ensure that their proposal, both during construction and after completion does not: • • encroach onto Network Rail land • • affect the safety, operation or integrity of the company’s railway and its infrastructure • • undermine its support zone • • damage the company’s infrastructure • • place additional load on cuttings • • adversely affect any railway land or structure • • over-sail or encroach upon the air-space of any Network Rail land • • cause to obstruct or interfere with any works or proposed works or Network Rail development both now and in the future

Network Rail strongly recommends the developer complies with the following comments and requirements to maintain the safe operation of the railway and protect Network Rail’s infrastructure.

Future maintenance The applicant must ensure that any construction and subsequent maintenance can be carried out to any proposed buildings or structures without adversely affecting the safety of/or encroaching upon Network Rail’s adjacent land and air-space. Therefore, any buildings are required to be situated at least 2 metres (3m for overhead lines and third rail) from Network Rail’s boundary. This requirement will allow for the construction and future maintenance of a building without the need to access the operational railway environment. Any less than 2m (3m for overhead lines and third rail) and there is a strong possibility that the applicant (and any future resident) will need to utilise Network Rail land and air-space to facilitate works as well as adversely impact upon Network Rail’s maintenance teams’ ability to maintain our boundary

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fencing and boundary treatments. Access to Network Rail’s land may not always be granted and if granted may be subject to railway site safety requirements and special provisions with all associated railway costs charged to the applicant. As mentioned above, any works within Network Rail’s land would need approval from the Network Rail Asset Protection Engineer. This request should be submitted at least 20 weeks before any works are due to commence on site and the applicant is liable for all associated costs (e.g. all possession, site safety, asset protection presence costs). However, Network Rail is not required to grant permission for any third-party access to its land.

Plant & Materials All operations, including the use of cranes or other mechanical plant working adjacent to Network Rail’s property, must at all times be carried out in a “fail safe” manner such that in the event of mishandling, collapse or failure, no plant or materials are capable of falling within 3.0m of the boundary with Network Rail.

Drainage Storm/surface water must not be discharged onto Network Rail’s property or into Network Rail’s culverts or drains except by agreement with Network Rail. Suitable drainage or other works must be provided and maintained by the Developer to prevent surface water flows or run-off onto Network Rail’s property. Proper provision must be made to accept and continue drainage discharging from Network Rail’s property; full details to be submitted for approval to the Network Rail Asset Protection Engineer. Suitable foul drainage must be provided separate from Network Rail’s existing drainage. Soakaways, as a means of storm/surface water disposal must not be constructed within 20 metres of Network Rail’s boundary or at any point which could adversely affect the stability of Network Rail’s property. After the completion and occupation of the development, any new or exacerbated problems attributable to the new development shall be investigated and remedied at the applicants’ expense.

Scaffolding Any scaffold which is to be constructed within 10 metres of the railway boundary fence must be erected in such a manner that at no time will any poles over-sail the railway and protective netting around such scaffold must be installed. The applicant/applicant’s contractor must consider if they can undertake the works and associated scaffold/access for working at height within the footprint of their property boundary. Piling Where vibro-compaction/displacement piling plant is to be used in development, details of the use of such machinery and a method statement should be submitted for the approval of the Network Rail’s Asset Protection Engineer prior to the commencement of works and the works shall only be carried out in accordance with the approved method statement. Fencing In view of the nature of the development, it is essential that the developer provide (at their own expense) and thereafter maintain a substantial, trespass proof fence along the development side of the existing boundary fence, to a minimum height of 1.8 metres. The 1.8m fencing should be adjacent to the railway boundary and the developer/applicant should make provision for its future maintenance and renewal without encroachment upon Network Rail land. Network Rail’s existing fencing / wall must not be removed or damaged and at no point during or post construction should the foundations of the fencing or wall or any embankment therein, be damaged, undermined or compromised in any way. Any vegetation within Network Rail’s land boundary must not be disturbed. Any fencing installed by the applicant must not prevent Network Rail from maintaining its own fencing/boundary treatment. Lighting Any lighting associated with the development (including vehicle lights) must not interfere with the sighting of signalling apparatus and/or train drivers’ vision on approaching trains. The location and colour of lights must not give rise to the potential for confusion with the signalling arrangements on the railway. The developers should obtain Network Rail’s Asset Protection Engineer’s approval of their detailed proposals regarding lighting. Noise and Vibration The potential for any noise/vibration impacts caused by the proximity between the proposed development and any existing railway must be assessed in the context of the National Planning Policy Framework which hold relevant national guidance information. The current level of usage may be subject to change at any time without notification including increased frequency of trains, night time train running and heavy freight trains. Vehicle Incursion Where a proposal calls for hard standing area/parking of vehicles area near the boundary with the operational railway, Network Rail would recommend the installation of a highways approved vehicle incursion barrier or high kerbs to prevent vehicles accidentally driving or rolling onto the railway or damaging lineside fencing. Landscaping Any trees/shrubs to be planted adjacent to the railway boundary these shrubs should be positioned at a

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minimum distance greater than their predicted mature height from the boundary. Certain broad leaf deciduous species should not be planted adjacent to the railway boundary as the species will contribute to leaf fall which will have a detrimental effect on the safety and operation of the railway. Network Rail wish to be involved in the approval of any landscaping scheme adjacent to the railway. Any hedge planted adjacent to Network Rail’s boundary fencing for screening purposes should be so placed that when fully grown it does not damage the fencing or provide a means of scaling it. No hedge should prevent Network Rail from maintaining its boundary fencing. If required, Network Rail’s Asset Protection team are able to provide more details on which trees/shrubs are permitted within close proximity to the railway. Existing Rights The applicant must identify and comply with all existing rights on the land. Network Rail request all existing rights, covenants and easements are retained unless agreed otherwise with Network Rail. If you would like to discuss any of the above, please contact your local Network Rail’s Asset Protection team: Anglia: [email protected] Kent and Sussex: [email protected] Wessex: [email protected] To identify your route, please use the link: https://www.networkrail.co.uk/running-the-railway/our-routes

Notes to Applicants: In dealing with this application the Council has implemented the requirement in the National Planning Policy Framework (2019) to work with the applicant in a positive and proactive manner. The council has made available on its website the policies and guidance provided by Lambeth Local Plan (2015) and its supplementary planning documents. We also offer a full pre- application advice service in order to ensure that the applicant has every opportunity to submit an application that’s likely to be considered acceptable. Yours sincerely

Assistant Director Planning, Transport & Development Growth, Planning and Employment Directorate

Date printed: 4th March 2021

INFORMATION FOR APPLICANTS GRANTED PLANNING PERMISSION SUBJECT TO CONDITIONS, OR WHERE PERMISSION HAS BEEN REFUSED.

General Information

This permission is subject to due compliance with any local Acts, regulations, building by-laws and general statutory provisions in force in the area and nothing herein shall be regarded as dispensing with such compliance or be deemed to be a consent by the Council thereunder.

Your attention is drawn to the provisions of the Building Regulations 1985 and related legislation which must be complied with to the satisfaction of the Council’s Building Control Officer, PO Box 734, Winchester SO23 5DG.

The Council’s permission does not modify or affect any personal or restrictive covenants, easements, etc., applying to or affecting the land or the rights of any person entitled to the benefits thereof.

STATEMENT OF APPLICANT’S RIGHTS ARISING FROM THE REFUSAL OF PLANNING PERMISSION OR FROM THE GRANT OF PERMISSION SUBJECT TO CONDITIONS.

Appeals to the Secretary of State

If the applicant is aggrieved by the decision of the local planning authority to refuse permission or approval for the proposed development or to grant permission or approval subject to conditions, he may appeal to the Secretary of State in accordance with Section 78 of the Town and Country Planning Act 1990 within six months from the date of this notice. Appeals must be made on a form which is obtainable from The Planning Inspectorate, Room 3/13 Temple Quay House, 2 The Square, Temple Quay, Bristol BS1 6PN. Alternatively

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an Appeal form can be downloaded from their website at www.gov.uk/government/organisations/planning- inspectorate. The Secretary of State has power to allow longer period for the giving of a notice of appeal but he will not normally be prepared to exercise this power unless there are special circumstances which excuse the delay in giving notice of appeal. The Secretary of State is not required to entertain an appeal if it appears to him that permission for the proposed development could not have been granted by the local planning authority, or could not have been so granted otherwise than subject to the conditions imposed by them, having regard to the statutory requirements, to the provisions of the development order, and to any directions given under the order.

Purchase Notice

If permission to develop land is refused or granted subject to conditions, whether by the local planning authority or by the Secretary of State for the Environment, and the owner of the land claims that the land has become incapable of reasonably beneficial use in its existing state and cannot be rendered capable of reasonable beneficial use by the carrying out of any development which has been or would be permitted, he may serve on the London Borough of Lambeth a purchase notice requiring that Council to purchase his interest in the land in accordance with the provisions of Section 137 of the Town and Country Planning Act 1990.

Compensation

In certain circumstances, a claim may be made against the local planning authority for compensation, where permission is refused or granted subject to conditions by the Secretary of State for the Environment on appeal or on a reference of the application to him. The circumstances in which such compensation is payable are set out in Section 120 and related provision of the Town and Country Planning Act 1990.

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Appendix 2: List of consultees (statutory and other consultees)

Statutory

Commission For Architecture & The Built Environment Environment Agency Greater London Authority Historic England - Archaeology Historic England Highways Agency L.F.C.D Authority London Underground Infrastructure London Ecology Unit London Heliport London Borough of Wandsworth Natural England Network Rail Transport for London Network Thames Water

Internal

LBL Arboricultural LBL Building Control LBL Enterprise, Employment & Skills LBL Lead Local Flood Authority (Flooding/SUDS) LBL Conservation and Urban Design LBL Highways LBL Housing LBL Parks & Open Spaces LBL Planning Policy LBL Regeneration LBL Sustainability Team On Air Quality LBL Transport LBL Ward Councillors LBL Waste Services (Veolia) LBL Corporate Asset Strategy Regulatory Support Services (Consultant Environmental Health Advisors) Bioregional (Consultant Sustainability Advisors) Design Out Crime Officer (Metropolitan Police) Schroeders Begg (Daylight & Sunlight Advisors)

Other

Cleaver Square, Cleaver Street , Bowden St Cleaver Square Friends Of Kennington Park Friends Of Lambeth High Street Recreation Ground Friends of The Oval Friends Of Vauxhall Pleasure Gardens

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Heart Of Kennington Residents' Association Kennington Association Planning Forum Kennington Park Road Residents' Assocation Kennington Oval & Vauxhall Forum Kennington Park Estate Tenants Association Oval & Kennington Residents Association Oval Mansions Regents Bridge Gardens Ltd Tradescant Area Residents Association Vauxhall Church Leaders Vauxhall Neighbourhood Housing Forum Vauxhall One Bussiness Improvement District Vauxhall 5 Chair of the TRA Vauxhall St Peters Heritage Centre

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Appendix 3: List of relevant policies in London Plan, Lambeth Local Plan consultees (statutory and other consultees)

London Plan (2021)

• GG1 Building strong and inclusive communities • GG2 Making the best use of land • GG3 Creating a healthy city • GG4 Delivering the homes Londoners need • GG6 Increasing efficiency and resilience • SD1 Opportunity Areas • SD4 The Central Activities Zone (CAZ) • D1 London’s form, character and capacity for growth • D2 Infrastructure requirements for sustainable densities • D3 Optimising site capacity through the design-led approach • D4 Delivering good design • D5 Inclusive design • D6 Housing quality and standards • D7 Accessible housing • D8 Public realm • D9 Tall buildings • D10 Basement development • D11 Safety, security and resilience to emergency • D12 Fire safety • D13 Agent of Change • D14 Noise • H1 Increasing housing supply • H4 Delivering affordable housing • H5 Threshold approach to applications • H6 Affordable housing tenure • H7 Monitoring of affordable housing • H10 Housing size mix • H11 Build to Rent • S4 Play and informal recreation • HC1 Heritage conservation and growth • HC2 World Heritage Sites • HC3 Strategic and Local Views • HC4 London View Management Framework • G1 Green infrastructure • G5 Urban greening • G6 Biodiversity and access to nature • G7 Trees and woodlands • G8 Food growing • SI 1 Improving air quality • SI 2 Minimising greenhouse gas emissions • SI 3 Energy infrastructure

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• SI 4 Managing heat risk • SI 5 Water infrastructure • SI 6 Digital connectivity infrastructure • SI 7 Reducing waste and supporting the circular economy • SI 8 Waste capacity and net waste self-sufficiency • SI 12 Flood risk management • SI 13 Sustainable drainage • T1 Strategic approach to transport • T2 Healthy Streets • T3 Transport capacity, connectivity and safeguarding • T4 Assessing and mitigating transport impacts • T5 Cycling • T6 Car parking • T6.1 Residential parking • T7 Deliveries, servicing and construction • T9 Funding transport infrastructure through planning • DF1 Delivery of the Plan and Planning Obligations

Regional Guidance

Relevant publications from the GLA include:

• Affordable Housing and Viability SPG (August 2017); • Housing SPG (March 2016); • Social Infrastructure (May 2015) • Accessible London: Achieving an Inclusive Environment (October 2014) • The control of dust and emissions during construction and demolition (July 2014) • Character and Context (June 2014) • Use of planning obligations in the funding of Crossrail, and the Mayoral Community Infrastructure Levy SPG (2013) • Shaping Neighbourhoods: Play and Informal Recreation SPG (Sep 2012) • London View Management Framework (March 2012) • London World Heritage sites (March 2012) • Planning for Equality and Diversity in London (2012) • London Cycle Design Guide (2014) • Practice note on the on threshold approach to affordable housing on public land (July 2018) • Energy Planning Guidance (2020) • Draft Be Seen Energy Monitoring guidance (2020) • Circular Economy Statements - consultation draft (October 2020) • Whole-life Carbon Assessments - consultation draft (October 2020)

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Lambeth Local Plan (2015) policies

Provided below is a list of the key Local Plan policies which are considered relevant in the determination of these applications:

• D2 Presumption in favour of sustainable development • D3 Infrastructure • D4 Planning obligations • H1 Maximising housing growth • H2 Delivering affordable housing • H4 Housing mix in new developments • H5 Housing standards • ED6 Town Centres • ED7 Evening economy and food and drink uses • ED14 Employment and training • S2 New or improved community premises • T1 Sustainable travel • T2 Walking • T3 Cycling • T4 Public transport infrastructure • T6 Assessing impacts of development on transport capacity • T7 Parking • T8 Servicing • EN1 Open space and biodiversity • EN2 Local food growing and production • EN3 Decentralised energy • EN4 Sustainable design and construction • EN5 Flood risk • EN6 Sustainable drainage systems and water management • EN7 Sustainable waste management • Q1 Inclusive environments • Q2 Amenity • Q3 Community safety • Q5 Local distinctiveness • Q6 Urban design: public realm • Q7 Urban design: new development • Q8 Design quality: construction detailing • Q9 Landscaping • Q10 Trees • Q12 Refuse/recycling storage • Q13 Cycle storage • Q15 Boundary treatments • Q16 shop fronts • Q18 Historic environment strategy • Q19 Westminster World Heritage site • Q20 Statutory listed buildings • Q22 Conservation areas

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• Q23 Undesignated heritage assets: local heritage list • Q25 Views • Q26 Tall and large buildings • PN2 Vauxhall

Draft Revised Lambeth Local Plan Proposed Submission Version (January 2020)

• D2 Presumption in favour of sustainable development • D3 Infrastructure • D4 Planning obligations • H1 Maximising housing growth • H2 Delivering affordable housing • H4 Housing size mix in new developments • H5 Housing standards • H12 Build to rent • ED7 Town Centres • ED8 Evening economy and food and drink uses • ED15 Employment and training • S2 New or improved social infrastructure • T1 Sustainable travel • T2 Walking • T3 Cycling • T4 Public transport infrastructure • T7 Parking • T8 Servicing • T10 Digital connectivity infrastructure • EN1 Open space, green infrastructure and biodiversity • EN3 Decentralised energy • EN2 Local food growing and production • EN4 Sustainable design and construction • EN5 Flood risk • EN6 Sustainable drainage systems and water management • EN7 Sustainable waste management • Q1 Inclusive environments • Q2 Amenity • Q3 Safety, crime prevention and counter terrorism • Q4 Public art • Q5 Local distinctiveness • Q6 Urban design: public realm • Q7 Urban design: new development • Q8 Design quality: construction detailing • Q9 Landscaping • Q10 Trees • Q12 Refuse and recycling • Q13 Cycle storage • Q15 Boundary treatments • Q16 Shop fronts • Q18 Historic environment strategy • Q19 Westminster World Heritage Site • Q20 Statutory listed buildings • Q22 Conservation areas • Q23 Non-designated heritage assets: local heritage list • Q25 Views • Q26 Tall and large buildings

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• PN2 Vauxhall

Local Guidance / Supplementary Planning Documents

Relevant local guidance and SPDs for Lambeth include:

• Development Viability SPD (2017) • Employment and Skills SPD (2018) • Waste Storage and Collection Requirements - Technical Specification (2013) • Air Quality Planning Guidance Notes • Vauxhall SPD (2013)

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Appendix 4: Other relevant Plans

Figure 1. The application boundary in the context of the aforementioned extant or implemented schemes and the ‘slot-in’ plan

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Figure 2 - Ground level implementation and ‘slot-in’ plan:

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Figure 3 Proposed northern elevation (left to right – Blocks C, B and A):

Figure 4 Northern elevation of the extant permission ref: 15/06216/FUL (left to right – Blocks C, B and A):

Page 121 Agenda Item 3

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ADDRESS: Clapham Common, London, SW4 Application Number: 21/00180/RG3 Case Officer: Jeni Cowan Ward: Clapham Common/Clapham Town Date Received: 18.01.2021 Proposal: Temporary use of Clapham Common for a range of events in 2021, involving installation and de-installation of temporary infrastructure including fencing, lighting, PA systems, Stages and other temporary structures, and other ancillary works. Applicant: EventLambeth Civic Centre, 3rd Floor, 6 Brixton Hill, Brixton, London SW2 1EG

RECOMMENDATION

1. Resolve to grant conditional planning permission.

2. Agree to delegate authority to the Director of Planning, Transport and Sustainability to finalise the recommended conditions as set out in this report, addendums and/or PAC minutes.

SITE DESIGNATIONS

Relevant site designations and constraints: Listed Buildings Within application site - Deep Tube Shelter and Surface Building (Grade II) [1385901] - Milestone on Common Opposite Junction with Victoria Rise (Grade II) [1080498]

Outside application site but located within the London Borough of Lambeth. - Church of Holy Trinity (Grade II*) - Clapham Common War Memorial (Grade II) - Ye Olde Windmill Public House (Grade II) Conservation Area CA1: Clapham Conservation Area Archaeological Priority Area Clapham (Reference: A9) Flood Zone Flood Zone 1 (low risk) Page 123

LAND USE DETAILS

Site area (ha): Approx. 35ha / 350,000sqm

LEGAL SERVICES CLEARANCE AUDIT TRAIL Consultation Name/Position Lambeth Date Sent Date Received Report Cleared department Susan Boucher Legal Services 31/03/2021 07/04/2021 07/04/2021

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EXECUTIVE SUMMARY

This application seeks full planning permission for the temporary change of use and enclosure of parts of Clapham Common for a schedule of events, as detailed within the Clapham Common Application Site Events Schedule 2021 submitted with this planning application and included in Appendix 3 of this report. This covers the year 2021, specifically between 8th May 2021 and 2nd October 2021, comprising a total of 12 events over 63 “event days” (59 calendar days).

