8 Albert Embankment & Land to Rear Bounded by Lambeth High Street

ADDRESS: 8 Albert Embankment & land to rear bounded by Lambeth High Street, Whitgift Street, The Railway Viaduct, Southbank House together with land at the corner of Black Prince Road and Newport Street, London, SE1

Application Numbers: 19/01304/FUL (Application A) and Case Officer: Michael Cassidy 19/01305/LB (Application B)

Ward: Princes Date Received: 29/03/2019

Proposal: Phased mixed use development including up to 443 residential units and comprising: part redevelopment and restoration, conversion and extension of former Fire Brigade Headquarters building and demolition of the existing extension and re-provision of obelisk to provide a new fire station (Sui Generis), a new London Fire Brigade museum (Class D1), residential units (Class C3), a ten storey hotel (Class C1) with up to 200 bedrooms and a flexible retail/lobby space (Classes A1/A2/A3/A4/C1), and a rooftop restaurant with ancillary bar (Class A3); demolition and redevelopment of the central workshop building to provide buildings of up to twenty-six storeys plus basements, comprising business floorspace (Use Class B1), a gym (Class D2), retail units (Classes A1/A2/A3/A4) and residential units (Class C3); development of land to the rear to provide a eleven storey building plus basement, comprising a flexible commercial unit (Classes A1/A2/A3/A4/D1/D2/ B1) and residential units (Class C3); all together with associated areas of new public realm, hard and soft landscaping, basement and surface parking, servicing, means of access and plant and equipment.

This application is a DEPARTURE APPLICATION: The proposed development is a departure from site allocation "Site 10 - 8 Albert Embankment and land to the rear bounded by Lambeth High Street, Whitgift Street, the railway viaduct and Southbank House SE1" of the Lambeth Local Plan (2015).

This application is accompanied by an Environmental Statement (ES) which is available for inspection with the planning application documents. Hard copies may be obtained for a fee from Lichfield, 14 Regent's Wharf, All Saints Street, London, N1 9RL. | 8 Albert Embankment And Land To Rear Bounded By Lambeth High St, Whitgift St, The Railway Viaduct, Southbank Hse Together With Land Corner Of Black Prince Rd And Newport St London.

Applicant: U & I (8AE) Limited & The London Fire Commissioner Agent: Lichfields

Drawing Numbers: Refer to Appendix 1

Supporting Documents: Refer to Appendix 1 RECOMMENDATIONS:

Application A - 19/01304/FUL

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

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

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

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

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

Application B - 19/01305/LB

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

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

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

SITE DESIGNATIONS Designation: Description: Listed Building Yes - Grade II Listed 8 Albert Embankment & its Drill Tower on West site Conservation Area (CA) Albert Embankment (CA57) Protected views/vistas 2B.1- Parliament Hill: East of the Summit – At the Prominent Oak Tree 4A.2 Primrose Hill: The Summit 17A.2 - Hungerford Bridge Upstream 18A.2 – Westminster Bridge Local Views Brockwell Park to the city (Brixton panoramic) Key Industrial & Business Area Yes – Central & East Sites fall within the South Bank House & (KIBA) Newport Street KIBA Archaeological Priority Areas Yes – West & Central Sites within North Lambeth Archaeological Priority Area Air Quality Management Area Air Quality Management Area Flood Zone Flood Zone 3a (high risk) Opportunity Area Vauxhall, Nine Elms, Battersea (VNEB) Opportunity Area Thames Policy Area Yes - West & Central Sites Central Activities Zone Yes - West & Central Sites Site Allocation Site 10 - 8 Albert Embankment and land to the rear bounded by Lambeth High Street, Whitgift Street, the railway viaduct and Southbank House SE1

LAND USE DETAILS Site area (ha): 1.06 Hectares

NON-RESIDENTIAL DETAILS Use Class Use Description Floorspace (m2) (Gross Internal Area) Existing Sui Generis Fire Station & associated 18,000sq.m buildings Proposed Sui Generis Fire Station 2,203sqm D1 Museum 1,434sqm A3 Restaurant 865sqm C1 Hotel 6,270sqm B1(a) Corporate Office 9,123sqm B1(a)/B1(b)/B1(c) Medium Workspace 1,348sqm B1(a)/B1(b)/B1(c) Small Workspace 153sqm B1(a)/B1(b)/B1(c) Micro Workspace 142sqm A1-A4/D1/D2/ Retail (incl. flexible unit on ‘East’ 628sqm B1(a)/B1(b)/B1(c) Site D2 Gym 2,849sqm C3 Residential (Market) 23,353sqm C3 Residential (Affordable) 14,231sqm N/A Parking/Plant/Refuse 8,094sqm Total 70,692sqm

RESIDENTIAL DETAILS Residential No. of bedrooms per unit Total Type Habitable Rooms Studio 1 2 3 4 Total Existing Affordable 0 0 0 0 0 0 0 Private/Market 0 0 0 0 0 0 0 Total 0 0 0 0 0 0 0

Proposed Affordable 0 30 52 0 0 82 216 On-Site Rented Social Rented 0 46 0 8 0 8 42 Intermediate 21 46 15 0 0 82 158 (Shared Ownership) Private/Market 26 152 82 11 0 271 620 Total 47 228 149 19 0 443 1,036

Details/Trigger Review Pre implementation within 24 months if not implemented & Mechanisms Late Stage Review triggered at 75% of sale of market units

ACCESSIBILITY Number of C3 Units M4(2) Units 399 M4(3) Units 44

PARKING DETAILS Car Parking Spaces Car Parking Spaces % of Bike Motor- (General) (Disabled) EVCP Spaces cycle Spaces Resi Sui Generis Visitor Resi Commercial/ Visitor Sui Generis Existing 0 89 0 0 0 0 0 0 0 Proposed 0 10 0 44 6 0 20% 1071 0

LEGAL SERVICES CLEARANCE AUDIT TRAIL Consultation Name/Position Lambeth Date Sent Date Report Comments in department Received Cleared para: Brian Hurwitz Legal Services 13/11/2019 - 13/11/2019- 21/11/2019 Various Partner, Sharpe 21/11/2019 21/11/2019 Pritchard EXECUTIVE SUMMARY

Once home to London Fire Brigade’s Headquarters and a hub for innovation, the application site is now largely underutilised, making little contribution towards place-making and (in the case of the CMC Building) detracting from the significance of heritage assets.

The site is allocated for development in the Lambeth Local Plan (Policy PN2 Site 10), which seeks retention/re-provision of the existing fire station alongside a mix of employment and residential uses. Whilst part of the site (the Central and East Sites) falls within a locally-defined Key Industrial and Business Area (KIBA), the allocation does not preclude residential development and notes that residential uses within the KIBA boundary may exceptionally be possible “if it can be demonstrated that this is necessary to achieve an acceptable scheme in all other respects”. The proposals have been subject to rigorous testing in order to provide varied employment opportunities, maximise the benefits of the scheme and demonstrate exceptional circumstances justifying residential within the KIBA boundary. This testing demonstrates the exceptional circumstances (as referred to in Policy PN2 Site 10), concluding that a mixed-use approach blending residential and employment on all three sites delivers more varied job opportunities, more housing, an enhanced public realm and significant heritage benefits when compared with an alternative scheme for employment only within the KIBA.

The proposed development will bring forward the regeneration of the site and is aligned with the desire for growth within the Vauxhall area. Comprising a new fire station alongside a mix of residential, employment (including low cost and affordable space), retail and other uses, including a LFB Museum and gallery, the proposal will provide a substantial uplift in jobs (approximately 1,264 in total) with a wide-range of flexible employment spaces creating diverse employment opportunities for established business, small to medium sized enterprises and start-ups. It further delivers a significant amount of new public realm (20% of the overall site), including the creation of new pedestrian routes through the site, improving connectivity within the immediate area.

The proposal would also provide 443 residential units of which 172 would be affordable units (which is 39% of the total number of units or 40% by habitable room) which will contribute to meeting the housing needs of the Borough. The affordable units would be split 62% affordable/social rent and 38% shared ownership based on habitable rooms or 52:48 based on units. Whilst the proposal does not provide a fully policy compliant mix of tenure, it incorporates a good range of dwelling types and tenures and an appropriate mix of housing. The market and shared ownership units provide mainly 1 and 2 bedroom units, which is supported in this central location, and allows greater affordability. The emphasis on larger 2 bedroom (four person) and 3 bedroom units for the affordable housing overall (this accounts for 44% of the total) is particularly positive and meets local housing needs particularly based on the 2017 Strategic Housing Market Assessment and the draft review Local Plan policy on dwelling mix. The proposal has been viability tested and the 40% offer made is considered the maximum reasonable proportion of affordable housing that the scheme can currently provide.

The application has been advertised as a departure from policy on the basis that it is not in accordance with the site allocation 10 in the development plan. Lambeth Local Plan (Policy PN2 Site 10 -8 Albert Embankment) states that the Council will support development on the site subject to a number of design principles and key development considerations, in particular (iv) ‘relates in height and bulk to the adjacent townscape taking into account the height, massing and scale of neighbouring buildings and the historic built form of the area; the heritage sensitivity of the site makes it inappropriate for tall building development’.

The height and massing of the development has been assessed in relation to its impact from a wide range of viewpoints and has been found to be satisfactory, including in relation to its impact on heritage assets. An assessment of the current application has identified less than substantial harm caused. This view is supported by both the GLA and Historic England who have also come to the same conclusion. In line with paragraph 196 of the NPPF, the resulting harm would be outweighed by the many public benefits of the proposal which include:

• Heritage – the restoration of two underused listed buildings, including partial re-use for original purposes, preserving the significance of the buildings in terms of their historic purposes and association and securing the buildings’ long-term future; • New Fire Station and Emergency Base – the creation of a new modern ‘fit for purpose’ firefighting and emergency services base for central London in a strategic location to maintain fast response times to emergency incidents in central London; • Museum – the creation of a permanent home for the London Fire Brigade museum, at its original site, resulting in educational and cultural benefits to the locality and wider London; • New Homes - delivery of new housing, including 40% affordable housing (39% based on units); • New and Diverse Employment Opportunities – the creation of space for approximately 1,264 on-site jobs across a range of sectors (including medium, small and micro workspaces well suited to small creative and cultural businesses and start-ups) and creation of additional jobs during construction and from associated resident and occupier expenditure; and • Public Realm - enhancements to public realm and way finding, including through provision of around 1,900sqm of high quality, permeable public realm (currently the site does not provide any public realm and the appeal scheme provided less than 600sqm).

There is therefore no objection to the development’s height in this location, which has a very high public transport accessibility level. The proposed buildings on the site have been sensitively designed, taking inspiration from the surroundings and historic context of the site, and would respect the character, context and the form and scale of neighbouring buildings and would sit comfortably within the streetscene and surrounding area. The appearance and detailed façade treatment of the development is considered to be high quality, displaying an appropriate response to the surrounding character and the proposal would have no adverse impact on the setting of nearby listed buildings, conservation areas and protected views.

The proposed development would meet all relevant residential space standards and the provision for private and communal amenity space and play space proposed is considered to be acceptable. Adequate levels of daylight would also be provided within the flats for future residents. The proposal provides units with a good standard of accommodation, in terms of unit sizes, aspect and amenity space provision, being provided.

The proposals respond to the shortcomings of the Appeal Scheme and conclusions of its dismissal at appeal, providing significant daylight improvements to key windows and rooms surrounding the development site, particularly Whitgift House and 2 Whitgift Street compared to the Appeal Scheme. Given the distance and orientation to the nearest residential properties, and the inclusion of appropriate mitigation measures, the proposal would not result in any significant material impact in terms of overlooking.

The proposed scheme does result in some adverse and noticeable reductions in daylight and sunlight, particularly to Whitgift House. However, consideration should be given to the particular characteristics of the properties reviewed and to the fairly minimal existing massing on the application site which is unusual in an urban context. It is also reasonable to consider the identified effects alongside the planning merits of the scheme overall. In conclusion officers consider that the overall impact of the scheme in terms of daylight, sunlight and overshadowing along with the many planning benefits that the scheme would deliver weighs strongly in favour of the proposals.

The development would have a sustainable construction, meeting all of the relevant sustainability standards. The ES and technical appendices consider the environmental impacts of the proposals and demonstrate how they are acceptable, propose mitigation where required and conclude that the proposed development will not result in significant adverse environmental effects.

The proposed development will secure the regeneration and revitalisation of an important site as identified within the Lambeth Local Plan, the VNEB OAPF and the Vauxhall SPG. It will realise LFB’s objectives, support the local area as a destination for arts and culture, whilst also sustaining and enhancing heritage assets and securing their long-term future.

As such, the proposal has been assessed in accordance with Sections 16, 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, Section 70(2) of the Town and Country Planning Act 1990 and Section 38(6) of the Planning and Compulsory Purchase Act 2004, the NPPF and the development plan. Officers consider that the scheme is acceptable and there are sufficient material considerations to demonstrate the departure from the development plan in this instance such that the Council is able to support the proposed development. .

OFFICER REPORT

Reason for referral to PAC: The application is being reported to the Planning Applications Committee in accordance with the Committee’s terms of reference as it relates to:

1) (i), (ii) and (iii) A major application for the provision of more than 10 residential dwellings and the provision of floorspace in excess of 1,000 square metres on a site with an area of 1 hectare or more; and 9) Applications which are recommended for approval where it is proposed to grant permission for a proposal which is a significant departure from the policies of the Council's Development Plan.

1 SITE AND SURROUNDINGS

1.1 The site (1.06 hectares) is located on the eastern side of Albert Embankment, at the junction with Black Prince Road. It is bounded by Whitgift Street to the north, the railway and Newport Street to the east, Southbank House and Black Prince Road to the south and the Albert Embankment to the west. The site, as shown in Figure 1 below, contains 18,000sq.m of existing floorspace and is subdivided into three separate parcels of land by Lambeth High Street and the railway lands. The three parcels are referred to in the applications submitted as the “West”, “Central” and “East” sites.

Figure 1 – Location Plan

West Site

1.2 The west parcel (0.41 hectares) is bounded by Albert Embankment to the west, with the River Thames beyond; Black Prince Road to the south, beyond which are residential buildings of up to 13 storeys, and White Hart Dock; the International Maritime Organisation Headquarters to the north, of up to ten storeys, and the Windmill public house; and Lambeth High Street to the east, beyond which is the central parcel of the application site. The parcel includes a Grade II listed building constructed in 1937 as the headquarters of the London Fire Brigade (LFB) (as shown in Photograph 1 below), of up to 10 storeys, and in ‘Sui Generis’ use as Lambeth Fire Station, with offices and sleeping accommodation above, although the upper floors are largely vacant (floorspace 8,650sq.m). To the rear, in the south- west corner of the parcel, is a vacant 3 storey 1980’s extension, known as the Communications Mobilising Centre (CMC) Building (1,763sq.m). The extension (as shown in Photograph 2 below) forms part of the listed building, although the listing description identifies it as not of special interest.

Photograph 1 – View of Listed Former Fire Headquarter Building from Millbank

Photograph 2 – View of Headquarter Building & CMC Extension from Albert Embankment

1.3 The remainder of the site is made up of a hard-surfaced drill yard, used by the fire brigade for parking, training and fire related operations. The yard contains a stone Obelisk, built in 1940 as a ventilation shaft for a war-time underground bunker but never used for that purpose. On the east side of the yard is the Grade II listed 10 storey Drill Tower (135sq.m) (as shown in Photograph 3 below), also constructed in 1937, still in use for training purposes by the fire brigade.

Photograph 3 – Aerial View of Headquarter Building Façade & Rear Area from Albert Embankment

Central Site

1.4 The central parcel (0.61 hectares) is bounded by Lambeth High Street to the west, with the west parcel beyond; Whitgift Street to the north, beyond which are residential buildings of up to 6 storeys and Old Paradise Gardens park; the railway viaduct between Waterloo and Vauxhall Stations to the east, with car-related and small-scale logistics uses in the arches beneath; and the Grade II listed Southbank House to the south, of up to 6 storeys, formerly part of the Royal Doulton Factory, now in use as office space, with the 23 storey 81 Black Prince Road residential block beyond. The parcel comprises an area of car parking that fronts onto Lambeth High Street (as shown in Photograph 4 below); behind which is a two to four storey building (The Workshop, 6,980sq.m) (as shown in Photograph 5 below), partly in meanwhile use (to December 2019) as a temporary London Fire Brigade Museum, event space, and space for charities, social enterprises, and artists (Use Class D1), including the Migration Museum and Institute of Imagination. The use of the building will revert back to Sui Generis on expiration of the temporary use.

Photograph 4 – Aerial View of Headquarter Building & Rear Area from Lambeth High Street

Photograph 5 – View of Existing Workshop Building from Whitgift Street

East Site

1.5 The east parcel (0.03 hectares) lies on the other side of the railway viaduct. The north and west boundaries are formed by a car park associated with the former ‘Ragged School’ at 22 Newport Street, which lies to the north, currently used as the Beaconsfield Art Gallery; with Newport Street to the east and Black Prince Road to the south. The parcel previously provided surface level car parking associated with the fire station, but is currently leased and in use as a plant nursery (as shown in Photograph 6 below).

Photograph 6 – View of Existing Plant Nursery from Newport Street

1.6 All three parcels are located within the Albert Embankment Conservation Area. The west and central parcels are within the Thames Policy Area and the Central Activities Zone (CAZ). The whole site falls within the background of a number of strategic views from Primrose Hill and Parliament Hill to the Palace of Westminster and within the Vauxhall, Nine Elms and Battersea (VNEB) Opportunity Area (OA).

1.7 The wider area between Albert Embankment and the railway viaduct is made up of large-scale buildings, with recently completed, under-construction and consented schemes (primarily residential) to the south of up to 30 storeys; and buildings to the north of up to 14 storeys. To the east of the railway viaduct, the context is primarily low-rise residential up to 4 storeys, including some retail as part of Black Prince Road local centre. Damien Hirst’s Newport Street Gallery lies approximately 150 metres to the north of the east parcel.

1.8 The whole site is allocated for mixed-use development, including residential and employment uses, under Policy PN2 Site 10 of Lambeth’s Local Plan and Draft Revised Local Plan, with the central and east parcels within the South Bank House and Newport Street Key Industrial and Business Area (KIBA).

1.9 The site is bounded by the A3036 Albert Embankment to the west, which forms part of the Transport for London Road Network (TLRN). The Vauxhall transport interchange is within 900 metres of the site, providing access to National Rail, Victoria line London Underground, and a number of bus services. In addition, bus stops are located within 100 metres of the site on Albert Embankment. As such, the site is afforded a public transport access level (PTAL) of 6a, on a scale of 0 to 6b, where 6b represents the greatest level of access to public transport. There are currently no designated cycle routes on the A3036 in the location of the site, and a Cycle Hire docking station in close proximity to the site at Fire Brigade Pier.

2. PROPOSAL

2.1 The application proposes the redevelopment of the site to provide 443 residential units, along with more than 24,000sq.m of non-residential floorspace (GIA) within buildings of up to 26 storeys in height. This includes the following:

 2,203sq.m Fire Station (Sui Generis);  1,434sq.m. LFB Museum (Use Class D1);  6,270sq.m hotel of up to 200 bedrooms (Use Class C1);  10,766sq.m of business floorspace (Use Classes B1 (a)/B1 (b)/ B1 (c));  628sq.m of flexible retail floorspace (Use Classes A1-A4 / D1 / D2 /B1(a)/ B1(b) / B1 (C);  Gym of 2,849sq.m. (Use Class D2);  865sq.m restaurant (Use Class A3); and  2,084sq.m of new public realm (20% of the site), basement and surface parking, servicing and access.

2.2 The ground floor layout of the development is shown in Figure 2 below. On the west parcel, the CMC Building is proposed to be demolished, to be replaced by a 10 storey L-shaped hotel with flexibility for up to 200 bedrooms. The Grade II listed Fire Station Building would have partial demolitions at the rear and roof level, construction of a double-height glazed rooftop restaurant linked to the hotel via a tenth floor footbridge, with flexible ground floor space for retail or hotel use, and internal alterations and extension to facilitate the fire station, LFB museum, and 95 residential units. The Obelisk would be relocated to the central parcel and the Grade II listed Drill Tower refurbished to enable its continued use. A public space (South Square) is proposed at the corner of Lambeth High Street and Black Prince Road.

Figure 2 - Ground floor and access into site

2.3 On the central parcel, the Workshop building is proposed to be demolished, and 4 buildings constructed of 4-5, 8-10, 24 and 26 storeys, comprising a range of office and workspace units, a gym, flexible retail units, and 318 residential units. New public space includes ‘Central Square’, fronting on to Lambeth High Street; linking to a ‘Central Garden’, including the Obelisk, connecting to the north to Whitgift Street and Old Paradise Gardens, and to the south to the ‘Eastern Garden’ and ‘Eastern Link’, which fronts onto Black Prince Road.

Figure 3 – Aerial view showing location of uses & massing of proposal 2.4 On the east parcel, an 11 storey building is proposed, providing a flexible retail/ commercial unit at ground floor level, and 30 residential units above.

2.5 The planning application (Application A - ref. 19/01304/FUL) is accompanied by a Listed Building Consent application (Application B – ref. 19/01305/LB) for works to 8 Albert Embankment, including the demolition of the CMC Building and Obelisk, and part redevelopment, restoration, conversion and extension. The general massing of the proposal and its context with surrounding buildings is shown in Figure 3 above.

3. AMENDMENTS

3.1 During the course of the application, the following amendments were made and additional information provided:

Amendments

 Removal of private residential car parking from basement (removal of 36 parking spaces);  Increase in the basement gym area by 796sqm (GIA) from 2,053sqm to 2,849sqm;  Increase in the number of residential units from 417 to 443 (an increase of 26 units) with fewer overall 3 bedroom units (19 compared to 55) and more 1-bedroom (228 compared to 173) and 2- bedroom units (149 compared to 142) proposed;  Changes to the tenure of 24 residential units within the East and West Towers from market to affordable (shared ownership) units – resultant increase providing 40% affordable housing;  Associated changes in cycle parking, play and amenity and disabled parking;  Use of ground floor flood proof doors for 3 no. residential units and 1 no. communal entrance door within the Whitgift Street Terrace;  Small scale design changes to the building on Whitgift Street relating to internal configuration with no change to the external envelope of the proposal;  Alteration to the phasing plan to include sub-phases;  Changes to the position of service bays within the public highway, and removal of the taxi-rank;  Increased landscaping within the site, including introduction of larger areas of green wall and green roofs;  Increase to water attenuation within the site, by introducing additional attenuation at roof level; and  Removal of drop off/set down point associated with the fire station.

3.2 Public re-consultation on the above changes and additional information received has been undertaken with further advice also sought from the Council’s Viability and Sunlight and Daylight consultants.

4 PLANNING PERFORMANCE AGREEMENT

4.1 The applications are subject to a Planning Performance Agreement agreed on the 4th December 2018 and remaining in force until the determination of the planning and listed building consent applications.

4.2 The proposal was considered at the pre-application stage on 27th June 2018 by Strategic Panel where an initial steer was given. The original applications were also presented at a Technical Briefing on 24th June 2019 with the amended applications being presented to a further Technical Briefing on 11th November 2019 in order to provide more detailed information about the scheme in advance of PAC.

5 RELEVANT PLANNING HISTORY

5.1 The relevant planning history for the site includes the following applications:

 10/00318/FUL – An application was submitted by Native Land in January 2010 for “the refurbishment and extension of the Grade II listed fire station and the construction of seven new buildings ranging in height from 5 to 16 storeys, to contain 360 residential units and 7,214sq.m of commercial floorspace” with associated listed building and conservation area consent applications. The Council resolved to refuse the application on the grounds of inappropriate development within the Key Industrial and Business Area (KIBA); failure to provide an appropriate mix of uses or a significant element of employment generating floorspace; unacceptable harm to the Grade II Listed 8 Albert Embankment, the Grade II Listed Drill Tower, the existing townscape, the Thames Policy Area and the Albert Embankment Conservation Area; overly dominant and incongruous additions to the street scene; insufficient daylight, sunlight, overshadowing, light pollution and solar glare assessment; failure to demonstrate effectively how surface water will be managed; excessive car parking; insufficient information on the likely impact on traffic and highway safety; failure to demonstrate that the scheme would not be viable with a higher level of affordable housing (10%); and failure to include any designated child play space for children under 5. The draft decision was referred to the Mayor of London who was content for the Council to determine the case itself; however, the application was withdrawn before the decision was issued.

 10/04473/FUL - A revised application was submitted by Native Land in December 2010 for “refurbishment, alterations and extensions to the Grade II listed fire station, together with construction of seven new buildings to rear, ranging in height from 5 to 15-storeys, to contain a mixed-use development including a new fire station, 265 residential units, 8,554sq.m of commercial floor space, shops and retail uses, with associated parking, public realm and landscaping works” with associated listed building and conservation area consent applications. The Council resolved to refuse the application (against officer recommendation) on grounds of unacceptable harm to the Grade II Listed 8 Albert Embankment, the existing townscape, the Thames Policy Area, and the Albert Embankment Conservation Area; unacceptable harm to levels of daylight and sunlight to neighbouring residential properties; an unacceptably low level of affordable housing (7%); and failure to relate satisfactorily to the adjacent townscape in terms of height, massing and scale. The draft decision was referred to the Mayor of London who was content for the Council to determine the case itself

The applicant subsequently appealed the refusal and a Public Inquiry was held in 2013. The Inspector identified the 4 main issues as; whether the scheme paid adequate regard to local employment and economic objectives; whether the proposed affordable housing was acceptable; the effect on the character, special interest and settings of listed buildings, the character and appearance of the Albert Embankment and Vauxhall Gardens Conservations Areas, and the surrounding locality; and the impact on the living conditions of nearby residential occupiers by reason of loss of daylight and sunlight. The Inspector concluded that the proposals were acceptable on 3 of the 4 main issues; however, the loss of daylight and sunlight to Whitgift House and 2 Whitgift Street represented a shortcoming in achieving a fully sustainable development, outweighing the benefits of the scheme and warranted dismissal of the appeal.

 16/03122/FUL - Change of use from Workshop (Use Class Sui Generis) to a Museum and Event Space (Use Class D1) for a temporary period of 18 Months starting from 1st July 2016 – Approved 07.09.2016.

 16/07019/EIASCP - Request for a Scoping Opinion in respect of an Environmental Impact Assessment in relation to proposed redevelopment at 8 Albert Embankment for part redevelopment and restoration, conversion and extension of main HQ building to provide a new fire station, a fire service museum, residential units and hotel with rooftop restaurant; proposed redevelopment of central workshops building to provide a main office building with basement areas, with gallery and ancillary retail units at ground level and with market and affordable housing units above (up to 75m AOD) and alongside; development on rear vacant site of employment space with affordable housing above; offices and employment spaces totalling up to 10,500sqm GEA, gallery and ancillary retail units up to 750sqm GEA and with 325 - 350 residential units; new areas of landscaped public realm with ancillary lower level servicing and car parking provision - Approved 06.02.2017.

 17/05142/VOC - Variation of Condition 1 (temporary permission end date) of planning ref 16/03122/FUL (Change of use from Workshop (Use Class Sui Generis) to a Museum and Event Space (Use Class D1) for a temporary period of 18 Months starting from 1st July 2016) – Approved 07.09.2016.

 18/04185/VOC - Variation of Condition 1 (temporary permission end date) of planning ref 16/03122/FUL (Change of use from Workshop (Use Class Sui Generis) to a Museum and Event Space (Use Class D1) for a temporary period of 18 Months starting from 1st July 2016) granted on 07.09.2016 and subsequent variation of Condition 1 (ref. 17/05142/VOC) - Approved 21/12/2017.

 18/03080/EIASCP - Request for a Scoping Opinion in respect of an Environmental Impact Assessment in relation to proposed redevelopment at 8 Albert Embankment for phased mixed use development including up to 442 residential units and comprising: part redevelopment and restoration, conversion and extension of former Fire Brigade Headquarters building and demolition of the existing extension and relocation of obelisk to provide a new fire station (Sui Generis), a new London Fire Brigade museum (Class D1), residential units (Class C3), a ten storey hotel (Class C1) with up to 200 bedrooms, and a rooftop restaurant with ancillary bar (Class A3); demolition and redevelopment of the central workshop building to provide buildings of up to twenty-six storeys plus basements, comprising business floorspace (Use Class B1), gym (Class D2), retail units (Classes A1/A2/A3/A4) and residential units (Class C3); development of land to the rear to provide an eleven storey building plus basement, comprising a flexible commercial unit (Classes A1/A2/A3/A4/D1/D2/B1) and residential units (Class C3); all together with associated areas of new public realm, hard and soft landscaping, basement and surface parking, servicing, means of access and plant and equipment – Approved 31.08.18.

6 CONSULTATIONS

6.1 A list of all those consulted is provided in Appendix 2. The following responses have been received as summarised below:

6.2 Statutory and External Consultees

The Greater London Authority (GLA

6.2.1 The GLA have made the following comments:

 Principle of development: The redevelopment of this long vacant/under-used site in an Opportunity Area and the Central Activities Zone will contribute significantly to Council and GLA’s aspirations for the site, particularly residential uses, significant employment space (including affordable), and emergency facilities. The principle of the uses proposed is supported in line with the London Plan, draft London Plan, and VNEB OAPF.

 Affordable housing: 34% affordable housing, made up of 71% affordable/social rent, and 29% shared ownership. Although the proposals are subject to abnormal costs, including the provision of Lambeth Fire Station, the Fire Brigade Museum, and the conversion and restoration of listed buildings; as the threshold for publicly owned sites is 50%, the offer does not meet the requirements for the fast-track route and a financial viability assessment has been provided, which is undergoing assessment by the Council’s advisers and GLA officers. Affordability thresholds and early/late stage viability reviews must be secured.

 Urban design: The proposals are of a high design quality, and subject to further information and amendments to improve residential quality, are supported.

 Historic environment: The proposals will cause ‘less than substantial’ harm to the listed buildings on the site and the Albert Embankment Conservation Area; however, this is outweighed by the considerable public benefits arising from the proposals. No harm will be caused to the Westminster World Heritage Site or strategic views.

 Transport: The amount of car parking should be reduced, and the vehicle access arrangements revised in agreement with TfL. Financial contributions towards pedestrian and cyclist enhancements should be secured, and a review of the trip generation is requested to confirm public transport impacts.

 Climate change: Further information has been requested on the energy strategy, Flood Risk Assessment, sustainable drainage, and urban greening.

6.2.2 Officer comment: Conditions of approval are recommended along with s106 Heads of Terms (HoTs) to address the issues raised. Further energy information has been supplied by the applicant to the GLA in advance of Stage II.

Historic England

6.2.3 On the basis of the information submitted, and following our assessment of the submitted visual analysis, our view is that the harm to the significance of the conservation area identified is less than substantial in terms of the NPPF, although it could be mitigated further if the proposed tall buildings were reduced in height. In line with paragraph 196 of the NPPF, it is for your authority to weigh the harm against the public benefits of the proposals when coming to a decision.

6.2.4 Historic England consider it would be appropriate at this stage to add some additional context to explain for the benefit of the Planning Committee how Historic England’s advice on the current applications has been reached. Our advice has focused on the principal proposed alterations to the exterior of the grade-ii listed former London Fire Brigade headquarters, and on new development on the wider application site. We have consequently concentrated on two key aspects of the scheme: the proposed rooftop extension to the fire station building and new buildings to its rear. It is for your authority to seek its own expert advice in considering the full effects of the applications for planning application and listed building consent, and to weigh the impacts and public benefits of the scheme in the manner required by the NPPF.

6.2.5 Our advice is framed in line with national legislation, policy and guidance. It is for your authority to determine how precisely these applications engage local planning policies, including your Local Plan, the London Plan, relevant conservation area appraisal and opportunity area planning framework.

Historic England (Archaeology)

6.2.6 No objection, subject to conditions subject to pre-commencement conditions requiring the submission and approval of a written scheme of investigation and details of foundation design and construction method being attached to any permission granted.

6.2.7 Officer comment: Appropriately worded conditions are recommended if the council is minded to approve the applications.

Environment Agency

6.2.8 No objection, subject to conditions relating to flooding, piling, contamination and sustainable drainage and informative relating to flood risk and waste being attached to any permission granted.

6.2.9 Officer comment: Appropriately worded conditions and informatives are recommended if the council is minded to approve the applications.

Thames Water

6.2.10 No objection to the scheme subject to a condition requiring a Housing and Infrastructure Phasing Plan, piling method statement and informatives relating to underground water assets and water mains being attached to any permissions granted.

6.2.11 Officer comment: Appropriately worded conditions and informatives are recommended if the council is minded to approve the applications.

London Underground

6.2.12 No comment to make on the applications.

Transport for London

6.2.13 The outstanding issues requiring further clarification include: 1) An alternative access to the fire station should be accepted, including any minor works to secure this route, supported by a suitable planning obligation or Memorandum of Understanding; 2) the proposed highway works on Albert Embankment should be secured and delivered via a S278 agreement with TfL (the scope of works should accord with TfL’s plans for improvements on Albert Embankment if a scheme comes forward prior to implementation of the works); and 3) details regarding the proposed taxi rank to be confirmed, including space for a single taxi and Rapid Charging Point.

6.2.14 Officer comment: Appropriately worded s106 Heads of Terms are recommended as set out in the ‘Planning Obligations and CIL’ section to cover points 1) and 2) and paragraph 8.7.19 in the ‘’Transport Section’ below responds to point 3).

Internal Consultees

6.2.15 Bioregional

6.2.16 No objection subject to conditions and s106 Heads of Terms relating to future district heating system connection, compliance with BREEAM and solar panels being secured in any permission granted.

6.2.17 Officer comment: Appropriately worded condition and s106 Heads of Terms recommended if the council is minded to approve the applications.

Design out Crime Officer (Metropolitan Police)

6.2.18 No objection subject to Secured by Design Certification being secured by conditions. This should very specifically be split phase by phase, and again split between Residential and Commercial use.

6.2.19 Officer comment: Appropriately worded condition recommended if the council is minded to approve the applications.

LBL Conservation & Urban Design

6.2.20 No objection subject to conditions relating to steel windows, external ironwork, detailed drawings (1:10 scale) and associated details of all new works to the exterior of the building; sample windows (including French doors) to be erected; detailed drawings (1:10 scale) including sections for the alterations within the Memorial Hall; Brick Cleaning Method Statement; Replacement brickwork matching; and construction drawings (1:10 scale) including sections of all external works; and sample panels (1:1 scale) for a representative part (window, walling, parapet etc.) of each new building to be erected on site for approval being attached to any permissions granted.

6.2.21 Officer comment: Appropriately worded conditions are recommended if the council is minded to approve the applications.

LBL EHST Noise Pollution

6.2.22 No objection subject to conditions relating to a Construction Environmental Management Plan, full noise report and consideration of façade impacts on each of the buildings are considered in order to finalise a suitable glazing scheme and that residents have access to suitable amenity space achieving the 55db levels predicted; contamination; wind mitigation; hydrogeological, noise levels and insulation being secured by condition.

