PLANNING APPLICATIONS COMMITTEE 03 DECEMBER 2019 SECOND ADDENDUM: AMENDMENTS AND ADDITIONAL INFORMATION ON AGENDA ITEMS

Page Number Report Changes Decision Letter Changes

ITEM 4 Applications 19/01304/FUL & 19/01305/LB – 8 Albert Embankment

Pages 167, and Amendments to report No 168 ‘Affordable Housing and  An addendum note has been provided by BNPP in relation to viability. Housing Mix’ Officer comment:

BNPP can comment on this should committee members have any questions.

Page 221 No ‘Planning  The contribution for implementation of Low Traffic Neighbourhood on local streets in the area is Obligations and £164,000. CIL’ Page 228, Additional Condition (amended to suggested additional condition set out in First Addendum) Yes Conditions Noise Mitigation and Control for Noise Generating Uses 43 Prior to the commencement of development of each relevant block containing an A4 or D2 use hereby permitted, a scheme of noise assessment and scheme of mitigation must be undertaken and shall be submitted to and approved in writing by the Local Planning Authority to ensure that the noise impacts from all/the relevant A4 and D2 uses shall be suitably mitigated and that the spaces shall be suitably ventilated to enable effective delivery of the proposed scheme. A suitably qualified independent person must undertake all work and the scheme of mitigation. The scheme shall ensure that operational noise levels from the commercial use do not exceed NR25 Leq,5mins between 22:00 – 07:00hrs within potentially adversely affected residential or other noise sensitive locations during typical activities. The scheme must include details of stages of validation during the construction phase and a post construction scheme of validation and measurement to demonstrate substantive compliance. Details of the post construction validation shall be submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved details.

PLANNING APPLICATIONS COMMITTEE 03 DECEMBER 2019 SECOND ADDENDUM: AMENDMENTS AND ADDITIONAL INFORMATION ON AGENDA ITEMS

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

Office comment:

The reason for the requested amendment is that the A4/D2 uses will come forward as part of different phases and will not come forward together. The fire station will also be delivered as the first phase and as worded its occupation could be delayed – phased provision will address this concern. The suggested noise limit condition also has no indication of the measurement parameter used or the period it should be applied and therefore has been amended to reflect timescales.

Pages 146 to 157 Additional Consultation Responses No ‘Consultation Responses' Primrose Hill Conservation Area Advisory Committee – objection for the following reasons:

 The application would significantly harm the protected views designated in the LVMF view (4A) from Primrose Hill which includes the setting of the Victoria Tower of the Palace of Westminster.

 The Primrose Hill Conservation Area Advisory Committee has welcomed the GLA’s enhanced recognition of the importance of a range of London views in the draft London Plan, and we contributed to the Planning Inspectors’ examination in public, supporting the protection of such views.

 It would be a blow to the democratic process to undermine these views, and undermining to communities across London for our treasured sense of place, of our London, to be harmed in the way proposed.

Whitgift Estate TRA No

 Further correspondence has been received attaching a review by the BRE dated 26/11/2019 of the daylight and sunlight report produced by Shroeders Begg.

Officer comment:

Shroeders Begg have been provided a copy of the review by the BRE and can comment on this should committee members have any questions. PLANNING APPLICATIONS COMMITTEE 03 DECEMBER 2019 SECOND ADDENDUM: AMENDMENTS AND ADDITIONAL INFORMATION ON AGENDA ITEMS

Vauxhall One Business Improvement District (BID) - Supports growth in Vauxhall and works to No ensure that all businesses benefit from the developments in our area. The BID welcomes the kind of innovation and positive change that creates skills, supports jobs and helps build a positive future for Vauxhall, while celebrating the area's important and thoroughly unique past.

Our most recent survey showed great support amongst local businesses for improved amenities for the area. These proposals include a number of low-cost rental spaces for new micro, small and medium sized enterprises, which will help to spread the benefits of growth in the local area, as well as provide new amenities for local residents. All these new businesses together will help to generate over £1.7 million a year for the Council through business rates and new and improved public spaces that can be enjoyed by all.

Florence Eshalomi AM (London Assembly Member for Lambeth & Southwark) No

 Letter of objection from Florence Eshalomi AM received attached as Appendix 3

Ward Councillors No

 Letter of objection received from Cllr Davies attached as Appendix 1  Letter of objection received from Cllr Simpson attached as Appendix 2

Transport for London No

 The following additional comments have been received:

“The only outstanding issue for TfL is the fire station access. We’ve relayed our concerns that the proposals assume the existing access arrangements for fire tender via Lambeth High Street, which will not be achievable for vehicles returning from Lambeth Palace Road once TfL’s scheme for Lambeth Bridge south is implemented. As such the committee report suggests that a planning obligation will be required to agree alternative access, as per the extract below, which is welcomed.