The Council’s Events Strategy 2020-2025 is considered alongside the application, which gives the Council and local community greater control over the scale and management of events on Clapham Common while ensuring a sustainable benefit to parks and local communities. Although the Events Strategy does not form part of the assessment of this application, it is a means of managing the site. Bringing the events within the ambit of planning control enables them to be further managed, which is part of what the Events Strategy seeks to achieve.

Bringing a series of events on an area of public open space under planning control with the grant of planning permission would offer reassurance to event organisers, local residents and communities that any events authorised by Lambeth Council is lawful and subject to appropriate and proportionate planning controls. This application seeks to supplement the robust regulatory controls that exist to protect this key public amenity for the enjoyment of all residents and visitors to the Common.

Similar applications for the Common were approved by the Planning Applications Committee in 2017 (LBL ref.17/02093/RG3), 2018 (LBL ref. 18/00058/RG3), 2019 (LBL ref: 18/05422/RG3), and 2020 (LBL ref. 20/00056/RG3). Matters arising from previous committee meetings regarding those earlier applications have been taken into account and therefore have informed the proposed recommendation.

As in previous years, there will be continued cooperation between Wandsworth and Lambeth Councils and the events’ organisers. This cross-borough and collaborative working approach will continue to be employed to monitor the operation of music events and help resolve issues of concern, if raised during the operation of events.

Officers consider that the principle of the use of the Common for the proposed events is acceptable as there would be no harm to the openness of the Common, which is designated Metropolitan Open Land. In addition, the associated impacts in respect of transport, residential amenity, biodiversity and heritage matters have been fully considered and officers are of the view that the proposal complies with the relevant policies on these matters.

The report includes an assessment of all events that have been applied for within the planning application, however, due to the COVID-19 pandemic, it is expected that some events might be cancelled or postponed.

In conclusion, Officers consider that the development would comply with the development plan for the Borough. Officers are therefore recommending approval of the scheme, subject to conditions, in accordance with the presumption in favour of sustainable development conferred upon Local Planning Authorities by the National Planning Policy Framework.

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OFFICER REPORT

Reason for referral to PAC: The application is reported to the Planning Applications Committee in accordance with Section 1 of the Committee’s terms of reference:

(1) Applications, other than applications made under S73 or S96A of the Town and Country Planning Act 1990, which are recommended for approval where the development carried out on a site having an area of 1 hectare or more.

1 THE APPLICATION SITE

1.1.1 Clapham Common (the Common) is a large public open space, measuring approximately 81.9 hectares (811,899 sqm), situated on the borough’s western boundary, adjacent to the London Borough of Wandsworth. The extent of the Common is denoted by a blue line in Figure 1 below. The Common is designated as Metropolitan Open Land (MOL).

1.1.2 The Common was originally ‘Common Land’ for the parishes of Clapham and Battersea until it was converted into public open space via the Metropolitan Commons Act 1878.

Figure 1: Extent of the LB of Lambeth ownership of Clapham Common

1.1.3 The Common is broadly triangular in shape and includes large expanses of open green space, an all-weather games area, tennis courts, a bowling green, grass pitches, a historic bandstand, cafes, ecological areas, as well as two play areas dedicated to children and families. The Common is popular with a wide range of users including cyclists, dog walkers, runners and sports teams as well as those who come to simply enjoy this outdoor space.

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1.1.4 The eastern part of the Common is located within the London Borough of Lambeth (hereafter referred to as ‘the Lambeth Side’) and measures approximately 35 hectares (350,000 sqm). The remaining area to the west is located within the London Borough of Wandsworth (hereafter referred to as ‘the Wandsworth Side’). The Common has been wholly managed and maintained by Lambeth Council since 1972. The borough boundary runs vertically and centrally through the Common, as shown in Figure 2 below.

1.1.5 Figure 2 shows the extent of the application site, outlined in red, with two parcels of land that are excluded from the application site shown hatched in red. These parcels of land are excluded from the application site and do not form part of the development proposal. However, they have been taken into account when considering the proposal against development plan policies.

Figure 2: Extent of the application site (wholly within the LB Lambeth boundary)

1.1.6 The outer extent of the Common is bounded by several roads, including Clapham Common South Side to the east, Clapham Common North Side to the north, Nightingale Lane to the south, as well as roads running though the Common.

1.1.7 The London Borough of Lambeth is the local planning authority for the eastern part of the Common and the London Borough of Wandsworth is the local planning authority for the western part of the Common.

1.1.8 The application site has is located within the Clapham Conservation Area (CA1) and contains several statutory listed buildings or structures. The site is also designated as a Site of Borough Nature Conservation Importance (SINC) and an Archaeological Priority Area.

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2 REQUIREMENT FOR PLANNING CONSENT AND OTHER APPROVALS

2.1.1 The purpose of this Section is to explain: • Why planning permission is required to stage an event on Clapham Common, • What other approvals are required to hold an event on Clapham Common, • What the relationship is between these different types of assessment/approval processes.

2.1.2 This planning application has been submitted by the Council’s event management service (EventLambeth). Planning permission is sought for a diverse programme of temporary events to be held within the Lambeth Side of the Common, which is further expanded upon in Section 3 of this report. Similar applications for the Common were approved by the Planning Applications Committee in 2017 (LBL ref. 17/02093/RG3), 2018 (LBL ref. 18/00058/RG3), 2019 (LBL ref. 18/05422/RG3), and 2020 (LBL ref. 20/00056/RG3).

2.1 Why is planning permission required for an event on Clapham Common?

2.1.1 Planning legislation (The Town and Country (General Permitted Development) (England) Order (2015)) (GDPO) allows for the temporary use of land for any purpose for not more than 28 days in total in any calendar year (except for markets and motor racing). It also allows for the provision on the land any moveable structures to be used in conjunction with this permitted use.

2.1.2 It should be noted that the GDPO has been amended to allow for the temporary use of land for any purpose for an additional 28-day period until the 31st December 2021. This is in addition to the initial permitted 28 days, therefore allowing 56 days in total.

2.1.3 This legislation is generally used by event organisers for fairs, festivals and other temporary events, allowing for the siting of moveable structures in connection with the use (for example, portable toilets, tents, information booths).

2.1.4 Clapham Common has a long and varied history of events taking place on it and currently hosts approx. 30 events a year, ranging from large and major events like music festivals and the Moonwalk, as well as a wide range of small and medium events such as food festivals, fun runs and sports events. This exceeds the 28 day and 56 day permitted development limit under the GPDO and as such full planning permission is required under the Town and Country Planning Act (1990). Planning permission has been applied for and granted in respect of summer events on the Common since 2017.

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2.2 What other approvals are required to hold an event on Clapham Common?

EventLambeth Permit

2.2.1 The Council’s professional events team, EventLambeth, are involved with more than 200 public events that take place across the borough each year. These range from community events, charity events such as the Moonwalk for Breast Cancer and the Great Ormond St. Santa Dash to large commercial events such as SW4 and the Council run Annual Lambeth Country Show.

2.2.2 Any event in a Lambeth park, open space or street must be approved by EventLambeth before it takes place and will be issued with a tenancy permit. All events are subject to strict processes from the outset as outlined in the Council’s published guide to organising outdoor events in Lambeth, which is available on the Council’s planning website (Lambeth Events Policy 2020–2025).

2.2.3 This process includes four stages, which all event applicants must comply with in order to be granted approval to use Council land for an event. All event applications can be approved or rejected at any stage of the event.

• Stage 1 – Application and Technical Assessment

• Stage 2 –Ward Councillor and Community Engagement

• Stage 3 – Health and Safety Assessment

• Stage 4 – Final Checks and Permit Approval

2.2.4 All organisers of large events and some medium events are required to present to the Lambeth Safety Advisory Group (SAG) before a conditional agreement notice is given by EventLambeth. These meetings take place on a monthly basis. Further information on SAG is discussed in paragraph 2.2.8.

2.2.5 The COVID-19 Pandemic and the response to it has changed whether events are able to be held at all and, if so, how they need to be managed. EventLambeth continues to engage with colleagues in Public Health and the Safety Advisory Group (SAG) to ensure that any events that are allowed to take place are in line with the current guidance.

2.2.6 Lambeth Council adopted a new Events Strategy for 2020-2025 in September 2020, which seeks to set out a clear systematic approach to the management of outdoor events in Lambeth. In relation to COVID-19, the delivery of the events strategy is conditional upon Government guidelines enabling events to take place, especially those which are large scale which has been impacted the most by COVID-19 requirements. The new Events Strategy is based on the following principles:

• support the balanced use of parks for appropriate community, charity and commercial events and non-event uses; • to support local community organisations through training to hold events in their local park; • an appropriate fee or charge will be levied on the organiser for the use of the park. The fee will vary dependent on the location and type of event; • a percentage of the total fees will be ring-fenced as Park Investment Levy, of which 80 per cent is spent in the park or open space where the event was held, in consultation between the primary stakeholder group and the Parks service; Page 129

• recognised Parks Friends groups or Management Advisory Committees (MACs) will be able to hire the park free of charge for free to enter events that they apply for and manage themselves. • Council officers retain the ability to negotiate with event organisers on the fee for their event to secure bookings that are in line with Council policy; • Where event organisers enter a multi-year contract with the Council, there will be a requirement to produce an action plan to improve the event: management, delivery, sustainability, volunteering and accessibility over the life of that agreement, as well as the park itself.

Premises’ licensing

2.2.7 In addition to applying for an EventLambeth Permit, events that have licensable activities are subject to rigorous scrutiny from the Council’s licensing team whilst larger and high- risk events also come under the scrutiny of the Lambeth Events and SAG.

2.2.8 Membership of Lambeth SAG includes the following organisations who oversee public safety:

• London Borough of Lambeth o Highways o Licensing o Community Safety o Events o Emergency Planning o Parks o Noise Control o Health and Safety o Food Safety • Metropolitan Police Service • London Fire Brigade • London Ambulance Service • NHS England • Transport for London • Ad hoc members will be invited as and when necessary and will be invited through the SAG Chairperson.

2.2.9 Lambeth SAG will consider the event proposal in detail and the meeting gives key partners the chance to raise specific objections or concerns on the event proposed.

2.2.10 As part of the event licensing process, event organisers are required to submit for EventLambeth’s approval Event Site Management Plans (ESMP) which cover areas such as: organisation of events (event structure, boundaries of sites); crowd management; details of infrastructure and facilities; build and breakdown plans and noise management.

Approvals required to hold the proposed 2021 events

2.2.11 Table 1a below specifies, which types of approval are required to hold each of the 2021 events proposed as part of this planning application. Further details of these events are provided in Section 3 of this report:

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Approvals required to hold 2021 event 2021 event Planning EventLambeth Premises’ permission permit licensing Festival Republic X X X Outdoor Cinema X X X London to Brighton Do it for X X Charity Cancer Research Race for Life X X and Pretty Muddy Runthrough Clapham X X Common Street Child Spring Sprint X X Bandstand Beds Harvest X X Feast Colourscape Festival X X Trinity’s Family Walk and Run X X Day

Table 1a: Approvals required to hold the 2021 events

2.2.12 Two events under this application require Premises Licencing: Festival Republic and Outdoor Cinema. Festival Republic has applied for a licence, which is currently going through the application process. Outdoor Cinema has not applied for a licence but will require a licence to operate.

2.3 What is the relationship between a planning permission, EventLambeth permit and Premises’ licence?

2.3.1 The general approach in imposing planning controls is to avoid duplication where controls already exist by other means.

2.3.2 This approach is supported by Planning Practice Guidance (PPG) which states “When proposed developments could include activities that would be covered by the licensing regime, local planning authorities should consider whether the potential for adverse noise impacts will be addressed through licensing controls (including licence conditions). Local planning authorities should not however presume that licence conditions will provide for noise management in all instances and should liaise with the licensing authority” (PPG Paragraph: 006 Reference ID: 30-006-20190722).

2.3.3 Paragraph 55 of the NPPF states planning conditions should be kept to a minimum and should only be imposed where they are:

• Necessary; • Relevant to planning and to the development to be permitted; • Enforceable; • Precise and; • Reasonable in all other respects.

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2.3.4 Events on the Common already require the consent of the Council. EventLambeth, SAG, and Licensing all provide an existing framework of control over the events, with effective means of enforcement. Together with protection offered under the Environmental Protection legislation dealing with statutory nuisance, a robust enforcement mechanism already exists. These are considered the most efficient method of controlling the operational activity of the events and planning conditions beyond those that are proposed to address these issues would be duplication of control.

2.3.5 Large and major events require Event permits and often require premises licencing, to which conditions are attached if granted. These conditions include information required through an Event Site Management Plan (ESMP), stewarding, crowd management, for example. Temporary Event Notices (TENs) are assessed by the Met Police and Council Services, such as licencing and environmental health.

2.3.6 EventLambeth require ESMPs, which include detailed information of how the events are run. This process for large and major events has been a successful operation by EventLambeth, and therefore it is not considered necessary to duplicate controls already exercised by EventLambeth. Under the planning application approved last year (20/00056/RG3), a basic ESMP was submitted for Festival Republic, and a condition was added to ensure the submission and adherence to the full ESMP; this is recommended again (condition 17). Although the intention is to avoid duplication of controls, this is required via a planning condition to ensure the ESMP would not be contrary to the terms of the planning permission.

2.3.7 Table 1b below shows the various matters that are considered as part of an application for an event on Clapham Common and which of the Council’s teams are involved in their assessment and management. A full assessment of these matters is provided in section 7 of this report.

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Application type Matter considered as part of Planning EventLambeth Premises application permission Licensing Licensing Land use x Design and x Conservation Biodiversity and x x Landscaping Tree protection x x Ecological x x management (i.e grass damage) Noise management x x x Hours of operation x x x Signage and Way- x x finding Toilet provision x x Lighting x x Crowd x x x management Car Parking x Event access x x x Delivery and x x servicing Waste management x x Cycle parking x Sustainability and x x air quality Flood Risk and x drainage Public Safety/ x x x Security/ emergency planning Licensable activities x x (i.e. sale of alcohol) Table 1b: Matters considered as part of application

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3 SUMMARY OF THE PROPOSAL

3.1.1 Full planning permission is sought for the temporary change of use and installation and de- installation of temporary infrastructure including fencing, lighting, PA systems, Stages and other temporary structures, and other ancillary works where necessary/required to facilitate 12 events. The proposed events are detailed within the Clapham Common Application Site Events Schedule 2021 submitted with this planning application, included in Appendix 4 of this report.

3.1.2 Due to the COVID 19 pandemic, some events that would have formed part of the 2021 events calendar have been cancelled. Of the 14 events originally proposed in the application, two events (Runthrough Clapham Common planned for the 13/03/2021 and Spring Performance planned for 28/03/2021) have already been cancelled. It is likely that, of the remaining 12 events, other events may also be cancelled. However, the assessment of this application has been made on the basis that all the remaining 12 events may take place in accordance with the details set out in the applicant’s submission, as discussed in this report. Should the applicant wish to propose changes to the 12 events under consideration, such as altering the dates of any of those events, an application would be required, which would enable assessment of the proposed changes.

3.1.3 Of the proposed 12 events, 6 events are commercial events, 5 are charity events, and 1 would be a community event. There is a full description of the events in section 3.7 of this report. A full table of events (to which this application relates), is as below:

CATEGORY EVENT Duration (including NO. OF rigging and de- EVENT DAYS rigging days) Major (1) Festival Republic 9/8/21 – 6/9/21 29 days Medium (3) Outdoor Cinema 27/5/21 – 1/6/21 6 days London to Brighton Do it for Charity 19/9/21 1 days Cancer Research Race for Life and Pretty 1/10/21 – 2/10/21 2 days Muddy Small (8) Runthrough Clapham Common 8/5/21 1 day Street Child Spring Sprint 15/5/21 – 16/5/21 2 days Runthrough Clapham Common & Chase 16/6/21 1 day the Sun 5k & 10K Runthrough Clapham Common 21/7/21 1 day Runthrough Clapham Common 15/8/21 1 day Colourscape Festival 7/9/21 – 23/9/21 17 days Trinity’s Family Walk and Fun Day 12/9/21 1 day Bandstand Beds Harvest Feast 18/9/21 (TBC) 1 day

Table 2: Event summary for Lambeth

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3.1.4 Of the 12 events, 5 would be held exclusively in Lambeth, while the remaining 7 would be ‘cross boundary’ events that are held partly within the Lambeth side and partly within the Wandsworth side of the Common. This application relates solely to the 12 events taking place within the application site area, for which Lambeth is the local planning authority (that is, the area denoted by the red line in Figure 2 above). Details about events scheduled to take place exclusively on the Wandsworth side are provided in the wider event schedule to give a complete picture of events proposed for the Common. This is included within Appendix 5 of this report.

3.1.5 This year’s major event (“major event” meaning more than 20,000 attendees) will be operated by Festival Republic, in line with a strategy to reduce the number of events requiring individual build and break periods, and therefore reduce the time the event site is closed whilst maximising the income that could be generated from the site.

3.1.6 Furthermore, Part 4, Class B of the Town and Country Planning (General Permitted Development) (England) Order 2015 allows 56 event days to take place under permitted development. EventLambeth have confirmed that some events will be occurring under permitted development, such as George Irvin’s Annual Funfair and FriendsFest. Events for which the applicant relies on the exercise of permitted development rights are not within the scope of this application.

3.1.7 Whilst details of Winterville have been provided, in terms of when this event may take place, this event does not form part of this planning application as the event site for it this year is proposed to be on the Wandsworth side of Clapham Common. It is understood that the event organisers will seek planning permission for this event in due course from LB of Wandsworth.

3.2 Comparison of the number of event days in previous years

3.2.1 Similar applications for the Common were approved by the Planning Applications Committee in 2017, 2018, 2019, and 2020. The table below provides a comparison:

2017 Application ref. 17/02093/RG3 proposed a total of 37 events over 165 ‘event days’ or 146 ‘calendar days’ on the Lambeth side of the Common.

2018 Application ref. 18/00058/RG3 proposed a total of 24 events over 201 ‘event days’ or 169 ‘calendar days’ on the Lambeth side of the Common.

2019 Application ref. 18/05422/RG3 proposed a total of 19 events over 91 ‘event days’ or 89 ‘calendar days’ on the Lambeth side of the Common.

2020 Application ref. 20/00056/RG3 proposed a total of 12 events over 86 ‘event days’ or 82 ‘calendar days’ on the Lambeth side of the Common.