6.2.23 Officer comment: Appropriately worded conditions are recommended if the council is minded to approve the applications.

LBL Highway Team

6.2.24 No objection to the proposals.

LBL Neighbourhood Housing

6.2.25 Objection on the grounds of impact to residential properties managed by the Council, including impact on light, green space, increase in traffic and health and safety concerns.

LBL Parks & Open Spaces

6.2.26 No objections. The proposals do not result in a loss of public open space and the risk of the loss of significant biodiversity habitat is minimal. The submitted ecological assessments and the conclusions/recommendations reached are appropriate and to the required standard, and the proposed landscaping plans would result in a significant improvement in the quality and ecological/amenity value of the site. Details of specifications for all external soft landscaping, which would have to include appropriate ecological enhancements, should be secured by condition.

6.2.27 Officer comment: Appropriately worded conditions are recommended if the council is minded to approve the applications.

LBL Planning Policy

6.2.28 No objection to the proposal. The application is broadly consistent with the site allocation policy for the site, subject to assessing that inclusion of residential in the KIBA part of the site is necessary to achieve an acceptable scheme in all other respects, and that the replacement employment floorspace has been maximised.

6.2.29 The quantum of residential units is considered to be acceptable but the amount of affordable housing proposed is below the policy requirement and the mix of size of the affordable units does not comply with requirements either, so the application must follow the Viability Tested Route. The viability appraisal should be independently assessed and any consent would be subject to a late stage review.

6.2.30 The proposed hotel is considered to be acceptable in principle. The proposed ground-floor units would provide active frontages which is supported. Any impact on the CAZ frontage caused by the introduction of retail uses should be carefully considered.

LBL Regeneration Team

6.2.31 No objection to the proposal.

LBL Transport

6.2.32 No objection to the proposal subject to conditions relating to closure of existing and new access points, Delivery and Servicing Plan, Cycle and Car Parking, Travel Plan, Construction Environmental Management Plan and Refuse and Recycling Storage Details being attached to any permission granted and a commitment being provided to enter into a s106 and S278 agreement (and s38 agreement where necessary) for off-site highways works and improvements along Albert Embankment, Black Prince Road, Newport Street and Whitgift Street including adoption of new footways and mitigation measures as set out in the ‘Transport Section’ below.

6.2.33 Officer comment: Appropriately worded condition and s106 Heads of Terms recommended if the council is minded to approve the applications.

Veolia Waste Lambeth

6.2.34 The proposed Waste Management Strategy is supported.

6.3 Other

6.3.1 London Borough of Camden

6.3.2 No objection to the proposal.

London Borough of Westminster

6.3.3 Objection on the grounds that: the proposed towers on the Central Site will have a harmful impact upon the setting of the World Heritage Site, specifically the grade I Palace of Westminster, harming strategic views, while also causing harm to the setting of the listed fire station, harming the views of this building from Westminster; and the setting of the conservation areas from where the building can be seen; the proposal will impact on Strategic Views; and the glass box extensions to the roof are considered incongruous to the host building and will compromise the building's integrity and the completed composition.

6.3.4 Officer comment: The concerns raised are addressed in the ‘Design and Conservation Section’ below.

The National Lottery Heritage Fund

6.3.5 The wider development includes a proposal to rehouse the London Fire Brigade Museum for which we have awarded an initial development grant. We have been made aware of various concerns from the local community relating to the development, including the suggestion that the applicants may be using the fact of our development grant to endorse their case for planning permission. Our current grant refers only to the small proportion of the proposed development that would become the London Fire Brigade Museum, and while progress to our second stage delivery grant is clearly dependent on the wider development going ahead, we have no view whatsoever on that wider development. We take no view on planning decisions which are entirely a matter for local democracy and due process.

Twentieth Century Society

6.3.6 Objection on the grounds that the proposed rooftop extension will destroy the character and form of the fire station building, resulting in substantial harm to the building's significance as a whole and further harm to the character of the Albert Embankment Conservation Area. We also note that this revised scheme has increased the massing of the proposed rooftop extension in comparison to the 2011 application. The Society is not convinced that the viability of the entire development relies on the inclusion of the rooftop extension, and the addition of a restaurant does not meet the requirement for public benefit necessary to balance the harm caused to the Grade II listed building. Museum of London

6.3.7 Support for the proposals. The Museum of London is excited by the prospect of further collaboration with the new museum with a particular focus on supporting schools in their teaching of the Great Fire of London and the history of the London Fire Brigade, alongside their important role in delivering fire safety education work for schools and families. The proposals include an expanded educational programme, with a designated learning centre within the new museum. It is hoped that the Council will recognise the importance of preserving and increasing access to the London Fire Brigade’s collection of artefacts and archives.

Migration Museum

6.3.8 Support for the proposals. Having a base at the Workshop has been transformative and has allowed us to stage a wide range of exhibitions, events and education activities reaching over 30,000 members of the public and has helped to build up strong local partnerships with schools, organisations and companies, community groups and tenants associations.

Lambeth Village

6.3.9 Objection to the proposals on the grounds that Lambeth’s planning policies set out design principles, which clearly state that the site is not suitable for tall buildings; the proposals would have a “major adverse” impact on light to council homes; the Grade II listed Fire Brigade Headquarters will be dwarfed by the 200-bed hotel next door, which will wrap around the back of and across the parade ground, removing both views of significance and causing great damage to the setting; further negative impact will come from the proposed two-storey glass box roof extension on top of the fire station; and the two towers would clearly breach the protected art deco outline of the listed building (plus protected views) and cause extensive shadowing across the neighbourhood, all the way to the Garden Museum on the doorstep of Lambeth Palace; and finally, on land principally protected for employment this is clearly a residential-led development.

Whitgift Estate Tenant Residents Association

6.3.10 Object to the proposal for the following reasons:  The proposal will damage the integrity of a Grade-II listed building [1] (the old Headquarters of the London Fire Brigade);  Ruin a historic village and its daily functioning;  Block residents’ access to light;  Blight the Garden Museum’s community work;  Overshadow the community’s park; and  Defy local planning policy by building residential tower blocks in a Key Industrial Business Area (KIBA).

9 Albert Embankment Residents Association

6.3.11 Objection on the grounds that the application is a departure and should be rejected as such with a most dense scheme with two almost 90 metre towers on a site deemed unfit for tall towers and deliberately ignores local plan policy and local neighbours; it will lead to a great deal of loss of light and amenity to two properties in Whitgift Street that happen to both be providing socially valuable services to the local community; it will adversely impact on the Heritage and setting of a Grade II listed property; and will result in a major increase in traffic on the small junction between Black Prince Road and Lambeth High Street resulting in inevitable gridlock.

6.3.12 Whilst the renovation of a historic building is a good idea and having a museum and a modern fire station would be a good thing, none of these require this design to achieve them. It would be perfectly possible to keep to the Lambeth Plan regarding building heights, respect the Grade II listing, keep the KIBA and still deliver all the components that are needed without making the traffic, noise and general chaos that is going to ensue from these designs. It will not reflect well on any of us if the current design is allowed to go ahead.

6.4 Adjoining owners/occupiers

6.4.1 Site notices were displayed from 19 April to 12 May 2019 (Original Application Submission) and following amendments to the scheme from 6 September to 27 September 2019 (Amendments 1 Application Submission) on Albert Embankment, Lambeth High Street and Newport Street. The applications were also advertised in the local paper on 17 April 2019 (Original Application Submission) and following amendments to the scheme on 4 September 2019 (Amendments 1 Application Submission). The formal consultation period ended on 6 October 2019.

6.4.2 Table 1 below provides a summary of the changes that have been to the proposals during the course of the applications and the plans/documents that formed the two separate formal consultation periods undertaken as set out above. As the amendments made on 27 September and 06 November 2019 were relatively minor (as set out below) and did not change the overall height or massing of the proposals further formal consultation was not considered necessary.

Date Original Application Submission 29.3.19 As noted in the application covering letter the original applications documents comprised:

 Planning and listed building consent application form and certificates;  CIL Additional Information Requirements Form;  Application drawings, prepared by Pilbrow and Partners as set out in drawing schedule submitted.  Planning Statement (including draft S.106 Heads of Terms), prepared by Lichfields;  Financial Viability Assessment, prepared by JLL;  Design and Access Statement, prepared by Pilbrow and Partners;  Landscape and Public Realm Strategy, prepared by Townshend Landscape Architects;  Statement of Community Involvement, prepared by London Communications Agency;  Daylight, Sunlight & Overshadowing Report, prepared by Point2 Surveyors;  Environmental Statement (ES),

Date Plans/Reports Amended – Amendments 1 Summary of Changes 30.8.19  Amended planning application drawings and Area  Removal of market Schedule, prepared by Pilbrow and Partners (see AUG 19 residential car parking P&P Drawing Schedule) from basement (removal  Amended landscape drawings, prepared by Townshend of 36 parking spaces); Landscape Architects (see 23.08.19 Townshend Drawing  Increase in the gym at Schedule) basement level (increase  Design and Access Statement Addendum, prepared by gym area by 796sqm Pilbrow and Partners GIA);  Landscape and Public Realm Strategy addendum,  Increase in number of prepared by Townshend Landscape Architects units from 417 to 443 as  Waste Management Strategy Update, prepared by WSP a result of a change in  Transport Assessment Addendum, prepared by WSP mix – reduction of 3  Financial Viability Appraisal Addendum, prepared by JLL beds, increase of 1 and  Environmental Statement Addendum, prepared by WSP 2 beds, associated and including the following appendices: change in cycle parking,  Appendix A: Detailed Project Construction Phases play and amenity and (Proposed Diagram) Drawing No. 1528- PP-Z0-XX- disabled parking). No DR-A-00-1009 change to the external  Appendix B: Updated Socio-Economics Assessment envelope, the changes relate to internal  Appendix C: ES Appendix 8.5 (Traffic Data Used in configurations only; the Assessment); and ES Appendix 8.8 (Model Results)  Use of flood proof doors for 3 residential units and  Appendix D: Internal Daylight and Sunlight - 1 communal entrance Addendum Statement  Appendix E: Updated Non-Technical Summary door within the Whitgift  Planning Addendum (Covering Letter dated 30.9.19) Street Terrace  Small scale design changes to the building on Whitgift Street to address GLA comments  Alteration to the phasing to include sub-phases: overall phasing remains as assessed  The drop off/set down point associated with the fire station removed (western site)

Date Plans/Reports Amended Summary of Changes 27.9.19 Amended planning application drawings, prepared by Pilbrow  Increase in the finished and Partners (see Sep 19 P&P Drawing Schedule) floor level (FFL) within  Addendum to the Design Access Statement, prepared by the ground floor Pilbrow and Partners residential apartments in  Amended landscape drawings, prepared by Townshend the Whitgift Street Landscape Architects (see 27.09.19 Townshend Drawing Terrace and part of the Schedule) ground floor residential  Addendum to Landscape and Public Realm Strategy, lobby from 4.8m AOD to prepared by Townshend Landscape Architects 5.25m AOD and the  FRA Addendum, prepared by WSP; and following associated  Letter prepared by WSP considering non-material changes: changes on ES and ES Addendum  Removal of the  Planning Addendum (Covering Letter dated, 27.9.19) proposed ramps, and introduction of additional stairs and reconfigured planters.  Internal reconfiguration of ground floor, including incorporation a platform lift alongside an additional corridor to the rear.  Small reduction in the total area of the proposed Small Workspace units T5,T6 and T7 from 186sqm to 153sqm Date Plans/Reports Amended Summary of Changes

6.11.19 Amended planning application drawings, prepared by Pilbrow  24 residential and Partners (see Nov 19 P&P Drawing) apartments within the  Addendum to the Design Access Statement, prepared by East and West Towers Pilbrow and Partners changed from private to  Amended landscape drawings, prepared by Townshend affordable housing Landscape Architects (see 6.11.19 Townshend Drawing (shared ownership) Schedule)  Increased landscaping  Addendum to Landscape and Public Realm Strategy, within the site, including prepared by Townshend Landscape Architects; introduction of larger  Letter prepared by WSP considering non-material areas of green wall and changes on ES and ES Addendum; and green roofs  Financial Viability Appraisal Addendum, prepared by JLL  Increase to water  Planning Addendum (Covering Letter dated 6.11.19) attenuation within the site, by introducing additional attenuation at roof level  Changes to the position of service bays within public highway, and removal of the taxi-rank. Table 1 – Amendments made to proposals

6.4.3 The Council has followed the procedural requirements relating to applications which are departures (i.e. do not comply with the development plan policies) and the application has been advertised as a departure on the basis that it is not in accordance with design principle (iv) ‘relates in height and bulk to the adjacent townscape taking into account the height, massing and scale of neighbouring buildings and the historic built form of the area; the heritage sensitivity of the site makes it inappropriate for tall building development’ of site allocation 10. The outcome of this consultation is set out below.

6.4.4 In total, 1,195 local residents were consulted on the applications with 626 individual representations having been received during the consultation period of which 343 were in support and 283 were in objection.

6.4.5 A petition of objection with 43 signatures has also received raising the following concerns:  The 24 and 26 storey towers, will be damaging to the historic area next to Lambeth Palace, removing the clear silhouette of the Fire Brigade HQ which is protected by planning policy. Reducing light from social housing neighbours (40%) and the green space at Old Paradise Gardens.  Excessively dense development with 2,500 people using the site, disruptive hotel uses when there is already plenty on Albert Embankment and inadequate provisions for deliveries, parking and traffic.  There are numerous tall buildings being erected in the local area, and these ones will block the views of the beautiful skyline from neighbouring properties.

6.4.6 A further petition of objection with 2,076 signatures has also been received opposing the proposals. No reasons for the objection have been given on the petition.

6.4.7 A summary of the individual responses in support are set out below:  The proposals will bring community benefit and economic development to the local area;  The provision of new offices and retail is supported;  The proposal will bring more life to the neighbourhood;  It will bring valuable businesses to the area and regenerate this part of London;  The area – and London – needs investors with a long-term vision and truly mixed use developments like these. The strong support for start-ups, innovation and small businesses is to be commended;  The mix of affordable houses is commendable and the overall scheme has a sensible mix of residential and commercial;  There will be a hotel attracting visitors to the area;  There will be workspaces, cafes and eateries, and other local amenities, bringing economic activity and vibrancy to an area that typically feels ‘dead’;  The proposal will create jobs;  Public realm will be greatly improved in the area;  The inclusion of a new purpose built home for the London Fire Brigade Museum, which is a major cultural asset and needed to deliver its fire safety education work and wealth of exciting family activities to Lambeth and the capital as a whole, is supported;  The proposed museum provides further opportunities for fun and learning and will continue to protect the history of the London Fire Brigade by preserving its extensive collection of artefacts and archives;  The proposals to transform this previously overlooked site are exciting and much needed for the area;  The proposal will create public access for the first time to a listed building of great significance, including the previously inaccessible Memorial Hall;  Expand its educational programme, with a designated learning centre to reach thousands of school children per year; and  Provide a number of skilled jobs and volunteering opportunities.

6.4.8 A summary of the individual objections received are set out in Table 2 below: Summary of objections Response Land Use  The proposals are a substantial departure Refer to ‘Land Uses’ section of report – paras. from KIBA policy and are in direct 8.1.1 to 8.1.49 of report. contradiction with the design principles and key development considerations set out Policy PN2 Site 10 of the Local Plan.  Overprovision of hotels within the local area. Refer to ‘Land Uses’ section of report – paras. 8.1.15 to 8.1.17 and 8.1.19 of report.  Loss of industrial employment land. The site is currently ‘sui generis’ with an increase in overall industrial employment land proposed.  Loss of plant nursery. There is no policy objection to the loss of the plant nursery on the East site.  Lack of thought to existing small businesses Refer to ‘Land Uses’ section of report – paras. and traders. 8.1.20 to 8.1.30 of report.  Lack of local infrastructure to cope with the The application generates a significant package proposals impacting on an already stretched of planning obligations and liability under the local health, education and other services Community Infrastructure Levy to deliver new which are not capable of accommodating and improvements to social and other the large number of additional residents infrastructure. arising from the development.  Unnecessary development of yet more Refer to ‘Land Uses’ section of report – paras. luxury apartments 8.1.50 to 8.1.64 of report.  Inadequate affordable housing provision Refer to ‘Land Uses’ section of report – paras. with a lack of truly affordable homes 8.1.50 to 8.1.64 of report. Design and Conservation  Overdevelopment of the site. Refer to ‘Standard of Residential Accommodation’ section of report – paras. 8.3.1 to 8.3.3 of report.  The density of the development is much Refer to ‘Standard of Residential greater than that of the existing local Accommodation’ section of report – paras. 8.3.1 environment. to 8.3.3 of report.  Visually oppressive form of development Refer to ‘Design and Conservation’ section of report – paras. 8.2.13 to 8.2.44 of report.  The height and scale of the proposals will Refer to ‘Design and Conservation’ section of completely dwarf surrounding buildings and report – paras. 8.2.13 to 8.2.44 of report. will be completely out of scale with the general heights and massing within the surrounding context.  The introduction of two very tall towers on the Refer to ‘Design and Conservation’ section of site is an unacceptable departure and report – paras. 8.2.13 to 8.2.44 of report. contrary to the policy presumption against tall building development contained in the Local Plan  The development will be completely out of Refer to ‘Design and Conservation’ section of keeping with the historic listed properties report – paras. 8.2.45 to 8.2.74 of report. around Lambeth Palace, Old Paradise Gardens, conservation area, Black Prince Road and will remove the clear silhouette of the Fire Brigade Headquarters Building which is protected by planning policy  The proposal would detrimentally impact the Refer to ‘Design and Conservation’ section of visual profile of a listed building that is an report – paras. 8.2.45 to 8.2.74 of report. important feature of the South Bank visual landscape when viewed from the River Thames, the North Bank and surrounding bridges.  The extension of the roof of the fire brigade Refer to ‘Design and Conservation’ section of building being constructed from glass would report – paras. 8.2.59 to 8.2.63 of report. provide an unsympathetic change to the character of this historic building.  The proposal will destroy an historic The proposals will not result in any loss or harm landscape, including the existing green to historic landscape or existing green spaces spaces and the surrounds of Lambeth and no objection has been raised by the Palace. Council’s Parks and Open Spaces Section Amenity  Overlooking and loss of privacy Refer to ‘Amenity for Neighbouring Occupiers’ section of report – para 8.4.1 to 8.4.53 of report.  Loss of sunlight and daylight to Refer to ‘Amenity for Neighbouring Occupiers’ neighbouring residential properties and section of report – para 8.4.54 to 8.4.55 of neighbouring public spaces report.  The proposed public realm areas will be Refer to ‘Daylight, Sunlight and Overshadowing’ overshadowed section of report – para 8.4.50 of report.  The possibility of creating local jobs for local Refer to ‘Employment and Training’ section of people during construction and when running report – paras. 8.10.1 to 8.10.4 of report. facilities has not been maximised.  Detrimental to welfare of the local The proposals will provide significant public community. benefits – see ‘Conclusion’ section of report – para 9.3.  There is a lack of greenery and no real public Refer to ‘Design and Conservation’ section of realm only streets and describing the report – paras. 8.2.39 to 8.2.44 of report. proposed square areas as ‘public’ is misleading.  Noise pollution. Refer to paras.8.3.15 to 8.3.20 and paras 8.4.57 to 8.4.61 of report.  Pollution of air quality. Refer to ‘Air Quality’ section of report – paras. 8.9.9 to 8.9.13 of report.  Increase in wind as a result of the tall Refer to ‘Wind Microclimate’ section of report – buildings making it unsafe for pedestrians. paras. 8.9.14 to 8.9.17 of report.  Increase in waste and smell nuisance. Refer to ‘Sustainable Design and Construction’ section of report – para 8.8.11 of report.  Impact on nature and local spaces. Refer to ‘Ecology, Trees and Landscaping’ section of report – paras. 8.6.1 to 8.6.6 of report.  Impact on physical and mental health. The proposal will have no adverse impact on physical and mental health. Transport  Increase in traffic. Refer to ‘Transport’ section of report – paras. 8.7.16 to 8.7.23 of report.  Inadequate provisions for delivery, parking Refer to ‘Transport’ section of report – paras. and traffic have been made for the 8.7.20 to 8.7.23 of report. development.  Prejudicial to highway safety with local Refer to ‘Transport’ section of report – paras. roads being too narrow for delivery lorries, 8.7.20 to 8.7.23 of report. taxis and coaches dropping off/picking up.  The proposal will be at odds with the Refer to ‘Transport’ section of report – para Council’s goal of the Quiet Cycleway and 8.7.15 of report. creating healthier and safer neighbourhoods.  Negative impact on bus routes and Refer to ‘Transport’ section of report – para consequently bus services during the 8.7.23 of report. building stage. Other  Not enough investment in new communal Refer to ‘Design and Conservation’ section of spaces for the community proposed. report – paras. 8.2.39 to 8.2.44 of report.  Blight the Garden Museum’s community Refer to ‘Daylight, Sunlight and Overshadowing’ work. section of report – para 8.4.50 of report.  The responses of support only relate to the Refer to ‘Consultations’ section of report – para. museum element and do not consider the 6.4.7 of report. full application proposals.  The community consultation undertaken Refer to ‘Consultations’ section of report – was very poor and there was no paras. 6.4.1 – 6.4.2 of report. engagement beyond presenting the plans. Table 2 – Summary of objections

7 POLICIES

7.1 Section 70(2) of the Town and Country Planning Act 1990 requires the Committee to have regard to the provisions of the development plan so far as material to the application; any local finance considerations, so far as material to the application; and any other material considerations. Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise. The development plan in Lambeth is the London Plan (2016, consolidated with alterations since 2011) and the Lambeth Local Plan (September 2015) and the South Bank and Waterloo neighbourhood development plan (‘the SoWNDP’) (October 2019). The material considerations must relate to matters which have a planning purpose. The question of what weight to give to material considerations is a matter for the Council. This includes the extent to which the proposed development does not accord with policies in the Lambeth Local Plan. .

7.2 The Draft London Plan was published on 1 December 2017 (updated August 2018) for consultation and will eventually supersede the current 2016 consolidated London Plan once the final version is published (anticipated late 2019). The Draft London Plan is a material consideration in planning decisions. The Examination in Public on the Draft London Plan was held between January and May 2019, and the Panel of Inspectors appointed by the Secretary of State have now issued their report and recommendations. This was made public on 21 October 2019. The recommendations contained within the Inspectors’ Report, in combination with the changes proposed by the Mayor during the examination process, give a good indication of the content of the final published version of the London Plan therefore the policies contained within the version as produced in July 2019 plus the recommendations within the Inspectors’ Report can now be given a significant amount of weight in planning decisions, although the current London Plan remains part of the development plan until the revised version has been adopted.

7.3 The Lambeth Local Plan is currently under partial review to ensure it complies with amendments to changes in the NPPF and London Plan. The Draft Revised Lambeth Local Plan underwent public consultation from October to December 2018 under Regulation 18 of the Town and Country Planning (Local Plans) (England) Regulations 2012. Pre-submission publication (Regulation 19) is anticipated in late 2019, early 2020. Officers consider that this should be afforded very limited weight at this stage.

7.4 The site falls within Kennington, Oval and Vauxhall (KOV) designated neighbourhood planning area. The designated KOV neighbourhood forum produced a draft version of their neighbourhood plan in March 2018 for pre-submission consultation. This document has extremely limited weight as a material consideration in decision-making at this time.

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

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

8 ASSESSMENT

8.1 Land Uses

8.1.1 The site lies within the Central Activities Zone (CAZ) and the VNEB London Plan Opportunity Area. Part of the site also lies within the South Bank House and Newport Street KIBA. The site is in areas of open space deficiency in relation to district and regional open space provision.

8.1.2 The site is designated as Site 10 – 8 Albert Embankment and land to the rear bounded by Lambeth High Street, Whitgift Street, the railway viaduct and Southbank House SE1 in the Lambeth Local Plan and the designation is proposed to remain in the Draft Revised Lambeth Local Plan. As defined by the allocation, the ‘preferred use’ for the site is the following:

'Retention/provision of an operational fire station. Mix of uses including residential and employment. Exceptionally, configuration of the site to include some residential within the KIBA boundary may be considered, if it can be demonstrated that this is necessary to achieve an acceptable scheme in all other respects. The amount of replacement employment should be maximised and should include space for small and medium enterprises'.

8.1.3 The allocation identifies the following design principles and key development considerations:

‘The site provides an opportunity to bring back into use these under-used and vacant premises. The council will support development on this site that:

(i) provides a sympathetic reuse of the listed buildings without radical alteration or extension; (ii) respects the silhouette of the head-quarters building as viewed from across the river; (iii) retains the ventilation obelisk on site; (iv) relates in height and bulk to the adjacent townscape taking into account the height, massing and scale of neighbouring buildings and the historic built form of the area; the heritage sensitivity of the site makes it inappropriate for tall building development; (v) ensures that 8 Albert Embankment continues to make a positive contribution to the townscape; (vi) makes sure both existing and new residential amenity is protected; (vii) focuses employment uses in and around the viaduct and Lambeth High Street; (viii) provides active frontages opposite the local centre on Black Prince Road and along Lambeth High Street; (ix) does not provide ground-floor residential uses on any part of the site; (x) provides public realm improvements to Albert Embankment, Lambeth High Street, Black Prince Road and Whitgift Street, to reduce traffic dominance and promote walking and cycling; (xi) maximises the amount of replacement employment and includes space for small and medium enterprises; (xii) provides a mixed and balanced community with an acceptable mix, tenure split/distribution of residential accommodation; (xiii) allows for the potential to connect to a future district-wide combined heat and power network'.

8.1.4 The site also lies within the Lambeth Gateway character as defined by Policy PN2, part (k). This sets out that development will be supported in the Lambeth Gateway that enhances the appearance and character of Albert Embankment, with active ground-floor frontages and an expanded range of employment and residential uses.

8.1.5 The proposal seeks to deliver 443 new homes, including 172 affordable homes (39% affordable by unit and 40% affordable by habitable rooms) alongside over 24,000sqm (GIA) of non-residential floorspace. The non-residential floorspace comprises:

 2,203sqm new fire station for LFB (Sui Generis);  1,434sqm LFB Museum (Use Class D1);  6,270sq.m hotel of up to 200 bedrooms (Use Class C1), including a 56sqm flexible retail or hotel space (Use Classes A1/A2/A3/A4/C1);  10,766sqm of new office and workshop floorspace, including: o 9,123sqm of corporate office floorspace (Use Class B1(a)); o 1,348sqm of medium workspace floorspace (Use Classes B1(a) / B1(b) / B1(c)); o 153sqm of small workspace floorspace (Use Classes B1(a) / B1(b) / B1(c)); o 142sqm of micro workspace floorspace (Use Classes B1(a) / B1(b) / B1(c));  455sqm flexible retail floorspace (Use Classes A1/A2/A3/A4);  173sqm flexible commercial unit (Use Classes A1/A2/A3/A4/B1(a)/B1(b)/B1(c)/D1/D2);  2,849sqm gym (Use Class D2); and  865sqm restaurant (Use Class A3).

8.1.6 The application includes a number of different types of commercial/retail and community premises. These uses would be accommodated in buildings on previously developed land that would make optimum use of the site.

8.1.7 In accordance with the ‘preferred use’ and design principles outlined in the site allocation (Policy PN2 Site 10), the proposed development:

1. Retains an operational fire station; 2. Provides a mix of residential and employment uses; 3. Maximises the amount of replacement employment floorspace and includes space for small 4. and medium enterprises; and 5. Activates Lambeth High Street and the land opposite Black Prince Road Local Centre through the provision of active uses.

8.1.8 As contemplated by Policy PN2 Site 10, the proposal includes residential within the KIBA boundary (Central and East Sites). For exceptional circumstances outlined in the section below, it is concluded that the inclusion of residential in these parts of the site is necessary to achieve an acceptable scheme in all other respects. Overall, the mix of uses and principle of development is therefore considered to be in accordance with planning policy.

8.1.9 The Council has followed the procedural requirements relating to applications which are departures (i.e. do not comply with the development plan policies) and the application has been advertised as a departure on the basis that it is not in accordance with design principle (iv) ‘relates in height and bulk to the adjacent townscape taking into account the height, massing and scale of neighbouring buildings and the historic built form of the area; the heritage sensitivity of the site makes it inappropriate for tall building development’ of site allocation 10. The principle of the proposed uses and the appropriateness of tall buildings on the site and their impact on heritage sensitivity is discussed in full below’. The outcome of this consultation is to be reported to the committee.

Fire Station

8.1.10 The re-provided operational fire station proposed would accord with the ‘preferred use’ identified in the site allocation. In addition to the site allocation, Policy S2, part (a) of the Local Plan advises that proposals for new or improved community premises will be supported where the site or buildings are appropriate for the intended use and accessible to the community, the facility does not harm the area's amenity and that the facility is designed to be flexible, adaptable and to maximise shared community use of the premises, where practical.

8.1.11 It is recognised that the site already accommodates a fire station. The proposal would provide a new and improved fire station within the northern part of the ground floor, comprising four of the seven appliance bays, public reception, community room, offices and equipment stores, with wash-down and practice areas behind. The new fire station has been designed to be flexible and adaptable and will house 24 firefighter gender-neutral rest rooms; a gym; lecture/TV area; kitchen; reception area and meeting room. A community room is proposed that will provide community engagement facilities adjacent to the pedestrian access to the fire station in line with the London Safety Plan 2017 which promotes a community ethos for all stations. The re-provided fire station is considered to be appropriate and will not harm the area's amenity in accordance with the requirements of Policy S2. Given its operational use requirements, it is accepted that it is not practical to share the fire station use with other community uses.

Museum and Gym

8.1.12 There is currently a temporary museum and other Class D1 uses housed within 'The Workshop' building on the Central site. It is proposed that this building will be demolished. The permanent use class of 'The Workshop' building is ‘sui generis’ as it was previously home to the research and development section of the London Fire Brigade before becoming vacant prior to its temporary use as Class D1 accommodation in 2016. It will revert back to the ‘sui generis’ use class in December 2019 when the temporary permission (ref. 16/03122/FUL) lapses. As such, it is not considered that the proposal would result in a loss of existing Class D1 uses on site, so there is no conflict in relation to Policy S1 of the Local Plan which seeks to safeguard existing community premises.

8.1.13 The proposal seeks to bring forward a new Class D1 unit (1,434sqm) for use as the LFB Museum. The other three appliance bays and southern extent of the ground floor will be incorporated into the new LFB Museum, to be separated from the operational appliance bays by a glazed screen enabling visitors both to learn about the history of the LFB and to also see a modern Fire Station in use. The Memorial Hall is proposed to be incorporated within the LFB Museum and will be accessible to visitors of the museum. The basement is proposed to be extended to provide the full LFB Museum, as well as plant space and access to the Central Site. A new Class D2 unit (2,053sqm) for use as a gym is also proposed at basement level with access being provided from ground level in the Central site.

8.1.14 The layout of the museum has been flexibly designed to allow a range of exhibition space configurations and includes facilities for school groups. The museum will support local education and public safety, as well as reinforcing the growing cultural destination in this part of the borough. The Museum will also help to extend the length of the area of more intensive tourist visitation along the South Bank, to the benefit of those parts further north. In conclusion, the proposed community facilities are considered to be acceptable and are flexibly designed and appropriately located within the site to maximise their use and minimise any harm to the amenities of the area in accordance with the requirements of Policy S2.

Hotel and Restaurant

8.1.15 The proposed hotel (C1) and restaurant (A3) uses are not identified within the site allocation but this does not preclude them in principle. Policy 4.5 of the London Plan indicates that within the CAZ strategically important hotel provision should be focussed on its opportunity areas, with smaller scale provision in CAZ fringe locations with good public transport (such as here). Further intensification of provision in areas of existing concentration should be resisted, except where this will not compromise local amenity or the balance of local land uses. The policy defines that 'strategically important hotel capacity' will depend on local circumstances, but typically comprises development exceeding 20,000m2 in Central London’.

8.1.16 Policy ED12 states that hotels (Class C1) will be supported in the CAZ and the VNEB OA. Part (a), (ii) of Policy ED12 explains that visitor accommodation must not unacceptably harm the balance and mix of uses in the area, including services for the local residential community. Further to this, paragraph 6.60 highlights that 'harm to the balance and mix of uses in an area will be assessed on a site by site basis, having regard to the characteristics of an individual locality, including existing concentrations of visitor accommodation, and the nature and scale of the proposed development’.

8.1.17 The principle of hotel use on the site is supported as it aligns with Policy ED12. Whilst the proposal is not large enough to classify as strategically significant in the context of Policy 4.5 of the London Plan, it would provide a large quantum of hotel accommodation in a part of the CAZ that is not wholly or predominantly residential in nature. It is not considered that that the application would cause harm to the balance and mix of uses in the area. As such, the hotel’s proposed location is considered to be acceptable in principle.

8.1.18 The proposed 865sqm restaurant is proposed on the top floor of the former LFB Headquarters Building and will be able to be accessed separately by the public without the need to stay or visit the hotel. Policy ED7, part (a) of the Local Plan identifies that evening and food and drink uses should be primarily located in town centres and the CAZ frontage. The site is not in a town centre or the CAZ frontage. However, paragraph 6.25 explains that such proposals will be acceptable elsewhere in the CAZ without the need for a sequential test, provided any impact on the identified CAZ frontages is carefully considered first. In addition, part (b) of the policy requires that such uses would not cause harm to community safety or the amenity of neighbouring residential areas and sensitive uses.

8.1.19 The proposed hotel, LFB museum and restaurant uses will assist in promoting tourism and providing visitor facilities in London, complementing the Mayor’s Culture Strategy and objectives set out in the London Plan. The hotel will also complement the proposed employment floorspace by providing visitor accommodation suitable for both business and leisure visitors. Similarly, the restaurant will provide an attractive new facility for both client entertainment and tourists alike. The proposals have been appropriately designed and located to ensure no adverse impact on the identified CAZ frontages or harm to community safety or the amenity of neighbouring residential areas and sensitive uses. As such, the hotel and restaurant uses are appropriate and in accordance with Council policy.

Office and Workspace

8.1.20 It is accepted that employment premises, including for small and medium enterprises, are supported by Site Allocation 10 and Policy PN2, part (k) of the Local Plan. The central and eastern parts of the site lie within the South Bank House and Newport Street KIBA.

8.1.21 Policy ED1 explains that 'development in KIBAs will be permitted only for business, industrial, storage and waste management uses, including green industries and other compatible industrial and commercial uses (excluding large scale retail) ancillary to, or providing for, the needs of the KIBA'. Policy ED3, part (a) supports offices greater than 1,000sqm in the CAZ and in London Plan Opportunity Areas. Policy PN2, part (k) also supports an expanded range of employment uses in the Lambeth Gateway area of Vauxhall, in which this site sits.

