ADDRESS: Lambeth Palace, Lambeth Palace Road, London, SE1 7JU Application Number: 16/07054/FUL Case Officer: Luke Farmer Ward: Bishops Date Received: 09/12/2016 Proposal: Erection of a building up to 9-storeys in height to provide a library and archive (Use Class D1) including new public library entrance via Lambeth Palace Road, together with creation of a new pond, landscaping works, removal and relocation of existing trees plus realignment of existing path. Installation of double height gate and services access via Lambeth Palace Road together with associated highways works, plus removal of a section of a modern, Grade II listed wall along Lambeth Palace Road within the curtilage of a Grade I listed building. (Planning Permission and Listed Building Consent ref: 16/07055/LB received). Drawing numbers: 100; 101E; 102E; 103E; 120; 121; 130; 140; 160; 161; 170; 180; 200; 201G; 202H; 205; 215A; 216A; 217; 218; 219; 220; 235; 236; 237; 238; 239; 260H; 261H; 268B; 271E; 273C; 276C; 280; 281; 282; 283; 500; 501; 505; 506; 507; 508; LPA-LD-100; LPA-LD-200; LPA-LD-205; LPA-LD-401; LPA-LD-402; LPA-LD-500; LPA-LD-501; LPA-LD-502; LPA-LD-503; LPA-LD-504; LPA-LD-505; LPA-LD-506; LPA-LD-507; LPA-LD-508; LPA-LD-509; LPA-LD-510; LPA-LD-511; LPA-LD-512; SK 183. Documents: Design and Access Statement; Planning Statement; Townscape, Visual Impact and Heritage Statement; Transport Assessment; Travel Plan (November 2016); Construction Logistics Plan; TfL Clarifications Report Rev. A; GLA Response on Living Roofs; Air Quality Statement; Archaeological Evaluation Report; BREEAM Ecologist’s Report; Flood Risk Assessment and SuDS Drainage Statement; Noise Impact Assessment; Arboricultural Impact Assessment; Arboricultural Method Statement; Accommodation Schedule; BREEAM New Construction 2014 Scoresheet; Ecology Report; Sustainability and Energy Statement; External Lighting Planning Assessment; Daylight, Sunlight and Overshadowing Report; Statement of Community Involvement. RECOMMENDATION:

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

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

 Finalise the recommended conditions as set out in this report including such amendments, additions and/or deletions as the Director of Planning, Transport and Development (in consultation with the Planning Committee Chair) considers reasonably necessary; and

 Negotiate, agree and finalise the planning obligations as set out in this report pursuant to Section 106 of the Town and Country Planning Act 1990, including adding to, amending and/or deleting the obligations detailed in the heads of terms as the Director of Planning, Transport and Development (in consultation with the Planning Committee Chair) considers reasonably necessary.

3. Delegate authority to the Assistant Director of Planning and Development to refuse planning permission in the event that the Section 106 Agreement is not completed (by 30th May 2017) on the grounds that the development would have an unacceptable impact on – transport and highways; street-trees, visitor management, sustainability and local labour in construction.

4. In the event that the committee resolves to refuse planning permission and there is a subsequent appeal, delegated authority is given to Officers, having regard to the heads of terms set out in the report, to negotiate and complete a Section 106 Agreement in order to meet the requirements of the Planning Inspector.

Associated Application: Application Number: 16/07055/LB Proposal: Erection of a building up to 9-storeys in height to provide a library and archive (Use Class D1) including new public library entrance via Lambeth Palace Road, together with creation of a new pond, landscaping works, removal and relocation of existing trees plus realignment of existing path. Installation of double height gate and services access via Lambeth Palace Road together with associated highways works, plus removal of a section of a modern, Grade II listed wall along Lambeth Palace Road within the curtilage of a Grade I listed building. (Planning Permission ref: 16/07054/FUL and Listed Building Consent received). Drawing numbers: 100; 101E; 102E; 103E; 120; 121; 130; 140; 160; 161; 170; 180; 200; 201G; 202H; 205; 215A; 216A; 217; 218; 219; 220; 235; 236; 237; 238; 239; 260H; 261H; 268B; 271E; 273C; 276C; 280; 281; 282; 283; 500; 501; 505; 506; 507; 508; LPA-LD-100; LPA-LD-200; LPA-LD-205; LPA-LD-401; LPA-LD-402; LPA-LD-500; LPA-LD-501; LPA-LD-502; LPA-LD-503; LPA-LD-504; LPA-LD-505; LPA-LD-506; LPA-LD-507; LPA-LD-508; LPA-LD-509; LPA-LD-510; LPA-LD-511; LPA-LD-512; SK 183. Documents: Design and Access Statement; Planning Statement; Townscape, Visual Impact and Heritage Statement. RECOMMENDATION:

1. Resolve to grant conditional listed building consent.

2. Agree to delegate authority to the Director of Planning, Transport and Development to finalise the recommended conditions as set out in this report including such amendments, additions and/or deletions as the Director of Planning, Transport and Development (in consultation with the Planning Committee Chair) considers reasonably necessary.

Applicant: The Church Commissioners Agent: Wright & Wright Architects LLP For England

SITE DESIGNATIONS

Relevant site designations: Type of designation Applicable designation Statutory Listed Building Lambeth Palace (Grade I Listed) (within grounds of) Statutory Listed Building Boundary Wall of Lambeth Palace (Grade II Listed) Historic Park and Garden Lambeth Palace Garden (Grade II Listed) Conservation Area Lambeth Palace (CA10) Archaeological Priority Area Lambeth Palace Protected Views (London View Westminster Bridge (LVMF 18) Management Framework (LVMF)) Protected Views (LVMF) Lambeth Bridge (LVMF 19) Protected Views (LVMF) Parliament Square to Palace of Westminster – Townscape View (LVMF 27) Central Activities Zone (CAZ) Waterloo Flood Zone 3 SINC (Site of Importance for Lambeth Palace – Grade I Site of Borough Nature Nature Conservation) Conservation Importance Transport for London (TfL) Road Lambeth Palace Road

LAND USE DETAILS

Site area 0.75 hectares

Use Class Use Description Floorspace (Gross External Area) Existing - Garden of Lambeth - Palace Proposed D1 Library 5,430 sqm

PARKING DETAILS

Car Parking Car Parking Bicycle Motorbike Spaces Spaces Spaces Spaces (general) (Disabled) Existing 0 0 0 0 Proposed 0 1 26 0

EXECUTIVE SUMMARY

The application is for full planning permission and listed building consent for the erection of a new purpose built Library to the northern end of the Lambeth Palace gardens. The Library would house the collection of 120,000 books that has been stored at Lambeth Palace since the Library was founded by Archbishop Richard Bancroft in 1610. However, more recently, due to the restrictions of the Palace buildings and the poor conditions that they provide, parts of the collection have been stored off-site. The collection which relates to English social, political and economic history as well as ecclesiastical history, is of international importance and makes a major contribution to the significance of Lambeth Palace. The retention of the collection on-site is therefore of paramount importance.

The application site contains a number of designated and non-designated heritage assets, including Lambeth Palace itself (Grade 1 listed), the Registered Garden (Grade II listed), and also that of the listed boundary wall (Grade II listed), part of which would need to be removed for the development. Therefore, any development within the garden of Lambeth Palace is considered to result in some harm to the heritage assets. Furthermore, the gardens are a Grade I listed Borough Site of Nature Conservation Importance.

The proposed Library building is considered to be appropriate in its siting, scale, form and detailed design which would integrate well with the adjacent buildings and landscape. Despite this, due to the inevitable loss of openness that would occur, Officers consider this to result in less than substantial harm to the significance of the Lambeth Palace Conservation Area, the listed wall and to the Registered Garden. Officers do not consider there to be harm caused by the proposed development to Lambeth Palace itself. In balancing this and having afforded considerable weight and importance to any harm identified to the designated heritage assets, the proposed development would provide significant heritage and other public benefits that would outweigh the harm that would be caused. Namely, the retention of the Library on-site within a new and more accessible facility; new public views over the Westminster World Heritage Site and Lambeth Palace and onto the Registered Garden, which would be provided by the proposed development. The area of garden surrounding the Library would undergo significant improvements to mitigate the loss of this part of the garden and the existing trees in this area, and to ensure that the ecological value of the Borough SINC is enhanced. Officers are satisfied that the statutory duties in relation to the assessment of development impact on heritage assets has been appropriately undertaken in this case.

The proposed development would not impact unacceptably on the neighbouring properties, including retaining the privacy of the main garden area to Lambeth Palace and the Palace buildings. The proposed development would also not impact unacceptably on the local transport system. Furthermore, the scheme would provide employment and training benefits for local people during the construction phase of the development.

Officers consider that the proposed development would be in compliance with the Development Plan for the Borough. Officers are therefore recommending approval of the scheme, subject to conditions and completion of a Section 106 Agreement.

PLANNING OFFICER’S REPORT

Reason for referral to PAC: The applications are reported to the Planning Applications Committee in accordance with (1)(ii) of the Committee’s terms of reference as they relates to a major application for the creation of more than 1,000sqm of new floorspace.

1 SITE AND SURROUNDINGS

1.1 The application site (hereafter referred to as ‘the Site’) is an area of garden at the northern end of the gardens of Lambeth Palace, located approximately 200 metres from the Palace itself and the main cluster of buildings. The Site is currently undeveloped and consists of open land and trees and is enclosed by a 2.50 metre Grade II listed brick wall to the garden. The gardens of Lambeth Palace are Grade II listed Registered Parks and Gardens of Special Historic Interest (RPGSHI) and are also designated as a Site of Borough Nature Conservation Importance with a Grade I listing. The Site is also adjacent to Archbishop’s Park, which originally formed part of the Palace gardens and is now designated as a Local Space of Heritage Value.

Figure 1: The location of the Site, outlined in red at the northern end of the Palace gardens, with the remaining parts of the Palace complex outlined in blue

Figure 2: An aerial view of the Site, with the area of the garden to the rear forming the proposed location of the new library

Figure 3: A view from the north of the Site along Lambeth Palace Road, with the Evelina Children’s Hospital to the right of the image

Figure 4: A view along Lambeth Palace Road to the north, with St. Thomas’ Hospital to the left of the image

Figure 5: The Site location, the rear section of the Palace gardens

1.2 Lambeth Palace is a Grade I listed building, situated in the centre of London, on the opposite bank of the River Thames to the Grade I listed Houses of Parliament and the Westminster World Heritage Site. The Palace is the current and historical home of the Archbishop of Canterbury, having first occupied the site is 1197. The Site contains a complex of buildings of medieval origin, the oldest part of which is the 13th century chapel and crypt. Lollard’s Tower, the guard room, and Morton’s gatehouse were added in the 14th and 15th centuries, while construction of the great hall was completed in the latter part of the 17th century. Further development and alterations to earlier buildings were undertaken in the 19th century, including the Archbishops’ quarters in 1833. The Palace was greatly damaged during World War II and the buildings were comprehensively restored under the guidance of Seely and Paget.

1.3 The Library was founded by Archbishop Richard Bancroft in 1610, who stipulated that the collection must stay at Lambeth Palace. The Library’s current collections contain over 120,000 books in addition to archives of the Archbishops’ of Canterbury and other church bodies. Amongst this collection are a number of valuable original manuscripts, dating as far back as the 9th century and other collections relating to English social, political and economic history as well as ecclesiastical history. As such, these documents form a collection of international importance. Currently, part of the collection is housed in the Great Hall and within Morton’s Tower at the Palace. The remaining part of the collection is held within a storage facility in Bermondsey where there is no public access.

