Catherine Carpenter Department: Planning Planning Strategy and Policy Team Our reference: LDD22/LDD16/HA01 London Borough of Lambeth Date: 14 December 2018 1st Floor Phoenix House 10 Wandsworth Road London SW8 2LL
By email: [email protected] [email protected]
Dear Catherine,
Statement of general conformity with the London Plan (Planning and Compulsory Purchase Act 2004, Section 24(4)(a) (as amended); Greater London Authority Acts 1999 and 2007; Town and Country Planning (Local Development) (England) Regulations 2012
RE: Draft Revised Lambeth Local Plan
Thank you for consulting the Mayor of London on the Draft Revised Lambeth Local Plan. As you are aware, all Development Plan Documents in London must be in general conformity with the London Plan under section 24 (1)(b) of the Planning and Compulsory Purchase Act 2004. The Mayor has afforded me delegated authority to make detailed comments which are set out below. Transport for London (TfL) have provided comments, which I endorse, and which are attached at Annex 1.
This letter sets out where you may need to amend existing and proposed policies and supporting text to be more in line with the current London Plan and the emerging Draft New London Plan.
The draft new London Plan The Mayor published his Draft London Plan for consultation on 1st December 2017 and the Minor Suggested Changes (following consultation) on 13 August 2018. The Examination in Public of the Draft London Plan will commence in January 2019 with publication anticipated in Winter 2019/20. Once published, the new London Plan will form part of the Lambeth’s Development Plan and contain the most up-to-date policies.
The Lambeth Local Plan is required to be in general conformity with the current London Plan, however any policies that diverge from the Draft New London Plan will become out of date as the Draft New London Plan gains more weight as it moves towards publication. In addition, the Draft New London Plan and its evidence base are now material considerations in planning decisions.
General The Mayor recognises this is a partial review of Lambeth’s existing Local Plan and welcomes the overall approach to growth and development in the draft document. However, set out below are some suggestions and other representations to clarify and improve upon some policy areas and to ensure the document is more aligned to the draft new London Plan.
On 8 December 2017, the Mayor provided comments (reference: LDF22/LDD15/CG01) on Lambeth’s earlier consultation on the Local Plan Review 2017, making suggestions as to how the Local Plan should progress in light of the emerging Draft New London Plan. This letter follows on from that earlier advice.
Housing delivery The Mayor welcomes the inclusion of Lambeth’s new London Plan housing target of 1,589 dwellings per annum and the inclusion of the borough’s housing trajectory along with indicative housing requirement figures for the five designated neighbourhood planning areas. Recognition of the strategic 50% affordable housing target as set out in the Draft New London Plan is also very welcome. Lambeth has performed well against London Plan housing targets and has, on average, exceeded those targets over the last few years.
Paragraph 1.25. It is noted that there are inconsistencies in the naming of some district centres when compared with the existing and Draft New London Plan. Lambeth should consider renaming these to provide consistency with the draft London Plan and adjoining borough Local Plans. For example, Camberwell Green in Lambeth’s Draft Local Plan is called Camberwell in the existing and Draft New London Plan and Southwark Local Plan.
Paragraph 2.110. The Mayor welcomes Lambeth’s commitment in providing digital infrastructure, such as borough-wide Wi-fi to support businesses, visitors and residents, in line with London Plan policy 4.11 and draft new London Plan policy SI6. At paragraph 2.125 the Mayor also welcomes the intention of Lambeth’s to promote arts and culture through its Creative and Digital Industries Strategy.
Policy D1 Part b), Policy PN1 Waterloo and South Bank, Policy PN2 Vauxhall, Paragraphs 11.38, 11.41and Annex 3. Lambeth’s Draft Local Plan describes Waterloo and Southbank and Vauxhall as town centres. Annex 3 of the Local Plan notes that the designation of Waterloo and South Bank as a Metropolitan Centre needs the agreement of the Mayor of London. The Mayor has no evidence that this area is functioning or has the potential to function as a Metropolitan Centre. Lambeth is welcome to include pro-active policies to encourage town centre uses in this area, in line with its designation as an Opportunity Area and Central Activities Zone (CAZ). However, the new town centre uses should not undermine the current function of Lower Marsh/ The Cut as a CAZ retail cluster that tends to function as a local centre and the arts, cultural and entertainment specialist cluster of the South Bank. In recognition of its CAZ location and function Lambeth may also wish to apply an appropriate CAZ designation for the Waterloo and South Bank area and to reflect its nature and the Council’s vision for the area.
