Statement of Common Ground Between City of Westminster and London Borough of Lambeth December 2019

Statement of Common Ground between City of Westminster and London Borough of Lambeth

December 2019

1 1. Executive Summary

This Statement of Common Ground has been prepared to demonstrate that Westminster’s City Plan 2019 – 2040 and Lambeth’s Draft Revised Lambeth Local Plan – Proposed Submission Version January 2020 (DRLLP PSV 2020) are ‘based on effective joint working on cross-boundary strategic matters’, in accordance with the requirements of paragraph 35 of the National Planning Policy Framework (NPPF). It focusses on areas of agreement or disagreement between both authorities on strategic cross-boundary matters.

Updates to this document will be agreed as matters progress and agreement is reached on any outstanding issues. It therefore includes details on mechanisms for review and updating.

WCC Duty to Co-operate Statement and Lambeth’s AMRs also provide further details of how both plans have been informed by ongoing engagement with key partners, including those that are not party to this Statement of Common Ground.

2. Parties involved

 London Borough of Lambeth  City of Westminster

Given the close alignment of both Westminster and Lambeth’s local plan productions timetable, both parties have agreed to develop a single bi-lateral SCG which will serve both local plan submissions.

3. Strategic geography

This section sets out the factual position regarding cross-boundary strategic matters.

The London Plan

The London Plan is the spatial development strategy for London, produced by the Greater London Authority on behalf of the Mayor of London. Every London borough local plan must be in general conformity with the London Plan. Together, the policies in the London Plan and in each borough’s Local Plan constitute the statutory local development plan for that borough, along with any neighbourhood plans/ neighbourhood development plans once made.

It is worth noting that in a London context, collaboration on many strategic issues that go beyond borough boundaries (e.g. distribution of housing targets, identification of major areas of growth etc.) are largely addressed through the London Plan.

The London Plan is currently subject to a review and the Draft London Plan is undergoing examination at the time of writing. It is expected the replacement London Plan will be published (adopted) in early 2020.

2 Transport for London

Transport for London (TfL) is the integrated transport authority responsible for implementing the Mayor's Transport Strategy, which covers three key elements - healthy streets and healthy people, a good public transport experience and new homes and new jobs. The boroughs are required to work with TfL to support implementation of the Mayor’s Transport Strategy.

TfL runs the day-to-day operation of the capital’s public transport network (London Buses, London Underground, London Overground, Docklands Light Railway, TfL Rail and London Trams). Network Rail own, operate and develop London’s railway infrastructure.

TfL also manages London’s main roads (the Transport for London Road Network or TLRN). The London boroughs are responsible for all the other roads within their boundaries (other than the national motorway network, which is managed by Highways England).

The London Enterprise Panel

The London Enterprise Panel1 (LEP) is the local enterprise partnership for London and is governed by the Mayor of London. It is the body through which the Mayor of London works with boroughs, business and TfL to take a strategic view of the regeneration, employment and skills agenda for London. Boroughs have historically engaged with the Mayor of London / GLA rather than directly with the LEP on relevant strategic planning matters. Both parties have effectively co-operated with the GLA regarding the development of its evidence base particularly in relation to business needs and likely changes in the market.

All London Green Grid

The ‘All London Green Grid partnership’ is recognised by DEFRA as the Local Nature Partnership for London. The partnership does not yet have a governance structure that allows it to respond on matters of local plan consultations.

LB Lambeth

Lambeth is an inner London borough with a northern boundary on the River Thames and situated mainly between the boroughs of Wandsworth and Southwark. It covers an area of approximately ten and a half square miles. It is surrounded by seven other London Boroughs - LB Southwark; LB Bromley; LB Croydon; LB Merton; LB Wandsworth; City of Westminster and City of London.

City of Westminster

Sitting at the heart of central London, the City of Westminster is bordered by the London Boroughs of Camden, Brent, Lambeth and Wandsworth, the City of London and the Royal Borough of Kensington and Chelsea. The London Borough of Southwark is also in close proximity to Westminster’s south-eastern border at the River Thames.

Westminster and Lambeth do not share a land border but sit on opposite sides of the River Thames with a border down the centre of the River Thames of just over 3 km. This Statement includes the whole of the LB Lambeth and the whole of the City of Westminster.

1 Also known as the London Economic Action Partnership 3 Map 1 – Authorities involved in this Statement Map 2 – Border between the two parties and key policy designations

5 Neighbourhood planning

There are no designated neighbourhood planning areas spanning the borough boundary between the two parties.

In Westminster the Pimlico neighbourhood area areas lie in close proximity to the Lambeth boundary. Pimlico Neighbourhood Forum ran a Regulation 14 formal consultation on their draft neighbourhood plan between 31st July and 10th October 2019.

In Lambeth, one designated neighbourhood area, South Bank and Waterloo Neighbours (SoWN), lies in close proximity to the City of Westminster borough boundary. It is a designated business area. SoWN’s proposed neighbourhood plan has proceeded to referendum. The two referendums took place on 24 October 2019 and more than half of those voting voted in favour of the NDP in each referendum. The results of the referendum mean the draft NDP now forms part of Lambeth’s development plan. The next stage in the process will be a Cabinet decision on the making of the draft NDP in December.

Economy, retail and commercial

Shared town centres None.

Employment

Central Activities Zone

Figure 1 – Area of London Plan Central Activities Zone

6 Areas of both boroughs lie within the Central Activities Zone (CAZ). The CAZ is a London Plan designation. It contains a broad range of functions that have London-wide, national and international significance including Government, business, culture, research and education, retailing, tourism, transport and places of worship. The London Plan seeks to promote and enhance the agglomeration and rich mix of strategic functions and local uses in the CAZ, whilst also supporting and enhancing its significant office functions.

Heritage, design and conservation designations

One of the most important strategic issues for both parties is the Westminster World Heritage Site (WWHS) and its setting. During the 2011 UNESCO Mission to the Westminster World Heritage Site concerns were raised about the impact of recent and proposed development on the immediate and wider setting of the WHS. Following the Mission, UNESCO requested that further work be undertaken in this area. As a response to UNESCO’s concerns, Lambeth instigated its own research to help inform local policies. From the outset, Lambeth has shared its investigations with other stakeholders, in particular through activities of the WWHS Steering Group. Westminster is leading on the production of the Westminster World Heritage Site Management Plan.

Conservation areas in Lambeth adjoining Westminster: Albert Embankment (CA57) South Bank (CA38)

Conservation areas in Westminster adjoining Lambeth:  Strand  Savoy  Whitehall  Westminster Abbey & Parliament Square  Smith Square  Millbank  Pimlico

Strategic and local views

Strategic views which cross the borough boundary between the two parties:  Protected Vista Parliament Square to Palace of Westminster  Protected Vista Primrose Hill to Palace of Westminster  Protected Vista Parliament Hill Oak Tree to Palace of Westminster  Protected Vista Parliament Hill Summit to Palace of Westminster  Protected Vista Westminster Pier to St Pauls Cathedral  Protected Vista King Henrys Mound to St Pauls Cathedral

Local views from Lambeth into Westminster:  Queen Elizabeth Hall (LV 2)  County Hall (LV 4)  Lambeth Palace (LV 6)  Lambeth Palace Gardens (LV 7)  Brixton Rooftop (LV 12)  Gipsy Hill (LV 17)

7  Brixton Historic Towers (LV 18)  Brixton Panoramic (LV 19)  Norwood Park (LV 22)  Courtenay Street (LV 27)  Royal Festive Hall

Local views from Westminster into Lambeth:  Westminster’s local views are listed here.

Transport

Shared bridges which cross the borough boundary between the two parties:  Vauxhall, Lambeth, Westminster, Hungerford, Jubilee and Waterloo

Main roads that cross the borough boundary between the two parties:  A202 (Vauxhall Bridge Broad) is part of the TfL Road Network  A3202 (Lambeth Bridge) is part of the TfL Road Network  A302 (Westminster Bridge) is part of the TfL Road Network  A4200 (Waterloo Bridge) is a London Distributor Road

Overground rail lines that cross the borough boundary and connect the two parties:  South Eastern mainline between London Charing Cross and London Waterloo East (Hungerford Bridge)

Overground stations on lines that cross the borough boundary and connect the two parties:  London Charing Cross (Westminster)  Waterloo East (Lambeth)

Underground rail lines that cross the borough boundary and connect the two parties:  Bakerloo Line  Jubilee Line  Northern Line  Victoria Line

Underground stations on lines that cross the borough boundary and connect the two parties:  Waterloo (Lambeth) (Bakerloo, Northern and Jubilee lines)  Embankment (Westminster) (Bakerloo and Northern lines)  Green Park (Westminster) (Jubilee Line)  Vauxhall (Lambeth) (Victoria Line)  Pimlico (Westminster) (Victoria Line)

Air quality

Air Quality Focus Areas spanning the borough boundary between the two parties:  Vauxhall Cross

Flood risk

8 The Thames Barrier is managed and maintained by the Environment Agency and protects 125 square kilometres of central London from flooding caused by tidal surges. This includes the protection of just under 29,000 properties in Lambeth and likewise thousands in Westminster who would otherwise be at risk of tidal and fluvial flooding. The Thames tidal defences also includes tidal walls and embankments along the banks of the River Thames. Should they fail or become breached the areas most at risk of flooding would be in the north of Lambeth and the south of Westminster, but this could also impact on the surrounding neighbourhoods. The Environment Agency holds tidal breach modelling. This is also detailed within Westminster’s SFRA and Lambeth’s SFRA Tidal Breach addendum.

The Environment Agency’s Thames Estuary 2100 Plan (November 2012) sets out the measures that require implementing to maintain adequate flood risk protection from the River Thames by the year 2100. The Plan identifies Lambeth and the City of Westminster within Action Zone 2 – Central London. The Plan outlines a number of recommendations to mitigate flood risk within this zone, including to maintain, enhance or replace, the river defence walls and active structures through central London over the first 25 years of the Plan from 2010 to 2034, and then from 2035 to 2049. The plan advises that by 2065, the existing flood defences of the river wall will need to be raised by 0.5m and a further 0.5m by 2100.

The provision of energy (including heat)

The Draft London Plan (DLP) states that boroughs should engage at an early stage with relevant energy companies and bodies to establish the future energy and infrastructure requirements arising from large-scale development proposals such as Opportunity Areas, Town Centres, other growth areas or clusters of significant new development (see DLP policy SI3). It also states that development plans should identify the need for, and suitable sites for, any necessary energy infrastructure requirements including energy centres, energy storage and upgrades to existing infrastructure. Furthermore boroughs should identify existing heating and cooling networks, identify proposed locations for future heating and cooling networks and identify opportunities for expanding and inter- connecting existing networks as well as establishing new networks.

The London heat map is an online tool, developed by the Mayor, used to find opportunities for decentralised energy (DE) projects in London. The Mayor has identified Heat Network Priority Areas, which can be found on the London Heat Map website (see DRLLP policy EN3). These identify where in London the heat density is sufficient for heat networks to provide a competitive solution for supplying heat to buildings and consumers.

River Thames

Sites of Nature Conservation Importance (SINCs) that cross the borough boundary between the two parties:  River Thames and Tidal Tributaries Metropolitan SINC

Site of Metropolitan Nature Importance that crosses the borough boundary between the two parties:  River Thames

The Thames runs along the borough boundary between the two parties. There are River services on the Thames for both passengers and freight.

Green infrastructure

9 There is no green infrastructure spanning the borough boundary between the two parties.

4. Strategic matters

This section sets out where agreement has or has not been reached on cross-border strategic matters.

4.1 Neighbourhood Planning

There are no designated neighbourhood planning areas spanning the borough boundary between the two parties.

4.2 Housing

4.2a. Overall housing need

Housing need is a strategic issue dealt with at the regional level in London by the Mayor. Within the Draft London Plan 2017 (consolidated with proposed further changes July 2019, plus EIP Panel recommendations), the Mayor sets borough-level housing targets. These targets are based on evidence of housing capacity in the capital set out in the London Strategic Housing Land Availability Assessment 2017 (London SHLAA 2017) and underwent examination during 2019. Through their own local plans, authorities must plan to meet or exceed their London Plan target to ensure they are in general conformity with the London Plan.

 Both parties agree that they can meet or exceed the total numerical housing target assigned to them by the Mayor of London in the Draft London Plan, within the confines of their own administrative boundary. 4.2b. Affordable housing

The London Plan and borough level Local Plans together set out the levels and types of affordable housing provision required.

 In terms of affordable housing, to ensure a consistent approach across London, both parties support the Mayor’s threshold approach to affordable housing and the Mayor’s strategic target of 50% affordable housing across London.

4.2c. Gypsies and Travellers

The City of Westminster has no existing gypsy and traveller accommodation within its border and no identified need for pitches within the City Plan period.

Lambeth has a need for 3 pitches for gypsies and travellers between 2019/20 and 2034/35, which equates to one pitch every five years. There is no identified need for plots for travelling showpeople in the borough. Lambeth will meet the needs of Lambeth’s gypsy and traveller community over this period by safeguarding the existing gypsy and traveller site in Streatham Vale (Lonesome depot) and managing churn in vacant pitches on this site to meet identified future need.

 Both parties agree that on this basis neither borough has unmet need for gypsy and travellers accommodation

10 4.3 Employment, retail, leisure and other commercial development

The continued commercial success of the Central Activity Zone, which covers much of Westminster and the northern extent of Lambeth is vital to London’s world city status. As supported by the Mayor of London, both parties have introduced Article 4 Directions within their portion of the CAZ to protect central London’s strategically important office supply against change of use to residential use under permitted development rights.

 Both parties agree to work collaboratively to deliver the Draft London Plan approach to the CAZ and consult each other on major applications with potential strategic cross border impacts 4.4 Health

Health infrastructure planning in Lambeth and Westminster reflects the priorities of their respective Clinical Commissioning Groups (the Lambeth Clinical Commissioning Group and the Central London and West London Clinical Commissioning Group). This approach has regard to and acknowledges potential movement of patients across the border between the two boroughs.

Both Lambeth and Westminster are home to regional hospitals that cater to health care needs beyond each administrative boundary.

 Both parties acknowledge that there is likely to be cross border movement of patients between each borough but agree there are no known planning reasons why these movements cannot continue.  Both parties agree to work collaboratively to plan for strategic cross border health facilities

4.5 Education

Both parties have school place planning teams who seek to ensure that projected levels of demand for both primary school and secondary school places are met. Each party has undertaken a school place planning exercise which has had regard to cross-border movement of pupils between the two boroughs. The findings are reflected in the Lambeth Draft Infrastructure Delivery Plan 2019 and the Westminster draft Infrastructure Delivery Plan (2019).

 Both parties acknowledge that there is likely to be cross border movement of school pupils between each borough but agree there are no known planning reasons why these movements cannot continue.

4.6 Telecommunciations

 Lambeth seeks to work collaboratively on the delivery of digital connectivity infrastructure where there are cross-border implications. Westminster agrees to work collaboratively on the development and outcomes of all schemes, which may have an impact on traffic flows, across the boundaries.

11 4.7 Security

 Lambeth seeks to work collaboratively on counter terrorism measures such as hostile vehicle mitigations. Westminster agrees to work collaboratively on the development and outcomes of all schemes, which may have an impact on traffic flows, across the boundaries.

4.8 Transport

Transport is by its nature a cross-border strategic issue - the approach in both local plans to managing the impacts of growth on the transport network can have significant impacts beyond the local authority boundary.

 Both parties agree to work collaboratively to deliver the Mayor’s Transport Strategy outcomes with regards to walking and cycling  Lambeth seeks to take a co-ordinated with TfL approach to bus corridors and bus priority measures. Westminster agrees to work collaboratively on the development and outcomes of all schemes, which may have an impact on traffic flows, across the boundaries.  Upcoming proposals for Parliament Square could have major traffic impacts on Central London and on Lambeth. Westminster agrees to give full consideration to Lambeth’s comments on the proposal in relation to the potential traffic impacts on Lambeth and work collaboratively to identify mitigation measures where necessary.  Westminster and Lambeth agree to work collaboratively on the development and outcomes of all schemes, which may have an impact on traffic flows, across the boundary between the two parties.

Transportation of City of Westminster waste through Lambeth

WCC refuse/recycling collection vehicles travel through Lambeth en route to the South East London Combined Heat and Power (SELCHP) site, a major waste incineration plant located in South Bermondsey. Lambeth considers this traffic contributes to congestion, poor air quality and, on some occasions, road safety issues in Lambeth. Lambeth formally raised the transportation of Westminster waste vehicles as a cross border strategic issue through consultation of the Draft Westminster City Plan. See appendix 2 for full correspondence between the two parties on this matter.

Westminster has recently committed Community Infrastructure Levy funding to convert street cleansing vehicles operating in the West End to electric power. This is the first stage before procuring a new fleet of waste collection vehicles to operate across Westminster. The current intention is that the new waste fleet will be electric (or potentially hydrogen) powered to deliver the council’s ambitions for air quality.

Westminster has said that when contracts are renewed, they will review the routes taken by waste vehicle contractors and seek to avoid the future use of Lambeth Bridge.

Lambeth does not consider that its concerns have yet been fully addressed and wish to agree a timetable and process by which potential solutions will be considered, involving Lambeth.

12  Both parties agree that the routes taken by waste vehicles have harmful implications for air quality, traffic congestion and in some cases road safety in Lambeth  Both parties agree that this is a cross border issue that cannot be dealt with through the local plan process.  Lambeth considers that this is a strategic matter - Westminster disagrees.  Both parties have not yet agreed a process and timetable for addressing Lambeth’s concerns.

Car parking

Westminster considers that its plan seeks to prioritise sustainable modes of travel including walking, cycling and public transport, to minimise congestion and pollution from private car use. It does however recognise the high levels of growth expected in areas where there is already very high on- street parking stress. It therefore allows for limited provision for off-street car parking in new residential developments in the Paddington and Marylebone areas only (parking zones B and F, shown on Figure 24 in the draft City Plan). This represents a significant reduction in allowance for new off-street car parking than in previously adopted policies in Westminster, and earlier drafts of the plan – in response to concerns raised by the Mayor of London, Transport for London, and the London Borough of Lambeth.

The DRLLP PSV 2020 applies Draft London Plan policy T6 to promote a reduction in car ownership and private car trips. In PTAL areas 1 and 2, the plan proposes to introduce lower Lambeth specific maximum car parking standards.

In Lambeth’s view, Westminster’s proposed approach will generate additional vehicle movements - some through Lambeth - which will have harmful impacts on traffic congestion, road safety and air quality in Lambeth. Lambeth’s position is that Westminster should adopt DLP maximum car parking standards.

 Lambeth disagrees with Westminster’s approach to its car parking policy.

4.9 Air quality

The whole of Westminster and Lambeth are designated as Air Quality Management Areas, with Air Quality Focus Areas defined in Draft London Plan paragraph 9.1.8.

Westminster have produced an Air Quality Manifesto, published an Air Quality Action Plan (which is currently being updated) and launched the #DontBeIdle campaign to encourage drivers to switch off their engines when stationary.

Lambeth has produced an Air Quality Action Plan. Lambeth proposes to follow the Draft London Plan policy approach to air quality in relation to new development.

 Both parties agree to continue their involvement in a number of cross-organisational projects and organisations to tackle poor air quality across London (see appendix 2).

However, Lambeth has ongoing concerns about Westminster’s approach to transportation of waste through Lambeth and Westminster’s approach to car parking (see 4.8 above), which in Lambeth’s view adversely affects air quality in Lambeth.

4.10 Waste management

Each Waste Planning Authority is expected to plan for their identified waste needs, including planning to meet London Plan apportionment targets.

Lambeth is planning for net self-sufficiency for LACW, C&I and C&D waste and a target of 95% beneficial use of excavation waste. Net self-sufficiency means providing enough waste management capacity to manage the equivalent of 100% of these waste streams generated in Lambeth, while recognising that some imports and exports will continue. This includes meeting the London Plan apportionment targets for the borough. Lambeth is planning for its identified waste needs by safeguarding existing waste sites and identifying sufficient land to provide opportunities to meet the waste management capacity gaps for the borough.

The scale of commercial activity that takes place in Westminster results in unusually high levels of waste production. The highly urbanised nature, lack of brownfield/ex-industrial sites and heritage sensitivities of the city also means identifying sites for future waste management is a significant challenge. Westminster is engaging with the Mayor on its conformity with the London Plan regarding its waste apportionment2.

There are no significant waste movements between Lambeth and Westminster, as set out in the Lambeth Waste Evidence Base 2019.

 Westminster agree that there are no implications from Lambeth’s position regarding strategic waste matters.  Lambeth cannot express a view at this stage because the WCC position is unknown.

4.11 Water supply, wastewater

Thames Water is the statutory water and sewerage undertaker for the area and is hence a “specific consultation body” in accordance with the Town & Country Planning (Local Development) Regulations 2012. From the 1st April 2018 all network reinforcement work required to support development will be delivered by Thames Water and funded through the Infrastructure Charge applied to each property connected to the water and wastewater networks. The Infrastructure Charge will also cover all modelling and design work required to deliver any necessary upgrades. The planning system will still play a key role in ensuring that development does not outpace the delivery of any necessary infrastructure provision.

2 As set out in the Statement of Common Ground between Westminster, the Mayor and Westminster’s other neighbouring boroughs

14 request phasing conditions are used to ensure that any new development or phase of development is not occupied until any necessary upgrades have been completed in line with Draft Revised Lambeth Local Plan policy EN4. In Westminster policy 36 sets out that WCC may use planning conditions to ensure necessary water or sewerage network upgrades3.

Thames Water are helping to deliver the Thames Tideway Tunnel project which will be a new fifteen- mile-long ‘super sewer’ running under the River Thames.

 Each party agrees to support Thames Water’s approach to planning for water and waste water infrastructure

4.12 Flood risk

Each council is statutorily required to produce a Local Flood Risk Management Strategy (LFRMS) for their respective borough which details how they assess and will manage Local Flood Risk within their administrative boundary. LFRMSs require cross boundary partnership working to achieve the ultimate outcome of reducing Local Flood Risk. As part of the partnership working, Westminster and Lambeth’s Flood Risk Officers meet at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

 Both parties agree to have regard to each other’s flood risk policies and evidence

4.13 Provision of energy (including heat)

 Both parties are separated by the River Thames and therefore acknowledge that this may be a barrier to any potential cross boundary energy infrastructure networks.

4.14 Green infrastructure (i.e SINCs and MOL)

Both parties are separated by the River Thames and therefore no green infrastructure crosses the borough boundary between the two parties.

4.15 Planning measures to address climate change mitigation and adaptation

City of Westminster declared a climate emergency in September 2019 and committed to ambitious carbon reduction targets. The City Council will be carbon neutral by 2030 and the whole city will follow suit by 2040 – ten years ahead of government targets. This target will inform everything

3 As set out in Westminster’s schedule of minor modifications 15

Westminster does as we strive to meet the challenges of climate change and delivery a carbon neutral city.

Lambeth Council declared a Climate Emergency in January 2019. Lambeth has set itself a target to achieve net zero carbon for council operations by 2030. In July 2019, Lambeth published a corporate carbon reduction plan which sets out initial actions to achieve this target, to be reviewed annually to ensure Lambeth is on track. Lambeth are also developing a wider Lambeth climate change response plan, which will be published in 2020. In the next eleven months Lambeth plans to engage widely, starting with a Citizens’ Assembly early next year, to raise awareness, gather evidence and seek to build consensus around Lambeth’s climate change response and the resulting action plan.

The sections above relating to transport, waste, flood risk, provision of energy and air quality are all relevant to mitigating and adapting to climate change.

 Both authorities agree to follow the approach outlined in the London Plan for zero carbon developments (see DLP policy SI2) and support the principle of the Mayor’s urban greening objectives

4.16 River Thames

4.16.1 Policy approach The River Thames provides a major asset that Westminster and Lambeth border. Both authorities recognise the importance of this setting and have complementary policy approaches to shape future development within the area designated through the London Plan as the Thames Policy Area.

 Lambeth notes the boundaries to the Thames Policy Area identified in Westminster’s City Plan, which adjoins Lambeth’s boundary and the policy approach to development within this area.  Both parties agree to consult each other on any proposals on/in the River Thames and have regard to each other’s respective Local Plan policies.

4.16.2 River services

 Both parties agree to work collaboratively to improve both passenger transport on the River and use of the River for freight movements.