8.1.22 The proposals aim to create a new and much more substantial level of employment and commercial floorspace, delivering significant benefits to the local area in terms of job creation, services provision, place making and workspace units for MSMEs. The application proposes 10,766sqm of new office and workshop floorspace of which 9,123sqm would be as Class B1 (a) for a corporate office and the remaining 1,643sqm would be for medium, small and micro businesses (Class B1 (a)/(b)/(c)). At present, there is no existing Class B1 floorspace on the site, although the current uses on-site employ approximately 130 people associated with the Fire Station (93) and the temporary LFB Museum and Workshop (36) uses.

8.1.23 The proposed Class B1 elements have been designed specifically to create a cluster for creative and digital industries; from start-ups to established businesses, fostering both collaboration and innovation. Together, this employment space (including low cost medium and small workspaces and affordable micro workspaces) is anticipated to generate nearly 900 new jobs and will widen employment opportunities and support a diverse range of businesses. Including the other employment generating uses (i.e. the Fire Station, LFB Museum, hotel, retail, restaurant and gym), the proposal is anticipated to support approximately 1,264 jobs overall (including retaining all jobs associated with the Fire Station) and will provide a significant net gain in employment.

8.1.24 The proposed mix of employment uses has been designed to meet the needs of a wide range of occupiers whilst also creating a dynamic employment hub and strong sense of place to create a welcoming and engaging environment for employees, residents and visitors. The office provision has been designed to support a range of businesses with potential to accommodate anything from co- working facilities for small creative and cultural businesses and start-ups to larger employers looking for representation in this locality.

8.1.25 Medium, small and micro workspaces are to be delivered from the outset in units ranging in size from 20 to 428sqm NIA, greatly differentiating these units from the corporate office with floor plates of typically c.900sqm NIA. Each self-contained unit would have its own ‘front door’ onto the proposed public realm, capable of achieving increased occupier identity and lower service charge costs compared to the corporate office and which will further reduce the MSME’s total occupation costs. Whilst the fit-out of the workspaces will be subject to detailed design and occupier requirements, the design criteria are proposed to be secured by s106 legal agreement in any permission granted. This will ensure the proposed workspace is suitable for intended occupiers and meet market expectations.

8.1.26 The proposed office and workspace element of the scheme is supported by Policy ED1 in that it provides additional business floorspace in the KIBA. A large quantum of employment floorspace (including for small and medium enterprises) is proposed. This accords with the preferred uses in the site allocation and lies between the viaduct and Lambeth High Street and is consistent with (vii) of the design principles and key development considerations. It meets the desire of Policy PN2, part (k) for an expanded range of employment uses. The proposed space for smaller businesses also meets (xi) of the design principles and key development considerations. The proposal also accords with Policy ED3, part (a) as the site is located in the CAZ and VNEB OA areas where large office developments are supported. As such, the business uses proposed as part of the scheme are acceptable and would be in accordance with Planning Policy.

Affordable Workspace

8.1.27 Draft Policy E2 of the London Plan states that where more than 2,500sqm of Class B1 floorspace is proposed, the development should include flexible workspace or smaller units suitable to micro- businesses and SMEs. Policy ED2 of the Draft Review Lambeth Local Plan also states that proposals for business uses should incorporate a range of unit sizes and types that are well designed and flexible. The policy encourages applicants to explore opportunities for the long term management of the units by a company specialising in managing space for small businesses. It also seeks that in major office developments in Waterloo and Vauxhall, 10 percent of Class B1 floorspace should be provided at 50 percent of market rents for a period of 15 years. This policy has limited weight at this stage. It should also be noted that the direction of travel for this policy is likely to limit the requirement for affordable workspace to the provision of Class B1a floorspace only.

8.1.28 Following dialogue with creatives and start-ups which are currently housed in the Workshop, the subsidised micro workspaces are to be provided at an initial discounted rent of £15/sq. ft., with annual indexation for the first 15 years. In order to ensure that 10% of the B1 floorspace will be provided at low cost, two medium workspaces are also proposed to be provided at no more than 50% of the estimated rental value (ERV) of the corporate offices for the first 15 years following practical completion. The current ERV of the small and medium workspace units combined with the micro workspace discounted units equates to an average rent of £25.76/sq. ft. This is 46% less than the ERV of the corporate office of £56.08/sq. ft. The proposed rental levels would be secured by s106 legal agreement in any permission granted.

8.1.29 Providing distinct and attractive self-contained units accessed directly from the public realm is central to the proposed place making strategy; it allows for more affordable and flexible tenure arrangements, with units having been designed to meet MSMEs’ requirements from the outset rather than retro-fitted – and the approach adopted does not reduce the level of affordable housing that can viably be delivered.

8.1.30 Notwithstanding the limited weight of the emerging policy, the application proposes 20% of the floorspace to be brought forward as affordable at an average discount rent of 46%. The quantum of floorspace is double the emerging policy requirement and is welcomed, even though the overall discount rate is slightly lower than the proposed requirement.

Flexible Commercial/Retail

8.1.31 The application proposes 3 flexible ground floor units/areas as part of the development:

(i) 455sqm of flexible retail floorspace (Use Classes A1/A2/A3/A4) within the central part of the site; (ii) 173sqm flexible commercial unit (Use Classes A1/A2/A3/A4/B1(a)/B1(b)/B1(c)/ D1/D2) on the eastern part of the site; and (iii) 56sqm flexible retail or hotel space (Use Classes A1/A2/A3/A4/C1) on the western part of the site to be used either by an independent operator or incorporated as ancillary hotel lobby space.

8.1.32 With regards to Class A1/A2 uses, Policy ED6 of the Local Plan explains that the primary location for such uses should be in town centres and the CAZ frontage. As per paragraph 6.25 of the supporting text, such proposals will be acceptable elsewhere in the CAZ without the need for a sequential test, provided any impact on the identified CAZ frontages is carefully considered first.

8.1.33 With regards to Class A3/A4 uses, Policy ED7 is also relevant. As with Policy ED6, part (a), Policy ED7, part (a) makes clear that the primary location for evening and food and drink uses should be in town centres and the CAZ frontage. Policy ED7, part (b) further requires that such uses would not cause harm to community safety or the amenity of neighbouring residential areas and sensitive uses.

8.1.34 The proposals have been appropriately designed and located to ensure no adverse impact on the identified CAZ frontages or harm to community safety or the amenity of neighbouring residential areas and sensitive uses. As such, the possible A1/A2/A3/A4 uses would be appropriate and in accordance with Council policy.

8.1.35 With regards to possible B1 class floorspace, such an inclusion would be supported by Policy ED1, which identifies that KIBAs are appropriate locations for such uses. Such floorspace would also accord with the aim of the stated preferred uses in the Site 10 allocation that seeks space for small and medium enterprises.

8.1.36 The proposed flexible commercial/retail and Class D1/D2 units in the central and western parts of the site accord with the aim of having active ground-floor frontages as expressed in Policy PN2, part (k) in this area of Vauxhall. The flexible unit in the central site would provide an active frontage on Lambeth High Street and the flexible unit on the eastern section of the site would provide an active frontage opposite the local centre on Black Prince Road. These elements are in accordance with (viii) of the design principles and key development considerations.

Housing

8.1.37 The site allocation supports residential development in principle. The application proposes 443 new residential units on the site of which 348 units would be brought forward in the KIBA boundary. In accordance with the wording in the site allocation policy, there is a requirement to consider whether the configuration of the site is necessary to achieve an acceptable scheme in all other respects. The applicant is also required to demonstrate that the replacement floorspace has been maximised.

8.1.38 Two of the three parts of the site (the Central and East Sites) are located within the KIBA. Land use alternatives, testing employment-only uses on the KIBA sites versus a mixed-use approach, have been considered with the applicants This testing concluded that a mixed-use approach blending residential and employment across the three sites delivers the significant overall planning benefits of a wider range of jobs, more housing (including affordable), an enhanced public realm and significant additional heritage benefits as compared with an alternative scheme with employment only within the KIBA - achieving an “acceptable scheme in all other respects” as established by Policy PN2 Site 10.

8.1.39 The most recent KIBA review was undertaken in October 2018. This concludes that the Southbank House and Newport Street KIBA (containing the central and east sites) should be protected in its current form and no alterations to the KIBA boundary are proposed. In assessing the potential of the KIBA to meet future demand for employment land/business floorspace, the KIBA review notes (at page 126) that, whilst the preferred use is set out at Policy PN2 Site 10, the potential of the Central and East Sites (referred to as parcels 2 and 3) to meet the demand for employment uses will depend “on the outcome of this proposal” - raising the question of whether there is a good prospect of an application coming forward for KIBA only uses within the Central and East Sites.

8.1.40 Acknowledging the changes in the demand for land, the NPPF (Para. 120) notes that where there is no reasonable prospect of an application coming forward for the allocated use, applications for alternative uses should be supported where the propose use would “contribute to meeting an unmet need for development in the area”. The NPPF recognises the value of using suitable brownfield land within settlements “for homes and other identified needs” and specifically supports the development of “under-utilised land and buildings, especially if this would help to meet identified needs for housing where land is constrained and available sites could be used more effectively” (Para. 118). Housing need within Vauxhall, and the need to secure more balanced and mixed-use communities, is specifically identified in Policy PN2, part (n) of the Local Plan.

8.1.41 The proposal seeks to ensure compliance with local planning policies, including Policy ED1 relating to the protection of KIBAs. The site allocation policy does not, in itself, preclude residential development but, rather, notes that residential uses within the KIBA boundary may be possible where it is demonstrated that it is necessary to “achieve an acceptable scheme in all other respects”.

8.1.42 In line with the key development principles for the site, as set out above, the proposal achieves the following:

1. The provision of a mixed and balanced community with an acceptable mix, tenure split/distribution of residential accommodation; 2. Provision of active frontages opposite the Black Prince Road Local Centre and along Lambeth High Street; 3. Protection of residential amenity; 4. Focus of employment uses in and around the viaduct and Lambeth High Street; and 5. Maximising the amount of replacement employment and provision of space for small and medium sized enterprises.

8.1.43 Along with re-providing the fire station, these are objectives that the development proposal achieves; by balancing maximisation of replacement employment floorspace provision against meeting other policy objectives. They are also objectives that would be difficult to achieve if, as noted by Policy PN2, part (o), buildings within the designated KIBA (the Central and East Sites) were proposed to be for a single land use. Furthermore, the principle of mixed-use development incorporating residential units on this site has already been accepted by the Appeal Inspector as appropriate in the Native Land appeal (ref. 10/04473/FUL) and is strongly encouraged by the NPPF, London Plan and CAZ SPG. To ensure a comprehensive approach is applied, an assessment of alternatives has been undertaken including the following:

1. Industrial - Conventional Class B2/B8 industrial spaces on the KIBA parts of the site (Central and East) with all residential use outside the KIBA on the west site; 2. Office - Accommodating a large office building within the Central Site and mixed-uses on the West and East Sites; 3. Tall Building Office - With a mix of office and residential accommodation provided on the KIBA sites. 4. Office and Light Industrial - Providing hybrid employment floorspace on the KIBA sites through a mix of combination of Class B1 office space and Class B2/B8 light industrial space; 5. Alternative Use Value (AUV) - With new office buildings on the West, Central and East Sites together with the conversion of the Former Headquarters Building to provide a fire station and additional office floorspace; and 6. Mixed-use - with employment and residential planned across each of the three sites.

8.1.44 The alternatives set out above were also compared with the previous inquiry scheme, judged by the Appeal Inspector as acceptable in land-use terms, albeit rejected for its adverse impacts on neighbouring properties on daylight/sunlight grounds. Each alternative was considered for its employment potential (both within the KIBA and overall), its provision of housing including on-site affordable, its impact on the daylight/sunlight of neighbours and its heritage and public realm potential.

8.1.45 An alternative scheme for assessment of AUV has been agreed with the applicant and the GLA in consultation with the Council’s Viability Consultants, BNP Paribas, purely for financial viability assessment purposes. This has been agreed on the basis that an Existing Use Value (EUV) plus a premium model would not have been an appropriate approach for this scheme/site and would not incentivise the landowner to release the site for development. This is set out in more detail and justified in the Financial Viability Assessment (FVA) submitted.

8.1.46 Whilst it does provide an increased theoretical employment level as compared to alternatives, an EUV approach fails to realise the most beneficial redevelopment potential of the site (and thus does not deliver an efficient use of the land as required under the NPPF) by not delivering or maximising other required important planning requirements for mixed-use development (including substantial new housing (with affordable housing), culture, community services, public realm and permeability, and place making) which can all be provided through the high quality mixed-use redevelopment of the site.

8.1.47 Compared to alternatives, the proposed approach will deliver a wider range of community, place making, economic and employment benefits. In part, this package of benefits is capable of being delivered due to the increased viability of the proposed mixed-use approach compared to alternatives. The mixed-use approach and improved viability assists in:

1 Supporting a wider range of employment opportunities and including an employment hub which will support innovation - particularly with purpose-built smaller units for the needs of creative and cultural businesses, including low-cost and affordable employment space; 2 Additional new homes, including an overall on-site affordable provision (39% based on units) substantially greater than that of the appeal inquiry scheme (7%); 3 Additional public realm provision of over 1,900sqm, enhanced connectivity and the provision of a new London Fire Brigade Museum (over three times the area within the Native Land appeal scheme); 4 The full restoration of the Grade II Listed 8 Albert Embankment and its Drill Tower, enhancements to their settings, to the setting of the adjacent Southbank House building and to the conservation area; 5 The delivery of a LFB Museum, consistent with the Mayors’ Culture Strategy (2018); 6 The creation of a new urban quarter with residential and commercial activity through the day and evening, increasing safety, securing, way-finding and sense of place; and 7 Making the efficient use of land and creation of a more balanced and mixed-use community, as required by the NPPF and set out in the Vauxhall SPD and Policy PN2 of the Local Plan.

8.1.48 Together, these provide the ‘exceptional circumstances’ referred to within the Site 10 allocation and support the continued regeneration within the Opportunity Area and CAZ. In addition, the proposals also provide significant ‘public benefits’ which include:  Heritage – the restoration of two underused listed buildings, including partial re-use for original purposes, preserving the significance of the buildings in terms of their historic purposes and association and securing the buildings’ long-term future;  New Fire Station and Emergency Base – the creation of a new modern ‘fit for purpose’ firefighting and emergency services base for central London in a strategic location to achieve fast response times to increasingly-regular emergency incidents;  Museum – the creation of a permanent home for the London Fire Brigade museum, at its original site, resulting in educational and cultural benefits to the locality and wider London;  New Homes - delivery of new housing, including 40% affordable housing (39% based on units);  New and Diverse Employment Opportunities – the creation of space for approximately 1,264 on- site jobs across a range of sectors (including medium, small and micro workspaces well suited to small creative and cultural businesses and start-ups) and creation of additional jobs during construction and from associated resident and occupier expenditure;  Public Realm - enhancements to public realm and way finding, including through provision of around 1,900sqm of high quality, permeable public realm (currently the site does not provide any public realm and the appeal scheme provided less than 600sqm); and

8.1.49 In summary, it is considered that in this exceptional case, the inclusion of residential units in the KIBA as proposed is acceptable, given the wording of the site allocation and the above public benefits that would be secured. The proposal would bring forward 443 new residential units (C3), which would help to increase the supply of housing in the borough and in this part of Vauxhall and as such would accord with the aims of Policy H1 of the Local Plan.

Affordable Housing and Housing Mix

8.1.50 Policy 3.13 of the London Plan and Policy H2 of the Local Plan require affordable housing for schemes of 10 or more units, with a mix of tenures being required in the interests of balanced and mixed communities. The Local Plan has a target of 50% affordable housing where public subsidy is available (or 40% on sites where there is no public subsidy), with a 70:30 split between social/ affordable rent and intermediate tenure. In considering the nature of the affordable housing sought under Policy H2, the council will need to take into account: (i) the specific circumstances of individual sites, including development viability, (ii) the characteristics of an area, the site and type of development proposed and (iii) the impact on mixed and balanced communities within a local neighbourhood.

8.1.51 The London Affordable Housing and Viability SPG (2017) establishes the ‘fast track’ and ‘viability tested’ routes for assessing affordable housing provision, requiring that planning applications that provide less than 35% are supported by a Financial Viability Assessment (FVA). The SPG promotes the delivery of a range of tenures, including at least 30% low cost rent (social rent or affordable rent) and at least 30% as intermediate products (with London Living Rent and/or shared ownership being the default tenures).

8.1.52 Policy 3.11 of the London Plan gives priority to family sized housing in the affordable tenure and Policy H4 of the Local Plan suggests that for new housing, a balanced mix, including family housing, should be provided for market housing. Affordable housing should reflect a mix not more than 20% 1 bed, 20-50% 2 bed and 40% 3 bed units.

8.1.53 The revised development proposes 172 affordable units (equal to 39% affordable by unit and 40% affordable by habitable rooms) out of 443 units, with a tenure split of 82 shared ownership (equal to 19% by unit and 15% by habitable room) to 90 affordable/social rented (equal to 20% by unit and 25% by habitable room). This 70:30 split between social/ affordable rent and intermediate tenure as shown in Table 3 – Housing Mix and Table 4 – Percentage Tenure Mix below.

Tenure Studio 1 bed 2 bed 3 bed Total

Market 26 152 82 11 271

% Mix (market) 10% 56% 30% 4% 100%

Affordable housing 21 46 15 0 82 (shared Ownership)

Affordable Housing 0 30 52 8 90 (Affordable/Social Rent) Affordable (Total) 21 76 67 8 172

% Mix (affordable) 12% 44% 39% 5% 100%

Total units 47 228 149 19 443

% Mix (total) 11% 51% 34% 4% 100%

Table 3 - Housing mix

Tenure Total units % of Total % of Affordable % of Affordable Housing Housing (by unit) (by hab. room) Private flats 271 61% N/A N/A

Affordable/ 90 20% 52% 62% Social rent Shared 82 19% 48% 38% ownership Table 4 - Percentage tenure mix

8.1.54 As explained in the accompanying FVA undertaken by JLL, the proposed development has been identified for Marginal Viability Funding through the Government’s Housing Infrastructure Fund (HIF) of approximately £10m. Designed to deliver new infrastructure to support the delivery of housing, the funding would assist in unlocking the redevelopment potential of the site if awarded. The proposal also qualifies for additional affordable housing grant from the GLA of £1.26m.

8.1.55 The FVA concludes that the “viable” level of affordable housing for the proposed scheme is 127 units and the scheme is unable to support any further affordable housing beyond 31% on a habitable room basis or 29% on a unit basis. It assesses the viability of the proposals and abnormal costs associated with the development, including the provision of Lambeth Fire Station and the works associated with the conversion and restoration of the site’s heritage assets.

8.1.56 At 172 units, the amended scheme proposes an additional 45 affordable housing units to the “viable” level of affordable housing and is a very significant uplift in affordable housing beyond that which was considered acceptable previously, providing an additional 153 affordable homes compared to the Native Land appeal scheme (19 units). Notwithstanding the different policy basis at that time, the Appeal Inspector concluded that the affordable housing provision was acceptable when taking into account the other important land use objectives for the site and viability.

8.1.57 As stated in the Mayor’s Affordable Housing and Viability SPG, the ‘existing use value plus’ (EUV+) approach to determining the benchmark land value is usually the most appropriate for planning purposes; however, an alternative approach may be considered in exceptional circumstances, where robustly justified. The principle of an ‘alternative use value’ (AUV) approach has been agreed, since the existing use as a fire station (Sui Generis) means that there is not a quantifiable market for the site.

8.1.58 Despite the inclusion of grant funding, the applicant’s current affordable housing offer is not supported by a commercial appraisal of viability and adopts an AUV appraisal approach based on a policy compliant scheme to determine the benchmark land value. The applicants are, however, willing to deliver the scheme on the basis of 40% of the habitable rooms comprising affordable housing on the basis of hope value.

8.1.59 BNPP’s review of the FVA includes an AUV appraisal (the benchmark land value) that generates a residual land value of £42,777,129. This is the minimum land value that, in principle, the application scheme needs to generate to be considered viable. As a result of the increase in affordable housing to 40%, BNPP’s appraisal of the application scheme generates a residual land value of £39,852,481 which is lower than their benchmark land value of £42,777,129. If GLA grant funding amounting to £1,260,000 is included in the appraisal, the residual land value increases to £40,923,959, which is marginally closer to their benchmark land value of £42,777,129, but still lower. The benchmark land value has been accepted by the applicants and BNPP have concluded that the offer of 40% affordable housing made can be considered the maximum reasonable proportion of affordable housing that the scheme can currently provide.

8.1.60 The affordable housing mix has been developed in collaboration with Notting Hill Genesis (NHG). NHG has specifically highlighted the demand for 1-bedroom and 2-bedroom units within the Borough, resulting in the proposed affordable housing split limiting the number of larger units. The overall split within the affordable housing element would be 62:38 between social/ affordable rent and intermediate tenure based on habitable rooms or 52:48 based on units.

8.1.61 The proposal will assist in delivering a significant number of new homes, helping to achieve the housing delivery targets set out in the Lambeth Local Plan and the London Plan. Whilst the proposal does not provide a fully policy compliant mix of tenure, it incorporates a good range of dwelling types and tenures and an appropriate mix of housing that has been viability tested. The market and shared ownership units provide mainly 1 and 2 bedroom units, which is supported in this central location, and allows greater affordability. The emphasis on larger 2 bedroom (four person) and 3 bedroom units for the affordable housing overall (this accounts for 44% of the total) is particularly positive and meets local housing needs particularly based on the 2017 Strategic Housing Market Assessment and the draft review Local Plan policy on dwelling mix.

8.1.62 Should the application receive planning permission, the requirement for an early stage viability review will be triggered if an agreed level of progress on implementation is not made within two years of the permission being granted, as set out in the Mayor’s Affordable Housing and Viability SPG and Lambeth Development Viability SPD; as well as a late stage viability review when 75% of the homes are sold/occupied. Further reviews may be necessary subject to phasing, and early delivery of affordable housing in relation to market units should be secured.

8.1.63 The affordable housing provision has been developed in discussion with Notting Hill Genesis, which has provided a supporting statement confirming that the social/affordable rent units would be delivered in line with Lambeth’s Tenancy Strategy. This means that 1 and 2 bedroom units would have rents capped at Local Housing Allowance, whilst three bedroom units would be offered at Target Rent levels, to be secured in any section 106 agreement.

8.1.64 The affordability of intermediate shared ownership units must be in accordance with the Mayor’s qualifying income levels, as set out in the Affordable Housing and Viability SPG and the London Plan Annual Monitoring Report, including a range of income thresholds. Following dialogue with the Council, it is proposed that ten homes will be affordable to household incomes of £60,000, with tiered affordability levels on the remaining homes up to the maximum cap of £90,000. Affordability thresholds would be secured in any section 106 agreement’.

8.2 Design and Conservation

8.2.1 Good design is central to all objectives of the London Plan and Lambeth Local Plan planning policies. Policy 7.1 of the London Plan sets out a series of overarching design principles for development in London. Policies 7.2, 7.4, 7.5 and 7.6 require that all new development be of high quality that responds to the surrounding context and enhances the character, legibility, permeability and accessibility of the surrounding neighbourhood. Policy 7.7 relates to the specific design issues associated with tall and large-scale buildings. The Mayor's London View Management Framework SPG (2012) identifies 27 strategic views in London for protection and management.

8.2.2 Policies Q5 and Q7 seek to create high quality urban environments and state that proposals will be supported where the design of development is a response to positive aspects of the local context and historic character.

8.2.3 The Vauxhall Nine Elms Battersea Opportunity Area Planning Framework came into force in March 2012, prepared by the GLA in partnership with LBs Lambeth and Wandsworth, the London Development Agency (LDA), Transport for London and Historic England. It sets out the vision and the policies to support the development of a new London quarter in this key area of central London. The Framework notes the broad parameters of acceptable development for tall buildings on the Albert Embankment, in terms of height and positioning on key sites along strategic routes. It highlights the importance of tall buildings having a positive relationship with the surrounding townscape. It also stresses that all tall buildings proposals should be accompanied by an assessment of impact on the Westminster World Heritage Site.

8.2.4 At a more local level, the Council has sought significant development in the area covered by the Vauxhall SPD (2013), which translates the objectives of the VNEB OAPF into a localised level of detail. The site at 8 Albert Embankment occupies a central location in that area, connecting the character areas of Lambeth Gateway and Central Embankment and providing a link between Lambeth High Street, Albert Embankment and Newport Street. The Vauxhall SPD encourages the mix and concentration of uses to strengthen the function of Black Prince Road Local Centre. Figure 5.12 identifies the West and Central Sites as being suitable for both residential and employment uses.

8.2.5 In respect of the opportunity for taller buildings to establish a suitable and varied skyline in the context of the long-term presence of standard building heights along the Embankment, Paragraph 4.914 of the Vauxhall SPD notes that “the Council suggests that this is best achieved (in the absence of any GLA density controls), by assuming a plot coverage of no more than 40% can be taken to the full height of the 80-90 metre zone. This will always ensure that there is a separation between towers and that the objective of a varied and interesting skyline is achieved”. The SPD notes that “proposals for the Fire Station will need to be carefully considered given the special character and visibility of the riverside” (Para. 5.12).

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

1. Demolition 2. Scale, massing, layout and appearance 3. Impact on heritage assets 4. Strategic and Local Views 5. Assessment of harm versus benefits

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

8.2.8 The site includes the Grade II listed building at 8 Albert Embankment and its former drill tower (separately listed at Grade II), and the land occupied by the former London Fire Commissioner workshops to the rear, bordered by Lambeth High Street to the west, Whitgift Street to the north and the railway viaduct to the east. The site borders the Grade II listed Southbank House (former Royal Doulton building, 1878) to the south.

8.2.9 The former fire brigade headquarters building dates from 1937 and was designed by EP Wheeler for the London County Council. It was part of a complex that incorporated the administrative headquarters of London firefighting, residential quarters, a working fire station with a range of staff facilities, a drill parade ground, a drill tower and a training school and maintenance workshops at the rear. Its significance lies principally in its landmark modern design and streamlined form; its important sculptural reliefs by Gilbert Bayes; and its historic role as the headquarters of the London Fire Brigade, the most important nationally and third largest in the world at the time.

8.2.10 The listed building has been compromised by an insensitive 1980s rear extension, known as the CMC Building. To the rear, across Lambeth High Street, are former workshops and a training school contained within large and low brick buildings. These are identified in the List entry (2009) as being of no special interest. The development site is contained within Albert Embankment Conservation Area, which occupies a stretch of river frontage on the Lambeth side from Westminster Bridge to Vauxhall Bridge. The Albert Embankment itself and the listed buildings associated with the fire station and the Victorian Southbank House form the principal character of the conservation area within the development site. The unlisted former training school and maintenance workshops have a degree of historic and architectural significance and were identified within the Albert Embankment Conservation Area, Conservation Area Character Appraisal (May 2017) as being a positive contributor to the conservation area.

Demolition

8.2.11 The 1980s CMC rear extension building will be demolished and replaced. The former training school and maintenance workshops to the rear are also proposed for demolition and will be replaced with a series of new buildings and associated landscaping. The Obelisk, which was built in 1940 as a ventilation shaft for the underground bunker intended to be used during the Second World War but was never used for this purpose and remains unused, is proposed to be removed and re-provided within the proposed Central Square public realm area. The Drill Tower is also proposed to be remodelled through partial demolition and alterations to facilitate connection with the new building and allow its continued use by LFB for operational training purposes.

8.2.12 The CMC rear extension building is a negative feature within the setting of the conservation area and no objection is therefore raised to its removal. Whilst the Workshops have been identified with the 2017 Conservation Area Character Appraisal as making a positive contribution to the conservation area, no objection is raised to the demolition of this building and its replacement with high quality mixed-use buildings and public realm to the benefit of the conservation area. The removal and re- provision of the Obelisk within a prominent part of the Central Site for its original use (as a ventilation shaft), where it will be visible to the public assists with way-finding from across the site and provide a physical and long-term link to the site’s historical association with LFB. This is supported and will impact positively on the conservation area. Similarly, the partial demolition works to the drill tower, with the changes predominantly relating to the ground and first floors of the tower, in connection with its full restoration, is also supported as it will enhance its settings making a positive contribution to the conservation area.

Scale, massing, layout and appearance

8.2.13 The existing site is physically constrained and in an area of high-density development that raises significant redevelopment challenges. The majority of the west parcel is occupied by listed buildings, with existing residential amenity considerations to the south; the central site is bounded by a railway viaduct to the east, and with existing residential amenity considerations to the north (of which daylight/sunlight impacts were given as the reason the Inspector dismissed the Appeal scheme); and the east parcel is bounded on the north and west sides by vehicular access to commercial uses in the railway viaduct arches.

8.2.14 The existing Former Headquarters Building is a very impressive building of great dignity and formality. It sits comfortably in the townscape with spaces to each side. The fine detailing, proportions and massing are all very carefully considered. The roof top is very carefully handled with the central and flanking ‘pavilion’ features. There is much good detailing – grilles, doors, brickwork, carving, mouldings, fenestration etc. The flanks are treated as well as the façade and are important elements in views from Albert Embankment, the river and the opposite side of the river. The rear elevation is a little more utilitarian but has much architectural and historic interest – it is largely intact and its form and treatment reflects practical requirements when the buildings was designed. The massing, tiered balconies and solidity of the forms are of particularly importance.

8.2.15 The design of the West Site is led by the heritage context of the site, principally the Grade II listed Former Headquarters Building, the Grade II listed Drill Tower and nearby Southbank House; which together influence the detailed design and massing of the proposed buildings. The bulk, massing and footprint of the existing CMC building has influenced the design of the West Site, informing the location of the proposed new hotel extension building which has been stepped back to respect the Grade II listed Southbank House. Whilst the CMC building is currently listed (in view of its connection to the Former Headquarters Building and location within its curtilage) Historic England’s listing description for the building (referred to as Lambeth Fire Station) notes that the “1980s rear extension is not of special interest”. At present, the CMC building clearly detracts from the setting of both the Fire Brigade Headquarters and Southbank House, obscuring views of the buildings from the west end of Black Prince Road and creating an abrupt junction between Lambeth High Street and Black Prince Road. It also detracts from the character of the Albert Embankment Conservation Area.

8.2.16 The replacement fire station is proposed to be created through both a partial change of use within the Former Headquarters Building and a new build component located to the north of the Fire Brigade Headquarters, spanning east to west from Albert Embankment to Lambeth High Street and partially screening the large blank wall of the adjoining International Maritime Organisation building. It comprises a stepped building ranging from 1 to 4 storeys. The location of the building and its set back frontage aim to complement the Former Headquarters Building, ensuring that the new building will be subordinate to it and will leave clear views through from the River Thames to the listed Drill Tower.

8.2.17 The new Fire Station is proposed to be linked from ground to second floor level with the listed Drill Tower and will be connected to the main listed building. To facilitate these linkages, the Obelisk is proposed to be removed and re-provided within Central Square. The Drill Tower is proposed to be remodelled through partial demolition and alterations to facilitate connection with the new building and allow its continued use by the LFB for operational training purposes. The changes predominantly relate to the ground and first floors of the tower, with internal and more minor external fenestration alterations proposed to floors three to nine. The lower levels of the new building will be comprised of brick, with the upper levels employing perforated metal screening and glazing. This choice of materials has been informed by the character of the surrounding area and seeks to complement the setting of the Former Headquarters Building. Furthermore, the ‘light touch’ approach to materials aims to contrast with the solid masonry of the listed building and adjoining Drill Tower.

8.2.18 The Former Headquarters Building will be repurposed through a change of use and alterations. It will host part of the replacement fire station, 73 residential units, a new rooftop restaurant and part of the LFB Museum. The fire station is proposed to use the northern part of the ground floor, comprising four of the seven existing appliance bays, housing the appliance bays, public reception, community room, offices and equipment stores, with wash-down and practice areas behind. The other three appliance bays and southern extent of the ground floor will be incorporated into the new LFB Museum, to be separated from the operational appliance bays by a glazed screen enabling visitors both to learn about the history of the LFB and to also see a modern Fire Station in use. The Memorial Hall is proposed to be incorporated within the LFB Museum and will be accessible to visitors of the museum. The basement is proposed to be extended to provide the full LFB Museum, as well as plant space and access to the Central Site. Figure 4 and Figure 5 below show the proposal as viewed from the opposite side of the River Thames and Figure 6 below shows the extended Former Headquarters Building as viewed from Albert Embankment.

Figure 4 – Proposed view of development from Millbank

Figure 5 – Proposed view of development from opposite side of River Thames

Figure 6 – Extended Former Headquarters Building as viewed from Albert Embankment

8.2.19 A new 10 storey and roughly L-shaped building is proposed to be constructed in place of the CMC building to house the hotel, part of the LFB museum, part of the restaurant and 22 residential units. The new building takes its scale and proportions from the listed Former Fire Brigade Headquarters. It is proposed to be set back from Black Prince Road and Lambeth High Street, thereby improving the setting of both the Former Headquarters Building and Southbank House and allowing for the creation of a more inviting and open public realm visible to the Embankment and acting as the key entry to the wider scheme. The choice of materials (including brick and glazing) complement the Former Headquarters Building, with the horizontal emphasis and alignment of fenestration being retained and with the detailing of the building being designed to be subordinate to the Former Headquarters Building.

8.2.20 The upper floors will house a hotel lounge and conference room. A bridge link would connect to the proposed single storey restaurant extension above the main headquarters building. The glazed restaurant extension is designed to be lightweight and subordinate to the Former Headquarters Building, whilst including an ancillary bar and café (at mezzanine level). The glazed extension respects the host building and responds to both the mixed character of Albert Embankment and local heritage.

8.2.21 At ground floor level, a flexible unit for retail or hotel use (Use Classes A1/A2/A3/A4/C1) is proposed on Lambeth High Street. Located adjacent to the hotel entrance it will activate the west side of the high street and could be occupied by either an independent operator or incorporated as ancillary hotel lobby space.

8.2.22 The Central Site proposes four new buildings: (1) a 26-storey building (known as the Central Square Building) providing 151 new homes and a mix of uses; (2) a stepped 8-10 storey office and workspace building (known as the office building) with mixed ground floor uses; (3) a 24-storey building (known as the Eastern Garden Building) providing 140 new homes above a mix of uses; and (4) a 5-storey residential building (known as the Whitgift Street Building), stepped from 4-storeys fronting Whitgift Street and providing 27 new homes.

8.2.23 The elevations of the two tallest buildings on the Central Site are formed of glazing and muted grey infill panels, which respond to LVMF view requirements (as discussed below). The diamond plan form of the buildings creates very slender massing in some views, with expanding massing as views are rotated; however, the greater massing in some views is mitigated to a certain degree by the lightness of the cladding materials.

Figure 7 – Proposal as viewed from Lambeth High Street / junction with Old Paradise Street

Figure 8 – Proposal as Viewed from Whitgift Street looking east

Figure 9 – Proposal as Viewed from Whitgift Street looking east

Figure 10 – Proposal as Viewed from Whitgift Street looking west

Figure 11 – Proposal as Viewed from Old Paradise Gardens

8.2.24 The design of the Central Site responds to the surrounding heritage assets and residential buildings, including daylight and sunlight impacts on surrounding proposals (as discussed below). This approach arises from the selected diamond plan form of the taller buildings and the lower height and setback of the Whitgift Street Building and Office Building.