Vauxhall is not recognised in Annex 3 of the draft Local Plan as a town centre, however draft policy D1 of the Local Plan groups Vauxhall with existing district and major centres. Vauxhall Street/Jonathan Street is identified as a local centre in Annex 3 of the Local Plan. It should be recognised that Vauxhall is proposed to be designated in the Draft New London Plan as a CAZ retail cluster in Table A1.1. The retail function and potential of Waterloo and South Bank and Vauxhall should be recognised in a way that reflects their location in the CAZ.
Policy D4. The inclusion of public transport improvements in the list of S106 planning obligations is very welcome and reflects the approach set out in current London Plan Policy 8.2 and Policy T9 of the Draft New London Plan. The inclusion of affordable workspace is also welcome and reflects Draft New London Plan Policy DF1.
Policy H2 Delivering affordable housing – Part b) and paragraph 5.11. Lambeth should note that the Mayor has strengthened his approach to ensure affordable housing for major developments is provided on site. Draft Policy H5, Part B states that affordable housing must only be provided off-site or as a cash in lieu contribution in exceptional circumstances. However, in order to facilitate the delivery of small sites, Part C of Draft New London Plan Policy H6 states that where it is agreed by the borough, small housing developments (schemes providing up to 25 homes) may follow the Fast Track Route where they meet the relevant threshold level off-site or as an in-lieu payment. Lambeth should note the differences in approach to the provision of off-site and in lieu contributions towards affordable housing as they relate to major, minor and small housing development.
The Mayor encourages boroughs to seek affordable housing contributions on minor housing developments (less than 10 units) through a tariff-based approach (See draft Policy H2). Most recently in London, Camden and Richmond have both adopted a tariff-based approach to support affordable housing delivery based on local evidence of need and viability. In this regard, Lambeth should retain policy H2(a)(iii).
Paragraph 5.16 of the draft Local Plan states that ‘Where shared ownership is proposed…the council may cap the maximum household income of purchasers at £60,000 per annum…’ However, this does not align with the existing (paragraph 3.62) or Draft New London Plan which sets out at paragraph 4.7.8 that intermediate ownership products should be affordable to households on incomes of up to £90,000. Further information on the income caps is set out in the Mayor’s Annual Monitoring Report and where necessary the caps will be reviewed and updated.
Policy H3 Safeguarding existing housing part a) i). Lambeth should amend its approach that supports the amalgamation of units to create 3bed+ residential accommodation. Occupiers should firstly look to extend properties, in line with draft London Plan policy H2 to create larger units, instead of the proposed approach that would result in the loss of residential units. In addition, in line with the results of the London SHMA, Lambeth should be satisfied that resulting large units will be occupied by a family, and not sharers as is potentially identified in paragraph 4.12.2 of the draft London Plan. The proposed approach could frustrate the presumption in favour of small housing development and could also encourage the development of over-sized homes in the borough, that are not affordable to local residents in need of family housing. The policy should be amended to consider these matters and put in place measures to monitor the effects of this policy in line with draft London Plan paragraph 4.2.11.
Policy H3 Safeguarding existing housing part a) ii) and Policy S2 Part b). Both policies allow for the development of nursery/childcare provision that results in the loss of housing/housing floorspace. Draft Local Plan policy H3 allows the loss of a residential unit for childcare facilities whereas draft policy S2 has been amended to specifically prevent the loss of a residential unit. Draft policy H3 should be amended to reflect the new wording in draft policy S2 so that residential units are not lost.
Policy H5 Part b). The requirement of 30m2 of private amenity space per house and amendments to the draft policy should include some flexibility to optimise housing delivery whilst ensuring good quality amenity space is provided. The ability of a scheme to provide private amenity space within housing development will differ between individual schemes and planning policies should take into account site layout, orientation and other design factors and constraints with an intention to provide private amenity space for each dwelling that is usable and results in a balance of openness and protection as set out in Table 3.2 of the Draft New London Plan.
Policy H6 Residential conversions, part a). It is noted that Lambeth wishes to protect family dwellings under 150 sqm from conversions into smaller dwellings. The threshold of 150sqm is considered to be excessive and should be reviewed in line with evidence that reflects local need and affordability. Table 3.1 of the Draft New London Plan sets out the minimum internal space standards for new dwellings and a threshold of 150sqm goes beyond the minimum space standards for a 6 bed dwelling for occupation by up to 8 people.