4.16.3 Sites of Importance for Nature Conservation

 Both parties agree to consult each other on any proposals that could impact on the River Thames and Tidal Tributaries Metropolitan SINC.  Both parties agree to have regard to the River Thames and Tidal Tributaries Metropolitan SINC designation and each other’s respective Local Plan policies when determining applications that could impact on this designation.

4.16.4 Bridges

Lambeth’s draft new Transport Strategy proposes a network of strategic cycle routes that tend to lead to River Thames crossings.

TfL has identified that junctions at either end of Lambeth Bridge require safety improvements. Plans for improvements on the Lambeth side are well advanced, but delivery of these is dependent on agreement of corresponding changes on the Westminster side. At present, Westminster has not agreed the changes put forward by TfL and this matter remains to be resolved.

 Lambeth seeks to agree that the boroughs jointly assess cycling connectivity on or in close proximity to the borough boundary where bridges join both boroughs and to analyse the capacity of bridges to facilitate the development of Lambeth’s Transport Strategy. Lambeth has requested a specific commitment from Westminster. Lambeth also seeks to work collaboratively to improve cycle ways across each bridge.  Westminster agrees to work collaboratively with Lambeth on the development and outcomes of all cycling schemes which cross the borough boundary, which may have an impact on traffic flows, across the boundaries.

4.17 Strategic and local views, and heritage, design and conservation

Westminster World Heritage Site

Both parties have worked collaboratively to improve the protections of the Westminster World Heritage Site and its setting in response to the recommendations of the 2017 Mission to the site, and to ensure the impacts of tall buildings in Vauxhall and Waterloo on the setting of the Site and protected views are understood. Lambeth is an active member of the Westminster World Heritage Site Steering Group which is chaired by Westminster and this provides a forum where significant schemes and projects in both boroughs with an impact on the site and protected views are discussed.

Lambeth and Westminster jointly developed the Westminster World Heritage Site Setting Study in 2018. Work on this document was informed by the World Heritage Site Steering Group.

Lambeth has inputted positively into the emerging Westminster World Heritage Site management plan – which informs the evidence base for both local plans and has taken the lead in the development of 3D modelling work in relation to building heights in Lambeth and their potential impact on the site. This work has helped to inform DRLLP policy Q19.

 Both parties agree to safeguard the integrity of the Westminster World Heritage Site and its setting.  Both parties agree to continue to support and contribute to the steering group, to work to protect both the Outstanding Universal Value of the World Heritage Site and other significant cross borough views  Both parties agree to further develop mutual understanding of the setting of the World Heritage Site and the impact of tall buildings site through use and development of shared 3D modelling.  Both parties agree to continue to work collaboratively and accelerate work on the Westminster World Heritage Site Management Plan.

Views, heritage, design and conservation

Within Lambeth, areas appropriate for tall buildings have been identified in the draft revised Lambeth Local Plan Annex 1, supported by policy Q26. Likewise, broad locations suitable in principle for higher buildings have been identified in Policies 42 and 43 of Westminster’s draft City Plan. The policies follow a ‘context height’ approach to determining appropriate heights.

 Both parties agree to have regard to the London View Management Framework (LVMF) and respective local plan polices when considering development proposals that could affect strategic and local views  Both parties agree to consult each other on any proposals that could impact on strategic and/or local views and to work together to ensure that in the case of strategic views such development will protect and enhance these views in line with the guidance in the LVMF, and in the case of all other views that development will optimise opportunities to protect and enhance in line with relevant local policy and guidance.  Both parties agree to have regard to the setting of heritage, design and conservation designations adjoining the borough boundary in the neighbouring borough when determining applications in accordance with the relevant legislation and policy, and consult each other on any proposals that could impact on these designations. 4.18 Cultural infrastructure

Westminster’s City Plan identifies Strategic Cultural Areas in Knightsbridge, Millbank, and the West End. The North bank is also identified in Westminster’s draft City Plan as an area for public realm improvements, which could also have implications for culture positive contributions to culture.

The Southbank Strategic Cultural Area is partly in Lambeth, and is opposite Westminster’s north bank.

Lambeth has developed a cultural evidence base (Visitor attractions, leisure, arts and cultural uses in Lambeth 2019) which sets out existing cultural uses in the borough. This has been used to inform DRLLP policy ED13 which seeks to follow the Draft London Plan approach to protecting and enhancing cultural infrastructure (see DLP policy HC5).

 Lambeth agrees to engage with WCC on Westminster’s emerging detailed policy guidance for the North Bank – to ensure co-ordinated proposals within the Mayor’s requirements for a Thames Strategy.

5 Governance arrangements

This statement has been informed by on-going engagement between the parties – as evidenced by the main body of the statement explaining joint working and the schedule of engagement between the parties in Appendix 1.

This statement of common ground is a live document and will be reviewed on a regular basis, informed by continued communication between the parties through meetings, statutory consultation at key plan making stages and electronic communication.

Key stages of each borough’s plan making process (set out in Table 1) will be triggers for the SCG to be reviewed, however strategic matters will be dealt with on an on-going basis in-between formal reviews of the SCG.

Timetable for agreement, review and update

Local Present plan Proposed Reg 18 date Anticipated Anticipated authority adoption plan review Reg 19 date submission start date date Lambeth September October 2017 October 2018 January 2020 April 2020 2015 Westminster November June 2017 June 2017 June 2019 November 2016 2019 Table 1: Plan review, update and submission dates

Ongoing collaboration between the parties will continue through regular meetings and through attendance at group meetings where cross boundary issues are discussed.

6 Signatories

Both signatories agree that this statement is an accurate representation of areas of agreement and disagreement between the two parties.

Signed: ______Signed: ______

Name: Councillor Matthew Bennett Name: Councillor Richard Beddoe

Position: Cabinet Member for Planning, Position: Cabinet Member for Place Shaping Investment & New Homes and Planning

London Borough of Lambeth City of Westminster

Date: Date: 13 November 2019

Appendix 1 – Preparation of this statement of common ground

The 2019 preparation process for this SCG is set out below:  22nd March– first draft SCG prepared by City of Westminster and sent to Lambeth. This SCG proposed to include all of Westminster’s neighbouring boroughs in one joint statement.  11th April – LBL responded to Westminster by stating a preference for bi-lateral SCG and providing comments on the initial draft prepared by Westminster.  25th September 2019 - Lambeth prepared and sent through a draft bi-lateral SCG to Westminster.  26th September – Westminster sent to Lambeth a revised draft SCG for all its neighbouring boroughs.  18th October – both parties met to discuss the format of the SCG. Both parties agreed to create a bi-lateral SCG. Westminster sought agreement of the SCG by 25th October. Lambeth advised this was not possible given their sign off process and it could not be formally agreed until December. Lambeth agreed to investigate an earlier in principle agreement by 13th November.  Lambeth agreed a holding statement on 29th October 2019. This stated that Lambeth would seek in principle agreement on 13th November with final agreement in December 2019.  6th November – officer level agreement on proposed SCG.

Appendix 2 - Schedule of engagement between the parties

Officer-level meetings and resultant correspondence to discuss strategic cross border planning matters under the duty to co-operate and to develop this statement of common ground took place:  30th June 2017 (with Southwark, Wandsworth, GLA and Historic England to discuss WHS Management Plan).  28th September 2017  16th April 2018 (with the GLA to discuss WWHS Setting Study)  16th May 2018  1st August 2018 - email sent by Lambeth questioning waste routes taken by Westminster waste vehicles through Lambeth)  5th December 2018 (email regarding waste routes taken by Westminster waste vehicles through Lambeth also re-sent on this date)  1st March 2019  3rd April 2019 – email reply sent by Westminster explaining routes taken by Westminster waste vehicles through Lambeth  22nd May 2019 – further questions sent by Lambeth regarding Westminster waste vehicles through Lambeth  18th October 2019  23rd October 2019 – email reply sent by Westminster providing further explanation on routes taken by Westminster waste vehicles through Lambeth

Air quality meetings:

Project Partner Schools Air Quality Audit Fund GLA Nurseries Air Quality Audit Fund GLA School Streets Campaign Living Streets (Lead) London Councils work into new AQ London Councils (lead), various other boroughs legislation Healthy Streets Everyday Islington (lead), Cross River Partnership, 15 other boroughs, GLA (funders) – TBC Clean Air Villages Lewisham (lead), Cross River Partnership, Camden, H&F, RBKC, Wandsworth, Defra (funders) Non Road Mobile Machinery register King’s College London, GLA, TFL, Brent, Camden, City of London, Croydon, Hammersmith and Fulham, RBKC, Islington, Lewisham, Tower Hamlets, Wandsworth, and Westminster. Air Quality Monitoring Network King’s College London Breathe London Project GLA (lead), University of Cambridge, King’s College London, AirMonitors, CERC, Environmental Defense Fund, Google Earth Outreach, National Physical Laboratory, C40 Cities. airTEXT service Islington Council (Current lead), University of Cambridge, London boroughs, GLA, Chelmsford, Colchester, Slough, Three Rivers, Thurrock, Environment Agency, Public Health England, CERC, European Commission, DEFRA, PREVAIR and European Space Agency

STARS programme TfL Pollution alerts to schools, GP surgeries GLA, King’s College London and care homes Ultra Low Emission Zone GLA Electric Vehicle Car Clubs project GLA (funders), TfL Statutory duties as Air Quality GLA, Defra Management Area Table 2: List of projects Westminster and Lambeth are part of taking place in London to monitor and improve air quality.

Organisation Participating authorities Frequency Central London Air Quality WCC, Hammersmith and Fulham, Camden, Quarterly Cluster Group Islington, City of London, Hackney, Southwark, Lambeth, London Councils, GLA APRIL Network (Air Pollution All boroughs, GLA, TfL, research institutions Quarterly Research in London) Table 3. Air quality organisations both authorities participate in

Flood officer meetings:

Westminster’s and Lambeth’s Flood Officer meet with each neighbouring council at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

All London Borough planning officer meetings (Association of London Borough Planning Officers):  13th Jan 2016  9th Feb 2017  14th March 2017  16th May 2017  16th February 2018  1st May 2018  3rd July 2018  18th September 2018  13th November 2018  25th January 2019  07th February 2019  12th March 2019  04th April 2019 (sub group meeting)  07th May 2019  05th June 2019 (sub group meeting)  16th July 2019  25th July 2019  17th September 2019  19th September 2019 (sub group meeting)  12th November 2019

Appendix 3 - Evidence of activities undertaken to address an issue

Local Plan consultations:

On 12th November 2018 Westminster notified Lambeth that it was consulting on its new draft City Plan under regulation 18. This consultation ran for six weeks. Lambeth submitted a response to this consultation on 21st December 2018 (shown in table below).

On 19th June 2019 Westminster notified Lambeth that it was consulting on its new draft City Plan under Regulation 19. This consultation ran for six weeks. Lambeth did not submit a response to this consultation.

On 9th October 2017, Lambeth notified the City of Westminster that the first stage of public consultation on the Lambeth Local Plan Review (Regulation 18 part 1 - Issues consultation) would run for eight weeks from 9 October to 4 December 2017. Lambeth invited Westminster to make representations. City of Westminster did not submit a response.

On 22nd October 2018, Lambeth notified the City of Westminster that the second stage of public consultation on the Lambeth Local Plan Review (regulation 18 part 2 - Draft Revised Lambeth local Plan 2018) would run for eight weeks from 22 October to 17 December 2018. Lambeth invited the Westminster to make representations. City of Westminster did not submit a response.

The table below sets out how comments made have been addressed to date.

Schedule of comments made by Lambeth and Westminster response.

Matter Lambeth comment Westminster response Parking Regulation 18 representation 21 December 2018 policy Lambeth’s Draft Transport Strategy (2018) has a key objective of reducing traffic As set out in Westminster’s Consultation Statement (published 28th levels in the borough and our Draft Revised Lambeth Local Plan (October 2018) October 2019): seeks to embed this by restricting the amount of parking permitted in new developments, reflecting and indeed going further than the Draft London Plan in The council considers the City Plan strikes a balance between the this respect. A key source of concern is the level of through traffic Lambeth merits of the private car and the transition to sustainable modes of suffers from due to its location on key routes providing access to central London. transport and that this is an appropriate evidence-based departure Many trips to Lambeth and trips passing through Lambeth have Westminster as an from the new London Plan’s approach to parking, as justified in the origin or destination. We are therefore concerned that Westminster’s proposed policy. The council have agreed a statement of common ground with maximum residential parking standards (set out in Appendix 2 of the Draft the Mayor and TfL on this objection [relating to the conformity of Westminster City Plan) are not justified and do not reflect the need to deter the policy with the London Plan] and will continue dialogue to reach a generation of additional car trips in central London and that our residents will be resolution. exposed to the negative externalities of additional traffic on Lambeth’s streets as a consequence. Congestion, road safety and air quality are particular concerns in this respect. We also note that the proposed parking standards do not appear to be in general conformity with the Mayor’s proposed standards, which require car- free development in central London; and indeed contrast starkly with the approach taken by other central London authorities, notably the City of London in their draft Local Plan also out to consultation. In Lambeth’s view, Westminster’s residential parking standards should be the same as those in the Draft London Plan. Waste- Regulation 18 representation 21 December 2018 3rd April 2019 Westminster email reply related traffic Lambeth’s policies also seek to reduce the impact of large vehicles on our streets As part of our informal City Plan consultation, you requested movements and to confine non-local traffic to the Strategic Road Network in order to protect information on waste routes through Lambeth. Apologies for the residential areas. We are aware that Westminster waste disposal vehicles are delay in sending this information across. operating on Lambeth’s highways and request further information about these movements. If some of Westminster’s waste is travelling through Lambeth to Please find the travel routes for WCC refuse/recycling collection vehicles through Lambeth attached. Deviations are only made when

reach its management destination, this will obviously have impacts on Lambeth’s roads are closed and have to be approved by the Contract Manager at roads in terms of traffic volumes, congestion, road safety and air quality. Veolia.

As noted in our email of 1 August 2018 and in our ‘duty to cooperate’ meeting Private waste operators routes are not known. held in November 2018, we set out below what we understand to be the position with regard to movement of waste that arises in Westminster and whether this The volumes vary every year depending how much we collect. may be travelling through the London Borough of Lambeth: Rule of thumb: • Westminster has contracts with Veolia for household and • Residual waste, SELCHP: approx. 145-150kt/a industrial/commercial waste (HIC waste) • Dry mixed recycling, IWMF: approx. 8kt/a directly delivered • Residual waste goes to SELCHP in LB Lewisham, and may pass through and approx. 15kt/a bulk hauled Lambeth to get there • Bulky waste & WEEE, IWMF: approx. 3kt/a • Recyclables go to MRFs in either Southwark and Greenwich (depending on the type of material), and again may pass through Lambeth to get there • A small amount of HIC waste (c5kt) also goes to Smuggler's Way in [6 maps were attached to the email showing the following routes: Wandsworth  Westminster Bridge to SELCHP • Construction, demolition and excavation waste (CD&E) waste mainly goes  Waterloo Bridge to SELCHP north, west and north east so the majority probably does not travel through  Vauxhall Bridge to SELCHP Lambeth, but a significant amount (c15kt) goes to Greenwich waste transfer  Lambeth Bridge to SELCHP stations, and so may pass through Lambeth.  Chelsea Bridge to SELCHP

We would like to understand more fully the volumes of waste that are travelling  Blackfriars Bridge to SELCHP] through the borough, how frequently and by which routes. In particular, we wish to understand the potential to re-route these vehicles, making use of more suitable corridors, including greater use of the river for waste movements. For residual movements, we seek to agree prescribed routes that protect local streets and also to ensure that both vehicles and drivers are provided with the latest safety equipment and training in order to minimise the threat posed to vulnerable road users.

We note for information that there was an accident on 29 June on Wincott Street in Lambeth involving a motorcyclist and a Westminster Council bin lorry. Whilst there is no suggestion that the bin lorry was at fault, this is an example of a Westminster waste vehicle travelling through Lambeth residential streets.

Waste- Lambeth follow-up email sent 22nd May 2019 23rd October Westminster email reply related traffic movements 1. For the Western Riverside Waste Authority boroughs, including Lambeth, 1. Western Riverside Waste Authority (WRWA) disposes of Veolia use Smugglers’ Wharf in Wandsworth: residual waste travels by river to waste on behalf of Lambeth. Lambeth is only a collection authority. Belvedere in LB Bexley. Has this option for a more sustainable mode of transport Waste trucked from Lambeth goes to WRWA’s own riverside waste been considered for Westminster’s residual waste? We also note the City’s transfer stations – City has its own wharves as well. They use residual waste travels to Belvedere by river from Wallbrook Wharf – has this route contractors who are able to barge to Belvedere from their wharves. been considered for Westminster and if not could it be? Could transport by river Barges from these waste transfer stations can only access the via routes such as these be part of the next specification for Westminster’s waste Belvedere facility and no other Energy Recovery Facilities. contract? 2. Turning to the current routes, we note those shown only relate to WCC does not have its own waste wharves and as unitary authority residual waste travelling to SELCHP. Please could you advise where is IWMF (the has responsibility for both waste collection and disposal and as such destination for recyclate) and how the waste travels there? Does it pass through needs to procure contracts to provide both services. Therefore, it uses Lambeth and if yes by which routes? Veolia and its facilities at SELCHP for which there is no wharf. 3. Please could you provide further information about the specification of the vehicles used by Veolia under your current contract? Does WCC’s contract 2. Recyclate is also trucked along the same route to with Veolia require they use the latest, safest and cleanest vehicles available? Southwark’s IWMF which is adjacent to SELCHP. 4. Are alternative routes defined in advance of disruptions to the planned routes? If not, can they be such that they never use unclassified roads? 3. Our fleet exceeds ULEZ compliance due to the Eminox filter retrofitting project. We are also introducing electric trucks, already Air quality, road safety and mitigation of climate change are significant priorities 25% of the total fleet is electric. The electricity used to charge the for Lambeth and London as a whole, and they are important cross-border strategic vehicles is generated directly from our own waste at SELCHP. It is planning issues. Lambeth Council wishes to ensure every opportunity is taken to important to note the pollutants emitted by tugs since they use heavy improve these issues in the borough. We would therefore like to continue to work fuel oils which form an air pollution blanket over the Thames. with WCC to find ways to reduce the impacts of Westminster waste movements through Lambeth. 4. If the route over Lambeth Bridge is blocked, access across the river will be via bridges in Westminster.

Hopkins, Kimberley: WCC

From: Catherine Carpenter Sent: 12 November 2019 09:04 To: Hopkins, Kimberley: WCC Cc: Rob Bristow; Robert East Subject: Statement of Common Ground - Lambeth and Westminster Attachments: Westminster Lambeth SCG 121119.pdf

Dear Kimberley,

I can confirm that Lambeth’s Cabinet Member for Planning Investment and New Homes has given in principle agreement to the attached Statement of Common Ground between Lambeth and Westminster, prior to considering it for formal agreement in December 2019.

Kind regards,

Catherine Carpenter BA MA MRTPI Head of Policy and Place-shaping Planning, Transport and Development Sustainable Growth and Opportunity London Borough of Lambeth

T: 020 7926 1251 M: 07785 660143 www.lambeth.gov.uk/planning

Postal address: London Borough of Lambeth, Planning Transport & Development, PO Box 734, Winchester, S023 5DG

Address for delivery in person or by courier: London Borough of Lambeth, Civic Centre 3rd floor 6 Brixton Hill, London SW2 1EG

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1 Statement of Common Ground between London Borough of Lambeth and the City of London December 2019

1. Executive Summary

This Statement of Common Ground has been prepared to demonstrate that both Lambeth’s Draft Revised Lambeth Local Plan – Proposed Submission Version January 2020 (DRLLP PSV 2020) and the City of London’s City Plan 2036 are ‘based on effective joint working on cross-boundary strategic matters’, in accordance with the requirements of paragraph 35 of the National Planning Policy Framework (NPPF). It focusses on areas of agreement or disagreement between Lambeth and the City of London on strategic cross-boundary matters.

Updates to this document will be agreed as matters progress and agreement is reached on any outstanding issues. It therefore includes details on mechanisms for review and updating.

Both councils’ monitoring reports also provide further details of how the DRLLP PSV 2020 and the City Plan 2036 have been informed by ongoing engagement with key partners, including those that are not party to this Statement of Common Ground.

2. Parties involved

• London Borough of Lambeth • City of London Corporation

3. Strategic geography

This section sets out the factual position regarding cross-boundary strategic matters.

The London Plan

Transport for London

The London Enterprise Panel

All London Green Grid

Thames Water

Thames Water is the statutory water and sewerage undertaker for the area and is hence a “specific consultation body” in accordance with the Town & Country Planning (Local Development) Regulations 2012. From the 1st April 2018 all network reinforcement work required to support development will be delivered by Thames Water and funded through the Infrastructure Charge applied to each property connected to the water and wastewater networks. The Infrastructure Charge will also cover all modelling and design work required to deliver any necessary upgrades. The planning system will still play a key role in assisting that development does not outpace the delivery of any necessary infrastructure provision.

It will be essential that all development is aligned with any necessary water and sewerage infrastructure upgrades required to avoid any adverse impacts such as sewer flooding, pollution of land or watercourses and impacts of low/no water pressure. In line with Draft Revised Lambeth Local Plan policy EN4, Thames Water will, where appropriate, request phasing conditions are used to ensure that any new development or phase of development is not occupied until any necessary upgrades have been completed.

Thames Water are helping to deliver the Thames Tideway Tunnel project which will be a new fifteen- mile-long ‘super sewer’ running under the River Thames. A new interceptor sewer will be constructed west of Blackfriars Bridge in the City of London, creating a new open space in the City.

1 Also known as the London Economic Action Partnership LB Lambeth

Lambeth is an inner London borough with a northern boundary on the River Thames. It is situated mainly between the boroughs of Wandsworth and Southwark. It covers an area of approximately ten and a half square miles. It is surrounded by seven other London Boroughs - LB Southwark; LB Bromley; LB Croydon; LB Merton; LB Wandsworth; City of Westminster and City of London.

City of London

The City of London lies to the north of the River Thames and covers an area of just over a square mile. It is surrounded by the City of Westminster, LB Camden, LB Islington, LB Hackney, LB Tower Hamlets, LB Southwark and LB Lambeth. The City of London and Lambeth do not share a land border but sit on opposite sides of the River Thames with a small notional border.

This Statement includes the whole of the LB Lambeth and the whole of the City of London.

Map 1 – Map of authorities involved in this Statement

Map 2 – Border between the two parties and key policy designations

Neighbourhood planning

There are no designated neighbourhood planning areas spanning the borough boundary between the two parties.

Employment, retail, leisure and commercial development

Shared town centres None.

Employment

Central Activities Zone

Figure 1 – Area of London Plan Central Activities Zone

The whole of the City of London and the area of Lambeth closest to the City (Waterloo) lies within the Central Activities Zone (CAZ). The CAZ is a London Plan designation. It contains a broad range of functions that have London-wide, national and international significance including Government, business, culture, research and education, retailing, tourism, transport and places of worship. The London Plan seeks to promote and enhance the agglomeration and rich mix of strategic functions and local uses in the CAZ, whilst also supporting and enhancing its significant office functions.

Transport

Main roads that cross the border between Lambeth and the City: None.

Overground rail lines that cross the borough boundary and connect the two parties: None.

Underground rail lines that cross the borough boundary and connect the two parties: None.

Air quality

Air Quality Focus Areas spanning the borough boundary between the two parties: None.

Flood risk

The Thames Barrier is managed and maintained by the Environment Agency and protects 125 square kilometres of central London from flooding caused by tidal surges. This includes the protection of just under 29,000 properties in Lambeth and 141 in the City who would otherwise be at risk of tidal and fluvial flooding. The Thames tidal defences also includes tidal walls and embankments along the banks of the River Thames. Should they fail or become breached the areas most at risk of flooding would be in the north of Lambeth and an area of the City within 200m of the Thames, but this could also impact on the surrounding neighbourhoods. The Environment Agency holds tidal breach modelling. This is also detailed within Lambeth’s SFRA Tidal Breach addendum and the City of London’s Strategic Flood Risk Assessment.