1.4 As well as the Grade I listed Palace of Westminster and World Heritage Site (WHS) to the west of the Site, there are a number of other heritage assets surrounding the Site. In terms of listed buildings and structures, these are as follows:

- South Wing of St. Thomas’s Hospital, excluding the post-1926 courtyard infill buildings, and Block 9 of St. Thomas’s Hospital Medical School, both are Grade II listed - The Church of St. Mary, Lambeth Road (former parish church and now Garden Museum) is Grade II* listed - The walls, railings, gates, and gate piers to the south and west of the Church of St. Mary are Grade II listed - There are three Grade II* listed tombs within the churchyard: - Tomb of William Sealy - Tomb of Admiral Bligh - Tomb of John Tradescant and Family - Lambeth Bridge and attached parapets, light standards and associated walls, approaches and obelisks, are Grade II listed - The former Holy Trinity Primary School (infants’ annexe) and No. 220 Lambeth Road, are Grade II listed - The front wall and gate piers to the former Holy Trinity Primary School (infants’ annexe) and No. 220 Lambeth Road, are Grade II listed - No. 214 Lambeth Road (St. Mary’s Rectory) is Grade II listed - Nos. 204 to 212 (even) Lambeth Road are Grade II listed - Nos. 4 to 8 and Nos. 9 to 12 (consec.) Pratt Walk are Grade II listed

1.5 The following locally listed buildings surround the Site:

- Timber shelter at southern end of Archbishop’s Park - Lambeth Palace lamp column on approach to Lambeth Bridge - Lambeth Pier, Albert Embankment - Entrance gate to Archbishop’s Park, Lambeth Road - Paving between Lambeth Bridge and Westminster Bridge - Bollards on the central reservations on the west and east sides of the railway bridge, Lambeth Road - No. 178 Lambeth Road - No. 180 Lambeth Road - No. 218 Lambeth Road - Marine Institute, No. 202 Lambeth Road - Street frontage building at No. 202 Lambeth Road

1.6 In addition, the Site is located within the Lambeth Palace Conservation Area and is adjacent to the Albert Embankment Conservation Area to the west and the Westminster Abbey and Parliament Square Conservation Area further to the west in the adjacent London Borough of Westminster. The Site is also located within an Archaeological Priority Area.

1.7 In terms of transport, the Site has a Public Transport Accessibility Level (PTAL) of 6b - the highest available. The Site is also located within the Waterloo ‘W’ Controlled Parking Zone (CPZ).

1.8 The Site is located within Environment Agency Flood Zone 3, which is classified as having a high probability of fluvial flooding.

2 PROPOSAL

2.1 The application seeks full planning permission and listed building consent for the erection of a publically accessible library and archive facility to house the existing collection. The building would be positioned to the rear of the Palace gardens in the northern end of the Site and would be sited along the boundary to Lambeth Palace Road, thus requiring the removal of part of the Grade II listed boundary wall. The public entrance would therefore be from Lambeth Palace Road. The building would consist of a 9-storey central tower with a 5-storey wing to the north of the tower and a 4-storey wing to the south of the tower. The building would also include a single-storey projection to the rear.

Figure 6: A visual of the proposed Library within its historic landscape

Figure 7: A view of the front of the building on Lambeth Palace Road

2.2 Given the nature of the use proposed, the building would be mostly constructed from brickwork, with areas of glazing mostly focused around the lower floors to provide an active frontage and views into the garden.

2.3 The proposed Library would include ancillary facilities such as seminar rooms and group working areas. The main seminar room would be located at the top floor of the tower (8th floor), which would include a terrace with views towards the Palace and towards the Palace of Westminster.

Figure 8: The proposed layout, indicating the uses and accessibility of the different parts of the building

2.4 The proposals include significant landscaping works within the garden, resulting in a loss of a number of trees, but also with a comprehensive new planting scheme, including the provision for a new pond.

2.5 The proposed development (hereafter referred to as the ‘Development’) includes a servicing area and disabled parking space to the rear. Servicing is also proposed to take place on the street within a new loading bay, which would require the adoption of part of the pavement outside the entrance to the ownership of Transport for London. This would also require the loss of 1 no. street tree along Lambeth Palace Road, and subject to construction management details, may require the removal of a second street tree. This would be mitigated through the planting of up to 3 no. new street-trees (2 no. trees if one of the existing trees is retained, but 3 no. new trees of both of these existing trees are removed).

Figure 9: The proposed loading bay on Lambeth Palace Road and vehicular access

Amendments

2.6 A slight amendment was received during the course of the application involving the proposed loading bay on Lambeth Palace Road. Following comments from TfL, this was moved slightly further south. The on-street cycle parking was also relocated to the area of footway within the ownership of the applicant.

3 RELEVANT PLANNING HISTORY

3.1 The Site has an extensive planning history, with the most recent relating to restoration, refurbishment and improvement works to the Palace. There is no relevant specific history in respect of this part of the site.

4 CONSULATIONS

4.1 Statutory and Internal/External Consultees

4.1.1 Conservation and Design: Raised no objections with comments given in the ‘Conservation and Design’ section of the report.

4.1.2 Transport and Highways: Raised no objections subject to further details on waste collection management.

4.1.3 Transport for London (TfL): Raised no objections following further discussions regarding trip generation, servicing arrangements, cycle parking, construction management, pedestrian crossing points and the proposed removal of 2 no. street- trees. Conditions and Section 106 obligations were requested regarding:

- A clause within the Section 106 Agreement to require the applicant to enter into a Section 278 and Section 38 Highways Agreements to deliver proposed highway works prior to occupation and to secure the adoption to TfL of part of the footway currently within the ownership of the applicant;

- Landscaping condition to address proposed street-tree replacements;

- Financial contributions to the Council which shall be transferred to TfL for the removal of up to 2 no. street-trees;

- A Delivery and Servicing Plan to be secured by condition, including further details of a blue badge parking;

- A Construction Logistics Plan to be secured by condition;

- Travel Plan monitoring fee to be secured through the Section 106 Agreement.

4.1.4 Arboricultural Officer: Raised no objections subject to conditions.

4.1.5 Biodiversity Officer: Raised no objections and supportive of the ecological benefits that the proposals would provide.

4.1.6 London Borough of Westminster: Wished to provide no comments on the proposals. 4.1.7 Historic England: In summary, Historic England considers that the proposals would cause some minor harm through the erosion of the openness of the Grade II Registered Garden and through impact to the garden setting of the Grade I Lambeth Palace buildings. However, the proposals would also deliver major heritage benefits in terms of the retention of the Library and archive collections onsite for public access within a suitable purpose built facility which has been carefully designed to respond to its sensitive historic context. Importantly, this would also relieve the pressure on the Grade I listed buildings which are currently housing the collection, allowing them to be repaired and put into a suitable new use consistent with their conservation and long term viable use. As such, Historic England is in support of the proposals.

4.1.8 Historic England (Archaeology): Raised no objections subject to conditions.

4.1.9 Greater London Authority: Raised no objections to the principle of the Development which was supported, nor the design of the building. However, noted that the Development would result in less than substantial harm to Lambeth Palace Gardens (Registered Park and Garden of Special Historic Interest, Grade II). The GLA confirmed that this harm would be outweighed by the significant public benefits that the scheme would provide.

The following points required further investigation however: - Whether a green/brown roof could be provided in addition to the photovoltaic array; - Whether the on-street cycle parking could be provided within the ownership of the applicant; - Further detail required on proposed loading bay arrangements; - Whether public access to the collection could be extended from its existing arrangement of 3 days per week to 6 days per week.

4.1.10 Environmental Health: Raised no objections subject to conditions.

4.1.11 Sustainability Consultants: Raised no objections subject to conditions.

4.1.12 Waste Collection: Raised no objections subject to the bins being presented on-street for collection.

4.1.13 Environment Agency: Raised no objections.

4.1.14 Secured by Design Officer: Raised no objections subject to conditions requiring a Crime and Community Safety Management Plan, Visitor Management Plan and for the development to meet Secured by Design standards.

4.1.15 Natural England: Raised no objections.

4.2 Other Consultees

4.2.1 Waterloo Community Development Group: Raised an objection on 5 grounds:

- Loss of open space and trees;

- No over-riding need for the facility which could be located elsewhere, such as Canterbury and not in an area which is struggling to cope with the number of tourists;

- Location in an area of a high risk from flooding is in contravention to Lambeth Local Plan policy EN5 which seeks to locate development towards areas of lowest flood risk;

- The building would be ugly and oppressive and would harm views from Archbishop’s Park;

- The applicant has been dismissive of the loss of the section of Grade II listed wall.

4.2.2 Society for the Protection of Ancient Buildings: Support the proposals on the basis of the collection remaining in its historic context, meaning the historic buildings at the site would not need potentially harmful interventions to otherwise retain the collection on site. Furthermore, the Society supports the proposals with regard to its design, noting that the scale of the building would respond to the human-scale of the park, also acting to bookend the park.

4.3 Adjoining owners/occupiers

4.3.1 A site notice was displayed from 18.01.2017 to 08.02.2017 and the application was advertised in the local paper on 18.01.2017. The statutory consultation period ended on 08.02.2017. In response to consultation, 17 letters of representation have been submitted.

4.3.2 2 letters of objections were received, a summary of the concerns raised is set out below:

Summary of objections Response Design The scale of the building at 9 storeys The scale of the building is not would be excessive and would block considered to be excessive, noting that views of the church. the bulk of the building would be between 4 and 5 storeys, with the tower element being the only part of the building which would be 9 storeys in height. It is not explicitly clear which church is referred to in the comments, but it is considered that the views analysis provided has demonstrated that the proposals would not have an unacceptable impact on the setting of any of the heritage assets, with Lambeth Palace and the Church of St. Mary (now the Garden Museum) included within this assessment. The building would be close to London The building would not interfere with this View Management Framework (LVMF) protected view. protected view 4A.2. Landscaping Unacceptable loss of trees. Whilst the proposed development would result in a loss of trees, this would be appropriately mitigated through the extensive planting programme and wider landscaping scheme proposed.

4.3.3 15 letters of support were received, summary of the points raised are set out below:

Summary of support Response Land Use There is a need for a new facility and the collection should be Noted. retained on site. Design The building would be in-keeping with the surrounding Noted. architecture and is well sited in relation to the heritage assets.

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.

5.2 The development plan in Lambeth is the London Plan (2015) (as amended by the Minor Alterations to the London Plan 2016), and the Lambeth Local Plan (2015).

5.3 The National Planning Policy Framework was published in 2012. 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.

5.4 The current planning application has been considered against all relevant national, regional and local planning policies as well as any relevant guidance. Set out below are those policies most relevant to the application, however, consideration is made against the development plan as a whole.

5.5 The London Plan (2015) (as amended by the Minor Alterations to the London Plan, 2016):

- Policy 2.10: Central Activities Zone – Strategic Priorities - Policy 2.11: Central Activities Zone – Strategic Functions - Policy 2.12: Central Activities Zone – Predominantly Local Activities - Policy 3.16: Protection and Enhancement of Social Infrastructure - Policy 5.1: Climate Change Mitigation - Policy 5.2: Minimising Carbon Dioxide Emissions - Policy 5.6: Decentralised Energy Networks - Policy 5.7: Renewable Energy - Policy 5.9: Overheating and Cooling - Policy 5.15: Water Use and Supplies - Policy 5.17: Waste Capacity - Policy 5.21: Land Contamination - Policy 6.9: Cycling - Policy 6.10: Walking - Policy 6.13: Parking - Policy 7.3: Designing Out Crime - Policy 7.6: Architecture - Policy 7.8: Heritage Assets and Archaeology - Policy 7.10: World Heritage Sites - Policy 7.11: London View Management Framework - Policy 7.12: Implementing the London View Management Framework - Policy 7.14: Improving Air Quality - Policy 7.15: Reducing and Managing Noise, Improving and Enhancing the Acoustic Environment and Promoting Appropriate Townscapes - Policy 7.18: Protecting Open Space and Addressing Deficiency - Policy 7.19: Biodiversity and Access to Nature - Policy 7.21: Trees and Woodlands - Policy 8.2: Planning Obligations - Policy 8.3: Community Infrastructure Levy

5.6 Lambeth Local Plan 2015 (LLP):

- Policy D4: Planning Obligations - Policy ED11: Visitor Attractions, Leisure, Arts and Culture Uses - Policy ED14: Employment and Training - Policy EN1: Open Space and Biodiversity - Policy EN3: Decentralised Energy - Policy EN4: Sustainable Design and Construction - Policy EN5: Flood Risk - Policy EN6: Sustainable Drainage Systems and Water Management - Policy Q2: Amenity - Policy Q3: Community Safety - Policy Q5: Local Distinctiveness - Policy Q7: Urban Design: New Development - Policy Q9: Landscaping - Policy Q10: Trees - Policy Q12: Refuse/Recycling Storage - Policy Q13: Cycle Storage - Policy Q15: Boundary Treatments - Policy Q19: Westminster World Heritage Site - Policy Q20: Statutory Listed Buildings - Policy Q21: Registered Parks and Gardens - Policy Q22: Conservation Areas - Policy Q23: Undesignated Heritage Assets: Local Heritage List - Policy Q25: Views - Policy S2: New or Improved Community Premises - Policy T1: Sustainable Travel - Policy T2: Walking - Policy T3: Cycling - Policy T6: Assessing Impacts of Development on Transport Capacity - Policy T7: Parking - Policy T8: Servicing

5.7 Regional Guidance

5.7.1 Relevant publications from the GLA:

- Accessible London: Achieving and Inclusive Environment SPG (2014) - Central Activities Zone SPG (2016) - The Control of Dust & Emissions During Construction & Demolition SPG (2014) - Character and Context SPG (Jun 2014) - Sustainable Design and Construction SPG (2014) - London View Management Framework SPG (2012) - London World Heritage Sites SPG (2012) - Planning for Equality and Diversity in London SPG (2007) - Use of Planning Obligations in the Funding of Crossrail, and the Mayoral Community Infrastructure Levy SPG (2013)

5.8 Local Guidance / Supplementary Planning Documents (SPDs)

5.8.1 Relevant local guidance and SPDs for Lambeth:

- Advertisement & Signage Guidance - Parking Survey Guidance - Refuse & Recycling Storage Design Guide - Waste & Recycling Storage and Collection Requirements - Air Quality Planning Guidance Note - Lambeth Local Views Study - Lambeth Palace Conservation Area Statement - Albert Embankment Conservation Area Statement

- Draft S106 SPD

6 PLANNING OFFICER’S ASSESSMENT

6.1 Land Use

6.1.1 As explained in the ‘Site and Surroundings’ section, the Library contains a collection of books of international importance. Their presence at the Palace makes a major contribution to the historic significance of Lambeth Palace. However, the current arrangements for the storage of the collection is clearly inadequate, with the collection being affected by damp and air pollution. Significant interventions into the historic fabric of the Palace buildings would be required in order to provide the appropriate conditions required for the storage of the books, some of which are of a considerable age. Furthermore, the accessibility of the collection is poor, with part of the collection currently housed within a storage facility in Bermondsey where there is no public access.