2021 This application originally proposed 14 events of which two have already been cancelled, leaving a total of 12 events over 63 ‘event days’ or 59 ‘calendar days’ on the Lambeth side of the Common.

Table 3: Summary comparison of event days proposed in context of previous approved applications. Page 135

3.3 Event Categories

3.3.1 A detailed events schedule has been submitted with the planning application, which provides details of all events granted permits by EventLambeth in the 2021 calendar year (see Appendix 4 submitted by the applicant – Clapham Common Application Site Events Schedule 2021). These temporary events are categorised as small, medium, large and major events, based on the number of attendees as defined in all EventLambeth reports and brochures. For the purposes of consistency, the same terminology has been adopted for this planning application submission as was used in the previous Planning Applications Committee reports (17/02093/RG3, 18/00058/RG3, 18/05422/RG3, and 20/0056/RG3). The categories are set out as follows:

CATEGORY NUMBER OF ATTENDEES

MAJOR Over 20,000 attendees

LARGE Up to but no more than 20,000 attendees

MEDIUM Up to but no more than 5,000 attendees

SMALL Up to but no more than 1,000 attendees

Table 4: Quantity of attendees for each event

3.4 Number of Event Days

3.4.1 The small and medium events generally only last a day, take up a small amount of space, require minimal infrastructure and attract a relatively small numbers of people in the context of the overall size of the Common. The impact of these events is relatively minor; this is elaborated upon in the assessment that follows.

3.4.2 Major events require more space and infrastructure and set-up and attract large crowds. These events are likely to have more of an impact on the Common, visitors, wildlife, the highway network and neighbouring residents and are the primary focus of this report.

3.4.3 The major events would also span multiple event days. For the purposes of this application, an “event day” is defined as any day where an event takes place on the Common, including days required for build (set-up) or de-rigging (removal) of associated infrastructure and enclosures. As such, each event commences when an organiser or operator arrives on site at the Common and starts to set up, through to when de-rigging is completed and the Common is clear of any of the event associated infrastructure or enclosures.

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3.4.4 The proposed Festival Republic Concert Series and Festival event is scheduled to be on- site for 29 event days from 9th August 2021 to 6th September 2021. The event would require a premises licence. The application submission states that it would be open to visiting members of the public between 20th and 30th August 2021, with 6 major event days and 1 large event day occurring over the last two weekends of August, which consist of the following 7 days: 20th – 22nd August and 27th – 30th August. Two community days would also occur in between the major events which are scheduled at the weekends (days where a free event would be organised).

Festival No. of Days Republic Onsite Concert Series and Festival 31 August - 6 Event 9 - 19 August 20 - 30 August September Build (set-up) 11 days 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Event operation 16 17 18 19 (public access) 11 days 20 21 22 De-rig 7 days 23 24 25 26 27 28 29 Total 29 days

Table 5: Event schedule showing total number of event days of the Festival Republic Concert Series and Festival Event

3.4.5 The submitted events schedule shows that 12 events over 63 ‘event days’ are proposed either solely on the Lambeth Side or as part of a cross-boundary event during the 2021 calendar year. This figure includes several small events for example, the Clapham Common Runthrough and the Colourscape Music Festival.

3.4.6 However, if an event day of a particular event would overlap with the event day of another, then for the purposes of this application, the days when events overlap will be treated as one single event day, even if more than one event is occurring on the Common on that day. The event schedule indicates that there would be 4 overlapping event days, on 15th August; 13th September; 18th September and; 19th September, which would amount to 59 ‘calendar days’, as opposed to 63 event days.

3.4.7 The proposed schedule involves the overlap of the major event (Festival Republic) with a small event (Runthough) on one of the set-up days of the major event and, overlaps of a small event (Colourscape Festival) with two other small events (Bandstand Bed Harvest Festival and Trinity’s Family Walk and Fun Day) and a medium event (London to Brighton Do It For Charity). The cumulative impacts of events are considered in the officer assessment.

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3.5 Number of Events to take place across Clapham Common

3.5.1 The wider events schedule (that is, events across Clapham Common, including the Wandsworth side, and events occurring under permitted development) indicates that there would be a total of 18 events held on the whole of Clapham Common, 5 of which would be solely on the Lambeth side, 8 events would cross the boundary between Lambeth and Wandsworth and 5 events would be solely within Wandsworth.

3.5.2 The Ice Rink event is scheduled to occur on the Lambeth side of the Common, but is not included as part of this application. Furthermore, events which take place in Wandsworth do not form part of this planning application. These have been included for information purposes only. A full breakdown based on event categories is shown in Table 6 below:

CATEGORY LAMBETH CROSS WANDSWORTH TOTAL ONLY BOUNDARY ONLY Major 1 1 Large 0 Medium 1 2 2 5 Small 3 6 3 12 TOTAL 5 8 5 18

Table 6: Number of events based on category (capacity)

3.5.3 Table 5 provides a schedule of the major event, which is scheduled between 9th August 2021 and 6th September 2021.

3.5.4 Figure 3 shows the location of the major event site. This site area is located on the north- east side of the Common and is indicated by a purple boundary. The hatched purple line shows an extended site area for the major event (Festival Republic).

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Figure 3: Major event location

3.5.5 The scheduled events solely on the Wandsworth side are detailed in Table 7 below. Whilst these events do not form part of the application submission, they are provided in order to inform consideration of the cumulative impact of the event schedule on the wider Common.

CATEGORY EVENT Duration (including NO. OF EVENT building days) DAYS Major (0) 0 Large (0) 0 Medium (2) Circus Extreme (800 daily 8/10/21 – 24/10/21 17 days attendees) Winterville 2021 (3,000 daily 28/10/21 – 6/1/22 72 days attendees) Small (3) Friendsfest (500 daily attendees) 20/6/21 – 14/7/21 25 days Halloween Fair 27/9/21 – 9/11/21 44 days George Irvin’s Festival Funfair (450 11/12/21 – 4/1/22 25 days daily attendees)

Table 7: Schedule of events on the Wandsworth Side

3.6 Installation of Temporary Structures

3.6.1 The proposal seeks permission for the erection of temporary structures, including site enclosure fencing, stages, marquees, tents and stalls for temporary periods. The largest of these structures would be located on the ‘Events Field’ which the Council’s Parks and Open Spaces team have stated already receives regular use for large scale commercial events. This is shown in Figure 3 above.

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3.6.2 The ‘Events Fields’ is situated between Long Road to its northern boundary, Rookery Road to its north-eastern boundary and Long Pond and the Windmill public house, which is Grade II listed, to its south-eastern boundary. The organisers of large and major events are required to fence off areas of the Common to keep park users clear of construction activity necessary for site set-up and dismantling and to better manage space, people and, for security and reasons. The perimeter fencing would comprise of transparent ‘Heras’ fencing, which is generally 2 metres high and solid metal fencing, dark green in colour.

3.6.3 The largest structures of the proposal, with respect to scale, form and massing, would be associated with the major events. Festival Republic would include a main stage and several smaller stages. It is likely to have the same set up as SW4 2019, therefore an image of the main stage from the SW4 2019 event is shown as an example in Figure 4 below. The main stage height is approximately 15m, with a big top height of 24m, and the perimeter steel-shield would be 3.4m.

3.6.4 Details of access arrangements, waste management, delivery/servicing are provided within the Transport section of this report.

Figure 4: Photo of main stage of SW4 2019

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3.7 Description of Events in 2021 application

Major Event

Festival Republic: Festival Republic is the only major event and has a total of 29 days (including rigging and de-rigging) allocated, however this would not be a continuous event. It would consist of two weekends of music events over 6 event days, rather than a condensed period of events across two weeks, as demonstrated in table 5 and explained in paragraph 3.4.4. The equipment would be erected on 9 August, then the event would finish on the August Bank Holiday weekend (30 August), with the equipment removed by 6 September.

3.7.1 The proposed 6 major event days, when concerts would take place include the following days: Saturday 21 August – Sunday 22 August, and Friday 27 August – Monday 30 August. Between 23 August and 26 August, when the equipment is still in place, this cordoned off area will have two community days.

Medium Events

3.7.2 There are three medium events proposed; Outdoor (Luna) Cinema, London to Brighton Do It For Charity, and Cancer Research Race For Life and Pretty Muddy.

3.7.3 Outdoor (Luna) Cinema: this event consists of an outdoor cinema in the main events site. The equipment would be set up on 27 May and the event would take place on 31 May. The equipment would be removed on 1st June, lasting for a total of 6 days. It would have up to (and no more than) 5,000 participants total, and it is expected to receive 1,000 attendees daily.

3.7.4 London to Brighton Do It For Charity: this event consists of a bike ride starting at Clapham Common. The equipment would be set up on 19th September and the event would last one day, with the equipment removed the same day. It is expected to have 4,000 participants. It would take place in the southern section of Clapham Common, mostly on the Wandsworth side, but overlapping onto the Lambeth side of the Common.

3.7.5 Cancer Research Race for Life and Pretty Muddy: this event would take place mainly on the funfair site and redgra, on the Wandsworth side of the Common, however there will be obstacles set up around the Common. It would also have up to (and no more than) 5,000 participants, with 3,000 attendees expected a day. The event set-up would begin on 1st October and the event would take place on 2nd October, with equipment de-rigging taking place on 2nd October. This event consists of a run through the Common through an obstacle course.

Small Events

3.7.6 Runthrough Clapham Common and Chase the Sun: Five events taking place will be running events, which will take place for one day only (including rigging and de-rigging). They will take place on the funfair site, with some structures setup around the Common to aid the runners. The events will occur on 8 May, 16 June, 21 July, and 15 August.

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3.7.7 Street Child Spring Sprint: This small event is a new charity event for 2021. The rigging will begin on 15 May, and the event will take place on 16 May, with de-rigging happening the same day. It will be located on the Funfair site, with small infrastructure setup across the Common to help the runners.

3.7.8 Bandstand Beds Harvest Feast: This small event will be the Bandstand Beds Harvest Feast; this will take place on 18 September (no additional rigging and de-rigging days). The bandstand is located on the Wandsworth side of the Common however, it is close to the boundary with Lambeth so there is likely to be an overlap. This is a community event.

3.7.9 Colourscape Festival: The event is the Colourscape Festival, which consists of colourful tunnels around the Common with music events. Equipment setup will commence on 7 September, with the event starting on 11 September. The event would continue until 19 September with de-rigging completed by 23 September; lasting for an overall total of 17 days. It is likely that this event will not take place on the Common because another site has been identified for the event at a earlier date. There is a contingency plan in place should the event take place on the Common in the event that there is bad weather. This event overlaps with London to Brighton Do It For Charity bike ride, the Bandstand Beds Harvest Feast, and Trinity’s Family Walk and Fun Day.

4 RELEVANT PLANNING HISTORY

4.1.1 This application follows on from four previously approved planning applications (ref. 17/02093/RG3, ref. 18/00058/RG3, ref. 18/05422/RG3, and ref. 20/006/RG3) for events on Clapham Common for 2017, 2018, 2019, and 2020 respectively.

4.1.2 Application ref 17/02093/RG3 was approved on 04.07.2017 for the “Temporary use of parts of Clapham Common for a range of small, medium, large and major events in 2017, including installation and de-installation of temporary infrastructure including fencing, lighting, PA systems, stages, temporary structures and other ancillary works.”

4.1.3 Application ref: 17/02507/RG4 was approved on 17.10.2017 for the “Temporary installation and use of an area of Clapham Common for Winterville 2017 festival operational from 23/11/2017 to 01/01/2018, including an ice rink, cinema, indoor miniature golf, entertainment tents, fairground rides, catering and market stalls, production cabins, lighting, and other associated structures including perimeter fencing, vehicular servicing and temporary display of signage comprising graphic/artistic displays and way finding signs.”

4.1.4 Application ref: 17/02508/ADV was approved on the 17.10.2017 for the “Temporary display of signage comprising graphic/artistic displays and way finding signs”.

4.1.5 Application ref. 18/02758/RG4 was approved on 09.10.2018 for the “Temporary installation and use of an area of Clapham Common for Winterville 2018 festival, operational from 15/11/2018 and 23/12/2018, including an ice rink, roller disco, cinema, indoor miniature golf, entertainment tents, fairground rides, catering and market stalls, production cabins, lighting, and other associated structures including perimeter fencing, vehicular servicing”. (Town Planning consent ref: 18/02758/RG4 and Advertisement Consent ref: 18/03753/ADV applications received).

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4.1.6 Application ref: 18/00058/RG3 was approved on 17.04.2018 for the “Temporary use of parts of Clapham Common for a range of events in 2018, including installation and de- installation of temporary infrastructure, including fencing, light, PA systems, stages, temporary structures and other ancillary works.”

4.1.7 Application ref: 18/05422/RG3 was approved on 23.04.2019 for the “Temporary use of parts of Clapham Common for a range of events in 2019, including installation and de- installation of temporary infrastructure including fencing, lighting, PA systems, stages, temporary structures and other ancillary works.”

4.1.8 Application ref: 18/05422/RG3 was approved on 23.04.2019 for the “Temporary use of parts of Clapham Common for a range of events in 2019, including installation and de- installation of temporary infrastructure including fencing, lighting, PA systems, stages, temporary structures and other ancillary works.” The Planning Applications Committee resolved to grant conditional planning permission, subject to the following additional informatives: • An informative to condition 9 requesting that where possible, delivery vehicles be consolidated and the use of electric vehicles be considered; • An informative suggesting that event organisers publicise details of cycle parking on ticket email confirmation and on the event websites; • An informative requesting that event attendees be asked why they did not travel by bicycle; • An informative to encourage the event organisers to continue working with Lambeth Cyclists.

The above points have been taken into account in this assessment and are discussed in the relevant sections of this report.

4.1.9 Application ref: 19/04694/DET was approved on 20.02.2020 for the “Approval of details pursuant to conditions 14 (transport monitoring report) and 15 (track pad details) of planning permission ref. 18/05422/RG3 (Temporary use of parts of Clapham Common for a range of small, medium, large and major events in 2019, including installation and de- installation of temporary infrastructure including fencing, lighting, PA systems, stages, temporary structures and other ancillary works.). Granted on 18.06.2019.”

4.1.10 Application ref: 20/00056/RG3 was approved on 12.05.2020 for the “Temporary use of parts of Clapham Common for a range of small, medium, large and major events in 2020, including installation and de-installation of temporary infrastructure including fencing, lighting, PA systems, stages, temporary structures and other ancillary works.” The Planning Applications Committee resolved to grant conditional planning permission.

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5 CONSULTATIONS

5.1 Statutory External Consultees

Environment Agency – 2 February 2021 No comment

Historic England – 2 February 2021 No comment

Natural England – 15 February 2021 No objection

Greater London Authority – 23 March 2021 No objection.

London Plan 2021 policies on Metropolitan Open Land, heritage and transport are relevant to this application. The application complies with these policies, for the following reasons:

• Principle of development: The installation of temporary structures for outdoor recreation use for a temporary period on Metropolitan Open Land constitutes appropriate development and is therefore acceptable in land use terms. Mitigation measures are proposed to ensure that the land is returned to its existing or a better condition. • Heritage: The proposed events site within Clapham Common would not harm nearby listed buildings or the Clapham Conservation Area owing to its siting within the Common and the temporary nature of the structures proposed. • Transport: There are no strategic transport concerns. TfL has representation on the Lambeth Events and Safety Advisory Group and will continue to liaise with the applicant with respect to events management.

The Mayor does not need to be consulted again on this application.

Transport for London – 18 March 2021 No objection subject to the following:

• It is important that vehicles do not stop on the cycle lane to drop-off or pick up passengers. TfL requests that this is better enforced during events.

• It is understood that cycle parking will be provided, this is welcomed.

• TfL would welcome the promotion of active and sustainable modes of transport for people attending the festival.

• It is understood that in the previous events, delivery vehicles which arrived early or missed their delivery slot were held on the funfair site, off street. This is supported.

• The applicant should note that TfL has a scheme to introduce a new signalised pedestrian crossing on the A205 The Avenue near the junction with the A24 Clapham Common.

• TfL welcomes the recommendation for the signage and wayfinding from public transport modes to the festival to be improved.

• The footway and carriageway on the A3 Long Road and the A24 Clapham Common South Side must not be blocked during the installation and removal of infrastructure. Temporary obstructions during the works must be kept to a minimum and should not Page 144

encroach on the clear space needed to provide safe passage for pedestrians or obstruct the flow of traffic on the A3 Long Road and the A24 Clapham Common South Side.

• All vehicles associated with the works must only park/ stop at permitted locations and within the time periods permitted by existing on-street restrictions.

• No skips or construction materials shall be kept on the footway or carriageway on the TLRN at any time. Should the applicant wish to install scaffolding or a hoarding on the footway whilst undertaking this work, separate licences may be required with TfL, please see, https://www.tfl.gov.uk/info-for/urban-planning-and-construction/highway- licences

Officer’s response: There is a double red line along most of the cycle highway on the A24; stopping at any time on the double red lines is not permitted and this is enforced by traffic wardens and civil enforcement officers. Officers brought this to the attention of TfL, who withdrew their objection to this, stating the current measures are sufficient. Condition 10 will address taxi-drop-off locations, signage and way-finding and cycle parking provision. Informatives 10 -14 are included to address the other comments.

5.2 Internal Consultees LBL Design and Conservation – 17 March 2021

Given that we are not being asked to comment on the majority of the events being held on the Wandsworth side of the common, it seems only two events will last longer than a week and are in line with previous years’ duration.

No objections to the events proposed by this planning application.

Officer’s response: Noted. This will be assessed within section 8.

LBL Transport – 15 February 2021

As a result of review of data from last year events, it was requested that the mini-cab and taxi management strategy is revised to incorporate the recommendations submitted in the applicant’s Transport Monitoring Report.

No objections subject to conditions relating to: a revised signage strategy (condition 10); reversing restrictions (condition 8); delivery restrictions (condition 9); use of track pads (condition 15); cycle parking (condition 10) and monitoring report of cycling (condition 14) and the submission of Event Site Management Plan (ESMP), Travel Plan and Delivery and Servicing Plan for all large and major events and the use of banksmen for servicing.

Officer’s response: The submission of Event Site Management Plan (ESMP), Travel Plan and Delivery and Servicing Plan for all large and major events and the use of banksmen for servicing will be secured as part of licensing application, as it has been done in previous years. However, a full ESMP for the major event, will be secured via condition 17, which will include details of Delivery and Servicing

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Parks and Open Spaces – 5 February 2021

We have no objections to this application with respect to biodiversity or public open space matters.

If any large and major events are proposed for other locations (areas outside the main events location) on Clapham Common that, as identified in the ecological impact assessment, are of higher ecological sensitivity and where the risks of adverse ecological harm are greater, then we would expect additional information and assessments to be undertaken and submitted to us for comment and approval before these can take place.

We would also expect there to be an appropriate ground protection and reinstatement strategy for any events in these ecologically sensitive locations which we would need to see and approve prior to the event being accepted and delivered.