The Environment Agency’s Thames Estuary 2100 Plan (November 2012) sets out the measures that require implementing to maintain adequate flood risk protection from the River Thames by the year 2100. The Plan identifies Lambeth and the City within Action Zone 2 – Central London. The Plan outlines a number of recommendations to mitigate flood risk within this zone, including to maintain, enhance or replace, the river defence walls and active structures through central London over the first 25 years of the Plan from 2010 to 2034, and then from 2035 to 2049. The plan advises that by 2065, the existing flood defences of the river wall will need to be raised by 0.5m and a further 0.5m by 2100.

Critical Drainage Areas

A Critical Drainage Area is a discrete geographic area (usually a hydrological catchment) where multiple and interlinked sources of flood risk (surface water, groundwater, sewer, main river and/or tidal) cause flooding in one or more Local Flood Risk Zones during severe weather thereby affecting people, property or local infrastructure. No Critical Drainage Areas span the borough boundary between the two parties.

The provision of energy (including heat)

The London heat map is an online tool, developed by the Mayor, used to find opportunities for decentralised energy (DE) projects in London. The Mayor has identified Heat Network Priority Areas, which can be found on the London Heat Map website. These identify where in London the heat density is sufficient for heat networks to provide a competitive solution for supplying heat to buildings and consumers. No existing or proposed heat networks cross the borough boundary between the two parties.

River Thames

Sites of Nature Conservation Importance (SINCs) that cross the borough boundary between the two parties:

• River Thames and Tidal Tributaries Metropolitan SINC

Sites of Metropolitan Nature Importance that cross the borough boundary between the two parties: • River Thames

The Thames Policy Area is a special policy area to be defined by boroughs in which detailed appraisals of the riverside will be required.

Strategic and local views

Strategic views which cross the borough boundary between the two parties:

• Protected Vista Westminster Pier to St Paul’s Cathedral • Protected Vista King Henry’s Mound to St Paul’s Cathedral Local views from Lambeth into the City:

National Theatre (LV 1) Queen Elizabeth Hall (LV 2) Knight’s Hill (LV 16) Gipsy Hill (LV 17) Brixton Panoramic (LV 19) Norwood Park (LV 22)

St Paul’s Heights Code viewpoints along South Bank and southern ends of Hungerford and Waterloo Bridges

The Draft Revised Lambeth Local Plan Proposed Submission Version January 2020 (DRLLP PSV 2020) proposes to designate a new local view from Queen’s Walk to St. Paul’s Cathedral.

Local views from the City into Lambeth: None

Heritage, design and conservation

Conservation areas in Lambeth adjoining City: South Bank (CA38)

Conservation areas in the City adjoining Lambeth: Temples Conservation Area

4. Strategic matters

This section sets out where agreement has or has not been reached on cross-border strategic matters.

4.1 Neighbourhood Planning

There are no designated neighbourhood planning areas spanning the borough boundary between the two parties.

4.2 Housing

4.2a. Overall housing need

• Both parties agree that they can meet or exceed the total numerical housing target assigned to them by the Mayor of London in the Draft London Plan, within the confines of their own administrative boundary. 4.2b. Affordable housing

The London Plan and borough level Local Plans together set out the levels and types of affordable housing provision required.

• In terms of affordable housing, to ensure a consistent approach across London, both parties support the Mayor’s threshold approach to affordable housing and the Mayor’s strategic target of 50% affordable housing across London.

The City of London manages 126 flats on the William Blake Estate in Lambeth, which provides affordable housing for City of London tenants. The City of London also manages the City of London Almshouses (44 flats) and the Gresham Almshouses (8 flats) in Lambeth.

• Both parties agree to work collaboratively on any additional development or redevelopment of these properties and estates to deliver new affordable housing for City and Lambeth residents. 4.2c. Gypsies and Travellers

The City of London has a need for 0 pitches and is not planning to make provision.

period by safeguarding the existing gypsy and traveller site in Streatham Vale (Lonesome depot) and managing churn in vacant pitches on this site to meet identified future need.

• Both parties agree that on this basis neither borough has unmet need for gypsy and travellers accommodation

4.3 Employment, retail, leisure and other commercial development

The continued commercial success of the Central Activities Zone is vital to London’s world city status. As supported by the Mayor of London, both parties have introduced Article 4 Directions within their portion of the CAZ to protect central London’s strategically important office supply against change of use to residential use under permitted development rights.

• Both parties agree to work collaboratively to deliver the Draft London Plan approach to the CAZ and consult each other on major applications with potential strategic cross border impacts

4.4 Health

Health infrastructure planning in Lambeth reflects the priorities of the Lambeth Clinical Commissioning Group - this has had regard to and acknowledges potential movement of patients across the border between the two boroughs.

The City is working with the City and Hackney CCG in relation to planning for health facilities.

Both Lambeth and the City of London are home to regional hospitals that cater to health care needs beyond each administrative boundary.

• Both parties acknowledge that there is likely to be cross border movements of patients between Lambeth and the City but agree there are no known planning reasons why these movements cannot continue. 4.5 Education

Both parties have school place planning teams who seek to ensure that projected levels of demand for both primary school and secondary school places are met. Each party has undertaken a school place planning exercise which has had regard to cross-border movement of pupils between the two boroughs. The findings are reflected in the Lambeth Infrastructure Delivery Plan 2019 and will be reflected in the City of London Infrastructure Delivery Plan 2020.

• Both parties acknowledge that there is likely to be cross border movements of school pupils between Lambeth and the City but agree there are no known planning reasons why these movements cannot continue.

4.6 Telecommunciations

• Both parties agree to work collaboratively on the delivery of digital connectivity infrastructure where there are cross-border implications

4.7 Security

• Both parties agree to work collaboratively on counter terrorism measures such as hostile vehicle mitigation where there are cross-border implications

4.8 Transport

Lambeth supports the City’s general approach to traffic reduction.

The draft City Plan requires all off-street parking facilities to be equipped with electric vehicle charging points. This is supported by Lambeth.

• Both parties agree to work collaboratively to deliver the Mayor’s Transport Strategy outcomes with regards to walking and cycling • Both parties agree to consult each other about proposed changes to traffic management and parking controls where these may have a cross-border impact • Both parties agree to take a co-ordinated, with TfL, approach to bus corridors and bus priority measures.

4.9 Air quality

The whole of Lambeth is an Air Quality Management Area, with Air Quality Focus Areas defined in Draft London Plan paragraph 9.1.8. Lambeth has produced an Air Quality Action Plan. Lambeth proposes to follow the Draft London Plan policy approach to air quality in relation to new development.

City of London is also an Air Quality Management Area and has adopted an Air Quality SPD and an Air Quality Strategy was adopted in 2019.

• Both parties agree to continue their involvement in a number of cross-organisational projects to tackle poor air quality across London (see appendix 2).

4.10 Waste management

Each Waste Planning Authority is expected to plan for their identified waste needs, including planning to meet London Plan apportionment targets. Lambeth is planning for net self-sufficiency for LACW, C&I and C&D waste and a target of 95% beneficial use of excavation waste. Net self- sufficiency means providing enough waste management capacity to manage the equivalent of 100% of these waste streams generated in Lambeth, while recognising that some imports and exports will continue. This includes meeting the London Plan apportionment targets for the borough. Lambeth is planning for its identified waste needs by safeguarding existing waste sites and identifying sufficient land to provide opportunities to meet the waste management capacity gaps for the borough.

The City of London works collaboratively with the South East London Joint Waste Planning Group to meet its London Plan Waste Apportionment in full. The City of London Local Plan promotes a Circular Economy approach to waste.

There are no significant waste movements between Lambeth and the City of London, as set out in the Lambeth Waste Evidence Base 2019.

• Both parties acknowledge that there are no implications for either party as a result of each other’s proposed position on waste

4.11 Water supply, wastewater

• Each party agrees to support Thames Water’s approach to planning for water and waste water infrastructure

4.12 Flood risk

Flood risk in each borough is addressed through respective Strategic Flood Risk Assessment (SFRAs) and Local Plans planning policies. SFRAs assess the risk from all sources of flooding, this includes fluvial, tidal, surface water and foul water sources.

Each local authority is statutorily required to produce a Local Flood Risk Management Strategy (LFRMS) for their respective borough which details how they assess and will manage Local Flood Risk within their administrative boundary. LFRMSs require cross boundary partnership working to achieve the ultimate outcome of reducing Local Flood Risk. As part of the partnership working, Lambeth’s and the City’s Flood Risk Officers meet at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

• Both parties agree to have regard to each other’s flood risk policies and evidence

4.13 Provision of energy (including heat)

Not applicable.

4.14 Green infrastructure (i.e SINCs and MOL)

Both parties are separated by the River Thames and therefore no green infrastructure crosses the borough boundary between the two parties.

4.15 Planning measures to address climate change mitigation and adaptation

Lambeth Council declared a Climate Emergency in January 2019. Lambeth has set itself a target to achieve net zero carbon for council operations by 2030. In July 2019, Lambeth published a corporate

carbon reduction plan which sets out initial actions to achieve this target, to be reviewed annually to ensure Lambeth is on track. Lambeth are also developing a wider Lambeth climate change response plan, which will be published in 2020. In the next eleven months Lambeth plans to engage widely, starting with a Citizens’ Assembly early next year, to raise awareness, gather evidence and seek to build consensus around Lambeth’s climate change response and the resulting action plan.

The City Corporation in July 2018 published a Responsible Business Strategy which outlined the Corporation’s commitment to address issues posed by climate change. The Corporation is developing a Climate Action Strategy which will be published in 2020. This will outline actions taken to reduce carbon emissions and increase climate resilience in the City and set a credible target to achieve net zero carbon within the City.

The sections above relating to transport, waste, flood risk, provision of energy and air quality are all relevant to mitigating and adapting to climate change.

• Both authorities agree to follow the approach outlined in the London Plan for zero carbon developments (see DLP policy SI2) and support the principle of the Mayor’s urban greening objectives

4.16 River Thames

4.16.1 Policy approach

The River Thames provides a major asset that Lambeth and the City of London border. Both authorities recognise the importance of this setting and have complementary policy approaches to shape future development within the area designated through the London Plan as the Thames Policy Area.

• Both parties agree to work collaboratively to implement policies affecting the London Plan Thames Policy Area

4.16.2 River services

• Both parties agree to work collaboratively to improve both passenger transport on the River and use of the River for freight movements.

4.16.3 Sites of Importance for Nature Conservation

• Both parties agree to consult each other on any proposals that could impact on the River Thames and Tidal Tributaries Metropolitan SINC. • Both parties agree to have regard to the River Thames and Tidal Tributaries Metropolitan SINC designation and each other’s respective Local Plan policies when determining applications that could impact on this designation. Both parties agree to work collaboratively to ensure that development does not have an adverse impact on the SINC 4.17 Strategic and local views

Strategic and local views

Within Lambeth, areas appropriate for tall buildings have been identified in the draft revised Lambeth Local Plan Annex 11, supported by policy Q26. Protected Views are covered by DRLLP policy Q25.

Within the City of London, areas inappropriate for tall buildings have been identified in the draft City plan 2036.

The City Plan 2036 includes a St Paul’s Heights policy. This is referenced in the supporting text to DRLLP policy Q25.

• Both parties agree to have regard to cross border strategic and local views when determining applications, and consult each other on any proposals that could impact on these views. Lambeth agrees to protect views of St Paul’s, under the St Paul’s Heights code, from identified viewpoints on the South Bank and the southern ends of Waterloo and Hungerford Bridges.

4.18 Cultural infrastructure

The Southbank/Bankside/London Bridge area is designated in the Draft London Plan as a strategic cluster of cultural attractions. This area crosses the borough boundary between the Lambeth and Southwark and lies adjacent to the boundary with the City of London.

• Both parties acknowledge that this area could result in cross border movements of people between Lambeth and the City but agree there are no known planning reasons why these movements cannot continue.

5 Governance arrangements

This statement has been informed by on-going engagement between the two parties – as evidenced by the main body of the statement explaining joint working and the schedule of engagement between the parties in Appendix 1.

Timetable for agreement, review and update

Local Present plan Reg. 18 date Anticipated Reg. Anticipated authority adoption 19 date submission date Lambeth September 2015 October 2018 January 2020 Spring 2020 City of January 2015 November May 2020 Summer 2020 London 2018 Table 1: Plan review, update and submission dates

Ongoing collaboration between the parties will continue through regular meetings and through attendance at group meetings where cross boundary issues are discussed.

6 Signatories

Both parties agree that this statement is an accurate representation of matters discussed and issues agreed upon.

It is agreed that these discussions will inform both the Lambeth Local Plan 2020 and the Draft City Plan 2036 and both parties will continue to work collaboratively in order to meet the duty to cooperate.

For the City of London the Statement of Common Ground is signed by the Policy and Performance Director with political oversight from the Chair and Deputy of the Planning & Transportation Committee.

Signed: ______Signed: ______

Name: Councillor Matthew Bennett Name: Paul Beckett

Position: Cabinet Member for Planning, Position: Policy and Performance Director Investment & New Homes,

London Borough of Lambeth City of London

Appendix 1 - Schedule of engagement between the parties

Officer-level meetings to discuss strategic cross border planning matters under the duty to cooperate and to develop this statement of common ground took place: • 21st January 2016 (with Southwark) • 15th September 2017 (also with LB Tower Hamlets and Southwark) • 5th December 2018 • 30th October 2019

Air quality meetings/projects:

Project Partner London Councils work into new AQ City and London Councils (lead), various other legislation boroughs Healthy Streets Everyday Islington (lead), Cross River Partnership, 15 other boroughs, GLA (funders) – TBC

Non Road Mobile Machinery register King’s College London, GLA, TFL, Brent, Camden, Croydon, Hammersmith and Fulham, RBKC, Islington, Lewisham, Tower Hamlets, Wandsworth, and Westminster. Air Quality Monitoring Network King’s College London Breathe London Project GLA (lead), University of Cambridge, King’s College London, AirMonitors, CERC, Environmental Defence Fund, Google Earth Outreach, National Physical Laboratory, C40 Cities. airTEXT service Islington Council (Current lead), University of Cambridge, London boroughs, GLA, Chelmsford, Colchester, Slough, Three Rivers, Thurrock, Environment Agency, Public Health England, CERC, European Commission, DEFRA, PREVAIR and European Space Agency Pollution alerts to schools, GP surgeries GLA, King’s College London and care homes Ultra Low Emission Zone GLA Statutory duties as Air Quality GLA, Defra Management Area London wide idling engine programme City and Camden (lead), GLA, London boroughs Table 2: List of projects both parties are part of taking place in London to monitor and improve air quality.

Air quality organisations:

Table 3: List of organisations both parties are part of taking place in London to monitor and improve air quality.

Flood officer meetings:

Lambeth’s and the City of London’s Flood Officers meet at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

All London Borough planning officer meetings (Association of London Borough Planning Officers): • 13th Jan 2016 • 21st June 2016 • 27th July 2016 • 13th October 2016 • 9th Feb 2017 • 14th March 2017 • 16th May 2017 • 16th February 2018 • 1st May 2018 • 3rd July 2018 • 18th September 2018 • 13th November 2018 • 25th January 2019 • 07th February 2019 • 12th March 2019 • 04th April 2019 (sub group meeting) • 07th May 2019 • 05th June 2019 (sub group meeting) • 16th July 2019 • 25th July 2019 • 17th September 2019 • 19th September 2019 (sub group meeting) • 12th November 2019

Appendix 2 - Evidence of activities undertaken to address an issue

Local Plan consultations:

On 9th October 2017, Lambeth notified the City of London that the first stage of public consultation on the Lambeth Local Plan Review (Regulation 18 part 1 - Issues consultation) would run for eight weeks from 9 October to 4 December 2017. Lambeth invited the City to make representations.

On 22nd October 2018, Lambeth notified the City of London that the second stage of public consultation on the Lambeth Local Plan Review (regulation 18 part 2 - Draft Revised Lambeth local Plan 2018) would run for eight weeks from 22 October to 17 December 2018. Lambeth invited the City of London to make representations.

On 19 September 2016, the City Corporation notified Lambeth of the first stage of public consultation on City Plan 2036 (Regulation 18 – Issues and Options). The consultation ran between 19 September and 31 October 2016. The City Corporation invited Lambeth to make representations.

On 12 November 2018, the City Corporation notified Lambeth of the second stage of consultation on City Plan 2036 (Regulation 18 – full draft Plan). The consultation ran from 12 November 2018 until 28 February 2019. The City Corporation invited Lambeth to make representations.

Schedule of representations received from the City in the Issues consultation 2017

On 4th December 2017, the City of London Corporation submitted comments to Lambeth as part of the Issues consultation. The City welcomed Lambeth’s proposed approach to increasing green infrastructure in new developments and improving air quality. The City also noted that, any re- provision of waste sites outside Lambeth would need to be agreed through a pooling of the relevant London Plan waste apportionment targets so that London can meet its net-self-sufficiency target.

Schedule of representations received from the City in the DRLLP consultation 2018

On 14th December 2018, the City of London Corporation submitted comments on the Draft Revised Lambeth Local Plan 2018. The table below outlines the points made by the City and the proposed Lambeth response.

Representation Wording Plan Policy/Sites/General Officer Proposed Change Section /Policies Map/Issue Response in DRLLP PSV Thank you for consulting the City of London General Duty to Cooperate Noted. No change. Corporation on the Draft Revised Lambeth Local Plan (October 2018) and for the opportunity to comment.

We note that the revised Local Plan updates the spatial strategy, vision and strategic objectives of the Lambeth Local Plan adopted in September 2015. We look forward to engaging positively with Lambeth now and in the future.

We do not have any comments to make General General Noted. No change. although we note and welcome Lambeth’s proposed approach to increasing the quality of open space and green infrastructure in new developments and improving air quality. We also welcome the inclusion of the City of Section Q25 Noted. No change London’s St Paul’s Heights policy and London 10 Views Management Framework (LVMF).

Statement of Common Ground between London Borough of Lambeth and London Borough of Southwark

December 2019

1. Executive summary

This Statement of Common Ground (SCG) has been prepared to demonstrate that the New Southwark Plan Submission Version (NSPSV 2019) – proposed submission late 2019 and Lambeth’s Draft Revised Lambeth Local Plan – Proposed Submission Version January 2020 (DRLLP PSV 2020) are ‘based on effective joint working on cross-boundary strategic matters’, in accordance with the requirements of paragraph 35 of the National Planning Policy Framework (NPPF). This SCG focuses on strategic cross-boundary matters being addressed and progress in cooperating to address them.

Updates to this document will be agreed as matters progress and agreement is reached on any outstanding issues. It therefore includes details on mechanisms for review and updating.

Southwark’s Duty to Co-operate Statement and Lambeth’s AMRs also provide further details of how both plans have been informed by ongoing engagement with key partners, including those that are not party to this Statement of Common Ground.

2. Parties involved

• London Borough of Lambeth • London Borough of Southwark

The NSPSV 2019 was submitted to the Secretary of State on 9th December 2019.

Given the close alignment of both Southwark and Lambeth’s local plan productions timetable, both parties have agreed to develop a single bi-lateral SCG which will serve both local plan submissions.

3. Strategic geography

This section sets out the factual position regarding cross-boundary strategic matters.

The London Plan

The London Plan Examination Panel report has been published, and the plan is expected to be adopted in 2020.

Transport for London

The London Enterprise Panel

All London Green Grid

Thames Water

Thames Water is the statutory water and sewerage undertaker for the area and is hence a “specific consultation body” in accordance with the Town & Country Planning (Local Development) Regulations 2012. From the 1st April 2018 all network reinforcement work required to support development will be delivered by Thames Water and funded through the Infrastructure Charge applied to each property connected to the water and wastewater networks. The Infrastructure Charge will also cover all modelling and design work required to deliver any necessary upgrades. The planning system will still play a key role in assisting that development does not outpace the delivery of any necessary infrastructure provision.

It will be essential that all development is aligned with any necessary water and sewerage infrastructure upgrades required to avoid any adverse impacts such as sewer flooding, pollution of land or watercourses and impacts of low/no water pressure. Thames Water will, where appropriate, request phasing conditions are used to ensure that any new development or phase of development is not occupied until any necessary upgrades have been completed In line with DRLLP EN4 and NSP P68.

Thames Water are helping to deliver the Thames Tideway Tunnel project which will be a new fifteen- mile-long ‘super sewer’ running under the River Thames.

1 Also known as the London Economic Action Partnership LB Lambeth

LB Southwark

Southwark is bordered by the London borough of Lewisham to the east, Bromley and Croydon to the south, Lambeth to the west, and the City of London and Tower Hamlets to the north. Lambeth lies immediately to the west of the Southwark. The land border between the two boroughs covers approximately 13 kilometres. This Statement includes the whole of Lambeth and the whole of Southwark. Lambeth and Southwark are not jointly part of any formal sub-regional groupings and therefore both parties have decided to enter into a bilateral statement of common ground (SCG).

Map 1 – Map of parties involved in this Statement

Map 2 – Border between the two parties and key policy designations

Neighbourhood planning

Two designated neighbourhood areas cross the borough boundary between the two parties.

South Bank and Waterloo Neighbours

South Bank and Waterloo Neighbours (SoWN) were designated by both Lambeth and Southwark as a neighbourhood forum and area in February 2014. They were subsequently re-designated by both authorities in February 2019. SoWN is a designated business area.

SoWN submitted their Draft Neighbourhood Plan to Lambeth and Southwark on 19 June 2018. Both authorities considered the legal compliance of the submitted documents and made a decision to proceed to publication and examination. The Plan subsequently underwent examination and the examiner’s report was published in May 2019. In July 2019 Lambeth and Southwark each made the decision to accept all of the Examiner’s recommendations to modify the draft neighbourhood plan. It was agreed that subject to these modifications, the draft neighbourhood plan should be sent to two referendums: one for residents and one for businesses.

The two referendums took place on 24 October 2019 and more than half of those voting voted in favour of the NDP in each referendum. The results of the referendum mean the draft NDP now forms part of Lambeth’s development plan. The next stage in the process will be a Cabinet decision by both Lambeth and Southwark on the making of the draft NDP in December.

Herne Hill Neighbourhood Forum

In December 2017, Lambeth and Southwark each approved the designation of the Herne Hill Neighbourhood Area. However, the application for the Herne Hill Neighbourhood Forum made by the Herne Hill Forum was refused. There has been no subsequent application to designate a neighbourhood forum.

Employment, retail, leisure and other commercial development

Shared town centres: • Camberwell Green (district centre) • Herne Hill (district centre) • Camberwell New Road (local centre)

Employment:

Central Activities Zone

Figure 1 – Area of London Plan Central Activities Zone

Areas of both boroughs lie within the Central Activities Zone (CAZ). The CAZ is a London Plan designation. It contains a broad range of functions that have London-wide, national and international significance including Government, business, culture, research and education, retailing, tourism, transport and places of worship. The London Plan seeks to promote and enhance the agglomeration and rich mix of strategic functions and local uses in the CAZ, whilst also supporting and enhancing its significant office functions.

Strategic Areas for Regeneration

As outlined by Draft London Plan policy SD10, there are parts of London where the impacts of inequality and causes of deprivation are particularly concentrated. Based on the Index of Multiple Deprivation (IMD), many of the city’s neighbourhoods lie within the 20 per cent most deprived areas in England. The Draft London Plan identifies these neighbourhoods as Strategic areas for regeneration (SARS).