6.1.2 The new Library facility is therefore proposed to house the entire collection of 120,000 books, thereby preserving the collection for future generations and in line with Archbishop Bancroft’s decree.

6.1.3 The Site falls within the CAZ, with strategic policy seeking to enhance and promote the unique international, national and London wide roles of this central London area. Policy also seeks to sustain and enhance the distinctive environment and heritage of the CAZ. LLP Policy ED11 explains that visitor attractions within the CAZ will be supported where they meet local and wider needs for arts and cultural facilities. Details on visitor management are given in the ‘Design and Conservation’ and ‘Standard of Library Facility’ sections of the report as required by LLP Policy ED11.

6.1.4 The provision of a new building within the grounds of Lambeth Palace is discussed further in the ‘Conservation and Design’ section of the report and it is noted that some harm would be caused to the significance of certain designated heritage assets. Furthermore, the loss of part of the listed Registered Garden is discussed in the ‘Trees, Landscaping and Ecology’ section of the report. Alternative locations have been considered for the new Library facility, including removing the collection from its current location and placing it with other remaining parts of the collection in Bermondsey and elsewhere. The relocation of the collection off-site would be harmful to the historical significance of the Palace, of which the on-site collection makes a major contribution towards. Furthermore, the internal interventions that would be required to the Palace buildings in order to provide suitable storage conditions for the collections, would also be harmful to their historic character. Noting the location of the Site within the CAZ and in an area with excellent access to public transport, the principle of the location of the Library at the end of the Palace gardens, directly accessed off Lambeth Palace Road is considered acceptable, subject to a further analysis on other matters such as the impact of the development on the designated heritage assets and on the loss of part of the garden.

6.2 Design and Heritage Assets

6.2.1 This section of the report deals with conservation (heritage) and design matters arising from the proposed development. It is set out under the following sub headings:

(a) Scale, massing, layout and appearance; (b) Tall buildings and views; (c) Legislative and national policy considerations; (d) Impact on designated heritage assets: Conservation Areas; (e) Impact on designated heritage assets: Listed Buildings; (f) Impact on designated heritage assets: Impact on Historic Park and Garden; (g) Impact on non-designated heritage assets: Locally Listed Buildings/Structures and Archaeological Priority Area (h) Cumulative impact on heritage assets;

(i) Impact upon heritage assets: Summary; (j) Assessment of harm versus benefits.

6.2.2 The Council’s Conservation & Design Officer’s comments are cross-referred to within the following sub-sections below where relevant.

(a) Scale, massing, layout and appearance

6.2.3 LLP Policy Q5 states that development should provide a positive response to the local context and historical character, and where proposals deviate from this, it should be demonstrated how the proposal clearly delivers design excellence and how it will make a positive contribution to its local and historic context.

6.2.4 LLP Policy Q7 seeks new development to be of a high quality design which has a bulk, scale, mass, siting, building line and orientation which adequately preserves or enhances the prevailing local character. It should be built of durable, robust and low- maintenance materials and have well considered fenestration.

6.2.5 The proposed Library would be sited along the northern boundary of the Palace gardens to Lambeth Palace Road, forming the boundary to the Site in this area in place of the existing modern section of the Grade II listed wall.

6.2.6 The massing of the building is typically that of a 4/5-storey building which would form the two wings, centred by a 9-storey tower. The northern wing of the building would be 5-storeys in height, whilst the southern wing would be 4-storeys in height, ensuring that the massing steps down as you approach the main Palace buildings from the north.

Figure 10: View along Lambeth Palace Road from the north, looking towards Lambeth Palace

Figure 11: View of the rear of the building with the improved landscaped garden visible from the publically accessible areas at the lower part of the building and from the top floor

6.2.7 The building would be constructed from handmade red bricks. Given the nature of the use of the proposed Library, most of the façades would be devoid from glazing, and therefore various forms of brick detailing are proposed in order to provide articulation to the building as a whole and to provide emphasis to the central tower. This will also allow for the bulk of the building to be appropriately managed and together with the use of glazing to the base section of the building, it will ensure that it will have a human-scale and animation along the street frontage. The bottom two floors of the building would contain the main publically accessible areas, and the use of glazing here will ensure an appropriate level of animation to the building and will allow for public appreciation of the historic Palace garden for the first time, with significant landscaping improvements also proposed. The careful siting of the building will ensure that the privacy of the Archbishop is retained, with views towards the Palace itself restricted.

Figure 12: Views into the Palace gardens from the double height entrance hall

Figure 13: The reading room, at ground floor level, providing views into the gardens 6.2.8 Bronze panels, bronze-finished aluminium together with glass would be used to emphasise the entrance portal. Bronzed metal louvers, recessed in the central openings of the tower, will provide ventilation to the plant room behind. Bronze would be used again to the top floor of the building, which would be largely glazed, providing an appropriate lightweight cap to the building, whilst ensuring a coherent use of materials throughout.

Figure 14: The base of the central tower feature, with the glazed entrance area, providing direct views through to the Palace gardens from the street

6.2.9 The siting, massing, form and detailing would positively respond to the listed buildings and structures within the Palace complex, where some of the most historic buildings are brick built towers, most notably Morton’s Tower, which sit prominently at the south end of Lambeth Palace Road. Furthermore, the listed brick boundary wall to Lambeth Palace Road would provide a physical connection between these old and new brick towers, thus reinforcing the historic character of the Site. The building would provide public appreciation of the Palace gardens for the first time, whilst ensuring that the privacy of the Archbishop is protected.

6.2.10 In summary, it is considered that the building would provide an appropriate response to the historic character of the Site and its surroundings. Conditions are suggested to ensure the proposed building is appropriately finished. However, given the number of designated and non-designated heritage assets both within the Site and surrounding the Site, this is subject to a further analysis in the following sections.

(b) Tall buildings and views analysis

6.2.11 The report will now turn to the principle of a tall building as part of the development.

6.2.12 In terms of the height of the proposed building, it should be noted that the main bulk of the building would extend up to 4/5-storeys, with the central tower feature being the tallest element of the building, at 9 storeys, at approximately 32 metres in height and 24 metres in width. The Site is not located within an area which has been identified as being inappropriate for tall buildings as referred to by LLP Policy Q26.

6.2.13 Policy Q26 of the LLP explains that there should be an ‘impact led’ approach towards the provision tall buildings. The permissive approach to this policy was based on a recognition that the northern half of Lambeth is characterised by tall buildings from the 1950s to 1970s. These are sometimes solo and sometimes in pairs of clusters and are an established part of Lambeth’s built form. The majority of these buildings were built by Lambeth Council and the LCC / GLC. Policy Q26 is therefore considered being supportive of tall building development where it is not harmful.

6.2.14 It is acknowledged that views of the Development would be available both immediately surrounding the Site along Lambeth Palace Road and in Archbishops Park in particular, and also further afield where glimpses of the tower would be possible. However, the principle of a taller element to the building is not considered problematic, subject to the preservation of protected views, local views and designated and non-designated heritage assets.

6.2.15 LLP Policy Q25 seeks to resist harm to the significance of strategic views and the composition and character of views of local interest. The Site falls within the backdrop of Parliament Square to Palace of Westminster – Townscape View (LVMF 27), and within the protected views of LVMF 18 from Westminster Bridge and LVMF 19 from Lambeth Bridge. The Site falls outside any protected local views, but given the sensitive nature of the Site in terms of designated heritage assets, an assessment on a number of views, including protected views, was carried out in the Townscape, Visual Impact and Heritage Assessment (TVIHA) as submitted by the applicant. Details of the views assessment that was carried out is given below.

Figure 15: The views assessment carried out in the TVIHA submitted by the applicant

6.2.16 In terms of LVMF 18 from Westminster Bridge (View 1 of the TVIHA), it is apparent that the Development would not be visible within this protected view, with the wireframe of the building shown below to be behind the buildings of St. Thomas’ Hospital and the Evelina Children’s Hospital.

Figure 16: LVMF 18A.3 from Westminster Bridge with the Development outlined in green

6.2.17 The Development (outlined in green) would also not be visible from LVMF 19 (View 6 of the TVIHA) from Lambeth Bridge, noting that the buildings of Lambeth Palace itself would screen the Development from view.

Figure 17: LVMF 19A.2 from Lambeth Bridge with the Development outlined in green

6.2.18 Long ranging views of the Development would be possible from the north-bank of the River Thames, with glimpses of the tower possible from the Westminster World Heritage Site. However, given the context of the backdrop of historic brick built towers and the buildings of St. Thomas’ Hospital, this is not considered to be harmful to these views.

Figure 18: Proposed View 9 from the TVIHA from Victoria Tower Gardens with only glimpses possible of the top of the tower

Figure 19: Proposed View 10 from the TVIHA from the Palace of Westminster

6.2.19 In terms of local views, as stated previously, the building will be more prominent within these views given the shorter separation distance. However, the excellent architectural detailing of the building can be appreciated in the areas closer to the Site, as can the positive links in character and form to the surrounding historic context, such as the existing character of brick built towers. Local views towards Lambeth Palace and the Palace of Westminster would not be unacceptably harmed.

Figure 20: View 2 (winter), existing and proposed from the TVIHA, from the north of the Site on Lambeth Palace Road

Figure 21: View 3 (winter), existing and proposed from the TVIHA, from Archbishops Park

6.2.20 Given the above, the height and massing of the proposed building is considered to be acceptable.

(c) Legislative and national policy considerations

6.2.21 This section sets out the legislative and national policy context for the Officer assessment of the impact of the development proposal on the historic environment and its heritage assets.

Legislative Framework

6.2.22 The following legal commentary is provided:

6.2.23 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.

6.2.24 Section 72(1) 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.

6.2.25 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

6.2.26 Paragraph 17 of the NPPF sets out 12 “core planning principles” that should underpin both plan-making and decision-taking. Those principles include the following: “Planning should always seek to secure high quality design and should conserve heritage assets in a manner appropriate to their significance so that they can be enjoyed for their contribution to the quality of life of this and future generation”.

6.2.27 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”.

6.2.28 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).

6.2.29 “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”.

6.2.30 Paragraph 129 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.

6.2.31 Paragraphs 131 and 132 of the NPPF provide as follows:

131. In determining planning applications, local planning authorities should take account of:  the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation;  the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and  the desirability of new development making a positive contribution to local character and distinctiveness.

132. 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. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.

6.2.32 Paragraph 133 of the NPPF deals with substantial harm to or total loss of significance of significance of a designated heritage asset.

6.2.33 Paragraph 134 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.

6.2.34 Paragraph 135 of the NPPF deals with non-designated heritage assets as follows:

135. 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.