The access arrangements for the Fire Station are proposed to remain essentially as existing. It’s proposed that fire appliances exit the site onto Albert Embankment, returning (in forward gear) to the rear via Lambeth High Street. However, TfL’s proposal for Lambeth Bridge South indicate restricted vehicle turning movements from Lambeth Palace Road to Lambeth Road - making this arrangement difficult for vehicles returning from the north of the site. TfL have stated that an PLANNING APPLICATIONS COMMITTEE 03 DECEMBER 2019 SECOND ADDENDUM: AMENDMENTS AND ADDITIONAL INFORMATION ON AGENDA ITEMS

alternative could be to route via Black Prince Road to access Lambeth High Street, avoiding significant re-routing. However, the existing road layout and building line inhibits that manoeuvre for larger vehicles. The applicant is therefore required to enter into a planning obligation to agree an alternative access, to ensure that the two schemes are compatible. It is likely that TfL will also be a party to the appropriate agreement.

In line with Local Plan Policy T1 which gives prioritises walking over taxis, we requested that the taxi rank proposed on Lambeth High Street should be removed to provide a wider footway. We opposed the positioning of the taxi rank here because of its effect on the pedestrian environment. Located on the footway, it would have resulted in a substandard footway width behind the rank. The Pedestrian Comfort Level [PCL] on the footway around the potential taxi-rank would fall to PCL=F with a two-taxi rank. On the PCL scale A [best] to F [worst] TfL’s own guidance states anything below C+ is unacceptable for ‘high street’ environments.

No suitable alternative location was identified, but there are 2 x alternative taxi ranks within approx. 300m of the site”.

Officer comment: Details of alternative access arrangements to be agreed with Tfl covered by s106 head of term as set out on Page 221 of the committee report. With respect to taxi parking, no suitable alternative location was identified, but there are 2 x alternative taxi ranks within approx. 300m of the site.

Beaconsfield Gallery – Objection on the following grounds: No

 Lack of consultation;  The proposed building will block the existing view of our historic, neo classical, Victorian building that currently has a sight-line extending from Vauxhall Spring Gardens, coming into view at Walker Books. The proposed U+I tower block will completely erase any view of the original, intact side of our building which is of key historic importance for the area as the philanthropic project of the former Lambeth Ragged School (built 1851);  The building of towers in a conservation area and on a site that has been designated not to have tall buildings (in Lambeth's Local Plan 2015) due to the heritage sensitivity of the location;  Loss of sun and daylight to all the surrounding communities and businesses and particularly to Beaconsfield Gallery Vauxhall, which requires light for its operation as a free, public art gallery and café;  Loss of sun and daylight that would result from the building of a tower on the corner of Black Prince Road and Newport Street: the building will block light to the windows of the Upper Gallery PLANNING APPLICATIONS COMMITTEE 03 DECEMBER 2019 SECOND ADDENDUM: AMENDMENTS AND ADDITIONAL INFORMATION ON AGENDA ITEMS

and Lower gallery/café space. This will severely impact both exhibitions and community use of the café, causing substantial adverse harm to the amenity we provide, the catering business that we support and therefore to the public.

Additional Responses No

 An additional 60 objection responses have been received – these raise no new issues to those already reported in the committee report.

Summary of total responses received to date (including those set out in the first and second No addendums)

 In total, 1,195 local residents were consulted on the applications with 699 individual representations having been received during the consultation period of which 344 were in support and 355 were in objection.  Three petitions of objection with 2,177 signatures, 100 signatures and 43 signatures respectively have also been received.

Appendix One

Dear PAC members,

I will be attending PAC to speak about my reservations regarding the 8 Albert Embankment proposed development. I know other councillors will be too. My concerns are several and in essence the following are points I hope that PAC will take seriously.

I know you have a great deal of detailed papers to get through so I will be brief and echo the motions passed by Princes and Bishops Ward Labour Parties and Vauxhall GC:

 Tall buildings (Policy PN2 Site 10 specifies that “the site is not appropriate for tall buildings”)  Severe loss of daylight and sunlight (as a result of those tall buildings), contrary to Policy Q2 protecting residential amenity

I was disappointed that we were unable to visit one of the flats in Whitgift House on the site visit to get a realistic idea of the predicted loss of light. The figures from even the developer’s survey would suggest significant loss of light to the flats in Whitgift House which are confirmed by Lambeth and the objectors’ surveys.

 Unacceptable negative impact on the substantial and unique heritage assets of the area, including two Conservation Areas and a range of listed buildings, in particular wrecking the last remaining pre-war building along the Albert Embankment, contrary to national policy in the NPPF as well Policy Q20 and Q22 of the Lambeth Local Plan, and contrary to the 20th Century Society’s clear advice that the proposals would have a profound negative impact on the listed building.