As shown on map below there are SARS which adjoin/cross the borough boundary between the two parties:

Figure 2 - Strategic Areas for Regeneration (based on 20 per cent most deprived lower super output areas in England)

Transport

Main roads that cross the border between Lambeth and Southwark: • A3200 (Stamford Street) is part of the TfL Road Network • A301 (Waterloo Road) is a London Distributor Road • A3202 (Westminster Bridge Road) is a London Distributor Road • A302 (St Georges Road) is a London Distributor Road • A3203 (Lambeth Road) is a London Distributor Road • A3204/A3 (Kennington Lane/Newington Butts) is part of the TfL Road Network • A3 (Kennington Park Road/Newington Butts) is part of the TfL Road Network • A202 (Camberwell New Road) is part of the TfL Road Network • A2217 (Coldharbour Lane/Denmark Hill) is a London Distributor Road • A215 (Denmark Hill/Herne Hill/Norwood Road) is a London Distributor Road • A2199 (Croxted Road/South Croxted Road) is a London Distributor Road • A205 (Thurlow Park Road) is part of the TfL Road Network

Overground rail lines that cross the borough boundary and connect the two parties: • South Eastern mainline between London Waterloo East and London Bridge • Thameslink line between between Loughborough Junction and Elephant and Castle • Overground line between Clapham High Street and Denmark Hill • South Eastern line between Herne Hill and West Dulwich • Southern line between Tulse Hill and North Dulwich

Overground stations on lines that cross the borough boundary and connect the two parties: • London Waterloo East (Lambeth) • London Bridge (Southwark) • Loughborough Junction (Lambeth) • Elephant and Castle (Southwark) • Clapham High Street (Lambeth) • Denmark Hill Station (Southwark) • Herne Hill Station (Lambeth) • West Dulwich Station (Southwark)

• Tulse Hill (Lambeth) • North Dulwich (Southwark)

Underground rail lines that cross the borough boundary and connect the two parties: • Jubilee Line • Northern Line

Underground stations on lines that cross the borough boundary and connect the two parties: • Waterloo (Lambeth)(Jubilee Line) • Southwark (Southwark)(Jubilee Line) • Kennington (Lambeth)(Northern Line) • Elephant and Castle (Southwark)(Northern Line)

Bakerloo Line Extension

The Bakerloo Line Extension (BLE) is a key element of the growth strategy in the London Plan, which would extend the Bakerloo Line into Southwark and Lewisham. The Mayor of London has committed to accelerating its delivery. The extension is being progressed through the growth partnership and the members are working together to expedite it. Southwark are working with TfL and Lambeth on the case for the new rail station at Camberwell. The delivery of the BLE would enable the Old Kent Road and New Cross and Catford OAs to maximise their development potential, supporting London’s continued growth and long-term economic success.

Figure 3 - The proposed route of the Bakerloo Line Extension.

Low Line project

The Low Line is a new walking route alongside railway viaducts which connects neighbourhoods. The purpose of the Low Line is to improve walking and cycling links along and through railway viaducts. The Low Line is opening up a wide variety of opportunities. The aspiration is to extend the project which originated in Southwark into Lambeth.

Air quality

Air Quality Focus Areas spanning the borough boundary between the two parties: • Waterloo Road • Elephant and Castle to St George’s Circus • Walworth Road/Camberwell Road/Camberwell Green • Herne Hill Croxted Road/Half Moon Lane/Dulwich Road/Norwood Road

Flood risk

The Thames Barrier is managed and maintained by the Environment Agency and protects 125 square kilometres of central London from flooding caused by tidal surges. This includes the protection of just under 29,000 properties in Lambeth and 95,000 in Southwark who would otherwise be at risk of tidal and fluvial flooding. The Thames tidal defences also include tidal walls and embankments along the banks of the River Thames. Should they fail or become breached, the areas most at risk of flooding would be in the north of the boroughs, but this could also impact on the surrounding neighbourhoods. The Environment Agency holds tidal breach modelling. This is also detailed within Lambeth’s SFRA Tidal Breach addendum.

The Environment Agency’s Thames Estuary 2100 Plan (November 2012) sets out the measures that require implementing to maintain adequate flood risk protection from the River Thames by the year 2100. The Plan identifies Lambeth and Southwark within Action Zone 2 – Central London. The Plan outlines a number of recommendations to mitigate flood risk within this zone, including to maintain, enhance or replace, the river defence walls and active structures through central London over the first 25 years of the Plan from 2010 to 2034, and then from 2035 to 2049. The plan advises that by 2065, the existing flood defences of the river wall will need to be raised by 0.5m and a further 0.5m by 2100.

Critical Drainage Areas

Figure 3 - Map of CDA(s) in Lambeth

Critical Drainage Areas spanning the borough boundary between the two parties: • Group7_031 • Group7_032

The provision of energy (including heat)

The Draft London Plan states that boroughs should engage at an early stage with relevant energy companies and bodies to establish the future energy and infrastructure requirements arising from large-scale development proposals such as Opportunity Areas, Town Centres, other growth areas or clusters of significant new development (see DLP policy SI3). It also states that development plans should identify the need for, and suitable sites for, any necessary energy infrastructure requirements including energy centres, energy storage and upgrades to existing infrastructure. Furthermore boroughs should identify existing heating and cooling networks, identify proposed locations for future heating and cooling networks and identify opportunities for expanding and inter-connecting existing networks as well as establishing new networks.

density is sufficient for heat networks to provide a competitive solution for supplying heat to buildings and consumers.

The London Heat Map identifies proposed heat networks that cross the borough boundary between the two parties at: • Upper Ground • Lothian Road/Wyndham Road • Denmark Road/Carew Street/Warner Road • Lowth Road/Caldecot Road • Bessember Road/Denmark Hill/De Crespigny Park • King’s College Hospital

Green infrastructure

Metropolitan Open Land (MOL) in Lambeth adjoining Southwark: • Brockwell Park MOL

Sites of Nature Conservation Importance (SINCs) in Lambeth adjoining Southwark: • Brockwell Park SINC • Ruskin Park SINC • Railway Lineside - Peabody Hill including Acid Grassland SINC • Kennington Park SINC

Metropolitan Open Land (MOL) in Southwark adjoining Lambeth: • Geraldine Mary Harmsworth Park • Burbage Road Playing Fields • Dulwich College Sports Grounds • Belair Park • Dulwich Upper Wood.

Sites of Nature Conservation Importance (SINCs) in Southwark adjoining Lambeth: • Geraldine Mary Harmsworth Park • Belair Park • Sydenham Hill and West Dulwich Railsides • Long Meadow • Gypsy Hill Railway Cutting.

River Thames

Sites of Nature Conservation Importance (SINCs) that cross the borough boundary between the two parties: • River Thames and Tidal Tributaries Metropolitan SINC

Sites of Metropolitan Nature Importance that cross the borough boundary: • River Thames

The Thames crosses the borough boundary between the two parties. There are River services on the Thames for both passengers and freight.

The Thames Policy Area is a special policy area to be defined by boroughs in which detailed appraisals of the riverside will be required.

Strategic and local views

Strategic views which cross the borough boundary between the two parties: • Protected Vista Parliament Square to Palace of Westminster • Protected Vista Primrose Hill to Palace of Westminster • Protected Vista King Henrys Mound to St Pauls Cathedrale • Protected Vista Westminster Pier to St Pauls Cathedrale

Local views from Lambeth into Southwark: • Dasset Road (LV 15) • Knight’s Hill (LV16) • Gypsy Hill (LV17) • Brixton Panoramic (LV 19) • Norwood Park (LV 22)

There are no local or borough views from Southwark into Lambeth.

Heritage, design and conservation designations

Conservation areas in Lambeth adjoining Southwark: • South Bank (CA38) • Waterloo (CA34) • Mitre Road and Ufford Street (CA51) • Lambeth Walk and China Walk (CA50) • Walcot (CA09) • Kennington (CA08) • St Marks (CA11) • Vassal Road (CA07) • Minet Estate (CA25) • Herne Hill (CA61) • Brockwell Park (CA39) • Gipsy Hill (CA14)

Conservation areas in Southwark adjoining Lambeth: • Dulwich Village (7) • Sunray Estate (39) • Camberwell Grove (4) • Camberwell Green (20) • Camberwell New Road (5) • Kennington Park Road (9) • Elliot's Row (46) • West Square (14) • Valentine Place (44) • Old Barge House Alley (23)

Historic parks and gardens in Lambeth adjoining Southwark: • Kennington Park, Ruskin Park and Brockwell Park.

Historic parks and gardens in Southwark adjoining Lambeth: • Belair Park

Archaeological priority areas in Lambeth adjoining Southwark: • North Lambeth APA2 • Roman Road APA3 • Camberwell APA17

Archaeological priority areas in Southwark adjoining Lambeth: • North Southwark and Roman Roads (APA1) • Camberwell Village (APA3)

Cultural infrastructure

Strategic Cultural Cluster designation in the London Plan

The Southbank/Bankside/London Bridge area is designated in the Draft London Plan as a strategic cluster of cultural attractions. This area crosses the borough boundary between the two parties and comprises a number of world class arts venues and galleries.

4. Strategic matters

This section sets out where agreement has or has not been reached on cross-border strategic matters.

4.1 Neighbourhood Planning

• Both parties agree to work collaboratively on emerging cross border decisions relating to neighbourhood plans.

4.2 Housing

4.2a. Overall housing need

The London Plan and borough level Local Plans together set out the levels and types of affordable housing provision required.

Southwark has four authorised traveller sites providing 39 pitches (three of which are double pitches). This is the fourth largest provision in London (7% of the total authorised pitch provision). The four official sites in Southwark that are available for Gypsies and Travellers are located at: • Ilderton Road • Brideale Close • Burnhill Close • Springtide Close.

Southwark are currently in the process of completing a Needs Assessment with regards to Gypsies and Travellers within the borough of Southwark, which will be released by the end of 2019. This will become part of the evidence base for the New Southwark Plan.

• Southwark agrees that Lambeth have no unmet need. • Lambeth cannot comment until the findings of the Southwark needs assessment are published. 4.3 Employment, retail, leisure and other commercial development

Central Activities Zone

The continued commercial success of the Central Activities Zone, which covers northern areas of both Southwark and Lambeth is vital to London’s world city status. As supported by the Mayor of London, both parties have introduced Article 4 Directions within their portion of the CAZ to protect central London’s strategically important office supply against change of use to residential use under permitted development rights.

• Both parties agree to work collaboratively to deliver the Draft London Plan approach to the CAZ and consult each other on major applications with potential strategic cross border impacts.

Visitor accommodation

DRLLP PSV 2020 policy ED14 proposes to introduce a new policy to restrict any further visitor accommodation in Waterloo within the boundary of the Central Activities Zone.

• Both parties agree to work collaboratively to manage the growth of visitor accommodation around Waterloo to ensure the most effective mix of land uses in that part of the CAZ.

Shared town centres

• Both parties agree to have regard to their respective policy approaches to shared town centres in their respective local plans. • Both parties agree to share monitoring information and analysis of the health of shared town centres – particularly where analysis suggests emerging issues that may require joint action.

4.4 Health

Health infrastructure planning in Lambeth reflects the priorities of the Lambeth Clinical Commissioning Group. This approach has regard to and acknowledges potential movement of patients across the border between the two boroughs.

NHS Southwark Clinical Commissioning Group (CCG) is a key partner, working with Southwark to ensure that development improves health services and health outcomes for Southwark’s residents. Under the Health and Social Care Act (2012) Health and Wellbeing Boards were set up to improve integration between practitioners in local health care, social care, public health and related public services.

Southwark council has worked with the CCG to align the New Southwark Plan, Old Kent Road Area Action Plan/Opportunity Area Planning Framework and an estates strategy for local health facilities. Together they will ensure that the need for new healthcare floorspace and the transformation of services are achieved.

Our Healthier South East London programme (OHSEL) is a proposal devised by the six CCGs covering the London Boroughs of Bexley, Bromley, Greenwich, Lambeth, Lewisham and Southwark. OHSEL is the body responsible for the delivering the Sustainability & Transformation Plans (STPs) for the six boroughs.

Both Lambeth and Southwark are home to regional hospitals that cater to health care needs beyond each administrative boundary.

• Both parties agree to work collaboratively under the OHSEL programme. • Both parties acknowledge that there is likely to be cross border movement of patients between each borough but agree there are no known planning reasons why these movements cannot continue. • Both parties agree to work collaboratively to plan for strategic cross border health facilities.

4.5 Education

Both parties have school place planning teams who seek to ensure that projected levels of demand for both primary school and secondary school places are met. Each party has undertaken a school place planning exercise which has had regard to cross-border movement of pupils between the two boroughs. The findings are reflected in the Lambeth Infrastructure Delivery Plan 2019 and the Southwark Infrastructure Delivery Plan (2017).

• Both parties acknowledge that there is cross border movement of school pupils between each borough but agree there are no known planning reasons why these movements cannot continue.

4.6 Telecommunciations

• Both parties agree to work collaboratively on the delivery of digital connectivity infrastructure where there are cross-border implications.

4.7 Security

• Both parties agree to work collaboratively on counter terrorism measures such as hostile vehicle mitigation as required. 4.8 Transport

Bakerloo Line Extension

• Both parties agree to work collaboratively to support the business case of the Bakerloo Line extension and other strategically important transport infrastructure, such as Crossrail 2. • Both parties agree to work collaboratively to minimise construction impacts that result from cross border transport projects such the Bakerloo line extension. • Both parties agree to work collaboratively to ensure that any impacts to the amenity of nearby residents arising from the BLE in both boroughs are mitigated. Active travel

• Both parties agree to work collaboratively to deliver the Mayor’s Transport Strategy outcomes with regards to walking and cycling. • Both parties agree to strategically co-ordinate the delivery of a healthy route between Brixton and Camberwell. • Both parties agree to work collaboratively to deliver the Low Line project to the south of Camberwell. • Both parties agree to work collaboratively, and with TfL, to deliver to Cycle future route 14 on Camberwell New Road. • Both parties agree to work collaboratively to deliver the Central London Bike Grid.

Car parking

Southwark has a car-free approach to car parking. Southwark’s Cycle and car parking standards SPD (2015) sets out the borough’s residential car provision for areas based on PTAL score and the adopted London Plan recommendations. Within PTAL zones 6 and 5, no car parking space may be provided, with a maximum of 2 spaces per unit in PTAL zones 1 and 2. A minimum of 1 cycle parking space must be provided for all units regardless of PTAL zone.

Approximately 50% of Southwark offers parking zones, accounting for 23 zones in total. The primary reason for the zone restrictions is to give parking priority to local residents and short-stay shop and business visitors.

• Both parties agree to consult with each other about proposed changes to parking controls where these may have a cross-border impact. • Lambeth notes that there is a CPZ coming forward in Dulwich. Both parties agree to strategically consider traffic, parking and transport issues in Dulwich and the wider area. • Both parties agree to work collaboratively to explore ways to deliver the workspace levy parking concept at sub regional level.

Other transport and infrastructure agreements:

• Both parties agree to strategically consider traffic, parking and transport issues related to the reconfiguration of King’s College Hospital and South London and Maudsley. Lambeth notes that Southwark is currently undertaking a transport study and encourages the study to consider such impacts on Lambeth. • Both parties agree to ensure a co-ordinated approach, with TfL, to bus corridors and bus priority measures. • Both parties agree to work collaboratively to improve east-west bus services. • Both parties agree to promote and support the development and implementation of improvements to local rail services as part of the Mayor’s ‘metroisation’ plan. • Both parties agree to work collaboratively to consider the impacts that re-opening Camberwell station could have on Loughborough Junction and the wider South London rail network, taking into account ‘metroisation’. • Both parties agree to ensure a coordinated approach to traffic management at Upper Ground spine route. • Both parties agree to work collaboratively around the implementation of schemes impacting Herne Hill and the wider management of transport issues in Herne Hill. • Both parties agree to work collaboratively to deliver the Draft London Plan approach to freight consolidation.

4.9 Air quality

Poor air quality is also a major concern for Southwark’s residents and is considered a strategic matter which cannot be resolved by local policy alone.

• Both parties agree to continue their involvement in a number of cross-organisational projects and organisations to tackle poor air quality across London (see appendix 1).

The impacts of construction traffic, including to air quality, can cross borough boundaries. This is the case in the north of the borough where the London Bridge, Borough and Bankside Opportunity Area logistics group facilitates bi-monthly coordination with all contractors in the opportunity area as well as business improvement districts, Lambeth council and TfL.

• Both parties agree that air quality is a trans-boundary strategic issue, which will require cooperation to tackle. • Both parties agree to work collaboratively to ensure that the impacts of construction are mitigated.

4.10 Waste management

Each Waste Planning Authority is expected to plan for their identified waste needs including planning to meet London Plan apportionment targets.

Lambeth is planning for net self-sufficiency for LACW, C&I and C&D waste and a target of 95% beneficial use of excavation waste. Net self-sufficiency means providing enough waste management capacity to manage the equivalent of 100% of these waste streams generated in Lambeth, while recognising that some imports and exports will continue. Lambeth is planning for net self-sufficiency by safeguarding existing waste sites and identifying sufficient land to provide opportunities to meet the waste management capacity gaps for the borough.

Southwark is a member of the London Waste Planning Forum, and is entered into a voluntary partnership with Bexley, Bromley, Greenwich, and Lewisham called the Southeast London Joint Waste Planning Group (SELJWPG). In order to demonstrate effective collaboration, the SELJWG produces the South East London Waste Technical Paper. This report sets out general planning policy for waste, each borough’s waste strategy and local planning policies and shows the sites which contribute to the waste management capacity requirement. It is reviewed by the group as individual boroughs prepare their Local Plan, allowing the capacity of sites to be kept up to date. Each borough must allocate its strategic waste sites formally in a DPD to safeguard them for the life of their Local Plan - in the event that a site is required for another use, the capacity must be re-provided, in accordance with London Plan policy. The NSP safeguards the Integrated Waste Management Facility site in line with the paper.

The London Borough of Southwark receives strategic amounts of waste exports from Lambeth as set out in the Lambeth Waste Evidence Base 2019. No significant waste exports from Southwark are received in Lambeth.

• Both parties agree to plan separately to meet their respective Local Plan waste apportionments following the approach described above. • Both parties agree there are no known planning reasons why exports of similar amounts of waste exports cannot continue.

4.11 Water supply, wastewater

• Each party agrees to support Thames Water’s approach to planning for water and waste water infrastructure.

4.12 Flood risk

Each council is statutorily required to produce a Local Flood Risk Management Strategy (LFRMS) for their respective borough which details how they assess and will manage Local Flood Risk within their administrative boundary. LFRMSs require cross boundary partnership working to achieve the ultimate outcome of reducing Local Flood Risk. As part of the partnership working, Lambeth’s and Southwark’s Flood Risk Officers meet at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

Lambeth’s Local Plan flood risk related policies state that all new development must avoid increasing the risk of flooding; and where possible, positively contribute to the reduction in risk to the borough and elsewhere (Policy EN5). It encourages the use of Sustainable Drainage Systems to achieve this (Policy EN6) due to their ability to mimic natural drainage while providing water quality, biodiversity and amenity benefits. The Lambeth Local Plan also requires developments to satisfy; the London Plan’s Sustainable Drainage Policy (Policy SI13) in particular the London Plan Drainage Hierarchy; and, the national Non-statutory Technical Standards for Sustainable Drainage Systems.

Southwark plans to mitigate surface flooding risk by mimicking natural drainage patterns by reducing hard surfaces and increasing absorbent surfaces through soil and planting. Policy P70 in the NSP states that development must not increase flood risk on- or off-site, by ensuring that major developments reduces surface water run-off to green field run-off rates. This must be through the application of water sensitive urban design and Sustainable Urban Drainage Systems (SUDS).

• Both parties agree to have regard to each other’s flood risk policies and evidence.

Southwark and Lambeth are hydraulically connected through shared watersheds which impact on each borough’s risk of flooding from surface water. The risk of flooding from surface water is assessed in respective Surface Water Management Plans, where areas at significant risk of flooding are identified and are labelled as Critical Drainage Areas (CDAs). There are 10 CDAs within Lambeth, of which two are shared with Southwark (Group7_031 and Group7_032).

• Both parties agree to work collaboratively to reduce the risk of flooding within Critical Drainage Areas.

4.13 Provision of energy (including heat)

Lambeth proposes to follow the Draft London Plan policy approach to the provision of energy in relation to new development (see Draft Revised Lambeth Local Plan policy EN3).

The South East London Combined Heat and Power plant currently heats 2,500 homes within the borough. There are plans to expand this network to provide heating to more homes. Southwark also proposed to Draft London Plan policy approach to the provision of energy in relation to new development (see New Southwark Plan Submission Version policy P69: Energy).

• Both parties agree to work collaboratively where opportunities arise to connect development to heat networks that cross, or are in close proximity to, the borough boundary between the two parties.

4.14 Green infrastructure (i.e SINCs and MOL)

• Both parties agree to consult each other on any proposals that could impact on green infrastructure in the neighbouring borough. • Both parties agree to have regard to each other’s SINC and MOL designations on or in close proximity to the borough boundary and their respective Local Plan policies when determining applications.

4.15 Planning measures to address climate change mitigation and adaptation

In April 2019 Southwark Council joined the international Climate Change Campaign and declared a Climate Change Emergency. Southwark is a low-lying borough next to the tidal Thames, and so is particularly vulnerable to the impact of the rising sea levels and flooding. Southwark have cut emissions by 37% since 2010 and are hoping to achieve carbon neutrality by 2030. An Integrated Impact Assessment is currently being produced for Southwark which will become part of the New Southwark Plan.

The sections above relating to transport, waste, flood risk, provision of energy, green infrastructure and air quality are all relevant to mitigating and adapting to climate change.

• Both authorities agree to follow the approach outlined in the London Plan for zero carbon developments (see DLP policy SI2) and support the principle of the Mayor’s urban greening objectives.

4.16 River Thames

4.16.1 Policy approach

The River Thames provides a major asset that Southwark and Lambeth border. Both authorities recognise the importance of this setting and have complementary policy approaches to shape future development within the area designated through the London Plan as the Thames Policy Area.

• Both parties agree to consult each other on any proposals on/in the River Thames and have regard to each other’s respective Local Plan policies. • Both parties agree to work collaboratively to implement policies affecting the London Plan Thames Policy Area.

4.16.2 River services

• Both parties agree to work collaboratively to improve both passenger transport on the River and use of the River for freight movements.

4.16.3 Sites of Importance for Nature Conservation

• Both parties agree to consult each other on any proposals that could impact on the River Thames and Tidal Tributaries Metropolitan SINC.

• Both parties agree to have regard to the River Thames and Tidal Tributaries Metropolitan SINC designation and each other’s respective Local Plan policies when determining applications that could impact on this designation.

4.17 Strategic and local views, and heritage, design and conservation

Strategic and Local Views

Within Lambeth, areas appropriate for tall buildings have been identified in the draft revised Lambeth Local Plan Annex 11, supported by policy Q26. Protected Views are covered by DRLLP policy Q25.

Southwark lists a range of criteria in policy to determine higher building applications instead of identifying specific zones. These criteria can be found in the NSP under P15. Protected views within the borough and across boundaries are also covered under NSP P20.

• Both parties agree to consult each other on any proposals that could impact on strategic and/or local views and to work together to ensure that in the case of strategic views such development will protect and enhance these views in line with the guidance in the LVMF, and in the case of all other views that development will optimise opportunities to protect and enhance in line with relevant local policy and guidance.

Heritage, design and conservation

• Both parties agree to have regard to the setting of heritage, design and conservation designations adjoining the borough boundary in the neighbouring borough when determining applications, and consult each other on any proposals that could impact on these designations.

4.18 Cultural infrastructure

Southwark published a Cultural Strategy in 2017 which sets out existing cultural uses in the borough and sets out own ambitions for the ongoing growth of cultural facilities within the borough. This has informed Policy P44 within the draft New Southwark Plan.

Southbank

Strategic clusters of cultural attractions

The Mayor has identified a number of areas of London which are rich in cultural heritage. One of the strategic clusters of cultural attractions, South Bank/Bankside/London Bridge, crosses the borough boundary between the two parties. Southbank contains one of London’s most significant agglomerations of cultural activities.

• Both parties agree to work collaboratively to deliver the Draft London Plan and Local Plan policy approaches in the South Bank/Bankside/London Bridge cultural cluster. • Both parties agree to consult each other on any proposals that could impact on this cluster in the neighbouring borough. • Both parties acknowledge that this area is likely to result in cross border movements of people between each borough but agree there are no known planning reasons why these movements cannot continue.

5 Governance arrangements

Timetable for agreement, review and update

Local Present plan Proposed Reg 18 date Reg 19 date Submission authority adoption plan review date start date Lambeth September October 2017 October 2018 January 2020 April 2020 2015 Southwark 2011 - - - December 2019 Table 1: Plan review, update and submission dates

Ongoing collaboration between the parties will continue through regular meetings and through attendance at group meetings where cross boundary issues are discussed.

6 Signatories

Both signatories agree that this statement is an accurate representation of areas of agreement and disagreement between the two parties.