Policy H7 Student Housing. Lambeth should note that the draft new London Plan takes a more proactive approach to delivering student housing noting that whether in Purpose Built Student Accommodation (PBSA) or shared conventional housing, housing needs of students is an element of the overall housing need for London determined in the 2017 London SHMA. There is a strategic need for 3,500 PBSA bed spaces annually across London (paragraph 4.17.2). The location of this need will vary based on higher education providers’ estate and expansion plans availability of appropriate sites, and changes in Government policy that affect their growth and funding.
Lambeth is home to two providers of higher education (King’s College London and Lambeth College) with another in very close proximity to the borough boundary, (London South Bank University). Proposed policy amendments should ensure that local and strategic need for student housing can be met.
Paragraph 5.70. This paragraph should also cross-reference wider housing amenity policies such as space standards and the requirements for affordable housing provision.
Policy H10 Gypsy and traveller needs. Draft New London Plan Policy H16 Gypsy and Traveller accommodation sets out a new, more comprehensive definition for Gypsies and Travellers. The Assessment of Gypsy and Traveller accommodation need in Lambeth: Bringing the evidence together (October 2017) was conducted prior to the publication of the Draft New London Plan and does not take into consideration the Mayor’s new definition.
While Lambeth has identified provision to meet the needs of Gypsies and Travellers falling within the Planning Policy for Traveller Sites (PPTS 2015) definition (for three pitches) at the Lonesome Way site, any additional need arising from the London Plan definition will not be planned for. Lambeth should assess if there is any additional demand for pitches in its borough, in line with the draft new London Plan definition and find additional capacity, if required.
Policy ED1 Offices. The Mayor welcomes the support and protection afforded to offices. He welcomes that large offices are directed to the CAZ, Opportunity Areas and major town centres, in line with London Plan policy 4.2, Annex 2 and draft London Plan policies SD1, SD4, SD5, E1 and Annex 1. Table A1.1 specifically identifies Brixton and Lavender Hill/Queenstown as town centres where small office space should be protected, and this too should be reflected in the Lambeth’s policy.
Policy ED2 Affordable workspace. The Mayor welcomes Lambeth’s draft policy on affordable workspace in order to support, in particular, creative and digital industries. However, it should ensure that the detailed requirements are viable and will not undermine the overall delivery of office floorspace and affordable workspace. In addition, the policy needs to be clear as to what type of employment space it is seeking to secure. In certain sections the approach appears to focus on traditional office space, all be it, co-working space as opposed to wider messy space, creative space and workshops.
In addition, a map of the proposed Brixton CEZ is required to understand the implications of the discounts on market rents outlined. Lambeth may want to move some of the text into a Supplementary Planning Guidance to enable more consideration to the proposed approaches and to align these with the Mayor’s emerging Cultural Strategy.
Policy ED3 Key Industrial Business Areas (KIBAs). This policy sets out that KIBAs are Lambeth’s Locally Significant Industrial Sites (LSIS). A list of acceptable uses within the KIBAs is set out in paragraph 6.22 of the draft Local Plan and includes new office space. Draft New London Plan Policy E4 sets out the uses which are acceptable in all of London’s industrial areas and excludes B1a office uses in order to preserve the industrial integrity of these protected areas.
Lambeth is a borough identified in the Draft New London Plan (Table 6.2) required to ‘retain capacity’ of its designated industrial land, and as such, whilst it is acknowledged there are existing B1a uses in the KIBAs, proposals for additional B1a uses in protected industrial areas should be resisted. Furthermore, new office development should be directed to the CAZ, OAs and town centres in line with London Plan policy 4.2 and Annex 2 and draft London Plan policies SD1, SD4, SD5, E1 and Annex 1 and Lambeth Policy ED1.