 The net loss of around 8,000m2 of employment-generating space, which is part of the existing 17,000m2 of employment-generating space left vacant without any attempt at marketing for up to 20 years by the landowners, the London Fire Brigade, contrary to Policy ED2

 The unnecessary introduction of massive residential towers on the most northerly protected industrial land in Lambeth, contrary to Policy ED1

In addition I am unhappy that the comments of the council's Conservation Team have been amalgamated into a joint distillation with Historic England. I would like to have a clearer steer from Lambeth's undoubted expertise.

Cllr Jon Davies, Princes Ward, 29th November 2019. Appendix 2

8 Albert Embankment: Representation from Cllr Joanne Simpson – Prince’s ward Councillor

Land Use / Principle of Development:

Lack of marketing evidence I am concerned that the use of the site is being classed as sui generis, despite being a designated KIBA. KIBAs are designated to ensure the retention of employment use, and in particular, industrial and business use, on a site. The site is portrayed as under-utilised, but no reasons have been given for why this is the case. My opinion is that it is not currently in use because the LFB has for many years failed to market it adequately. Were the land considered a Use Class B, the applicant would be required, as per Local Plan policy, to provide marketing evidence to demonstrate that there is no market appetite for its continuation. Whilst I appreciate that the scheme will result in an uplift in employment space, the introduction of residential in the KIBA is a departure from policy, unless it can be demonstrated that there are exceptional reasons for the delivery of an acceptable scheme. I believe that marketing evidence ought to have been submitted, in order to support the applicant’s claim that the residential use is required.

Affordable housing mix It is totally unacceptable that there are no family sized dwellings in the affordable housing offer (note by this I mean affordable rented and social rented, not shared ownership which is not genuinely affordable in North Lambeth). There are only one- bed units offered for social rented (housing this area badly needs) and one and two- bed properties in affordable rented. Two points on this below:

1. The report states that according to the Strategic Housing Market Assessment (SHMA), family-sized homes are not a priority in this area. This is not borne out in my Councillor surgeries, where every month I meet dozens of families living in desperate, crowded and unsatisfactory housing conditions. This development is right in the heart of Whitgift Estate, a Lambeth estate, and next door to Vauxhall Garden’s Estate, the largest Council estate in the Borough. There are very real, existing communities living here in Council blocks, many of whom require rehousing. Prince’s ward is absolutely no different to any other area of Lambeth in this respect. 2. The report states that two-bed properties can be considered family-sized. Why then, when I recently objected to a planning application on Vauxhall Gardens Estate which proposed the conversion of a two-bed flat into two units, on the grounds it would result in the loss of a family-sized dwelling, was a told that this concern could not be considered because two-bed properties are not treated as family units when assessing the acceptability of conversions – only 3+ bedrooms were. Policy is policy and its application must be consistent, otherwise the Council is in danger of cherry picking.

Affordable Housing offer Policy requires 50% per unit and yet 39% is included. Given the need to justify the introduction of residential in the KIBA, this ought to be 50%. Whilst it may be true that the viability assessment demonstrates that the scheme cannot deliver more, this is a separate point that in order to justify the introduction of residential in the KIBA and the departure from the tall buildings restriction in the site allocation, this scheme needs to over-deliver on this, not under-deliver.

Gym This D1 use is neither industrial/business or even residential, and therefore there is no justification for it being in the KIBA. There is a perfectly good gym round the corner on Black Prince Road at the Black Prince Hub. What is the policy justification for its inclusion in the scheme, in particular, within the KIBA?

Hotel There is an abundance of hotels in North Lambeth, in Vauxhall and Waterloo in particular, so much so that officers are proposing in the draft Revised Local Plan to ‘not allow further hotel developments in Waterloo and set a cap on new hotel bedspaces in Vauxhall’. The application site is located between Waterloo and Vauxhall, where it is recognised that there is an existing over-saturation of hotels. The draft London Plan also states that the Council proposes ‘encourage new hotels to locate in appropriate town centres elsewhere in Lambeth [i.e. not Vauxhall or Waterloo]’ and ‘require hotel developers to assess the impact of their proposal on local services and neighbours’ and ‘not restrict the supply of land needed for new housing’. Some points below: 1. The delivers a below-policy requirement of affordable housing, and so land needed for new housing is being restricted. 2. The hotel has an unacceptable impact on the local area, with regards to traffic impact, noise and air pollution, as discussed in more detail in sections below. 3. The report states that policy officers raise no objection. Why then is hotel development to be restricted in the revised Local Plan? In order for a Local Plan to be considered sound by the Secretary of State, evidence must be required to justify policies. There is therefore evidence that it is damaging and undesired allow additional hotel development in North Lambeth.

Office use Recently PAC considered a scheme at nearby Westminster Tower, also on 8 Albert Embankment, which proposed the conversion of office space into residential. Officers recommended approval on the grounds that its location, in between both Vauxhall and Westminster tubes but not close enough to either, meant that there was no demand for office space in this location, and that the market wanted office space in Vauxhall town centre instead. This application site is in the same area. What evidence has been provided to demonstrate that the officer advice given to PAC members recently no longer applies?