8.2.25 Figures 7 - 11 above show the proposal as viewed from Lambeth High Street, Whitgift Street and Whitgift Street Park (Old Paradise Gardens).

8.2.26 Annex 11 of the Local Plan (taken from the Lambeth Tall Buildings Study 2014) identifies that the entire Vauxhall SPD Area falls within a location identified as being ‘sensitive’ to tall buildings, the design principles for the site (PN2 Site 10) state that the “heritage sensitivity of the site makes it inappropriate for tall building development” (criteria iv). The proposal has therefore been advertised as a departure from the local plan on this basis. Notwithstanding this, criterion ii) requires that any proposed development respects the silhouette of the headquarters building as viewed from across the river, intimating that taller buildings may be acceptable subject to heritage assessment. Informed by the shortcomings of the Appeal Scheme, this criterion is a central objective of the proposal.

8.2.27 Policy 7.7 of the London Plan encourages a plan-led approach to the location of tall buildings and generally supports tall buildings within the CAZ, Opportunity Areas and areas that have good access to public transport (Part C, Criterion a). It notes that the impact of tall buildings in sensitive locations (including conservation areas and in the setting of listed buildings) should be given particular consideration. The policy encourages urban design analysis to demonstrate that proposals for tall buildings form part of a strategy and identifies a number of criteria that tall buildings should meet, including:

1 Only be considered in areas whose character would not be affected adversely by the scale, mass or bulk of a tall or large building. 2 Relating well to the form, proportion, composition, scale and character of surrounding buildings, urban grain and public realm (including landscape features), particularly at street level. 3 Individually or as a group, improve the legibility of an area, by emphasising a point of civic or visual significance where appropriate, and enhance the skyline and image of London. 4 Incorporate the highest standards of architecture and materials, including sustainable design and construction practices. 5 Incorporate publicly accessible areas on the upper floors, where appropriate. 6 Have ground floor activities that provide a positive relationship to the surrounding streets. 7 Contribute to improving the permeability of the site and wider area, where possible. 8 Incorporate publicly accessible areas on the upper floors, where appropriate. 9 Make a significant contribution to local regeneration. 10 Not adversely affect their surroundings in terms of microclimate, wind turbulence, overshadowing, noise, reflected glare, aviation, navigation and telecommunication interference. 11 Not adversely impact on local or strategic views.

8.2.28 Policy Q26 of the Local Plan provides local level guidance on the location of tall buildings and their design, requiring them to: achieve design excellence; make a positive contribution to the townscape and skyline; be of the highest standard of architecture and design; and have no adverse impacts on the significance of strategic or local views or heritage assets including their settings.

8.2.29 The site falls within the Vauxhall SPD and VNEB OAPF. Guidance from both recognises the potential for taller buildings on the site and, more generally, along Albert Embankment and establishes a plan-led approach to the provision of new tall buildings. Indeed, the VNEB OAPF anticipates taller buildings along Albert Embankment of up to 80-90m in height. The Vauxhall and Albert Embankment Tall Buildings Assessment (2018) also assesses building heights against a maximum AOD height of 90m. The tallest proposed buildings are the Central Square Building and Eastern Garden Building and are below the maximum height identified with heights of 88.62m AOD and 81.64m AOD, respectively. Both the SPD and OAPF require that tall buildings contribute towards the creation of a varied skyline and avoid appearing cumulatively as a “uniform wall of development” (OAPF p120) in strategic views.

8.2.30 The character of the area is evolving and now includes a number of tall buildings of similar height to those proposed. The architectural design and appearance of the two taller buildings has been given careful consideration and has been informed by the design of recently constructed and consented developments along Albert Embankment; by discussions with Historic England and design officers at both the Council and the GLA; and by the previous proposals by Native Land.

8.2.31 The earlier Native Land appeal scheme, as shown in Figure 12 below, comprised 2 tall buildings of 15 and 13 storeys but spanning north-south across the Central Site.

Figure 12 – Native Land Appeal Scheme

8.2.32 When viewed from the River Thames and Albert Embankment, the buildings created a ‘slab block’ appearance dominating the silhouette of the listed Former Headquarters Building and conflicting with policy aspirations for a varied skyline – as well as affecting daylight standards along Whitgift Street. In contrast to the appeal scheme, the Central Square and East Garden Buildings now take a diamond plan form, which creates a more varied skyline and visual interest whilst also responding to the townscape, heritage and daylight/sunlight constraints of the site as shown in Figure 13 below.

Figure 13 – Proposed Scale and Massing of Proposal

8.2.33 The location and orientation of the taller buildings has been carefully designed to respond to the heritage and daylight/sunlight constraints of the site. Detailed consideration has been given to the design and impacts of the taller buildings, particularly in relation to the surrounding heritage assets and residential amenity.

8.2.34 In summary, the taller buildings:

1. Respond positively to the character of the area and surrounding buildings – through high quality architectural design, the proposed diamond-plan form, slender massing and choice of materials that sensitively relate to the silhouette of the listed Former Headquarters Building – and preserve suitable levels of daylight and sunlight to surrounding properties; 2. Improve the legibility and permeability of the area by creating landmarks which will assist with way-finding to and across the site from Albert Embankment; 3. Complement the new composition of taller buildings along Albert Embankment; 4. Relate positively at ground floor level - activating the public realm and assisting in the creation of well-defined public spaces and routes; 5. Contribute to the regeneration of the site and local area by facilitating: creation of a vibrant new employment, residential and cultural hub; provision of a new LFB Museum; and assisting to ensure the long-term preservation of heritage assets; 6. Are of high architectural quality and sustainable design; and 7. Will not have a significant harmful impact on any strategic, local or incidental views.

8.2.35 The Design and Access Statement and the Heritage, Townscape and Visual Impact Assessments submitted with the applications both conclude that the taller buildings will make a positive contribution to the skyline and complement the composition of taller buildings along Albert Embankment. The Environmental Statement (ES) further confirms that the tall buildings will not generate residual significant adverse impact in relation to microclimate, wind turbulence, overshadowing, noise, reflected glare, aviation, navigation and telecommunication interference. As such, it is considered that the scale and mass of the proposed towers is appropriate for the site and their design will respect the heritage context of the site and complement the silhouette of the Former Headquarters Building.

8.2.36 The East Site is separated from the Central Site by the raised main Waterloo railway line viaduct. Its surrounding built context comprises lower density commercial and residential development. This includes 2-4 storey buildings, with taller buildings (ranging between 5-13 storeys) in close proximity along Vauxhall Walk and Tyers Street. The design of the Newport Street Building has been informed by the more vernacular character of the surrounding townscape and draws on the design of Southbank House with a warehouse-style industrial language and with brick arches forming a visual link with the adjacent viaduct. The high-quality design and materials complement the character of the listed Southbank House, across the viaduct.

8.2.37 Located at the junction of Black Prince Road and Newport Street, the building, as shown in Figures 14-15 below, will act as a way-finder, marking the new riverside quarter and improving legibility. Its curved corner facade maximises presence on the street, thereby strengthening the connection between Black Prince Road Local Centre (to the south) and the growing cultural destination of Newport Street (to the north). The proposed set back from the street also enables the pavement width to be substantially increased, providing enhanced and safer public realm, activating the street frontage and softening the impact of the massing.

Figure 14 – Proposed Newport Street Building as viewed from Black Price Road looking west

8.2.38 Other than the listed Former Headquarters Building, the existing site presents a negative aspect to its surroundings, with extensive blank frontages and under-used/vacant buildings, and very limited permeability/public access. The proposals introduce a sequence of linked public spaces through the site, from South Square, to Central Square, to the Central Garden, and to the Eastern Garden and Eastern Link, connecting to Old Paradise Gardens. The proposed public realm represents 20% of the site, three times the amount of public space in the Appeal scheme. The public realm is lined by a range of active uses, with minimal blank frontages. The Eastern Garden fronts onto Southbank Buildings recently completed restaurant space, and includes a lightwell to small office spaces below, wrapped by a spiral cycle ramp, which will require careful detailing. Servicing of the central parcel is adjacent to the railway viaduct, accessed in between the proposed office building and the commercial uses in Southbank Buildings, which allows Central Square and Central Garden to be exclusively pedestrian.

Figure 15 – Proposed Newport Street Building as viewed looking North from Peldars Park

8.2.39 The proposal seeks to deliver substantial areas of public realm across the proposed development as shown in Figure 16 below. These areas of public realm have been designed to provide a variety of more civic (South and Central Squares) and local (Eastern Garden) spaces and are central to creating a successful employment destination and creating an area that works well for residents, employees, visitors and the local community.

Figure 16 – Proposed Public Realm Areas

8.2.40 Within the Central Site the buildings are arranged around the following three areas of public realm. These include: (1) Central Square - an enclosed plaza fronting Lambeth High Street; (2) Central Garden – a new urban route between The Office Building and Whitgift Street Building; and (3) Eastern Garden – a triangular piazza formed at the base of the Eastern Garden Building providing access to the basement cycle store. Linked by a shared surface, South Square and Central Square will create a smooth transition and gateway from Albert Embankment through to Lambeth High Street and the new urban quarter beyond, with active uses around it.

8.2.41 Together, these public works will create approximately 2,084sqm of substantial new public realm and open space, representing 20% of the application site area. This, and the re-provision of the Obelisk within a prominent part of the site (Central Garden), will greatly enhance public realm, way-finding and place-making within the site and surrounding area, knitting the urban form into the surrounding area and providing new routes across the site to encourage walking and cycling.

8.2.42 The public realm concept – layout, routes etc. is practical and well considered. The proposal provides a well-designed collection of buildings which come together coherently as an attractive and considered townscape composition. The selection of materials respond well to the local context and none of the treatments are jarring or discordant. In design terms, the buildings are a significant improvement on the Appeal scheme and have been carefully considered. Overall, the proposal is of a high design quality providing buildings that respond well to local context.

8.2.43 Within the public realm area proposed, pieces of new art and design are intended to be commissioned to the benefit of all those using and passing through the development. Full details of the intended pieces and timeframes for installation are to be agreed by way of a Public Art and Heritage Strategy to be secured by s106 legal agreement.

8.2.44 Figures 17-19 below provide visual images of the public realm areas proposed.

Figure 17 – Proposed South Square at the junction of Lambeth High Street & Black Prince Road

Figure 18 – Proposed View to Hotel Lobby across Central Square. South Square & Entrance to the Museum are seen in the distance to the left

Figure 19 – Proposed Central Garden view looking West towards Central Square

Impact on heritage assets

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

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

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

8.2.48 However, where the decision-maker concludes that there would be some harm to the heritage asset, in deciding whether that harm would be outweighed by the advantages of the proposed development (in the course of undertaking the analysis required by s.70 (2) of the TCPA 1990 and s.38 (6) of the PCPA 2004, the decision-maker is not free to give the harm such weight as the decision-maker thinks appropriate. Rather, Barnwell Manor establishes that a finding of harm to a heritage asset is a consideration to which the decision-maker must give considerable importance and weight in carrying out the balancing exercise.

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

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

8.2.51 Where more than one heritage asset would be harmed by the proposed development, the decision- maker also needs to ensure that when the balancing exercise in undertaken, the cumulative effect of those several harms to individual assets is properly considered. Considerable importance and weight must be attached to each of the harms identified and to their cumulative effect.

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

8.2.53 Sections 16 and 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 impose a statutory duty on planning authorities to safeguard the special interest of listed buildings and their settings. Section 72 of the Act imposes a statutory duty on planning authorities to preserve or enhance the character and appearance of conservation areas.

8.2.54 Where harm is caused to a heritage asset, the NPPF requires decision makers to determine whether the harm is substantial, or less than substantial. If the harm is deemed to be less than substantial, paragraph 196 of the NPPF requires the harm to be weighed against the public benefits of the proposals, including securing the optimum viable use of the heritage asset.

8.2.55 If the harm is substantial, or results in a total loss of significance, paragraph 195 states that local authorities should refuse consent unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh the harm or loss, or all four of the following criteria apply: the nature of the heritage asset prevents all reasonable uses of the site; and no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation; and conservation by grant-funding or some form of not for profit charitable or public ownership is demonstrably not possible; and the harm or loss is outweighed by the benefit of bringing the site back into use.

8.2.56 Policy 7.8 of the London Plan and Policies Q20 and Q22 of the Local Plan explain that development should identify, value, conserve, restore, reuse and incorporate heritage assets, where appropriate. Policy Q20 requires developments affecting a listed building to not diminish the buildings “ability to remain viable in use in the long term” and not harm the significance/setting (including views to and from) listed buildings.

8.2.57 Paragraph 193 of the NPPF advises that “when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance”. Paragraph 194 further advises that “any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification”.

8.2.58 The impact on Heritage Assets, including listed buildings on and neighbouring the site, conservation areas and locally listed buildings/structures is considered in detail below.

No 8 Albert Embankment

8.2.59 The Grade II listed Former Headquarters Building is a very impressive building of great dignity and formality. It sits comfortably in the townscape with spaces to each side. The fine detailing, proportions and massing are all very carefully considered. It is acknowledged, however, that the building is currently in poor condition and under-used. The utilitarian structures to the rear are buildings with a large footprint and of little architectural interest that do not make a positive contribution to the conservation area. In that regard, there is considerable scope for regenerating this part of Lambeth and improving the urban realm on and around the site.

8.2.60 The Heritage Townscape and Visual Impact Assessment (HTVIA) submitted with the application records that “The judgment about direct impacts on the listed buildings is one taken in the round, on the basis of the end result, balancing off some harmful impacts” and noting that, in relation to No.8 Albert Embankment, “the net effect would be beneficial because the building would have a secure future use, including for its original purpose and an educational purpose that reflects that original purpose”, and “the building fabric, in poor condition, would be repaired and put into a long-term maintenance regime from that use”. The Environmental Statement provided concludes that in respect of the listed buildings - No. 8 Albert Embankment and the Drill Tower - there is no net harm and that the direct impacts on the listed Former Fire Brigade Headquarters Building are of a Moderate Beneficial effect, with considerable importance and weight in the planning balance.

8.2.61 The proposed rooftop extension (as shown in Figures 4-6 above) is very carefully handled with the central and flanking ‘pavilion’ features. The proposed extension would sensitively integrate into the Former Headquarters Building retaining the central architectural 'crest' of the modern fire station building and is set back from the cornice line providing a high quality contemporary element to the listed building that will not harm the significance of the listed building. There is much good detailing proposed, such as grilles, doors, brickwork, carving, mouldings and fenestration, and the restoration of the significant sculptural reliefs is welcome. The flanks are treated as well as the façade and are important elements in views from Albert Embankment, the river and the opposite side of the river. The rear elevation is a little more utilitarian but has much architectural and historic interest – it is largely intact and its form and treatment reflects practical requirements when the building was designed. The massing, tiered balconies and solidity of the forms are of particularly importance.

8.2.62 The main building retains numerous features of interest internally. The plan form is largely original. The memorial halls, stairwells, fixtures and fittings, recreation rooms, conference room pole shafts etc. However, it is accepted that on the upper floors much of it is either altered or extremely plain / utilitarian to the point of having little interest.

8.2.63 A detailed analysis of the impact of the proposal on the listed building is set out in Table 3 below. This includes consideration of the listed/building issues that were raised by the Inspector in the Appeal Scheme, which are relevant to this current proposal. The conclusion of that assessment is that the proposed alterations will result in less than substantial harm to the significance of the listed building.

Drill Tower

8.2.64 The proposed minor alterations to the Drill Tower will have a neutral impact on its significance as a built form. Currently a good view of the tower is gained from Albert Embankment through a gap in the building frontage to the north of No.8. This is perhaps the only decent view of the drill tower from a public vantage point. View 21 - Albert Embankment, at International Maritime Organization within the HTVIA shows this. The proposed infill extension for new Fire Brigade accommodation would largely block this view as shown in Figure 20 below. The drill yard in which the tower stands will also be diminished – reducing the number of vantage points within the site from which to appreciate the tower. The overall result will be a minor adverse impact on its setting – less than substantial harm.

Figure 20 – Existing & Proposed View 21 - Albert Embankment, at Internal Maritime Organisation

8.2.65 Apart from the conversion and alteration of the listed Former Headquarters building, the rear part of the site to Lambeth High Street is to be cleared and redeveloped. Two point blocks, a residential block and an employment block are arranged around a new central pedestrian route through the site with the lane maintained down the back of the grade II listed Southbank House. The existing utilitarian structures to the rear are buildings with a large footprint and limited in architectural interest, with the exception of the Workshops which have been identified as making a positive contribution to the conservation area. Subject to a high quality design that makes a positive contribution to the conservation area, there is considerable scope for regenerating this part of Lambeth and improving the urban realm on and around the site.

ISSUE What the Inspector said: Comments

Fire Station Given the particular elements of fire This situation is unchanged with Remaining on service linkage in the historic interest the current application. site of the building, such retention of an active fire station on the site would help sustain this aspect of its significance. New Uses The proposed uses would therefore This situation is unchanged with help preserve the significance of the the current application. building in terms of its historic purpose and association. Repairs The works of refurbishment in the This situation is unchanged with appeal scheme would assist in also the current application. preserving physical aspects of the structure’s value, with elements of enhancement where the existing condition of the fabric would be improved. Roof top addition As a result of these effects on the The roof addition in 2011 was composition of the building as single storey. The proposed roof originally designed and constructed, addition is now two storey. the extension would therefore detract However, the basic impact and from its significance. issues remain unchanged with the current application. Rear extension The extension would infill almost the The extent of the infill extension full depth of the return ends which is now much less than the 2011 give the original rear elevation a more scheme. However, the effect still distinctive architectural interest. While results in the erosion of a replacement pole housing type significance from the losses. design feature would be created, the Therefore, the basic situation is original would be lost as an external unchanged with the current structure, and some elements of the application. viewing platforms would also be removed. There would be an erosion of significance from these losses of original Fire Brigade related fabric. Partial decking There would be a further erosion of This situation is unchanged with over drill yard significance from loss of the original the current application. open nature of the drill yard. Interior Harm to the significance of the The proposal no longer entails alterations building would therefore arise from the subdivision of the memorial some effects of the proposal on hall. However, assorted internal interior features of interest. elements will still be lost. This general impact on the interiors is therefore unchanged with the current application. Impact on The 1980s control room extension to The current proposal opens up Southbank no. 8 has a negative effect on the the corner of Lambeth High House (Doulton listed building, and also on the setting Street and Black Prince road HQ) of Southbank House and on some which allows a better Conservation Area views, by reason appreciation of Southbank of its incongruous materials and House. The effect is positive. detailing, intrusive massing and lack This situation is unchanged with of street level animation. Overall this the current application. would have a positive effect on the heritage assets. Training School / It is common ground that the training Since 2011 a character Workshop school and workshop buildings have appraisal of the Albert a neutral effect on the Conservation Embankment CA has been Area. prepared and para 2.98 states that the Workshop / training School building makes a positive contribution to the character and appearance of the Albert Embankment CA. The situation has therefore changed. Its loss would harm the significance of the CA.

Local View Policy With the current proposal that effect The current proposal is Q25 – Landmark would be extended to more of the significantly different from the Silhouette XVI vista, including by the intrusion of 2011 scheme. Two tall buildings built form in the currently open sky are now proposed behind no. 8 above the silhouette of no. 8 when Albert Embankment. Whilst the viewed from directly opposite across design has changed the effect the River. While not a purposefully on significance has not. The designed viewpoint or one protected result would be less than by policy, it is from this position that substantial harm to the setting of the overall profile of the building with the listed building. sky gaps on either side is most apparent. Although the sky gaps from this position would be maintained, as seen from other parts of the vista they would be diminished. In addition, as seen behind no. 8 the width of Building D as well as its height would be apparent, and with the horizontality in its design treatment it would to some extent challenge that quality of no. 8. This would result in a degree of conflict with policy 41 of the UDP on views, which includes reference to landmark buildings and silhouettes, and policy 43 on urban design in the River Thames policy area.

Offsetting these concerns, when the separating effects of distance and parallax are taken into account, Building D (and Building F in views in which this is seen) would be perceived as set well to the rear of no. 8, detracting from its symmetry and silhouette to a lesser extent than suggested by simple elevations. The contrasting nature of the proposed roof extension, while itself being harmful as set out above, would provide an element of visual capping to the listed building and further disassociate the structures. In adding depth to the River frontage Whilst the proposal is different as perceived in views across the this situation is unchanged with River, and marking a new quarter the current application. within the Conservation Area, the proposal would be consistent with these aims. This is a factor to be balanced against the harm that would result from the visibility of the proposed new buildings in the setting of no. 8. The ‘East’ Proposed Building G on this currently The proposed building today is (Newport Street / vacant site would be taller than other significantly taller than that in the Black prince buildings in the immediate vicinity. 2011 scheme. Whilst the points Road) site The viaduct forms a divide in raised by the Inspector are still townscape character, with taller relevant the resulting increase in buildings beyond to the west, but the height (it is now G+10 storeys) proposal would be seen in the would be adverse. This can be context of these, and on this site its seen in the applicant’s views 28, scale would not appear excessive. 29 and 30 where the comparison between the leap scale of the red brick proposal and its low rise neighbours is stark. The result is less than substantial harm to significance of the Albert Embankment CA. Overall impact on I assess that the degree of residual Whilst the current scheme is significance of harm to the heritage assets of no. 8 noticeably different to the 2011 heritage assets and the Albert Embankment scheme in a number of ways the Conservation Area would be less over-all heritage impact remains than substantial. ‘less than substantial harm’. Table 3 – Impact on statutory listed buildings

8.2.66 In summary, the balance of any minor individual harms arising from building alterations and extensions are clearly outweighed by the public benefit of the listed buildings’ restoration for secure long term beneficial use and their re-use in part for original purpose as a fire station – hence preserving the significance of the building in terms of its historic purpose and association.

Albert Embankment Conservation Area

8.2.67 The proposed development would make a positive contribution to the Albert Embankment Conservation Area, which includes the workshop building to the rear fronting Lambeth High Street and the undeveloped East Site to Black Prince Road / Newport Street. The proposal will involve the demolition of the CMC Building (a negative feature within the setting of the conservation area) and The Workshop (which makes a positive contribution to the conservation area) and replacement with high quality mixed-use buildings and public realm; to the benefit of the conservation area. Similarly, the redevelopment of the currently undeveloped East Site is considered in keeping with the character of the conservation area. In the case of the Workshop / training school, while noting the comment in the table above, the Council is satisfied that any harm to the significance of the conservation area as a result of the loss, will be less than substantial and that this is outweighed by the public benefits referred to in this report.

Settings of Designated Heritage Assets

Southbank House

8.2.68 The neighbouring former Doulton works on Black Prince Road is grade II listed. The impact on its setting will be positive at the western end because the new South Square will open up better views of Southbank House from Albert Embankment. However, the effect is diminished somewhat by the tall banners on the footway (required to address wind effects) which screen much of Southbank House from view. Whilst the new development is large, Southbank House is robust and the townscape on Black Prince Road intimate and enclosed. It is considered the general impact on its setting of the tall buildings etc. will be neutral.

Lambeth Palace – Grade II listed

8.2.69 View 8 – Lambeth Palace Gardens of the HTVIA, as shown in Figure 21 below, shows the impact of the towers on the setting of Lambeth Palace in views from the north. The view location is within the Palace’s private garden. The long, low front of the Blore Building (main part of Palace) can be viewed through the trees. An existing tall building – Westminster Tower is already visible in the backdrop and Millbank Tower is too but largely screened by trees. The proposed towers will make a noticeable impact on the setting – rising to the left of the view to a similar height as Westminster Tower. The view is a winter one when the trees are bare. When the trees are in leaf much of the proposal will be screened from view. The proposal will result in a minor adverse impact which results in less than substantial harm to the setting of Lambeth Palace.

Figure 21 – Existing & Proposed View 8 – Lambeth Palace Gardens

Lambeth Palace – Registered Park and Garden

8.2.70 The garden is extensive and lies to the immediate north of the Palace. There is an extensive central lawn with trees dotted about it. View 8 of the HTVIA as shown above is from the centre of the lawn looking back towards the Palace. It is not on one of the principal walks. Modern development is already visible – St Thomas’ Hospital to the North. The view looks south and Westminster Tower is currently the most prominent tall building. The proposal will result in a minor adverse impact which results in less than substantial harm to the setting of Lambeth Palace Garden.

Lambeth Palace Conservation Area.

8.2.71 The Old Paradise Gardens to the north of the application site lies within the Lambeth Palace Conservation Area. The gardens are a historic burial ground and numerous grave stones remain. Some of the perimeter walling is listed. The space itself is on the local heritage list. The proposal’s tall buildings will be highly visible form the Gardens as shown in View 23 - Whitgift Street Park (Old Paradise Gardens) of the HTVIA. Whilst there are other tall buildings in the vicinity of the application site none are particularly close to the Old Paradise Gardens. The effect is dominant and rather stark as shown in Figure 22 below. This results in less than substantial harm to the setting of the open space and to the Lambeth Palace Conservation Area.

Figure 22 – Existing & Proposed View 23 – Whitgift Street Park (Old Paradise Gardens)

8.2.72 The proposal will be prominent and visually dominant as a result of their proximity. The view from the garden of Lambeth Palace is relevant here too and the view from Archbishop’s Park.

Figure 23 – Proposed View 9 – Archbishop’s Park: South of Royal Street and Playing fields

8.2.73 View 9 – Archbishop’s Park: South of Royal Street and Playing fields of the HTVIA, as shown in Figure 23 above, is form the northern end of the park where the two towers are just glimpsed. The visual impact is negligible with the trees in leaf. However if the viewer was to move south into the centre of the park – the MUGA or the lawn to its south there would be a similar visual impact then as in view 7. This would be less than substantial harm to the setting of the CA. The overall result is less than substantial harm to the setting of the Lambeth Palace Conservation Area.

Impact on Non-designated assets

8.2.74 Archbishop’s Park and Old Paradise Gardens are both on the local heritage list. As discussed above, the proposal will be highly visible and quite dominant. The result is less than substantial harm their settings.

Strategic and Local Views

Panorama 2B.1- Parliament Hill: East of the Summit – At the Prominent Oak Tree

8.2.75 This is a broad view from an elevated vantage point as shown in View 2 - Parliament Hill: East of the Summit – At the Prominent Oak Tree of the HTVIA. Nestled in the cityscape, the towers of Palace of Westminster are visible and identified as a feature of the view. The LVMF states of the view:

107 All three towers of the Palace of Westminster are set against the distant hills. The scale and simple outline of existing tall buildings in the view frame the Palace of Westminster and contrast with its more delicate and intricate silhouette of towers.

8.2.76 In terms of guidance the LVMF states:

Foreground and Middle Ground 109 The viewer’s ability to perceive the visual relationship between the Clock Tower, the Central Tower and the Victoria Tower should be maintained or enhanced. Any development proposals that would undermine this relationship should be refused. A Protected Vista, incorporating the full width of the Palace of Westminster, reinforces this requirement.

Figure 23 – View 2 - Parliament Hill: East of the Summit – At the Prominent Oak Tree

8.2.77 View 2, as zoomed in detail in Figure 23 above, shows that the proposal will sit in the background of this view. Even with a zoom lens, it is difficult to actually discern the three towers of the Palace from this distance. The tallest elements of the proposal attach to the left side of the Elizabeth Tower (Big Ben) which is already largely screened by the foreground tree.

8.2.78 The LVMF states:

Background 110 Small scale incremental change in the background of the three towers of the Palace of Westminster might be appropriate if it does not dominate the individual towers or diminish the spatial relationship between them.

8.2.79 In conclusion, the proposal meets the requirement of the LVMF guidance in this view.

Panorama 4A.2– Primrose Hill: The Summit

8.2.80 This is a broad view from an elevated vantage point as shown in View 3 - Primrose Hill: The Summit of the HTVIA. Nestled in the cityscape the towers of Palace of Westminster are visible and identified as a feature of the view.

8.2.81 The LVMF guidance states:

Description of the View 126 The summit of Primrose Hill is a clearly defined and popular place from which to enjoy a wide panorama of London. Good views of St Paul’s Cathedral and the Palace of Westminster are available from here. Therefore, two Protected Vistas are provided between the Assessment Points (4A.1 and 4A.2) and the Strategically Important Landmarks.

127 The foreground and much of the middle ground of the panorama is dominated by open space, with only London Zoo introducing significant urban content. The panorama is wide, extending into Islington in the east, and as far as the Trellick Tower, beyond Paddington, in the west. To the east, there is residential development of brick and painted stucco, pitched slate and tile roofs, complemented occasionally by church spires, blocks of flats and trees.

128 Urban development dominates the far middle ground, beyond Regent’s Park. There is little order or prevailing character amongst the groups of large commercial buildings and tall residential buildings. Continued development of this kind in the middle ground could reduce the viewer’s ability to see the principal buildings in the City of London, as well as the Palace of Westminster further west.

Figure 24 – View 3 - Primrose Hill: The Summit

8.2.82 View 3, as zoomed in detail in Figure 24 above, shows that the viewer’s ability to appreciate the tower is the Palace is already compromised by foreground tall buildings. The small brown tapering form to the immediate left of the Victoria Tower appears to be the roof of the Westminster Tower on Albert Embankment. The proposal’s towers will rise up behind it but not high enough to break the tree line behind.

8.2.83 The LVMF states:

135 Development in the background of the Palace of Westminster should preserve or enhance the viewer’s ability to recognise and appreciate the Strategically Important Landmark. The form and materials of new development should help improve the clarity with which the silhouette of the towers of the Palace of Westminster can be distinguished from their surroundings.

8.2.84 In conclusion, the proposal meets the requirement of the LVMF guidance in this view.

LVMF 17A.2 - Hungerford Bridge Upstream

8.2.85 This is a view from Hungerford Bridge looking upstream as shown in View 5 – Hungerford Bridge Upstream: Close to the Westminster Bank of the HTVIA. The proposal, as shown in Figure 25 below, would have no adverse impact.

Figure 25 – View 5 - Hungerford Bridge Upstream: Close to the Westminster Bank

LVMF 18A.2 Westminster Bridge

Figure 26 – View 6 – Westminster Bridge Upstream: At the Centre of the Bridge

8.2.86 This is a view from Westminster Bridge looking upstream as shown in View 6 – Westminster Bridge Upstream: At the Centre of the Bridge of the HTVIA. The proposal, as shown in Figure 26 above, would have no adverse impact.

Local Views

8.2.87 There is no harm to the panorama view (I) from Brockwell Park as shown in View 4 – North West from Brockwell Park of Brixton Landmarks (Lambeth Town Hall’s Tower and St. Matthew’s Church Tower); and Views North and to the City (Panorama) of the HTVIA.

Figure 27 – View 4 – North West from Brockwell Park of Brixton Landmarks (Lambeth Town Hall’s Tower and St. Matthew’s Church Tower); and Views North and to the City (Panorama)

8.2.88 The landmark silhouette XVI view from Millbank to 8 Albert Embankment is a fairly straight-on view of the Fire station’s façade with sky gaps and the listed drill tower to one side. View 15 – Millbank: Victoria Tower Gardens (South Gateway) of the HTVIA is from this viewpoint as shown in Figure 4 above. The two tall buildings will appear behind the listed building – pale, recessive forms, one behind the other. They are not the only tall buildings in the townscape but rise right up behind the listed building in the view. The Inspector addressed this in the previous appeal scheme although in that instance the buildings were noticeably lower. The HTVIA considers the impact beneficial although the Council consider the impact to be adverse. The policy objective of Policy Q25 is not therefore met as the proposal would harm the silhouette. Notwithstanding this, the view is not a designated heritage impact and therefore it would be appropriate to use the terms ‘substantial’ or ‘less than substantial’ harm.

Assessment of harm versus benefits

8.2.89 Paragraph 196 of the NPPF notes that, where the overall net balance of heritage considerations is that any harm is less-than-substantial, “this harm should be weighed against the public benefits of the proposal, including, where appropriate, securing its optimum viable use.”

8.2.90 With respect to heritage matters, the Inspector in the previous appeal decision noted that there would be ‘less than substantial harm’ to the significance of a designated heritage asset and that this harm would be outweighed by the public benefits of the proposal, including:

1. Securing an optimum viable use; 2. Bringing 8 Albert Embankment back into use; 3. Re-establishing the fire station as a public benefit with its use being consistent with the aspirations of the English Heritage/London Fire Brigade guide, 4. Meet land use objectives and bring economic benefits consistent with the development plan and Government policy.

8.2.91 In this case, the proposals would provide a heritage benefit with the restoration of two underused listed buildings, including partial re-use for original purposes, preserving the significance of the buildings in terms of their historic purposes and association and securing the buildings’ long-term future and its optimum viable use.

8.2.92 An assessment of the current application has identified less than substantial harm caused by the proposed change to the original principal elevation facing Albert Embankment although this harm will be mitigated to some extent through high quality design. Harm has also been identified from the scale of the proposed two residential towers, which contrasts with the current low-lying industrial character of this part of the conservation area and would also appear in the LVMF View (4A) of the Victoria at the Palace of Westminster. This harm would, however, be less than substantial. This view is supported by both the GLA and Historic England who have also come to the same conclusion. In line with paragraph 196 of the NPPF, the resulting harm would be outweighed by the many public benefits of the proposal which include:

 Heritage – the restoration of two underused listed buildings, including partial re-use for original purposes, preserving the significance of the buildings in terms of their historic purposes and association and securing the buildings’ long-term future;  New Fire Station and Emergency Base – the creation of a new modern ‘fit for purpose’ firefighting and emergency services base for central London in a strategic location to achieve fast response times to increasingly-regular emergency incidents;  Museum – the creation of a permanent home for the London Fire Brigade museum, at its original site, resulting in educational and cultural benefits to the locality and wider London;  New Homes - delivery of new housing, including 40% affordable housing (39% based on units);  New and Diverse Employment Opportunities – the creation of space for approximately 1,264 on- site jobs across a range of sectors (including medium, small and micro workspaces well suited to small creative and cultural businesses and start-ups) and creation of additional jobs during construction and from associated resident and occupier expenditure;  Public Realm - enhancements to public realm and way finding, including through provision of around 1,900sqm of high quality, permeable public realm (currently the site does not provide any public realm and the appeal scheme provided less than 600sqm); and

8.2.93 As such, the proposal is considered to be acceptable and in accordance with Sections 16, 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, the NPPF and development plan policies.

8.3 Standard of residential accommodation

Housing and Development Density

8.3.1 In supporting the efficient use of land, Paragraph 122 of the NPPF notes that decisions should have regard to: identified needs for different types of housing and other forms of development; local market conditions and viability; the desirability of promoting regeneration and change; and the importance of securing well-designed, attractive and healthy places.