In ‘retain capacity’ boroughs, Draft New London Plan Policy E4C applies the principle of no net loss of industrial floorspace capacity within designated LSIS. The Lambeth Local Plan proposes to de-designate 9.3ha of LSIS which has either been redeveloped or is in the pipeline to be redeveloped. In turn, through the draft Local Plan, Lambeth proposes to designate new LSIS to provide 4.7ha of industrial land. While the designation of additional LSIS at Acre Lane, Belinda Road, Knolly’s Yard and Parade Mews set out in Lambeth’s Review of Key Industrial and Business Areas (2018) are welcome in affording a greater level of protection, it is noted that they are currently in industrial use and are considered to be non-designated industrial land. This means that there would be no net gain of industrial land or capacity secured through the newly proposed designations. The proposed strategy could result in the net loss of 9.3ha of industrial land. The loss of this quantum of industrial land will only be considered acceptable where it is evidenced through a process of intensification, the overall approach would lead to no overall net loss of industrial capacity including storage and warehousing and other uses set out in Draft New London Plan Policy E4, with the appropriate provision of yard space for servicing as set out in Draft New London Plan Policy E7. The Mayor supports Lambeth’s approach to the intensification of industrial uses; however, it should develop a more detailed approach to identify industrial capacity. Some of the KIBAs have no industrial uses for example Abbeville Mews, which also includes residential uses. Lambeth should clearly set out which sites contain industrial activities and this capacity should clearly be protected. Lambeth should then review the KIBAs to identify the potential to increase industrial floorspace capacity, not just site coverage. This approach should demonstrate no net loss of industrial capacity.
Knolly’s Yard – The Mayor supports the designation of Knolly’s Yard as LSIS (KIBA) and recognises the difficulties of access to this site as evidenced in Lambeth’s Review of Key Industrial and Business Areas 2018. It is understood that the introduction of residential on the site would enable delivery of necessary road/rail infrastructure changes which in turn could enable effective use of the site for both industrial and residential uses. The introduction of residential uses on the site could be achieved through a process of intensification and/or consolidation of industrial uses in accordance with Draft New London Plan Policy E7. Due to the site peculiarities and difficulties associated with access it is advised that Lambeth should consider including the site as an allocation, highlighting the requirements and priorities for delivering the site.
Policy ED4 Non-designated industrial sites. Non-designated industrial sites make up 36% of London’s overall industrial capacity and therefore makes a significant contribution to the functioning of London. The introduction of mezzanines is no longer considered to be a form of industrial intensification in the Draft New London Plan (suggested minor changes) Policy E7 and should be removed from part a) of the Lambeth draft policy.
Policy ED8 Evening economy and food and drink uses. Policy HC6A of the Draft New London Plan states that boroughs should develop a vision for the night time economy, supporting its growth and diversification, in particular within strategic areas of night-time activity as set out in Table A1.1. Table A1.1 identifies six areas of night time activity in Lambeth. The South Bank is classified as an area of international or national significance, while Brixton, Streatham, Lower Marsh/The Cut and Vauxhall are all classified as areas of regional or sub- regional significance. As such these designations should be recognised in Lambeth’s policy or supporting text.
Air Quality – Lambeth’s Draft Local Plan at paragraph 9.3 identifies the borough’s five Air Quality Focus Areas but does not set out implications for development proposals falling within these areas. Lambeth should follow the guidance in Policy SI1 of the Draft New London Plan which sets out that development proposals within AQMAs should incorporate design solutions which prevent or minimise exposure to existing air pollution and make provisions to address local problems of air quality. Furthermore, Opportunity Areas, such as Vauxhall Nine Elms Battersea and Waterloo should adopt an Air Quality Positive approach that actively reduces air pollution in accordance with Draft New London Plan paragraph 9.1.3 and within the CAZ practical air quality positive measures should be implemented to reflect the approach set out in Draft New London Plan Policy SD4.
Section 8 Transport and communications. TfL broadly support the Lambeth Local Plan. However, the Mayor objects to two key points. The first being the proposed flexibility in the application of minimum cycle parking standards and the second being the proposed parking requirements for commercial development. TfL have provided more detailed comments which are set out in Annex 1. TfL officers would be pleased to meet with Lambeth transport officers to discuss these points.
Policy EN1 Open space, green infrastructure and biodiversity. The Mayor welcomes the reference to the urban greening factor in his draft new London Plan. The Mayor encourages Lambeth to develop a local Urban Greening Factor that should be secured from minor developments and one which better reflects local circumstances.
Policy EN2 Local food growing and production. The Mayor welcomes the ambition of the Draft Local Plan to support local food growing and production in line with Draft New London Plan Policy G8 and Policy 7.22 of the current London Plan.
Policy EN3 and EN4 Decentralised energy and Sustainable design and construction. The Mayor welcomes Lambeth’s approach to promoting and supporting decentralised energy and sustainable design and construction in the Draft Local Plan.