Officer's response: A condition to secure a further Ecological Mitigation and Management Plan (EMMP) is recommended should any large and major event locations move to areas outside the main events location. This would ensure appropriate mitigation take place to limit potential ecological implications (Condition 13). Condition 1 will require the all events to be operated in accordance with the submitted information, including the ecological management and mitigation Plan. Condition 15 would secure the final details of track pads.

LBL Policy – 24 February 2021

No objection. The temporary use of open space for performance and creative work is supported by ED11 (d) of the Lambeth Local Plan. However, this is subject to compliance with other policy.

The site is protected as open space and MOL and it must be demonstrated that the temporary development does not harm the MOL. The impact on the openness of the MOL must be considered; regard should be had to the Planning Practice Guidance which states the courts have identified a number of matters, which may need to be taken into account in making this assessment. Although the policy has limited weight at this stage, regard should also be had to policy ED13e) of the DRLLP Proposed Submission Version which states open space will be expected to be returned to its previous use and improvements made to the quality of the open space.

Officer’s response: Noted. The assessment will include the impact of the openness of the MOL in terms of DRLLP policy and measures to ensure the protections of the open space are included.

Refuse and Waste (Veolia Waste Management) – 19 February 2021 No objection. Temporary waste arrangements will be made for each event nearer the time between the Parks team and the LBL waste contractor.

Officer's response: Events held on the Common are required to be accompanied by a waste management plan approved by Event Lambeth as part of the event applications process. Further details of waste management are provided within the report (paragraph 7.5.22-7.5.26).

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Bioregional – 17 February 2021

No objection. Noted that many of the sustainability requirements within Lambeth Local Plan Policies EN3 and EN4 and the London Plan 2021 should not apply due to temporary nature of the events. Recommended a condition to encourage event organisers to comply with the guidance set out in the "Lambeth Green Events Guide" document.

Officer's response: This is addressed in section 7.3. An informative rather than condition is recommended to address this (informative 7).

Regulatory Support Services [Noise Pollution] – 14 February 2021

The licensing of the proposed events is the principal mechanism for ensuring that potentially adverse impacts on the neighbourhood are appropriately controlled. All events are required to comply with the EventLambeth Guidance on the control of sound at out- door events (2016) and other measures to minimise disturbance to local residents and the wider locality.

It is considered that the major and large events have the greatest potential for causing off- site noise impacts due to their scale and duration. As with previous applications, it is recommended conditions are imposed to support the licensing of events involving music performances or other amplified sound.

Officer’s response: This is addressed in section 7.4. Condition 16 is included to ensure an additional (fourth) noise monitoring point is used.

Regulatory Support Services [Food and Health & Safety Team] – 5 February 2021 No objection

5.3 Other Consultees

Clapham Society – 18 February 2021

As in previous years, the Clapham Society objects to this 'blanket' approval process, which is designed solely to reduce the scrutiny that individual events receive. Large scale events on Clapham Common are hugely controversial and extremely impactful on the local environment and residents. Lambeth has a duty to ensure each event is properly assessed by the PAC through the planning process. Having observed the PAC consider this 'blanket' application in person in previous years, I can say that the quality of discussion and oversight was very poor with key issues simply not even discussed. If Lambeth wants local 'buy in' to its Events strategy it needs openness and transparency and, this planning application is the opposite of that. What does Lambeth have to hide? If efficiency is what is driving this 'blanket' approval, we propose a tiny increase in the levies charged to commercial event organisers to cover the costs (which we suspect are in reality de- minimus) of permitting proper event-by-event PAC scrutiny.

Officer’s response: The application includes details of each event, which allows for individual scrutiny and has included all events for 2021 to ensure the cumulative impacts can also be taken into account and highlighting where any further applications are proposed to be made.

Clapham Common Management Advisory Committee (CCMAC) No comments received.

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5.4 Adjoining owners/occupiers

5.4.1 A total of 7 (seven) site notices were displayed from 10 February 2021 and a further 5 (five) site notices were displayed from 21 March 2021. The application was advertised in the local paper on 3 February 2021. The formal consultation period ended 14 March 2021.

5.4.2 318 representations were received during the consultation period; 315 were in objection, 1 was in support, and 2 were neutral. A summary of the concerns raised is set out below:

Summary of objections Response Use of the Common: A maximum of 10% of the Common will be unavailable at any one time, as demonstrated on the site plan for Fencing off a section of the the major event; 90% of the Common would be Common for events means less available for use by the local community. space for local residents of Clapham Common.

This is following on from the closure of a section of the Common for the rejuvenation of the grass.

Amenity/Noise: It is considered that amenity impacts would be appropriately managed and mitigated. Please refer to Noise pollution, including lack of Section 7.4 for full assessment of the noise associated clarity on Festival Republic (the with the proposals. It is considered that sufficient major event). information has been submitted with the application to enable it to be determined in planning terms.

Anti-social behaviour As part of the licensing process, all events are required to submit information relating to security, health and safety. All large and major events are required to submit very detailed Security Plans which are reviewed by the Lambeth Event Safety Advisory Group (SAG). Membership of SAG includes the Metropolitan Police who will continue to engage with the event organiser regarding security measures as part of the licensing process. EventLambeth would continue to liaise with the Metropolitan Police during the operation of Events as per previous years through the SAG process. Please refer to Section 7.8 for a detailed discussion of crime mitigation measures including engagement with the Metropolitan police.

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Litter The control of waste management will be secured as part of the terms and conditions of a subsequent Event Lambeth permit to be issued to each separate event organiser.

These requirements are set out in a document titled: ‘Park Event terms and conditions for the hire of a Lambeth Park or other open Space for Events (2017)’. The Event Lambeth permit is issued in accordance with this documents, which secures certain requirements for the management of litter, bins, and recycling for events to be carried out within the borough’s parks and open spaces. These conditions require that each event organiser to be responsible for: 1. The provision of suitable refuse receptacles; 2. Litter picking on the event ingress and egress routes; 3. Additional picking in the local area, if required 4. The organising of litter picking, sweeping and collection services

Section 7 of the planning statement ‘Clapham Common Planning Application for Temporary Events 2021’ confirmsthat if additional street cleaning by the Council’s contractor is brought in for the events then this charge will be taken from the event organisers’ damage deposit to reimburse the Council. If residents report issues of litter the cleaning crews are sent to those locations. This is also secured via the terms and conditions of the Event Lambeth permit.

Excessive Duration/impact on The impact of the time periods associated with the open space: events is assessed in section 7.2 below.

Duration of events are excessive, when considering the rigging and re-rigging time.

Loss of access to open space Officers are of the view that the proposal is consistent with policies relating to the use of open space. This is discussed in further detail at section 7 of this report.

Impact on the aesthetics of the The proposed structures are temporary. It is considered Common, especially following the that there would be no harm to heritage assets, and rejuvenation of the grass in parts this is assessed in more detail in the Design and of the Common Conservation assessment at section 7.2.

The Council’s ecologist has raised no objection to the application. Officers have given full consideration to the Page 149

impact of events on biodiversity, please refer to section 7.3 of this report

Impact on the soft landscaping The Council’s ecologist has raised no objection to the application. Officers have given full consideration to the impact of events on biodiversity, please refer to section 7.3 of this report.

Transport: The Council’s Transport officer has raised no objection to this application and noted that monitoring data from Additional traffic previous years demonstrates the transport impacts to be within acceptable limits.

A full assessment of transport impacts is included in section 7.5 of this report.

Environment: The control of any damage to the common will be secured as part of the terms and conditions of a Impact on newly rejuvenated subsequent Event Lambeth permit to be issued to each grass separate event organiser.

A damage deposit is taken from all event organisers and this is held against any damage caused by the event. Where reinstatement is required following an event, this is agreed in consultation with the parks team who undertake the work. The event organiser pays for all the requisite reinstatement as part of the terms and conditions of the Event Lambeth permit to hold the event.

EventLambeth works with colleagues in the Parks team to look at works that can be done to prepare and maintain areas pre and post event season. This is discussed and agreed upon at the start of the year and is not linked to any event reinstatement requirements.

Landscape management, include a Grounds Management plan that contains information on how damage to the existing parkland will be prevented, is also required as part of the permit application.

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Impact on climate change The proposed development is for temporary installations and structures that will be in operation for approximately 29 days for Festival Republic. Therefore, due to the temporary nature of the application the sustainability requirements within LLP Policies EN3 and EN4 and the LP do not apply. This includes all of policy EN3 (the requirement to connect to a decentralised energy network where possible) and LP Policy SI 2 C (meeting a 35% reduction in carbon emissions).

Regarding LLP policy EN4 (sustainable design and construction), a BREEAM assessment will not be required due to the temporary nature of the development, neither would measures to address climate change adaptation be necessary.

The Sustainability officer has recommended a condition addressing the suggested ways to reduce the environmental impacts of events, as set out in the “Lambeth Green Events Guide”. As compliance with the essential requirements set out in this document form part of the event licencing process, a condition is not required as it would duplicate processes already in place. However, an informative is recommended to encourage meeting higher (‘desirable’) sustainability measures set out in the “Lambeth Green Events Guide” where possible.

Procedural/Consultations: Permission is sought for a limited number of events, which have been detailed above. Each event is ‘Blanket’ approval for a period of scrutinised within this application. The proposal twelve months reduces the comprises events within the Lambeth part of the amount of scrutiny of each event. Common between 13 March 2021 and 2 October 2021 only.

Consultation with/approval of the It is acknowledged that approvals under other Secretary of State required. legislation may be required but this is not a material planning consideration.

Lack of consultation The LPA has undertaken a full consultation in line with the Statement of Community Involvement, with letters sent to local dwellinghouses, site notices being displayed around the Common, and an advert of the application placed in the local press.

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Information missing from All documents submitted for this application have been application made available, with the exception of the plan for the stage set up for Festival Republic, which is confidential due to safety reasons.

Documents relating to this application have been made available from the start of the consultation process and remain publicly available to date.

Other Matters: Winterville is not included within this application and is only shown on the event schedule for reference of the Objections to Winterville event potential full calendar year of events.

The planning application is solely The public benefits associated with proposals are set for monetary gain/ out at paragraph 7.1.9 of this report commercialisation of the Common Conflict of interest between In line with the Town and Country Planning Act 1990 Lambeth as the LPA and as (Section 316) the application is to be determined by owner of the site. Lambeth Council in its capacity as the local planning authority. The application has been assessed against the relevant polices of the development plan in the same manner as any other application would be assessed. Legal right to fence off Common Assessment of the application is concerned only with land the planning merits of the proposed use of land, not with whether other consents may be required for the land to be used in the manner proposed. Impact on COVID-19 pandemic While there is no planning policy which deals with the impact of COVID-19, the applicant will be required to comply with general law. This is explained further in paragraph 7.8 – Crime Prevention, Visitor Management, and Public Safety. Furthermore, the applicant will be required to submit further details on the safety of visitors in this regard, which is secured via condition 18.

5.4.3 The comments submitted in support of the proposal are summarised as follows:

- Events bring visitors to Lambeth, benefiting the local community and businesses, as well as showcasing the borough’s arts, culture, music, diversity and charitable causes.

- Events provided revenue for the borough and supports local businesses.

- The levy generated to support the ongoing maintenance of the Common is welcome.

6 POLICIES

6.1.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material Page 152

considerations indicate otherwise. The development plan in Lambeth is the new London Plan (2021) (LP) and the Lambeth Local Plan (September 2015) (LLP). This application is also subject to the heritage statutory provisions as set out in the agenda pack and heritage analysis of the report.

6.1.2 Following the successful completion of the Examination process and formal consent to publish by the Secretary of State, on 2 March 2021 the Mayor of London formally published the new London Plan which now has full weight in planning decisions.

6.1.3 The LLP is currently under partial review to ensure it complies with amendments to the National Planning Policy Framework (NPPF) and the new London Plan. The Draft Revised Lambeth Local Plan (DRLLP) underwent public consultation under Regulation 19 of the Town and Country Planning (Local Plans) (England) Regulations 2012 between 31 January and 13 March 2020 and was submitted to the Secretary of State for examination on 22 May 2020. The examination hearing took place between the 27 October and 13 November 2020. The Inspector’s proposed main modifications will be made available for public consultation between 15 February and 29 March 2021. Those draft policies that are unaffected by proposed main modifications can be considered to have significant weight at this point, with moderate weight afforded to those policies that are subject to proposed main modifications.

6.1.4 The latest NPPF was published in 2018 and updated in 2019. This document sets out the Government’s planning policies for England including the presumption in favour of sustainable development and is a material consideration in the determination of all applications.

6.1.5 The current planning application has been considered against all relevant national, regional and local planning policies as well as any relevant guidance. A full list of relevant policies and guidance has been set out in Appendix 3 to this report.

7 ASSESSMENT

7.1 Land Use

7.1.1 Policy G3 of the LP (2021) relates to Metropolitan Open Land (MOL) and seeks to give the strongest protection of MOL from inappropriate development, giving the same level of protection as that proffered to the Green Belt. Appropriate development should be limited to small scale structures to support outdoor open space uses and minimise any adverse impact on the openness of MOL.

7.1.2 When considering an application involving MOL, reference to the ‘Green Belt’ needs to be read as reference to MOL. Paragraphs 133-147 of the National Planning Policy Framework (NPPF 2019) relate to protecting Green Belt land. It states within paragraph 133 that “the Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence”. Paragraph 144 further states that “When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt”. “Very special circumstances will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations”.

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7.1.3 Policy EN1 (Open space and biodiversity) of the LLP states that the Council will meet the requirements for open space by maintaining open spaces and their function. Development which would involve the loss of existing public or private open space will not be supported unless certain criteria is met. Paragraph 9.2 of explanatory text of this policy discusses MOL and refers to the criteria set out by LP Policy G3. Policy EN1 of the DRLLP reiterates this approach. While the DRLLP is emerging policy and would therefore have some weight, the adopted policy has full weight. .

7.1.4 Clapham Common is a large public open space bounded by main roads and mature trees. The Common has a long history and tradition of sports, recreation and cultural uses and, contains purpose-built structures such as the Bandstand to host events. Supporting text to Policy PN5 of the LLP at paragraph 11.50 recognises that the Common is:

“…an extremely popular community space and venue for formal and informal leisure and recreational activities. The Common’s sports facilities include football, rugby and lacrosse/hockey pitches, tennis and basketball courts, and a bowling green; all of which are used for local sports participation. It also hosts festivals and music events, some of which draw up to twenty thousand participants and spectators, with people coming across the capital and beyond.”

7.1.5 The use of the borough’s open spaces for cultural activities is supported by LLP Policy ED11(d) which states “Temporary use of vacant commercial premises, open space, and public realm for performance and creative work will be supported, subject to the nature of the proposed activity and the requirements of other policies.” As such, it is considered that the principle of the proposed temporary use of parts of the Common for events complies with Policy ED11.

7.1.6 As noted in LLP Policy ED11, the nature of the proposed activity must also be considered. A broad range of events is proposed within the application and those falling within the major and large category include a music festival, which would take place on the events site located in the northern part of the Common. The Clapham Common Application Sites Events Schedule 2021 outlines each event and its size/space taken up. This would involve the temporary closure of approximately 8ha of land, which is less than 10% of the Common. Whilst this is a large area of land, it is not considered to be significant in the context of the whole of the Common. Furthermore, the temporary enclosures associated with major event would be in place for relatively short periods of time: Festival Republic (29 days), with no large events proposed. The Festival Republic will have 6 days when actual events take place spread across 2 weekends, as opposed to a compressed 2-week programme.

7.1.7 No more than 10% of the Common would be enclosed by temporary fencing for use for events at any one time. Whilst the proposal includes several medium and small events, minimum infrastructure would be required for many of them, for example, a few tables (charity runs), which would not occupy more than a few square metres. Furthermore, whilst a large proportion of the proposed events would take place between March and October, the public would continue to have access to at least 90% of the Common at any one time, including the summer when the demand for public access is likely to be the greatest.

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7.1.8 Overall, given the relatively small area of MOL land that would be enclosed by temporary fencing at any one time and the temporary nature of the proposed uses and associated structures, officers consider that the proposals do not represent an inappropriate form of development within the MOL and, would preserve the openness of the Common. As such, the proposals are considered to comply with Policy EN1, ED11 and PN5 of the LLP (2015), EN1 of the DRLLP, and Policy G3 of the LP (2021).

7.1.9 Should Members conclude that the proposal would cause a degree of harm to the MOL, officers are of the opinion, (having regard to the fact that the strongest protection should be given to the MOL) that the benefits accruing from the proposed events would clearly outweigh any harm to the MOL. These benefits are outlined below:

Community: • EventLambeth has advised that, in line with the adopted Lambeth Events Strategy, part of the income from the events would be allocated to the parks service budget to administer and spend in consultation with local stakeholders. This includes grants allocated through the Community Events Fund and Training Programme, which recently provided financial support to events organised by local organisations such as Clapham Park Project, Friends of Clapham Common, Studio Voltaire and Bandstand Beds Association. • All events held on Clapham Common pay a Park Investment Levy (PIL). The PIL paid by event organisers is reinvested back into the Common by the LB Lambeth Parks team and used for material improvements. Some of this money also goes into a funding ‘pot’ for locations that cannot generate income independently – this is decided by the LBL Parks service. In recent years, PIL has been used to pay for the installation of footpaths around the Bandstand Beds, additional bins, storage containers, improvements to the water supply around the Event Site and replacing the perimeter fencing to prevent vehicle incursions onto the Common. • Due to the COVID-19 pandemic, the Park Infrastructure Levy (PIL) for 2020/2021 is forecasted to be £6,000. By comparison, the PIL from 2018/2019 was £128,474 and in 2019/2020 this was £60,258. The fall in expected PIL for 2019/2020 is largely due to Winterville festival not having taken place last year. It is forecasted that the PIL for 2021/2022 will be approximately £200,000 however, this depends on restrictions on leisure and sporting activity due to COVID-19. The increase in the forecast from 2020 onwards is related to the method of PIL calculation, which changed in 2020 and is now linked to the overall charges for the event received by the Council rather than number of attendees. These figures are outlined within the submitted document titled ‘Appendix 4 – New Contract for Clapham Common’.

Sports: • London to Brighton Do It For Charity event includes ‘grass root’ sporting events which allow for sports teams to partake in sports days on existing outlined pitches on the Common.

Economic: • The influx of attendees into the area would increase the potential users of nearby commercial operators within Clapham District Centre and Clapham South Local Centre. Policy PN5 of the LP and accompanying text in paragraph 11.48 recognises that leisure and hospitality play an important role in Clapham’s economy.

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Cultural: • The large number of events proposed including performance of acts and creative works would add to the cultural offer available to residents and is supported by Policy PN5 of the LLP which seeks to encourage provision for cultural, creative, visual and performing arts.

7.2 Design and Conservation

7.2.1 The beginning of the Agenda Pack contains a summary of the legislative and national policy context for the assessment of the impact of a development proposal on the historic environment and its heritage assets. This is in addition to Lambeth Local Plan and London Plan policies.