8.3.2 Policy 3.4 (Optimising Housing Potential) of the London Plan, supported by Policy H1 (Maximising housing growth) of the Local Plan, seek to optimise development densities based on local context, character and accessibility. In addition, Policy D1 of the Local Plan seeks to maximise the use of previously developed land and vacant buildings in fully exploring regeneration opportunities, as is the case in this application.

8.3.3 The site is located in the VNEB Opportunity Area and benefits from a PTAL rating of 6a. The density matrix within the adopted London Plan indicates the appropriate density range as being 140-405 units per hectare (u/ha) and/or 650-1,100 habitable rooms per hectare (hr/ha). The London Plan cautions against applying the density ranges mechanistically, noting that site specific factors should be taken into account. The proposals fall above this range with a density of 1,688hr/ha (or 722u/ha). As assessed above within the Design and Conservation section, the proposal is of high-quality design and provides an appropriate housing mix for the locality. The density is therefore considered acceptable.

Unit sizes, layout and access

8.3.4 Policy 3.5 of the London Plan promotes high quality design of housing development that takes into account its physical context, local character, density, tenure and land use mix and relationship with, and provision for public, communal and open spaces taking into account the needs of children and older people.

8.3.5 New development should conform to the minimum space standards set out in the National Technical Housing Standards as shown in Table 4 (Table 3.3 of the London Plan) below.

Table 4 – Technical housing standards - nationally described space standard

8.3.6 Policy Q1 of the Local Plan further promotes inclusive environments, which is echoed within the London Plan. Under the London Plan, development should, amongst other things, enable people to live healthy active lives as per Policy 7.1 of the London Plan, and be inclusive including addressing the specific needs of older and disabled people as per Policy 7.2.

8.3.7 Within the proposed development, the units would have GIA’s of between 39sqm for the smallest studio units and 95sq.m for the largest 3-bedroom units. All of the proposed units would meet or exceed the requirement of the Nationally Described Space Standards (2015).

8.3.8 All of the units would also meet the requirements outlined in the Housing SPG (2016) in relation to amenity space quantum and minimum dimensions. The typical floor plans of the taller residential tower buildings would range from 4 to 8 units per floor with the scheme having a maximum of 8 units per floor. All units would achieve a minimum 2.6 metre floor to ceiling heights to help promote natural ventilation, with all habitable rooms also having access to full height windows and private balconies.

Accessible, Adaptable and Wheelchair Housing Provision

8.3.9 The proposals respond to Policy 7.2 of the London Plan and Policy Q1 of the Local Plan to achieve an accessible and inclusive environment. Policies 3.5 and 3.8 of the London Plan require that 90% of new dwellings are ‘accessible and adaptable’ (this is defined by building regulations – Part M4 (2) and 10% of new dwellings are ‘wheelchair user dwellings’ (this is defined by building regulations – Part M4 (3)).

8.3.10 The proposal provides 10% (44) wheelchair units to an adaptable standard distributed through all tenures and levels of the development including provision in the affordable units in accordance with Part M4 (3). This provision will be secured through an appropriate condition. The rest of the affordable housing and market housing (399) has been designed to meet Part M4 (2) ‘Wheelchair User Dwelling’ as confirmed in the Design and Access Statement. The scheme is therefore considered to accord with planning policy providing an accessible and inclusive environment for all.

Daylight, sunlight, privacy and aspect

8.3.11 Each apartment would have adequate light and ventilation and the proposal would provide a good level of aspect for all future residents with appropriate setbacks from the boundaries of the site and spacing in front of proposed windows being provided.

8.3.12 An internal daylight and sunlight assessment has been provided with the application, as part of the Daylight and Sunlight Analysis report undertaken by Point 2 Surveyors, to assess the quality of daylight and sunlight into the new residential units. The report concludes that the scheme demonstrates an acceptable level of compliance with BRE Guidance in terms of sunlight and daylight amenity. The report has been independently reviewed by Schroeders Begg who agree with the findings. The scheme has been designed to allow good levels of sunlight and daylight similar to other urban schemes.

8.3.13 The Mayor’s Housing SPG advises that habitable rooms should be provided with suitable privacy. 18-21m is indicated as a suitable minimum distance between facing habitable rooms, although the standard notes that “adhering rigidly to these measures can limit the variety of urban spaces and housing types in the city and can sometimes unnecessarily restrict density”. Within the application site, a separation distance in excess of 18m is achieved between the habitable room windows of the Headquarters Building and Central Square and between the Newport Street Building and Eastern Garden Building. Whilst the Whitgift Street Building would be 8m (at its closest point) from the Central Building and 10m (at its closest point) from the Eastern Garden Building, through the careful orientation of buildings on the site and positioning of windows and balconies, the proposal would minimise the potential for overlooking, which will allow for privacy in line with standards in the Mayor’s Housing SPG.

8.3.14 Similarly, with respect to the possible implications on amenity by way of overlooking and impact on privacy to existing neighbouring occupiers, this has also been addressed through the careful positioning of windows and balconies to minimise the potential for overlooking. The development would provide a minimum 18m separation distance with Whitgift House, No.2 Whitgift Street and 9 Albert Embankment to the north and south. Where separation distances fall short of the 18m, such as between the proposed Newport Street Building and the nearest neighbouring properties on Black Prince Road (Nos. 71 and 73-79) to the south, the windows and balconies have been appropriately positioned and designed to minimise the opportunity for overlooking. Where required, windows will be obscurely glazed within the development to ensure no undue overlooking or loss of privacy.

Noise and disturbance

8.3.15 Policy 7.15 of the London Plan requires development proposals to contribute to the reduction of noise. This approach is maintained by emerging new draft London Plan Policy ED7, which seeks to reduce, manage and mitigate noise.

8.3.16 In respect of residential developments, the Lambeth Local Plan (Policy H6) seeks to ensure that conversions will not lead to an unacceptable level of noise and disturbance. For food and drink uses, Policy ED7 requires that food and drink uses do not cause unacceptable harm to residential amenity, including through noise impacts.

8.3.17 A noise and vibration assessment is provided in Chapter 9 of the ES. This assesses the likely noise impacts during the construction phase, the noise effects of the development and the noise effects on the development. The noise impacts on residents of the development are considered to be acceptable subject to mitigation. Mitigation measures include mechanical ventilation and glazing specifications; these measures are considered to be sufficient in mitigating noise impacts associated with existing and new road traffic noise, noise from the railway viaduct and noise created in association with the fire station.

8.3.18 During the long-term life of the scheme, the assessment concludes that the predicted noise levels within the proposed outdoor amenity areas should generally be below the upper targets for such areas, providing that the terraces associated with the Central Square Building and East Garden Building are glazed. The provision of screening is welcomed and the noise levels within the public realm, predicted at no higher than 55db, are considered to be acceptable.

8.3.19 Conditions will be required to ensure a full noise report and consideration of façade impacts on each of the buildings are considered in order to finalise a suitable glazing scheme and that residents have access to suitable amenity space achieving the 55db levels predicted.

8.3.20 Overall, with the proposed mitigation measures in place that will manage the development and minimise noise levels, the requirements of Policy 7.15 of the London Plan and Policy D13 of the Local Plan are met.

Residential Amenity and Play Space

8.3.21 Each residential unit would be provided with external amenity space in the form of balconies with 979sqm of communal amenity space also being provided at rooftop levels. All tenure units would have direct access to the communal gardens in each individual building.

8.3.22 Policy 3.6 of the London Plan seeks to ensure that development proposals include suitable provision for play and recreation, with further detail in the Mayor’s supplementary planning guidance ‘Shaping Neighbourhoods: Play and Informal Recreation’, which sets a benchmark of 10sq.m of useable child play space to be provided per child, with under-fives play space provided on-site as a minimum.

8.3.23 In accordance with the Mayor’s Play and Informal Recreation Play SPG, approximately 90 children (74 children in the affordable/social rented, 2 in the intermediate, and 14 in the market) are predicted to live in the development. All 0-4 year old play space provision for the development (552sqm) is provided on-site with a 12sqm of ‘Play on the Way’ provision also being provided to meet the GLA and Lambeth’s requirements for overall amenity use for that age group. Adverse impact on the active frontages of the public realm prohibits dedicated provision for older age groups (5-10 and 11-15), however, it is proposed that the shortfall (300sqm) in such provision is enabled or offset by a financial contribution towards play provision within one of the open space areas (such as Old Paradise Gardens, Pedlars Acre Gardens, Lambeth Walk Open Space, Glasshouse Walk Playground, Black Prince Road and Playground and Vauxhall Pleasure Gardens) within easy walking distance easy access of the site to be secured by s106 legal agreement.

8.4 Amenity for Neighbouring Occupiers

Daylight, Sunlight and Overshadowing

8.4.1 In accordance with Lambeth Local Plan 2015 Policy Q2 (Amenity) the application is accompanied by a Daylight and Sunlight Assessment prepared by Point2Surveyors. This provides an assessment of the potential impact of the development on sunlight, daylight and overshadowing to neighbouring residential properties and open spaces based on the approach set out in the Building Research Establishment’s (BRE) ‘Site Layout Planning for Daylight and Sunlight: A Good Practice Guide’. This includes an assessment of impacts on the site’s residential neighbours.

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

8.4.3 The BRE guidelines are not mandatory; they do however act as a guide to help understand the impact of a development upon properties and other spaces, while acknowledging that in some circumstances, such as that of an urban environment or where the existing site is only previously partially developed some impact may be unavoidable. It should be further noted that the BRE guide considers level of daylight, sunlight and overshadowing tests based on an expectation of reasonable levels of light within a suburban context and this should be kept in mind when considering a central London context as is the case for the application site.

8.4.4 The earlier submitted appeal scheme was dismissed by the Inspector in May 2013 with one sole fundamental reason relating to an adverse impact upon the amenity of daylight to neighbouring properties, fundamentally, in respect of Whitgift House and 2 Whitgift Street. Whilst the proposed scheme differs significantly from the appeal scheme, some benchmarking can be considered applicable in reference to the comments made within the Planning Inspectorate report albeit given the appeal was 6 years ago, this must be caveated that more recent planning cases and appeals, such as the Whitechapel and Graphite Square appeals, have changed some industry views from that time in an ever evolving review of daylight and sunlight.

8.4.5 The application site is within an urban site and currently there is fairly limited massing on the site with some neighbouring properties having higher levels of daylight and / or sunlight than ordinarily anticipated for more typical urban environments. It is inevitable that for such a site, there will be departures to the BRE Guide default ‘target criteria’ and due suitable flexibility and interpretation of the analysis results will be required. This is reinforced within The Mayor of London’s ‘Housing Supplementary Planning Guidance’.

8.4.6 The Council has sought an independent review of the Point2Surveyor’s report findings in respect of possible impacts of the new development on surrounding sites and within the development itself. This review was undertaken by Schroeders Begg. The review commences with an examination of the Planning Inspectorate report on the refused appeal scheme, as set out below, then examination with extracts from the applicants daylight and sunlight consultant Point 2’s report and analysis with their comments review incorporated and ending with a conclusion.

The Planning Inspectorate Report on the Appeal Scheme

8.4.7 The issue of daylight/sunlight is considered within the Planning Inspectorate report under the title; ‘Issue d) the impact of the proposal (appeal scheme) would have on the living conditions of nearby residential occupiers resulting from loss of daylight and sunlight’ – this should be read in full from paragraphs 88 – 111 Inclusive. From the consideration of the report, the following is highlighted:

Generally:

1. Mention is made to Policy 33 of the UDP to ‘protect the residential amenity of existing and future residents’ and Policy 40 that ‘amenities and development possibilities of surrounding sites should not be impaired’ (these policies have now been superseded by the adopted Local Plan).

2. In consideration of review, this divides into two aspects; ‘firstly, the degree of harm from such impact, and secondly the significance of the harm in the overall balance of consideration’.

3. Appropriate assessment criteria considers the BRE Guide and for daylight review, the two indicators of Vertical Sky Component (VSC) and Daylight Distribution. In addition, Average Daylight Factor is referenced to a lesser extent but considered a ‘useful indicator’ (as a measure of actual light within a room) and ‘given the agreed position of the main parties in this case that there should there be a reasonable expectation of some loss of light, and therefore absolute levels within affected rooms are important’. That said, it seems overall the planning inspector places slightly less emphasis on ADF then compared to VSC and daylight distribution analysis.

4. In reference to comparable, it seems evidence of reductions / daylight levels is sought ‘for the buildings around the appeal site’. It seems very close proximity is required and we infer that examples such as the Shell Centre site are too distant / disparate in variables etc.

5. Acknowledgement is made for the BRE Guide ‘to be applied flexibly and to help rather than constrain design’.

6. It is apparent that the key buildings in which ‘harm to the living conditions of the occupiers’ with ‘substantial loss of amenity’ is to Whitgift House and 2 Whitgift Street.

7. In reference to daylight distribution ‘there is no support in the guidance for the appellants’ use of an alternative 50% room proportion behind the working plane as an indicator of unsatisfactory daylight distribution’. However, in the 6 years since the appeal, there are appeal cases that have considered appropriate alternative target criteria (as opposed to the BRE ‘default’ target criteria) with 50% daylight distribution being considered as an alternative target criteria; this was within the most recent Graphite Square appeal case.

Whitgift House

8.4.8 In terms of analysis, the report highlights that:

 60 windows in the south elevation and 30 living rooms were considered.  Existing VSCs mostly exceed or are very close to 27% (adequate daylight).  Reductions in VSC would mostly exceed 40% loss with resultant VSCs all below 20% and nearly half falling to below 16% VSC.  Daylight distribution – almost half of living rooms having a greater reduction then 20%.  ADF – almost all rooms currently exceed an ADF of 2% ‘predominantly daylight’ – almost all living rooms would fall below this level with virtually all room losses exceeding or near to 30% of existing value.

8.4.9 Paragraph 96 is considered key as it appears that even if minimum target ADFs are still achieved in the proposed, reduction in daylight is not acceptable, thus inherently highlighting consideration on the extent of loss for VSC and daylight distribution. Paragraph 96 states ‘the effect of the proposal on Whitgift House is that the accommodation in almost all flats would appear markedly gloomier and there would be a substantial increased reliance on electric lighting. While most rooms would exceed the BS minimum ADF levels, given that for many living rooms these would only just be met or missed, coupled with the degree of loss of light and the unsatisfactory distribution in many cases, this in itself does not make the impact acceptable’.

8.4.10 Whilst it is appreciated that Whitgift House is opposite fairly low-level massing and a view could be taken that such daylight (and sunlight as applicable) could be considered good for an urban locality, the report does highlight ‘evidence that the appellants’ assertion that Whitgift House enjoys usually beneficial daylight for its location is therefore not establish’.

8.4.11 The report highlights the use of alternative target criteria and application of consideration of mirror- development has not been correctly undertaken. Whilst formal alternative target criteria has not been agreed for this application, useful guidance for alternative daylight target criteria can be obtained from various recent planning appeal cases where VSCs in the mid-teens have been considered acceptable and daylight distribution to half the room area (at working plane), such as in the recent appeal cases for Graphite Square, albeit due consideration is always needed on the specifics of each case.

2 Whitgift Street

8.4.12 In terms of analysis, the report highlights that:

 36 windows reviewed. Multiple windows to each room.  Existing VSCs – all living rooms have more than one window exceeding a 27% VSC (adequate daylight).  Reductions in VSC would be substantial with many exceeding 50% loss and all windows with greater than a 20% reduction (noticeable).  Daylight distribution – remains relatively good with no losses exceeding 20% (highlighted though ‘this is not a measure of the amount of daylight, and there is no sound justification for weighing the assessment towards this criterion’).  ADF – the 6 living rooms would still exceed 2%, those for all 4 affected bedrooms would fall below 1%.

8.4.13 The degree of impact is noted as ‘substantial harm’ – this is perhaps slightly surprising given that quality of daylight within the rooms is maintained in terms of ADF and daylight distribution for the appeal scheme with the exception of ADF to bedrooms (ordinarily, bedroom use given less important than living rooms).

Summary

8.4.14 Based on consideration of the particular points highlighted above, it seems apparent that:

 VSC and daylight distribution are of equal importance (as per the BRE Guide and supported in various planning appeal cases).  Acceptable reduction parameters are not provided for these specific properties (albeit some commentary is provided for the other properties).  ADF appears placed at a lesser importance unless an ADF of 2% or more is still achieved (predominantly daylight) as opposed to the minimum levels of 1.5% for living rooms and 1% for bedrooms.

Review Methodology

8.4.15 The base document and methodology for review of Daylight and Sunlight is the BRE Guide – Site Layout Planning for Daylight and Sunlight – a guide to good practice (BR209). However, it must be borne in mind that the parameters of target criteria within that document are based more on a suburban context as opposed to an urban context with higher densities of development where the ‘default’ target criteria may not always be possible to be met. The BRE recognises that context of development sites does vary and accordingly, within the introduction of the BRE Guide, the background of is stated amongst other aspects that the BRE Guide advice is not mandatory, it is there to assist rather than constrain and numerical guidelines provided should be interpreted flexibly.

8.4.16 Analysis has been undertaken in reference to: Existing v Proposed and Appeal v Proposed in the Point2Surveyor’s report submitted. Primarily, the key analysis is ‘Existing to Proposed’ with the appeal comparison analysis as useful reference on shift improvement. However, ultimately, the shift improvement is not so applicable, as the scheme is expected to be less adverse in terms of impact on neighbouring daylight in any event – the main consideration is whether the current scheme results in a material deterioration in conditions and whether that deterioration would be acceptable in the overall context and circumstances of the case.

8.4.17 Whilst the Planning Inspectorate report forms a good reference / gives some indication in acceptability of reductions, it is important that when comparison is made with the ‘appeal scheme’, analysis should be on a like for like basis / adjusted accordingly.

8.4.18 Whilst all applicable neighbouring properties have been considered, given some of the adversity of the analysis results within Point 2’s report, Schroeders Begg have provided particular examination and review, especially upon the following properties which confirm some larger degrees of adversity (primarily in respect of daylight reductions) to the following neighbouring properties:

 Whitgift House  Whitgift Street  Albert Embankment – Building A – East  71 Black Prince Road  73-79 Black Prince Road

Figure 28 – Relationship with neighbouring properties (sunlight and daylight)

8.4.19 The Schroeders Begg review has focused upon daylight consideration in reference to the primary and equal aspects of Vertical Sky Component (VSC) and Daylight Distribution / No Sky Line in reference to the BRE Guide and also considered ‘supplementary testing’ in respect of the Average Daylight Factor (ADF). However, given the urban context of the site, fairly limited existing massing on the site and proposed massing representing a significant increase, a significant number of analysis results do not meet the BRE Guide target criteria in respect of reductions thus reference is made to categorise the extent of ‘adverse impact’ on a typical industry standard with further consideration being given in an Environmental Impact Assessment (EIA) for reductions which exceed 20% reduction (i.e. ‘adverse / noticeable effect) as following:

 Minor Adverse: Reductions in VSC or NSL of 20% to 29.9%;  Moderate Adverse: Reductions in VSC or NSL of 30% to 39.9%; and  Major Adverse: Reductions in VSC or NSL of equal / greater than 40%.

8.4.20 It is important that relative consideration is given to retained values, especially in considering informal alternative target criteria of whether the proposed analysis would still achieve VSCs in mid- teens and daylight distribution to 50% of the room area (at working plane). Retained values were, in part, a consideration in the Planning Inspectorate report for the appeal scheme.

Daylight

8.4.21 The reductions in daylight for the residential neighbouring properties, as shown in Figure 28 above, can be summarised as follows:

Whitgift House

8.4.22 There are 25 flats within Whitgift House (although to highlight, flats are numbered 1-24 inclusive plus flat 11a). These are arranged with 5 flats on each floor with all flats being dual aspect. There are 60 windows in the main / closest building elevation facing the application site arranged as 12 windows per storey. Of the 12 windows, there are 5 living rooms and 7 bedrooms with the end rooms at first and second floor levels being dual aspect.

8.4.23 From consideration of the impact on living rooms, it is apparent that all primary living room windows would have reductions in VSC which do not meet BRE Guide target criteria and such reductions could be considered as ‘moderate adverse’ for VSC. This is also the case for adjoining bedrooms windows. Thus all 60 windows facing site can be considered as ‘moderate adverse’ reductions. Taking into account a theoretical consideration of analysis ‘without eaves’ (there is an eaves projection immediately above the fourth floor windows), whilst some reduction occurs in the adversity in this case, there is no material change in the overall analysis results i.e. the results still do not meet the BRE Guide default target criteria so the inherent effect of the eaves projection is not a significant factor in such reductions. Overall, such reductions do, however, represent an improvement to the ‘appeal scheme’.

8.4.24 In consideration of the impact on all 60 windows, it is apparent that the retained value is fairly uniform across each storey level and improving as you move up the building in storey height (excluding the fourth floor due to the eaves projection). The retained VSC value for an urban context / site locality could still be considered reasonable at the lowest / worst floor but such a reduction will be noticeable and consideration also needs to be given as to whether that availability of daylight is still reasonable given the room use and arrangement. The retained levels in VSC are above an informal alternative target criteria of retained VSCs in the ‘mid-teens’ (i.e. VSC 15%-17%) from a number of planning appeal cases, such as the Whitechapel and Graphite Square appeals.

8.4.25 For the ground and first floors, reductions in daylight distribution do not meet BRE Guide target criteria but for the second, third and fourth, they almost all readily meet target criteria. Focusing upon living rooms, reductions to the living rooms could be considered on a reduction basis as ‘major adverse’ for the ground floor and typically ‘moderate adverse’ for the first floor (floors above meeting BRE Guide target criteria). Pending bedroom room sizes being considered, results are similar (although slightly better than living rooms as typically, some bedrooms are smaller); at ground floor reductions are ‘major’ to 5 bedrooms and ‘moderate’ to 1 bedroom and ‘minor ‘ to 1 bedroom. At first floor, less adversity in that 5 bedrooms having ‘moderate’ reductions with the remainder meeting BRE Guide target criteria. In terms of retained values of daylight distribution (where reductions are applicable), for all the ground floor rooms, this can be summarised as ranging 50.0% - 71.9% having access to direct skylight at the working plane with an average daylight distribution of 52.1% for living rooms and 58.5% for bedrooms. For the first floor, retained daylight distribution is better (where reductions are applicable), ranging 60.7% - 87.1% having access to direct skylight at the working plane with an average daylight distribution of 67.2% for living rooms and 70.8% for bedrooms.

8.4.26 Whilst reductions would be noticeable at ground and first floor, existing levels of daylight distribution are particularly high at almost 100% daylight distribution. Again consideration to the retained levels in daylight distribution are above an informal alternative target criteria of retained daylight distribution of 50% in reference to the planning appeal case of Graphite Square.

8.4.27 With respect to an analysis of ADF, all bedrooms retain an ADF value of 1% or greater in the proposed scenario and therefore meets the target minimum standard for a bedroom which is 1%. In terms of living rooms, the minimum target standard is for an ADF of 1.5%, effectively no living room in the proposed scenario would meet that standard although it is relevant to add that for existing ADFs, currently, 14 rooms also do not meet this standard (which is contrary to the appeal analysis / Inspectorate’s report). Notwithstanding this aspect, it is apparent that percentage reductions in ADFs are fairly limited to more typically ‘minor adverse’ if reductions were considered on a similar categorisation basis to that of VSC and Daylight Distribution.

8.4.28 In summary, there is some significant adversity to daylight reductions to Whitgift House to the living rooms and bedrooms with windows facing site. For VSC, such reductions are ‘moderate adverse’ on an individual VSC review basis throughout and for daylight distribution, typically (for living rooms) ‘major adverse’ to ground floor and ‘moderate adverse’ to 1st floor (other floors then meeting BRE Guide target criteria for daylight distribution). For supplementary analysis, in terms of ADF, reductions for the application scheme are typically ‘minor adverse’. However, in terms of daylight reductions, it is important to highlight that we are commencing reductions from good daylighting level in respect that existing VSCs are over a VSC of 27% and daylight distribution is almost 100%.

8.4.29 In consideration of retained values for both VSC and daylight distribution, whilst the majority could be considered still ‘reasonable / not unexpected for an urban locality’ and above informal alternative target criteria. Whilst the effect of the proposal could be considered overall under EIA classification more towards a ‘moderate / major adverse impact’, when consideration is given to informal alternative criteria, primarily in respect of the retained values, such retained values could still be considered reasonable for such an urban context and acceptable.

2 Whitgift Street

8.4.30 There are 36 windows (including those windows relating to north-west corner bedrooms furthest from the site) serving 17 flats in total with 6 if these flats having windows which are applicable for assessment. This effectively relates to 1 flat per floor located at the front of the building / facing out onto Whitgift Street. Excluding those windows beneath a balcony /soffit, reductions in VSC are typically ‘moderate adverse’ for the lower storeys (ground, first and second floor) and ‘minor adverse’ for the upper storeys (third, fourth and fifth floor). Retained VSC values for these corresponding windows are all above a VSC value of 20 with the isolated exception at ground floor which have a VSC value of circa 17. Thus the retained values for these windows are considered acceptable.

8.4.31 For windows with a balcony or soffit above, reductions are typically ‘major adverse’ although the actual reduction in real terms is limited in terms of VSC; indeed all reductions do not exceed 5 percentage points with the isolated exception of one bedroom window which is marginally over 5 percentage points. Theoretical consideration on analysis ‘without balconies’ does not significantly or materially improve the reduction percentages indicating that in terms of VSC, so it could be more the obstruction resulting in adverse effect rather than the inherent arrangement of the 2 Whitgift Street. However, it is highlight that windows adjacent and outside the balcony soffit area, are minor / moderately affected as opposed to ‘major adverse’ reductions.

8.4.32 The appeal scheme seemed not to have differentiated to any vast degree those windows without balconies and so stated that ‘reductions in VSC would be substantial, with many considerably exceeding 50% … all windows having a noticeable impact’.

8.4.33 Daylight for living rooms at ground to fifth floor levels all have reductions readily within BRE Guide target criteria / minimal reduction to these rooms, especially since they are dual aspect. For the applicable bedrooms reviewed, again, all of these have reductions which readily meet BRE Guide target criteria with the isolated exception to a first floor bedroom (room R3/51) which has a ‘major adverse’ impact reduction and for the second floor bedroom (room R3/52) having a ‘minor / moderate’ adverse impact reduction. Thus in summary, reductions in daylight distribution readily meet BRE Guide target criteria with the isolated exception of 2 bedrooms (daylight considered less important to bedrooms).

8.4.34 For the applicable Living / Kitchen / Diners (LKD) reviewed, all would achieve an ADF in the proposed scenario of over 1.5% (meets target when considering the predominant room use) with the isolated exception of the first floor LKD (room R4/51) which has an ADF of 1.36% (thus within 10% of the target). For the bedrooms, retained values are much worst and the balcony position / soffit is considered to be having some effect, especially in for the lowest floors, as existing, only a circa 1% ADF was achieved even with minimal massing opposite. For the applicable LKDs reviewed, all would achieve an ADF in the proposed scenario of over 1.5% (meets target when considering the predominant room use) with the isolated exception of the first floor LKD (room R4/51) which has an ADF of 1.36% (thus within 10% of the target). For the bedrooms, retained values are much worse but typically has only just met ADF target criteria as existing / with minimal massing opposite.

8.4.35 Given all of the above, the impact of the proposal can be considered ‘moderate’ overall under EIA classification, especially when consideration is given to informal alternative criteria, primarily in respect of the retained values, such retained values could still be considered reasonable for such an urban context and acceptable.

9 Albert Embankment – Building A – East

8.4.36 There are 162 windows within 9 Albert Embankment - Building A - East. In terms of VSC, from the 162 windows analysed, 66 meet BRE Guide target criteria (41%) whilst 96 windows (59%) do not meet target (reductions greater than 20% if a retained value of 27 is not achieved). For the 96 windows not meeting target, reductions are as follows:

 Major adverse: 23 windows (3 living rooms and 20 bedrooms)  Moderate adverse: 45 windows (27 living rooms and 18 bedrooms)  Minor adverse : 28 windows (4 living rooms and 24 bedrooms)

8.4.37 From the analysis, the theoretical analysis of VSC ‘without balconies’ does appear to significantly reduce the adversity thus for VSC. It is apparent that VSC ‘without balconies’ analysis, for the lower half of the building (1st to 6th floor inclusive), VSC losses would be typically in the lower proportion of ‘minor adverse’ / close to not exceeding a 20% reduction, which for the upper half of the building (7th to 11th floor inclusive), reductions typically are not exceeding a 20% reduction / ‘within’ BRE Guide target criteria. With due analysis of an urban context, it is reasonable to state that in terms of impact to the windows serving habitable rooms, the adversity is resulting more from the inherent sensitivity of windows beneath balcony soffits / projections above windows to this neighbouring property for VSC review.

8.4.38 With respect to daylight distribution, impact can be summarised as follows:

 Major adverse: 8 (4 living rooms and 4 bedrooms)  Moderate adverse: 6 (4 living rooms and 2 bedrooms)  Minor adverse: 6 (3 No living rooms and 3 bedrooms)

8.4.39 A total of 20 rooms would have some adverse impact to daylight distribution with the majority of the reductions relating to rooms on the lowest 3 to 4 residential floors. In consideration of retained values, if considering an alternative target value of 50% of the room area remaining with daylight distribution, then such adversity would be reduced to 8 rooms (4 living rooms and 4 bedrooms). In terms of consideration of theoretical analysis ‘without balconies’ conversely to VSC review, whilst this reduces the impact, this makes fairly limited difference suggesting the reductions / impact (at least in reference to daylight distribution) is resulting more from the proposal than any inherent limitation / sensitivity. However, given the adversity highlighted relates to the lowest floors, it is considered that the impact is rather that these habitable rooms, whilst having reasonable daylight distribution as existing, are still sensitive to direct skylight from a limited direct / gap between existing properties which these rooms are then more sensitive to reduction to such a gap from the proposed massing. Thus it is considered that it is more the inherent context that is resulting in some isolated adversity in terms of daylight distribution.

8.4.40 In terms of ADF analysis, with the exception of the first floor which has larger windows, ADF is already limited / below target criteria even as existing for the lowest three floors (second, third and fourth floors) thus already some increased reliance upon artificial lighting. This would suggest that whilst the proposal would have some impact on these floors in terms of daylight distribution, the actual quantum of daylight in terms of ADF is already limited / does not meet target criteria even as existing. In summary, there will be a noticeable reduction to 96 windows relating to VSC albeit circa half of this impact can be considered as ‘moderate adverse’ then circa a quarter ‘major adverse’ and remaining quarter ‘minor adverse’). However, in the theoretical analysis of ‘without balconies’ the impact is significantly reduced suggesting the balconies are an inherent factor to VSC sensitivity.

8.4.41 In terms of daylight distribution, there is some adverse impact to daylight distribution with the majority of the reductions relating to rooms on the lowest 3 to 4 residential floors. In consideration of retained values, if considering an alternative target value of 50% of the room area remaining with daylight distribution, then such adversity would be reduced to 8 rooms (4 living rooms and 4 bedrooms). In terms of the ADF review, these lower floors already have limited daylight levels (low ADF values / increased reliance on artificial lighting). In summary, there is some adversity to the lower half of this neighbouring property but in consideration of theoretical and supplementary analysis, it is apparent that some of this sensitivity is inherent e.g. balconies, etc. In consideration of such inherent sensitivity and retained values, it is considered that such adversity is more isolated (lower floors) in consideration of all habitable rooms to this neighbouring property with windows facing the proposal. Given all of the aforementioned, the impact from the proposal could be considered ‘moderate’ overall under EIA classification and on that basis, could be considered acceptable.

9 Albert Embankment – Building A – West

8.4.42 The ground floor is in commercial use with residential above. Adversity from the proposal in terms of VSC is fairly minimal; typically meeting BRE Guide target criteria with some ‘minor adversity’ (except for isolated areas of ‘moderate adversity’ but in such instances, retained VSC is above mid-teens). For daylight distribution, reductions typically meet BRE Guide target. The reductions are therefore considered acceptable.

9 Albert Embankment – Building B

8.4.43 The ground and first floors are in commercial use with residential above. Adversity from the proposal in terms of VSC appears fairly minimal; typically meets BRE Guide target criteria with some ‘minor adversity’ (except for isolated windows directly below balcony projections which have greater adversity). For daylight distribution, reductions typically meet BRE Guide target criteria with some ‘minor adversity’ (very isolated ‘moderate adversity’) at lower levels. The reductions are therefore considered acceptable.

Parliament House, 81 Black Prince Road

8.4.44 The ground and first floors are in commercial use with residential above. In the VSC analysis undertaken, windows typically meet BRE Guide target criteria with some isolated adversity typically considered ‘minor’. In terms of daylight distribution, the analysis indicated for any applicable reduction, these all meet BRE Guide target criteria. In summary, any applicable reductions in daylight to property typically meets or is close to BRE Guide target criteria and are considered acceptable.

71 Black Prince Road

8.4.45 There is residential above the ground floor commercial café (former Queens Head PH) and rooms will be adversely affected. In terms of VSC, reductions are ‘major adverse’ with retained VSC values being at the low end of mid-teens. In terms of daylight distribution, existing values range from 93.6% to 98.8% thus heading towards almost 100%. The reductions to the values to these particular three rooms will be ‘major adverse’ with retained values in the proposed being 41.8%, 32.7% and 50.1%. From the Council’s records, however, these rooms are not denoted as to a particular room use thus it is difficult for judgement on supplementary review of ADF values given the room use is unknown. In summary, whilst the extent of residential accommodation is limited to this property, there is noticeable adversity in reductions to daylight albeit the room use to these three rooms is unknown.

73-79 Black Prince Road

8.4.46 There are 16 bedrooms with windows facing / in close proximity to the site (4 bedrooms per floor x 4 storeys). Whilst there are some ‘major adverse’ reductions to VSC in term of retained values, these are all at minimum mid-teens and above. In terms of daylight distribution, these typically meet BRE Guide target criteria. In terms of ADF analysis, the ADFs in the proposed scenario are typically circa 1% or more (1% ADF minimum target for bedrooms). In summary, such reductions could be considered acceptable.

15, 16 & 17 Lambeth High Street

8.4.47 This property is divided into small flats / studio units (social care). VSC reductions (excluding secondary windows) typically meet BRE Guide target criteria with isolated ‘minor’ or ‘moderate’ adversity. For daylight distribution, these typically meet BRE Guide target criteria. The impact on daylight to this property is considered acceptable.

44 Lambeth High Street

8.4.48 There appears to be 2 flats above commercial (Windmill PH). Whilst typically there will be ‘moderate’ or ‘major’ adversity relating to reductions in VSC to some windows, in terms of daylight distribution, reductions meet BRE Guide target criteria. ADFs in the proposed scenario are typically meeting for living room or bedroom use thus on balance, such reductions overall could be considered acceptable.

Sunlight

8.4.49 In consideration of reductions in the availability of sunlight to living rooms, typically reductions would generally meet BRE Guide target criteria or relatively close to target for applicable properties with living room windows facing within 90 degrees of south. Whilst there is some isolated adverse reductions to bedrooms, these are limited and bedrooms are considered less important for sunlight.