Design/Character/Appearance/Layout

Para 8.2.7 of the report states that the Council’s Design and Conservation Team’s comments and those of the GLA and Historic England have been incorporated into the report. I would ask that it is made clear at Committee which consultee said what about each particular aspect, otherwise there might a risk of cherry picking in order to present the ‘expert advice’ as more unified and positive than it necessarily is.

Tall buildings Point iv of the Site 10 Allocation in the Local Plan is very clear about the non- acceptability of tall buildings in this site: ‘the heritage sensitivity of the site makes it inappropriate for tall building development’. Further to this, though not as imperative as the Site Allocation, the Vauxhall SPD area falls within a location identified as being ‘sensitive’ to tall buildings’. Some points below: 1. The Site Allocation was included in the most recently-adopted Local Plan and as far as I am aware, there are no proposals to amend it in emerging revised Plan. The current Plan was assessed by the Planning Inspector/ Secretary of State and found to be sound. This assessment was undertaken after the area was designated a CAZ and part of the VNEB (where tall buildings are encouraged), and so the inclusion of a restriction on tall buildings on this particular site was done so for good reason. 2. Last month I joined some of you in the assessment of the Lambeth College site, where a 20-storey tower was approved, despite it being taller than the existing building form of the locality. Please note, however, that whilst this site is also in the VNEB, it differs from the College scheme in that a) there is a significant number of heritage assets within the immediate and surrounding vicinity, b) there are strategically important views to consider, and c) the Site Allocation specifically states that tall buildings are not acceptable (for reasons a and b).

Rear of the Fire HQ The rear of this building has architectural and historic interest in that it still boasts largely intact features such as tiered balconies and viewing platforms, which formed an integral part of the operational use of the building at the time. I object to the proposed extension at the rear which would remove these features and replace them with a uniform and ugly building which fails to appear a proportionate or subordinate addition to the host building; neither does it respect the original form or its historic interest which is mentioned in its listing.

New public realm Little information is provided regarding the conditions of the proposed public realm, with regards levels of sunlight/daylight receives, noise ambience and wind levels, given the height and massing of the buildings proposed on site. New public realm that is not of an excellent and attractive quality, ought not to be presented as a public benefit of a scheme, where in reality spaces are not well-used, such as the dark and windy ‘public spaces’ at St Georges Wharf, Vauxhall.

Neighbouring Amenities:

Impact on Daylight/Sunlight/Outlook The Council’s own housing department has formally objected to the proposal on the grounds of impact to Lambeth Council homes including impact on light, green spaces, increase in traffic and health and safety concerns. I may have missed it, but I cannot recall in my 6 years sitting PAC seeing an objection from Lambeth Housing. These concerns ought to be given serious consideration. Residents, together with Cllr Davies, have highlighted the main issues, but I did want to raise some further points/questions below: 1. I understand from Cllrs Amos and Davies, who accompanied residents on a door-knocking exercise of Whitgift House, that the internal layout of this block is very different to that of Arne House, which the Inspector considered as part of the Graphite Square Appeal scheme, Prince’s ward. Unlike Arne House, it is living rooms, i.e. primary habitable rooms, which face the proposal site, and not galley kitchens and/or secondary bedrooms. The Inspector’s comment therefore need to be read with this in mind and be considered in this context.

2. Much is made about the BRE assessment of light levels; however, it should be remembered that the assessment of outlook and a sense of enclosure caused by a development is somewhat different. The sheer height of the proposals and the intense density of the sight combined will lead to an undue sense of enclosure and unacceptable loss of outlook for residents. 3. Para 8.3.17 of the report states that ‘[t]he noise impact on residents of the development are considered to acceptable subject to mitigation’. This is in reference to new residents in the proposed blocks. If the noise levels would only be acceptable subject to mitigation, why is it also claimed in the same report that noise levels for existing residents would be acceptable? It cannot be both. 4. Point vi of the Site 10 Allocation in the Local Plan states that the Council will support development on this site that ‘makes sure both existing and new residential amenity is protected’. This is not the case.

Beaconsfield Gallery I have previously enquired at the latest technical briefing about the impact of the proposal on Beaconsfield Gallery, which is an art gallery and exhibition spaces which immediately adjoins the East Site. There is no mention of this in the report. Whilst I appreciate that it is not residential, the Planning Inspector for the recent Graphite Square Appeal did consider the impact of the proposal on Walkers Books publishers, even visiting inside the premises as part of his site visit, and concluded in his Decision that it was a material planning consideration, despite not being residential.

Housing Standards

How many of the proposed units are genuinely dual aspect, as defined in Lambeth’s policy?