6.2.35 Paragraphs 137 and 138 of the NPPF are as follows:

137. 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 or better reveal the significance of the asset should be treated favourably.

138. Not all elements of a World Heritage Site or Conservation Area 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 133 or less than substantial harm under paragraph 134, 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.

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

Approach required

6.2.37 Turning to consider the application of the legislative and policy requirements set out above, the first step is for the decision-maker to consider each of the designated 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 significance of the designated heritage asset.

6.2.38 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. 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.

6.2.39 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.

6.2.40 The case-law also establishes that even where the harm identified is less than substantial (i.e. falls within paragraph 134 of the NPPF), that harm must still be given considerable importance and weight.

6.2.41 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. In their response, Historic England has not suggested that the cumulative effect of the individual instances of harm identified amounts to substantial harm and Officers do not consider that the total harm (i.e. the cumulative effect of the several instances of harm identified) amounts to substantial harm in this case. Looking at the position as a whole, there are a number of adverse impacts on heritage features which individually and cumulatively result in less than substantial harm. However, less than substantial harm does not mean insignificant harm. Considerable importance and weight must be attached to each of the harms identified and to their cumulative effect.

6.2.42 What follows is an Officer assessment of the extent of harm which would result from the proposed development to the identified heritage assets. This includes Conservation Areas, Listed Buildings and the Registered Garden. 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.

6.2.43 Officers have taken into account the Design Officer comments, the relevant conservation area statements, listed building entries and judgements reached in the Applicant’s Townscape, Visual Impact and Heritage Statement and the comments of HE.

(d) Impact on Conservation Areas

6.2.44 The Site is located within the Lambeth Palace Conservation Area and is adjacent to the Albert Embankment Conservation Area to the west and the Westminster Abbey and Parliament Square Conservation Area further to the west in the adjacent London Borough of Westminster.

Lambeth Palace Conservation Area

6.2.45 The Lambeth Palace Conservation Area encompasses all of Lambeth Palace and the adjacent Archbishop’s Park, with the boundary running through the centre of Lambeth Palace Road to the west, Royal Street to the north, Carlisle Lane to the east, and Lambeth Road to the south (with small sections extending further south). The openness of the gardens of Lambeth Palace when viewed along Lambeth Palace Road forms a strong part of the character and appearance of the conservation area.

6.2.46 Lambeth Palace has developed over many hundreds of years and its character is rich and varied as a result. A new high-quality addition to the Palace complex would be part of this historic evolution. It is considered that the building has been carefully designed to reinforce the established architectural character of the Palace complex, but it is acknowledged that the principle of the new Library building will make a significant change to that part of the conservation area by introducing a large building where there was not one previously. However, the carefully considered mass and excellent architectural detailing would ensure that that change is largely a positive one – both in terms of townscape as it would counter-act the current dominance of the Evelina Children’s Hospital on Lambeth Palace Road, and by providing activity at this end of the conservation area. The loss of the section of the listed wall and the impact on the sense of openness within the landscape would have an effect on the character and appearance of the conservation area, but Officers consider this harm to be less than substantial.

Figure 22: View 4 (winter), existing and proposed from the TVIHA, Lambeth Palace Road to the south of the proposed library

Albert Embankment Conservation Area

6.2.47 The Development would be positioned within the Lambeth Palace Conservation Area, but given the boundary of this runs through the centre of Lambeth Palace Road, and given the areas to the opposite side of Lambeth Palace Road are within the Albert Embankment Conservation Area, the Development would be visible within the setting of this conservation area. Whereas whilst the character of the Lambeth Palace Conservation Area is that of openness in the area around the Site, the character of the Albert Embankment Conservation Area is that of red brick buildings, of which the Development would fall within its setting. As such, it is considered that the setting of the Albert Embankment Conservation Area would be preserved.

Westminster Abbey and Parliament Square Conservation Area

6.2.48 Given the distance of the Development from this conservation areas, and the minor glimpses of the tower element that it would provide from the north bank of the river, Officers consider no harm to be caused to the setting of this conservation area.

(e) Impact on Statutory Listed Buildings

6.2.49 As per the national policy and LLP Policy Q20, development should conserve and not harm the significance/special interest of statutory listed buildings and should not harm the significance of their setting (including views to and from). It is noted that the Site contains the Grade I listed Lambeth Palace within the Palace complex, as well as the Grade II listed boundary wall to Lambeth Palace Road. The following statutory listed buildings/structures also surround the Site:

- The Palace of Westminster, which is Grade I listed and the designated World Heritage Site - South Wing of St. Thomas’s Hospital, excluding the post 1926 courtyard infill buildings, and Block 9 of St. Thomas’s Hospital Medical School, both are Grade II listed - The Church of St. Mary, Lambeth Road (former parish church and now Garden Museum) is Grade II* listed - The walls, railings, gates, and gate piers to the south and west of the Church of St. Mary are Grade II listed - There are three Grade II* listed tombs within the churchyard: . Tomb of William Sealy . Tomb of Admiral Bligh . Tomb of John Tradescant and Family - Lambeth Bridge and attached parapets, light standards and associated walls, approaches and obelisks, are Grade II listed - The former Holy Trinity Primary School (infants’ annexe) and No. 220 Lambeth Road, are Grade II listed - The front wall and gate piers to the former Holy Trinity Primary School (infants’ annexe) and No. 220 Lambeth Road, are Grade II listed - No. 214 Lambeth Road (St. Mary’s Rectory) is Grade II listed - Nos. 204 to 212 (even) Lambeth Road are Grade II listed - Nos. 4 to 8 and Nos. 9 to 12 (consec.) Pratt Walk are Grade II listed

Lambeth Palace and Boundary Wall

6.2.50 The proposed building would be located at the furthest point on the Lambeth Palace site from the listed buildings; because of this the two can’t be viewed together in close proximity of one-another in their entirety. However, there are similarities of character which help the proposed building respond positively to this listed building. For example some of the most historic buildings in the complex are the brick built towers which sit prominently at the southern end of Lambeth Palace Road – Morton’s Tower being the key one. The proposal too is a brick tower and the listed brick boundary wall to Lambeth Palace Road would provide a physical connection between these old and new brick towers, thus reinforcing the historic character of the site.

6.2.51 In views outward from the listed building northwards up through the garden, the Development will be visible rising over the treetops. However, its presence doesn’t isn’t in itself result in harm to the listed building. The presence also has the benefit of being partially screening the Evelina Children’s Hospital from view. The setting of the listed buildings would not be harmed.

Figure 23: View of the Development from the first floor of Lambeth Palace

6.2.52 The construction of the Library necessitates the demolition of a section of the Grade II listed wall that encloses the garden along Lambeth Palace Road. This section of the wall was erected when Lambeth Palace Road was re-aligned in the 1960s; therefore the fabric of the wall is not particularly old or historic. The historic section of the wall which was constructed in the 19th century, would remain unaltered and therefore the historic interest of the wall would not be harmed. The demolition would result in a shortening of the wall and a reduction in its physical presence along Lambeth Palace Road. This would have a modest adverse impact on the special architectural interest of the wall, but Officers consider this harm to be less than substantial, noting the historic section of the wall would remain unaltered.

Other Statutory Listed Buildings/Structures

6.2.53 Similarly to the assessment made on the surrounding conservation areas, it is also considered that the setting and historical significance of the surrounding statutory listed buildings and structures would be preserved with no harm caused. This is due to only glimpses of the building being possible within the backdrop of the surrounding designated and non-designated heritage assets, including that from the World Heritage Site. Furthermore, the publically accessible roof-top pavilion would provide a vantage point where both Lambeth Palace and the Palace of Westminster complexes could be appreciated together, reinforcing our understanding of the Outstanding Universal Value of the World Heritage Site and the important Church and State roles of the sites play to British Parliamentary democracy. This is a heritage benefit.

Figure 24: An aerial image of the proposed library, with the central tower feature providing a positive response to the historic context of the Site and surroundings

Figure 25: Views from the Upper Room terrace, the top floor of the tower

(f) Impact on Registered Landscape - Historic Park and Garden

6.2.54 The gardens of Lambeth Palace are a Grade II listed Registered Park and Garden. It is one of the largest private gardens in London and sits immediately north and east of the Lambeth Palace buildings. The garden is formal in character immediately beside the Palace and becomes increasingly informal as one moves northward. The current layout largely dates from the 1980s and follows traditional lines. The north-most end of the garden has an informal character of trees and a small pond – attractive but of little historic interest. Before the works in the 1980s this end of the garden was derelict. Northward views across the garden from the Palace are fairly limited because of the number of trees. However, the tall buildings of the St. Thomas’ Hospital Complex rise up in the backdrop – the Evelina Children’s Hospitals’ large glazed roof being particularly dominant. Its glazed treatment, curved form and sheer proximity result in a discordant visual impact on the landscape, especially in winter. An appreciation of the garden’s character from outside the Palace grounds is virtually impossible because of the presence of solid boundaries of fencing to Archbishops Park and the listed wall to Lambeth Palace Road. However, the numerous mature trees within the Site can be seen and produce a particularly attractive effect when viewed in conjunction with the wall along Lambeth Palace Road. The building has been well designed to mitigate against its impact within the historic landscape; however, there is no escaping that its presence does have an impact on the openness and spatial quality of the landscape. Officers consider this harm to be less than substantial.

(g) Impact on Non-Designated Heritage Assets: Locally Listed Buildings/Structures and Archaeological Priority Area

6.2.55 The Site is located within the Lambeth Palace Archaeological Priority Area. Furthermore, the following locally listed buildings/structures surround the Site:

- Timber shelter at southern end of Archbishop’s Park - Lambeth Palace lamp column on approach to Lambeth Bridge - Lambeth Pier, Albert Embankment - Entrance gate to Archbishop’s Park, Lambeth Road - Paving between Lambeth Bridge and Westminster Bridge - Bollards on the central reservations on the west and east sides of the railway bridge, Lambeth Road - No. 178 Lambeth Road - No. 180 Lambeth Road - No. 218 Lambeth Road - Marine Institute, No. 202 Lambeth Road - Street frontage building at No. 202 Lambeth Road

Lambeth Palace Archaeological Priority Area No. 1

6.2.56 The Site sits within an Archaeological Priority Area. Historic England Archaeology have provided comments on the application, and are satisfied with the preliminary investigations that have taken place prior to submission. However, further investigations will be required during the construction of the Development in order to appropriately preserve any archaeological artefacts located at the Site. A condition has been suggested to be added in this respect.

Other Locally Listed Buildings/Structures

6.2.57 It is considered that the historic significance of the locally listed buildings and structures that surround the Site would be preserved following the Development and no harm would be caused.

(h) Cumulative assessment of the impact of development to the designated heritage assets

6.2.58 As outlined above, an individual assessment has been carried out against each heritage asset, and Officers have concluded that less than substantial harm would be caused by the development on the Registered Park and Garden and Lambeth Palace Conservation Area. Officers also consider that the cumulative impact of the Development on the significance of designated heritage assets to be less than substantial.

(i) Impact upon heritage assets: summary

6.2.59 The proposed development site lies within a sensitive historic context of national (if not international) significance and upon land which has not been developed since the Palace grounds were first enclosed in 1197. As such, it is likely inevitable that any development here will result in a degree of adverse impact to the historic environment, simply through encroachment into the historic grounds of the Palace.

6.2.60 In conclusion, due to the loss of openness of the Registered Park and Garden and Lambeth Palace Conservation Area, and due to the shortening of the listed boundary wall, it is considered that less than substantial harm would be caused to these heritage assets. This harm is limited noting the appropriate siting, massing, choice of materials and detailing of the proposed building. Officers have considered the cumulative impacts of this harm, but do not consider that the Development would result in substantial harm in this respect.

(j) Assessment of harm versus benefits

6.2.61 The NPPG provides guidance on the meaning of public benefits. It advises that public benefits:

“may follow from many developments and could be anything that delivers economic, social or environmental progress as described in the National Planning Policy Framework. Public benefits should flow from the proposed development. They should be of a nature of scale to be of benefit to the public at large and should not just be a private benefit. However, benefits do not always have to be visible or accessible to the public in order to be genuine public benefits.

Public benefits may include heritage benefits”

6.2.62 Officers have concluded that less than substantial harm would be caused to the designated heritage assets of the Registered Park and Garden, Lambeth Palace Conservation Area, and the listed wall, and no harm would be caused to the significance of the non-designated heritage assets. It is noted that there should be a strong presumption in favour of the preservation of designated heritage assets and that presumption must be the starting point of the decision making process.