8.4.50 In terms of availability of sunlight to amenity areas, these meet the BRE Guide target criteria in terms of the BRE 2 hour test. For consideration on transient shadowing, there is no adverse impact. This includes consideration of the objections raised of adverse shadowing to the Garden Museum, 5 Lambeth Place Road; this amenity is some distance away from the proposal and there is very limited impact and this is not considered adverse. In summary, the proposal does not result in any significant reductions to sunlight to neighbouring properties / typically meets / close to the BRE Guide target criteria.

Conclusion

8.4.51 Considering all aspects in terms of daylight and sunlight, the proposed scheme does result in some adverse and noticeable reductions in daylight but for such reductions, these need to be considered in reference to the detail and background to the particular property under review. Clearly, there is a degree of adversity to the daylight to some of the residential neighbouring properties resulting from the proposed massing. This degree of adversity primarily relates to the windows / rooms within the areas identified / applicable within Whitgift House, 2 Whitgift Street, 9 Albert Embankment – Building A – East, 71 Black Prince Road, 73-79 Black Prince Road. In terms of sunlight, for reductions to neighbouring properties, the proposal adheres closely to the BRE Guide with minimal departure.

8.4.52 Given the target compliance to the BRE Guide is not mandatory, it is reasonable to say that given the effect to some neighbouring properties in terms of daylight reduction, the overall merits of the scheme will have an influence on the balance of acceptably (in terms of isolated harm versus the benefits). However, for an urban scheme of this nature, it is considered that the adversity impact could be considered acceptable with the scheme also representing an improvement (lesser impact) when compared to the appeal scheme.

8.4.53 In terms of the recent Graphite Square Appeal (Scheme A & B), whilst it is not possible to completely make direct comparisons, in terms of consideration towards retained target values / alternative targets, many neighbouring properties impacted by the proposed 8 Albert Embankment scheme would still meet the alternative target criteria set within the Graphite Square Appeal although accepted, the context and neighbouring impacts should always be considered relevant to site specifics.

Outlook, Openness, Privacy and Overlooking

8.4.54 As shown in Figure 29 below, the development has been designed to ensure no undue overlooking or loss of privacy to neighbouring residential properties. With respect to the possible implications on amenity by way of overlooking and impact on privacy to existing neighbouring occupiers, this has been addressed through the careful positioning of windows and balconies to minimise the potential for overlooking. The development has been designed to ensure that privacy is maintained where the separation distances fall short of the 18m. The windows and balconies within the extended Headquarters Building and proposed residential blocks are appropriately located and designed to ensure no undue overlooking or loss of privacy to residential properties in Albert Embankment (the nearest neighbouring property, No.9, is located approximately 14m-18m at its nearest point), Black Prince Road (the nearest neighbouring properties, No. 71 and 73-79, are located approximately 10.4m-10.6m at their nearest point), Lambeth High Street (the nearest neighbouring property, No. 17, is located approximately 10m at its nearest point), Newport Street (the nearest neighbouring properties, Nos. 57-67, are located approximately 17.4m at their nearest point), and Whitgift Street (the nearest neighbouring properties, Whitgift House and No.2 Whitgift Street are located approximately 21m and 17m respectively).

8.4.55 Given the separation distances proposed and positioning of the proposed windows and amenity areas, the proposed development would not appear visually overbearing or result in any undue overlooking or loss of privacy to neighbouring residential properties.

Figure 29 – Relationship with Neighbouring Properties on Central Site (separation distances)

Noise and Vibration

8.4.56 Chapters 5 and 9 of the ES and the separate Basement Impact Assessment provided include a full assessment of the likely noise impacts during the construction phase, the noise effects of the development and the noise effects on the development on existing neighbouring residential occupiers. 8.4.57 The Basement Impact Assessment report provided identifies that the basement will be circa 10m or 3 storeys deep. In respect of construction noise, the assessment identifies that the effects during construction will be negligible to major adverse in the short to medium term. However, such instances are anticipated to be limited to discrete activities and of limited duration. Best practice measures and, construction hours’ limitations have been recommended.

8.4.58 No objection has been raised by the Council’s Environmental Health section to the findings of the assessments undertaken. A Construction, Environmental and Management Plan (CEMP), including construction noise monitoring and reporting, will be adopted and agreed with the Council by condition with control of the final mitigation measures being secured by s106 legal agreement.

8.4.59 At this stage, the precise location and type of all fixed plant during the operational phase have not yet been determined. Noise emission limits have therefore been set for fixed plant items to inform the selection and design process associated with the fixed plant and their installation to ensure that sound levels are adequately controlled. The ES assessment notes higher ambient noise levels due to the site’s proximity to Albert Embankment. The assessment of change in road traffic noise levels on the local road network as a result of the proposed development has shown that effects would not be significant and no mitigation measures are required. Noise levels relating to proposed plant and machinery would be secured by condition to ensure no undue disturbance to existing neighbouring residential properties.

8.4.60 The proposed development achieves acceptable standards for existing residential occupiers, in accordance with national and local standards. Subject to the above matters relating to noise being secured by condition, the proposal would not result in any significant increase in noise and disturbance to existing neighbouring properties.

8.5 Designing Out Crime

8.5.1 Local Plan Policy Q3 requires developments to be designed in a manner that does not engender opportunities for crime or anti-social behaviour, or create a hostile environment that would produce fear of crime.

8.5.2 For a development of this nature, the main considerations would relate to counter terrorism, access to the building and the areas of public realm around the building. No objection has been raised by the Designing out Crime Officer to the proposed development which would incorporate principles of Secured by Design. Conditions requiring a delivery and servicing plan, public realm management plan, a car park management plan and Secured by Design certification will ensure that the proposed development provides a safe and secure environment.

8.6 Ecology, Trees and Landscaping

8.6.1 Policy Q9 of the Local Plan reflects the aims of Policy EN1, promoting opportunities for greening as well as protection and enhancement of existing biodiversity. Policy Q9 also supports the use of landscaping to provide strong boundary treatments, together with access routes and parking areas compliant with safety standards and minimum parking standards.

8.6.2 A Phase 1 Habitat Survey of the site provided with the application has confirmed that the site is of limited ecological interest and that there is a limited scope for development to cause negative ecological impacts. Accordingly, it is possible for the proposed development to result in a net positive impact on biodiversity.

8.6.3 In order to achieve this, the following measures recommended by the Phase 1 Habitat Survey will deliver benefits for wildlife in accordance with the strategy of Policy 7.19 of the London Plan and Policy EN1 of the Local Plan to take advantage of opportunities to deliver positive gains for nature through the layout, design and materials of the development:

1. Tree planting and other soft landscaping at the site using species that have known benefits to wildlife; 2. Bird boxes to be installed at suitable locations; and 3. The installation of green walls and roofs.

8.6.4 These approaches have been incorporated into the landscaping proposals, which propose extensive hard and soft landscaping across the site, including:

1. Creation of green walls such as the centre of the south elevation of the Whitgift Street Building to frame the Central Garden; 2. Installation of bat, bird and bug boxes/units; 3. Tree planting throughout the site, including the creation of a run of tree planters along the length of the Central Garden; and 4. Implementation of green/brown roofs on the upper levels of the buildings including green roofs above the east and west towers and species rich lawn.

8.6.5 Overall, extensive areas of hard and soft landscaping are proposed across the site at ground, lower ground and roof level, offering a substantial improvement for a site that currently has no formal landscaping as shown in Figure 30 below. An Arboricultural Assessment provided with the application confirms that the only part of the site which contains trees is the East Site, where 3 self- seeded multi-stemmed trees are present. The assessment identifies that they are of poor quality (Category C) and that their removal is therefore acceptable. Suitable replacement trees are to be secured by condition as part of the overall landscaping scheme.

Figure 30 – Proposed landscaping and green roof strategy for the site

8.6.6 Overall, the landscaping proposals will provide a material uplift in the ecological value of the site. The proposals therefore provide positive contributions though significantly improved landscaping across the site (over 2,084sqm of substantial new public realm and open space, representing 20% of the application site area is proposed), creating benefits for local wildlife subject to the implementation of appropriate avoidance and mitigation.

8.7 Transport

8.7.1 Policies 6.1 and 6.3 of the London Plan seeks to ensure that the impacts of development in transport capacity and the transport network are fully assessed.

8.7.2 Policies T3, T6, T7 and T8 of the Local Plan seek to ensure that proposals for development will have a limited impact on the performance and safety of the highway network and that sufficient and appropriate car parking and cycle storage is provided whilst meeting objectives to encourage sustainable transport and to reduce dependence on the private car. If development will have an unacceptable transport impact, it should be refused in the absence of mitigation measures to make the development acceptable.

Site context

8.7.3 The site is located on the east side of Albert Embankment which forms part of the Transport for London Route Network (TLRN), at the junction with Black Prince Road. It is bound by Whitgift Street to the north, the railway and Newport Street to the east, Southbank House and Black Prince Road to the south and the Albert Embankment to the west.

8.7.4 The site has a PTAL level of 6a, which is considered ‘excellent’, and is the highest level of accessibility. The site is within the Kennington ‘K’ CPZ, which is operational Monday-Friday 08:30- 18:30. The Transport Assessment (TA) Addendum contains a review of accident data. The majority of accidents which have occurred locally were a result of driver, pedestrian or cyclists failing to look properly, or exhibiting reckless or careless behaviour, and not specifically attributable to highway design, vehicle flows or speeds.

Access

8.7.5 Vehicular access to the Central Site is proposed via the internal service road, providing access to 3 x loading bays and the ramp to the basement car parking. The internal service road is proposed to operate one-way, with entry from Lambeth High Street and exit onto Whitgift Street. Access to the internal service road is proposed to be controlled by retractable bollards.

8.7.6 The access arrangements for the Fire Station are proposed to remain essentially as existing. It’s proposed that fire appliances exit the site onto Albert Embankment, returning (in forward gear) to the rear via Lambeth High Street. However, TfL’s proposal for Lambeth Bridge South indicate restricted vehicle turning movements from Lambeth Palace Road to Lambeth Road - making this arrangement difficult for vehicles returning from the north of the site. TfL have stated that an alternative could be to route via Black Prince Road to access Lambeth High Street, avoiding significant re-routing. However, the existing road layout and building line inhibits that manoeuvre for larger vehicles. The applicant is therefore required to enter into a planning obligation to agree an alternative access, to ensure that the two schemes are compatible. It is likely that TfL will also be a party to the appropriate agreement.

8.7.7 Many of the existing footways surrounding the site are narrow. Under the proposals, new 2 metre wide footways would be created around the site, which would be dedicated as public highway, to be secured via a S38 agreement within a S278 agreement to be agreed.

Sustainable travel and cycle parking

8.7.8 In total, 933 long-stay and 139 short-stay cycle parking spaces are proposed. The total number of cycle parking spaces proposed is 1,072, which exceeds (draft) New London Plan Policy T5. Long- stay cycle parking is proposed by way of secure and covered locations within the site. Short- stay cycle parking spaces are proposed at easily accessible locations within and around the site. Lockers, showers and on-site changing facilities have also been incorporated into the design of the proposals to further encourage cycling. The cycle parking facilities are accessed from street-level via ramps and appropriately sized lifts. Provision of free cycle hire membership for all residential units is proposed, and cycle hire keys will be available to 10% of employees.

8.7.9 Provision of three years Car Club membership is also proposed for all residents from first occupation of the development to be secured via s106 legal agreement. A car club bay and fast charge point is also proposed on Lambeth High Street immediately to the north of Whitgift Street, to be secured via s106 agreement.

8.7.10 Electric vehicle charge points are to be provided for all car parking to meet London Plan standards. All loading bays, within the site and on the public highway will have EV charge points. A financial contribution of £10,000 is required for each EV charge point to be installed on the public highway. The delivery and servicing strategy includes a commitment to 50% freight consolidation, to reduce the number of servicing vehicles on surrounding roads. The development will be parking permit-free for all residents and employees on site, and a Travel Plan will cover all uses proposed on site.

Pedestrian and Cycling Infrastructure & Network Impacts

8.7.11 Pedestrian and cycle access will be provided by the network of footways and carriageways that make up the existing public highway. The development will also provide enhanced public realm between Black Prince Road, Lambeth High Street and Whitgift Street. This will allow pedestrians to travel through the Site and provide access to building entrances and cycle parking facilities.

8.7.12 Lambeth High Street will feature a 60mm kerb line where required to differentiate vehicular carriageway within the public highway, and provide for mobility impaired pedestrian traffic. A raised table informal pedestrian crossings will be provided across Whitgift Street at Old Paradise Gardens, and at the Whitgift Street junction with Lambeth High Street.

8.7.13 Baseline pedestrian and cycle traffic around the Site is comparatively low for inner London. The highest pedestrian flow near the Site is on the Albert Embankment footpath adjacent to the River Thames – with an average pedestrian traffic flow of 477 pedestrians per hour. Away from Albert Embankment - the next highest pedestrian flow is on Black Prince Road – with an average pedestrian flow of 289 pedestrians per hour. The highest Baseline cycle flow near the Site is on Albert Embankment – with an average traffic flow of 279 cyclists per hour. However, the proposals will generate significant increases in pedestrian and cyclist traffic.

8.7.14 A total of 803 (2 way) development related trips will be generated by the proposal in the AM peak, with 879 (2 way) trips in the PM peak hour. The office (B1) element of the application presents the largest trip generator, comprising 340 (AM) person trips and 328 (PM) person trips. Public transport is the key mode that will support the movement of people to and from the site – reflecting the excellent public transport provision.

8.7.15 Whitgift Street and Newport Street form part of Lambeth’s proposed Healthy Routes Network, and this area (between Lambeth Road and Kennington Lane) is also a high priority as a Low Traffic Neighbourhood (LTN), as defined in Lambeth’s Transport Strategy. Therefore a financial contribution towards the delivery of the LTN, delivering traffic reductions to facilitate walking and cycling, is to be secured by s106 legal agreement.

Car parking

8.7.16 The site will be parking permit free, secured via s106 legal agreement. All residents and employees will be prevented from applying for parking permits. The previously proposed 36 x standard residential bays have been removed from the amended proposals and only parking for people with disabilities is now proposed. The entire development will be secured as parking permit free (for both residents and business permits) with 44 basement disabled parking spaces proposed for the residential units, and an additional 5 disabled bays proposed on the service road within the site, to serve the other uses on site (Office = 1 space; Hotel = 1 space; Museum = 1 space; Retail = 1 space; and Dry Gym = 1 space) and 10 operational car parking spaces are proposed for the fire station within the drill yard. EV charge points would also be secured by condition.

8.7.17 A Car Club bay is also proposed on Lambeth High Street immediately north of Whitgift Street. A financial contribution of £10,000 for the provision of a Car Club bay, together with an associated fast charge point (£10,000), is to be secured by s106 legal agreement.

8.7.18 A previously proposed drop-off bay on Albert Embankment has been removed from the proposals following a Stage 1 Road Safety Audit which confirmed potential road safety issues. It is understood the drop off would now take place in the drill yard, accessed from Lambeth High Street. This change is welcomed. The previously proposed designated coach drop-off bay has also been removed from the proposals, which is welcomed. Alternative coach parking facilities are available on Albert Embankment.

8.7.19 In line with Policy T1 of the Local Plan, which prioritises walking over taxis, the previously proposed taxi rank on Lambeth High Street has been removed to provide a wider footway. No suitable alternative location has been identified. There are 2 x alternative taxi ranks within approximately 300m of the site.

Servicing

8.7.20 The servicing and delivery strategy for the development is based on the provision of five new loading/unloading bays, both within the site and on the surrounding public highway. Three loading bays are located within the site, on the internal service road which is proposed to operate one-way, with entry from Lambeth High Street and exit onto Whitgift Street. The originally proposed half-on- half-off-loading bay on Whitgift Street is now proposed on the carriageway, to provide a wider footway. The previously proposed half-on-half-off-loading bay on Newport Street has now been removed, to prevent obstruction of the carriageway. A new loading bay is now shown in a more appropriate location on the carriageway in an indicative location on Black Prince Road. Final details of this bay together with a contribution (£10,000) towards its installation and an associated Rapid Charge point (£10,000) are to be secured by s106 legal agreement.

8.7.21 The previously proposed loading bay on the footway on Lambeth High Street at the junction with Black Prince Road has been removed, to ensure the availability of the footway for pedestrians. Land is to be offered up for adoption to be dedicated as highway to create an improved footway and will be secured by s278 agreement.

8.7.22 The changes to the loading strategy (involving the loss of one on-street loading bay) necessitate a more efficient servicing strategy. A 50% target has been agreed for freight consolidation, and the final Delivery and Service Management Plan (DSMP) should include a commitment to a Freight Consolidation Strategy, targeting a 50% reduction in servicing trips. The s106 legal agreement will also include a mechanism to control the level of freight consolidation, whereby the number of servicing trips generated by the development would be capped at an agreed level (e.g. 72 daily servicing trips, which is half the number of servicing trips predicted in the TA), and the developer would monitor the number of servicing trips generated by the site. The DSMP should also include a service routing diagram, minimising the use of local streets to approach the site.

Construction

8.7.23 Wates Construction have produced an outline Construction Traffic Management Plan (CTMP) for the proposed development. The forecast maximum number of lorry movements associated with construction is estimated at 95 lorry arrivals per day. The maximum daily HGV construction vehicle forecast is identified for the week commencing 28th March 2022. For that week 95 daily construction traffic HGV arrivals are forecast on-site. No temporal profile for daily arrivals is provided in the supporting data. Therefore, assuming a flat arrival profile over a 10-hour working day (0800-1800) gives 10 HGV arrivals per hour for construction traffic. It is noted that there are several planned schemes within the area which will likely disrupt traffic movements during this time. A detailed Construction, Environmental and Management Plan would be secured by condition, which should prioritise the safety of other road users,

Mitigation

8.7.24 The following mitigation measures will be delivered as part of the development:

 Car club 3yrs free membership per household;  New Car Club bay on Lambeth High Street;  Parking permit-free for employees and residents;  Construction Traffic Management Plan;  Delivery and Service Management Plan, including a commitment to 50% freight consolidation;  Travel Plan and monitoring  Management plans including: o Hotel Visitor Management Plan; o Museum Visitor Management Plan; o Estate Management Plan; and o Residential Car Parking Management Plan;  Provision of Rapid Charge Points for two on-street loading bays on Whitgift Street and Black Prince Road;  Contribution towards Low Traffic Neighbourhood on local streets in the area;  3 years free cycle hire membership for residential units; and  Cycle hire keys available covering 10% of employees.

8.7.25 No objection has been raised by the Council’s Transport and Highways Sections to the proposals. Subject to the above mitigation measures, the proposals would be in accordance with Policies 6.1 and 6.3 of the London Plan and Policies T3, T6, T7 and T8 of the Local Plan.

8.8 Sustainable Design and Construction

8.8.1 Policies 5.2 and 5.3 of the London Plan state that development proposals should minimise carbon dioxide emissions and exhibit the highest standards of sustainable design and construction, whilst Policy 5.7 states that they should provide on-site renewable energy generation. Policy 5.5 states that Boroughs should seek to create decentralised energy networks, whilst Policy 5.6 requires development proposals to connect to an existing heating network as a first preference if one is available.

8.8.2 Policy 5.3 provides a list of the sustainability criteria against which planning applications will be assessed. The London Plan policy seeks to ensure the following sustainable design principles:

 Minimizing carbon dioxide emissions across the Site, including buildings and services  Avoid internal overheating and contributions to the urban heat island effect  Efficient use of natural resources including water  Minimising pollution (including noise and air)  Minimising the generation of waste and maximizing reuse or recycling  Ensuring developments are comfortable and secure for users  Securing sustainable procurement of materials  Promoting and protecting biodiversity and green infrastructure

8.8.3 Policy EN3 of the Local Plan EN3 requires development to utilise decentralized heating, cooling or power networks in the vicinity of the site, or future proof for planned energy networks.

8.8.4 London Plan Policies 5.1 and 5.2 also expect an overall reduction in carbon dioxide emissions by 60% by 2025, and it is expected that under guidance from the GLA, London boroughs will take measures to meet this target. Policy 5.2 requires development to implement measures designed to reduce carbon dioxide emissions. It requires new residential buildings forming part of major development proposals to be 'zero carbon'.

8.8.5 The London Housing SPG defines 'zero carbon homes' as homes forming part of major development applications where the residential element of the application achieves at least a 35% reduction in regulated carbon dioxide emissions (beyond Part L Building Regulations 2013) on-site (in line with London Plan Policy 5.2B). The remaining regulated carbon dioxide emissions, to 100%, are to be offset through a cash in lieu contribution. In Lambeth, contributions will be set at £1,800 per tonne of carbon, which represents £60 per tonne over a period of 30 years. In accordance with Policy 5.2, non-domestic development should seek to achieve a 35% reduction against Part L 2013.

8.8.6 The London Plan also requires that the development follows an energy hierarchy when considering reducing CO2 emissions. The energy hierarchy must consider incorporation of energy efficiency measures including passive design, supplying energy efficiently (with a particular emphasis on decentralised energy generation including CHP) and using renewable energy technologies.

8.8.7 The Energy Statement submitted identifies the following measures, as shown in Figure 31 below, which seek to maximise carbon savings:

1. A highly efficient building fabric; 2. Efficient building services plant, including providing high efficiency air handling plant with heat recovery and low specific fan power; 3. 100% low energy lighting and maximised use of LED and low energy fixtures; 4. Heat and cooling networks provided by Air Source Heat Pumps, Water Source Heat Pumps, high efficiency Water Cooled Chillers and high efficiency boilers serving the West and Central Sites; 5. High efficiency VRF system providing heat and hot water to the East Site; and 6. Roof mounted PV panels.

Figure 31 – Proposed Energy Strategy for the site

8.8.8 Overall, the Energy Strategy confirms that a 52.5% CO2 reduction is achieved over the Building Regulations Part L 2013 baseline utilising SAP 10.0 carbon factors. As well as the development as a whole exceeding the minimum carbon reduction target of 35% set by the GLA, the residential (63% carbon reduction) and non-residential (46.1% carbon reduction) elements also meet the targets for zero carbon homes and 35% CO2 reductions for commercial developments. Residential elements have maximised efforts to achieve targets set by Lambeth and the GLA (zero carbon homes). As explained within the Energy Strategy, investigations into further methods to reduce energy consumption and carbon emissions have been undertaken and have shown that these are not feasible. A financial contribution relating to the shortfall in carbon reductions will therefore need to be secured. Carbon offsetting will be calculated and paid on completion of each construction phase in accordance with an updated Energy Statement for that phase to be secured through by s106 legal agreement.

8.8.9 In order to comply with Policy EN4 of the London Plan, pre-assessments have been conducted which confirm that it is feasible for all new build, non-residential elements of the development to achieve BREEAM Excellent. The Sustainability Statement submitted demonstrates that for those parts of the development which are proposed to be refurbished (i.e. the Former Headquarters Building), it is not technically feasible to meet ‘Excellent’ standard. Rather, these areas will instead target a minimum of BREEAM rating ‘Very Good’ with a scope of achieving the 63% threshold, thereby meeting the required target of Policy EN4 b (ii). Additionally, all new build residential elements of the development are targeting Home Quality Mark ‘3 Star’ rating.

8.8.10 The Sustainability Statement outlines that the proposed development aims to maximise opportunities for water efficiency, which include the use of water saving fixtures and fittings, reduced water flow rates and the installation of water meters to all residential units. Additionally, all residential units will be designed to meet a water consumption rate of 105 litres per person per day.

8.8.11 In accordance with Policy EN7, a Waste Management Strategy has been provided. This, together with the Sustainability Statement, identifies that construction waste and waste created through the operation of the development are sought to be minimised in accordance with the waste hierarchy and sufficient internal space for the storage, recycling and composting of waste has been incorporated for all proposed uses. The Statement confirms that the proposed development has been carefully designed to take the likely impacts of climate change into account. The incorporation of SuDS, brown roofs and other sustainability measures will reduce the water demands of the development and manage it as close to its source as possible. The proposed development also includes some planting to combat the effects of climate change; incorporates solar control glazing to reduce reliance on air conditioning systems and effective ventilation to reduce internal heat gains.

8.8.12 Due to the site’s accessible location, the proposed development also takes opportunities to encourage transport by non-car modes and provides 1,071 cycle parking spaces (933 long stay and 138 short stay) to encourage sustainable modes of travel. Lockers, showers and on-site changing facilities are incorporated into the design to further encourage this and no car parking spaces are proposed for the office, hotel and retail occupants. The Transport Assessment also includes a draft Travel Plan which will encourage and maximise the use of sustainable travel options available in the vicinity of the site.

8.8.13 Notwithstanding the evolving Energy Strategy, the proposed development has been designed to be highly sustainable and maximise the potential carbon savings that can be achieved in accordance with the aims of the NPPF, London Plan, the Mayor’s Sustainable Design and Construction SPG and Lambeth Local Plan.

8.9 Other Environmental Matters

8.9.1 Flood Risk

8.9.2 The NPPF states that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk but, where development is necessary, making it safe without increasing flood risk elsewhere. Policy 5.12 of the London Plan states that development proposals must meet flood risk assessment and management requirements. The London Plan SPG states new development should incorporate Sustainable Urban Drainage Systems and green roofs where practical with the aim of maximising all opportunities to achieve a Greenfield run-off rate, increasing biodiversity and improving water quality. Greenfield runoff rates are defined as the runoff rates from a site, in its natural state, prior to any development. Typically this is between 2 and 8 litres per second per hectare. Surface water run-off is to be managed as close to source as possible.

8.9.3 A Flood Risk Assessment (FRA) has been submitted with the application to demonstrate that the proposed development can be satisfactorily accommodated without worsening flood risk for the area and without placing the development itself at risk of flooding, as per National guidance provided within the National Planning Policy Framework document (NPPF) and in accordance with Policy EN5 of the Local Plan.

8.9.4 The Flood Zone Map (FZM) for the locality as produced by the Environment Agency (EA) identifies the site as being located within Defended Flood Zone 3 (high risk). Notwithstanding this, the EA identifies that the River Thames is defended along this section by the Thames Barrier and the Thames Tidal Flood Defences against a tidal flood event that has a 0.1% probability of occurring.

8.9.5 All but three apartments are located at the first floor or above and therefore would remain unaffected in any potential flood event. Three apartments within Whitgift Street Building are located on the ground floor but these units are raised internally to a finished internal floor level of 5.25AOD, which reduces their residual risk of flooding. As noted in the Flood Warning and Evacuation Plan, all units have safe evacuation routes to upper floors.

8.9.6 In summary, The FRA concludes the following:

 Safe refuge areas in case of flood (as detailed in the Flood Water Evacuation Plan appended to the FRA); and  On-site surface water drainage system, including attenuation tanks.

8.9.7 The proposed drainage strategy will ensure that the sustainable management of surface water runoff through the use of SuDS is in line with policy and best practice. The FRA has also informed finished floor levels across the site, which are proposed at levels to prevent overland surface water flow from entering buildings, and identifies that the development will not increase the rate of surface water discharge leaving the site or representative rainfall events up to 1% annual probability (including a climate change allowance), in accordance with NPPF, and therefore will not affect the overall surface water flood risk. Overall, it is concluded that the policy requirements of the NPPF, London Plan policies 5.11-5.15, emerging new draft London Plan Policy SI12 and Lambeth Local Plan policies EN5 and EN6 are met.

8.9.8 No objection has been raised by the Environment Agency subject to conditions relating to flooding prevention measures being attached to any permission granted. The FRA has been undertaken in accordance with the principles set out in NPPF and it concludes that providing the development adheres to the mitigation strategy recommended the proposed development can accommodate without increasing flood risk within the locality in accordance with planning policy objectives.

Air Quality

8.9.9 The site falls within an Air Quality Management Area in relation to a breach of nitrogen dioxide and particulate matters objectives as specified in the Air Quality Regulations 2000. Policy 7.14 of the London Plan requires development to support measures that reduce levels of local air pollution and improve air quality.

8.9.10 Chapter 8 of the ES submitted provides an assessment of the impacts of the development (during construction and operation) on air quality and the impacts of air quality on residents of the development. The assessment of the potential impacts on local air quality from construction activities concludes that the residual effects are not significant. The limited traffic generated by the proposed development and the proposed energy generation plant are also not considered to be significant and no mitigation measures are required.

8.9.11 The ES concludes that the proposed development is air quality neutral in terms of building emissions but not of transport emissions. A number of transport-led mitigation measures are identified in order to reduce the effect of the development on local air quality and the amount of vehicle emissions generated. A condition would therefore be attached to any permission granted requiring the implementation of appropriate mitigation measures to ensure the proposal is air quality neutral. The residual effects of the proposed development are considered to be negligible for NO2 and particulate matter and the overall effect of the proposed development on local air quality is not considered to be significant.

8.9.12 Policy T8 of the Local Plan requires planning applications to be accompanied by a construction and logistic plan, demonstrating arrangements for construction traffic and how environmental, traffic and amenity impacts would be minimised. An outline of the principles of a construction management plan are set out in the submitted documents.

8.9.13 A final management plan will be required setting out full details of the demolition and construction programme to fully protect the locality from the transport and environmental impacts of construction. These further details would be secured by condition. A condition is also recommended to ensure any Non-Road Mobile Machinery (NRMM) used during construction and demolition is compliant with EU regulations in order to minimise detrimental impact on air quality.

Wind Microclimate

8.9.14 Policy 7.7 of the London Plan states that tall buildings should not have an unacceptable harmful impact on their surroundings and should not adversely affect microclimate or wind turbulence.

8.9.15 Chapter 13 of the ES considers the likely significant effects of the proposed development on the site and surrounding area in terms of the wind microclimate. The assessment has been subject to wind tunnel testing which has influenced the design of public and private amenity spaces within the proposed development in order to ensure that the wind microclimate is suitable for the intended use.

8.9.16 The existing wind conditions throughout the site are suitable for existing uses during the windiest times of the year (i.e. sitting use and leisure walking), apart from isolated areas along Black Prince Road which are classified as suitable for ‘business walking use’. The assessment concludes that wind conditions at the proposed building entrances will be suitable for the required use and that balcony conditions will be acceptable for sitting during the summer season. Ground and terrace level amenity spaces are found to be suitable for sitting and are considered suitable for the intended use.

8.9.17 The assessment finds that the effect on one ground floor location (No. 58 – close to the junction of Black Prince Road and Lambeth High Street) is likely to be of moderate negative significance. In order to mitigate against these existing isolated adverse wind conditions, 5 mast-mounted porous baffles are proposed. In view of the location of these baffles on highway land, such mitigation will need to be secured by s106 legal agreement. An application for the stopping up of necessary areas/portions of immediately adjoining highways will also need to be made under section 247 and 248 (as applicable) of the Town and Country Planning Act 1990. With the exception of receptor 58, where wind conditions will be no worse than the existing wind conditions in the baseline scenario (and not due to the proposed development), the ES concludes that embedded mitigation through design, including landscaping, the site is considered acceptable for its intended use throughout the year.

Ground Conditions and contamination

8.9.18 Whilst the Local Plan does not contain specific policies on land contamination, the supporting text to Policy EN4 notes that a remediation strategy should be submitted prior to commencement of development in instances where contamination exists.

8.9.19 Chapter 12 of the ES assesses the likely significant effects of the proposed development associated with potential contamination risks during the construction and operational stages. The assessment is informed by the information available at the time of writing the ES which includes a ground investigation undertaken in the Central part of the Site during October and November 2016 and a further ground investigation in the West Site during April and May 2017. The assessments conclude that:  West Site: Potential risks may be present which may require risk assessment and remedial measures based on the end use. Any areas of contamination identified by ongoing and planned ground investigations will be addressed as a part of the proposed development.  Central Site: Remedial action is not considered necessary as part of the site’s redevelopment, taking the proposed development into consideration.  East Site: Potential risks may be present which may require risk assessment and remedial measures based on the end use. Any areas of contamination identified by ongoing and planned ground investigations will be addressed as a part of the proposed development.

8.9.20 No objection has been raised by either the Environment Agency or the Council’s Environmental Health Section to the proposals. Measures to mitigate the potential effects of contamination are recommended in the ES and would be secured by condition. In addition, a variety of good environmental site practices will be implemented whilst undertaking construction activities in order to avoid or minimise effects at the source. These include dust suppression measures during construction, a Piling Risk Assessment and chemical validation of imported soils for soft landscaping areas.

Archaeology

8.9.21 The West and Central Sites are within the North Lambeth Archaeological Priority Area (APA), while the entire site lies within the Albert Embankment Conservation Area (CA57). The archaeological assessment accompanying the application, as set out in Chapter 7 of the ES, identifies that the development has potential to impact upon buried archaeological deposits. It assesses the relative likelihood of archaeological survival across the site as being low within the where a basement is proposed within the West Site but high across the Central and East Sites and remainder of the West Site as these are largely without basements. Overall, the West and Central Sites are assessed as having the greatest archaeological potential, primarily from the remains of 18th and 19th century pottery manufactories and their associated waste dumps.

8.9.22 The Archaeological chapter of the ES explains that a watching brief was carried out on site during geotechnical investigations works in May 2017 in order to confirm the depths of natural deposits and the presence and extent of the former dock wall and buildings relating to Stiff’s London Pottery works. The watching brief confirmed the presence of the former Stiff’s pottery warehouse in the north of the west site and uncovered possible evidence from the dock walls behind the existing redbrick basement walls.

8.9.23 A total of 14 further investigations have been carried out within the study area, comprising a mixture of evaluations, watching briefs and excavations. Eight of these investigations recorded evidence of pottery manufacture in the area dating from the 17th century through to the 20th century. Little archaeological evidence dating to earlier periods was recorded during these investigations, although prehistoric flint tools, a single shard of Roman pottery, medieval pottery, field boundaries/ditches and cultivation soil have been recovered. The report notes that the proposals could potentially result in the loss of in situ archaeological remains.

8.9.24 Whilst the magnitude of change during the demolition and construction phase is assessed as being up to a Major Negative effect, this could be successfully mitigated through a programme of preservation by record, involving the full excavation of the proposed basement areas for well- preserved remains of high significance or a watching brief for poorly preserved remains. Following mitigation, the assessment concludes that the residual effect during demolition and construction would be reduced to negligible.

8.9.25 Historic England (Archaeology) have reviewed the proposals and have raised no objections subject to pre-commencement conditions requiring the submission and approval of a written scheme of investigation and details of foundation design and construction method being attached to any permission granted.

8.10 Employment and Training

8.10.1 The completed development is estimated to support up to 1,264 jobs, which would be a net increase of 900 jobs compared to the existing development.

8.10.2 Lambeth seeks to maximise local employment opportunities and help address skills deficits in the local population. Accordingly, the s106 legal agreement would secure an Employment and Skills Plan (ESP) developed in accordance with the Employment and Skills SPD (Feb 2018) with the following key requirements:

 Reasonable endeavours to secure 25 per cent of jobs and training opportunities created by the development during construction and the first 2 years of end-use occupation for local residents; and  Engagement with local school and colleges to promote the skills and qualifications needed for employment in the commercial sectors of the end-use occupiers in place during the first two years of the development.