7.2.2 In considering the application of the legislative and policy requirements referred to above, the first step is for the decision-maker to consider each of the designated heritage assets (referred to hereafter simply as “heritage assets”) which would be affected by the proposed development in turn and assess whether the proposed development would result in any harm to the heritage asset.

7.2.3 The decision of the Court of Appeal in Barnwell Manor confirms that the assessment of the degree of harm to the heritage asset is a matter for the planning judgement of the decision-maker.

7.2.4 However, where the decision-maker concludes that there would be some harm to the heritage asset, in deciding whether that harm would be outweighed by the advantages of the proposed development (in the course of undertaking the analysis required by s.38(6) PCPA 2004) the decision-maker is not free to give the harm such weight as the decision- maker thinks appropriate. Rather, Barnwell Manor establishes that a finding of harm to a heritage asset is a consideration to which the decision-maker must give considerable importance and weight in carrying out the balancing exercise.

7.2.5 There is therefore a “strong presumption” against granting planning permission for development which would harm a heritage asset. In the Forge Field case the High Court explained that the presumption is a statutory one. It is not irrebuttable. It can be outweighed by material considerations powerful enough to do so. But a local planning authority can only properly strike the balance between harm to a heritage asset on the one hand and planning benefits on the other if it is conscious of the statutory presumption in favour of preservation and if it demonstrably applies that presumption to the proposal it is considering.

7.2.6 The case-law also establishes that even where the harm identified is less than substantial (i.e. falls within paragraph 196 of the NPPF), that harm must still be given considerable importance and weight.

7.2.7 Where more than one heritage asset would be harmed by the proposed development, the decision-maker also needs to ensure that when the balancing exercise in undertaken, the cumulative effect of those several harms to individual assets is properly considered. Considerable importance and weight must be attached to each of the harms identified and to their cumulative effect.

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7.2.8 What follows is an officer assessment of the extent of harm which would result from the proposed development to the nearby heritage assets; this includes Conservation Areas and neighbouring Listed Buildings.

Impact on heritage assets: Conservation Areas

7.2.9 Paragraph 196 of the NPPF 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 this instance, the designated heritage asset is the Clapham Conservation Area and the adjoining conservation area within the LB Wandsworth side of Clapham Common.

7.2.10 Policy Q22 of the LLP 2015 and DRLLP 2020 (Conservation areas) states that development proposals affecting conservation areas will only be permitted where they preserve or enhance its character and appearance, which is achieved by respecting and reinforcing the established, positive characteristics of the area, including building line, siting, design and overall form.

7.2.11 The application site is located within the Clapham Conservation Area (CA1). Figure 6 shows the extent of the Clapham Conservation Area. The Clapham Conservation Area is centred on Clapham Common which is levelled wide open space bounded by main roads and mature trees. The historic Clapham Village Old Town is included within the conservation area and has some of the oldest properties in Lambeth dating back to 1706. As the area began to develop in the late 1700s, properties were built away from the village on land overlooking the Common; an assortment of Georgian terraces, Victorian villas and mansion blocks survive today. The roads radiating from the Common, are an eclectic mix of development which characterise the development of the area, ranging from grand Crescents and Squares to more modest Georgian workers’ cottages. The Clapham Common Conservation Area is a wide, open space of Clapham Common with historic grand houses that front onto it. It is noted that the Wandsworth side of the Common is also designated as a Conservation Area.

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Figure 6: The extent of the Clapham Conservation Area, outlined in bold black.

7.2.12 The following map (figure 6a) show the conservation areas that incorporate the Common. There are also other Conservation Areas nearby in Lambeth, but these do not derive their special interest from the Common itself and are not affected by the proposed development.

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Figure 6a: Conservation Areas surrounding Clapham Common (Lambeth)

7.2.13 CA35: The Chase CA – The heritage significance of the CA is informed by its history as a drive linking Wandsworth Road and Clapham Common North Side. Developed from the 1870s with large housing of varying styles. The trees that line the road contribute to significant mature landscaping, and either end is terminated by views of mature trees. The character of the CA is not dependent on the common itself. The views into and out of the CA will not be harmed by the proposal and the proposed festival will not impact on the character of the CA or its setting.

7.2.14 CA22: Clapham High Street CA – The heritage significance of the CA is the character as a high street evolved from 18th Century and 19th Century residential properties to commercial. There is variation in the townscape with single-storey projections to the front housing the later Victorian and Edwardian shops. Although views out of the CA to the south-west are terminated by the Common, the character of the CA is not dependent on the Common itself. The views into and out of the CA will not be harmed by the proposal and the events will not impact on the character of the CA or its setting.

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7.2.15 CA1: Clapham CA – The heritage significance of the CA is its character as a levelled wide-open space bounded by main roads and mature trees. The common itself forms the heart of the Clapham Conservation Area. The historic Clapham village Old Town (north east of the common) is included within the conservation and has some of the oldest properties in Lambeth dating back to 1706. The common is a flat grassed open land with mature trees tracking the boundary of the common and public paths. The open common itself is a significant part of the significance of the CA, with it defining the surrounding pattern of development. The common has a long history of recreation use and hosting temporary events with associated temporary structures.

Figure 6b: Conservation Area Boundary (Wandsworth)

7.2.16 Clapham Common CA (Wandsworth) – As with Clapham CA, this CA is characterised by the wide, open space of Clapham Common and the often grand houses that front onto it. There are several listed buildings and some fine churches within the conservation area. Interesting buildings such as the Clapham South tube station and the bandstand on the common itself ensure a varied architectural scene.

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7.2.17 As discussed above, whilst some of the structures associated with major event will be relatively large, given their temporary nature, it is considered that there would be no harm to the character or appearance of the Clapham Conservation Area or the adjoining conservation area within the London Borough of Wandsworth. The LB Wandsworth Clapham Common character appraisal states that the dominant feature of the conservation area is clearly the Common itself. However, the (LB Wandsworth) character appraisal also states that there are other green elements that make an important contribution to the character of the conservation area which include the 19th Century houses and gardens which face onto the Common. It is noted that the submission includes details of the largest structures and while the detailed design of the structures is not considered to influence significantly on the overall visual impact of the proposals, it is considered necessary to restrict their maximum height to no more than 30m to ensure that there is no harm to the wider area. This would be secured through a condition (condition 3).

7.2.18 The medium and small events involve significantly smaller structures and their individual impact and the cumulative impacts on the character and appearance of the Clapham Conservation Area and the adjoining conservation areas of the Chase and Clapham High Street is considered acceptable.

7.2.19 The events would take place in various areas of the Common and some events overlap. Festival Republic is a major event and overlaps with Runthrough, which is a small event taking place on 15 August. The Colourscape Festival is a small event and overlaps with 3 other events, 2 of which are small events and 1 is a medium event; Trinity’s Family Walk and Fun Day (12 September); Harvest Feast (18 September); and London to Brighton Cycle (19 September). It is acknowledged that additional events are scheduled to take place on the Wandsworth side of the Common, and some of them involve relatively large structures.

7.2.20 Nevertheless, the proposal would not harm the character or appearance of the Clapham Conservation Area and adjoining conservation areas of the Chase, Clapham High Street, and Clapham (Wandsworth), and would therefore accord with Policies Q18 and Q22 of the LLP (2015) and the requirements of the Planning (Listed Buildings and Conservation Areas) Act 1990.

7.2.21 The proposal also complies with DRLLP policy Q22 also, which is given significant weight in this assessment as it is not affected by proposed main modifications.

Impact on heritage assets: Statutory Listed Buildings

7.2.22 Policy 20 of the LLP and DRLLP (Statutory listed buildings) seeks to ensure that development affecting statutory listed buildings will be supported where they would (i) conserve and not harm the significance/special interest; (ii) not harm the significance/setting (including views to and from); and (iii) not diminish its ability to remain viable in use in the long term.

7.2.23 There are several statutory listed buildings and structures within the Common and the surrounding streets. To the north of the application site is the Church of Holy Trinity which is Grade II* Listed. To the east of the Church of Holy Trinity is the Grade II Listed ‘stout polished granite column’ drinking fountain. To the northern part of the application site, just to the south of Clapham Common North Side road and opposite the junction with Victoria Rise, is the Grade II Listed early C18 Milestone. To the centre of the Common, on the Page 161

Lambeth side, on Windmill Drive, is the Grade II Listed Ye Olde Windmill Public House. To the south, on the corner close to the junction with Clapham Common South Side and The Avenue, is the Grade II Listed Tube Shelter and Surface building, a single storey structure erected as an entrance to the deep underground shelter as an extension to Clapham South Underground Station.

7.2.24 They are also several listed buildings and structures on the Wandsworth side of the Common:

• To the west of the application site, and in the centre of Clapham Common, is the Grade II Listed Bandstand, a two-storey circular bandstand. To the west of the application site, and within Clapham Common, is the Grade II Listed fluted cast iron posts and rails separating the north side of Windmill Drive and the south side of Mount Pond. • To the north-west of the application site, and within Clapham Common, is the two parish boundary markers between Battersea and Clapham.

7.2.25 The Common is also surrounded by several listed buildings and structures which face onto the Common, to the north of Clapham Common North Side, to the east of Clapham Common South Side and to the south of Nightingale Lane.

Figure 6c: Map of statutory listed building and structures with the red outline showing the main area for large and major events.

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7.2.26 The proposed scheme, and in particular the major event, includes relatively large structures such as stages, which would be located within the events site shown in Figure 3. It is considered that due to the temporary nature of the proposals, the distance of the events site to the listed buildings and structures and, in some cases, the presence of natural shielding from mature trees surrounding the edges of the Common, the proposal would not harm the setting or significance of the identified Grade II and Grade II* statutory listed buildings.

7.2.27 Events falling within the medium and small category involve significantly smaller structures and enclosures such as small tents and gazebos. These events may take place significantly closer to listed buildings and structures such as the Band Stand. However, given the relatively minor scale of the proposed structures and their very temporary nature which in most cases is restricted to 1 or 2 days, it is considered that the proposal would not harm the setting or significance of the identified Grade II and Grade II* statutory Listed buildings. Overall, the proposal would accord with Policy Q20 of the LLP and the requirements of the Planning (Listed Buildings and Conservation Areas) Act 1990.

7.2.28 The proposal also complies with DRLLP policy Q20. This is given significant weight in this assessment as it is subject only to proposed minor modifications to the explanatory text which do not affect the parts of the draft policy relevant to the current application.

Impact on heritage assets: Archaeological Priority Area

7.2.29 The northern part of the application site falls within a designated Archaeology Priority Area. This is a significant distance from the events site for major and large events, and the proposals do not include removal of topsoil. As such it is considered that the proposal complies with Policy HC1 of the LP.

7.2.30 This also complies with DRLLP policy Q23, which states that the Council will resist the destruction of assets on the local heritage list (or harm to their settings) and expects applicants to retain, preserve, protect, safeguard and, where desirable, enhance them when developing proposals that affect them; and apply London Plan policy HDC1D.

Assessment of Harm versus Benefit

7.2.31 Officers have concluded that no harm would be caused to the identified designated heritage assets because of the development. An assessment of harm versus benefits regarding heritage assets is not required as there is no harm identified.

7.2.32 However, should Members come to a different view, they must consider the impact of the proposed development on the significance of each designated heritage asset, and should also consider any cumulative impact if harm to more than one such asset is identified. Great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance (as per paragraph 193 of the NPPF).

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7.2.33 If Members come to a view that there would be substantial harm to or total loss of the significance of a designated heritage asset, consent should be refused, unless it is demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh the identified harm or loss (as per paragraph 195 of the NPPF).

7.2.34 If Members come to a view that there would be less than substantial harm to the significance of a designated heritage asset, the identified harm must still be given considerable importance and weight when weighed against the public benefits of the proposal, including where appropriate, securing the heritage asset’s optimum viable use (as per paragraph 196 of the NPPF). In this case, officers consider that the public benefits the development provides (as outlined in paragraph 7.1.9) constitute significant public benefits that would outweigh any harm to heritage assets.

7.3 Biodiversity, Landscaping and Tree Protection

Biodiversity and Landscaping

7.3.1 Policy EN1 of the LLP and Policy G6 of the LP encourage development to make a positive contribution to protection, enhancement, creation and management of biodiversity. Part b) of Policy EN1 seeks to prevent development which would result in loss, reduction in area or significant harm to the nature conservation or biodiversity value of an open space including any designated or proposed Local Nature Reserves (LNR) or Sites of Importance for Nature Conservation (SINC) such as Clapham Common unless adequate mitigation or compensatory measures are included appropriate to the nature conservation value of the assets involved.

7.3.2 All medium and major events would take place in areas of amenity grassland or hard standing, which would minimise their impact. Some smaller running events, which don’t have a fixed site boundary may pass through the more biodiverse areas of the Common, such as on/near the ponds or the edges of woodland/meadow grassland. Any temporary lighting installed as part of the events would need to comply with the ‘Bats and Lighting in the UK Guidance’ produced by the Bats Conservation Trust.

7.3.3 The applicant’s submission includes a biodiversity report which has been reviewed by the Council’s ecologist who has raised no objection to the application. However, the Council’s ecologist has requested a condition (condition 13) to secure an ecological management and mitigation plan (EMMP); this would be required to be submitted if any event is proposed on an area of the Common which has higher ecological values. It is considered that subject to this condition there would be appropriate mitigation measures in place to ensure that there would be no harm or damage to the Common’s biodiversity.

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Figure 7: Ecological constraints in Clapham Common

7.3.4 For each event, the level of any damage is determined during a site walk with the event organiser, the Council’s Parks team, and the Events team. Damage is assessed based on pre and post-event surveys and is discussed when areas of impact are reached. Following this, all areas are reviewed, and a proposed programme of reinstatement is drawn up. This discussion informs aspects of the proposal that could be improved in the future, and further measures that may be considered necessary. A variety of factors affect whether damage is done to the Common, for example, the impact of the weather, which happened at some events in 2019. On signing the contract for the event, the organiser of the event submits a bond to EventLambeth which allows some of this money to be held in bond to cover the costs of any reinstatement.

Tree Protection

7.3.5 Policy Q10 of the LLP 2015 states that proposals for new development will be required to take account of existing trees on site and on adjoining land. It further states that development will not be permitted that would result in the loss of trees of significant amenity, historic or ecological/habitat conservation value, or give rise to a threat, immediate or long term, to the continued wellbeing of such trees.

7.3.6 Policy Q10 of the DRLLP largely reiterates the existing adopted policy as above.

7.3.7 No excavation or removal of trees is proposed as part of the scheme. To mitigate against the risk of any trees in or adjacent to event sites suffering damage, events of any size are required to abide by a number of rules set out in Chapter 13 of the of the planning statement (Clapham Common Planning Application for Temporary Events (20 December 2019). This document outlines how events are managed by EventLambeth, which includes giving due consideration to maintaining an adequate Tree Protection Zone (TPZ) and ensuring that that barriers are put around any relevant trees. Event organisers are not Page 165

allowed to locate temporary structures or vehicles in the TPZ or attach anything to trees. Compliance with the above measures would be secured by a condition (condition 1).

7.3.8 The Council’s Parks team have raised no objection. EventLambeth have confirmed that there have been no reports of tree damage in the past year. As such, the proposals would comply with Policy Q10 of the LLP.

Protection and Regrowth of Grass

7.3.9 Although there can be damage to grass areas because of events (large and major events), this is partly mitigated with the use of track pads for vehicles for larger events. Repair to grassed areas after events is undertaken by officers in Lambeth Landscapes team and funds to undertake this work is secured through the event application process.

7.3.10 The Council’s Park team have advised previously that the track pads have had a positive impact on the Common, and that they have “radically” reduced the severity of impacts resulting from constant and widespread compaction and tyre damage. It is therefore recommended that a condition is imposed (Condition 15) to secure the final details of track pads.

7.3.11 Over the Winter of 2020/2021, the grass where the major event will be held has undergone regeneration. The Event team will carry out checks of the grass following the event and carry out repair works where necessary. The survey of the grass is also included in the site walk through as described in paragraph 7.3.4 above.

7.4 Amenity for Neighbouring Occupiers/Event Management

7.4.1 The main potential impacts on residential amenity caused by this application are: noise, crowd-management (way finding/signage and toilet facilities), and lighting.

Noise

7.4.2 Policy Q2 of the LLP supports development that does not harm the amenity of neighbouring residents and uses, which includes ensuring that there is an acceptable level of noise.

7.4.3 The Festival Republic event proposes concerts which would require PA systems. The proposed scheme includes restrictions on the maximum sound levels permitted, which follows the guidance as set out in the ‘EventLambeth Guidance on the control of sound at out-door events (2016)’.

7.4.4 Festival Republic consists of 6 major event days, which is less than the 8 days permitted by the Lambeth Event Strategy. For a major event, the sound levels approved by the Lambeth Event Strategy are:

“The maximum Music Level (MNL) shall be 75dB L(A) eq 15 minutes (free field) outside any noise sensitive premises. The maximum low frequency Music Noise Level (LFMNL) shall be 90 dB L(C) e.q. 15 minutes (free field) outside any noise sensitive premises.”

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7.4.5 It is considered useful to cite the acoustic terminology provided within the ‘EventLambeth Guidance on the control of sound at out-door events (2016)’ which is as follows:

• The human ear can detect a very wide range of pressure fluctuations, which are perceived as sound. In order to express these fluctuations in a manageable way, a logarithmic scale called the decibel or dB scale is used. The decibel scale typically ranges from 0dB (the threshold of hearing) to over 120dB; • dB (decibel) – The scale on which sound pressure is expressed; • dB(A) A-weight decibel – This is a measure of the overall level of sound across the audible spectrum with frequency weighting (‘A’ weighting) to compensate for the varying sensitivity of the human ear to sound at different frequencies; • dB(C) C-weighted decibel – This is a measure of the overall sound taking into account the low (bass) frequencies; • LAeq – This can described in simplistic terms as the ‘average’ sound level over a given tie period; • FMNL – Music Noise Level – This is the (A-weighted) monitoring sound level of the music played at an event and is normally determined off-site, for example, outside the nearest residential premises; • LFMNL – Low Frequency Music Noise Level – This is the (C weighted) monitoring sound level of the music played at an event and is normally determined off-site, for example outside the nearest residential premises.

7.4.6 The figure below shows the sound levels in the context of common sounds and as a reference point of the threshold of pain is the pain at which sound becomes painful for the listener.

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Figure 8: Sound Levels Guide

7.4.7 It is noted that the LB Wandsworth has not formally commented on this year’s planning application, nor did they comment on the planning applications submitted over the last two years. However, they formally objected to the 2018 application on the grounds of noise nuisance. However, the 2018 EventLambeth SW4 post event report, which was created by EventLambeth as a summary of how the event was carried out, states that Lambeth Council and Wandsworth Council are now working cooperatively and are both on-site during music events and liaise with each other if complaints are received from their respective contact centres.