Paragraph 9.21. The cross reference here should be to Draft New London Plan Policy SI2.
Policy Q2 Amenity part viii). The Agent of Change principle is set out in Draft New London Plan Policy D12 and not Policy D2.
Policy Q10 Trees. The Mayor welcomes Lambeth’s approach to the protection and enhancement of London’s urban forest which will contribute to meeting the target set by the Mayor to increase tree canopy cover in London by 10% by 2050.
Policy Q11 Building alterations and extensions and Policy Q14 Development in gardens and on previously developed rear land with no street frontage. The Draft New London Plan elevates the role that small housing developments can play in delivering the homes that London needs, proactively supporting the delivery of new sites by diversifying supply. The small housing sites target for Lambeth is 654 homes per annum. The Draft New London Plan acknowledges that accommodating this growth may lead to a change of character in some areas as London evolves. Draft New London Plan Policy H2, B, 2) provides a platform for boroughs to formulate design codes to achieve and manage how this happens. Lambeth should take a more proactive approach to building alterations, extensions and garden development in those areas where the presumption in favour of small housing developments apply. Both policy Q11 and Q14 should be amended, taking account the presumption in favour of small housing development. Further amendments to Policy Q14 should also note that Draft New London Plan Policy H2 Part D, sets out that no more than 50% of an entire curtilage should be covered by buildings (an approach which is aligned with the Government’s permitted development rights for a household). In this regard, as per the 30smq garden requirement mentioned above, Lambeth should review this approach.
Policy Q19 Westminster World Heritage Site. The Mayor welcomes the recognition and importance that Lambeth has given to the Westminster World Heritage Site.
Policy Q26 Tall buildings and Annex 11. Following the report of the joint ICOMOS/ICCROM Reactive Monitoring Mission to the Westminster World Heritage Site (WHS) and the recommendations of the World Heritage Committee in 2017 in regard to the development of tall buildings in the Vauxhall area, the borough should consider if the extent and height guidance for the areas identified in the Vauxhall tall buildings map in Annex 11 and related Policy Q26 is sufficiently sensitive to the impact of new tall buildings on the Outstanding Universal Value of the World Heritage Site. In particular, the borough should consider if there is sufficient justification to designate the land to the northwest of the Wandsworth Road along the river Thames as an area appropriate for further tall building development, given its visual proximity to the WHS, it being within the Thames Policy area and the requirements of Draft New London Plan Policy D8C parts 1e-f and 3a.
Policy Q27 Basement development. The Mayor welcomes Lambeth’s approach to protect the amenity of residents from basement developments. He is also particularly keen to ensure basement developments do not harm the local environment.
Paragraph 11.37. It should be recognised that Table 2.1 of the Draft New London Plan sets out indicative guidelines for new homes and jobs in London’s Opportunity Areas. The indicative guidelines are that Lambeth should contribute towards the Vauxhall Nine Elms Battersea Opportunity Area to deliver 18,500 new homes and 18,500 new jobs and this should be recognised in the Draft Local Plan.
Site allocations/General. The list of site allocations in the Draft Local Plan are clear and concise. However, site tables lack information relating to some designations, including those for biodiversity, open space and others. Industrial capacity should be retained on those sites where it is identified as an existing use.
Policy PN3 Brixton. It should be noted that Brixton and Lambeth’s other town centres (of regional significance) are identified in Table A1.1 of the Draft New London Plan, containing information, including those relating to office guidelines, strategic location and night-time classification. Information contained in Table A1.1 should be reflected in Lambeth’s area-based policies wherever they relate to town centres or retail clusters.
Lambeth’s successful bid in designating Brixton as a Creative Enterprise Zone (CEZ) should be taken forward in the Local Plan by providing maps showing the extent of the CEZ boundary, making clear distinctions between affordable workspace and low-cost business spaces and differentiate between cultural uses that are underpinned by policies which seek to protect and / or re-provide cultural spaces and affordable workspace. It is understood that as being designated a CEZ in accordance with the London Plan, Lambeth will be working closely with the Mayor’s Culture Team. The Culture Team will be publishing guidance in Spring 2019 that will help boroughs bring forward cultural development in their area.