8.10.3 The Employment and Skills SPD also seeks a monetary contribution to help support those sections of the Lambeth workforce that are furthest from employment, having been out of work for a long period of time and/or having low levels of skills. The financial contributions will be used by the council to fund training and support to enable access to newly created employment opportunities arising from development. For this development the financial contribution would be £658,112 based on the formula set out in the SPD. This would be secured by s106 agreement.

8.10.4 Subject to this agreement, the development would be compliant with Policy 4.12 of the London Plan and Policy ED4 of the Local Plan.

8.11 Environmental Impact Assessment

8.11.1 Under the Town and Country Planning (Environmental Impact Assessment) Regulations 2017, the proposed development would fall under Schedule 2 10(b) ‘urban development projects’ as the site area is more than one hectare. Due to the size and nature of the development it is considered likely to have significant effects on the environment and therefore it is ‘EIA Development’. Accordingly, the application was supported by an environmental statement. This statement was peer reviewed by a consultant instructed by the local planning authority and was found to be compliant with the Regulations subject to some clarifications. The content of the environmental statement has been discussed in the relevant sections of this report.

8.12 Planning Obligations and CIL

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

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

8.12.3 The proposed obligations to be secured through the s106 Agreement are as follows:

 Re-provision of fire station and a new fire station museum;  Provision of affordable housing on-site at 40% (calculated by habitable rooms) with 90 Affordable/Social rented units (the 1 and 2-bedroom homes are to be delivered as Affordable Rent capped at Local Housing Allowance levels and the 3-bedroom homes are to be delivered as Social Rent in line with the Council’s Tenancy Strategy) and 82 Shared Ownership units (10 of the Shared Ownership homes will be available for household incomes from £60,000 with the remainder of the units on a sliding scale up to £90,000) being secured;  Affordable housing viability reviews (early and advanced stage);  Provision of flexible MSME workspace at discounted rent;  Employment and training contribution of £658,112;  Employment and skills plan;  Considerate contractors scheme/Nine Elms Construction Charter/Compliance with FORS;  Off-site Children’s Playspace contribution of £3,640;  Legible London contribution of £10,000;  Enter into s278 agreement (and s38 agreement where necessary) for off-site highways works and improvements along Albert Embankment, Black Prince Road, Newport Street and Whitgift Street including adoption of new footways and including such agreements and/or financial contributions as required by TfL;  Public realm and public realm access;  Public Art and Heritage Strategy;  Obelisk relocation;  Wind Mitigation Strategy;  Delivery and Servicing Management Plan including mechanism to monitor 50% freight consolidation with cap on servicing trips (e.g. 72 daily servicing trips - half the predicted number);  Construction, Environmental and Management Plan;  details as agreed with TfL on provision of alternative access; ;  Management plans including: o Hotel Visitor Management Plan; o Museum Visitor Management Plan; o Estate Management Plan; and o Residential Car Parking Management Plan  Travel plans and monitoring (fee is £5,000 per plan) for residential and non-residential uses;  Parking permit free development for employees and residents;  Securing of wheelchair units and associated car parking spaces;  Contribution (tbc) for implementation of Low Traffic Neighbourhood on local streets in the area;  Final Energy statement for future energy network connection, and identify value of any carbon off-setting contribution (estimated currently to be £873,964);  3yrs free cycle hire membership for residential units;  Cycle hire keys available covering 10% of employees;  Car club 3yrs free membership per household;  Provision of 1 Car club bay on-street within the vicinity of the site (£10,000);  Provision of two new loading bays on Whitgift Street and Black Prince Road and installation of rapid charge points (2 x £10,000 = £20,000) with Black Prince Road loading bay to be installed if and when required (depending on final use of the ground floor unit of the proposed Newport Street Building); and  Administration and implementation fee (for obligations of this scale, 5% of total value of financial contributions).

8.12.4 If the application is approved and the development is implemented, a liability to pay the Mayoral and Lambeth Community Infrastructure Levies (CIL) will arise. On the basis of the information supplied with the applications, the Mayoral CIL is estimated to be £4.1m. The Lambeth CIL contribution is estimated to be approximately £8.7 million. Expenditure of the majority of a future CIL receipt will be applied towards Borough infrastructure needs in accordance with the applicable policies and procedures relating to expenditure decisions.

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

9 Conclusion

9.1 The proposed development will bring forward the regeneration of the site and is aligned with the desire for growth within the Vauxhall area. Comprising a new fire station alongside a mix of residential, employment (including low cost and affordable space), retail and other uses, including a LFB Museum and gallery, the proposal will provide a substantial uplift in jobs (approximately 1,264 in total) with a wide-range of flexible employment spaces creating diverse employment opportunities for established business, small to medium sized enterprises and start-ups. If further delivers a significant amount of new public realm (20% of the overall site), including the creation of new pedestrian routes through the site, improving connectivity within the immediate area.

9.2 The proposal would also provide 443 residential units of which 172 would be affordable units (which is 39% of units or 40% by habitable room) which will contribute to meeting the housing needs of the Borough. The proposal has been viability tested and the 40% offer made is considered the maximum reasonable proportion of affordable housing that the scheme can currently provide.

9.3 The height and massing of the development has been assessed in relation to its impact from a wide range of viewpoints and has been found to be satisfactory, including in relation to its impact on heritage assets. An assessment of the current application has identified less than substantial harm caused. This view is supported by both the GLA and Historic England who have also come to the same conclusion. In line with paragraph 196 of the NPPF, the resulting harm would be outweighed by the many public benefits of the proposal which include:

9.4 There is therefore no objection to the development’s height in this location, which has a very high public transport accessibility level. The proposed buildings on the site have been sensitively designed, taking inspiration from the surroundings and historic context of the site, and would respect the character, context and the form and scale of neighbouring buildings and would sit comfortably within the streetscene and surrounding area. The appearance and detailed façade treatment of the development is considered to be high quality, displaying an appropriate response to the surrounding character and the proposal would have no adverse impact on the setting of nearby listed buildings, conservation areas and protected views.

9.5 The proposed development would meet all relevant residential space standards and the provision for private and communal amenity space and play space proposed is considered to be acceptable. Adequate levels of daylight would also be provided within the flats for future residents. The proposal provides units with a good standard of accommodation, in terms of unit sizes, aspect and amenity space provision, being provided.

9.6 The proposed scheme does result in some adverse and noticeable reductions in daylight and sunlight, particularly to Whitgift House. However, some consideration should be given to the particular characteristics of the properties reviewed and to the fairly minimal existing massing on the application site which is unusual in an urban context. It is also reasonable to consider the identified effects alongside the planning merits of the scheme overall. In conclusion officers consider that the many planning benefits that the scheme would deliver are sufficient to outweigh the identified impacts on residential amenity.

9.7 The development would have a sustainable construction, meeting all of the relevant sustainability standards. The ES and technical appendices consider the environmental impacts of the proposals and demonstrate how they are acceptable, propose mitigation where required and conclude that the proposed development will not result in significant adverse environmental effects.

9.8 The proposed development will secure the regeneration and revitalisation of an important site as identified within the Lambeth Local Plan, the VNEB OAPF and the Vauxhall SPG. It will realise LFB’s objectives, support the local area as a destination for arts and culture, whilst also sustaining and enhancing heritage assets and securing their long-term future.

9.9 In conclusion officers consider that the many planning benefits the development would deliver are sufficient to outweigh the identified impacts on heritage and residential amenity; and that, in this instance, taking account of all the relevant material considerations and notwithstanding the departure from the design principles and key development consideration (iv) in the allocation of Site 10, the proposed development on this site should be supported. . As such, the proposal is considered to be acceptable when judged against national, London wide and local plan policy and guidance and all relevant material considerations and is recommended for approval.

9.10 The proposed development is an application of potential strategic importance to London and as such is referable to the Mayor of London pursuant to the Town and Country Planning (Mayor of London) Order 2008. The GLA has issued its stage 1 consultation response, and the officer recommendation contained in this report acknowledges the need to refer the application to the Mayor for his final decision (Stage 2 referral).

10 PROCEDURAL MATTERS

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

11 EQUALITY DUTY AND HUMAN RIGHTS

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

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

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

12 RECOMMENDATIONS

Recommendation A: 19/01304/FUL (Application A)

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

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

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

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

Recommendation B: 19/01305/LB (Application B)

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

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

a. Finalise the recommended conditions as set out in this report, addendums and/or PAC minutes; and

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

APPENDICES

Appendix 1: Draft Decision Notices

Existing and Proposed Drawings & Supporting Documents

Site Location, Ownership and Project Construction Phases 1528-PP-Z0-XX-DR-A-00-1000revP0, 1528-PP-Z0-XX-DR-A-00-1001revP0, 1528-PP-Z0-XX-DR-A-00- 1002revP0, 1528-PP-Z0-XX-DR-A-00-1003revP0, 1528-PP-Z0-XX-DR-A-00-1004revP0, 1528-PP-Z0-XX- DR-A-00-1005revP2, 1528-PP-Z0-XX-DR-A-00-1006revP0, 1528-PP-Z0-XX-DR-A-00-1007revP0, 1528-PP- Z0-XX-DR-A-00-1008revP2, 1528-PP-Z0-XX-DR-A-00-1009revP2

Existing Buildings: 1528-PP-Z0-99-DR-A-01-0099revP0, 1528-PP-Z0-00-DR-A-01-0100revP0, 1528-PP-Z0-01-DR-A-01- 0101revP0, 1528-PP-Z0-02-DR-A-01-0102revP0, 1528-PP-Z0-03-DR-A-01-0103revP0, 1528-PP-Z0-04-DR- A-01-0104revP0, 1528-PP-Z0-05-DR-A-01-105revP0, 1528-PP-Z0-09-DR-A-01-0106revP0, 1528-PP-Z0- XX-DR-A-01-2000revP0, 1528-PP-Z0-XX-DR-A-01-2001revP0, 1528-PP-Z0-XX-DR-A-01-3000revP0, 1528- PP-A2-99-DR-A-01-4000revP0, 1528-PP-A2-00-DR-A-01-4001revP0, 1528-PP-A2-01-DR-A-01-4002revP0, 1528-PP-A2-03-DR-A-01-4003revP0, 1528-PP-A2-05-DR-A-01-4004revP0, 1528-PP-A2-07-DR-A-01- 4005revP0, 1528-PP-A2-09-DR-A-01-4006revP0, 1528-PP-A2-XX-DR-A-01-5000revP0, 1528-PP-A2-XX- DR-A-01-5001revP0, 1528-PP-A2-XX-DR-A-01-5002revP0, 1528-PP-A2-XX-DR-A-01-5003revP0, 1528-99- B0-99-DR-A-01-6000revP0, 1528-PP-B0-00-DR-A-01-6001revP1, 1528-PP-B0-01-DR-A-01-6002revP0, 1528-PP-B0-02-DR-A-01-6003revP0, 1528-PP-B0-XX-DR-A-01-7000revP0, 1528-PP-B0-XX-DR-A-01- 7001revP0, 1528-PP-B0-XX-DR-A-01-7002revP0

Demolition:

1528-PP-Z0-99-DR-A-02-0099revP0, 1528-PP-Z0-00-DR-A-02-0100revP0, 1528-PP-Z0-01-DR-A-02- 0101revP0, 1528-PP-Z0-02-DR-A-02-0102revP0, 1528-PP-Z0-03-DR-A-02-0103revP0, 1528-PP-Z0-04-DR- A-02-0104revP0, 1528-PP-Z0-05-DR-A-02-0105revP0, 1528-PP-Z0-09-DR-A-02-0106revP0, 1528-PP-Z0- 10-DR-A-02-0107revP0, 1528-PP-Z0-XX-DR-A-02-2000revP0, 1528-PP-Z0-XX-DR-A-02-2001revP0, 1528- PP-Z0-XX-DR-A-02-3000revP0, 1528-PP-A2-99-DR-A-02-4000revP0, 1528-PP-A2-00-DR-A-02-4001revP0, 1528-PP-A2-01-DR-A-02-4002revP0, 1528-PP-A2-03-DR-A-02-4003revP0, 1528-PP-A2-05-DR-A-02- 4004revP0, 1528-PP-A2-07-DR-A-02-4005revP0, 1528-PP-A2-09-DR-A-02-4006revP0, 1528-PP-A2-XX- DR-A-02-5000revP0, 1528-PP-A2-XX-DR-A-02-5001revP0, 1528-PP-A2-XX-DR-A-02-5002revP0, 1528-PP- A2-XX-DR-A-02-5003revP0, 1528-PP-B0-99-DR-A-02-6000revP0, 1528-PP-B0-00-DR-A-02-6001revP0, 1528-PP-B0-01-DR-A-02-6002revP0, 1528-PP-B0-02-DR-A-02-6003revP0, 1528-PP-B0-XX-DR-A-02- 7000revP0, 1528-PP-B0-XX-DR-A-02-7001revP0, 1528-PP-B0-XX-DR-A-02-7002revP0, 1528-PP-B0-XX- DR-A-02-7003revP0

Proposed Drawings for planning and listed building applications

1528-PP-Z0-B2-DR-A-03-0097revP1, 1528-PP-Z0-B1-DR-A-03-0098revP1, 1528-PP-Z0-LG-DR-A-03- 0099revP1, 1528-PP-Z0-00-DR-A-03-0100revP3, 1528-PP-Z0-01-DR-A-03-0101revP2, 1528-PP-Z0-02-DR- A-03-0102revP2, 1528-PP-Z0-03-DR-A-03-0103revP2, 1528-PP-Z0-04-DR-A-03-0104revP2, 1528-PP-Z0- 05-DR-A-03-0105revP2, 1528-PP-Z0-06-DR-A-03-0106revP2, 1528-PP-Z0-07-DR-A-03-0107revP3, 1528- PP-Z0-08-DR-A-03-0108revP3, 1528-PP-Z0-09-DR-A-03-0109revP3, 1528-PP-Z0-10-DR-A-03-0110revP2, 1528-PP-Z0-11-DR-A-03-0111revP2, 1528-PP-Z0-14-DR-A-03-0114revP2, 1528-PP-Z0-20-DR-A-03- 0120revP2, 1528-PP-Z0-21-DR-A-03-0121revP2, 1528-PP-Z0-22-DR-A-03-0122revP2, 1528-PP-Z0-23-DR- A-03-0123revP2, 1528-PP-Z0-24-DR-A-03-0124revP3, 1528-PP-Z0-25-DR-A-03-0125revP2, 1528-PP-Z0- 26-DR-A-03-0126revP3, 1528-PP-A0-B1-DR-A-10-0098revP0, 1528-PP-A0-LG-DR-A-10-0099revP0, 1528- PP-A0-00-DR-A-10-0100revP2, 1528-PP-A0-01-DR-A-10-0101revP1, 1528-PP-A0-02-DR-A-10-0102revP1, 1528-PP-A0-03-DR-A-10-0103revP1, 1528-PP-A0-04-DR-A-10-0104revP1, 1528-PP-A0-05-DR-A-10-0105revP1, 1528-PP-A0-06-DR-A-10-0106revP1, 1528-PP-A0-07-DR-A-10- 0107revP1, 1528-PP-A0-08-DR-A-10-0108revP1, 1528-PP-A0-09-DR-A-10-0109revP1, 1528-PP-A0-10-DR- A-10-0110revP1, 1528-PP-A0-11-DR-A-10-0111revP1, 1528-PP-B0-B2-DR-A-10-0097revP1, 1528-PP-B0- B1-DR-A-10-0098revP1, 1528-PP-B0-LG-DR-A-10-0099revP1, 1528-PP-B0-00-DR-A-10-0100revP3, 1528- PP-B0-01-DR-A-10-0101revP2, 1528-PP-B0-02-DR-A-10-0102revP2, 1528-PP-B0-03-DR-A-10-0103revP2, 1528-PP-B0-04-DR-A-10-0104revP2, 1528-PP-B0-05-DR-A-10-0105revP2, 1528-PP-B0-06-DR-A-10- 0106revP3, 1528-PP-B0-08-DR-A-10-0108revP3, 1528-PP-B0-10-DR-A-10-0110revP3, 1528-PP-B0-13-DR- A-10-0113revP2, 1528-PP-B0-14-DR-A-10-0114revP2, 1528-PP-B0-20-DR-A-10-0120revP2, 1528-PP-B0- 21-DR-A-10-0121revP2, 1528-PP-B0-22-DR-A-10-0122revP2, 1528-PP-B0-23-DR-A-10-0123revP2, 1528- PP-B0-24-DR-A-10-0124revP3, 1528-PP-B0-25-DR-A-10-0125revP2, 1528-PP-B0-26-DR-A-10-0126revP3, 1528-PP-C0-B1-DR-A-10-0099revP0, 1528-PP-C0-00-DR-A-10-0100revP2, 1528-PP-C0-01-DR-A-10- 0101revP0, 1528-PP-C0-11-DR-A-10-0111revP0, 1528-PP-C0-12-DR-A-10-0112revP0, 1528-PP-Z0-XX- DR-A-11-1000revP0, 1528-PP-Z0-XX-DR-A-11-1100revP0, 1528-PP-Z0-XX-DR-A-11-1101revP2, 1528-PP- A0-XX-DR-A-11-2100revP0, 1528-PP-A0-XX-DR-A-11-2101revP0, 1528-PP-A0-XX-DR-A-11-2102revP0, 1528-PP-A0-XX-DR-A-11-2103revP0, 1528-PP-B0-XX-DR-A-11-2200revP0, 1528-PP-B0-XX-DR-A-11- 2201revP0, 1528-PP-B0-XX-DR-A-11-2202revP0, 1528-PP-B0-XX-DR-A-11-2203revP2, 1528-PP-B0-XX- DR-A-11-2204revP1, 1528-PP-B0-XX-DR-A-11-2205revP2, 1528-PP-B0-XX-DR-A-11-2206revP1, 1528-PP- B0-XX-DR-A-11-2207revP1, 1528-PP-C0-XX-DR-A-11-2300revP0, 1528-PP-A0-XX-DR-A-12-2100revP0, 1528-PP-A0-XX-DR-A-12-2101revP0, 1528-PP-A0-XX-DR-A-12-2102revP0, 1528-PP-A0-XX-DR-A-12- 2103revP0, 1528-PP-A0-XX-DR-A-12-2104revP0, 1528-PP-A0-XX-DR-A-12-2105revP0, 1528-PP-B0-XX- DR-A-12-2200revP3, 1528-PP-B0-XX-DR-A-12-2201revP1, 1528-PP-B0-XX-DR-A-12-2203revP1, 1528-PP- C0-XX-DR-A-12-2300revP0, 1528-PP-A1-XX-DR-A-15-0100revP0, 1528-PP-A1-XX-DR-A-15-0101revP0, 1528-PP-A1-XX-DR-A-15-0102revP0, 1528-PP-A2-XX-DR-A-15-0101revP0, 1528-PP-A2-XX-DR-A-15- 0102revP0, 1528-PP-A2-XX-DR-A-15-0103revP0, 1528-PP-A2-XX-DR-A-15-0104revP0, 1528-PP-A2-XX- DR-A-15-0105revP0, 1528-PP-A2-XX-DR-A-15-0106revP0, 1528-PP-A2-XX-DR-A-15-0107revP0, 1528-PP- A2-XX-DR-A-15-0108revP0, 1528-PP-A2-XX-DR-A-15-0109revP0, 1528-PP-A2-XX-DR-A-15-0110revP0, 1528-PP-B1-01-DR-A-15-0101revP2, 1528-PP-B1-08-DR-A-15-0108revP2, 1528-PP-B1-22-DR-A-15- 0122revP1, 1528-PP-B1-25-DR-A-15-0125revP1, 1528-PP-B3-01-DR-A-15-0101revP1, 1528-PP-B3-03-DR- A-15-0103revP1, 1528-PP-B3-05-DR-A-15-0105revP2, 1528-PP-B3-10-DR-A-15-0110revP2, 1528-PP-B3- 20-DR-A-15-0120revP1, 1528-PP-B3-23-DR-A-15-0123revP1, 1528-PP-B4-00-DR-A-15-0100revP2, 1528- PP-B4-02-DR-A-15-0102revP1, 1528-PP-B4-04-DR-A-15-0104revP1, 1528-PP-C1-00-DR-A-15-0101revP0, 1528-PP-A1-XX-DR-A-21-0011revP0, 1528-PP-A1-XX-DR-A-21-0021revP0, 1528-PP-A1-XX-DR-A-21- 0022revP0, 1528-PP-A1-XX-DR-A-21-0023revP0, 1528-PP-A1-XX-DR-A-21-0024revP0, 1528-PP-A3-XX- DR-A-21-0051revP0, 1528-PP-A3-XX-DR-A-21-0011revP0, 1528-PP-B1-A4-XX-DR-A-21-0021revP0, 1528- PP-A4-XX-DR-A-21-0022revP0, 1528-PP-B1-XX-DR-A-21-0021revP0, 1528-PP-B1-XX-DR-A-21- 0051revP0, 1528-PP-B3-XX-DR-A-21-0021revP0, 1528-PP-B3-XX-DR-A-21-0022revP0, 1528-PP-B3-XX- DR-A-21-0023revP0, 1528-PP-B3-XX-DR-A-21-0051revP0, 1528-PP-B3-XX-DR-A-21-0052revP1, 1528-PP- B2-XX-DR-A-21-0021revP0, 1528-PP-B2-XX-DR-A-21-0022revP0, 1528-PP-B2-XX-DR-A-21-0051revP0, 1528-PP-B2-XX-DR-A-21-0053revP0, 1528-PP-B2-XX-DR-A-21-0055revP0, 1528-PP-B4-XX-DR-A-21- 0022revP1, 1528-PP-B4-XX-DR-A-21-0051revP0, 1528-PP-B4-XX-DR-A-21-0052revP2, 1528-PP-C1-XX- DR-A-21-0021revP0, 1528-PP-C1-XX-DR-A-21-0023revP0, 1528-PP-C1-XX-DR-A-21-0051revP0, 1528-PP- C1-XX-DR-A-21-0052revP0, 1528-PP-A1-XX-DR-A-22-1020revP0, 1528-PP-A1-XX-DR-A-22-1021revP0, 1528-PP-A1-XX-DR-A-22-1022revP0,1528-PP-A1-XX-DR-A-22-1200rveP0, 1528-PP-A1-XX-DR-A-22- 1201rveP0, 1528-PP-A1-XX-DR-A-22-1202rveP0, 1528-PP-A1-XX-DR-A-22-1300revP0, 1528-PP-A1-XX- DR-A-22-1301revP0, 1528-PP-A1-XX-DR-A-22-1350revP0, 1528-PP-A1-XX-DR-A-22-1500revP0, 1528-PP- A1-XX-DR-A-22-1501revP0, 1528-PP-A1-XX-DR-A-22-1550revP0, 1528-PP-A1-XX-DR-A-22-1551revP0, 1528-PP-A2-00-DR-A-22-2100revP0, 1528-PP-A2-01-DR-A-22-2101revP0, 1528-PP-A2-03-DR-A-22- 2102revP0, 1528-PP-A2-05-DR-A-22-2103revP0, 1528-PP-A2-07-DR-A-22-2104revP0, 1528-PP-A2-09- DR-A-22-2105revP0, 1528-PP-A2-B1-DR-A-22-3150revP0, 1528-PP-A2-00-DR-A-22-3151revP0, 1528-PP- A2-01-DR-A-22-3152revP0, 1528-PP-A2-02-DR-A-22-3153revP0, 1528-PP-A2-03-DR-A-22-3154revP0, 1528-PP-A2-04-DR-A-22-3155revP0, 1528-PP-A2-05-DR-A-22-3156revP0, 1528-PP-A2-06-DR-A-22- 3157revP0, 1528-PP-A2-07-DR-A-22-3158revP0, 1528-PP-A2-08-DR-A-22-3159revP0, 1528-PP-A2-09-DR- A-22-3160revP0, 1528-PP-A2-10-DR-A-22-3161revP0, 1528-PP-A2-XX-DR-A-22-5000revP0, 1528-PP-A2- XX-DR-A-22-5100revP0, 1528-PP-A2-XX-DR-A-22-5102revP0, 1528-PP-A2-XX-DR-A-22-5105revP0, 1528- PP-A2-XX-DR-A-22-5107revP0, 1528-PP-A2-XX-DR-A-22-5125revP0, 1528-PP-A2-XX-DR-A-22- 5126revP0, 1528-PP-A2-XX-DR-A-22-5127revP0, 1528-PP-A2-XX-DR-A-22-5128revP0, 1528-PP-A2-XX- DR-A-22-5130revP0, 1528-PP-A2-XX-DR-A-22-5175revP0, 1528-PP-A2-XX-DR-A-22-5176revP0, 1528-PP- A2-XX-DR-A-22-5180revP0, 1528-PP-A2-XX-DR-A-22-6100revP0, 1528-PP-A2-XX-DR-A-22-6101revP0, 1528-PP-A2-XX-DR-A-22-6110revP0, 1528-PP-A2-XX-DR-A-22-61110revP0, 1528-PP-A2-XX-DR-A-22- 6112revP0, 1528-PP-A2-XX-DR-A-22-6170revP0, 1528-PP-A2-XX-DR-A-22-6171revP0, 1528-PP-A2-XX- DR-A-22-6172revP0, 1528-PP-A2-XX-DR-A-22-6180revP0, 1528-PP-A2-XX-DR-A-22-6200revP0, 1528-PP- A2-XX-DR-A-22-6201revP0, 1528-PP-A2-XX-DR-A-22-6210revP0, 1528-PP-A2-XX-DR-A-22-6211revP0, 1528-PP-A2-XX-DR-A-22-6220revP0, 1528-PP-A2-XX-DR-A-22-6221revP0, 1528-PP-A2-XX-DR-A-22- 6230revP0, 1528-PP-A2-XX-DR-A-22-6270revP0, 1528-PP-A2-XX-DR-A-22-6271revP0, 1528-PP-A2-XX- DR-A-22-6272revP0, 1528-PP-A2-XX-DR-A-22-6280revP0, 1528-PP-A2-XX-DR-A-22-6500revP0, 1528-PP- A2-XX-DR-A-22-6501revP0, 1528-PP-A2-XX-DR-A-22-6510revP0, 1528-PP-A2-XX-DR-A-22-6511revP0, 1528-PP-A2-XX-DR-A-22-6520revP0, 1528-PP-A2-XX-DR-A-22-6521revP0, 1528-PP-A2-XX-DR-A-22- 6530revP0, 1528-PP-A2-XX-DR-A-22-6531revP0, 1528-PP-A2-XX-DR-A-22-6532revP0, 1528-PP-A2-XX- DR-A-22-6533revP0

Proposed Landscape Drawings

TOWN634(08)3000, R05; TOWN634(08)3001, R02; TOWN634(08)3002, R03; TOWN634(08)3003, R04; TOWN634(08)3004, R04; TOWN634(08)3005, R03; TOWN634(08)3011, R01; TOWN634(08)3012, R02; TOWN634(08)3013, R03; TOWN634(08)3014, R03; TOWN634(08)3015, R01; TOWN634(08)3100, R02; TOWN634(08)3101, R03; TOWN634(08)3120, R03; TOWN634(08)3130, R02; TOWN634(08)3140, R02; TOWN634(08)3000, R05; TOWN634(08)3000, R05; TOWN634(08)3000, R05; TOWN634(08)3000, R02; TOWN634(08)3000, R02; TOWN634(08)3150, R02; TOWN634(08)3160, R03; TOWN634(08)3170, R00; TOWN634(08)3030, R02; TOWN634(08)2001, R08; TOWN634(08)20030, R00;

Proposed Listed Building Consent Drawings

1528-PP-A2-99-DR-A-02-4000revP0, 1528-PP-A2-00-DR-A-02-4001revP0, 1528-PP-A2-01-DR-A-02- 4002revP0, 1528-PP-A2-03-DR-A-02-4003revP0, 1528-PP-A2-05-DR-A-02-4004revP0, 1528-PP-A2-07-DR- A-02-4005revP0, 1528-PP-A2-09-DR-A-02-4006revP0, 1528-PP-A2-XX-DR-A-02-5000revP0, 1528-PP-A2- XX-DR-A-02-5001revP0, 1528-PP-A2-XX-DR-A-02-5002revP0, 1528-PP-A2-XX-DR-A-02-5003revP0, 1528- PP-A0-B1-DR-A-10-0098revP0, 1528-PP-A0-LG-DR-A-10-0099revP0, 1528-PP-A0-00-DR-A-10-0100revP2, 1528-PP-A0-01-DR-A-10-0101revP1, 1528-PP-A0-02-DR-A-10-0102revP1, 1528-PP-A0-03-DR-A-10- 0103revP1, 1528-PP-A0-04-DR-A-10-0104revP1, 1528-PP-A0-05-DR-A-10-0105revP1, 1528-PP-A0-06-DR- A-10-0106revP1, 1528-PP-A0-07-DR-A-10-0107revP1, 1528-PP-A0-08-DR-A-10-0108revP1, 1528-PP-A0- 09-DR-A-10-0109revP1, 1528-PP-A0-10-DR-A-10-0110revP1, 1528-PP-A0-11-DR-A-10-0111revP1, 1528- PP-A0-XX-DR-A-11-2100revP0, 1528-PP-A0-XX-DR-A-11-2101revP0, 1528-PP-A0-XX-DR-A-11- 2102revP0, 1528-PP-A0-XX-DR-A-11-2103revP0, 1528-PP-A0-XX-DR-A-12-2100revP0, 1528-PP-A0-XX- DR-A-12-2101revP0, 1528-PP-A0-XX-DR-A-12-2102revP0, 1528-PP-A0-XX-DR-A-12-2103revP0, 1528-PP- A0-XX-DR-A-12-2104revP0, 1528-PP-A0-XX-DR-A-12-2105revP0, 1528-PP-A1-XX-DR-A-15-0100revP0, 1528-PP-A1-XX-DR-A-15-0101revP0, 1528-PP-A1-XX-DR-A-15-0102revP0, 1528-PP-A2-XX-DR-A-15- 0101revP0, 1528-PP-A2-XX-DR-A-15-0102revP0, 1528-PP-A2-XX-DR-A-15-0103revP0, 1528-PP-A2-XX- DR-A-15-0104revP0, 1528-PP-A2-XX-DR-A-15-0105revP0, 1528-PP-A2-XX-DR-A-15-0106revP0, 1528-PP- A2-XX-DR-A-15-0107revP0, 1528-PP-A2-XX-DR-A-15-0108revP0, 1528-PP-A2-XX-DR-A-15-0109revP0, 1528-PP-A2-XX-DR-A-15-0110revP0, 1528-PP-A1-XX-DR-A-21-0022revP0, 1528-PP-A1-XX-DR-A-21- 0024revP0, 1528-PP -A4-XX-DR-A-21-0021revP0, 1528-PP-A4-XX-DR-A-21-0022revP0, 1528-PP-A1-XX- DR-A-22-1020revP0, 1528-PP-A1-XX-DR-A-22-1021revP0, 1528-PP-A1-XX-DR-A-22-1022revP0,1528-PP- A1-XX-DR-A-22-1200revP0, 1528-PP-A1-XX-DR-A-22-1201revP0, 1528-PP-A1-XX-DR-A-22-1202revP0, 1528-PP-A1-XX-DR-A-22-1300revP0, 1528-PP-A1-XX-DR-A-22-1301revP0, 1528-PP-A1-XX-DR-A-22- 1350revP0, 1528-PP-A1-XX-DR-A-22-1500revP0, 1528-PP-A1-XX-DR-A-22-1501revP0, 1528-PP-A1-XX- DR-A-22-1550revP0, 1528-PP-A1-XX-DR-A-22-1551revP0, 1528-PP-A2-00-DR-A-22-2100revP0, 1528-PP- A2-01-DR-A-22-2101revP0, 1528-PP-A2-03-DR-A-22-2102revP0, 1528-PP-A2-05-DR-A-22-2103revP0, 1528-PP-A2-07-DR-A-22-2104revP0, 1528-PP-A2-09-DR-A-22-2105revP0, 1528-PP-A2-B1-DR-A-22- 3150revP0, 1528-PP-A2-00-DR-A-22-3151revP0, 1528-PP-A2-01-DR-A-22-3152revP0, 1528-PP-A2-02-DR- A-22-3153revP0, 1528-PP-A2-03-DR-A-22-3154revP0, 1528-PP-A2-04-DR-A-22-3155revP0, 1528-PP-A2-05-DR-A-22-3156revP0, 1528-PP-A2-06-DR-A-22-3157revP0, 1528-PP-A2-07-DR-A-22- 3158revP0, 1528-PP-A2-08-DR-A-22-3159revP0, 1528-PP-A2-09-DR-A-22-3160revP0, 1528-PP-A2-10-DR- A-22-3161revP0, 1528-PP-A2-XX-DR-A-22-5000revP0, 1528-PP-A2-XX-DR-A-22-5100revP0, 1528-PP-A2- XX-DR-A-22-51026revP0, 1528-PP-A2-XX-DR-A-22-5105revP0, 1528-PP-A2-XX-DR-A-22-5107revP0, 1528-PP-A2-XX-DR-A-22-5125revP0, 1528-PP-A2-XX-DR-A-22-5126revP0, 1528-PP-A2-XX-DR-A-22- 5127revP0, 1528-PP-A2-XX-DR-A-22-5128revP0, 1528-PP-A2-XX-DR-A-22-5130revP0, 1528-PP-A2-XX- DR-A-22-5150revP0, 1528-PP-A2-XX-DR-A-22-5175revP0, 1528-PP-A2-XX-DR-A-22-5175revP0, 1528-PP- A2-XX-DR-A-22-5176revP0, 1528-PP-A2-XX-DR-A-22-5180revP0, 1528-PP-A2-XX-DR-A-22-6100revP0, 1528-PP-A2-XX-DR-A-22-6101revP0, 1528-PP-A2-XX-DR-A-22-6110revP0, 1528-PP-A2-XX-DR-A-22- 61110revP0, 1528-PP-A2-XX-DR-A-22-6112revP0, 1528-PP-A2-XX-DR-A-22-6170revP0, 1528-PP-A2-XX- DR-A-22-6171revP0, 1528-PP-A2-XX-DR-A-22-6172revP0, 1528-PP-A2-XX-DR-A-22-6180revP0, 1528-PP- A2-XX-DR-A-22-6200revP0, 1528-PP-A2-XX-DR-A-22-6201revP0, 1528-PP-A2-XX-DR-A-22-6210revP0, 1528-PP-A2-XX-DR-A-22-6211revP0, 1528-PP-A2-XX-DR-A-22-6220revP0, 1528-PP-A2-XX-DR-A-22- 6221revP0, 1528-PP-A2-XX-DR-A-22-6230revP0, 1528-PP-A2-XX-DR-A-22-6270revP0, 1528-PP-A2-XX- DR-A-22-6271revP0, 1528-PP-A2-XX-DR-A-22-6272revP0, 1528-PP-A2-XX-DR-A-22-6280revP0, 1528-PP- A2-XX-DR-A-22-6500revP0, 1528-PP-A2-XX-DR-A-22-6501revP0, 1528-PP-A2-XX-DR-A-22-6510revP0, 1528-PP-A2-XX-DR-A-22-6511revP0, 1528-PP-A2-XX-DR-A-22-6520revP0, 1528-PP-A2-XX-DR-A-22- 6521revP0, 1528-PP-A2-XX-DR-A-22-6530revP0, 1528-PP-A2-XX-DR-A-22-6531revP0, 1528-PP-A2-XX- DR-A-22-6532revP0, 1528-PP-A2-XX-DR-A-22-6533revP0

Supporting Documents  Design and Access Statement  Design and Access Statement Addendum  Heritage and Renewal Strategy  Area Schedule  Amended planning application drawings and Area Schedule, prepared by Pilbrow and Partners (see AUG 19 P&P Drawing Schedule)  Landscape and Public Realm Strategy, prepared by Townshend Landscape Architects;  Landscape and Public Realm Strategy addendum, prepared by Townshend Landscape Architects  Waste Management Strategy Update, prepared by WSP  Transport Assessment, prepared by WSP  Transport Assessment Addendum, prepared by WSP  Financial Viability Appraisal Addendum, prepared by JLL  Environmental Statement, prepared by WSP.  Environmental Statement Addendum, prepared by WSP.  Planning Statement (including draft S.106 Heads of Terms), prepared by Lichfields;  Planning Addendum (Covering Letter dated 30.9.19)  Financial Viability Assessment, prepared by JLL;  Statement of Community Involvement, prepared by London Communications Agency;  Daylight, Sunlight & Overshadowing Report, prepared by Point2 Surveyors;  Environmental Statement (ES), including:

Conditions and Informatives

Planning Application - 19/01304/FUL (Application A)

Time period 1. The development to which this permission relates must be begun no later than three years from the date of this decision notice.