That there is a complete lack of provision for playspace for older children demonstrates that the application is over dense. Time and time again this is justified by officers by way of a financial contribution to nearby parks. This is not sustainable. Transport:

Impact of the hotel

A hotel of 200 bedrooms will result in a substantial increase in vehicular traffic, both in terms of servicing and taxi usage. Some points below: 1. The report estimates that the proposal will generate a total of 803 2-way (therefore 1,606 in total) trips in the am peak with 879 2-way (1,758 in total) in the pm peak hour. That is huge. 2. Lambeth High Street is a very narrow street, and there is an existing problem of bottlenecks at the junction with Black Prince Road, which is a danger in particular to cyclists. This problem will only increase. I understand that a Servicing/Traffic Management Plan is suggested via condition. However, this does not in itself guarantee that an acceptable solution or situation is possible. An area with narrow streets serving a highly dense housing estate is simply not appropriate for a hotel. 3. Hotel users invariable use taxis. Remember that this area was advised by officers as being inappropriate for office space (during the consideration of the Westminster Tower scheme) on account of it not being near a tube. Whilst the PTAL is excellent, this tool is arbitrary and hotel users will not want travel on local buses with their luggage. They will use taxis. The report states that thete are taxi ranks within approx.. 200m of the site. Googlemaps states that this distance is 9 minute walk. It is therefore unlikely that hotel customers will walk to taxi rank and will instead call an uber. Where will these ubers park and has this been factored into the transport assessment? I see no mention of it. 4. Point x of the Site 10 Allocation in the Local Plan states that the Council will support development on this site that would ‘reduce traffic dominance and promote walking and cycling’. I feel to see how this can realistically be achieved; indeed the problems with traffic will only become worse to an unacceptable level. Air Quality

Para. 8.9.10 refers to the ‘limited traffic’ generated by the proposal. I would suggest that this will not be the case, particularly given the proposed hotel, and that not only will levels of daylight and outlook be unacceptability compromised for existing residents, but so too will their levels of clean air.

Thank you for your consideration.

Cllr Joanne Simpson Labour Councillor for Prince's ward

Florence Eshalomi AM City Hall London Assembly Member for Lambeth & Southwark The Queen’s Walk London SE1A 2AA Switchboard: 020 7983 4000 Minicom: 020 7983 4458 Web: www.london.gov.uk

Lambeth Planning Committee Lambeth Council 1 Brixton Hill London SW2 1RW

Sent via email [email protected]

02 December 2019

Lambeth Council Planning Committee,

Re: 8 Albert Embankment 19/01304/FUL

I am writing as the local London Assembly Member for Lambeth and Southwark to formally object to the planning application submitted by U+I and the London Fire Brigade (LFB) at 8 Albert Embankment (19/01304/FUL). I had hoped to speak at the planning committee meeting on Tuesday 3rd December but understand that as I am also currently a PPC for the Vauxhall constituency that this has been deemed inappropriate by Democratic Services. I was disappointed not to be able to voice my concerns in person but hope that this letter can serve in its place.

I recently arranged a meeting with the Fire Commissioner, Deputy Mayor for Fire, U+I and residents to discuss the proposals for the site. During this meeting all present were able to walk around the proposed site area to gain a better understanding of the impact on existing residents and businesses. I was also able to meet with anxious local residents who were worried about loss of sight and sunlight from their properties.

As a member of the Fire, Resilience and Emergency Planning Committee at City Hall, I am supportive of the LFB’s need to refurbish and modernise Lambeth Fire Station which is a critical piece of infrastructure for London’s fire cover and appreciate the difficulty they are having with opposition to this application. However, there are a number of grounds that I must support local residents on in opposing the application.

Sunlight and shadowing Access to daylight is a fundamental right and I believe acceptable reductions in sunlight should not be higher than 20% in planning applications. In the 8 Albert Embankment application, developers will be causing many of the surrounding residential windows to fall below the limit of light received as stipulated in the guidelines. I have been contacted by a number of residents, local charities and businesses who are rightfully concerned about the loss of light the new development would cause them. This includes art gallery spaces which are crucial to the area’s community and of course rely on natural light.

There are also valid concerns over the shadowing of Old Paradise Gardens. The Gardens are a historic public space gifted to the community by the Archbishop of Canterbury which is currently being revived as a community garden. The current planning application would

Direct telephone: 020 7983 4427 Fax: 020 7983 4418 Email: [email protected]

Florence Eshalomi AM City Hall London Assembly Member for Lambeth & Southwark The Queen’s Walk London SE1A 2AA Switchboard: 020 7983 4000 Minicom: 020 7983 4458 Web: www.london.gov.uk unfortunately block the sunlight to the gardens. The gardens are well used by the local community and reducing the sunlight to the garden would be devastating for residents.

Lambeth Local Plan As you will be aware, the Lambeth Local Plan has protected the area from certain types of developments since 2015. This application is a clear ‘Departure Application’ from our Local Plan, which states that ‘tall building development’ would be ‘inappropriate’ on this specific site, owing to ‘heritage sensitivities’ of the Lambeth Green area.