Policy PN3 Part c) and Policy PN4 Part e). While the first part of the policies seek to promote the growth and diversity of the night-time economy they state further on that ‘no more bars (A4) will be permitted’. A more flexible approach which seeks to diversify the night time offer would better reflect the Mayor’s ambition to promote London as a 24-hour city and would better capitalise on Brixton’s NT2 status and the fact that the centre is well served by the night tube. Amendments to Lambeth’s Policies PN3 and PN4 should take into account the approaches set out in Policies HC6 and SD6B of the Draft New London Plan which recognise that diversification of town centre uses can help to reduce cumulative impacts arising from high concentrations of licensed premises. Policy SD6B of the Draft New London Plan further supports the diversification of town centres in response to the challenges and opportunities brought about by multi-channel shopping and changes in technology and consumer behaviour. The Mayor encourages greater collaborative approaches through strategic and local partnership working to develop strong, resilient and adaptable town centres in accordance with Draft New London Plan Policy SD9. PN3 Part e) and PN7 Part d) iii). The Mayor welcomes the approach to supporting the Creative Enterprise Zones in Brixton through the provision of affordable workspace for the creative and digital industries. Policies should also seek the protection, re-provision and the use of necessary planning obligations to protect against the loss of these types of spaces. Lambeth should work with the Mayor’s Culture Team to determine whether the approach to Norwood High Street can be integrated into the designation of Brixton as a CEZ. As stated earlier a map clearly showing the extent of the proposed CEZ boundary should be provided.
Site 10 – 8 Albert Embankment. This allocation proposes to introduce an element of residential within the LSIS boundary of the site. This would be considered acceptable only where it is demonstrated that through a process of intensification of remaining industrial uses on site that there would be a net increase (or at the very least, no net loss) of industrial floorspace capacity within the LSIS boundary in accordance with Draft New London Plan Policies E4 and E7. Where residential use is introduced within the site, active frontages should be maximised onto the public facing sides of development proposals and where appropriate, wrapping around inactive frontages in accordance with the qualitative design aspects set out in Table 3.2 of the Draft New London Plan. Residential uses may therefore be considered more acceptable at ground floor level on non-public facing sides of proposed development. Pre-application advice provided by GLA officers regarding potential development of the site, indicated support for plans for a Fire Museum and for tall buildings, of a scale which respects the visual proximity of the Westminster World Heritage Site as stated in our earlier comments regarding Policy Q26 Tall buildings and Annex 11.
Site 12 Land bounded by Wandsworth Road to the west, Parry Street to the north, Bondway and the railway viaduct to the east SW8. The supporting text/table for this site allocation indicates that there is existing warehousing uses (B8) on the site. Lambeth is a ‘retain capacity’ borough for industrial uses and should therefore adopt a ‘no net loss’ approach in safeguarding existing industrial capacity in line with Draft New London Plan Policy E4 and therefore the loss of any warehousing floorspace through redevelopment should be re-provided.
I hope these comments inform the development of the Lambeth Local Plan. If you have any specific questions regarding the comments in this letter, please do not hesitate to contact Hassan Ahmed on 020 7983 4000 or at [email protected].
Yours sincerely
Juliemma McLoughlin Chief Planner
Cc Florence Eshalomi, London Assembly Constituency Member Nicky Gavron, Chair of London Assembly Planning Committee National Planning Casework Unit, DCLG Lucinda Turner, Tf
Annex 1 – Transport for London comments
Draft Revised Lambeth Local Plan October 2018; TfL Comments
Generally, the revisions to the Lambeth Local Plan in transport terms are supported, being in broad accordance with draft London Plan (DLP) and Mayor’s Transport Strategy (MTS) policy and direction of travel. Specific comments are set out below, either where the Local Plan could be improved in respect of, or is at variance with, the DLP and MTS, or where specific wording would support determination of current major planning applications in the borough and/or TfL’s statutory transport functions.
Paragraph 2.36, page 23 This paragraph states that public transport infrastructure is less good for those with disabilities/access needs. Whilst this is acknowledged for some rail and London Underground (LU) services (given the historic nature of the infrastructure), all bus services in the borough are accessible, so the text could be amended to reflect this fact. People with disabilities are more likely than other Londoners to rely on active travel and public transport, and are less likely to have access to or use a car. Support for increasing step-free access at stations through developer funding could be mentioned here, in particular at key interchanges such as Waterloo, which for which the LU platforms are only partially step-free and where there are development opportunities in the area that could deliver improvements in this respect.