Signed: ______Signed: ______

Name: Councillor Matthew Bennett Name: Simon Bevan

Position: Cabinet Member for Planning, Position: Director of Planning Investment & New Homes

London Borough of Lambeth London Borough of Southwark

Date: Date: 4 December 2019

Appendix 1 - Schedule of engagement between the parties

Schedule of meetings between Southwark and Lambeth:

Organisation Dates Southwark, Lambeth and City of 2015 – 15 September London 2017 – 15 September Officer level duty to cooperate meetings Southwark and Lambeth 2016 – 21 January Officer level duty to cooperate 2017 – 22 July meetings 2018 – 25 June 2019 – 18 October (meeting to discuss strategic cross border planning matters under the duty to co-operate and to develop this statement of common ground took place) Cross-River Partnership Twice yearly board meetings includes the central London boroughs along with business groups and other key stakeholders such as Network Rail, Groundwork London, London & Partners, Transport for London and the GLA. Its key focus is on economic growth, sustainable employment, carbon reduction and place-making. Association of London Borough 2013 – 30 April, 25 June, 10 September Planning Officers 2014 – 14 January, 4 March, 24 June, 9 September 2015 – 3 February, 31 March, 19 May, 29 September, 24 November 2016 – 21 January, 21 June, 27 July, 13 October 2017 – 14 March, 22 March, 16 May, 7 September, 7 December 2018 – 16 February, 1 May, 3 July, 18 September, 13 November 2019 – 25 January, 7 February, 12 March, 4 April (sub group meeting), 7 May, 5 June (sub group meeting), 16 July, 25 July, 17 September, 19 September (sub group meeting), 12th November London Councils 2013 – 12 February, 12 March, 14 May, 11 June, 9 July, 8 London Councils represents October, 12 November, 10 December London’s 32 boroughs and the 2014 – 11 February, 11 March, 9 April, 15 July, 14 October, 9 City of London. It is a cross-party December organisation that works on 2015 – 10 February, 24 March, 2 June, 14 July, 13 October, 8 behalf of all of its member December authorities regardless of political 2016 – 9 February, 22 March, 7 June, 12 July, 16 October, 6 persuasion. The strategic December direction of London Councils is 2017 – 7 February, 21 March, 11 July, 10 October, 5 December set by the Leaders’ Committee. Our Leaders’ Committee comprises the Leaders of all of

London’s local authorities. There is also a cross-party Executive, which guides the organisation’s day-to-day work. The London Fire and Emergency Planning Authority and the Mayor’s Office for Policing and Crime are also in membership. London Borough Development Every three months Viability Group Our Health South East London 2016 – 1 February, 26 April, 17 May, 11 October OHSEL is a proposal devised by 2017 – 26 July, 13 December the 6 Clinical Commissioning 2018 – 12 March, 26 September Groups (CCGs) covering the 2019 – 21 March, 22 July London Boroughs of Bexley, Bromley, Greenwich, Lambeth, Lewisham and Southwark.

Air quality meetings:

Statutory duties as Air Quality GLA, Defra Management Area Table 2: List of projects both parties are involved in taking place in London to monitor and improve air quality.

Air quality organisations:

Organisation Participating authorities Frequency Central London Air Quality WCC, Hammersmith and Fulham, Camden, Quarterly Cluster Group Islington, City of London, Hackney, Southwark, Lambeth, London Councils, GLA APRIL Network (Air Pollution All boroughs, GLA, TfL, research institutions Quarterly Research in London) Table 3: List of organisations both parties are involved in taking place in London to monitor and improve air quality.

Flood officer meetings:

Southwark’s and Lambeth’s Flood Officers meet at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

Cross-River Partnership meetings:

Cross-River Partnership include the central London boroughs along with business groups and other key stakeholders such as Network Rail, Groundwork London, London & Partners, Transport for London and the GLA. Its key focus is on economic growth, sustainable employment, carbon reduction and place-making. Board meetings take place twice annually.

South Bank and Bankside Cultural Quarter:

The South Bank and Bankside Cultural Quarter (SBBCQ) is a partnership consisting of 30 cultural organisations, local authorities including Lambeth and Southwark, business improvement districts and universities. The partnership is director-led and meets approximately three times a year.

South Bank Partnership:

South Bank Partnership brings together the area’s two MPs, major employers and business representatives, the Greater London Authority, the Metropolitan Police, Network Rail, Transport for London, representatives from the local community sector, and elected representatives and officers from Lambeth Council and Southwark Council. The Partnership released Manifestos in 2014 and 2018, which set out the priorities for the area.

LB Southwark

Southwark Council engages with other boroughs and the City of London through regular meetings either between officers or elected members with formalised governance arrangements such as the London Councils Leaders’ Committee, Association of London Borough Planning Officers, the Cross River Partnership, and the South East London Duty to Cooperate Group. Southwark also maintain

correspondence between planning departments on a variety of issues and projects and organise additional meetings on strategic planning matters when needed.

Appendix 2 - Evidence of activities undertaken to address an issue

Local plan consultations:

On 9th October 2017, Lambeth notified Southwark that the first stage of public consultation on the Lambeth Local Plan Review (Regulation 18 part 1 - Issues consultation) would run for eight weeks from 9 October to 4 December 2017. Lambeth invited Southwark to make representations. Southwark did not submit a response to this consultation.

On 22nd October 2018, Lambeth notified Southwark that the second stage of public consultation on the Lambeth Local Plan Review (regulation 18 part 2 - Draft Revised Lambeth local Plan 2018) would run for eight weeks from 22 October to 17 December 2018. Lambeth invited Southwark to make representations. Southwark did not submit a response to this consultation.

On 14 December 2017, Southwark notified Lambeth that informal consultation on the New Southwark Plan Proposed Submission Version would run until 24 December 2017, with formal consultation running for six weeks from 2 January 2018 to 12 February 2018.

On 25 January 2019, Southwark notified Lambeth that consultation on the New Southwark Plan Amended Policies Version would run from 25 January 2019 until 17 May 2019.

Schedule of representations received from Southwark in the DRLLP regulation 18 consultation

None.

Schedule of representations received from Lambeth in the New Southwark Plan Proposed Submission Version consultation on 15th December 2017

Representation Wording Southwark Officer Response Proposed Change in NSP PSV 2019 We note that a number of the site allocations in around Camberwell and Extra care homes requirements have been None. Dulwich allow for the provision of new extra care homes. Has the need for removed from the site allocations due to proposals this specialist accommodation, in this location, been discussed with the for housing of this type to be considered under the Lambeth clinical commission group, in the context of the emerging market ‘Housing for older people’ policy. Any identified position statement for adult social care in the two boroughs? need will be addressed in the Southwark Housing Strategy. There is still no mention of the clinical commissioning group (CCG). This point has not been addressed

The ambitions that both Councils have for Blackfriars and Waterloo (to see This ambition is already stated within the None. these become thriving business districts) can be mutually complimentary and Blackfriars Road Area Vision. beneficial.

This isn’t stated – the collaborative ambition for this location should be reflected in the document.

Unprecedented growth is already underway, in both Blackfriars and Waterloo, The reasons to our hotels policy notes that we and moreover TfL and LBL are pursuing the redevelopment of the have delivered one of the highest numbers of hotel roundabout. All of this growth will bring pressures; on the public realm, open rooms in London. References to new visitor space and transport links. Many of the workers and new residents of the accommodation were removed from site Blackfriars Road developments will use Waterloo Station and the routes allocations in the plan with the exception of key connecting Waterloo and Blackfriars Road, notably the Cut and Stamford strategic development sites in the Canada Water Street. Both these streets suffer increasingly from congestion and are in need and Old Kent Road opportunity areas. This was due of significant investment. TfL and Lambeth taking forward plans for the to ensuring the site allocations set out a concise list redevelopment of the high road. of required uses including housing and offices and Waterloo has recently experienced significant growth in hotel developments, where other uses are proposed this would be and Lambeth will be testing the implications of this growth through the assessed against normal development forthcoming Local Plan review. We will be exploring what the impact of management policies and in the context of further hotel development would be on the sustainability of Waterloo and the meeting the requirements of the site allocation. surrounding areas. We note that a number of the site allocations in this area propose new visitor accommodation. The impact of this use on the wider

locale including in Lambeth needs to be tested. For the site allocations that include proposals for visitor accommodation, please can this potential impact be acknowledged.

The PSV does not acknowledge any potential impacts that further hotel developments may have on the mix and balance of uses in the wider Waterloo area including on the Lambeth side. It only states: Development for hotels and other forms of visitor accommodation must not harm the local character or amenity by the design, scale, function, parking and servicing arrangements

The Waterloo area has traditionally lacked much permeability and we Indicative Low Line routes are planned to extend NSP P51 sets out details welcome all commitments to enhance connectivity, especially for pedestrians into Lambeth in the Waterloo area. regarding the expansion of and cyclists, and are pleased to see commitments to furthering the ‘low line’. Low Line routes.

Lambeth is committed to safeguarding The Cut and Lower Marsh as a retail Noted. Our policies also safeguard The Cut as a CAZ None. Centre and welcomes all moves which contribute to its vitality. Conversely we frontage and seek to safeguard 40% A1 uses to would be concern about any proposals that detract from the vitality and support the vitality and viability of these frontages. viability of the Lower Marsh / The CUT CAZ frontage.

In addition we are conscious of the urgency to coordinate efforts around We require detailed construction management Policies updated to include managing the impact of construction during this period of development, and plans for development to mitigate adverse impacts references to mitigation in particular to mitigate against air pollution. and the construction phase of development is during construction phase. Policy P66 on Improving air quality policy does not mention mitigating impacts included in our highways impacts policy, reducing during the construction process waste policy, hazardous substances policy and now specifically mentioned in the reasons to the air quality policy. Blackfriars Road This site allocation has been removed from the None. NSP. NSP14 Telephone Exchange and 50 – 60 Blackfriars Road This site lies immediately adjacent to the Lambeth borough boundary This is because the site owners confirmed there is alongside its western flank on Hatfields. It is in reasonable proximity to the no prospect of redevelopment within the NSP Lower Marsh / The Cut CAZ Boundary and Waterloo Opportunity area,

therefore the site will need to acknowledge any potential implications this timeframe as the site houses telecoms equipment may have. In turn NSP14 lies just to the East of Lambeth Local Plan Site 7 that cannot be relocated. (Waterloo Station/Waterloo Road SE1).

There needs to be recognition in the supporting text of this site’s position on the borough boundary. On the Lambeth side the Waterloo CA adjoins and the Roupell Street CA is very close. There are significant implications for these designated heritage assets with tall buildings at this end of the site.

We welcome the commitment to the provision of improved public realm and increased links.

NSP16 Land enclosed by Colombo Street, Meymott Street and Blackfriars We have acknowledged the site’s proximity to the We have stated that: Road borough boundary with Lambeth. ‘Development proposals must recognise the site’s close The site is lies adjacent to the borough boundary. It is also in close proximity The reasons to our hotels policy notes that we proximity to the borough to the Waterloo OA, and lies to the east of Lambeth Local Plan Site 7 have delivered one of the highest numbers of hotel boundary and must consider (Waterloo Station/Waterloo Road SE1). rooms in London. References to new visitor the setting of heritage assets accommodation were removed from site in Lambeth, in addition to any There are potential concerns about allowing visitor accommodation in this allocations in the plan with the exception of key cross-boundary issues and the location given the significant concentration of hotels that exist in Waterloo. strategic development sites in the Canada Water provisions of policies and site and Old Kent Road opportunity areas. This was due allocations within reasonable to ensuring the site allocations set out a concise list proximity of the site as set out of required uses including housing and offices and in the Lambeth Local Plan.’ where other uses are proposed this would be assessed against normal development We have stated that: management policies and in the context of ‘Southwark needs to meeting the requirements of the site allocation. accommodate significant growth for offices and other workspaces which are growing in demand contributing to the central London economy and status as a world city.’

NSP18: Southwark Station and 1 Joan Street The site allocation requires that redevelopment of We have stated that: the site must maintain and improve access and ‘Development proposals must The site is lies adjacent to the borough boundary and Waterloo OA. NSP18 is egress from Southwark Station and Waterloo East recognise the site’s close also in close proximity Lower Marsh / The Cut CAZ Boundary, just to the East station. Temporary access requirements would be proximity to the borough of Lambeth Local Plan Site 7 (Waterloo Station/Waterloo Road SE1). part of the detailed site design with TFL. boundary and must consider the setting of heritage assets We welcome the development of an enhanced station, but wish to The reasons to our hotels policy notes that we in Lambeth, in addition to any understand further what provisions are to be made to for temporary have delivered one of the highest numbers of hotel cross-boundary issues and the access/egress during redevelopment, and what long term intentions rooms in London. References to new visitor provisions of policies and site TfL/Network Rail have to improve access to Waterloo East. accommodation were removed from site allocations within reasonable allocations in the plan with the exception of key proximity of the site as set out We welcome to the commitment to town centre frontages along The Cut, strategic development sites in the Canada Water in the Lambeth Local Plan.’ which will contribute to its vitality. and Old Kent Road opportunity areas. This was due to ensuring the site allocations set out a concise list We have stated that: There are potential concerns about allowing visitor accommodation in this of required uses including housing and offices and ‘Southwark needs to location given the significant concentration of hotels that exist in Waterloo. where other uses are proposed this would be accommodate significant assessed against normal development growth for offices and other management policies and in the context of workspaces which are growing meeting the requirements of the site allocation. in demand contributing to the central London economy and status as a world city.’ NSP20 Land between Paris Gardens, Colombo Street, etc. We have acknowledged the site’s proximity to the We have stated that: borough boundary with Lambeth. ‘Development proposals must NSP21 is adjacent to the borough boundary and Waterloo OA. It is in recognise the site’s close reasonable proximity to Lambeth Local Plan Site 7 (Waterloo We encourage the provision of office and other proximity to the borough Station/Waterloo Road SE1) and Site 9 (ITV Centre and Gabriel’s Wharf). workspace in the area with the desire of increasing boundary and must consider the amount of employment floorspace. the setting of heritage assets There needs to be recognition in the supporting text of this site’s proximity on in Lambeth, in addition to any the borough boundary and the implications this has for the setting of heritage cross-boundary issues and the assets in Lambeth. provisions of policies and site allocations within reasonable There are potential concerns about allowing visitor accommodation in this proximity of the site as set out location given the significant concentration of hotels that exist in Waterloo. in the Lambeth Local Plan.’

We have stated that: ‘Southwark needs to accommodate significant growth for offices and other workspaces which are growing in demand contributing to the central London economy and status as a world city.’ NSP21 – 1 – 5 Paris Gardens and 16 – 19 Hatfields We have acknowledged the site’s proximity to the We have stated that: borough boundary with Lambeth. ‘Development proposals must NSP21 lies immediately adjacent to the borough boundary and Waterloo OA. recognise the site’s close It is also in close proximity to Lambeth Local plan Site 7 (Waterloo We encourage the provision of office and other proximity to the borough Station/Waterloo Road SE1) and reasonable proximity to Site 9 (ITV Centre workspace in the area with the desire of increasing boundary and must consider and Gabriel’s Wharf). the amount of employment floorspace the setting of heritage assets in Lambeth, in addition to any There needs to be recognition in the supporting text of this site’s proximity on cross-boundary issues and the the borough boundary and the implications this has for the setting of heritage provisions of policies and site assets in Lambeth. allocations within reasonable proximity of the site as set out We welcome the commitment to providing an East-West link through the site. in the Lambeth Local Plan.’ We note the additional pressure the uplift in residential numbers will bring on Hatfields Gardens currently managed by the BOST open space trust.

There are potential concerns about allowing visitor accommodation in this location given the significant concentration of hotels that exist in Waterloo.

Lambeth understand that Southwark have approved an office scheme on the Paris Gardens site so the comments about pressure from increased residential are not so pressing. NSP22 - Camberwell Station We have revised the site design and accessibility The site design and This site lies immediately to the west of the borough boundary and guidance to state that the access from the west accessibility guidance now Camberwell Trading Estate KIBA.

would likely be in the vicinity of the wider reflects the access to the new Please include the same paragraph about cross border issues that has been Knatchbull Road/ McDowall Road area. proposed station. included in site allocation 26. Specific access requirements would be reviewed in The proposed new station at Camberwell promotes improved connectivity a detailed scheme design. and we think an entrance into Lambeth but it would be coming out into the middle of a residential street, so may have some adverse impact. Please could the site allocation acknowledge this and seek mitigated as required.

PSV states: Any new station must have direct access from both Camberwell Station Road and McDowall Road to ensure the station is accessible to all.

New Lambeth Comment - Southwark do not seem to have addressed the need to mitigate the impact on residential amenity of creating a station entrance in the middle of a residential street.

NSP 26: Camberwell Bus Garage The site design and accessibility guidance has been None. updated to reflect its proximity to the borough And boundary.

NSP27: Abellio Bus Garage, Camberwell The guidance states that if the bus garage is deemed surplus to requirements any potential These sites lie in reasonable proximity to (the west of) the Camberwell impacts on the bus network must be mitigated. Trading Estate KIBA. We have stated: ‘Development proposals must If the bus stations are considered to be surplus to requirements, please could recognise the site’s close proximity to the borough any potential impacts on any service provision in Lambeth be acknowledged boundary and must consider the function of and mitigated as required. Camberwell Trading Estate, in addition to any cross-boundary issues and the provisions of Please include the same paragraph about cross border issues that has been policies and site allocations within reasonable included in site allocation 26 for 27 proximity of the site as set out in the Lambeth Local Plan.’

Dulwich (126) The site design and accessibility guidance already None. reflects the site’s proximity to the borough NSP35 Guys and St Thomas Trust Rehabilitation Centre, Crystal Palace. boundary.

This site lies just to the north of the borough boundary and Crystal Palace We have stated: ‘The site is located adjacent to the District Centre. intersection of the three borough boundaries of Southwark, Lambeth and Bromley. Accordingly, Site vision should acknowledge the site location on the borough boundary development proposals must consider any cross- with Lambeth and Bromley. boundary issues as well as the provisions of policies and site allocations within reasonable proximity to the site as set out in the Lambeth Local Plan and the Draft Bromley Local Plan.’ Herne Hill and North Dulwich The site design and accessibility guidance reflects Site guidance restructured and its proximity to the borough boundary and the references the two NSP50 Bath Trading Estate Brockwell Park Registered Landscape and conservation areas and locally Conservation Area. listed in Lambeth railway The site lies immediately to the south of the Herne Hill District centre. viaduct. The site guidance is clear that development must Site vision needs to acknowledge that the site sits on the borough boundary consider the setting of heritage assets in Lambeth, and that development should preserve or enhance the setting of Brockwell in addition to the provisions of policies and site Park (a Registered Landscape and Conservation Area). allocations within reasonable proximity as set out in the Lambeth Local Plan. Lambeth is currently preparing a draft Conservation Area Statement for Brockwell park CA. It includes suggested extensions to the conservation area The site allocation would allow for comprehensive including at Dulwich Road and Railton Road. The draft document also redevelopment of the site however this must be acknowledges the importance of the Bath Road Trading Estate: sensitive to the two adjacent conservation areas and this is reflected in the updated site guidance. It The current parade of shops is generally is low, uniform and unobtrusive in also acknowledges the railway viaduct as a locally form. This means that in views from the historic landscape it has a positive listed asset in Lambeth. The site opportunities role in allowing views of open sky and distant tree canopies. include intensifying employment uses, providing residential development on upper floors of the Development on top of the shops as proposed will harm important views into shops (sensitive to the settings of the conservation the historic landscape from trains on the railway viaducts immediately

adjoining the site allocation. These are the only elevated location from which areas) and provide better linkages as part of the to appreciate the English Landscape. town centre to Half Moon Lane.

If piecemeal ad-hoc development were to be allowed on this parade there is a The inclusion of the site allocation discourages ad substantial risk of harm to these designated heritage assets. hoc development due to securing an overall aspiration for the site’s future development and In light of the important contribution the low, uniform height of this shopping design guidance in the context of important parade makes to the special interest of the Brockwell Park Conservation Area heritage settings. Therefore it is appropriate to we ask that the site allocation is dropped and that the parade and adjoining remain a site allocation. viaduct are designated as a conservation area by Southwark. There is a precedent for such an approach on Herne Hill where Lambeth designated the Herne Hill Conservation Area partially in response to the contribution Lambeth buildings made to the Stradella Conservation Area.

The ornate cast iron railway bridge to the immediate south staddles the borough boundary. Lambeth’s half (RHS) is locally listed. We ask that consideration be given to similar recognition be given to Southark’s half (LHS) and consideration be given to its inclusion within the conservation area designation we recommend above. Similarly we would ask that the Southwark half of the railway bridge spanning Herne Hill is also designated.

NSP50 is does not fully address our point. Given the sensitivities of the site we consider comprehensive redevelopment (as opposed to a piecemeal) is necessary to ensure that all the public benefits brought by redevelopment to the locality are optimised. APPENDIX 1 This will be updated in a map in our Annex on This will be updated in a map Borough views. in our Annex on Borough This should consider including the views of adjoining boroughs where they views. cross Southwark. See schedule in Lambeth Local Plan Policy Q26. We can provide view cone data.

Annex 4 states that Southwark will continue to work closely with City of London, London Borough of Tower Hamlets and HE to ensure that

development that may impact upon the significance or our Borough Views is appropriate and have regard to the purpose and scope of our views designations.

This does not appear to have considered Lambeth views

Statement of Common Ground between London Borough of Lambeth and London Borough of Croydon

December 2019

1. Executive summary

This Statement of Common Ground (SCG) has been prepared to demonstrate that Lambeth’s Draft Revised Lambeth Local Plan – Proposed Submission Version January 2020 (DRLLP PSV 2020) is ‘based on effective joint working on cross-boundary strategic matters’, in accordance with the requirements of paragraph 35 of the National Planning Policy Framework (NPPF). This SCG focuses on strategic cross-boundary matters being addressed and progress in cooperating to address them.

Updates to this document will be agreed as matters progress and agreement is reached on any outstanding issues. It therefore includes details on mechanisms for review and updating.

Lambeth’s AMRs also provide further details of how the DRLLP PSV 2020 have been informed by ongoing engagement with key partners, including those that are not party to this Statement of Common Ground.

2. Parties involved

• London Borough of Lambeth • London Borough of Croydon

The Croydon Local Plan was adopted in February 2018. Croydon is reviewing its 2018 Local Plan. The Issues and Options consultation, which is based around three spatial strategies, sites and planning policies necessary to meet these needs runs from 8 November 2019 until 13 January 2020.

Please note that this Statement addresses the majority of cross boundary matters between Lambeth and Croydon. However in respect of (i) the shared town centre boundary at Upper Norwood/Crystal Palace, (ii) Strategic Outer London Development Centres, (iii) transport, (iv) air quality and (v) green infrastructure, a separate tri-lateral Statement between Lambeth, Croydon and Bromley addresses these five strategic cross boundary matters.

3. Strategic geography

This section sets out the factual position regarding cross-boundary strategic matters.

The London Plan

The adopted London Plan (2016) is currently subject to a review and the Draft London Plan is undergoing examination at the time of writing. It is expected the replacement London Plan will be published (adopted) in early 2020. Transport for London

The London Enterprise Panel

All London Green Grid

LB Lambeth

Lambeth is an inner London borough with a northern boundary on the River Thames. It is situated mainly between the boroughs of Wandsworth and Southwark and covers an area of approximately ten and a half square miles. Lambeth is surrounded by seven other London Boroughs - LB Southwark; LB Bromley; LB Croydon; LB Merton; LB Wandsworth; City of Westminster and City of London.

The following Geographic Designations are within Lambeth but are noted by be close to the LB Croydon boundary

LB Croydon

Croydon is an outer London borough, situated in south London. It bounds Lambeth to the south. It is bordered by Bromley to the east, and Sutton and Merton to the west. The land border between Croydon and Lambeth is approximately 4 kilometres long.

This Statement includes the whole of the LB of Lambeth and the whole of the LB of Croydon.

1 Also known as the London Economic Action Partnership

Map 1 – Boroughs involved in this Statement

Map 2 – Length of border between Lambeth and Croydon and key policy designations

Neighbourhood planning

There are no designated neighbourhood planning areas spanning, or close to, the borough boundary between the two parties.

Flood risk

The Thames Barrier is managed and maintained by the Environment Agency and protects 125 square kilometres of central London from flooding caused by tidal surges. This includes the protection of just under 29,000 properties in Lambeth. The Thames tidal defences also include tidal walls and embankments along the banks of the River. Should they fail or become breached, the areas most at risk of flooding would be in the north of Lambeth, but this could also impact on the surrounding neighbourhoods. The Environment Agency holds tidal breach modelling. This is also detailed within Lambeth’s SFRA Tidal Breach addendum.