6.2.63 The Lambeth Palace Library collection has been housed at Lambeth Palace since 1610 when Archbishop Bancroft’s private collection of books and manuscripts, which include records from the 9th century to the present day, were turned into a free public library, one of the first of its kind in England. The Library and archive collection are a highly important and integral part of the historic and communal values of the Lambeth Palace complex. The current arrangements for the storage of the collection are clearly inadequate, both for the collection and for the buildings currently housing them, for example with the insertion of structural steelwork into Morton's Tower has harmed its Tudor fabric.

6.2.64 The removal of the collection from the Lambeth Palace site would be particularly harmful to its significance and therefore its retention in a new fit-for-purpose facility is strongly supported. Importantly, this would also relieve the pressure on the Grade I listed buildings which are currently housing the collection, allowing them to be repaired and put into a suitable new use consistent with their conservation and long term viable use. Were the collection to be retained on-site but without a purpose built facility, significant and likely significantly harmful interventions would be required to the historic fabric of the listed buildings in order to provide a suitable library facility. It is unlikely however that the same quality of facilities could be provided were this option to be chosen.

6.2.65 The applicant has undertaken a rigorous assessment of alternative site locations, considering the relative merits and demerits of these alternative sites. As such, Officers are content that the plot chosen, being furthest away from the Grade I listed buildings, is the least harmful location if the library collection is to be retained on-site.

6.2.66 Officers consider that the Development would deliver major heritage benefits:

(1) The retention of the internationally important collection on-site for public access within a suitable purpose built facility, which has been carefully designed to ensure proper future conservation of the collection.

(2) Raised profile of the collection and much improved public access to it.

(3) New public views onto the Palace garden.

(4) Top of the tower will be publically accessible, providing a vantage point of both the Lambeth Palace and Palace of Westminster complexes, and allow for these to be appreciated together, thus reinforcing our understanding of the Outstanding Universal Value of the World Heritage Site and the important Church and State roles of the sites play to the British Parliamentary democracy.

(5) Arrangements to this area as well as the rest of the building will be secured and managed through a Visitor Management Plan, which will be required as part of the Section 106 Agreement. This will ensure that public access to the building and collection would be maximised as requested by the GLA

(6) Other historic buildings on the site made available for refurbishment / more appropriate re-use.

6.2.67 Together with the major heritage benefits that the Development would provide, a number of other public benefits would also be provided:

(1) An improved public realm and activation to this part of Lambeth Palace Road.

(2) Ecological benefits of an improved landscaped.

(3) Level access to the collection for those with mobility issues.

6.2.68 Given the above, it is considered that the Development would provide sufficient public benefits that would, having attached considerable weight and importance to the less than substantial harm that would be caused to the significance of the designated heritage assets of the Registered Park and Garden, Lambeth Palace Conservation Area, and the listed wall, outweigh the harm that would be caused by the Development. The Development would as such accord with paragraph 134 of the NPPF, the statutory obligations contained within Sections 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, and the relevant London Plan and Lambeth Local Plan policies.

6.3 Standard of Library Facility

6.3.1 The Library has been designed specifically for its needs of storing an old collection of books of international importance. Appropriate access arrangements are therefore required, but there will be a number of publically assessable areas within the building, including the entrance hall, readings rooms, and the upper room within the tower. It is noted that access to these area will need to be controlled, with final details of this to be requested within the Visitor Management Plan, which will be required as part of the Section 106 Agreement.

6.4 Amenity

6.4.1 The Site is not located adjacent to any residential development, but it is located across Lambeth Palace Road from the Evelina Children’s Hospital, which has inpatient rooms facing towards the Site.

6.4.2 The following assessment has been provided with regard to the potential impacts of the development on neighbouring amenity.

Daylight and Sunlight

6.4.3 A Daylight/Sunlight Assessment has been undertaken by Point 2 Surveyors on behalf of the applicants

Scope of the assessment

6.4.4 The relevant atrium rooms within the Evelina Children’s Hospital have been assessed using a three-dimensional computer model of the site and surrounding context. Floor plans of the consented scheme were also used and have been incorporated into the model.

6.4.5 Figure 26 below shows the assessment models which were used.

Figure 26: Assessment models used

6.4.6 Point 2 Surveyors also tested the Palace gardens and the neighbouring Archbishop’s Park.

Assessment of the Results – Daylight to neighbouring properties

6.4.7 The assessment provided demonstrates that the Development would adhere to BRE Guide target criteria with regard to daylight to the rooms within the atrium of the adjacent Evelina Children’s Hospital, and given there are no other residential properties surrounding the Site, the application is considered acceptable in this respect.

Assessment of the Results – Sunlight to neighbouring properties

6.4.8 Point 2 Surveyors have reviewed sunlight to the atrium rooms within the neighbouring Evelina Children’s Hospital, and as per the BRE Guide, for assessment of windows that face within 90 degrees of south (assessment of windows that face within 90 degrees of north is not applicable on the basis that the availability of sunlight is already limited). The Development would not result in any reductions in sunlight levels to this property beyond that permitted in the BRE guidance.

Assessment of the Results – Sunlight to neighbouring gardens/amenity spaces

6.4.9 For sunlight levels to neighbouring amenity, the reports provided gave a detailed review of the impact of the Development on the Palace gardens and the neighbouring Archbishop’s Park in terms of the BRE Guide 2 hour amenity test at the 21st March spring equinox, with details given below in Figure 27. As can be seen in the assessment provided, the Development would have a minimal impact on the levels of sunlight received in these amenity areas.

Figure 27: Overshadowing analysis for amenity areas existing and proposed at the 21st March spring equinox. Areas in yellow are areas which would receive 2 hours of direct sunlight at the equinox, with percentage figures stating amount of amenity areas that would receive 2 hours of direct sunlight at the equinox

Assessment of the Results – Conclusion

6.4.10 Given the above assessment, it is considered that the Development would not impact unacceptably on the surrounding properties with regard to daylight, sunlight and overshadowing.

Outlook and Sense of Enclosure

6.4.11 In terms of outlook, similarly to the above assessment, given the lack of residential properties surrounding the Site, there are not any significant concerns regarding the potential loss of outlook to properties. Good levels of outlook would be retained from the neighbouring Evelina Children’s Hospital, which is the nearest sensitive property in this respect.

Noise

6.4.12 The proposed Library would almost entirely provide fully enclosed facilities. Access into the garden area would be restricted, and therefore the only increase in noise that would be caused would be through the use of the roof-top terrace to the tower, and through general access movements to and from the Site. It is considered that the operation of the building and use of the roof-top terrace would not result in a significant and unacceptable level of noise, and therefore the application is acceptable in this respect. Conditions are suggested however to control the level of noise from the building.

Privacy

6.4.13 The Development due to its siting and distance to surrounding properties would adequately retain the privacy of both the Archbishop within Lambeth Palace, and those within the adjacent Evelina Children’s Hospital. Furthermore, apart from the roof-top terrace and room to the tower, the publically accessible areas would be limited to the lower part of the building.

Conclusion

6.4.14 Given the above assessment, the application is considered acceptable with regard to amenity.

6.5 Transport

6.5.1 Policy T1 of the Lambeth Local Plan states that the Council will promote a sustainable pattern of development in the Borough, minimising the need to travel and reducing dependence on the private car.

Access

6.5.2 The Development would be accessed directly off Lambeth Palace Road, with the building positioned along the boundary of the Site to the road. A new vehicular access is proposed to provide access into a servicing area, where the loading and unloading of books would take place within a secure environment. This is a requirement due to the sensitive nature of the collection and that of Lambeth Palace itself. The collection of refuse and recycling and the general day-to-day servicing of the building would take place within the proposed loading bay, which would form part of the proposed vehicular access. This loading bay forms part of the public footway as existing, and in order to retain a sufficiently wide footway around the loading bay, an area of land would need to be adopted by TfL, as shown in the green hatched area below. This would be secured through the Section 106 Agreement.

Figure 28: The proposed access arrangements with the area hatched in green proposed to be adopted by TfL in order to retain a sufficiently wide public footway

6.5.3 The proposed access arrangements would require the removal of street-tree T79, which is a False Acacia. The loss of this tree has been accepted by TfL subject to a financial payment from the applicant to compensate for its loss, and also subject to its appropriate replacement in the form a new street-tree planting. This would be secured through landscaping conditions and through the Section 106 Agreement.

Figure 29: The implications of the Development on existing street-trees

6.5.4 Subject to conditions and obligations contained within the Section 106 Agreement, the proposed access arrangements are considered acceptable.

Trip Generation

6.5.5 The applicant has provided details regarding the likely number and method of trips to and from the Site, with details given in the below table. Following comments from the Council’s Transport Officer and from TfL, it is considered that these trips can be accommodated on the existing transport network.

AM Peak Hour PM Peak Hour Daily Mode 08:00-09:00 17:00-18:00 08:00-18:00 Motorcycle 0.03 0.03 0.24 Cycle 0.94 1.14 8.97 Walking 4.31 5.23 41.08 Tube 17.17 20.84 163.78 Train 8.04 9.76 76.74 Bus 11.08 13.45 105.70 Taxi 0.13 0.15 1.21 Total 41.7 50.6 397.72

6.5.6 The application was also accompanied with a Travel Plan, setting out how more sustainable methods of transport to and from the Site, would be promoted. The final version of this would be secured by condition, with an obligation contained within the Section 106 Agreement to ensure that a contribution is provided by the applicant for its monitoring.

Cycling

6.5.7 Policy T3 of the Lambeth Local Plan requires development to provide cycle parking in accordance with London Plan requirements. Storage for 6 bicycles would be provided within the servicing area, and a further 20 cycle parking spaces would be provided on-street, in the area of footway within the ownership of the applicant. The level of cycle storage proposed is acceptable, meeting London Plan policy requirements. However, the management of the access to the secure servicing area within the Site, will need to be managed appropriately. Details of this would be requested within the Visitor Management Plan, which itself would be secured through the Section 106 Agreement. Whilst details have been provided of the cycle parking to the front of the Site, further details of the cycle storage within the Site itself are required. This is recommended to be requested by condition.

Car Parking

6.5.8 The Site would not provide any general car parking, and given the excellent access to public transport that the Site has, this is considered acceptable given the other methods available to arrive to and leave from the Site. Furthermore, as the site is located within a CPZ, it would not be possible for staff or visitors to park within the surrounding streets during the restricted hours of the CPZ. A clause within the Section 106 Agreement would ensure that the Development would be Business Permit-free. A blue badge car parking space would be provided on-site, but access arrangements to this and the management of this space, is required. This should be provided within the Visitor Management Plan as part of the Section 106 Agreement.

Pedestrian Movement

6.5.9 The pedestrian audit submitted has been assessed, and it noted that pedestrian access from the opposite side of Lambeth Palace Road is available via the existing refuse island immediately north of the proposed access. However, level access is not possible due to the lack of dropped kerbs. The applicant has agreed to provide dropped kerbs to this refuge island, with details to be secured as part of the Section 278 Highways Agreement, which itself would be secured through the Section 106 Agreement.

Deliveries and Servicing

6.5.10 As explained in the ‘Access’ section, deliveries and servicing would take place either at the front of the Site, using the proposed on-street loading bay, or within the secure servicing area on-site. The collection of refuse and recycling and the general day-to- day servicing would take place within the on-street loading bay, with the on-site servicing area limited to the loading and unloading of the collection to and from the Library. Access to the on-site servicing area would be restricted through the use of two sets of gates, with the gates to the highway to be opened when deliveries to this area are expected. These arrangements have been proposed partly due to the acute requirement to secure the contents of the collection, as well as to ensure the safety and security of the staff and public who would use the building. Furthermore, were access into the on-site servicing area be required for larger vehicles such as refuse vehicles, this would further reduce the size of the Registered Garden, and would likely require the removal of additional trees. The principle of the proposed servicing arrangements is therefore accepted. Also, it has been demonstrated that the on- street loading bay would not interfere with the vehicular access to the Site, meaning that a vehicle will be able to enter or leave the Site were a refuse vehicle be parked in the on-street loading bay. As such, this would not impact unacceptably on the operation of the highway. It is noted that details regarding the outline of the on-street loading bay would be secured as part of the Section 278 Highways Agreement (secured within the Section 106 Agreement), to ensure that access to the Site is not restricted by the on-street loading bay. Tracking details for the two servicing areas have been given in the submitted Transport Assessment, with details given below:

Figure 30: Top image demonstrating a refuse truck entering and leaving on-street loading bay; image below demonstrating access to on-site servicing area of a light good vehicle when a refuse truck is parking in the on-street loading bay

Figure 31: A light goods vehicle can enter and leave the Site in forward gear

6.5.11 In terms of the amount of deliveries that is anticipated, these are likely to be low in number, as the proposed use would not generate a significant amount of servicing. It is acknowledged that events would take place within the building, particularly to the top floor room of the tower. However, the servicing requirement for this is not likely to be excessive. A Delivery and Servicing Management Plan would be required as a condition to ensure the appropriate management of deliveries.