7.4.8 The Council appointed an acoustic consultant to monitor off-site noise levels for the Lets Rock and SW4/House of Common Events in 2017, 2018 and 2019. The consultant was not responsible for controlling or managing sound levels. It was noted that only two significant breaches in 2017 for Lets Rock were recorded and five breaches were recorded for the 2018 event. These breaches were referred to the LBL manager who has the authority that if the levels of noise continue to be in breach of the LB Lambeth Noise Guidance (2016) after the hirer has been warned, then the source of the noise would be shut down. The offsite noise levels for SW4 were compliant with LB Lambeth Noise Guidance (2016) and no breach of the 2016 guideline.

7.4.9 In 2019, Event Lambeth created a post-event assessment, which demonstrated that in relation to the SW4/House of Common event, 10 noise complaints from 7 individuals on the Saturday, 2 individual complaints on the Sunday and none were recorded on the Monday. A total 9 complaints were received post-event by Lambeth and 8 were received by Wandsworth. However, no breaches were recorded at the event, by neither the Acoustic Consultant employed by SW4, nor the acoustic consultant employed by EventLambeth, nor from colleagues from Wandsworth Council Environmental Health Team.

7.4.10 As part of the EventLambeth licencing, all organisers are required to submit ESMPs which include a Noise Management Plan. This report will need to demonstrate that the event noise levels will be in accordance with the levels set out in the Council’s Guidance on the control of sound at out-door events (2016), and details of how any breaches will be dealt with. In previous years these documents were submitted as part of the planning application documentation and the Council’s noise consultants were satisfied with the details provided.

7.4.11 Last year’s temporary permission differed from this approach, in that a basic ESMP was submitted for Festival Republic. This year, the ESMP for the Festival Republic has not been submitted, and therefore the Council’s noise consultant has recommended that this is secured through a condition (condition 17). It is recommended that the Noise Management Plan includes four monitoring points (8a Windmill Drive, 14 Clapham Common West Side, 30 Clapham Common North Side and Notre Dame Estate. Page 168

7.4.12 The maximum noise levels permitted at monitoring points for a major event are comparable to average traffic on street corner or conversational speech. In this case, this would be for 6 major event days, which is considered acceptable. In line with the EventLambeth Guidance on the control of sound at out-door events (2016)’, the noise levels during the large event days will have lower levels set than those set out above for major events. Compliance with the above is secured by condition 1 and will inform the Noise Management Plan as required by condition 17.

7.4.13 The licensing of public events is the primary mechanism for ensuring that potentially adverse impacts on the neighbourhood are appropriately controlled. The PPG states that conditions may not be relevant to planning if they duplicate controls outside planning legislation that provide an alternative means of managing certain matters. In this case, the compliance with measures and maximum noise levels set out in those management plans would be controlled through licensing and as such it is considered that additional planning conditions (other than those discussed in the report) are not necessary and therefore would not meet the relevant statutory test.

7.4.14 The impact of the Festival Republic event, which is the major event planned, would not result in unacceptable impacts on the amenities of the neighbouring residents subject to its compliance with the recommended conditions. Furthermore, given the nature and scale of the other events, it is not considered that they would result in any significant noise levels either individually or cumulatively. Overall, it is considered that the proposals comply with Policy Q2 of the LLP and Q2 of the DRLLP.

7.4.15 Noise and disturbance associated with events is caused not only by sounds created as part of the event production but also by the comings and goings of visitors. It is therefore recommended that a condition relating to customer opening hours is imposed to ensure that the major event days do not take place outside the hours of 11:00 and 23:00. This will be secured under condition 5.

Signage and Way-finding

7.4.16 Signage and way-finding strategies are included within the Transport Assessments submitted to LB Lambeth’s Events team as part of the event licensing application process. These Transport Assessments are submitted to SAG, which includes input from TfL, Metropolitan Police and relevant statutory bodies, for comment. This is to ensure each event is acceptable in terms of crowd management.

7.4.17 The major event would include the use of stewards to direct attendees and the public, whilst there is also the use of small-scale temporary signage, such as posters within tube stations and stand-alone structures, specifically related to the event. Smaller events rely on the already existing signage and way-finding infrastructure in around the Common, and within Clapham, to assist visitors in navigating. Information is also provided on websites created by many events. It is considered that the effective use of signage assists in hastening egress of events away from the Common as attendees make their exit.

7.4.18 Within the event site themselves, EventLambeth would ensure that event organisers provide signs for all safety and welfare facilities on site, such as first aid, toilets, drinking water, ancillary sales, etc. This is secured through event licencing.

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7.4.19 The Transport team have requested a review of signage and way-finding to ensure that more measures are taken at critical points, for example, around Clapham Common Station to prevent event attendees from turning left at the top of the stairs which exits onto the A24. This will be secured with a condition to have further details prior to the large and major events (condition 10).

Toilet Facilities

7.4.20 As part of the Licensing assessment, all events are required to provide public toilets in line with national guidance in the “Purple Guide to Health, Safety, and Welfare at Music and Other Events”, which specifies the requirements for different events and different numbers of attendees.

7.4.21 In order to obtain an Events permit, major and large events are required to provide temporary toilets both inside and outside the event, to also cater for those attendees who are queuing to gain entry to the event site. Medium and small events may not be required to be provide temporary toilet facilities. This would be decided up on outside of the planning system, as part of the event licensing applications.

Lighting

7.4.22 The majority of events held on the Common take place during daylight hours and do not require any lighting from the existing temporary provision. For large and major events, which require egress to Clapham South Underground station, lighting is provided from tower lights for safety. They are positioned across the Common and will be turned on at an agreed time before the main egress commences. The lights will be turned off when egress is completed.

7.4.23 All events that need additional lighting are required to provide these details as part of the licensing application process. To avoid unreasonable impacts, Lambeth Events expects a number of guidelines to be followed and these are outlined in the submitted Lighting Strategy, which is set out in section 15 of the approved planning statement (Clapham Common Planning Application for Temporary Events20 December 2019). Officers consider that the measures proposed in the Lighting Strategy would ensure that the proposals comply with Policy Q2 of the LLP and Q2 of the DRLLP.

7.5 Transport

7.5.1 Policy T6 of the LLP states that all planning applications will be supported where they do not have unacceptable transport impacts, including cumulative impacts on highway safety; traffic flows; congestion of the road network; on-street parking; footway space, desire lines and pedestrian flows, and all other transport modes, including public transport and cycling.

7.5.2 Furthermore, Policy T8 of the LLP states that servicing will be expected to be on-site unless demonstrated it can take place on street without affecting highway safety or traffic flow. This is reiterated in DRLLP policy T8.

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7.5.3 The transport officer has agreed that the submission of a comprehensive monitoring survey is not necessary this year, as previous applications for events in Clapham Common (example, 18/05422/RG3) have shown that events were successfully managed; this was also the approach in 2020. There are aspects of the transport assessment which need to be reviewed, specifically, the cycle parking, the signage and way-finding and taxi management. These will be included in one condition with information to be submitted prior to the major event to ensure these are adequately addressed (condition 10). The Transport Assessment is included within condition 1, to ensure measures incorporated within it are enforceable.

7.5.4 Due the COVID-19 pandemic related travel and work restrictions, the most recent surveys which are detailed below are from the events in 2019; this is because no events took place in 2020.

Location and Accessibility

7.5.5 The application site has a public transport accessibility level (PTAL) rating of between 4 (good) and 6a (excellent), with the higher level located to the north-east and south-east corners of the Common. These are the locations of Clapham Common and Clapham South Underground stations, respectively. A further Underground station, Clapham North, is located approximately 600m to the north-east of the Common.

7.5.6 In addition, Clapham High Street Overground Station is located approximately 600m north- east of the Common. Clapham Junction rail station is located approximately 650m north- west of the Common and provide National Rail connections to the wider region.

7.5.7 The Common is well served by local bus routes. Several routes run along Rookery Road, which traverses the Common, while others run along its northern, eastern and western edges.

Traffic, Transport and Crowd Management Impacts

7.5.8 The use of the Common for temporary events has a history extending back over 10 years. The major event would take place in August. Events associated with Festival Republic are scheduled for two weekends in August, including the late bank holiday, which will be similar to SW4 which has taken place previously. Transport for London have raised no objection to the proposal. Furthermore, the planning application from 2019 included a condition requiring detailed monitoring reports to be submitted. The supporting information to discharge this condition was reviewed by transport officers and was approved under application ref. 19/04694/DET. The review of this data showed that events are well managed and, it informed the assessment of the current application. The monitoring report, however, outlined recommendations for a more successful approach to signage and way-finding which is discussed in paragraphs 7.4.16-19, and taxi management, which is included within the Parking section below, in paragraphs 7.5.12-15.

7.5.9 The transport officers have recommended that a full transport monitoring assessment does not need to be attached again in its previous form and instead further monitoring required should focus on cycling which is further discussed below.

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7.5.10 The egress of pedestrians also requires careful management and event management plans will ensure that no overcrowding would occur at any part of the site, thereby achieving an even flow of people at ingress and egress points. This is important because the layout of the ‘island’ platforms at Clapham Common Underground station make it unsuitable for large scale egress. TfL have advised that they will be introducing a new signalised pedestrian crossing on the A205 The Avenue, near the junction with A24 Clapham Common. TfL will also be consulted as part of their representation on the SAG. This approach to scrutinise events through the licensing application process has been used in previous years and will be presented to and agreed by SAG as part of its consideration of the event licence application and would be included with the ESMP.

7.5.11 As such, there is no in principle objection to the proposal in respect of traffic, transport and crowd management impacts.

Parking

7.5.12 The local Controlled Parking Zone (CPZ) (Clapham L and Clapham C within LB Lambeth) is operational Monday – Friday 08:30 / 09:00 – 18:30 / 20:00. Therefore, visitors will be able to park for free on surrounding roads at any time during weekend events. However, the numbers of visitors choosing to do so are expected to be small, given the nature of some of the events (late night, involving the consumption of alcohol, target demographic, etc…), and the excellent public transport accessibility to the site.

7.5.13 A post-event car parking survey was carried out as part of the 2019 Transport Monitoring condition (19/04694/DET). This was to determine the levels of car parking available in the surrounding area in order to accommodate any visitors choosing to drive to the events. The survey covered all roads in LB Lambeth and LB Wandsworth surrounding the Common, and was undertaken at 11am, 3pm and 6:30pm on all event days. A total of 57 roads were surveyed. The results of the survey demonstrate that there was an increase of cars throughout the day, however, the peak parking stress (recorded at 6:30pm on Bank Holiday Monday) was still relatively low, at 51%. Transport officers consider some of the spaces unusable, which were included within this statistic; for example, bus stops, dropped kerbs, etc. However, they consider that whilst this is high, there were 61 parking spaces available, which is considered to be sufficient. Below is a map of the extent of roads surveyed: Page 172

Figure 9: Extent of Parking Stress Survey

7.5.14 It is also important to note that the parking survey was undertaken on a normal (i.e. not bank holiday) weekend, and that the weather was very good, meaning the Common may have attracted a particularly large number of visitors. By contrast, the major event to be held on the Common is scheduled for a bank holiday weekend, when it is expected that levels of parking stress would be lower as London tends to be quieter at these times. Furthermore, it is anticipated that the event will have less attendees than previous years due to the COVID-19 pandemic; therefore, the information submitted is considered a worst-case-scenario.

7.5.15 The transport monitoring report recommended that Windmill Drive should be made either one way, or parking should be suspended. To ensure the management of this is reviewed prior to the start of the first opening of each medium and major event, a condition is recommended to secure revised details of signage as set out above (condition 10).

E vent Access Arrangements

7.5.16 Vehicle entry points to Clapham Common for event access are detailed below and presented in visual form in the accompanying aerial photo in Figure 10. These are as listed below. This year’s large and major events would again have a condition requiring the use of track pads during large and major events. This would require vehicles to drive only on track pads, which would minimise damage to the Common.

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• Access to the main event site (denoted in purple in Figure 11 below), where the Major event (Festival Republic) takes place, is situated just off Long Road (A3). This is a dedicated vehicle entrance with a track pad just inside it. • For the Festival Republic event the vehicle entrance is off Rookery Road. • Events at the bandstand and the fields in that location would use the Windmill Drive entrance. • The funfair/circus site would be accessed off the Avenue (A205) at the junction with Windmill Drive. • The London to Brighton bike ride would use the entrances off the Avenue (A205) and Nightingale Lane (B237). • Holy Trinity uses the Common for their Fayre and vehicles enter via the church access off the B303. • Should there by an emergency or health & safety requirement, other access points may need to be considered on a case-by- case basis.

Figure 10: Access locations for events

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Figure 11: Events locations

Delivery and Servicing Arrangements

7.5.17 As in previous years’ applications, many of the scheduled events have delivery and servicing requirements for event hardware, such as stages, tents, PA equipment and lighting, as well as consumables such as food and drink. These requirements will vary depending on the nature, scale and duration of the event and needs to be carefully managed to avoid negatively impacting upon users of the Common and the local highway network. Furthermore, experience of previous events now requires track pads to be laid on the Common in order to minimise any potential damage from service vehicles or vehicles involved in the installation of the large-tented structures on the Common. This requirement will be required as a condition of consent (condition 15).

7.5.18 The applicant’s Events Report advises that many of the small-scale events do not require any delivery or servicing due to the small number of people attending or the type of event. For some small and medium events, delivery and servicing will take place via the Common’s existing access routes adhering to applicable restrictions on vehicular access. These routes have been detailed in paragraph 7.5.16 above.

7.5.19 For large-scale, multi-day events, delivery and servicing will be required before, during and after the event for build (set-up), de-rig, public toilet cleaning and the restocking of on-site bars and food outlets. The timing of deliveries relates directly to the event’s hours of operation, with all deliveries and servicing taking place outside of event hours. This will be controlled by the ESMP for the major event, which is secured via condition 17.

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7.5.20 The Transport officer advised that the major event is likely to have significant servicing demands in terms of the build-out, catering and waste management prior to and after the event. A condition is proposed to ensure that no deliveries or collection are undertaken on the public highway (Condition 9). A condition is proposed to ensure that all vehicles enter and exit the site in forward gear (Condition 8). It is also noted that the Park Events terms and conditions require the use of a banksman for all vehicle movements onto Lambeth park land, and therefore this be secured through compliance with event licensing. Similar, to last year’s recommendations, an informative is recommended to encourage the use of electric vehicles and, where possible, consolidate deliveries. It is noted that the use of electric servicing vehicles is also encouraged through the Lambeth Green Events Guide.

7.5.21 Subject to these recommended conditions officers do not raise any objections to the delivery and servicing arrangements.

Waste Management Arrangements

7.5.22 Application for events held on the Common are required to be accompanied by a waste management plan, which is assessed by EventLambeth as part of the event applications process.

7.5.23 EventLambeth terms and conditions provide guidelines for the management of litter, bins, and recycling for events carried out within the borough’s parks and open spaces. These conditions require that the event organiser is responsible for:

• The provision of suitable refuse receptacles; • Litter picking on the event ingress and egress routes; • Additional picking in the local area, if required; • The organising of litter picking, sweeping and collection services.

7.5.24 As part of the licensing process for larger events held on the Common, the Waste Management Plans are submitted to SAG and passed on to the relevant statutory bodies for comment. This is to ensure each event is acceptable in terms of impact on the local waste management provision.

7.5.25 Officers are satisfied that these measures provide appropriate safeguards to ensure that waste generated by events is appropriately managed. A condition is recommended to ensure that all waste, refuse and recycling is removed from the relevant event site by the end of one day after completion of de-rig for each event (condition 6).

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Cycle Parking

7.5.26 LLP Policy T3(c) requires the provision of appropriate secure and covered cycle parking facilities in accordance with LP standards for development proposals that would generate additional trips. There are no LP standards for temporary events of this nature. DRLLP policy T3(e) outlines that the council will require the provision of appropriate secure and covered cycle parking facilities in accordance with minimum standards outlined in LP policy T5 and LLP policy Q13; however, there are no standards for temporary events.

7.5.27 Last year’s Events application secured temporary Sheffield stands for the Large and Major Events on the Common and 100 cycle parking spaces (or 50 Sheffield stands) was considered appropriate.

7.5.28 The results of the SW4 Travel Survey show that the cycling mode share was very low, at 1%. However, the surveys found that only 11% of respondents were aware that cycle parking would be available and 14% said they had not cycled because they had not seen the adverts informing them that cycling was encouraged, or that cycling parking would be available. Although cycling will not be a viable option for all (for those travelling long distances or planning to drink alcohol for example), event applicants should ensure that for future events, the availability of cycle parking is clearly advertised on the website and within booking confirmation, to ensure that those who would like to cycle are not discouraged. A further issue with cycle parking is that attendees to events are not permitted to have bags larger than A5 within the event site, therefore this impedes the storage of helmets/lights in bags. Therefore, where attendees’ bag size is restricted, suitable secure storage for cyclists’ gear should be provided and promoted.

7.5.29 The applicant has suggested that pedestrian barriers could be used to provide cycle parking, rather than temporary Sheffield stands, which may be acceptable subject to the barriers being sufficiently secure and, in an area where they would be seen by security staff, for example. A condition is recommended to secure further details of temporary cycle parking, for all medium, large and major events for the duration of the event. This shall include details of publicity and, where necessary, storage facilities for cycling gear. Furthermore, it is considered that the monitoring of cycling should continue this year to enable a review of the effectiveness of the above measures. This is secured by condition 14.

7.5.30 Based on the submitted information, there are no objections on transport and highways grounds to the proposal. The proposal would not result in unacceptable impacts that would be of detriment to highway users. The scheme therefore complies with Policies T6 and T8 of the LLP, and DRLLP policy T8.

7.6 Sustainable Design and Air Quality

7.6.1 Paragraph 181 of the NPPF states that planning policies and decisions should sustain and contribute towards compliance relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts on air quality from individual sites in local areas.

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7.6.2 LP Policy SI 1 states that development proposals should minimise increased exposure to existing poor air quality and make provision to address local problems of air quality (particularly within Air Quality Focus Areas and where development is likely to be used by large numbers of those particularly vulnerable to poor air quality, such as children or older people). However, the requirement for Air Quality Assessment in the Mayor’s SPG is primarily to mitigate the impacts of construction and demolition. The nature of the modular assembly on site means that there is likely to be no significant impact in this regard.

7.6.3 The proposed development is for temporary installations and structures that will be in operation for approximately 29 days for Festival Republic. Therefore, due to the temporary nature of the application the sustainability requirements within LLP Policies EN3 and EN4 and the LP do not apply. This includes all of policy EN3 (the requirement to connect to a decentralised energy network where possible) and LP Policy SI 2 C (meeting a 35% reduction in carbon emissions). With regard to LLP policy EN4 (sustainable design and construction), a BREEAM assessment will not be required due to the temporary nature of the development, along with measures to address climate change adaptation.

7.6.4 The Sustainability officer has recommended a condition addressing the suggested ways to reduce the environmental impacts of events, as set out in the “Lambeth Green Events Guide”. As compliance with the essential requirements set out in the document form part of the event licencing process, a condition is not required as it would duplicate processes already in place. However, an informative is recommended to encourage meeting higher (‘desirable’) sustainability measures set out in the “Lambeth Green Events Guide” where possible.