U+I consultation I have been contacted by a number of local businesses that expressed their concern over the lack of consultation with them over the planning application. One in particular, the Beaconsfield Charity have been mentioned within U+I’s development plan as an example of local history and as a cultural provider with mention to their ‘cultural quarter’ in their literature. Unfortunately, Beaconsfield inform me that U+I have not once visited the gallery to speak to them in person or consulted them in any way about their plans. They understandably feel as though they have been used to conceptualise and sell the scheme without any communication. I am also concerned that at meetings with residents, U+I committed to providing additional information and assessments to residents, but this never materialised. It’s crucial that developers are transparent and cooperative with the local community they are trying to work in and unfortunately U+I have not been throughout this process.

There are many further claims of lack of proper consultation which have been raised in objections submitted to the committee from residents and businesses that I would urge the planning committee to consider.

In light of all the above, and the further objections from residents, I encourage the committee to object to the development.

With best wishes,

Florence Eshalomi Assembly Member for Lambeth and Southwark

Direct telephone: 020 7983 4427 Fax: 020 7983 4418 Email: [email protected]

8 ALBERT EMBANKMENT AND LAND TO REAR BOUNDED BY LAMBETH HIGH STREET, WHITGIFT STREET, THE RAILWAY VIADUCT, SOUTHBANK HOUSE TOGETHER WITH LAND AT THE CORNER OF BLACK PRINCE ROAD AND NEWPORT STREET LONDON SE1 – FINANCIAL VIABILITY

This Addendum Note should be read in conjunction with our report1 dated June 2019; our response dated 26 September 2019 to Jones Lang LaSalle’s letter of 31 July 2019; and our letter to Michael Cassidy dated 21 November 2019. Our report identified appraisal inputs where we disagreed with Jones Lang LaSalle’s assumptions. As a result of discussions between the parties, including inputs where we have agreed to disagree, our final appraisal adopts the following inputs:

Table 1: Development appraisal – assumptions

Input Assumption Revenue Private residential sales values (per square foot) £1,599 Rented affordable housing values (per square foot) £312 Intermediate affordable housing values (per square foot) £656 Hotel and serviced apartment values (per square foot) £928 Ground rents per unit (capital value) £222 Offices capital value per square foot (rented at £56.08 per square foot, 1 year £973 rent free, 5.25% yield) Retail capital value per square foot (rented at £25 per square foot, 9 months’ rent £482 free, 5% yield) Housing Infrastructure Fund grant £10 million London Affordable Homes Programme grant £1.26 million Costs Construction (per square foot) Lambeth CIL £8.70 million Mayoral CIL £4.11 million Planning and Section 106 costs (including carbon offset) £2.42 million Professional fees (% of construction costs) 10% Private housing marketing including sales agent (% of private GDV) 1.5% Letting agent fee (% of first year’s rent) 10% Letting legals fee (% of first year’s rent) 5% Commercial sales agent fee (% of capital value) 1.5% Residential sales legal fees (per unit) £1,000 Commercial sales legal fee (% of capita value) 0.5% Profit on private housing (% of GDV) 20% Profit on affordable housing (% of GDV) 6% Profit on commercial (% of GDV) 15% Finance rate 5.50% Benchmark land value £42.78 million

1 ‘8 Albert Embankment, London SE1: Review of ‘Financial Viability Assessment’, June 2019 The benchmark land value for the site is based on a policy compliant alternative scheme, which has been approved for this purpose by the Council.

A summary of the appraisal itself it provided in Table 2.

Table 2: Summary development appraisal – 40% affordable housing by habitable rooms

Input Cost/revenue (£ millions) Gross development value £485.14 Less purchasers’ costs (£5.81) Net development value £479.33 Plus HIF and affordable housing grant £11.26 Total income £490.59

Construction costs £272.85 Planning & Section 106 costs £2.42 Lambeth CIL £8.70 Mayoral CIL £4.11 Professional fees £25.99 Market, letting, legal and disposal fees £13.22 UK Power Networks – network reinforcement £4.20 Profit £82.94 Finance £33.02 Total costs £447.45 Residual land value £43.14 Less stamp duty and acquisition costs £3.58 Net residual land value £39.56

At 40% affordable housing (62% rent, 38% shared ownership by habitable rooms), the scheme generates a residual land value of £39.56 million, which is marginally lower than the Site’s benchmark land value of £42.78 million. The appraisal confirms that the maximum reasonable proportion of affordable housing is 40% by habitable rooms. All full appraisal summary is attached as Appendix 1.