6.5.12 With regard to refuse management, an area for the storage of refuse and recycling storage has been shown within the on-site servicing area. As explained above, the collection of waste would occur within the on-street loading bay, which is located approximately 30 metres from the proposed storage area. Lambeth’s guidance on refuse and recycling storage typically requires this distance to be limited to 25 metres. However, it is not anticipated that the Development would generate a significant amount of waste, and given this recommended maximum distance would only be marginally exceeded, this is considered acceptable in this instance. Further details are required regarding the type of storage proposed and its management. This is recommended to be requested as a condition.

Construction Management

6.5.13 A draft Construction Logistics Plan (CLP) has been submitted with the application.

6.5.14 Access to the Site for construction would be from Lambeth Palace Road. Given a section of the existing wall would need to be removed to facilitate the development, access for construction would be available once this section of wall has been removed. In order to maintain full use of the footway during construction, a gantry is proposed. It is likely that street-tree T78 (shown at Figure 29 above) would need to be removed to facilitate the construction works, but as advised by TfL, the Construction Management Plan would need to assess whether this tree could be retained during construction. Details of this would be secured as a condition. Furthermore, as part of the Section 106 Agreement, a payment would be secured from the applicant to TfL for the removal of this tree should this be required, with details also secured for its replacement.

6.5.15 It is anticipated that the construction works would take approximately 2 years. Deliveries would be managed to ensure the continued safe operation of the highway, and deliveries would be made during off-peak times only. The site operation hours are anticipated to be Monday to Friday between 8am and 6pm, with no work taking place on Sundays or Bank Holidays.

6.5.16 The draft CLP is considered acceptable, with full details to be secured by condition, also ensuring appropriate measures are implemented to mitigate the impact of the construction of the Development on the adjacent hospital.

Conclusion

6.5.17 The application is considered acceptable subject to conditions and obligations contained within a Section 106 Agreement regarding the Travel Plan, car parking, cycle parking, street-trees, deliveries and servicing, waste management and construction management.

6.6 Trees, Landscaping and Ecology

6.6.1 The existing landscape of the gardens of Lambeth Palace contains a number of mature and younger trees, as well as containing a small pond. The Site is also a Grade I designated SINC.

Figure 32: The existing garden of Lambeth Palace. The bottom two images represent the approximate location of the Development. The large Horse Chesnut tree to the left of the centre image is to be retained. The existing pond can be seen in the bottom image

6.6.2 The existing trees T30, T31, T32, G34 (a group), T48, T49, T50, G51, T78 (street tree), T79 (street tree) and T82 would be removed to facilitate the Development. These trees are identified on the Tree Constraints Plan drawing contained in the Arboricultural Report prepared by Landmark Trees Ltd dated 16/12/16.

6.6.3 The aforementioned trees are situated towards the north-western boundary of the Site and are made up of a mixture of mature established trees and younger specimens of modest to low landscape value. Of these trees to be removed only the upper canopies of Horse Chestnut trees T48, T49 and T50 are visible from public views outside of the Site.

6.6.4 A number of further existing trees would be removed to allow for landscape enhancements as part of the new Library building, the trees to be removed can be listed as, T7, T15, G24a, T25, T26, T27, T28 and G29 and are also identified on the Tree Constraints Plan drawing.

6.6.5 Therefore a total of 19 existing trees would be removed. Of these, at least 1 no. street tree would be removed to facilitate the loading bay and access (T79). A second street tree (T78) may also need to be removed subject to final discussions with TfL regarding construction management and site access. At least 2 no. new street trees would be planted, with 3 no. new street trees planted were both street trees removed. These works would be secured in the Section 106 Agreement, with a financial contribution to TfL required to be paid by the applicant for the loss of these trees.

6.6.6 The following table provides details of the trees proposed to be removed:

Tree Number Type Category Reason for Removal T30 Common Ash C Facilitate Development T31 Common Ash C Facilitate Development T32 Black Poplar B Facilitate Development G34 Tree of Heaven U Facilitate Development G51 Alder C Facilitate Development T48 Horse Chesnut B Facilitate Development T49 Horse Chesnut U Facilitate Development T50 Horse Chesnut C Facilitate Development T78 (street tree) London Plane C Facilitate Development T79 (street tree) False Acacia B Facilitate Development T82 English Oak C Facilitate Development T7 Bird Cherry C Landscaping T15 Black Poplar C Landscaping G24a Silver Birch C Landscaping T25 Horse Chesnut C Landscaping T26 Scots Pine C Landscaping T27 Scots Pine C Landscaping T28 Black Poplar B Landscaping G29 White Willow C Landscaping

6.6.7 A significant landscaping scheme is proposed in order to mitigate the impacts of the Development against the loss of this part of the Registered garden and to ensure that the importance of the Borough Grade I SINC is preserved. A total of 35 new trees would be planted, with a new larger pond installed, the existing pathways would be modified to account for the new building and landscape and new benches would be installed within the garden. As part of the Development, Natural Stone paving would be installed to the footway outside the entrance of the Library, with final details to be secured within the Section 278 Highways Agreement. Details of the trees proposed to be removed and new landscaping scheme is given below, with an indication provided as to how the requirement to retain the privacy to the main part of the garden has influenced the proposed planting scheme. It should be noted that as part of the proposed landscaping scheme, some existing trees would be relocated, with these being a Memorial Beech tree, a Pear tree and a group of Yew trees:

Figure 33: The proposed landscaping scheme

6.6.8 As the submitted Arboricultural Report has explained (Section 6.0 – Discussion of impacts), the loss of the trees both to facilitate the Development and to allow for accompanying landscape enhancement of the Site would not be detrimental to the wider landscape character, as the tree removal is limited to a relatively small area of the Site that is screened from a public road (Lambeth Palace Road) by a high boundary wall and the retention of existing adjacent trees.

6.6.9 Through the development of the proposals the applicant has been involved in detailed discussions with the Council’s Biodiversity Officer to ensure an appropriate landscaping scheme has been designed, and a high level of detail has been provided at application stage. As the scheme is delivered the applicant is advised to work closely with the Biodiversity Officer to ensure the translocation of reptiles and amphibians from the existing pond in Lambeth Palace Gardens, as this will need to be drained down and covered over whilst the Library is constructed and then returned when the proposed new pond is in place. It is anticipated that potential receptor sites in the neighbouring Archbishop’s Park could be used. An informative is added in this respect. Given the landscaping improvements proposed, despite the loss of part of the gardens to Lambeth Palace, it is considered that the biodiversity value of the Borough SINC would be enhanced. The application is therefore considered to be in compliance with LLP Policy EN1.

Figure 34: The proposed landscaped areas to the rear

6.6.10 Finally, the construction impacts posed by any changes in existing soil levels and the position of the building generally can be mitigated against through the implementation of a Tree Protection Plan and an appropriate Arboricultural Method Statement in line with the recommendations set out in BS5837:2012. Conditions are recommended to ensure this.

6.7 Sustainable Design and Construction

6.7.1 Strategic Policy sets out the Mayor’s vision for London to become: “a world leader in improving the environment locally and globally, taking the lead in tackling climate change, reducing pollution, developing a low carbon economy and consuming fewer resources and using them more effectively”. LLP Policy EN4: ‘Sustainable Design and Construction’ requires development to meet the highest standards of sustainable design and construction feasible, relating to the scale, nature and form of the proposal. The LLP also requires major non-residential development to accord with BREEAM requirements, where at least BREEAM ‘Excellent’ should be achieved, unless it is demonstrated that it is not technically feasible or viable to do so, in which case proposals should achieve a ‘Very Good’ rating with a minimum score of 63%.

6.7.2 London Plan Policy 5.2 states that development proposals should make the fullest contributions to minimising carbon dioxide emissions in accordance with the following energy hierarchy:

1. Be lean: use less energy 2. Be clean: supply energy efficiently 3. Be green: use renewable energy 6.7.3 The Development as a whole is anticipated to achieve a 35% reduction in carbon dioxide emissions over Building Regulations requirements, which meets the London Plan target. The BREEAM pre-assessment indicates that the building would achieve an ‘Excellent’ rating, which meets the requirements of LLP Policy EN4.

6.7.4 The applicant has demonstrated that all opportunities to reduce carbon dioxide and maximise the sustainability of the building have been maximised through such measures as photovoltaic solar panels and the feasibility of connecting to a heat network. The use of a Combined Heat and Power (CHP) system would not be suitable in this instance given the anticipated low usage of water. In terms of cooling and overheating, it is acknowledged due to the requirement to provide temperature control in the archive areas, these areas have not been included within the analysis. This approach has been accepted by Officers.

6.7.5 Furthermore, the comments of the GLA are noted regarding the potential for a green/brown roof to be provided. Further detail was provided by the applicant to demonstrate that this would not be feasible in this instance given the unique nature of the development proposed, where the acute risks to the internationally significant collection are required to be minimised. As a green or brown roof could pose a potential risk in this respect, the principle of not providing a green or brown roof is accepted in this instance.

6.8 Flood Risk

6.8.1 The Site is located within Environment Agency Flood Zone 3, which in itself is considered to have a high risk of fluvial flooding. However, this risk is reduced by the flood defence systems along the River Thames. It is noted that no residential accommodation is proposed.

6.8.2 Policy EN5 of the LLP requires development in such areas to contribute positively to actively reducing flood risk through avoidance, reduction, management and mitigation. The NPPF requires the Local Planning Authority to apply the Sequential Test for new development in Flood Zone 3, which the Site is located within. The aim of this is to steer development towards areas with the lowest probability of flooding. Given the central London location of the Site, and its allocation within a CAZ it is considered unreasonable to prevent the development of the Site on flood risk issues alone. Further to the Sequential Test, the NPPF advises that ‘more vulnerable’ development can be considered appropriate in Flood Zone 3, following satisfactory application of the Exception Test. The Exception Test aims to ensure that more vulnerable property types are not allocated to areas at high risk of flooding. Residential uses are considered to be ‘more vulnerable’ forms of development.

6.8.3 The Development would not provide any residential uses and is considered to be a ‘less vulnerable’ form of development. As such, the Development is deemed appropriate with no Exception Test required.

6.8.4 As noted, the likelihood of the tidal flood defences being breached is low. Therefore, whilst the ‘residual’ risk is high, the actual flood risk to the Development is considered to be low.

6.8.5 Policy EN6 requires that sustainable drainage systems (SuDS) are incorporated in development proposals to mitigate and enhance the development’s impact on flood risk, water quality and habitat/amenity value. Whilst the Site would result in an increase in impermeable areas, it is proposed to introduce measures to collect rainwater and to direct rainwater to permeable areas within the garden or to the proposed pond. Subject to the installation of such measures, the application is considered acceptable in this respect.

6.9 Employment and Training

6.9.1 Policy ED14 of the Lambeth Local Plan seeks to use planning obligations that secure employment opportunities and apprenticeships during the construction phase of major developments and during its end use operation, so that local residents are given access to the right skills training so that they can take advantage of opportunities created by new development. The draft SPD on Section 106 obligations requires major developments to commit to providing a minimum of 20% of all construction jobs created by the development to local people. Furthermore, a minimum of 10% of all construction jobs created by the development is required to be provided for trainees and apprentices.

6.9.2 Whilst the Development would not generate any employment opportunities beyond those already employed at the existing Library, the Development would provide for employment opportunities during the construction phase. As part of a Section 106 Agreement, the Council will require the applicant to commit to obligations to employ local people during the construction phase. As part of the Section 106 Agreement the Council will require a completed ‘Employment and Skills Plan’ and ‘Worksmart’ document, setting out how the development will aim to achieve the targets set within the Section 106 Agreement. A financial contribution will also be required towards Local Labour in Construction.