Paragraph 2.38, page 24 ‘Thameslink’ National Rail (NR) services between Herne Hill and Blackfriars are also crowded, more so than to/from Victoria. The plan therefore could also support improvements to the ‘Wimbledon loop’ Thameslink services, for example by increasing frequencies from the current 2 trains per hour on the loop, which is below TfL’s own ‘turn up and go’ ‘metro’ level of at least four trains per hour. This is currently a matter for the Department for Transport and Network Rail, however.
Support for platform lengthening at Clapham High Street and Wandsworth Road to allow Victoria trains to call there appears at odds with the statement that Herne Hill to Victoria trains are crowded.
Crossrail 2, which would relieve Clapham Junction to Waterloo trains, as well as the Victoria and Northern lines and the NR/LU interchange at Vauxhall, could be mentioned here as a key transport investment.
Paragraph 2.40, page 24 The paragraph cites 2011 census data for car ownership levels. More up-to-date figures can be made available on request from TfL, through the London Travel Demand Survey (LTDS).
Paragraph 4.17, page 68 This paragraph may need to be updated following any changes to the CIL Regulations/Planning Policy Guidance in respect of the requirement for a ‘Reg 123’ list and restrictions on pooling of planning obligations.
Policy ED8 Evening economy and food and drink uses e) and f), page 136 Restrictions on drive-through takeaways and ‘home delivery of food’ applications are strongly supported. These uses can often cause traffic congestion and road safety issues, and
impact on pedestrian and cycle movement on the Transport for London Road Network (TLRN) where TfL is the highway authority, so borough support in opposing them in inappropriate locations is welcomed.
Paragraph 6.56, page 137 As per comment above, opposition of drive-through takeaways is strongly supported, and is fully in line with DLP and MTS policies to reduce car use in favour of walking, cycling and public transport.
Policy T1 Sustainable travel e), page 177 ‘Access’ could be better/more specifically defined here and/or in the supporting text – it could be construed as meaning ‘access to and from the site’ or ‘access for people with mobility impairment’. In reality, the policy is probably aimed at both.
Policy T1 Sustainable travel g), page 177 This is strongly supported, however to strengthen further, the Mayor’s ‘Vision Zero’ target (no KSIs on London’s roads by 2041) could be specifically cited here or in the supporting text.
Paragraph 8.8, page 180 This clear statement of intent with regards to planning obligations is welcomed. However, it could be strengthened further by specifically mentioning that improvements in physical access to the public transport and street network will be sought.
Policy T2 Walking page 182 The policy could cite Legible London signage provision/refresh of existing signs will be sought through new development.
The Mayor’s Healthy Streets Approach could be cited/briefly summarised in the supporting text, as Policy T2 helps deliver the Healthy Streets objectives directly.
Policy T3 Cycling h) and paragraph 8.20 page 184/186 Initial free membership of the Cycle Hire scheme, ideally for 3 years, for each dwelling in new residential developments should be included here. The Council are already securing such a provision in some recent developments, via the s106 agreement. Encouragement of business accounts1 for commercial occupiers could also be mentioned here.
Paragraph 8.18, page 185 This paragraph seeks flexibility in applying DLP cycle parking standards. The standards have for some time been minimum standards, which means that they are a requirement. The DLP is clear that meeting the spirit of the standards is the aim, so flexibility should be about site constraints and innovation in delivery rather than reducing numbers, for example delivering more cycle parking in the public realm or on mezzanines and higher up floors if basement space is highly constrained. We are concerned with the proposal for reduced quantums of cycle parking linked to ‘first occupation’ as there is no tested mechanism for monitoring and delivering increases should demand exceed supply. Therefore TfL objects to this proposal. The TfL London Plan team would be happy to meet with Lambeth transport officers to discuss this.
Policy T4 Public transport infrastructure, page 187
1 https://tfl.gov.uk/modes/cycling/santander-cycles/business-accounts Specific mention of the need for development to facilitate/deliver step-free access to the Bakerloo line northbound platform and Northern line at Waterloo should be included in the policy wording here (e.g. either in sub paragraph ii) or vi).
Crossrail 2, more specifically support for the proposal, should be cited here. Although there are no planned stations in the borough, it will have a transformational impact on public transport capacity in Lambeth, by relieving NR services between Clapham Junction, Vauxhall and Waterloo, the NR/LU interchange at Vauxhall, Jubilee line at Waterloo and the Victoria and Northern lines through the borough.