BNP Paribas Real Estate 2 December 2019

APPENDIX 1: APPRAISAL APPRAISAL SUMMARY BNPPARIBAS REALESTATE 8 Albert Embankment - 40% AH with grant NOT TO BE RELIED UPON FOR FUNDING PURPOSES

Summary Appraisal for Phase 1

Currency in £

REVENUE Sales Valuation Units ft² Rate ft² Unit Price Gross Sales West site private residential 95 62,656 1,561.38 1,029,788 97,829,825 Central site - Central Sq Bldg private 99 69,449 1,627.60 1,141,770 113,035,192 Central site - Central Sq Bldg intermediate 52 27,448 693.69 366,162 19,040,403 Central site - Eastern Gdn Bldg Private 77 53,443 1,605.17 1,114,092 85,785,100 Central site - Eastern Gdn Bldg Intermediate 30 19,741 603.48 397,110 11,913,299 Central site - Eastern Gdn Bldg Low cost rent 33 23,788 311.08 224,242 7,400,001 Central site - Whitgift St low cost rent 27 22,228 278.82 229,540 6,197,582 East Site - Low cost rent units 30 20,451 350.59 239,000 7,170,000 Totals 443 299,204 348,371,403

Rental Area Summary Initial Net Rent Initial Units ft² Rate ft² MRV/Unit at Sale MRV West site hotel and restaurant 143 54,670 44.07 16,849 2,409,438 2,409,438 West site Retail unit 1 603 25.00 15,075 15,075 15,075 Central site Corporate office 1 69,438 56.08 3,893,970 3,893,970 3,893,970 Central site Medium workspace 1 13,832 25.60 354,132 354,132 354,132 Central Site Central Sq Bldg Retail 1 2,809 25.00 70,225 70,225 70,225 Central site - Eastern Gdn Bldg Micro Workspace 1 1,442 15.00 21,630 21,630 21,630 Central site - retail 1 893 25.00 22,325 22,325 22,325 Central site Gym 1 29,138 13.36 389,284 389,284 389,284 Whitgift site retail 1 1,033 25.00 25,825 25,825 25,825 Central site Whitgift st small workspace 1 1,561 35.00 54,635 54,635 54,635 East site - flexible commercial 1 1,765 25.00 44,125 44,125 44,125 Ground rents 271 10 2,710 2,710 Totals 424 177,184 7,303,374 7,303,374

Investment Valuation West site hotel and restaurant Current Rent 2,409,438 YP @ 4.7500% 21.0526 50,725,011 West site Retail unit Market Rent 15,075 YP @ 5.0000% 20.0000 (0yrs 9mths Rent Free) PV 0yrs 9mths @ 5.0000% 0.9641 290,667 Central site Corporate office Market Rent 3,893,970 YP @ 5.2500% 19.0476 (1yr 10mths Rent Free) PV 1yr 10mths @ 5.2500% 0.9105 67,529,382 Central site Medium workspace Market Rent 354,132 YP @ 5.7500% 17.3913 (0yrs 6mths Rent Free) PV 0yrs 6mths @ 5.7500% 0.9724 5,989,039 Central Site Central Sq Bldg Retail Market Rent 70,225 YP @ 5.0000% 20.0000 (0yrs 9mths Rent Free) PV 0yrs 9mths @ 5.0000% 0.9641 1,354,035 Central site - Eastern Gdn Bldg Micro Workspace Market Rent 21,630 YP @ 6.0000% 16.6667 (0yrs 2mths Rent Free) PV 0yrs 2mths @ 6.0000% 0.9903 357,016 Central site - retail Market Rent 22,325 YP @ 5.0000% 20.0000 (0yrs 9mths Rent Free) PV 0yrs 9mths @ 5.0000% 0.9641 430,457 Central site Gym Current Rent 389,284 YP @ 5.0000% 20.0000 7,785,674 Whitgift site retail Market Rent 25,825 YP @ 5.0000% 20.0000 (0yrs 9mths Rent Free) PV 0yrs 9mths @ 5.0000% 0.9641 497,942 Central site Whitgift st small workspace Market Rent 54,635 YP @ 6.0000% 16.6667 (0yrs 2mths Rent Free) PV 0yrs 2mths @ 6.0000% 0.9903 901,783 East site - flexible commercial Market Rent 44,125 YP @ 5.0000% 20.0000 (0yrs 9mths Rent Free) PV 0yrs 9mths @ 5.0000% 0.9641 850,791 Ground rents Current Rent 2,710 YP @ 4.5000% 22.2222 60,222 136,772,016

GROSS DEVELOPMENT VALUE 485,143,419

Purchaser's Costs 4.25% (5,812,811) APPRAISAL SUMMARY BNPPARIBAS REALESTATE 8 Albert Embankment - 40% AH with grant NOT TO BE RELIED UPON FOR FUNDING PURPOSES (5,812,811)

NET DEVELOPMENT VALUE 479,330,609

Additional Revenue Housing Infrastructure Funding 10,000,000 Affordable Hsg Grant 1,260,000 11,260,000