7.6.5 Most visitors to the site will use public transport, which will assist in offsetting negative air quality impacts from the development. Furthermore, condition 12 is recommended to ensure that no non-road mobile machinery (NRMM) would be used on the site unless it is compliant with the NRMM Low Emission Zone requirements (or any superseding requirements) and until it has been registered for use on the site on the NRMM register (or any superseding register). This would ensure that all machinery to be used on site would be non-polluting to improve air quality.

7.7 Flood Risk and Drainage

7.7.1 The National Planning Policy Framework (NPPF) requires all development to be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere [paragraph 160].

7.7.2 Policy EN6 of the LLP relates to sustainable drainage systems and water management and states that development should seek to ensure that the layout and design of development does not have a detrimental impact on floodwater flow across the site. This is reiterated in DRLLP policy EN5.

7.7.3 The application site is designated within Flood Risk Zone 1, as set by the Environment Agency, therefore indicating that flooding from the rivers or sea is unlikely (at a likelihood of 0.1% or 1 in 1000).

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7.7.4 There are two bodies of water located within the application site: Long Pond to the east of the site, and Eagle Pond to the south. A further body of water, Mount Pond, is located on the Common but outside the application site to the west.

7.7.5 There is no objection in terms of policies EN5 of the LLP (2015) and SI 12 of the LP (2021).

7.8 Crime Prevention, Visitor Management and Public Safety

Security 7.8.1 Policy Q3 of the LLP states that the Council will expect development to utilise good design to design out opportunistic crime, antisocial behaviour and fear of crime in a site-specific manner, based on an understanding of the locality and likely crime and safety issues it presents. This requirement is contained within Section 17 (2) of The Crime and Disorder Act 1998, which imposes an obligation on the Local Planning Authority to consider crime and disorder reduction in the assessment of planning applications.

7.8.2 DRLLP policy Q3 (Safety, crime prevention, and counter terrorism) outlines that in order to create a safe borough for all, the council will expect good design to design out opportunistic crime, anti-social behaviour, violence, and fear of crime in a site-specific manner, based on an understanding of the locality and likely crime and safety issues it presents; and pay particular regard to shared public space and communal areas (particularly cycle stores and refuse stores).

7.8.3 As part of the licensing process, all events are required to submit information relating to security, health and safety. All large and major events are required to submit detailed Security Plans, which are reviewed by SAG. Membership of SAG includes organisations such as Metropolitan Police, London Fire Brigade and London Ambulance Service. The Council’s Events team would liaise with the Metropolitan Police Service, which would continue up to the event delivery through the Safety Advisory Group. It should be noted that this ongoing monitoring between the event organiser and the Met Police for last year’s event was also finalised outside of planning control through the licensing application for each event. The Metropolitan Police, through their Borough Operations team, review each event on a case-by-case basis taking in to account the current threat level, specific concerns and intelligence. If any concerns are raised, then it is referred to their Central Operations team.

7.8.4 If, during the operation of any event, organisers are told about the location of anti-social behaviour or drug use, they can notify the police. There will be police officers and police community support officers onsite at large and major events. It is noted that the event organisers have stated that the Police have not raised the issue of street crime or robberies with EventLambeth.

7.8.5 Given the above, it is considered that the proposals incorporate safety and security measures compliant with Policy Q3 of the LLP and Q3 of the DRLLP.

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Public Safety

7.8.6 In the light of the global coronavirus (COVID-19) pandemic, legislation including the Coronavirus Act 2020, the Health Protection (Coronavirus) Regulations 2020 and the Health Protection (Coronavirus, Restrictions) (England) Regulations 2020 has been enacted. Alongside the legislation, the government has issued guidance covering a range of matters including social distancing.

7.8.7 Social distancing guidelines are a national requirement and fall outside of the remit of planning controls. As such, the applicant will be required to conduct events in accordance with any restrictions contained in general law. Additionally, a possible consequence of legislation stemming from the coronavirus pandemic may be that an event cannot take place at all or may only take place in certain circumstances. Such legislative controls are outside the scope of planning control.

7.8.8 The applicant has submitted a document (‘COVID-19 and Events’) outlining the relevant steps that have been added to the event application process. As a result, Public Health are consulted on all event applications when they are submitted and before they are issued with a permit, to ensure adequate measures are incorporated into the proposals. The applicant would continue to work with SAG to ensure events will comply with coronavirus pandemic restrictions.

7.8.9 If an event can go ahead, in some cases it may be necessary for an applicant to seek an amendment to the terms of an existing planning permission to enable the event to go ahead in such a way as to comply with coronavirus-related legislation and/or government guidance. In other cases, an amendment to the permission may not be necessary, but the way in which the event will have to operate may have consequences for issues such as visitor management.

7.8.10 It is recommended to impose an additional condition that requires the applicant to demonstrate to the satisfaction of the local planning authority that an event which goes ahead is able to satisfactorily absorb the impact in planning terms of any additional steps relating to the way in which the event will need to operate that arise from adherence to coronavirus legislation/guidance. Examples of the type of impacts that may need to be mitigated against are management of public safety in queues for events or facilities such as public toilets. The proposed additional condition is included as Condition 18.

8 CONCLUSION

8.1.1 In summary, officers consider the proposed temporary change of use and the erection of temporary structures and fencing on parts of the Common to represent an appropriate and acceptable use of the Metropolitan Open Land with public retaining normal access to at least 90% of the Common at any one time. It is considered that there would not be any harm caused to the openness of the Common, the character or appearance of the Clapham Conservation Area and the adjoining conservation areas or the setting of listed buildings and structures.

8.1.2 In terms of residential amenity, officers are satisfied that the supporting information submitted with the application and the licensing requirements of Event Lambeth adequately address issues relating to noise control, visitor management and other operational issues pertaining to the proposed uses.

8.1.3 The proposals would be acceptable on transport and highway grounds.

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8.1.4 Having regard to the above assessment it is considered that subject to the conditions set out below, the proposed development would comply with the relevant policies of the development plan. Accordingly, the application is considered appropriate and acceptable for the reasons in this report and is therefore recommended for approval.

8.1.5 A copy of the Draft Decision Notice with the recommended conditions, reasons and informatives is provided in Appendix 1

9 EQUALITY DUTY AND HUMAN RIGHTS

9.1.1 In line with the Public Sector Equality Duty the council must have due regard to the need to eliminate discrimination and advance equality of opportunity, as set out in section 149 of the Equality Act 2010. In making this recommendation, regard has been given to the Public Sector Equality Duty and the relevant protected characteristics (age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation).

9.1.2 In line with the Human Rights Act 1998, it is unlawful for a public authority to act in a way which is incompatible with a Convention right, as per the European Convention on Human Rights. The human rights impacts have been considered, with particular reference to Article 1 of the First Protocol (Protection of property), Article 8 (Right to respect for private and family life) and Article 14 (Prohibition of discrimination) of the Convention.

9.1.3 The Human Rights Act 1998 does not impair the right of the state to make decisions and enforce laws as deemed necessary in the public interest. The recommendation is considered appropriate in upholding the council's adopted and emerging policies and is not outweighed by any engaged rights.

10 RECOMMENDATION

10.1.1 Resolve to grant conditional planning permission

10.1.2 Agree to delegate authority to the Director of Planning, Transport and Sustainability to finalise the recommended conditions as set out in this report, addendums and /or PAC minutes.

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APPENDICES

Appendix 1: Draft Decision Notice

List of Approved Drawings and Documents:

Covering Letter (18/1/21); Lambeth Events Strategy 2020-2025; Lambeth Green Events Guide 2020-2025; Clapham Common Planning Applications for Temporary Events 18 January 2021; Clapham Common Planning Applications; Appendix 3- Clapham Common Application Site Events Schedule 2021; Appendix 4- New Contract for Clapham Common; COVID-19 and Events; Event Lambeth Guidance on the control of sound at out-door events (2016); 5667/001; 5667/002; Assessing the Ecology Impact of Events; Bats and Artificial Lighting in the UK; Calendar of All Events; Consultation on Lambeth’s Event Strategy Consultation Report January 2020; Ecological Impact Assessment for Clapham Common July 2018; Ecological Impact Assessment for Clapham Common July 2020 update; Ecology Management Plan: Large and major events on Clapham Common 2020; Event Access Arrangements; Lambeth Council guidelines for animals at events; Lambeth Events Policy 2020-2025; Lambeth Outdoor Events Terms & Conditions; Transport Monitoring Report December 2019; Appendix 2- Transport and Parking; Site Plan.

Conditions

1. The development hereby permitted shall be carried out in accordance with the approved documents, plans and drawings listed in this decision notice, other than where those details are altered pursuant to the conditions of this planning permission.

Reason: For the avoidance of doubt and in the interests of proper planning.

2. The temporary structures hereby permitted shall be removed from the land and the temporary uses discontinued, in accordance with the dates set out within the Clapham Common Application Site Events Schedule 2021 and the land restored to its former condition as open common on or before completion of de-rig.

Reason: The nature and duration of the temporary uses and structures are acceptable, but the use of these parts of the common on a continuous and permanent basis, would cause unacceptable harm to the character and appearance of the common and conservation area and the openness of the Metropolitan Open Land (Policies EN1, Q2 and Q22 of the London Borough of Lambeth Local Plan (2015)) and EN1, Q2, and Q22 of the Draft Revised Lambeth Local Plan (2020).

3. No structure associated with the temporary events hereby approved shall exceed 30m in height.

Reason: To minimise the impact of the temporary structures on the character appearance of the common and conservation area (Policies EN1, Q2 and Q22 of the London Borough of Lambeth Local Plan (2015)) and EN1, Q2, and Q22 of the Draft Revised Lambeth Local Plan (2020).

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4. In addition to the approved documents, plans and drawings listed in this decision notice, the events hereby approved must not operate other than in accordance with all documents submitted and accepted by EventLambeth.

Reason: To protect the character and value of the common and conservation area, to protect trees and landscaping, to limit impact on amenity of adjoining occupiers and users of the area, and to minimise the transport and highways impact of the development (Policies EN1, EN5, EN6, Q2, Q3, Q9, Q10, Q12, Q22, ED7, T1, T6 and T8 of the London Borough of Lambeth Local Plan (2015)), and EN1, EN5, EN6, Q2, Q3, Q9, Q10, Q12, Q22, ED8, T1, T3, T8 of the Draft Revised Lambeth Local Plan (2020).

5. The major events days hereby approved shall not be open to members of the public (attendees) other than within the following times:

11:00 Hours to 23:00 Hours

Reason: To limit nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers or users of the area generally (policies Q2, ED7 and T6 of the London Borough of Lambeth Local Plan (2015)), and Q2 and ED8 of the Draft Revised Lambeth Local Plan (2020).

6. All waste, refuse and recycling will be removed from the relevant event site, and the area within 10m of the perimeter of the event site, by the end of one day after completion of de-rig for each event.

Reason: To ensure suitable provision for the occupiers of the development, to encourage the sustainable management of waste and to safeguard the visual amenities of the area (policies Q2 and Q12 of the London Borough of Lambeth Local Plan (2015)), and policies Q2 and Q12 of the Draft Revised Lambeth Local Plan (2020).

7. The vehicular access to the site shall be provided and used in accordance with the Event Access Arrangements document.

Reason: To minimise danger, obstruction and inconvenience to users of the highway (policies T1, T6 and T8 of the London Borough of Lambeth Local Plan (2015)) and T3, T7, T8, and T9 of the Draft Revised Lambeth Local Plan (2020).

8. No vehicles shall enter or leave the events sites other than in a forward direction.

Reason: To minimise danger, obstruction and inconvenience to users of the highway (policies T1, T6 and T8 of the London Borough of Lambeth Local Plan (2015)) and T3, T7, T8, and T9 of the Draft Revised Lambeth Local Plan (2020).

9. For all events hereby approved, no deliveries or collections from vehicles arriving at or leaving the site shall be undertaken on the public highway.

Reason: To minimise danger, obstruction and inconvenience to users of the highway (policies T1, T6 and T8 of the London Borough of Lambeth Local Plan (2015)) and T8 of the Draft Revised Lambeth Local Plan (2020).

10. Prior to the first opening of each Medium, Large, and Major event(s) hereby approved, the following details shall be submitted to and approved in writing by the Local Planning Authority:

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• The provision to be made for cycle parking. The details shall include specification of cycle stands and their location; storage lockers for cyclists and details of how cycling parking will be promoted; • A review of the signage and way-finding; • A review of the taxi-drop-off.

All details shall be implemented in full accordance with the approved details prior to the first opening of the event.

Reason: To ensure adequate cycle parking is available on site and to promote sustainable modes of transport, ensure pedestrian and other highway users’ safety and amenity of the area (policies T1, T3, T6, Q2 and Q13 of the London Borough of Lambeth Local Plan (2015)) and T2, T3, T7, and T9 of the Draft Revised Lambeth Local Plan (2020).

11. The Major event hereby approved shall only occur within the purple boundary of the events site as shown on drawing number '5667/002/Large and Major Events Locations', and in no other part of the site whatsoever.

Reason: To mitigate the impact on the biodiversity value of the open space (policy EN1 of the London Borough of Lambeth Local Plan (2015)), and EN1 of the Draft Revised Lambeth Local Plan (2020).

12. No non-road mobile machinery (NRMM) shall be used on the site unless it is compliant with the NRMM Low Emission Zone requirements (or any superseding requirements) and until it has been registered for use on the site on the NRMM register (or any superseding register).

Reason: To ensure that air quality is not adversely affected by the development in line with London Plan policy SI 1 and the Mayor's SPG: The Control of Dust and Emissions during Construction and Demolition.

13. Prior to first opening any event(s) proposed for other locations on Clapham Common that, as identified in the ecological impact assessment, are of higher ecological sensitivity and where the risks of adverse ecological harm are greater, then the applicant shall submit an updated ecological mitigation and management plan (EMMP) for these areas to the Local Planning Authority for approval. This (EMMP) shall detail measures to be put in place to mitigate any potential ecological implications of each Event within the areas identified above.

Reason: To ensure adequate mitigation or compensatory measures are in place to prevent harm to the biodiversity value of the open space (Policies Q22 and EN1 of the Lambeth Local Plan 2015 along with Policy G3 (Metropolitan Open Land) of the London Plan 2021) and Q22 and EN1 of the Draft Revised Lambeth Local Plan (2020).

14. Within 3 months of the major event hereby approved, the applicant shall submit a monitoring report to the Local Planning Authority for approval. The report shall include the following details:

Monitoring of the use of cycle parking (to include details of security and advertising / promotion (both in promotional materials, booking information and on site)).

Reason: To promote sustainable modes of transport and to minimise danger, obstruction and inconvenience to users of the highway (Policies Q2, Q13, T1, T3, T6, T7 and T8 of the London Borough of Lambeth Local Plan (2015)) and Q2, Q13, and T3 of the Draft Revised Lambeth Local Plan (2020).

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15. Prior to the first opening of the major event hereby approved, where track pads are to be used, details of the track pads including layout plans and detailed product specifications shall be submitted to the local planning authority for approval. All details shall be implemented in full accordance with the approved details.

Reason: In order to reduce the impact of heavy vehicle movements on the amenity grass, and to reduce recovery time for its reuse as public amenity space (Policies Q2, EN1 and PN5 of the London Borough of Lambeth Local Plan (2015)) and Q2, EN1, and PN5 of the Draft Revised Lambeth Local Plan (2020).

16. The noise monitoring locations for the major event shall include the locations as identified in appendix B of the ‘EventLambeth Guidance on the control of sound at out-door events (2016)’ and an additional noise monitoring station on the Notre Dame Estate, to be located at the point outside the residential property closest to the event site boundary, unless otherwise agreed in writing by the local planning authority.

Reason: In order to monitor the impact of noise on residential properties on the estate (Policy Q2 and PN5 of the London Borough of Lambeth Local Plan (2015)) and Q2 and PN5 of the Draft Revised Lambeth Local Plan (2020).

17. The major event shall not commence until an Event Site Management Plan and a Noise Management Plan has been submitted to the local planning authority for approval. The event shall occur in accordance with the approved documents.

Reason: To limit nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers or users of the area generally (policies Q2, ED7 and T6 of the London Borough of Lambeth Local Plan (2015)) and Q2, ED8, and T7 of the Draft Revised Lambeth Local Plan (2020).

18. Prior to the opening to the public of any event(s) hereby permitted, the applicant shall submit for the written approval of the LPA the following details:

A) Any impacts on the event(s) in relation to considerations of visitor management and public safety that derive from any applicable coronavirus-related law and/or government guidance (and if no such impacts are anticipated, a statement with reasons to that effect); and B) Where any impacts are identified at (A) above, any measures in addition to any measures that have previously been approved that are proposed to be put in place in order to manage/mitigate those impacts and if no such additional measures are proposed, an assessment of the adequacy of any existing approved measures in relation to visitor management and public safety.

The event(s) shall operate in accordance with any details approved pursuant to this condition (and for the avoidance of doubt a single submission made in respect of this condition may relate to more than one event).

Reason: To ensure safe management of visitors and that the development does not have a detrimental impact on the surrounding area including amenity and pedestrian/highway safety (Policies EN1; ED11; Q1; Q2; Q3; Q20, Q22 and T6 of the Lambeth Local Plan (2015)) and EN1; ED13; Q1; Q2; Q3; Q20, Q22 and T7 of the Draft Revised Lambeth Local Plan (2020).

Informatives Page 185

1. For the avoidance of doubt, the following terms have been used within this decision notice:

Build - the time from when the event is on-site, including the period to set up the items and equipment necessary to operate the event, running from arrival of items and equipment on site, to the "Event start". Event start - The start of the event being open to attendees. Event end - The end of the event being open to attendees. De-rig - the time ending with when the event is off-site, including the period to remove items and equipment, running from the "Event end" to completion of full site clearance.

Small Events - less than 1,000 attendees Medium Events - from 1,000 to 4,999 attendees Large Events - from 5,000 to 19,999 attendees Major Events - 20,000 attendees or more amd shall mean the Festival Republic event which is to occur between the 9th August 2021 and 6th September 2021.

2. Please contact our Environmental Health Team to make sure you meet all other requirements under the Control of Pollution Act 1974 and the Environmental Protection Act 1990.

3. As part of the licensing requirements, you are required to comply with the "Guidance on the control of sound at out-door events (2016)".

The maximum Music Noise Level (MNL) shall be 75dB L(A) eq 15 minutes (free field) outside any noise sensitive premises. The maximum low frequency Music Noise Level (LFMNL) shall be 90 dB L(C) eq 15 minutes (free field) outside any noise sensitive premises.

All other events will be expected to operate at lower sound levels, which will be determined on a case-by-case basis by EventLambeth Operations in consultation with approved acoustic consultants. All events shall be operated in accordance with the relevant Event Management Plans and Noise Management Plans as approved by the Local Planning Authority.

4. For information on the NRMM Low Emission Zone requirements and to register NRMM, please visit "http://nrmm.london/".

5. You are advised to monitor the numbers and modal splits of event attendees to support transport measures to be undertaken for future events.