Support for the MTS proposal for TfL to take over suburban NR services could be included in the supporting text.
Certain proposals in the policy ‘list’ are not actively being pursued by TfL e.g. new Overground station stops.
Policy T7 Parking, page 194 The deference to the car parking standards in the DLP is strongly supported, as is the application of more restrictive standards for lower PTAL areas in the borough (Sub policy b)).
Sub policy d) introduces a requirement to provide disabled Blue Badge (BB) car parking for 5% of the workforce. TfL objects to such high provision for BB parking given that demand is likely to be far lower than this caters for. Less than 3% of Londoners have BBs and of those many are not in the work force, i.e. they may be are older or disabled to the point where they cannot work. The total provision should be much less than 5% and in any event requires an evidence base to justify. Also, parts of Lambeth are in the CAZ which is particularly concerning in this regard. Requiring a high level of BB car parking creates problems on constrained sites, which could stifle development. Again, the TfL London Plan team would be happy to meet Lambeth transport officers to discuss this.
Sub policy b) iv) (page 195) should be amended to reflect the caveat in the DLP that car club provision is not appropriate in the CAZ (DLP policy T6.1 D).
The removal of the requirement for an average of 0.2 parking spaces per unit in the VNEB/NEV (paragraph 8.35, page 196) is supported.
Policy T9 Minicabs, taxis and, private hire vehicles and ride hail services, page 201 Promoting as opposed to managing these forms of transport needs to be carefully considered in the context of the Mayor’s DLP/MTS target that 80% of all trips should be undertaken by public transport, walking or cycling by 2041. Minicabs, taxis and, private hire vehicles and ride hail services fall under the ‘other’ 20%. Sub policy b) in particular could be interpreted as ‘encouraging’ these modes, so the wording of this paragraph should be reconsidered.
Paragraphs 10.20/10.21, page 244 Public realm improvements on the TLRN should accord with TfL Streets Toolkit/Streetcape Guidance2, and this may differ from local guidance, so a line on this should be included in the supporting text.
2 https://tfl.gov.uk/corporate/publications-and-reports/streets-toolkit More generally, public realm improvements should accord with the Healthy Streets Approach3, so this should be referenced here also.
Policy Q10 Trees, page 250 This policy could be strengthened by specifically citing protection of street trees. There have been recent examples in the borough where a development has led to a potential loss of street trees on the TLRN, which TfL generally objects to.
Paragraph 10.48, page 260 Typo - should read ‘London Cycle Design Standards’ rather than ‘London Cycle Demand Standards’.
Site 5 – Elizabeth House, York Road SE1, page 312 A requirement for redevelopment of this site to provide for step-free access to the Bakerloo (northbound) and Northern line platforms should be included.
Policy PN11 Upper Norwood, page 417 Reference to extension of Tramlink to Crystal Palace is inconsistent with changes proposed elsewhere e.g. page 14 where it is deleted. This project is not actively being progressed by TfL.
Infrastructure Delivery Plan (IDP) TfL has just published an updated Business Plan4 for the period to 2023/24. The IDP will therefore need to be reviewed in light of this.
For example, the IDP states that the Northern line Upgrade Part 2 (page 8) ‘will involve 17 additional trains being purchased to increase capacity throughout the network, anticipated to take place from 2023’. An indicative date for this is no longer possible. The Business Plan does include a frequency uplift on the Northern line to 31 trains per hour on the Morden branch in the peak from 2020, though this does not involve more trains being purchased.
The IDP also states (page 8) that the ‘TfL Business Plan identifies that from 2023, works to upgrade the Bakerloo line will be undertaken to increase capacity’. Similar to above, no date is now available for this to occur, although the Mayor remains committed to extending the Bakerloo line and TfL are actively developing this project.
The Vauxhall gyratory and Waterloo City Hub scheme are included in the Business Plan, but the other TfL-involved projects need to be reviewed with the TfL Surface Sponsorship team to ascertain a) if TfL funding is still available and b) if the amount identified in the IDP schedule is still adequate for delivery. An example of this is the Tulse Hill gyratory.
3 https://tfl.gov.uk/corporate/about-tfl/how-we-work/planning-for-the-future/healthy-streets 4 http://content.tfl.gov.uk/fc-20181213-item07-tfl-business-plan-approval.pdf