Critical Drainage Areas

Map 3 - Critical Drainage Areas in Lambeth

Critical Drainage Areas spanning the borough boundary between the Lambeth and Croydon:

• Group7_030 • Group7_031

The provision of energy (including heat)

The London Heat Map is an online tool, developed by the Mayor, used to find opportunities for decentralised energy (DE) projects in London. The Mayor has identified Heat Network Priority Areas, which can be found on the London Heat Map website (see DRLLP policy EN3). These identify where in London the heat density is sufficient for heat networks to provide a competitive solution for supplying heat to buildings and consumers.

No existing or proposed heat networks cross the borough boundary between Lambeth and Croydon.

Strategic and local views

Strategic views: • No strategic views cross the borough boundary between Lambeth and Croydon

Lambeth local views into Croydon: • The Rookery (LV21)

Croydon local views into Lambeth: None.

Heritage, design and conservation

Crystal Palace Park is entirely within the borough of Bromley but borders Lambeth and Croydon. It is designated Metropolitan Open Land and grade II listed park (heritage asset).

Conservation areas in Lambeth adjoining Croydon: • Westow Hill (CA23) • Streatham Common (CA43) • Streatham Lodge (CA62)

Conservation areas in Croydon adjoining Lambeth: • Upper Norwood Triangle • Harold Road • Norwood Grove

Archaeological priority areas in Lambeth adjoining Croydon: • Roman Road APA4

Archaeological priority areas in Croydon adjoining Lambeth: • Norwood Grove • London to Brighton Roman Road

Historic parks and gardens in Lambeth adjoining Croydon: • The Rookery

Historic parks and gardens in Croydon adjoining Lambeth: • Norwood Grove

4. Strategic matters:

This section sets out where agreement has or has not been reached on cross-border strategic matters.

4.1 Neighbourhood Planning

There are no designated neighbourhood planning areas spanning the borough boundary between the two parties.

4.2 Housing

4.2a. Overall housing need

Housing need is a strategic issue dealt with at the regional level in London by the Mayor in the London Plan. Through their own local plans, authorities must plan to meet or exceed their London Plan target to ensure they are in general conformity with the London Plan.

• Lambeth’s position in its Draft Revised Lambeth Local Plan is that it is able to meet its own Draft London Plan housing target within its administrative boundary. • Croydon can meet its housing targets set out in the Croydon Local Plan 2018, and is currently consulting until 13 January 2020 on how it might meet the targets set out in the draft London Plan. At this point in time, Croydon is not asking Lambeth to meet any of its housing need. 4.2b. Affordable housing

The Draft London Plan and borough level Local Plans together set out the levels and types of affordable housing provision required.

• Both Lambeth and Croydon have a need for social and affordable rented accommodation that is higher than can be delivered within each borough. Croydon is currently consulting on whether to adopt the Mayor’s threshold approach to affordable housing for all applications in Croydon. Lambeth already supports the approach. Both boroughs support the Mayor’s strategic target of 50% affordable housing across London. Both boroughs agree to seek to meet us much of that need as is possible within their own respective boroughs and that neither borough is able to help meet the needs of the other. Gypsies and Travellers

LB Croydon has a need for 36 pitches between 2016 and 2036 and is planning to meet this need within its border. The first ten years of this need will be met through the development of the Purley Oaks depot site (allocated in the Croydon Local Plan 2018 for 20 Gypsy and Traveller pitches), and

the expansion of the existing Gypsy and Traveller site at Lathams Way. The Croydon Local Plan 2018 sets out a policy mechanism through which the need for the last ten years can be met.

4.3 Health

The six south east London CCGs (Bexley, Bromley, Greenwich, Lambeth, Lewisham and Southwark) received approval to merge from 1 April 2020. This merger will enable the new South East London CCG to work in greater partnership with local authorities in each borough; and commission services for those patient pathways that span the entire south east London integrated care system. Our Healthier South East London programme (OHSEL) is the body responsible for the delivering the Sustainability & Transformation Plans (STPs) for the six boroughs.

• Croydon and Lambeth agree that both boroughs are meeting the need for healthcare facilities in their areas, and that through close working with NHS bodies, this incorporates any cross-boundary movements of patients.

4.5 Education

Both parties have a school place planning teams who seek to ensure that projected levels of demand for both primary school and secondary school places are met. Each party has undertaken a school place planning exercise which has had regard to cross-border movement of pupils between the two boroughs. The findings are reflected in the Lambeth Infrastructure Delivery Plan 2019 and the Croydon Infrastructure Delivery Plan 2019.

• Lambeth and Croydon have both planned to meet their school place needs within their own boroughs, and intend to continue to do so, taking into account an allowance for cross- boundary movements as part of their pupil place forecasting.

4.6 Telecommunciations

• Both parties agree that there have been or will continue to be on going duty to cooperate discussions on emerging Local Plan policies for the delivery of digital connectivity infrastructure where there are cross-border implications

4.7 Security

• Both parties agree that there have been or will continue to be on going duty to cooperate discussions on emerging Local Plan policies for counter terrorism measures such as hostile vehicle mitigation as required.

4.8 Waste management

Croydon is one of the four boroughs of the South London Waste Plan alongside the Royal Borough of Kingston, the London Borough of Merton and the London Borough of Sutton. The councils adopted the South London Waste Plan (SLWP) in 2012 that runs to 2021. Joint work with the south London Waste authorities on a revised waste plan has commenced with an issues and options consultation started in October whose plan period will be from 2021 to 2036.

There are no significant waste movements between Lambeth and Croydon as set out in the Lambeth Waste Evidence Base 2019.

• Both parties agree to plan separately to meet their respective Local Plan waste apportionments following the approach described above.

4.9 Flood risk

Flood risk in each Flood risk in each borough is addressed through respective Strategic Flood Risk Assessment (SFRAs) and Local Plan policies. SFRAs assess the risk from all sources of flooding, this includes fluvial, tidal, surface water and foul water sources. The joint Strategic Flood Risk Assessment for Croydon, Sutton, Merton and Wandsworth (SFRA, 2015) identifies the main risks of fluvial flooding in the vicinity of the Norbury Brook through Thornton Heath and Norbury and through Kenley, Purley and Waddon along the Brighton Road and Godstone Road valleys and around the culverted River Wandle. Croydon has been ranked the 4th settlement in England most susceptible to surface water flooding.

Each council is statutorily required to produce a Local Flood Risk Management Strategy (LFRMS) for their respective borough which details how they assess and will manage Local Flood Risk within their administrative boundary. LFRMSs require cross boundary partnership working to achieve the ultimate outcome of reducing Local Flood Risk. As part of the partnership working, Lambeth’s and Croydon’s Flood Risk Officers meet with each neighbouring council at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

• Each party has had regard to each other’s flood risk policies and agree that they are complimentary.

Croydon and Lambeth are hydraulically connected through shared watersheds which impact on each borough’s risk of flooding from surface water. The risk of flooding from surface water is assessed in

each parties’ respective Surface Water Management Plans, where areas at significant risk of flooding are identified and are labelled as Critical Drainage Areas (CDAs).

There are 10 CDAs within Lambeth, of which two are shared with Croydon (Group7_030 and Grou7_031).

• Lambeth and Croydon agree to work collaboratively to reduce the risk of flooding within Critical Drainage Areas.

4.10 Provision of energy (including heat)

Not applicable.

4.11 Planning measures to address climate change mitigation and adaptation

Croydon Council declared a Climate Emergency in June 2019 and this is now a priority that is a key issues where Local Plan policies to address this are being reviewed through the Issues and Options consultation of the Croydon Local Plan review. It is envisaged that this will be addressed through the delivery of increasingly carbon neutral homes that promote the use of alternatives to the private car.

The sections above relating to transport, waste, flood risk, provision of energy, green infrastructure and air quality are all relevant to mitigating and adapting to climate change.

• The DRLLP PSV 2020 follows the approach outlined in the Draft London Plan for zero carbon developments (see DLP policy SI2) and aligns with the Mayor’s urban greening objectives (including adopting an urban greening factor – see DLP policy G5). • Croydon has declared a Climate Emergency and is currently consulting on a Local Plan review to address this important matter taking account of the approach in the emerging London Plan. There have been or will continue through on going duty to cooperate discussions to inform the development of Local Plan policies.

4.16 Strategic and local views, and heritage, design and conservation

Strategic and local Views

• Lambeth wish to discuss with Croydon a protocol by which Lambeth will be consulted on relevant major planning applications that fall within Lambeth Local View LV21 The Rookery.

Heritage, design and conservation

• Both parties agree to have regard to the setting of heritage, design and conservation designations adjoining the borough boundary in the neighbouring borough

Both parties agree that there will be further discussions on future proposals that could impact Conservation Area designations, particularly those in the Upper Norwood/Crystal Palace area (this detail is in a separate agreement).

4.12 Heritage and Cultural infrastructure

Croydon vision which is reflected in the vision of CLP18 is for a place that draws people to its culture and creativity – an inspiration and enabler of new artistic and sporting talent in the country. The adopted Local Plan policies seek to deliver this vision and are not a focus for review of eh Local Plan (except for updating and to address changes needed to deliver sustainable development.

• Both parties agree that there have been or will continue through on going duty to cooperate discussions to have regard to supporting heritage and cultural matters during the development of Local Plan policies.

5. Governance arrangements

Timetable for agreement, review and update

Local Present plan Proposed Reg 18 date Anticipated Anticipated authority adoption plan review Reg 19 date submission start date date Lambeth September October 2017 October 2018 January 2020 Spring 2020 2015 Croydon February February 8 November November February 2018 2019 2019 – 13 2020 2021 January 2020 Table 1: Plan review, update and submission dates

Ongoing collaboration between both parties will continue through regular meetings and through attendance at group meetings where cross boundary issues are discussed.

6. Signatories

All signatories agree that this statement is an accurate representation of areas of agreement and disagreement between the two parties.

Signed: ______Signed: Name: Cllr Matthew Bennett Name: Steve Dennington Position: Cabinet Member for Planning, Investment & New Homes Position: Service Head - Spatial Planning

London Borough of Lambeth London Borough of Croydon Date Date 2.12.2019

Appendix 1 - Schedule of engagement between the parties

Officer-level meetings to discuss strategic cross border planning matters under the duty to cooperate and to develop this statement of common ground took place on:

• 21st November 2018 • 29th October 2019 (with Bromley)

Flood officer meetings:

Lambeth’s and Croydon’s Flood Officers meet at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

All London Borough planning officer meetings (Association of London Borough Planning Officers):

• 13th Jan 2016 • 21st June 2016 • 27th July 2016 • 13th October 2016 • 9th Feb 2017 • 14th March 2017 • 16th May 2017 • 16th February 2018 • 1st May 2018 • 3rd July 2018 • 18th September 2018 • 13th November 2018 • 25th January 2019 • 07th February 2019 • 12th March 2019 • 04th April 2019 (sub group meeting) • 07th May 2019 • 05th June 2019 (sub group meeting) • 16th July 2019 • 25th July 2019 • 17th September 2019 • 19th September 2019 (sub group meeting) • 12th November 2019

Appendix 2 - Evidence of activities undertaken to address an issue

Local Plan consultations:

Lambeth

On 9th October 2017, Lambeth notified Croydon that the first stage of public consultation on the Lambeth Local Plan Review (Regulation 18 part 1 - Issues consultation) would run for eight weeks from 9 October to 4 December 2017. Lambeth invited both parties to make representations. No representations were received from Croydon.

On 22nd October 2018, Lambeth notified Croydon that the second stage of public consultation on the Lambeth Local Plan Review (regulation 18 part 2 - Draft Revised Lambeth local Plan 2018) would run for eight weeks from 22 October to 17 December 2018. Lambeth invited Croydon to make representations.

Schedule of representations received from Croydon in the DRLLP regulation 18 consultation

On 17th December 2018, LB Croydon submitted comments on the Draft Revised Lambeth Local Plan 2018. The table below outlines the points made by Croydon and the proposed Lambeth response.

Representation Wording Plan Policy/Sites/General/ Officer Response Proposed Change in DRLLP Section Policies Map/Issue PSV Thank you for inviting the London Borough of Croydon (LBC) to comment on General Duty to Cooperate Noted. No change. the draft Revised Lambeth Local Plan (DRLLP). In addition to these comments we confirm that there have been helpful and ongoing discussions to meet the requirements of the duty to cooperate through the preparation of our Local Plans.

The Croydon Local Plan (CLP18) adopted February 2018 sets out a strategy to ensure Croydon continues to be an attractive and thriving place for all who live, work and visit. Once the new London Plan is adopted the Croydon Local Plan 2018 will be reviewed. There is an up to date program to reflect this in the Local Development Scheme (LDS) It is noted that the DRLLP includes an increased housing target for Lambeth Section 05 H01 Noted. No change. as set out in the emerging New London Plan (NLP) which is supported. As background to this, the CLP18 has a housing target of 32,890 (2016 – 2036) which will be delivered in three almost equal ways; in the Croydon Opportunity Area, on allocated development sites and the sustainable growth of the suburbs. However, the target in the NLP proposes to increase Croydon’s target 1,435 per annum to 2,949 per annum. How to deliver this level of growth will be considered and addressed in the review of CLP18 as set out in the LDS. However, it should be noted that the housing target in the CLP18 is capacity based and given the higher housing target in NLP it is very unlikely Croydon will have capacity for unmet needs of other local authorities. It is noted and supported that the DRLLP updates housing policies to reflect Section 05 H02 Support noted. No change. legislation and updated evidence, including reflecting the affordable housing target and the need for this to be delivered on small sites as set out in the New London Plan. The approach to housing is supported. The general approach in the DRLLP has a similar approach to the NLP to Section 06 ED01 Support noted. No change. protect industrial capacity whilst offering prospects of bringing about investments and renewal of industrial/employment locations. The detailed policies encouraging flexible workspaces which are suitable for small and medium business and the requirement for developments to include a proportion of affordable workspaces is supported.

The general approach in the DRLLP has a similar approach to the NLP to Section 06 ED02 Support noted. No change. protect industrial capacity whilst offering prospects of bringing about investments and renewal of industrial/employment locations. The detailed policies encouraging flexible workspaces which are suitable for small and medium business and the requirement for developments to include a proportion of affordable workspaces is supported. The general approach in the DRLLP has a similar approach to the NLP to Section 06 ED03 Support noted. No change. protect industrial capacity whilst offering prospects of bringing about investments and renewal of industrial/employment locations. The detailed policies encouraging flexible workspaces which are suitable for small and medium business and the requirement for developments to include a proportion of affordable workspaces is supported. Croydon is one of the four boroughs of the South London Waste Plan Section 09 EN07 Noted. No change. alongside the Royal Borough of Kingston, the London Borough of Merton and the London Borough of Sutton. The councils adopted the South London Waste Plan in 2012 and have just started work on a replacement plan whose plan period will be from 2021 to 2036. It is noted that Lambeth will plan for waste as an individual authority and has reflected the approach in the NLP.

Statement of Common Ground between London Borough of Lambeth and London Borough of Merton

December 2019

1. Executive summary

This Statement of Common Ground (SCG) has been prepared to demonstrate that Lambeth’s Draft Revised Lambeth Local Plan – Proposed Submission Version January 2020 (DRLLP PSV 2020) is ‘based on effective joint working on cross-boundary strategic matters’, in accordance with the requirements of paragraph 35 of the National Planning Policy Framework (NPPF). It focusses on areas of agreement or disagreement between Lambeth and Merton on strategic cross-boundary matters.

Updates to this document will be agreed as matters progress and agreement is reached on any outstanding issues. It therefore includes details on mechanisms for review and updating.

Lambeth’s AMRs also provide further details of how the DRLLP PSV 2020 plans have been informed by ongoing engagement with key partners, including those that are not party to this Statement of Common Ground.

2. Parties involved

• London Borough of Lambeth • London Borough of Merton

3. Strategic geography

This section sets out the factual position regarding cross-boundary strategic matters.

The London Plan

Transport for London

The London Enterprise Panel

All London Green Grid

Thames Water

Thames Water is the statutory water and sewerage undertaker for the area and is hence a “specific consultation body” in accordance with the Town & Country Planning (Local Development) Regulations 2012. From the 1st April 2018 all network reinforcement work required to support development will be delivered by Thames Water and funded through the Infrastructure Charge applied to each property connected to the water and wastewater networks. The Infrastructure Charge will also cover all modelling and design work required to deliver any necessary upgrades. The planning system will still play a key role in assisting that development does not outpace the delivery of any necessary infrastructure provision.

It will be essential that all development is aligned with any necessary water and sewerage infrastructure upgrades required to avoid any adverse impacts such as sewer flooding, pollution of land or watercourses and impacts of low/no water pressure. In line with DRLLP policy EN4, Thames Water will, where appropriate, request phasing conditions are used to ensure that any new development or phase of development is not occupied until any necessary upgrades have been completed.

LB Lambeth

1 Also known as the London Economic Action Partnership LB Merton

Merton is an outer London borough, situated in south west London, in the Wandle Valley. It covers an area of approximately 14.7 square miles and is surrounded by five other London Boroughs – Wandsworth, Lambeth, Croydon, Sutton and Kingston upon Thames. Merton bounds Lambeth to the south west.

The boundary between the two boroughs is less than 3 kilometres in length. This Statement includes the whole of the LB Lambeth and the whole of LB Merton.

Map 1 – Map of authorities involved in this Statement

Map 2 – Border between the two parties and key policy designations

Map 3 - River Graveney and associated flood risk zones

Neighbourhood planning

There are no designated neighbourhood planning areas spanning the borough boundary between the two parties.

Gypsy and Travellers site

The Streatham Vale Gypsy and Traveller site in Lambeth lies in close proximity to the borough boundary between the two parties.

Employment, retail, leisure and commercial development

Shared town centres: None.

Transport

Main roads that cross the border between Lambeth and Merton: There are no London distributor roads or roads on the TfL Road Network that cross the borough boundary between the two parties.

Rail lines that cross the borough boundary and connect the two parties: • Streatham to Mitcham Eastfields • Streatham to Tooting

Mainline stations on lines that cross the borough boundary and connect the two parties: • Streatham (Lambeth) • Mitcham Eastfields (Merton) • Tooting (Merton)

Air quality

Air Quality Focus Areas spanning the borough boundary between the two parties: None.

Flood risk

River Graveney

The River Graveney runs through both Merton and Lambeth and spans the boundary between the two parties. The River Graveney flood risk zones also span the borough boundary between the two parties.

River Thames

The Thames Barrier is managed and maintained by the Environment Agency and protects 125 square kilometres of central London from flooding caused by tidal surges. This includes the protection of just under 29,000 properties in Lambeth. The Thames tidal defences also includes tidal walls and embankments along the banks of the River Thames. Should they fail or become breached the areas most at risk of flooding would be in the north of Lambeth, but this could also impact on the

surrounding neighbourhoods. The Environment Agency holds tidal breach modelling. This is also detailed within Lambeth’s SFRA Tidal Breach addendum.

Critical Drainage Areas

The provision of energy (including heat)

Green infrastructure

Sites of Importance for Nature Conservation (SINCs) in Lambeth adjoining the borough boundary with Merton: • Eardley Road Sidings – Acid Grassland SINC • Railway Lineside – Tooting Bec to Eardley Road (towards Mitcham Eastfields) SINC

Strategic and local views

Strategic views which cross the borough boundary between the two parties: None.

Lambeth Local views into Merton: • Streatham Common (LV 20) • The Rookery (LV 21)

Merton Local views into Lambeth: None

Heritage, design and conservation designations

There are no conservation areas in either Lambeth or Merton adjoining the borough boundary between the two parties.

There are no historic parks and gardens in either Lambeth or Merton adjoining the borough boundary between the two parties.

Archaeological priority areas in Lambeth adjoining Merton: • Roman Road APA4

Archaeological priority areas in Merton adjoining Lambeth: None

4. Strategic matters

This section sets out where agreement has or has not been reached on cross-border strategic matters.

4.1 Neighbourhood Planning

There are no designated neighbourhood planning areas spanning the borough boundary between the two parties.

4.2 Housing

4.2a. Overall housing need

Housing need is a strategic issue dealt with at the regional level in London by the Mayor in the London Plan. Authorities must plan to meet or exceed their London Plan target to ensure they are in general conformity with the London Plan.

As part of attempting to meet housing need within Merton and in recognition of the difficulty Merton Council currently anticipates in being able to meet its Draft London Plan housing target, Merton has written to Lambeth to request if any of Merton’s share of London’s new homes could be accommodated within Lambeth’s boundary. During the next 12 months Merton will be exploring housing delivery further as part of its new emerging Local Plan and will also be writing to other boroughs to request if any of Merton’s housing target can be accommodated within their boundaries.

Lambeth’s position in its Draft Revised Lambeth Local Plan is that it is able to meet its own Draft London Plan housing target within its administrative boundary. However, Lambeth does not have sufficient surplus capacity to assist other boroughs in meeting their unmet housing requirements. Lambeth has therefore responded to Merton’s request and advised them that it is not able to assist in meeting Merton’s unmet housing requirement.

4.2b. Affordable housing

The London Plan and borough level Local Plans together set out the levels and types of affordable housing provision required.

4.2c. Gypsies and Travellers

In their current adopted Local Plan, LB Merton has a need for 2 pitches between 2014 and 2024 and is planning to meet this need within its border by utilising vacancies on its existing site in north Wimbledon. In 2019 Merton undertook an accommodation assessment of gypsy and traveller needs to inform its emerging new Local Plan. The findings of this accommodation needs assessment will feed into Merton’s emerging Local Plan by mid-2020.

LB Lambeth has a need for 3 pitches for gypsies and travellers between 2019/20 and 2034/35, which equates to one pitch every five years. There is no identified need for plots for travelling showpeople in the borough. Lambeth will meet the needs of Lambeth’s gypsy and traveller community over this period by safeguarding the existing gypsy and traveller site in Streatham Vale (Lonesome depot) and managing churn in vacant pitches on this site to meet identified future need.

• Both parties agree that on this basis both boroughs can meet their identified need for gypsy and travellers accommodation within their own boundary

4.4 Health

Health infrastructure planning in Merton reflects the priorities of Merton’s Clinical Commissioning Group. Merton’s CCG, Merton Council and other providers are working together on Merton Borough Estates Group to inform Merton’s health infrastructure planning.

• Both parties acknowledge that there is likely to be cross border movements of patients between each borough but agree there are no known planning reasons why these movements cannot continue. • Both parties agree to work collaboratively to meet the needs for strategic cross border health facilities

4.5 Education

Both parties have school place planning teams who seek to ensure that projected levels of demand for both primary school and secondary school places are met. Each party has undertaken a school place planning exercise which has had regard to cross-border movement of pupils between the two boroughs. The findings are reflected in the Lambeth Infrastructure Delivery Plan 2019 and will be reflected in the Merton Infrastructure Delivery Plan 2020.

• Both parties acknowledge that there is likely to be cross border movements of school pupils between each borough but agree there are no known planning reasons why these movements cannot continue.

4.6 Telecommunciations

• Both parties agree to work collaboratively on the delivery of digital connectivity infrastructure where there are cross-border implications

4.7 Security

• Both parties agree to work collaboratively on counter terrorism measures such as hostile vehicle mitigation.

4.8 Transport

• Both parties agree to take a co-ordinated approach when possible to traffic management at cross border level. • Both boroughs agree to consult each other about proposed changes to parking controls where these may have a cross-border impact. • Both parties agree to work collaboratively on the delivery of digital connectivity infrastructure where there are cross-border implications. • Both parties agree to take a co-ordinated approach to bus corridors and bus priority measures. • Both parties agree to promote and support the development and implementation of improvements to local rail services as part of the Mayor’s ‘metroisation’ plan.

4.9 Air quality

The whole of Lambeth is an Air Quality Management Area, with Air Quality Focus Areas defined in Draft London Plan paragraph 9.1.8. Both parties have produced an Air Quality Action Plans. Both parties propose to follow the Draft London Plan policy approach to air quality in relation to new development.

• Both parties agree to continue their involvement in a number of cross-organisational projects and organisations to tackle poor air quality across London (see appendix 1).

4.10 Waste management

Each Waste Planning Authority is expected to plan for their identified waste needs including planning to meet London Plan apportionment targets.