6. You must operate events in accordance with the approved Tree Protection Plan (section 13 of the Clapham Common Events Report dated 18/12/2018) and not fix any items to trees using invasive methods.

7. The Council's Sustainability Officer has recommended that event organisers shall endeavour to comply with guidance provided within the Lambeth Green Events Guide

8. With regard to condition 9 above, it is requested that where possible, the use of delivery vehicles is consolidated and, the use of electric vehicles be considered.

9. The applicant is encouraged to work with Lambeth Cyclists to increase the numbers of people cycling to events and to provide secure cycle parking where possible. More information can be found at http://www.lambethcyclists.org.uk/

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10. TfL support the use of the funfair site (off street) as a holding site for delivery vehicles which arrived early or missed their delivery slot

11. The applicant should note that TfL has a scheme to introduce a new signalised pedestrian crossing on the A205 The Avenue near the junction with the A24 Clapham Common.

12. The footway and carriageway on the A3 Long Road and the A24 Clapham Common South Side must not be blocked during the installation and removal of infrastructure. Temporary obstructions during the works must be kept to a minimum and should not encroach on the clear space needed to provide safe passage for pedestrians or obstruct the flow of traffic on the A3 Long Road and the A24 Clapham Common South Side.

13. All vehicles associated with the works must only park/ stop at permitted locations and within the time periods permitted by existing on-street restrictions.

14. No skips or construction materials shall be kept on the footway or carriageway on the TLRN at any time. Should the applicant wish to install scaffolding or a hoarding on the footway whilst undertaking this work, separate licences may be required with TfL, please see, https://www.tfl.gov.uk/info-for/urban-planning-and-construction/highway-licences

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Appendix 2: List of consultees (statutory and Other Consultees)

Statutory and External Consultees Greater London Authority Ward Councillors Clapham Society Parks & Open Spaces Natural England London Ecology Unit London Wildlife Trust Transport Lambeth Transport for London Conservation & Urban Design Historic England Veolia Waste Lambeth Bioregional Design Out Crime Environment Agency Flooding - SUDS Thames Water Sewers Major Development Thames Water Regeneration Team Brixton, Clapham Areas Friends Of Clapham Common Clapham Business Improvement District (CBID) Brixton Town Centre Manager Clapham Common Management Advisory Committee (CCMAC) London Borough of Wandsworth Planning Policy Met Office And Licensing Arboricultural Officer Public Health, Animal Welfare, Pest Control Regulatory Services - Food Safety EHST Noise Pollution Marsha De Cordova MP

Neighbours Consulted

44 Alfriston Road Battersea SW116NN Conservative Group Office Lambeth Town Hall London SW2 Flat 18, The Woodlands London Sw4 0RJ 27 Comyn Road London SW111QB 46 Lessar Avenue London SW4 9HQ 36 Clapham Common North Side London SW4 0RW 19 Childebert Road London SW17 8EY 31 Crescent Grove Clapham SW4 7AF 116 Clapham Common Westside London SW4 9ba 2B The Chase Clapham Common London SW4 0NH Flat 10 57 Orlando Road London SW4 0LH Page 188

40 Lillieshall Road London Lambeth SW4 0LP 20 Clapham Common Northside London SW4 0RQ 31, LILLIESHALL ROAD London SW4 0LN 8 The Polygon Clapham Common London SW4 0JG 85 Wroughton Road LONDON SW11 6AS 99 Sugden Road LONDON SW11 5ED 8A Windmill Drive London SW4 9DE 51D Lillieshall Road London SW4 0LW 21 Lambourn Road London SW4 0LS The Open Spaces Society 25A Bell Street Henley-on-Thames RG9 2BA 24 Orlando Road CLAPHAM London SW4 0LF 117 Thurleigh Road Balham SW12 8TY 89 Clapham Common North Side London SW4 9SF 20A Grandison Rd London SW11 6LW Lock N Load Events, Royal Oak Yard Sycamore Court London SE1 3ER 62 Nansen Road London SW11 5NT 20 Clapham Common Northside London SW4 0RQ 42 Alfriston Road London SW11 6NN 21 Shandon Road London SW4 9HS 20 Macualay Road London SW4 0QP 514P Wandsworth Rd London SW8 3LT 78 Park Hill London Sw4 9pb 16 Grafton Square Clapham Sw40da 27 Longbeach Road London SW11 5SS 24 The Chase THE CHASE London SW4 0NH 39 Glycena Road Battersea London SW11 5TP 91A Clapham Common North Side London SW4 9SG 20 Pickets Street London SW128QB Flat 3, 29 Clapham Common Northside London SW4 0RW 5 Navy Street London SW46ET 46 The Chase London SW40NH 42 Alfriston Road London SW11 6NN 27 The Chase London SW4 0NP Flat 25 31 Macaulay Road London SW4 0QP 81 Sisters Avenue London SW11 5SW Flat 17, 5 Porteus Place Macaulay Walk Clapham SW4 0AP 34 Clapham Common North Side London Sw4 0rw 56 Jedburgh St London Sw11 5qb 210 Broomwood Road London SW116JY 180 Broomwood Road London SW11 6JY 11 Hunter Close Balham London SW12 8EQ 7 Jedburgh Street London SW11 5qa 79 Kyrle Road Battersea SW11 6BB 42 Alfriston Road London SW11 6NN 94 Sugden Road Battersea SW11 5EE The Spinney Windmill Drive London SW4 9DE Flat A Hallam House 7 Windmill Drive London SW4 9DE Flat B Hallam House 7 Windmill Drive London SW4 9DE Residential Accommodation Ye Olde Windmill Windmill Drive London SW4 9DE 5 Hallam House 7 Windmill Drive London SW4 9DE Page 189

Flat 6 10 Windmill Drive London SW4 9DE Flat 1 10 Windmill Drive London SW4 9DE Flat 1 3 Windmill Drive London SW4 9DE Flat 2 6 Windmill Drive London SW4 9DE Flat 4 6 Windmill Drive London SW4 9DE The Windmill On The Common Windmill Drive London SW4 9DE Flat 8 9 Windmill Drive London SW4 9DE Flat 3 9 Windmill Drive London SW4 9DE 9A Windmill Drive London SW4 9DE Flat 5 6 Windmill Drive London SW4 9DE 10A Windmill Drive London SW4 9DE Flat 5 10 Windmill Drive London SW4 9DE Flat 3 10 Windmill Drive London SW4 9DE Flat 6 9 Windmill Drive London SW4 9DE Flat 4 9 Windmill Drive London SW4 9DE 2 Windmill Drive London SW4 9DE Flat 3 Heathview 8 Windmill Drive London SW4 9DE Flat 9 9 Windmill Drive London SW4 9DE 8A Windmill Drive London SW4 9DE Flat 4 10 Windmill Drive London SW4 9DE Flat 2 10 Windmill Drive London SW4 9DE Flat 2 3 Windmill Drive London SW4 9DE Flat 3 3 Windmill Drive London SW4 9DE Flat 7 9 Windmill Drive London SW4 9DE Flat 5 9 Windmill Drive London SW4 9DE Flat 2 9 Windmill Drive London SW4 9DE Flat 1 9 Windmill Drive London SW4 9DE Holly Lodge 5 Windmill Drive London SW4 9DE Flat 3 6 Windmill Drive London SW4 9DE Flat 5 8 Windmill Drive London SW4 9DE 9 Hallam House 7 Windmill Drive London SW4 9DE 10 Hallam House 7 Windmill Drive London SW4 9DE 8 Hallam House 7 Windmill Drive London SW4 9DE Garden Flat 1A 8 Windmill Drive London SW4 9DE Flat 2 Heathview 8 Windmill Drive London SW4 9DE Flat 1 Heathview 8 Windmill Drive London SW4 9DE 11 Hallam House 7 Windmill Drive London SW4 9DE 7 Hallam House 7 Windmill Drive London SW4 9DE 6 Hallam House 7 Windmill Drive London SW4 9DE 4 Hallam House 7 Windmill Drive London SW4 9DE 3 Hallam House 7 Windmill Drive London SW4 9DE 2 Hallam House 7 Windmill Drive London SW4 9DE 1 Hallam House 7 Windmill Drive London SW4 9DE Flat 6 6 Windmill Drive London SW4 9DE Flat 1 6 Windmill Drive London SW4 9DE 1 Windmill Drive London SW4 9DE 4 Windmill Drive London SW4 9DE Flat 6 8 Windmill Drive London SW4 9DE Flat 4 Heathview 8 Windmill Drive London SW4 9DE 60 Gaskarth Road London SW12 9NL Page 190

16 Old Town Clapham London SW4 0JY 44 Clapham Common West Side London SW4 9AR 94 Kyrle Road London SW11 6BA Gaskarth Road London SW12 9NN 78 London Sw116nw 110 Gaskarth Road London SW12 9NW LB Wandsworth Wandsworth SW18 1DA 45 Rodenhurst Road London SW4 8AE 193 Victoria Rise London SW4 0PF 25 Malwood Road London SW12 8EN 8 Altenburg Gardens London SW11 1JJ 22 Criffel Avenue London SW2 4AZ 109A Sugden Road London SW11 5ED 91 Narbonne Avenue London SW4 9LQ 36 Rodenhurst Road London SW4 8AR 56 Clapham Common Westside London SW4 9AT 20 Malwood Road London SW12 8EN 99 Sugden Road Battersea SW11 5ED 94 Clapham Common Northside London SW49SG 90 Abbeville Road London SW4 9NA 14 Welmar Mews London Sw4 7dd 15 Tregarvon Road London SW11 5QD 34A Hayter Road London SW25AP 4 Sudbrooke Road London SW12 8TG 78 Tennyson Street London Sw8 3sx 42 Muncaster Rd London Sw11 6nu 5 Shaftesbury Mews Clapham SW49BP 46 Lessar Avenue London SW4 9HQ 21 Kyrle Road London SW116BD Flat 2 31 Hemberton Road London SW9 9LF 34 Clapham Common North Side London Sw4 0rw 47 Rudloe Road London SW12 0DR 33 Red Post Hill London SE24 9JJ 14 Malwood Road London Sw12 8en 35, Churchmore Road London SW16 5UY PO Box 25035 London SW4 0WP 32 Broxash Road London Sw11 6ab 35, Clapham Common South Side London SW4 9BS 28 Salcott Road London Sw11 6de 82 Woodfield Avenue SW16 1LD Flat 1 8 Englewood Road London SW12 9NZ 60C Clapham Common South Side, Clapham London SW4 9DA 3 Windmill Drive Clapham SW4 9DE 18 Elms Road London Sw4 9ex 1 Lessar Avenue London SW4 9HL Flat 4 1 Wharncliffe Mews London SW4 8DP 33 Heron House SW 11 4DU London SW11 4RJ 111 The Chase London Sw40nr 180 MacMillan Way London SW176AU 11B Clapham Common South Side London SW4 7AA Page 191

2 Poynder's Road Clapham London SW4 8NX 11 Houghton Square London SW99AN 85 Abbeville Road Clapham London SW4 9JL 3 Woodland Common Rodenhurst Road London Sw48ab 61A Balham Park Road London SW128DZ Flat 4, 43 Cavendish Road London Sw120bh 75 Victoria Rise Lambeth SW4 0pb 4 Thurleigh Court Nightingale Lane Balham Sw12 8ap 44 Eland Road London SW11 5JY 16 Malwood Road London SW12 8EN 18 Elms Road London SW4 9EX 64 Elms Crescent London SW4 8QY 41 Longbeach Road London Sw11 5SS 43A Lynette Avenue London SW49HF 7 Lessar Avenue London SW4 9HL 5 Broxash Road London SW11 6AD 60C Clapham Common South Side London Sw4 9da 69 The Chase London SW4 0NP 54 Riggindale Road London SW16 1QJ 193 Victoria Rise London SW4 0PF 14 Lessar Avenue London SW4 9HJ 52 The Chase London SW40NH 24 Sugden Road London SW11 5EF Flat 3 1 Fairbourne Road London SW4 8DG 7 Broxash Road London Sw11 6ad 16 Cresset Street London SW4 6BP 100 Bonneville Gardens London SW4 9LE 91 Clapham Common North Side London SW4 9SG 143 Hambalt Road London SW4 9EL G413 Du Cane Court London SW17 7JR 93 Marney Road London SW11 5EW 71 Narbonne Avenue London Sw4 9jp 51 Roseneath Rd London Sw11 6 Ag 18 Lynette Avenue London SW4 9HD 141 Taybridge Road London SW11 5PY 19 Klea Avenue London SW4 9HG 14 Clapham Common Westside London SW49AJ 3 Klea Avenue London SW4 9HG 1 Orlando Road London Sw4 0le 22 Alfriston Road LONDON SW11 6NN 48 The Chase, London London SW4 0NH 59 Elms Road Clapham London SW4 9EP 36 Clapham Common Southside London Sw49Bs 21A Lavander Gardens Lonfon SW11 1DH 23 Abbeville Road London SW4 9LA 9 Killyon Rd London SW8 2XS Flat 202 Maritime House Old Town London SW4 0JW Basement Flat 120 Cavendish Road London Sw120de 27 Mayflower Road London Sw9 9jy 17 Malwood Road London SW128EN Page 192

18 Lynn Rd London Sw12 9la 3 Rosebery Road London Sw2 4dq 32 Broxash Road London Sw116ab Flat 1 30 Altenburg Gardens London SW11 1JJ 52 The Chase London SW40NH Page 193

Appendix 3: List of relevant policies in London Plan, Lambeth Local Plan. Reference to SPGs, SPD and other relevant guidance

London Plan (2021)

GG1 Building strong and inclusive communities GG2 Making the best use of land GG3 Creating a healthy city GG5 Growing a good economy D8 Public Realm D14 Noise S1 Developing London’s social infrastructure S6 Public toilets E9 Retail, markets and hot food takeaways E10 Visitor infrastructure HC1 Heritage conservation and growth HC5 Supporting London’s culture and creative industries HC6 Supporting the night-time economy G1 Green infrastructure G3 Metropolitan Open Land G4 Open Space G6 Biodiveristy and access to nature G7 Trees and woodlands SI 1 Improving air quality SI 2 Minimising greenhouse gas emissions SI 7 Reducing waste and supp SI 12 Flood risk management T1 Strategic approach to transport T3 Transport capacity, connectivity and safeguarding T4 Assessing and mitigating transport impacts T5 Cycling T6 Car parking T7 Deliveries, servicing and construction

Lambeth Local Plan (2015)

Policy D2: Presumption in favour of sustainable development Policy D3: Infrastructure Policy ED7: Evening economy and food and drink uses Policy ED11: Visitor attractions, leisure, arts and culture uses Policy T1: Sustainable Travel Policy T2: Walking Policy T3: Cycling Policy T4: Public Transport Infrastructure Policy T6: Assessing impacts of development on transport capacity Policy T7: Parking Policy T8: Servicing Policy EN1: Open Space and biodiversity Policy EN4: Sustainable design and construction Page 194

Policy EN5: Flood risk Policy EN6: Sustainable drainage systems and water management Policy EN7: Sustainable Waste Management Policy Q1: Inclusive Environments Policy Q2: Amenity Policy Q3: Community safety

Draft Revised Lambeth Local Plan (2021) ED8 Evening Economy and Food and Drink Uses ED13 Visitor Attractions, Leisure, Arts and Culture Uses T1 Sustainable Travel T2 Walking T3 Cycling T4 Public Transport Infrastructure T7 Parking T8 Servicing EN1 Open Space and Biodiversity EN5 Flood Risk EN7 Sustainable waste management Q1 Inclusive environments Q2 Amenity Q3 Community Safety Q4 Public Art Q5 Local Distinctiveness Q6 Urban design: public realm Q10 Trees Q20 Statutory Listed Buildings Q22 Conservation Areas

Relevant Supplementary Planning Guidance (SPG’s) from the GLA:

Accessible London: Achieving and Inclusive Environment SPG (2014)

Culture and Night-Time Economy SPG (2017)

Planning for Equality and Diversity in London SPG (2007)

Local Guidance / Supplementary Planning Documents (SPDs)

Refuse & Recycling Storage Design Guide (2013)

Waste & Recycling Storage and Collection Requirements (2013)

Page 195

Appendix 4: Clapham Common Application Site Events Schedule 2021 (Lambeth side of the common only)

Event Type Size Start Date End Date Duration Location (days)

Runthrough Commercial Small 8/5/21 8/5/21 1 Across borough

Street Child General Small 15/5/21 16/5/21 2 Across borough Spring Sprint

Luna Commercial Medium 27/5/21 1/6/21 6 Events site Cinema

Runthrough Commercial Small 16/6/21 16/6/21 1 Across borough

Runthrough Commercial Small 21/7/21 21/7/21 1 Across borough

Runthrough Commercial Small 15/8/21 15/8/21 1 Across borough

Festival Commercial Major 9/8/21 6/9/21 29 Events site Republic

Trinity’s Community Small 12/9/21 12/9/21 1 No infrastructure Family Walk and Fun Day

Colourscape Community Small 7/9/21 23/9/21 17 Across borough

London to Commercial Medium 19/9/21 19/9/21 1 Across borough Brighton Cycle

Bandstand Community Small 18/9/21 18/9/21 1 Bandstand Beds Harvest Feast

Race for Community Medium 1/10/21 2/10/21 2 Across borough Life/Pretty Muddy

Page 196

Appendix 5: Wider event schedule (entire common)

Event Type Size Start Date End Date Duration Location (days)

George Community Small 27/3/21 4/5/21 39 Funfair Site Irvin’s Funfair

Runthrough Commercial Small 8/5/21 8/5/21 1 Across borough

Street Child General Small 15/5/21 16/5/21 2 Across borough Spring Sprint

Luna Commercial Medium 27/5/21 1/6/21 6 Events site Cinema

Runthrough Commercial Small 16/6/21 16/6/21 1 Across borough

Friendsfest Commercial Small 20/6/21 14/7/21 25 Wandsworth

Runthrough Commercial Small 21/7/21 21/7/21 1 Across borough

Runthrough Commercial Small 15/8/21 15/8/21 1 Across borough

Festival Commercial Major 9/8/21 6/9/21 29 Events site Republic

Trinity’s Community Small 12/9/21 12/9/21 1 Potentially no Family Walk infrastructure and Fun Day

Colourscape Community Small 7/9/21 23/9/21 17 Across borough

London to Commercial Medium 19/9/21 19/9/21 1 Across borough Brighton Cycle

Bandstand Community Small 18/9/21 18/9/21 1 Bandstand Beds Harvest Feast

Halloween Commercial Small 27/9/21 9/11/21 44 Funfair Site Fair

Circus Commercial Medium 8/10/21 24/10/21 17 Funfair Site Extreme

Race for Community Medium 1/10/21 2/10/21 2 Across borough Life/Pretty Muddy

Winterville Commercial Medium 28/10/21 6/1/21 72 Wandsworth

Ice Rink Commercial Small 18/11/21 2/1/21 46 Lambeth Page 197

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