6.10 Planning Obligations and CIL

6.10.1 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 its July 2013 revised draft S106 Planning Obligations Supplementary Planning Document (SPD) produced for consultation. The July 2013 revised draft S106 Planning Obligations SPD arose from a review of the S106 Planning Obligations SPD that was adopted in 2012.

6.10.2 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.

6.10.3 The proposed obligations to be secured through the Section 106 Agreement are as follows:

Obligation:

Travel Plan Monitoring Fee of £1,000.

Securing a financial contribution of £3,911 to TfL for the removal of street tree T78 and of £23,068 for the removal of street tree T79 (both located outside the Library entrance on Lambeth Palace Road).

A clause requiring the developer to enter into a Section 278 highways agreement to deliver the highway alterations of the vehicular access and loading bay outside the Library entrance, to deliver the public realm improvements of new paving to the footway and new street-tree planting, and to secure the new pedestrian island crossing with dropped kerbs immediately to the north of the entrance on Lambeth Palace Road.

A clause requiring the developer to enter into a Section 38 Highways Agreement to secure the adoption of part of the footway to the ownership of TfL.

Requiring the submission of a Visitor Management Plan, including setting out the number of days per year in which the top floor viewing terrace and room is open to the public. Also setting out arrangements for access to the on-site Blue Badge parking bay and cycle parking.

Securing the Development as Business Permit-free.

Securing employment and training opportunities including apprenticeships, procurement, training and brokerage arrangements, during the construction phase of the development.

Securing a Local Labour in Construction financial obligation of £62,500 (£2,500 per £1 million construction costs of £25 million).

Requiring the Site to be connected to a District Heat Network should one become available and the connection be feasible.

Monitoring fee of £4,523.95 (5% of total financial contributions of £90,479).

6.10.4 If the application is approved and the development is implemented, a liability to pay the Lambeth and Mayoral Community Infrastructure Levy (CIL) will arise. The Council’s CIL Team will confirm with the applicant the required CIL payment following the granting of planning permission.

6.10.5 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, and locally through the Cooperative Local Investment Plan initiative.

6.11 Other Planning Issues

Secured by Design

6.11.1 Development is required to minimise the risks of opportunistic crime, anti-social behaviour and fear of crime in accordance with London Plan Policy 7.3 and LLP Policy Q3.

6.11.2 Access arrangements to the building and grounds of Lambeth Palace will be restricted in order to minimise the security risks of the Development. The applicant has been involved in extensive discussions with Secured by Design Officers during the development of the scheme, and subject to the Development achieving a Secured by Design accreditation and subject to the receipt of a satisfactory Crime and Community Safety Management Plan, the application is considered acceptable in this regard.

Air Quality

6.11.3 The submitted Air Quality Statement Technical Assessment has concluded that the Development would not result in any deterioration in Air Quality. As the building will be mechanically ventilated, users of the Development would not be exposed to poor air quality. Given the proximity of the Development to Lambeth Palace Road it is important to ensure that the intakes for the building ventilation system would be sited away from such emission sources. The recommendations in the Air Quality Statement Technical Assessment should be implemented to ensure any potential exposure to atmospheric pollution is mitigated and the Local Emission Ventilation discharge from the conservation suite is appropriately located. Subject to these measures, the Development will be able to meet the requirement of being Air Quality Neutral. Details have been requested by condition.

Land Contamination

6.11.4 Paragraph 120 of the NPPF requires development to prevent unacceptable risks from land contamination. This is reaffirmed by London Plan Policy 5.21. Given the history of the Site, it is unlikely that the Development would be subject to any land contamination. However, a condition is suggested to deal with the eventuality that unsuspected contamination is found.

6.12 Procedural Matters

6.12.1 The application is referable 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.

7 CONCLUSION

7.1 The Development would provide a new purpose built Library to house the collection of 120,000 books that has been stored at Lambeth Palace since the Library was founded by Archbishop Richard Bancroft in 1610. Due to the restrictions of the existing Palace buildings and the poor conditions that they provide, parts of the collection have more recently been stored off-site. The return and retention of the collection on-site is therefore of paramount importance and strongly supported by officers.

7.2 The Site contains a number of heritage assets, namely that of Lambeth Palace itself, the Registered Garden, and also that of the listed boundary wall, part of which would need to be removed for the Development. Therefore, any development within the garden of Lambeth Palace would likely inevitably result in some harm to the heritage assets.

7.3 The proposed Library building is considered to be appropriate in its siting, scale, form and detailed design which would integrate well with the adjacent buildings and landscape. Despite this, due to the inevitable loss of openness that would occur, Officers consider this to result in less than substantial harm to the significance of the Lambeth Palace Conservation Area, the listed wall and to the Registered Garden. Officers do not consider there to be harm caused by the proposed development to Lambeth Palace itself. In balancing this and having afforded considerable weight and importance to any harm identified to the designated heritage assets, the proposed development would provide significant heritage and other public benefits that would outweigh the harm that would be caused. Namely, the retention of the Library on-site within a new and more accessible facility; new public views over the Westminster World Heritage Site and Lambeth Palace and onto the Registered Garden, which would be provided by the proposed development. The area of garden surrounding the Library would undergo significant improvements to mitigate the loss of this part of the garden and the existing trees in this area, and to ensure that the ecological value of the Borough SINC is enhanced. Officers are satisfied that the statutory duties in relation to the assessment of development impact on heritage assets has been appropriately undertaken in this case.

7.4 The Development would not impact unacceptably on the neighbouring properties, including retaining the privacy of the main garden area to Lambeth Palace and the Palace buildings. The Development would also not impact unacceptably on the local transport system. Furthermore, the scheme would provide employment and training benefits for local people during the construction phase of the Development.

7.5 Officers consider that the Development would be in compliance with the Development Plan for the Borough. Officers are therefore recommending approval of the scheme, subject to conditions and completion of a Section 106 Agreement.

8 RECOMMENDATION

8.1 Resolve to grant conditional planning permission (A) and listed building consent (B) subject to any direction that may be received following referral to the Mayor of London and subject to completion of an agreement under Section 106 of the Town and Country Planning Act 1990 of the planning obligations listed in this report.

8.2 Agree to delegate authority of the Director of Planning and Development to:

 Finalise the recommended conditions as set out in this report including such amendments, additions and/or deletions as the Director of Planning, Transport and Development (in consultation with the Planning Committee Chair) considers reasonably necessary; and

 Negotiate, agree and finalise the planning obligations as set out in this report pursuant to Section 106 of the Town and Country Planning Act 1990, including adding to, amending and/or deleting the obligations detailed in the heads of terms as the Director of Planning, Transport and Development (in consultation with the Planning Committee Chair) considers reasonably necessary.

8.3 Delegate authority to the Assistant Director of Planning and Development to refuse planning permission in the event that the Section 106 Agreement is not completed (by 30th May 2017) on the grounds that the development would have an unacceptable impact on – transport and highways; street-trees, visitor management, sustainability and local labour in construction.

8.4 In the event that the committee resolves to refuse planning permission and listed building consent and there is a subsequent appeal, delegated authority is given to Officers, having regard to the heads of terms set out in the report, to negotiate and complete a Section 106 Agreement in order to meet the requirements of the Planning Inspector.

Recommendation A: Planning Permission Conditions and Informatives

Conditions and Reasons

1. The development to which this permission relates must be begun not later than the expiration of three years beginning from the date of this decision notice.

Reason: To comply with the provisions of Section 91(1) (a) of the Town and Country Planning Act 1990 (as amended by Section 51 of the Planning and Compulsory Purchase Act 2004).

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

Reason: Otherwise than as set out in the decision and conditions, it is necessary that the development be carried out in accordance with the approved plans for the avoidance of doubt and in the interests of proper planning.

3. Prior to the commencement of development of the building above ground level and notwithstanding the details shown on the drawings hereby approved, detailed construction drawings of all external elevations (at scale 1:10) including the following items shall be submitted to and approved in writing by the Local Planning Authority. The development shall not be carried out other than in accordance with the approved details unless otherwise agreed in writing by the Local Planning Authority.

- Detailed elevations; - Details of windows (including technical details, opening methods, elevations, reveal depths, plans and cross sections); - Details of the roof-top terrace (including soffits), and balustrades; - Details of entrances, canopies and doors (including technical details, elevations, surrounds, reveal depths, plans and sections); - Details of roof treatments, cills and parapets; - Details of rainwater goods (including locations and fixings); - Details of boundary treatments including external walls, fences and gates; - Details of external furniture, lighting and ramps; - Vents, extracts, flues and ducts; - Louvers to front of building to plant room.

Reason: To ensure that the external appearance of the building is satisfactory, to preserve the setting of Lambeth Palace and to preserve the character and appearance of the Lambeth Palace Conservation Area (Policies Q2, Q5, Q7, Q20 and Q22 of the London Borough of Lambeth Local Plan 2015).

4. No above ground development of the building shall take place until a schedule of all materials to be used in the external elevations, including samples and the invitation to view a brick sample panel with pointing on-site, shall be submitted and approved in writing by the Local Planning Authority. The development shall not be carried out other than in accordance with the approved materials unless otherwise agreed in writing by the Local Planning Authority.

Reason: To ensure that the external appearance of the building is satisfactory, to preserve the setting of Lambeth Palace and to preserve the character and appearance of the Lambeth Palace Conservation Area (Policies Q2, Q5, Q7, Q20 and Q22 of the London Borough of Lambeth Local Plan 2015).

5. Notwithstanding the provisions of Article 3 and Class A of Part 2 of Schedule 2 of the Town and Country Planning (General Permitted Development) Order 2015 as amended (or any Order revoking or re-enacting that Order) no gates, fences, walls or other means of enclosure other than those shown on the approved plans (including those which may be agreed pursuant to other conditions of this consent) shall be erected at the site without the prior approval of the Local Planning Authority.

Reason: To ensure the Local Planning Authority suitable control over the details of the development (Policy Q15 of the London Borough of Lambeth Local Plan 2015).

6. 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 (2016) Policy 7.14 and the Mayor’s SPG: The Control of Dust and Emissions During Construction and Demolition.

7. An updated Travel Plan shall be submitted to and approved in writing by the Local Planning Authority prior to the use hereby permitted commencing. The measures approved in the Travel Plan shall be implemented prior to the use hereby permitted 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 (London Plan (2016) Policies 6.3 and 6.13, and London Borough of Lambeth Local Plan (2015) Policy T7).

8. No demolition or enabling works shall commence until full details of the proposed demolition in the form of a Method of Demolition Statement, has been submitted to and approved in writing by the Local Planning Authority.

No further construction works following demolition shall commence until full details of the proposed construction in the form of a Method of Construction Statement, has been submitted to and approved in writing by the Local Planning Authority.

The Method of Demolition Statement and the Method of Construction Statement shall include details regarding:

a) The notification of neighbours with regard to specific works; b) Advance notification of road closures; c) Details regarding parking, deliveries, and storage; d) Details regarding dust mitigation; e) Details of measures to prevent the deposit of mud and debris on the public highway; and f) Any other measures to mitigate the impact of construction upon the amenity of the area and the function and safety of the highway network.

No demolition, enabling works or construction works shall commence until provision has been made to accommodate all site operatives', visitors' and construction vehicles loading, offloading, parking and turning within the site or otherwise during the construction period in accordance with the approved details. The demolition, enabling works and development shall thereafter be carried out in accordance with the details and measures approved in the Method of Demolition Statement and Method of Construction Statement.

Reason: The relevant parts of the development must not commence before this condition is discharged to avoid hazard and obstruction being caused to users of the public highway and to safeguard residential amenity from the start of the construction process (Policies 7.14 of the London Plan 2016 and Policies T6 and T8 of the London Borough of Lambeth Local Plan 2015).

9. Prior to the occupation of the development hereby permitted, details of the provision to be made for cycle parking shall be submitted to and approved in writing by the Local Planning Authority. The cycle parking shall thereafter be implemented in full in accordance with the approved details before the use hereby permitted commences 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).

10. Prior to the commencement of the use hereby permitted, details of waste and recycling storage and management for the development shall be submitted to and approved in writing by the Local Planning Authority. The waste and recycling storage shall be provided and managed in accordance with the approved details prior to the commencement of the use hereby permitted, and shall thereafter be retained solely for its designated use. The waste and recycling storage areas/facilities should comply with the Lambeth’s Refuse & Recycling Storage Design Guide (2013), unless it is demonstrated in the submissions that such provision is inappropriate for this specific development.

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).