NET REALISATION 490,590,609

OUTLAY

ACQUISITION COSTS Residualised Price 39,556,619 Stamp Duty 5.00% 1,977,831 Agent Fee 1.00% 395,566 Legal Fee 0.80% 316,453 West site survey 447,000 East site survey 447,000 43,140,469 CONSTRUCTION COSTS Construction Units Unit Amount Cost West site private residential 95 un 205,053 19,480,000 West site basement 1 un 6,100,000 6,100,000 West site Musuem shell and core 1 un 2,560,000 2,560,000 West site Private resi fit out 1 un 12,770,000 12,770,000 West site amenity fit out 1 un 300,000 300,000 Hotel/restaurant shell and core 1 un 16,280,000 16,280,000 Hotel/restaurant fit out 1 un 8,770,000 8,770,000 Fire Stn shell and core 1 un 5,660,000 5,660,000 Fire Stn Cat A fitout 1 un 830,000 830,000 Fire Stn Cat B fitout 1 un 900,000 900,000 Fire Stn FFE 1 un 500,000 500,000 Central Site basement shell and core 1 un 23,740,000 23,740,000 Central site Central Bldg shell and core 1 un 32,060,000 32,060,000 Central site: Central Sq Bldg private fit out 1 un 15,070,000 15,070,000 Central Site: Central Sq Bldg intermediate fit out 1 un 2,680,000 2,680,000 Central Site: Central Sq Bldg residential amenity 1 un 300,000 300,000 Central Site Eastern Gdn Bldg shell & core 1 un 32,990,000 32,990,000 Central Site Eastern Gdn Bldg Private resi fit out 1 un 13,210,000 13,210,000 Central Site: Eastern Gdn Bldg Intermediate fit out 1 un 930,000 930,000 Central site: Eastern Gdn Bldg Low cost rent fit out 1 un 2,170,000 2,170,000 Central Site: Eastern Gdn Bldg micro workspace fit out 1 un 50,000 50,000 Central Site amenity fit out 1 un 300,000 300,000 Central Site Whitgift St shell and core 1 un 7,300,000 7,300,000 Central Site Whitgift St Low cost rent fit out 1 un 1,870,000 1,870,000 Central Site Whitgift St small workspace fit out 1 un 70,000 70,000 Central Site office/gym shell and core 1 un 21,360,000 21,360,000 Central Site: Corporate office Cat A fit out 1 un 2,780,000 2,780,000 Central site medium workspace fit out 1 un 510,000 510,000 East site Basement 1 un 710,000 710,000 East site resi/flex commercial shell and core 1 un 7,360,000 7,360,000 East site Low cost rented fit out 1 un 1,930,000 1,930,000 Totals 241,540,000 241,540,000

Developers Contingency 5.00% 12,984,500 West Site demolition 1,690,000 Central site demolition 1,060,000 East site demolition 30,000 15,764,500 Other Construction West site: restaurant bridge 500,000 West site: S278 works 270,000 Project benchmark mockup 200,000 West site: rebuild obelisk 200,000 West site: energy centre 2,080,000 West site: incoming services 920,000 West site: renewables 140,000 West site: external works 850,000 Central site: external works 2,240,000 Central site: renewables 320,000 APPRAISAL SUMMARY BNPPARIBAS REALESTATE 8 Albert Embankment - 40% AH with grant NOT TO BE RELIED UPON FOR FUNDING PURPOSES Central site: incoming services 1,750,000 Central site: energy centre 4,000,000 PCSA fees 900,000 Main contractor OH&P 250,000 Central site: S278 costs 540,000 East site: external works 180,000 East site: renewables 40,000 East site: incoming services 130,000 East site S278 40,000 15,550,000 Municipal Costs Borough CIL 8,698,489 Mayoral CIL 4,112,595 Planning and Section 106 costs 1,548,752 Carbon offset 873,964 15,233,800

PROFESSIONAL FEES Architect 10.00% 25,987,000 25,987,000 MARKETING & LETTING Marketing 1.50% 4,449,752 Letting Agent Fee 10.00% 730,337 Letting Legal Fee 5.00% 365,169 5,545,258 DISPOSAL FEES Sales Agent Fee 1.50% 6,413,237 Aff Hsg disposal fee 75,000 Sales Legal Fee 0.50% 913,402 Sales Legal Fee private resi 271 un 1,000.00 /un 271,000 7,672,639

Additional Costs Third party costs 200,000 UKPN Network reinforcement 4,000,000 4,200,000

MISCELLANEOUS FEES Profit on private residential 20.00% 59,330,024 Profit on commercial 15.00% 20,506,769 Profit of affordable housing 6.00% 3,103,277 82,940,070 FINANCE Debit Rate 5.500% Credit Rate 0.000% (Nominal) Land 8,968,035 Construction 22,124,336 Other 1,924,500 Total Finance Cost 33,016,872

TOTAL COSTS 490,590,608

PROFIT 1

Performance Measures Profit on Cost% 0.00% Profit on GDV% 0.00% Profit on NDV% 0.00% Development Yield% (on Rent) 1.49% Equivalent Yield% (Nominal) 5.08% Equivalent Yield% (True) 5.25%

IRR 5.53%

Rent Cover 0 yrs 0 mths Profit Erosion (finance rate 5.500%) 0 yrs 0 mths