Merton has a joint Development Plan Document (the South London Waste Plan) produced with the London Boroughs of Croydon and Sutton and the Royal Borough of Kingston upon Thames and

adopted in 2012. It identifies the waste arisings and sets out how the four boroughs meet the London Plan apportionment targets within their borough boundaries. The four boroughs are currently revising the South London Waste Plan and published the Regulation 18 consultation on 31st October 2019 for six weeks. Evidence for the new South London Waste Plan demonstrates that the four south London boroughs will be able to continue to meet the London Plan apportionment targets by safeguarding existing waste sites.

Both parties have a separate Statement of Common Ground as part of the South London Waste Plan boroughs.

The South London Boroughs (which includes LB Merton) receive strategic amounts of construction, demolition and excavation (CD&E) waste exports from Lambeth.

• Both parties agree there are no known planning reasons why exports of similar amounts of waste exports cannot continue. • Both parties agree to plan separately to meet their respective Local Plan waste apportionments following the approach described above

4.11 Water supply, wastewater

• Each party agrees to support Thames Water’s approach to planning for water and waste water infrastructure.

4.12 Flood risk

Flood risk in each borough is addressed through respective Strategic Flood Risk Assessment (SFRAs) and Local Plan policies. SFRAs assess the risk from all sources of flooding, this includes fluvial, tidal, surface water and foul water sources. The joint Strategic Flood Risk Assessment for Croydon, Sutton, Merton and Wandsworth (SFRA, 2017) identifies the main risks of fluvial flooding in the vicinity of the Norbury Brook through Thornton Heath and Norbury and through Kenley, Purley and Waddon along the Brighton Road and Godstone Road valleys and around the culverted River Wandle.

Each council is statutorily required to produce a Local Flood Risk Management Strategy (LFRMS) for their respective borough which details how they assess and will manage Local Flood Risk within their administrative boundary. LFRMSs require cross boundary partnership working to achieve the ultimate outcome of reducing Local Flood Risk. As part of the partnership working, Lambeth’s and Mertonn’s Flood Risk Officers meet at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

• Both parties have had regard to each other’s flood risk policies and agree that they are complimentary. • Both parties agree to consult each other on any proposals within the flood risk zone where these may have a cross-border impacts

4.13 Provision of energy (including heat)

Lambeth and Merton proposes to follow the Draft London Plan policy approach to the provision of energy in relation to new development (see Draft Revised Lambeth Local Plan policy EN3).

• Although no significant development is currently identified near the borders of each borough, both parties agree to work collaboratively where opportunities arise to connect development to heat networks that cross, or are in close proximity to, the borough boundary between the two parties.

4.14 Green infrastructure (i.e SINCs and MOL)

• Both parties agree to consult each other on any proposals that could impact on SINCs in the neighbouring borough. • Both parties agree to have regard to each other’s SINC designations on or in close proximity to the borough boundary and their respective Local Plan policies when determining applications.

4.15 Planning measures to address climate change mitigation and adaptation

Merton Council declared a Climate Emergency in July 2019, proposing targets to achieve net zero carbon for council operations by 2030 and net zero carbon across the borough by 2050. To inform the action plan on how we will meet these targets Merton is currently asking residents, workers, young people and anyone else interested what priorities and actions they think should be delivered. Merton’s climate change action plan is also informed by Merton’s Climate Change Working Group of volunteers from a variety of disciplines and interests. Merton’s climate change action plan is due to be published in 2020.

The sections above relating to transport, waste, flood risk, provision of energy, green infrastructure and air quality are all relevant to mitigating and adapting to climate change.

• Both authorities agree to follow the approach outlined in the London Plan for zero carbon developments (see DLP policy SI2) and support the principle of the Mayor’s urban greening objectives

4.16 Strategic and local views, and heritage, design and conservation

• Both parties agree to have regard to cross border local views when determining applications, and consult each other on any proposals that could impact on these views.

4.17 Cultural infrastructure

Merton’s adopted Local Plan recognises the importance of arts, culture, leisure and tourism and continues to support the London Plan approach of protecting and enhancing cultural infrastructure. To this end, funding has been allocated from Merton’s Community Infrastructure Levy towards supporting such attractions in Merton, including the Polka Children’s Theatre and Morden’s new Leisure Centre.

5. Governance arrangements

Timetable for agreement, review and update

Local Present plan Plan review Reg 18 date Anticipated Anticipated authority adoption date Reg 19 date submission date Lambeth September October 2017 October 2018 January 2020 April 2020 2015 Merton July 2014 2018 Autumn 2020 Spring 2021 Summer 2021 Table 1: Plan review, update and submission dates

6. Signatories

Both signatories agree that this statement is an accurate representation of areas of agreement and disagreement between the two parties.

Signed: ______Signed: ______

Name: Councillor Matthew Bennett Name: Tara Butler

Position: Cabinet Member for Planning, Position: Deputy FutureMerton manager Investment & New Homes

London Borough of Lambeth London Borough of Merton

Date: Date:

Appendix 1 - Schedule of engagement between the parties

Officer-level meetings to discuss strategic cross border planning matters under the duty to cooperate and to develop this statement of common ground took place: • 21st November 2018 • 9th October 2019

Correspondence regarding Merton’s proposed London Plan housing target: • 26th December 2019 – Merton emailed Lambeth requesting the help of neighbouring and adjoining boroughs, such as Lambeth to meet Merton’s housing target.

Air quality meetings:

Project Partner Schools Air Quality Audit Fund GLA Nurseries Air Quality Audit Fund GLA School Streets Campaign Living Streets (Lead) London Councils work into new AQ London Councils (lead), various other boroughs legislation Healthy Streets Everyday Islington (lead), Cross River Partnership, 15 other boroughs, GLA (funders) – TBC Clean Air Villages Lewisham (lead), Cross River Partnership, Camden, H&F, RBKC, Wandsworth, Defra (funders) Non Road Mobile Machinery register King’s College London, GLA, TFL, Brent, Camden, City of London, Croydon, Hammersmith and Fulham, RBKC, Islington, Lewisham, Tower Hamlets, Wandsworth, and Westminster. Air Quality Monitoring Network King’s College London Breathe London Project GLA (lead), University of Cambridge, King’s College London, AirMonitors, CERC, Environmental Defence Fund, Google Earth Outreach, National Physical Laboratory, C40 Cities. airTEXT service Islington Council (Current lead), University of Cambridge, London boroughs, GLA, Chelmsford, Colchester, Slough, Three Rivers, Thurrock, Environment Agency, Public Health England, CERC, European Commission, DEFRA, PREVAIR and European Space Agency STARS programme TfL Pollution alerts to schools, GP surgeries GLA, King’s College London and care homes Ultra Low Emission Zone GLA Electric Vehicle Car Clubs project GLA (funders), TfL Statutory duties as Air Quality GLA, Defra Management Area Table 2: List of projects both parties are part of taking place in London to monitor and improve air quality.

Air quality organisations:

Organisation Participating authorities Frequency APRIL Network (Air Pollution All boroughs, GLA, TfL, research institutions Quarterly Research in London) Table 3: List of organisations both parties are part of taking place in London to monitor and improve air quality.

Flood officer meetings:

Lambeth’s and Merton’s Flood Officers meet at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

Appendix 2 - Evidence of activities undertaken to address an issue

Local Plan consultations

On 9th October 2017, Lambeth notified Merton that the first stage of public consultation on the Lambeth Local Plan Review (Regulation 18 part 1 - Issues consultation) would run for eight weeks from 9 October to 4 December 2017. Lambeth invited Merton to make representations. No representations were received from Merton.

Schedule of representations received from Merton in the DRLLP 2018 regulation 18 consultation

None.

Schedule of representations received from Lambeth in the Merton New Local Plan Stage 2 consultation on 23rd January 2019

Representation Wording Merton Officer Response

We would welcome reference to the integration of Agreed proposed cycle networks with neighbouring boroughs. Please refer to Lambeth’s proposed Healthy Route Network included within our Draft Transport Strategy - https://www.lambeth.gov.uk/sites/default/files/co- lambeth-transport-strategy-consultation-draft_0.pdf.

We would welcome joint working on boundary issues, such Agreed as managing demand for parking and reducing short car journeys, particularly for education trips. We would also welcome support for investment in and restructuring of the suburban rail network in order to provide a metro style service in south London.

Official

Final SCG LBL-Wandsworth 041219 Statement of Common Ground between London Borough of Lambeth and London Borough of Wandsworth

December 2019

Official

Final SCG LBL-Wandsworth 041219

1. Executive Summary

This Statement of Common Ground has been prepared to demonstrate that Lambeth’s Draft Revised Lambeth Local Plan – Proposed Submission Version January 2020 (DRLLP PSV 2020) is ‘based on effective joint working on cross-boundary strategic matters’, in accordance with the requirements of paragraph 35 of the National Planning Policy Framework (NPPF). It focusses on areas of agreement or disagreement between Lambeth and Wandsworth on strategic cross-boundary matters.

Updates to this document will be agreed as matters progress and agreement is reached on any outstanding issues. It therefore includes details on mechanisms for review and updating.

Both Councils’ AMRs also provide further details of how both plans have been informed by ongoing engagement with key partners, including those that are not party to this Statement of Common Ground.

2. Parties involved

 London Borough of Lambeth  London Borough of Wandsworth

The existing statutory development plan for the Wandsworth consists of the following:  The Core Strategy, adopted March 2016  The Development Management Policies Document (DMPD), adopted March 2016  The Site Specific Allocations Document (SSAD), adopted March 2016  The Policies Map, adopted March 2016  The London Plan (consolidated with alterations since 2011), adopted March 2016  The Local Plan Employment and Industry Document, adopted December 2018 (which replaces employment and industrial land policies, area spatial strategies and site allocations in the existing Local Plan documents).

The main proposed additional / forthcoming plan is the new Local Plan Full Review, which together with the Policies Map, will, upon its adoption, supersede all the Borough’s existing Local Plan documents. Wandsworth is currently working towards the second stage issues consultation of the new Wandsworth Local Plan.

3. Strategic geography

This section sets out the factual position regarding cross-boundary strategic matters.

The London Plan

Final SCG LBL-Wandsworth 041219

Transport for London

The London Enterprise Panel

All London Green Grid

Thames Water

1 Also known as the London Economic Action Partnership Official

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outpace the delivery of any necessary infrastructure provision. It will be essential that all development is aligned with any necessary water and sewerage infrastructure upgrades required to avoid any adverse impacts such as sewer flooding, pollution of land or watercourses and impacts of low/no water pressure. In line with policies in the boroughs’ local plans (DRLLP policy EN4 and Wandsworth Local Plan 2016: Core Strategy Policy IS6 and DMPD Policy DMS3), Thames Water will, where appropriate, request phasing conditions are used to ensure that any new development or phase of development is not occupied until any necessary upgrades have been completed.

Thames Water are helping to deliver the Thames Tideway Tunnel project which will be a new fifteen- mile-long ‘super sewer’ running under the River Thames.

LB Lambeth

Lambeth is an inner London borough with a northern boundary on the River Thames. It is situated mainly between the boroughs of Wandsworth and Southwark, and covers an area of approximately ten and a half square miles. It is surrounded by seven other London Boroughs - LB Southwark; LB Bromley; LB Croydon; LB Merton; LB Wandsworth; City of Westminster and City of London.

LB Wandsworth

Wandsworth is an inner London borough with a northern boundary on the River Thames. It bounds Lambeth to the west and is also bound by LB Merton (to the south) and RB Kingston (to the south west) and Richmond (to the west).

This Statement includes the whole of the LB Lambeth and the whole of LB Wandsworth. The border between the two boroughs covers approximately 10 kilometres. LB Lambeth and LB Wandsworth are not jointly part of any formal sub-regional groupings and therefore both parties have decided to enter into a bilateral statement of common ground (SCG).

An agreement exists that provides one council or the other with the maintenance responsibility for each boundary street.

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Map 1 – Map of parties involved in this Statement

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Map 2 – Border between the two parties and key policy designations

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Neighbourhood planning

There are no designated neighbourhood planning areas in Lambeth spanning the borough boundary or close to the borough boundary with Wandsworth, however the designated Tooting Bec and Broadway Neighbourhood Area lies directly on the boundary with LB Lambeth and includes two Lambeth owned cemeteries (Streatham Cemetery and Lambeth Cemetery).

Employment, retail, leisure and other commercial development

Vauxhall, Nine Elms and Battersea Opportunity Area

Vauxhall, Nine Elms and Battersea Opportunity Area - The Draft London Plan identifies areas that will see the most significant change. These are known as Opportunity Areas (OAs). Many OAs are already seeing significant development, and have the potential to deliver a substantial amount of the new homes and jobs. The Vauxhall, Nine Elms and Battersea Opportunity Area (VNEB OA) crosses the border between the two parties. The Draft London Plan states that the VNEB OA has the potential to deliver greater levels of housing alongside employment than the other CAZ Opportunity Areas. In these areas, offices and other CAZ strategic functions may be given equal weight relative to new residential development. Most of the VNEB OA lies within the borough of Wandsworth, and will be further connected to both Lambeth and Central London by two new underground stations on the Northern Line. The original masterplan set out two new centres to serve this new neighbourhood and beyond: a major new centre at Battersea Power Station and smaller centre in Lambeth at Vauxhall.

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Map 3 – Vauxhall, Nine Elms and Battersea Opportunity Area

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Shared town centres  Lavender Hill/Queenstown Road district centre  Clapham South local centre

Central Activities Zone

Figure 1 – Area of London Plan Central Activities Zone

Areas of both boroughs lie within the Central Activities Zone (CAZ). The CAZ is a London Plan designation. It contains a broad range of functions that have London-wide, national and international significance including Government, business, culture, research and education, retailing, tourism, transport and places of worship. The Draft London Plan seeks to promote and enhance the agglomeration and rich mix of strategic functions and local uses in the CAZ, whilst also supporting and enhancing its significant office functions.

Strategic Areas for Regeneration

As shown on map below there are SARS which adjoin/cross the borough boundary between the two parties:

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Figure 2 - Strategic Areas for Regeneration (based on 20 per cent most deprived lower super output areas in England)

The South London Innovation Partnership

This has been recently formed with Lambeth, Southwark and Lewisham to establish and deliver the South London Innovation Corridor. The programme will support the creative and digital business clusters including Battersea, Nine Elms, Vauxhall and Brixton in Wandsworth and Lambeth.

Transport

Main roads that cross the border between Lambeth and Wandsworth:  A216 (Mitcham Lane) is a London Distributor Road  A214 (Tooting Bec Road) is part of the TfL Road Network  A24 (Balham Hill) is part of the TfL Road Network  A205 (The Avenue) is part of the TfL Road Network  A3 (Long Road) is part of the TfL Road Network  A3036 (Lavender Hill / Wandsworth Road is a London Distributor Road  A3205 (Nine Elms Lane) is part of the TfL Road Network

Overground rail lines that cross the boundary and connect the two parties:  Vauxhall to Queenstown Road (South Western)  Streatham Hill to Balham (Southern)  Streatham Common to Balham (Southern)  Clapham Junction to Wandsworth Road (Overground service)

Mainline stations on lines that cross the boundary and connect the two parties:  Vauxhall (Lambeth)  Queenstown Road (Wandsworth)  Wandsworth Road (Lambeth)  Clapham Junction (Wandsworth)  Streatham Hill (Lambeth)  Streatham Common (Lambeth)  Balham (Wandsworth)

Underground rail lines that cross the borough boundary and connect the two parties:  Northern Line

Underground stations on lines that cross the borough boundary and connect the two parties:

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 Clapham South (Lambeth)  Balham (Wandsworth)

Air quality

Air Quality Focus Areas spanning the borough boundary between the two parties:  Vauxhall Cross

Flood risk

The Thames Barrier is managed and maintained by the Environment Agency and protects 125 square kilometres of central London from flooding caused by tidal surges. This includes the protection of just under 29,000 properties in Lambeth and 28,000 in Wandsworth who would otherwise be at risk of tidal and fluvial flooding. The Thames tidal defences also includes tidal walls and embankments along the banks of the River Thames. Should they fail or become breached the areas most at risk of flooding would be in the north of the boroughs, but this could also impact on the surrounding neighbourhoods. The Environment Agency holds tidal breach modelling. This is also detailed within Lambeth’s SFRA Tidal Breach addendum.

The Environment Agency’s Thames Estuary 2100 Plan (November 2012) sets out the measures that require implementing to maintain adequate flood risk protection from the River Thames by the year 2100. The Plan identifies Lambeth within Action Zone 2 (Central London) and Wandsworth within Action Zone 1 (West London). The Plan outlines a number of recommendations to mitigate flood risk within the Central Zone, including to maintain, enhance or replace, the river defence walls and active structures through central London over the first 25 years of the Plan from 2010 to 2034, and then from 2035 to 2049. Within the West Zone, the Plan outlines several recommendations including to agree a programme for planning and putting in place within 25 years, alternative measures for managing fluvial flood risk in the west London tidal area. The plan advises that by 2065, the existing flood defences of the river wall will need to be raised by 0.5m and a further 0.5m by 2100.

Critical Drainage Areas

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Figure 3 - Map of CDA(s) in Lambeth

Critical Drainage Areas spanning the borough boundary between the two parties:  Group7_025  Group7_027  Group7_028

The provision of energy (including heat)

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Green infrastructure

Metropolitan Open Land (MOL) that crosses the borough boundary between the two parties:  Clapham Common and associated playing pitches is managed by Lambeth only  Tooting Bec and Graveney Commons (and associated playing pitches)

Metropolitan Open Land (MOL) in Lambeth adjoining Wandsworth:  Woodfield Recreation ground is managed (by Enable) solely on behalf of Wandsworth. It is located entirely within LB Lambeth

Sites of Nature Conservation Importance (SINCs) that cross the borough boundary between the two parties:  Clapham Common SINC

Sites of Importance for Nature Conservation (SINCs) in Lambeth adjoining Wandsworth:  Railway Lineside – Tooting Bec to Eardley Road SINC

Other green infrastructure in Wandsworth adjoining, or in very close proximity to Lambeth:  Linear Park in Nine Elms (name not yet confirmed – incremental delivery which has commenced and will meet the local needs of the new Nine Elms residents in Wandsworth)  Heathbrook Park

River Thames

Sites of Nature Conservation Importance (SINCs) that cross the borough boundary between the two parties:  River Thames and Tidal Tributaries Metropolitan SINC

Sites of Metropolitan Nature Importance that cross the borough boundary:  River Thames - the Thames runs along the borough boundary between the two parties.

The Thames runs along the borough boundary between the two parties. There are River services on the Thames for both passengers and freight, and two safeguarded wharves within the Wandsworth VNEB on the Thames.

The Thames Policy Area is a special policy area to be defined by boroughs in which detailed appraisals of the riverside will be required.

Views, heritage, design and conservation

Westminster World Heritage Site

Both Lambeth and Wandsworth have a shared responsibility to protect the setting of the Westminster World Heritage Site. Both boroughs participate in the Westminster World Heritage Site Steering Group whereby they agree to work collaboratively with Westminster to protect the setting of the World Heritage Site.

The Vauxhall, Nine Elms, Battersea Opportunity Area Planning Framework (OAPF) sets out a tall buildings strategy which supports an emerging cluster at Vauxhall. It establishes a series of parameters, which respond to the need to protect the setting of the Palace of Westminster World Heritage Site (WHS) from key river prospects including Waterloo, Hungerford and Westminster Bridges.

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Strategic and local views

Strategic views which cross the borough boundary between the two parties:

Both Wandsworth and Lambeth have a shared responsibility as part of the Westminster World Heritage Site partnership.

Local views from Lambeth into Wandsworth:  County Hall (LV 4): County Hall to Palace of Westminster - Wandsworth is not the focus of the view but the periphery.  Battersea Power Station (LV 9): St George Wharf Pier to Battersea Power Station - The viewer is looking upstream towards Battersea Power Station. The River Thames largely occupies the foreground of the view.  Brixton Historic Towers (LV 18): Brockwell Park to Lambeth Historic Towers - This view from Brockwell Park. Wandsworth forms the distant backdrop.  Brixton Panoramic (LV 19): Battersea Park to The Gherkin and Canary Wharf - The view from Brockwell Park to the city is a broad panorama that ranges westwards across the very northern part of Wandsworth (from Battersea Power Station northward). Wandsworth is not the focus of the view but the periphery with the glimpses of the Power Station being the only feature within Wandsworth of note.  Streatham Common (LV 20): Streatham Common (LV 20): Streatham Common to Rosehill, Pollards Hill, and Morden - Wandsworth is not the focus of the view but the periphery.

Local views from Wandsworth into Lambeth:  View 2 – Downstream from Battersea Bridge – includes view of part of the VNEB including the Vauxhall Tower in Lambeth.  View 3 Downstream from Albert Bridge – includes the tall buildings of the Nine Elms cluster which are emerging to the left of the view.  View 4 Battersea Power Station from Chelsea Bridge – references consented schemes for tall building and the Vauxhall Tower Lambeth in the context of protecting the background of the Battersea Power Station chimney’s silhouette.  View 6 Battersea Power Station from Battersea Park tall buildings of the Nine Elms cluster are emerging to the left of the view – references Vauxhall Tower in Lambeth in the context of the background on the view of Battersea Power Station chimneys.

Conservation areas in Lambeth adjoining Wandsworth:  Clapham (CA01)  Streatham Park and Garrads Road (CA12)  Hyde Farm (CA48)  La Retrait (CA36)  Wandsworth Road (CA59)  Albert Embankment (CA57)  Westow Hill (CA23)  Streatham Common (CA43)  Streatham Lodge (CA62)

Conservation areas in Wandsworth adjoining Lambeth:  Clapham Common (CA1)

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 Dinsmore Road (CA32)  Old Devonshire Road (CA44)  Park Town Estate (CA18)  Garrads Road (CA43)

Historic parks and gardens in Lambeth adjoining Wandsworth: None.

Historic parks and gardens in Wandsworth adjoining Lambeth:  Clapham Common (Locally listed)  Tooting Bec Common (Locally listed)

Archaeological priority areas in Lambeth adjoining Wandsworth:  North Lambeth APA2  Roman Road APA3  Streatham APA15

Archaeological priority areas in Wandsworth adjoining Lambeth:  Battersea Channel APA  Clapham Common APA  Stane Street APA  Tooting Common APA

Lambeth cemeteries in Wandsworth:  Streatham Cemetery  Lambeth Cemetery  Lambeth Crematorium

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4. Strategic matters

This section sets out where agreement has or has not been reached on cross-border strategic matters.

a. Neighbourhood Planning

There are no designated neighbourhood planning areas spanning the borough boundary between the two parties.

 Wandsworth agrees to keep Lambeth informed of any neighbourhood plans adjoining the borough boundary between the two parties, particularly those covering Tooting Bec where there are two Lambeth cemeteries b. Housing

4.2a. Overall housing need

Lambeth’s position in its Draft Revised Lambeth Local Plan is that it is able to meet its own Draft London Plan housing target within its administrative boundary.

Wandsworth:

Whilst it is considered that Wandsworth will be able to meet its proposed housing targets, Wandsworth maintains its position of the London Plan examination: Wandsworth objects to the target but signals its intent on working towards meeting the target within its own borders.

4.2b. Affordable housing

The London Plan and borough level Local Plans together set out the levels and types of affordable housing provision required.

4.2c. Gypsies and Travellers

Wandsworth:

Since 2009 there has been a significant decrease in both resident turnover and demand for traveller pitch licences in Wandsworth Borough.

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As of April 2019, due to the low turnover rate and relatively settled status of the occupying households, the three vacant pitches, and a current lack of a waiting list for the site, there is no evidenced requirement or need for additional pitches on the existing (Trewint Street) site or elsewhere in the wider Borough.

There is also no evidence that the Borough needs to consider temporary site needs for show people, with no approaches having been made in this respect, according to records, over the intervening period since the last analysis was undertaken.

 Going forward, both boroughs acknowledge the London Plan Inspector’s report which recommended a strategic evidence base: ‘the mayor should commit to leading a London- wide accommodation needs assessment for gypsies and travellers as soon as possible’ to inform new London Plan policy.  Wandsworth agrees that Lambeth can meet its identified need for gypsy and traveller pitches over the DRLLP PSV plan period within the confines of its own administrative boundary.