11. Prior to the commencement of the use hereby permitted, details of a Delivery and Servicing Management Plan for the development shall be submitted to and approved in writing by the Local Planning Authority. The development shall thereafter be operated in accordance with the approved Delivery and Servicing Management Plan for the duration of the use.

Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally, and to avoid unnecessary hazard and obstruction to the public highway (Policies EN4, EN7, Q12 and T8 of the London Borough of Lambeth Local Plan 2015).

12. No development shall take place until a Written Scheme of Investigation has been submitted to and approved by the Local Planning Authority in writing outlining a programme of archaeological mitigation, and a report on that evaluation has been submitted to and approved by the Local Planning Authority in writing. The development shall thereafter be implemented in accordance with the archaeological mitigation measures contained within the approved Written Scheme of Investigation.

The use of the development hereby approved shall not commence until the on-site archaeological intervention and monitoring work plus post-site assessment reporting has been completed in accordance with the programme set out in the approved Written Scheme of Investigation, and the provision for analysis, publication and dissemination of the results and archive deposition has been secured.

Reason: Development must not commence before this condition is discharged to safeguard the heritage of the borough by ensuring that any archaeological remains that may exist on site are not permanently destroyed (Policy 7.8 of the London Plan 2016).

13. The development shall be constructed and operated thereafter to ‘Secured by Design Standards’. A certificate of accreditation to Secured by Design Standards shall be submitted to the Local Planning Authority for approval in writing prior to the occupation of the development.

Reason: To ensure that the development maintains and enhances community safety (Policy Q3 of the London Borough of Lambeth Local Plan 2015).

14. Prior to the occupation of the development hereby permitted a Crime and Community Safety Management Plan shall be submitted to the Local Planning Authority for written approval. The development shall thereafter be operated in accordance with the approved details for the duration of the use hereby permitted.

Reason: To ensure that the development maintains and enhances community safety (Policy Q3 of the London Borough of Lambeth Local Plan 2015).

15. No building hereby permitted shall be occupied until the sustainable drainage scheme for the site has been completed in accordance with the submitted details. The sustainable drainage scheme shall be managed and maintained thereafter in accordance with the agreed management and maintenance plan.

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 London Borough of Lambeth Local Plan 2015).

16. The development permitted by this planning permission shall only be carried out in accordance with the approved Flood Risk Assessment (FRA).

Reason: To reduce the impact of flooding on occupants of the development and ensure that the development does not increase the risk of surface water flooding (Policy EN5 of the London Borough of Lambeth Local Plan 2015).

17. Prior to the commencement of relevant building works above ground, full details of any external plant equipment and trunking, including building services plant, ventilation and filtration equipment and any commercial kitchen exhaust ducting / ventilation and their on-going maintenance, shall be submitted to and approved in writing by the Local Planning Authority. All flues, ducting and other equipment shall be installed in accordance with the approved details prior to the use commencing on site and shall thereafter be maintained in accordance with the manufacturer's instructions and approved on-going maintenance plan.

Reason: To ensure that no nuisance or disturbance is caused to the detriment of the amenities of future residential occupiers or of the area generally (Policy Q2 of the London Borough of Lambeth Local Plan 2015).

18. Noise and vibration from any mechanical equipment or building services plant shall not exceed the background noise level when measured outside the window of the nearest noise sensitive or residential premises, when measured as a L90 dB(A) 1 hour.

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

19. Noise from any source of amplified sound, speech or music shall not exceed the background noise level L90 dB(A) 15 minutes, when measured from outside the nearest noise sensitive receptor.

Reason: To protect the amenities of surrounding residential properties and/or institutions (Policy Q2 of the London Borough of Lambeth Local Plan 2015).

20. If, during development, contamination not previously identified is found to be present at the site then no further development shall be carried out until the developer has submitted to, and obtained written approval from the Local Planning Authority for, an amendment to the remediation strategy detailing how this unsuspected contamination will be dealt with.

Reason: In the event unsuspected contamination is found a risk assessment and additional investigations may be required. Remediation works may also be needed. If this is the case, it will be necessary to demonstrate that any work has been carried out effectively and that the environmental risks have been satisfactorily managed (Policies 5.21 of the London Plan (2016) and EN4 of the London Borough of Lambeth Local Plan 2015).

21. The intakes and exhausts of the building ventilation systems shall be installed in accordance with CIBSE Guide B and CIBSE TM21 “Minimising Pollution at Air Intakes”.

Before commencement of operation of the building ventilation systems the applicant shall appoint a suitably qualified person to validate that the building ventilation systems as installed conform to the recommendations of CIBSE Guide B and CIBSE TM21 “Minimising Pollution at Air Intakes”. The validation report shall be submitted to and approved in writing by the Local Planning Authority.

Reason: To minimise increased exposure to existing poor air quality and make provision to address local problems of air quality (particularly within AQMAs) (Policy 7.14 of the London Plan 2016).

22. Prior to occupation a lighting scheme must be submitted to the Local Planning Authority for written approval in accordance with the External Lighting Planning Assessment Issue D dated 19th December 2016 prepared by Max Fordham LLP. The scheme must be designed by a suitably qualified person in accordance with the recommendations for Environmental Zone E4 in the ILP document “Guidance Notes for the Reduction of Obtrusive Light GN01:2011”. The scheme must thereafter be carried out and maintained in accordance with the approved details.

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 London Borough of Lambeth Local Plan 2015).

23. Notwithstanding the provisions of the Town and Country Planning (Use Classes) Order 1987 or the Town and Country Planning (General Permitted Development) Order 2015 (as amended) (or any orders revoking and re-enacting those orders with or without modification) the development hereby approved shall be used as a library (or uses associated with the use of a library) only, and for no other purpose falling within Use Class D1 of the schedule to the Town and Country Planning (Use Classes) Order 1987.

Reason: To ensure the Local Planning Authority suitable control over the details of the development (Policy ED11, S1 and Q2 of the London Borough of Lambeth Local Plan 2015).

24. The development shall be implemented in accordance with the approved Energy Strategy and shall not commence until full Design Stage calculations under the National Calculation Method have been submitted to and approved in writing by the Local Planning Authority to show that the development will be constructed in accordance with the approved Energy Strategy and achieve a reduction in carbon dioxide emissions of 35% over that required by Part L of the Building Regulations 2013.

Prior to first occupation of the building(s) evidence (e.g. photographs, installation contracts and as-built certificates under the National Calculation Method) should be submitted to the Local Planning Authority and approved in writing to show that the development has been constructed in accordance with approved Energy Strategy and achieved a reduction in carbon dioxide emissions of 35% over that required by Part L of the Building Regulations 2013.

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan (2016) Policy 5.2 and London Borough of Lambeth Local Plan (2015) Policy EN3.

25. Within 3 months of work starting on site a BREEAM UK New Construction 2014 (or such equivalent standard that replaces this) Design Stage certificate and summary score sheet must be submitted to and approved in writing by the Local Planning Authority to show that an ‘Excellent’ rating will be achieved.

Within 6 months of first occupation of the building(s) a BREEAM UK New Construction 2014 (or such equivalent standard that replaces this) Post Construction Review certificate and summary score sheet must be submitted to and approved in writing by the Local Planning Authority to show that an ‘Excellent’ rating has been achieved. All the measures integrated shall be retained for as long as the development is in existence.

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

26. The development shall be implemented in accordance with the approved Energy Strategy and the relevant works shall not commence until details of the proposed solar PV array has been submitted to and approved in writing by the Local Planning Authority. The PV panelling shall be installed in accordance with the approved details and retained as such for the duration of the use.

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan (2016) Policy 5.2 and London Borough of Lambeth Local Plan (2015) Policy EN3.

27. Notwithstanding the details shown on the approved drawings, no trees shall be felled, pruned, damaged, uprooted or otherwise disturbed without the prior written agreement of the Local Planning Authority, other than those shown to be removed as identified on the Approved Tree Protection Plan drawing (Appendix 5 of the Approved Arboricultural Method Statement prepared by Landmark Trees Ltd dated 16/12/16 ref: CHC/ LPL/AMS/01b) and on Drawing Ref. LPA-LD-100, with exception to T78, where details shall be submitted to the Local Planning Authority for written approval prior to its removal (with consultation with TfL) to demonstrate that all reasonable measures have been explored for its retention.

Reason: To ensure the retention of, and avoid damage to, the retained trees on the site which represent an important visual amenity to the locality (Policies Q2, Q9 and Q10 of the London Borough of Lambeth Local Plan 2015).

28. Subject to the approval of condition 28 of this decision, all retained trees as part of the approved application shall be protected in strict accordance with the details set out in the Approved Arboricultural Method Statement (Sections 2.0 – 5.0 and Appendices 1-5) prepared by Landmark Trees Ltd dated 16/12/16 ref: CHC/ LPL/AMS/01b. Where it is concluded by the Local Planning Authority in condition 28 that T78 can be retained through the development, T78 shall be fully protected throughout the course of development in line with the guidance as set out in BS5837:2012.

The protection measures shall be implemented before the commencement of any groundworks or demolition and shall include a pre-start site meeting with Council’s Arboricultural Officer to ensure compliance with all relevant details of the agreed Arboricultural Method Statement and appropriate site induction. The tree protection measures shall remain in place until completion of development.

Reason: To ensure the retention of, and avoid damage to, the retained trees on the site which represent an important visual amenity to the locality (Policies Q2, Q9 and Q10 of the London Borough of Lambeth Local Plan 2015).

29. All hard and soft landscape works shall be carried out in accordance with the details hereby approved. The works shall be completed within the first planting and seeding season following the occupation of the development hereby permitted or before the substantial completion of the development, whichever is the sooner.

Reason: In order to ensure implementation of landscaping in and around the site in the interests of ecological value and to ensure satisfactory landscaping of the site in the interests of visual amenity (Policies Q6, Q9 and Q10 of the London Borough of Lambeth Local Plan 2015).

30. All planting, seeding or turfing comprised in the approved details of landscaping 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.

Reason: To ensure a satisfactory and appropriate landscape scheme relative to the development in order to comply with Policy Q9 of the London Borough of 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.

2) 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.

3) You are advised to consult the Council's Environmental Health Division concerning compliance with any requirements under the Housing, Food, Safety and Public Health and Environmental Protection Acts and any by-laws or regulations made there under.

4) Your attention is drawn to the provisions of The Party Wall Act 1996 in relation to the rights of adjoining owners regarding party walls etc. These rights are a matter for civil enforcement and you may wish to consult a surveyor or architect.

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) Regarding conditions 8 and 27, you are advised that all measures should be explored within the final details of the Construction Management Plan for the retention of street-tree T78.

7) Regarding condition 12, written schemes of investigation will need to be prepared and implemented by a suitably qualified archaeological practice in accordance with Historic England Greater London Archaeology guidelines. They must be approved by the planning authority before any on-site development related activity occurs.

8) Regarding condition 14, the Crime and Community Safety Management Plan shall include details as to how opportunistic crime will be mitigated for the public areas of the building. You are advised to continue discussions with the Metropolitan Police regarding both this matter and the Secured by Design requirements as requested under condition 13.

9) The Environment Agency strongly recommends that the applicant consults their Pollution Prevention Guidance notes (PPGs). These are aimed at a wide range of industries and activities that have the potential to cause pollution. They can be downloaded from their website (www.environment-agency.gov.uk)

10) With regard to the proposed landscaping works, you are advised to contact the Council’s Biodiversity Officer regarding potential receptor sites for species present on site during the construction and landscaping works. The details are as follows:

Iain Boulton [email protected] 0207 926 6209

11) For information on the NRMM Low Emission Zone requirements and to register NRMM, please visit “http://nrmm.london/”.

Background documents – Case file (this can be accessed via the planning Advice Desk, Telephone 020 7 926 1180).

For advice on how to make further written submissions or to register to speak on this item, please contact Democratic Services, 020 796 2170 or email.

Recommendation B: Listed Building Consent Conditions and Informatives

Conditions and Reasons

1. The development to which this permission relates must be begun not later than the expiration of three years beginning from the date of this decision notice.

Reason: To comply with the requirements of Section 18(1) (a) of the Planning (Listed Buildings and Conservation Areas) Act 1990.

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

Reason: Otherwise than as set out in the decision and conditions, it is necessary that the development be carried out in accordance with the approved plans for the avoidance of doubt and in the interests of proper planning.

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 18(1) (a) of the Planning (Listed Buildings and Conservation Areas) Act 1990.

2) 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.