4.3 Employment, retail, leisure and other commercial development

The continued commercial success of the Central Activities Zone, which covers the northern extent of both Lambeth and Wandsworth is vital to London’s world city status. As supported by the Mayor of London, both parties have introduced Article 4 Directions within their portion of the CAZ to protect central London’s strategically important office supply against change of use to residential use under permitted development rights.

 Both parties agree to work collaboratively to deliver the Draft London Plan approach to the CAZ and consult each other on major applications with potential strategic cross border impacts

Visitor accommodation

DRLLP policy ED14 proposes to introduce a new policy to manage any further visitor accommodation in Vauxhall within the boundary of the Central Activities Zone. DRLLP H3 proposes to manage change of use of permanent residential accommodation to short-term holiday lets.

 Both parties agree to work collaboratively to manage the growth of visitor accommodation around Vauxhall to ensure the most effective mix of land uses in that part of the CAZ.

Vauxhall, Nine Elms Battersea Opportunity Area

The VNEB Opportunity Area is identified in the London Plan as overseen by the Nine Elms Vauxhall Strategy Board, a partnership of key stakeholders in the area including landowners, TfL and the GLA,

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co-charged by the Leaders of both LB Lambeth Council and LB Wandsworth Council. The Board oversees the development of the OA and meets twice a year to review overall progress and manage strategic risks.

 Both parties agree to work collaboratively through the VNEB Strategy Board to deliver the housing and employment targets and any other strategic matters affecting VNEB.  Both parties agree to work collaboratively to deliver the infrastructure identified via the Nine Elms DIRR study, where it is identified as having cross-borough implications.

Shared town centres

The DRLLP proposes to update policy to restrict the number and concentrations of betting shops and payday loan shops in specific town centres. Wandsworth has highlighted that this policy may give rise to likely impacts through displacement of demand.

 Both parties agree to work collaboratively to ensure that their respective policy approaches to shared town centres in their respective local plans are aligned.  Both parties agree to work collaboratively and share monitoring information and analysis of the health of town centres – particularly where analysis suggests emerging issues that may require joint action.

Strategic Areas for Regeneration

 Both parties agree to work collaboratively to ensure that their respective policy approaches to Strategic Areas for Regeneration in their respective local plans are aligned.  Both parties agree that joint work on employment benefits from the VNEB area via planning obligations (S106 agreements) have secured shared areas of benefit.

4.4 Health

Health infrastructure planning in both Lambeth and Wandsworth reflect the priorities of the respective Clinical Commissioning Groups Group - this has regard to and acknowledges potential movement of patients across the border between the two boroughs.

 Both parties acknowledge that there is likely to be cross border movements of patients between each borough but agree there are no known planning reasons why these movements cannot continue.  Both parties agree to work collaboratively to meet the needs for strategic cross border health facilities including that in the Vauxhall Nine Elms Battersea OA  Both parties agree to ensure that their infrastructure delivery plan acknowledge cross- boundary issues and take into account wider healthcare needs and service catchments.

It is important that health and wellbeing impacts of major developments on the border of each borough is considered so that overall health and wellbeing impacts on existing/new residents can be considered.

 Both parties agree to work collaboratively in terms of sharing of information about health impacts

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4.5 Education

 Both parties acknowledge that there is likely to be cross border movements of school pupils between each borough but agree there are no known planning reasons why these movements cannot continue.

4.6 Telecommunciations

 Both parties agree to work collaboratively on the delivery of digital connectivity infrastructure where there are cross-border implications

4.7 Security

 Both parties agree to work collaboratively to ensure that counter terrorism measures such as hostile vehicle mitigation are in place as required.

4.8 Transport

 Both parties agree to work collaboratively to deliver the Mayor’s Transport Strategy outcomes with regards to walking and cycling  Both parties agree to consult each other about proposed changes to parking controls (for example, proposed new CPZs) where these may have a cross-border impact  Both parties agree to ensure a co-ordinated approach to bus network and service improvements.  Both parties agree to promote and support the development and implementation of improvements to local rail services  Both parties agree to work collaboratively to support strategically important transport infrastructure  Both parties agree to consult each other about proposals for Clapham Common and the wider area including any transport impacts  Wandsworth agrees that, in order to mitigate impact of traffic associated with the redevelopment Pensbury Place waste transfer station, it will ensure cross-border consultation on all proposals to intensify the waste uses particularly in regard to transport impacts.  Both parties agree to work collaboratively to improve cycle links through Tooting Bec Common

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 Both parties agree they recognise and support the strategic need for a pedestrian and cycle crossing of the River Thames between Pimlico and Vauxhall Nine Elms  Both parties agree to take a co-ordinated approach to construction, logistics and road safety in the VNEB OA.  Both parties agree to work collaboratively to deliver the Nine Elms Cycle Strategy through the VNEB board.  There is a point of disagreement concerning TfL’s plan to replace the Vauxhall Gyratory. Wandsworth Council’s position is qualified as: ‘The proposals for the Vauxhall Gyratory support the ambitions of the Nine Elms Vauxhall Partnership for the transformation of the VNEB Opportunity Area into a new central London district. However, it is also important that the scheme does not have an adverse impact on traffic movement in Wandsworth borough.’ Lambeth Council’s position is that the Gyratory proposal has already been subject to extensive public consultation and traffic modelling by TfL, who are satisfied that traffic impacts are within acceptable levels, and it is therefore understood that Tfl will implement the gyratory in the form proposed. Due to these factors and the benefits arising from the proposal, Lambeth are supportive of the scheme as currently proposed. Both parties agree to work collaboratively to deliver the removal of the Vauxhall Gyratory and mitigate local impacts should they arise.

4.9 Air quality

Wandsworth has five Air Quality Focus Areas entirely within the borough boundary: Clapham Junction/Falcon Road/Battersea Rise/Lavender Hill; Putney High Street/Putney Bridge Road/ Lower Richmond Road; Wandsworth Gyratory - Wandsworth High Street/Armoury Way; York Road (A3205) from Wandsworth Bridge to Latchmere Road. There is an Air Quality Action Plan place (2016-2021); a Clapham Junction Air Quality Action Plan and Tooting High Street Air Quality Action Plan (both 2018). This seeks to protect health, ecosystems and buildings, and to reduce pollution to below national air quality objectives. It contains measures to improve air quality across the borough helping to reduce the key pollutants – Nitrogen Dioxide (NO2) and Particulate Matter (PM10).

Wandsworth funds a dedicated Nine Elms Air Quality Officer to work in the Wandsworth section of the OA, who works closely with counterpart in Lambeth to manage the impact on air quality across the OA in Wandsworth.

A separate but related consideration relate to air quality management during the construction phase for Nine Elms to ensure adequately mitigated AQ impacts. Lambeth and Wandsworth work together on the co-ordination of construction logistics in the VNEB area.

 Lambeth and Wandsworth agree to cooperate in the implementation of each borough’s respective strategies and action plans.  Both parties agree to continue their involvement in a number of cross-organisational projects and organisations to tackle poor air quality across London (see appendix 1).

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4.10 Waste management

Both parties are part of the Cross London sub-regional grouping of boroughs for waste planning matters.

LB Wandsworth receives strategic amounts of waste exports from Lambeth as set out in the Lambeth Waste Evidence Base 2019. In addition to Lambeth’s household waste, Lambeth also exports some CD&E waste to Wandsworth. No significant waste exports from Wandsworth are received in Lambeth.

 Both parties agree there are no known planning reasons why exports of similar amounts of waste exports cannot continue.  Both parties agree to plan separately to meet their respective Local Plan waste apportionments in accordance with the approach described above

4.11 Water supply, wastewater

 Each party agrees to support this approach to planning for water and waste water infrastructure.

4.12 Flood risk

Each council is statutorily required to produce a Local Flood Risk Management Strategy (LFRMS) for their respective borough which details how they assess and will manage Local Flood Risk within their administrative boundary. LFRMSs require cross boundary partnership working to achieve the ultimate outcome of reducing Local Flood Risk. As part of the partnership working, Lambeth’s and Wandsworth’s flood Risk Officers meet at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

 Both parties agree to have regard to each other’s flood risk policies and evidence

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Wandsworth and Lambeth are hydraulically connected through shared watersheds which impact on each borough’s risk of flooding from surface water. The risk of flooding from surface water is assessed in respective Surface Water Management Plans, where areas at significant risk of flooding are identified and are labelled as Critical Drainage Areas (CDAs).

 Both parties agree to work collaboratively to reduce the risk of flooding within Critical Drainage Areas.

4.13 Provision of energy (including heat)

Lambeth proposes to follow the Draft London Plan policy approach to the provision of energy in relation to new development (see Draft Revised Lambeth Local Plan policy EN3).

There is an Energy Masterplan for Vauxhall Nine Elms Battersea Opportunity Area (2012).

 Both parties agree to work collaboratively where opportunities arise to connect development to heat networks that cross, or are in close proximity to, the borough boundary between the two parties.  Both parties agree to work collaboratively and through the VNEB Board to ensure the continuing development and delivery of a coherent, low carbon energy supply system for the area.  Both parties agree to take a co-ordinated approach to utilities co-ordination (in particular District Heat Networks)

4.14 Green infrastructure (i.e SINCs and MOL)

 Each party acknowledges that Clapham Common (MOL) and Woodfield Recreation Ground and School Playing Field (MOL) are shared resources in terms of meeting green infrastructure needs, given their proximity to each borough’s residents.  Both parties agree to consult and to cooperate in respect of the management decisions on these spaces.  Both parties agree to consult each other on any proposals that could impact on open spaces, outdoor recreation and other green infrastructure, including SINCs and/or MOL, within the the neighbouring borough.  Both parties agree to have regard to each other’s SINC and MOL designations, on or in close proximity to the borough boundary, and their respective Local Plan policies when determining applications.

4.15 Planning measures to address climate change mitigation and adaptation

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The DRLLP PSV 2020 follows the approach outlined in the Draft London Plan for zero carbon developments (see DLP policy SI2) and aligns with the Mayor’s urban greening objectives (including adopting an urban greening factor – see DLP policy G5).

Wandsworth Council is formalising this commitment to environmental and sustainability issues via an ambitious ten year strategy which will see Wandsworth become the greenest council in inner London and be carbon neutral by 2030 and zero carbon by 2050.

The Wandsworth Environmental and Sustainability Strategy (WESS) sets out the Council’s ambitions for the next ten years in relation to urban greening, carbon reduction, air quality and waste and recycling. The Strategy will be supported by an annual action plan that will be driven forward by a senior leadership Climate Change Group (Committee paper 19-197).

The sections above relating to transport, waste, flood risk, provision of energy, green infrastructure and air quality are all relevant to mitigating and adapting to climate change.

 Lambeth and Wandsworth agree to cooperate in the implementation of each borough’s respective strategies and action plans.

4.16 River Thames

4.16.1 Policy approach

The River Thames provides a major asset that Lambeth and Wandsworth border. Both authorities recognise the importance of this setting and have complementary policy approaches to shape future development within the area designated through the London Plan as the Thames Policy Area.

 Both parties agree to consult each other on any proposals that have an impact on the neighbouring borough either through views or infrastructure, on/in the River Thames and have regard to each other’s respective Local Plan policies.  Both parties agree to work collaboratively to implement policies affecting the London Plan Thames Policy Area

4.16.2 River services

There are river services on the Thames for both passengers and freight, and two safeguarded wharves which handle waste and aggregates within the Wandsworth VNEB OA on the Thames.

 Both parties agree to work collaboratively to improve both passenger transport on the River and use of the River for freight movements.  Both parties support river transport and agree there are no known planning reasons why these river services cannot continue.

4.16.3 River Thames Sites of Importance for Nature Conservation

 Both parties agree to consult each other on any proposals that could impact on the River Thames and Tidal Tributaries Metropolitan SINC.

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 Both parties agree to have regard to the River Thames and Tidal Tributaries Metropolitan SINC designation and each other’s respective Local Plan policies when determining applications that could impact on this designation.

4.17 Strategic and local views, and heritage, design and conservation

Within Lambeth, areas appropriate for tall buildings have been identified in the draft revised Lambeth Local Plan Annex 11, supported by policy Q26. Protected Views are covered by DRLLP policy Q25.

Within Wandsworth, Local Plan policy DMS4 sets out the approach to assessing proposals for taller buildings, and a Local Views SPD was adopted in 2014.

 Both parties agree to have regard to cross border strategic and local views when determining applications, and consult each other on any proposals that could impact on these views.  Both parties agree to have regard to the setting of heritage, design and conservation designations adjoining the borough boundary in the neighbouring borough when determining applications, and consult each other on any proposals that could impact on these designations.  Both parties agree to work collaboratively on the Westminster World Heritage Site Management Plan with the stakeholders, and to uphold the VNEB Tall Buildings Strategy.

4.18 Cultural infrastructure

Wandsworth has developed a Nine Elms Battersea Cultural borough-wide Culture Strategy for the sections of the VNEB OA within the Wandsworth border. This builds on the shared vision of all the VNEB Partners, and where appropriate involves Lambeth in the delivery of key joint events and an update to this Strategy has commenced. The Wandsworth Cultural Strategy seeks to achieve the creation of three cultural quarters – a design quarter in Battersea, a food and horticultural quarter around CGMA and a galleries and visual arts quarter. The latter two overlap with Lambeth’s Gallery Quarter around Albert Embankment and the borough boundary at Wandsworth Road / Nine Elms Station. The Battersea Design Quarter is being brought forward by Wandsworth as one of the projects within the South London Innovation Corridor project which is a partnership between Lambeth, Wandsworth, Southwark and Lewisham. 5. Governance arrangements

This statement has been informed by on-going engagement between the two parties - as evidenced by the main body of the statement explaining joint working and the schedule of engagement between the parties in Appendix 1.

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Timetable for agreement, review and update

Local Present plan adoption Proposed Target Anticipated Anticipated authority plan Reg 18 Reg 19 submission review date date date date Lambeth September 2015 October October January April 2020 2017 2018 2020 Wandsworth Core Strategy, Winter Summer Spring 2021 Summer Development Management 2018/19 2020 2021 Policies and Site Specific Allocations: March 2016; Local Plan Employment and Industry: December 2018 Table 1: Plan review, update and submission dates

Ongoing collaboration between the parties will continue through regular meetings and through attendance at group meetings where cross boundary issues are discussed.

6. Signatories

Both signatories agree that this statement is an accurate representation of areas of agreement and disagreement between the two parties.

It is agreed that these discussions will inform both the Lambeth Local Plan 2020 and Wandsworth Local Plan 2022 and both authorities will continue to work collaboratively in order to meet the duty to cooperate.

Signed: ______Signed: ______

Name: Councillor Matthew Bennett Name: Councillor Paul Ellis

Position: Cabinet Member for Planning, Position: Cabinet Member for Strategic Investment & New Homes Planning and Transportation

London Borough of Lambeth London Borough of Wandsworth

Date: Date:

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Appendix 1 - Schedule of engagement between the parties

Officer-level meetings to discuss strategic cross border planning matters under the duty to cooperate and to develop this statement of common ground took place:  17th November 2015  3rd May 2017  15th March 2018  21st November 2018  30th October 2019

Air quality meetings:

Project Partner Schools Air Quality Audit Fund GLA Nurseries Air Quality Audit Fund GLA School Streets Campaign Living Streets (Lead) London Councils work into new AQ London Councils (lead), various other boroughs legislation Healthy Streets Everyday Islington (lead), Cross River Partnership, 15 other boroughs, GLA (funders) – TBC Clean Air Villages Lewisham (lead), Cross River Partnership, Camden, H&F, RBKC, Wandsworth, Defra (funders) Non Road Mobile Machinery register King’s College London, GLA, TFL, Brent, Camden, City of London, Croydon, Hammersmith and Fulham, RBKC, Islington, Lewisham, Tower Hamlets, and Westminster. Air Quality Monitoring Network King’s College London Breathe London Project GLA (lead), University of Cambridge, King’s College London, AirMonitors, CERC, Environmental Defence Fund, Google Earth Outreach, National Physical Laboratory, C40 Cities. airTEXT service Islington Council (Current lead), University of Cambridge, London boroughs, GLA, Chelmsford, Colchester, Slough, Three Rivers, Thurrock, Environment Agency, Public Health England, CERC, European Commission, DEFRA, PREVAIR and European Space Agency STARS programme TfL Pollution alerts to schools, GP surgeries GLA, King’s College London and care homes Ultra Low Emission Zone GLA Electric Vehicle Car Clubs project GLA (funders), TfL Statutory duties as Air Quality GLA, Defra Management Area Table 2: List of projects both parties are part of taking place in London to monitor and improve air quality.

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Air quality organisations:

Flood officer meetings:

Lambeth’s and Wandsworth’s Flood Officers meet at quarterly Flood Group meetings, which form part of the reporting mechanism for the Thames Regional Flood and Coastal Committee. These meetings assist in collaborative working and also provide a platform for sharing knowledge and common issues in flood risk management.

All London Borough planning officer meetings (Association of London Borough Planning Officers):  13th Jan 2016  21st June 2016  27th July 2016  13th October 2016  9th Feb 2017  14th March 2017  16th May 2017  16th February 2018  1st May 2018  3rd July 2018  18th September 2018  13th November 2018  25th January 2019  07th February 2019  12th March 2019  04th April 2019 (sub group meeting)  07th May 2019  05th June 2019 (sub group meeting)  16th July 2019  25th July 2019  17th September 2019  19th September 2019 (sub group meeting)  12th November 2019

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Appendix 2 - Evidence of activities undertaken to address an issue

Local Plan consultations:

On 9th October 2017, Lambeth notified Wandsworth that the first stage of public consultation on the Lambeth Local Plan Review (Regulation 18 part 1 - Issues consultation) would run for eight weeks from 9 October to 4 December 2017. Lambeth invited Wandsworth to make representations.

Lambeth Issues (regulation 18 part 1) consultation representations

On 20th December 2017, Wandsworth submitted comments to Lambeth as part of the Issues consultation. Of all of the questions answered, Wandsworth only disagreed with one which regarded the provision of short term lets, such as Airbnb, and their ability to meet demand for visitor accommodation. Wandsworth stated that the growing gap between demand and supply does not justify losing permanent housing. They supported use of student halls out of term time. A full breakdown of the comments provided by Wandsworth is viewable in the Issues Consultation Report October 2018.

Lambeth DRLLP (regulation 18 part 2) consultation representations

On the 17th December 2017, LB Wandsworth provided comments on the Draft Revised Lambeth Local Plan 2018. The table below outlines the points made by Wandsworth and the proposed Lambeth response.

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Table 4 - DRLLP consultation 2018: Wandsworth representations and proposed Lambeth response

Representation Wording Plan Section Policy/Sites/ Officer Response Proposed Change General/ Policies in DRLLP PSV Map/Issue Thank you for providing the opportunity to comment on the above General Duty to Cooperate Noted. Specific comments No change. document. Following on from our recent Duty to Cooperate meeting I raised on the draft Local Plan can confirm that we are broadly supportive of the policy approach have been addressed and that each Council has committed to preparing bilateral individually per chapter and statements of common ground in due course. Lambeth’s updated policy of the document. evidence base is noted, and as many policy areas share common geographies the methodology and content may be helpful informing Wandsworth’s own evidence base.

Officers have a number of comments on some of the consultation topic areas as follows:

Housing, including students and older people, gypsies and travellers: Section 05 General Noted. No change. From a housing perspective and in respect of those matters which may impact housing in Wandsworth the Council have no comments to make.

The policy position on student housing and older peoples housing is Section 05 H07 Noted No change. noted, and is broadly in line with the Council’s preferred approach.

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The Council is intending to update its evidence on gypsy and traveller Section 05 H10 Noted No change accommodation including if people identifying as gypsies and travellers occupying bricks and mortar accommodation indicate they wish to have a pitch. We note Lambeth’s updated evidence on gypsy and traveller needs and we will take this on board in establishing evidence for the Wandsworth Local Plan review. The Council does not accept the London Plan’s proposed definition of gypsies and travellers, and notes that the evidence (Fordhams 2008) is out of date, and has made a representation to this effect. Officers can discuss methodology and evidence on gypsy and traveller need in Wandsworth with you as required through the Duty to Cooperate.

Economy (CAZ, town centres, offices, affordable workspace): Town Section 06 ED07 Comment noted. Matters No change. Centres relating to cross border town General comments: Wandsworth effectively shares centres at centres will be addressed in the Vauxhall, Clapham South and Lavender Hill/Queenstown Road, as well Statement of Common Ground as many non-designated parades running along main roads on either between the two boroughs. side of the borough boundary. As such officers look forward to working through the details of policy development relating to town centre uses and the evening economy to ensure that the policy approach is supportive and mutually compatible.

The Council looks forward to working together on future policy development.

The Council is supportive of the approach to secure Affordable Section 06 ED02 Support noted. No change. Workspace, especially through Affordable rent which is an approach Wandsworth Council has recently adopted.

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A2 uses/betting shops/payday loans: Introduce new policy to Section 06 ED10 Support noted. Where there No change prevent concentrations and clustering of betting shops and payday are likely to be cross-border loan shops in town centres impacts, this issue can be The Council is in overall agreement with the identification of issues, addressed in the Statement of particularly the negative effects on vitality and viability of identified Common Ground between the town and local centres and the smaller parades. Your updated two boroughs. evidence on these uses and how these uses can adversely affect public health is noted.

The policies do acknowledge impact on health and well-being and amenity of ‘neighbouring areas’ and officers would like to work jointly with you on this matter so that both the updated Lambeth and Wandsworth Local Plans once adopted, will support each other in achieving a shared, desired outcome. The Sustainability Appraisal does not appear to consider the likely Sustainability Noted. This will be addressed No change. impacts of policies seeking to control these uses on adjoining Appraisal in the next iteration of the SA. boroughs such as through displacement of demand. Hotel and visitor accommodation: the general approach is supported. Section 06 ED14 Support noted. Where there No change. Lambeth’s preferred policy position controlling short stay are likely to be cross-border accommodation is noted, and this, and the evidence base will be impacts, this issue can be taken into account and discussed further as necessary and through addressed in the Statement of the Duty to Cooperate meetings regarding Wandsworth updated Common Ground between the policy options. two boroughs. Air quality: The Council is supportive of the approach set out in the Section 09 Air Quality Noted. No change Draft London Plan and that Lambeth propose to be in line with these policies. Waste: The overall position on managing the Lambeth waste Section 09 EN07 Noted. The issue of waste will apportionment figure is supported and officers have sent comments be addressed in the Statement on the draft MOU by separate email exchange. of Common Ground between the two boroughs.

Schedule of representations received from Lambeth in the Regulation 18 Wandsworth Local Plan 2018 Issues Document

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On the 5th February 2019, LB Lambeth provided comments on the Regulation 18 Wandsworth Local Plan 2018 Issues document. The table below outlines the points made by Lambeth.

Representation Wording Wandsworth Response (In progress, yet to be published) Question 37 - Is the approach to out-of-centre development, including seeking mixed uses on redevelopment sites such as the riverside and Focal Points of Activity, still appropriate in light of new national policy which supports a ‘town centre first approach’ and identifies a need to ensure resilience?

Wandsworth should ensure that town centre uses, even at small scale, outside of the defined town centre hierarchy do not detrimentally impact on retail provision in neighbouring boroughs’ designated town centres. Policies should ensure town centre uses are only considered in out of centre locations if a sequential test, and if necessary an impact assessment, have been undertaken in line with national policy, taking account of town centres across borough boundaries. Lambeth would like to be consulted on any such schemes in Wandsworth that are in close proximity to the borough boundary.

Question 55 - Do you support a shift away from car use to people using public transport, walking or cycling?

Lambeth’s Draft Transport Strategy emphasises the need to reduce traffic levels in the borough, both in terms of private motor vehicle trips made by our residents and in terms of trips to and through Lambeth that originate elsewhere. We therefore would encourage Wandsworth to work with other boroughs in the sub-region to develop a co-ordinated approach to traffic reduction and to the promotion of improvements to public transport, including the South London Metro concept, as well as in the effective integration of a new generation of cycle routes across borough boundaries. Question 84 - Are there any sites or locations that should be considered as a site allocation as part of the Local Plan review for waste management?

The NPPW and Draft London Plan direct new waste facilities to industrial land. Question 85 - Should the Council continue to protect its existing safeguarded waste management sites and if not/so why?

Both the current London Plan and the Draft London Plan require boroughs to safeguard waste sites for waste uses. A waste site can only be redeveloped for other uses if equivalent compensatory capacity is re-provided.