Reason: To comply with the provisions of Section 91 of the Town and Country Planning Act 1990.

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

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

Pre-commencement Conditions

Drainage scheme 3. No construction (excluding soft strip, asbestos removal and demolition) within the relevant phase/sub-phase of the development shall commence until a detailed drainage scheme for the relevant phase/sub-phase designed with regard to the drainage hierarchy set out in the London Plan, has been submitted to and approved in writing by the Local Planning Authority.

The drainage scheme for each phase/sub-phase of development shall be implemented and maintained in accordance with the approved details and retained permanently thereafter. No discharge of foul or surface water from the site shall be accepted into the public system until the drainage works referred to in the strategy have been completed. No drainage systems for the infiltration of surface water drainage into the ground are permitted other than with the express written consent of the Local Planning Authority. The drainage scheme shall include:

a) The final surface water drainage design to scale, showing all connections, SuDS features and water storage details for the entire site. b) Details of how the scheme achieves betterment compared to the existing peak surface water runoff rates from the site. c) Details of a rainwater harvest system. d) Details of how trees and planters will be located to maximise betterment. e) Any offsite consents required, such as agreed surface water discharge consents from Thames Water Utilities. f) A maintenance and management plan for the proposed drainage scheme.

All provisions for drainage must be undertaken in accordance with the details herby approved, unless the written consent of the Local Planning Authority is received for any variation.

Reason: To minimise the risk of flooding (Policy EN6 of the Lambeth Local Plan 2015).

Contamination 4. (A) Prior to the commencement of development approved by this planning permission (or such other date or stage in development as may be agreed in writing with the Local Planning Authority), the following components of a scheme to deal with the risks associated with contamination of the site shall be submitted to, and approved in writing by, the Local Planning Authority:

(i) A site investigation scheme, based on previous findings to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site; (ii) The site investigation results and the detailed risk assessment resulting from (i); (iii) An options appraisal and remediation strategy giving full details of the remediation measures required and how they are to be undertaken; (iv) A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in iii) are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action.

The development of the relevant phase shall thereafter be implemented in accordance with the details and measures approved.

(B) Prior to occupation of any part of the development in the relevant phase/sub-phase, a verification report demonstrating completion of the works set out in the approved remediation strategy and the effectiveness of the remediation for the relevant phase/sub-phase shall be submitted to and approved in writing by the local planning authority. The report shall include results of sampling and monitoring carried out in accordance with the approved verification plan to demonstrate that the site remediation criteria have been met. It shall also include any plan (a "long-term monitoring and maintenance plan") for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action, as identified in the verification plan, and for the reporting of this to the local planning authority.

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

Reason: For the protection of controlled waters and the site is located over a Secondary Aquifer and it is understood that the site may be affected by historic contamination. (Policies 5.21 of the London Plan and EN4 of the Lambeth Local Plan 2015).

Asbestos Survey 5. Prior to the commencement of soft strip to suit each relevant phase/sub-phase an asbestos survey of buildings to be demolished shall be submitted to and approved in writing by the Local Planning Authority. Development shall thereafter be carried out in accordance with the approved details.

Construction and Environmental Management Plan 6. Prior to the commencement of each phase/sub-phase of development (excluding demolition) a Construction and Environmental Management Plan (CEMP) for the relevant phase shall be submitted to and approved in writing by the local planning authority.

The CEMP shall include details of the following relevant measures:

(i) An introduction consisting of construction phase environmental management plan, definitions and abbreviations and project description and location; (ii) A description of management responsibilities. (iii) A description of the construction programme which identifies activities likely to cause high levels of noise or dust; (iv) Site working hours and a named person for residents to contact; (v) Detailed Site construction logistics arrangements; (vi) Details regarding parking, deliveries, and storage, including confirmation that the developer will join the VNEB construction working group. (vii) Details of an air quality and dust management plan; (viii) Details of noise mitigation measures to be deployed including identification of sensitive receptors and ongoing monitoring; (ix) Details of the hours of works and other measures to mitigate the impact of construction on the amenity of the area and safety of the highway network; (x) Measures to prevent the deposit of mud and debris on the public highway; and (xi) Communication procedures with the LBL and local community regarding key construction issues.

The construction of each phase shall thereafter be carried out in accordance with the details and measures approved in the CEMP for the related phase, unless the written consent of the Local Planning Authority is received for any variation.

The applicant is encouraged to consult with local residents and evidence of and details related to consultation with local residents on the CEMP to be submitted shall be included within the submission. The construction shall thereafter be carried out in accordance with the details and measures approved in the CEMP for the related phase, unless the written consent of the Local Planning Authority is received for any variation. Reason: This is required prior to construction to avoid hazard and obstruction being caused to users of the public highway and to safeguard residential amenity during the whole of the construction period. (Policies T6 and Q2 of the Lambeth Local Plan (2015)

Piling Method Statement 7. No impact piling or other penetrative foundation work shall take place until a Piling Method Statement has been submitted to and approved in writing by the Local Planning Authority. The Piling Method Statement shall include details of: a) The depth and type of piling to be undertaken; b) The methodology by which such piling will be carried out; c) Measures to prevent and minimise the potential for damage to subsurface water infrastructure; d) Measures to ensure there is no resultant unacceptable risk to groundwater as a result of the work; and e) The programme for the works. Any piling or other penetrative works must be undertaken in accordance with the terms of the approved Piling Method Statement, unless the written consent of the Local Planning Authority is received for any variation.

Reason: To ensure that any piling works would not unduly impact upon the local underground sewerage utility infrastructure and in order to avoid adverse environmental impact upon the community. (Policies EN5 and EN6 of Lambeth Local Plan 2015).

Archaeology 8. No development other than demolition to existing ground level shall take place within any phase/ sub- phase until the applicant (or their heirs and successors in title) has secured the implementation of a Stage 1 Written Scheme of Investigation (WSI) has been submitted to and approved in writing by the local planning authority in writing. For land that is included within the WSI, no demolition or development shall take place other than in accordance with the agreed WSI, and the programme and methodology of site evaluation and the nomination of a competent person(s) or organisation to undertake the agreed works.

If heritage assets of archaeological interest are identified by stage 1 then for those parts of the site which have archaeological interest a stage 2 WSI shall be submitted to and approved by the local planning authority in writing. For land that is included within the stage 2 WSI, no demolition/development shall take place other than in accordance with the agreed stage 2 WSI which shall include:

A. The statement of significance and research objectives, the programme and methodology of site investigation and recording and the nomination of a competent person(s) or organisation to undertake the agreed works.

B. The programme for post-investigation assessment and subsequent analysis, publication & dissemination and deposition of resulting material. This part of the condition shall not be discharged until these elements have been fulfilled in accordance with the programme set out in the stage 2 WSI.

Reason: Heritage assets of archaeological interest may survive on the site. The planning authority wishes to secure the provision of appropriate archaeological investigation, including the publication of results, in accordance with Section 12 of the NPPF (Policy 7.8 of the London Plan 2016).

Air Quality and Dust Management Plan 9. No demolition or development shall commence until full details of the proposed mitigation measures for impact on air quality and dust emissions, in the form of an Air Quality and Dust Management Plan (AQDMP), have been submitted to and approved in writing by the local planning authority. In preparing the AQMDP the applicant should follow the guidance on mitigation measures for Medium Risk sites set out in Appendix 7 of the Control of Dust and Emissions during Construction and Demolition SPG 2014. Both ‘highly recommended’ and ‘desirable’ measures should be included. The AQDMP can form part of the Construction Environmental Management Plan (CEMP).The AQDMP shall include the following for each relevant phase of work (demolition, earthworks, construction and trackout): a) A summary of work to be carried out; b) Proposed haul routes, location of site equipment including supply of water for damping down, source of water, drainage and enclosed areas to prevent contaminated water leaving the site; c) Inventory and timetable of all dust and NOx air pollutant generating activities; d) List of all dust and emission control methods to be employed and how they relate e) to the Air Quality (Dust) Risk Assessment; f) Details of any fuel stored on-site; g) Details of a trained and responsible person on-site for air quality (with knowledge h) of pollution monitoring and control methods, and vehicle emissions); i) Summary of monitoring protocols and agreed procedure of notification to the local j) authority; and k) A log book for action taken in response to incidents or dust-causing episodes and the mitigation measure taken to remedy any harm caused, and measures employed to prevent a similar incident reoccurring. No demolition or development shall commence until all necessary pre-commencement measures described in the AQDMP have been put in place and set out on site. The demolition and development shall thereafter be carried out and monitored in accordance with the details and measures approved in the AQDMP.

Reason: Development must not commence before this condition is discharged to manage and mitigate the impact of the development on the air quality and dust emissions in the area and London as a whole, and to avoid irreversible and unacceptable damage to the environment (London Plan Policies 5.3 and 7.14, and the London Plan SPGs for Sustainable Design and Construction and Control of Dust and Emissions during Construction and Demolition).

Non road-mobile machinery 10. No non-road mobile machinery (NRMM) shall be used on the site unless it is compliant with the NRMM Low Emission Zone requirements (or any superseding requirements) and until it has been registered for use on the site on the NRMM register (or any superseding register).

Reason: To ensure that air quality is not adversely affected by the development in line with London Plan policy 7.14 and the Mayor’s SPG: The Control of Dust and Emissions during Construction and Demolition.

Amenity

Noise and Vibration 11. Prior to the commencement of building works above ground of the relevant part of the development, a scheme of noise and vibration attenuation shall be submitted to and approved in writing by the Local Planning Authority. The approved noise and vibration attenuation measures shall thereafter be retained and maintained in working order for the duration of the use in accordance with the approved details.

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

Residential noise standards 12. The residential units shall be designed and constructed to meet the following noise standards: a) for living rooms, 35dB LAeq 16 hour between 0700 and 2300 hours; b) for bedrooms, 30dB LAeq 8 hour between 2300 and 0700 hours; and c) to not normally exceed 45dB(A) max for any individual noise event (measured with F time weighting) between 2300 and 0700 hrs.

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

Residential noise standards – amenity space 13. Prior to the commencement of above ground construction works for each phase/sub-phase, a scheme of measures to ensure that all residential units have access to amenity space within the development where noise levels do not exceed 55dB LAEQ (16 hour) shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall include details of post construction validation. Thereafter the development of each phase/sub-phase shall be carried out in accordance with the approved details and a separate validation report shall be submitted to and approved in writing by the Local Planning Authority 3 months prior to occupation of each phase/sub-phase.

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

Plant 14. Prior to the commencement of building works above ground of the relevant part of the development, full details (including elevational drawings) of any internal and external plant equipment and trunking, including building services plant, ventilation and filtration equipment and commercial kitchen exhaust ducting / ventilation, shall be submitted to and approved in writing by the Local Planning Authority. All flues, ducting and other equipment shall be installed in accordance with the approved details prior to the use commencing on site and shall thereafter be maintained in accordance with the manufacturer's instructions.

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

Plant noise assessment 15. The operation of any building services plant, shall not commence until an assessment of the acoustic impact arising from the operation of all internally and externally located plant for each phase has been submitted to and approved in writing by the local planning authority. The assessment of the acoustic impact shall be undertaken in accordance with BS 4142: 2014 (or subsequent superseding equivalent) and current best practice, and shall include a scheme of attenuation measures to ensure the rating level of noise emitted from the proposed building services plant complies with the limits established by the approved Noise and Vibration ES Chapter.

Design Details

External Materials 16. Prior to the completion of the frame of each new building of the development hereby permitted, the following details of the materials to be used in the external elevations of that building shall be submitted to and approved in writing by the local planning authority. The development hereby permitted shall be thereafter built in accordance with the approved details. The following details are required:

a) a technical specification schedule of the materials; b) a sample panel to be provided on site (1m by 1m); and c) a photographic record of the sample panels.

17. Reason: To ensure that the external appearance of the building is satisfactory and does not detract from the character and visual amenity of the area along with setting of the nearby conservation areas (Policies Q6, Q7, Q8, and Q22 of the Lambeth Local Plan 2015).

New materials condition for Glass Box: 18. Prior to construction of the glass extension hereby permitted on the roof of the west site the following details of the materials to be used for the exterior of the building shall be submitted to and approved in writing by the local planning authority. The development hereby permitted shall be thereafter built in accordance with the approved details. The following details are required:

a) a technical specification schedule of the materials; b) a sample panel to be provided on site; and c) a photographic record of the sample panels.

Reason: To ensure that the external appearance of the building is satisfactory and does not detract from the character and visual amenity of the area along with setting of the nearby conservation areas (Policies Q6, Q7, Q8, and Q22 of the Lambeth Local Plan 2015).

Fine Detailing 19. Notwithstanding the details shown on the approved drawings, prior to the completion of the frame of each new building, construction drawings (including sections at 1:10 scale) of all external elements of the new building (including rain water goods, soffits, copings, ledges, reveals, shopfronts, windows and balcony screens where required) for the relevant building shall be submitted to and approved in writing by the Local Planning Authority. The development of the relevant building shall be implemented in accordance with the approved details and retained permanently thereafter.

Plumbing 20. No plumbing or pipes, other than rainwater pipes, shall be fixed to the external faces of buildings.

Reason: To ensure an appropriate standard of design (Policies Q6, Q8 and PN3 of the Lambeth Local Plan 2015).

Wheelchair units 21. At least ten per cent of the residential units hereby permitted shall be constructed to comply with Part M4 (3) of the Building Regulations. Any communal areas and accesses serving the M4 (3) compliant Wheelchair User Dwellings should also comply with Part M4 (3).

Reason: To secure appropriate access for disabled people, older people and others with mobility constraints (Policy 3.8 of the London Plan MALP 2016 and Policy Q1 of the Lambeth Local Plan 2015).

Site Maintenance and Management

Waste and recycling storage 22. Prior to the commencement of the use hereby permitted, details of waste and recycling storage (including detail on ventilation of bin stores) for the development shall be submitted to and approved in writing by the local planning authority. The waste and recycling storage shall be provided in accordance with the approved details prior to the commencement of the use hereby permitted, and shall thereafter be retained solely for its designated use. The waste and recycling storage areas/facilities should comply with the Lambeth's Refuse & Recycling Storage Design Guide (2013), unless it is demonstrated in the submissions that such provision is inappropriate for this specific development.

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

Waste Management Strategy 23. Prior to the occupation of the relevant use hereby permitted, a Waste Management Strategy for the relevant phase/sub-phase shall be submitted to and approved in writing by the local planning authority. The development hereby permitted shall be built in accordance with the approved details and shall thereafter be retained solely for its designated use. The uses hereby permitted shall thereafter be operated in accordance with the approved Waste Management Strategy.

Car Park Management Plan 24. Prior to the occupation of the development hereby approved, a Car Park Management Plan shall be submitted to and approved in writing by the local planning authority. The Plan submitted shall include details of car parking allocation for residential and commercial occupants. The development shall be carried out in accordance with the approved details.

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

Cycle Storage 25. Prior to the occupation of the development hereby permitted, details of the provision to be made for cycle parking shall be submitted to and approved in writing by the Local Planning Authority. The cycle parking shall thereafter be implemented in full in accordance with the approved details before the use hereby permitted commences and shall thereafter be retained solely for its designated use.

Reason: To ensure adequate cycle parking is available on site and to promote sustainable modes of transport (policies T1, T3 and Q13 of the London Borough of Lambeth Local Plan (2015)).

Existing vehicular access to be removed 26. Within 3 months of occupation of the development hereby approved the existing redundant vehicular access points shall be removed by raising the dropped kerb and reinstating the footway to the specification required by the Council’s Highways Department.

Reason: To minimise danger, obstruction and inconvenience to users of the highway (Policies T1 and T6 of the London Borough of Lambeth Local Plan (2015)).

Delivery and Servicing Management Plan 27. The use hereby permitted shall not commence until a Delivery and Servicing Management Plan has been submitted and approved in writing by the local planning authority. The use hereby permitted shall thereafter be operated in accordance with the approved details. The submitted details must include the following:

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

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

Public Realm Management Plan 28. The use hereby permitted shall not commence until a Public Realm Management Plan has been submitted and approved in writing by the local planning authority. The use hereby permitted shall thereafter be operated in accordance with the approved details.

Travel Plan – Non-residential uses 29. Prior to the non-residential uses hereby approved commencing, a Travel Plan relating to those uses shall be submitted to and approved in writing by the Local Planning Authority. The measures approved in the Travel Plan to be implemented before occupation shall so be implemented prior to the use commencing and shall be so maintained for the duration of the use, unless the prior written approval of the Local Planning Authority is obtained to any variation.

Reason: To ensure that the travel arrangements to the site are appropriate and to limit the effects of the increase in travel movements (Policy 6.3 of the London Plan MALP 2016 and Policies T1 and T6 of the Lambeth Local Plan 2015).

Travel Plan – Residential use 30. Prior to the occupation of the residential units, a Travel Plan relating to those units shall be submitted to and approved in writing by the Local Planning Authority. The measures approved in the Travel Plan to be implemented before occupation shall be implemented prior to the use commencing and shall be so maintained for the duration of the use, unless the prior written approval of the Local Planning Authority is obtained to any variation.

Crime Prevention 31. Prior to the occupation of buildings, a Crime Prevention Strategy including a Security Management Plan shall be submitted to and approved in writing by the Local Planning Authority. The submitted details will include the following: a) A summary of known crime risks in the area; b) Details of how the development has mitigated known crime risks in the area; and c) Detail of how the development seeks to achieve 'Secured by Design Standards', including details of a CCTV scheme, external security, street lighting and landscaping.

The use shall thereafter be operated in accordance with the approved details, unless the written consent of the Local Planning Authority is received for any variation.

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

Permitted Development Rights 32. Notwithstanding the provisions of the Town and Country Planning (General Permitted Development) (England) Order 2015 (or any Order revoking or re-enacting that Order with or without modification), no aerials, antennae, satellite dishes or related telecommunications equipment shall be erected on any part of the development hereby permitted, without planning permission first being granted.

Reason: To ensure that the visual impact of telecommunication equipment upon the surrounding area can be considered. (Policies 7.6 and 7.8 of the London Plan MALP 2016 and Policies T10, Q6 and Q22 of the Lambeth Local Plan 2015).

Flood Warning and Evacuation Plan: 33. The approved Flood Warning and Evacuation Plan (ref. 7001647-FWEP-DI-001 dated March 2019) shall be implemented prior to first occupation of residential units within any phase. The Flood Warning and Evacuation Plan shall thereafter be maintained for the duration of the residential use.

Reason: To minimise the risk of flooding (Policy EN6 of the Lambeth Local Plan 2015).

Landscaping, biodiversity and External Amenity

Landscaping Scheme and Ecological Enhancements Strategy 34. Prior to the first occupation within each phase/sub-phase of the development hereby permitted, a soft and hard landscaping scheme and ecological enhancement strategy shall be submitted to and approved in writing by the local planning authority. The submitted details shall include details of tree planting, boundary treatments, green/brown roofs, green walls, play areas and play equipment, seating, obelisk details, cycle parking facilities, bird, bat and bug boxes, a management and maintenance plan, together with a timetable for implementation.

Each phase of development shall thereafter be carried out in accordance with the approved timetable. All tree, shrub and hedge planting included within the above specification shall accord with BS3936:1992, BS4043:1989 and BS4428:1989 (or subsequent superseding equivalent) and current Arboricultural best practice.

Reason: In order to introduce high quality soft landscaping in and around the site in the interests of the ecological value of the site and to ensure a satisfactory landscaping of the site in the interests of visual amenity (Policy Q9 of the Lambeth Local Plan 2015).

Landscaping Timescales 35. All planting, seeding or turfing comprised in the approved details of landscaping for each phase/sub-phase shall be carried out in the first planting and seeding season following the occupation of each phase of development hereby permitted. Any trees, hedgerows or shrubs forming part of the approved landscaping scheme which within a period of five years from the occupation or substantial completion of the relevant phase die, are removed or become seriously damaged or diseased shall be replaced in the next planting season with others of similar size and species, unless the Local Planning Authority gives written consent to any variation.

Horticultural Management Plan 36. Prior to the implementation of the landscaping scheme for each phase/sub-phase, a horticultural management plan for the relevant phase/sub-phase shall be submitted to and approved in writing by the Local Planning Authority. The plan shall set out how the planting will be managed for a minimum of five years to ensure full and successful establishment of plants and trees. The plans shall identify all areas that will be under communal management and clearly specify that properly qualified horticulturists will be contracted to manage the site. The planting shall be thereafter managed in accordance with the approved management plan.

Lighting Scheme 37. Prior to occupation of each phase/sub-phase, an external lighting scheme must be submitted and approved by the Local Planning Authority in accordance with the Institute of Lighting Professional's Guidance notes for the reduction of obstructive light. The scheme must be designed by a suitably qualified person in accordance with the recommendations for environmental zone E3 in the ILP document "Guidance Notes for the Reduction of Obtrusive Light GN01:2011. The development of each phase/sub- phase shall be implemented in accordance with the approved details and retained and properly maintained thereafter.

Reason: To ensure that the lighting enhances community safety and does not unreasonably affect residential amenity (Policies Q2, Q3 and Q7 of the Lambeth Local Plan 2015)

Sustainability and Energy

BREEAM – Design Stage Assessment 38. Prior to above ground construction or refurbishment works of the relevant building/use, the appropriate design stage BREEAM 2014 assessment showing how the building/use has been designed to achieve the relevant target score must be submitted to and approved in writing by the Local Planning Authority.

The relevant buildings/units and target scores are as follows: a) Fire Station (BREEAM UK Non-Domestic Refurbishment & Fit-out 2014): 63% and Very Good b) Museum (BREEAM UK Non-Domestic Refurbishment & Fit-out 2014): 63% and Very Good c) Hotel (BREEAM UK New Construction 2014): 70% Excellent d) Restaurant (BREEAM UK New Construction 2014): 70% Excellent e) Offices/Workspaces (BREEAM UK New Construction 2014): 70% Excellent f) Retail (BREEAM UK New Construction 2014): 70% Excellent g) Residential Created via Change of Use within Phase P1 (BREEAM Domestic Refurbishment 2014): 63% and Very Good

BREEAM – Post-Construction Assessment: Within three months after final occupation of the relevant building/use, the appropriate Post-construction stage BREEAM 2014 assessment showing how the relevant building/use achieves the following target score must be submitted to and approved in writing by the Local Planning Authority. The relevant buildings/uses comprise:

a) Fire Station (BREEAM UK Non-Domestic Refurbishment & Fit-out 2014): 63% and Very Good b) Museum (BREEAM UK Non-Domestic Refurbishment & Fit-out 2014): 63% and Very Good c) Hotel (BREEAM UK New Construction 2014): 70% Excellent d) Restaurant (BREEAM UK New Construction 2014): 70% Excellent e) Offices/Workspaces (BREEAM UK New Construction 2014): 70% Excellent f) Retail (BREEAM UK New Construction 2014): 70% Excellent g) Residential Created via Change of Use within Phase P1 (BREEAM Domestic Refurbishment 2014): 63% and Very Good

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

Internal residential water use 39. Prior to first occupation of the residential units evidence (schedule of fittings and manufacturer's literature) should be submitted to, and approved in writing by the Local Planning Authority, to show that the development has been constructed in accordance with the approved internal water use calculations so as not to exceed 105 L/person/day.

Reason: To reduce the consumption of potable water in the home from all sources, including borehole well water, through the use of water efficient fittings, appliances and water recycling systems (Policy 5.15 of the London Plan MALP 2016)

Provide parking spaces 40. Prior to the commencement of the use hereby permitted, the parking spaces shall be laid out in accordance with the approved plans, and the disabled/accessible parking space shall be retained for the duration of the use. No vehicles, other than blue-badge holder vehicles and operational vehicles for the users of the site, shall park on the site. Vehicles shall only park within the designated spaces shown on the approved plans, and on no other part of the site.

Reason: To enable accessible parking to be provided, prevent excessive parking and minimise danger, obstruction and inconvenience to users of the site and surrounding area (policies T1, T6, T7, T8 and Q2 of the London Borough of Lambeth Local Plan (2015)).

Photovoltaic panels 41. Prior to above ground construction works within Phase P3, plans, elevations and sections of the roof showing the location of the proposed photovoltaic array(s) should be submitted for approval to the Local Planning Authority. The photovoltaic array(s) shall be implemented in accordance with the approved details and retained and properly maintained permanently thereafter.

Reason: To safeguard the appearance of the completed development and to ensure that the development has an acceptable level of sustainability (Policies Q2, Q7, Q8 and EN4 of the Lambeth Local Plan, adopted September (2015)).

Fume extraction 42. No A3 use hereby permitted (within the flexible unit) shall commence until details and full specifications of fume extraction and filtration equipment, and an ongoing maintenance plan, have been submitted to and approved in writing by the local planning authority. The A3 use hereby permitted shall not commence until the approved details are fully implemented. The approved fume extraction and filtration equipment shall thereafter be retained and maintained in working order for the duration of the A3 use in accordance with the approved details.

Reason: To ensure appropriate appearance and that no nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers or to the area generally (policy Q2 and Q7 and ED7 of the London Borough of Lambeth Local Plan (2015)).

Informatives

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

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

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

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

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

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

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

8. As soon as building work starts on the development, you must contact the Street Naming and Numbering Officer if you need to do the following:

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

9. For information on the NRMM Low Emission Zone requirements and to register NRMM, please visit “http://nrmm.london/”. Background documents – Case file (this can be accessed via the planning Advice Desk, Telephone 020 7 926 1180). For advice on how to make further written submissions or to register to speak on this item, please contact Democratic Services, 020 796 2170 or email.

10. Written schemes of investigation will need to be prepared and implemented by a suitably qualified archaeological practice in accordance with Historic England’s Archaeology guidelines. They must be approved by the planning authority before any on-site development related activity occurs.

11. When construction timeframes are known the developer will need to pass related details (precise location, maximum height and associated timescales) to the Defence Geographic Centre (DGC) which maintains the UK's master database of tall structures (the Digital Vertical Obstruction File). The DGC point of contact is 0208 818 2702/[email protected].

12. Temporary structures such as cranes can be notified through the means of a Notice to Airmen (NOTAM). If above a height of 300ft (91.4m) above ground level, the developer must ensure that the crane operator contacts the CAA's Airspace Regulation (AR) section on [email protected] or 02074536599.

13. For cranes below this high the developer must ensure that the crane operator contacts Low Flying Operations at RAF Wittering [email protected] / 01780 146 208. However, in this case that is not necessary as no military low-flying routinely takes place in this location. If the crane is to be in place for in excess of 90 days it should be considered a permanent structure and will need to be notified as such: to that end the developer should also contact the DGC (see above). Additionally, any crane of a height of 60m or more will need to be equipped with aviation warning lighting in line with CAA guidance concerning crane operations which is again available at http://publicapps.caa.co.uk/docs/33/CAP%201096%20In%20Focus%20-%20Crane%20Ops.pdf.

14. Written schemes of investigation will need to be prepared and implemented by a suitably qualified professionally accredited archaeological practice in accordance with Historic England’s Guidelines for Archaeological Projects in Greater London. This condition is exempt from deemed discharge under schedule 6 of The Town and Country Planning (Development Management Procedure) (England) Order 2015.

Listed Building Consent Application - 19/01305/LB (Application B)

Time period 1. The development to which this permission relates must be begun no later than three years from the date of this decision notice.

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

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

Materials 3. Notwithstanding the information provided within the application, the colour of the steel windows and external ironwork colours shall be blue/ black colour. Exact details of that colour shall be submitted to and approved in writing by the Council prior to the commencement of window replacement works. The development shall be carried out in accordance with the approved details.

Reason: To ensure that the external appearance of the building is satisfactory and that it protects or enhances the character and appearance of the listed building and the Albert Embankment Conservation Area (policies Q2, Q11 and Q22 of the London Borough of Lambeth Local Plan (2015)).

Detail drawings and samples 4. Notwithstanding the details shown on the drawings hereby approved, no development within the relevant phase/sub-phase (including partial demolition of the Former Fire Brigade Headquarters Building but excluding demolition of the CMC Building) shall take place until drawings at a 1:10 scale (including sections) showing construction detailing has been be submitted to and approved by the Local Planning Authority in writing, unless otherwise agreed in writing by the Local Planning Authority. The drawings shall include details of the following as relevant to the individual phase/sub phases:

a) the rooftop extension and glazed additions at levels 8 and 9;

b) the restaurant bridge;

c) ventilation grilles and ducts;

d) acoustic treatments;

e) the rooftop works

f) details of boundary walls & access gates

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

5. A sample window for each type (including French doors) shall be erected on-site adjacent to an original example for comparison and agreement and the specification approved in writing by the local planning authority before the relevant parts of the works are begun

6. Sample panels (1m by 1m) of all new facing brickwork for the Head Quarters Building, showing the proposed brick types, colour, texture, face bond and pointing shall be provided on site and the specification approved in writing by the local planning authority before the relevant parts of the works are begun.

Phasing 7. Construction of the approved development shall be undertaken in accordance with the approved phasing plan ref. 1528-PP-Z0-XX-DR-A-00-1009 Rev P0. Phasing and Sub-phasing as described in Section 5 of the ES addendum (30 August 2019).

Demolition Works to HQ Building 8. With the exception of the demolition of the CMC Building and asbestos removal, no works to the listed buildings authorised by this consent shall take place until the applicant has implemented a programme of asbestos removal and building recording and analysis by a person or body approved by the local planning authority that supplements the HRRS. This programme of recording and asbestos removal shall be in accordance with a written scheme which has been submitted by the applicant and approved by local planning authority.

Demolition Works 9. Before commencement of the relevant phase of development, full details of the proposed demolition methodology, in the form of a detailed Demolition Method Statement, shall be submitted to and approved in writing by the Local Planning Authority.

Contracts 10. The works of demolition or alteration by way of partial demolition hereby approved at the West Site (excluding the demolition of the CMC Building, basement, soft strip and asbestos removal) shall not be commenced before contract(s) for the carrying out of the completion of the works on the West Site for which consent is hereby granted, including the works contract, have been made and evidence of such contract(s) has been submitted to and accepted in writing by the local planning authority.

Reason: To ensure that the development protects or enhances the character and appearance of the listed building and the Albert Embankment Conservation Area (policies Q2, Q11 and Q22 of the London Borough of Lambeth Local Plan (2015)).

Internal Works 11. No internal works (excluding demolition of the CMC Building, basement, soft strip and asbestos removal) shall take place within the listed Fire Brigade Headquarters until a Works Method Statement has been submitted to and approved in writing by the Local Planning Authority. The Statement shall include details and a programme about:

a) the construction methods and techniques used to reveal/restore the retained artefacts as identified in the artefacts catalogue Appendix A1.2; b) the restoration of the Memorial Hall; c) the restoration / decoration of the Northern Entrance Hall; d) the restoration and adaptions of the primary staircase circulation in the main cores; e) agreed features to be retained within the LFB Museum (fireman’s pole); f) linking stair between museum extension and Memorial Hall; g) scheme for interior decoration.

The internal works shall be constructed in accordance with the methodology specified in the approved statement, unless the written consent of the Local Planning Authority is received for any variation.

Obelisk 12. Prior the removal of the Obelisk a method statement for its removal and detailed drawings and timetable for its re-provision shall be submitted to and approved by the Council. The obelisk shall then be re- provided in accordance with the approved details and timetable.

Making Good/Matching: 13. All new external and internal works and finishes and works of making good to the retained fabric of the listed buildings, shall match the existing adjacent work with regard to the methods used and to material, colour, texture and profile, unless shown otherwise on the drawings or other documentation hereby approved or required by any condition(s) attached to this consent.

14. Prior to any brick cleaning being undertaken, a brick cleaning method statement shall be submitted to and approved in writing by the local planning authority. The brick cleaning shall then be undertaken in accordance with the approved details.

Fine detailing 15. No new grilles, security alarms, lighting, CCTV cameras or other appurtenances shall be fixed on the external faces of the Head Quarters building unless otherwise approved in writing by the local planning authority.

16. No plumbing or pipes, other than rainwater pipes, shall be fixed to the external faces of the HQ Building and Drill Tower unless shown on the drawings hereby approved or as otherwise agreed in writing by the Local Planning Authority.

Appendix 2: List of consultees (statutory and Other Consultees)

Statutory

Environment Agency Greater London Authority Historic England Historic England - Archaeology L.F.C.D Authority London Ecology Unit London Underground Network Rail Thames Water Transport for London - Planning Transport for London - Road Network Development

Internal/Consultants

Bioregional Design out Crime Officer (Metropolitan Police) Lambeth Arts LBL Arboricultural Officer LBL Conservation & Urban Design LBL EHST Noise Pollution LBL Enterprise, Employment and Skills LBL Highway Team LBL Housing LBL Implementation Team LBL Parks & Open Spaces LBL Planning Policy LBL Policy & Partnerships LBL Regeneration Team LBL Transport Veolia Waste Lambeth Planning App Ward Councillors

Other

9 Albert Embankment Residents' Association Ancient Monuments Society Association of Waterloo Groups Council for British Archaeology City of Westminster Design for London EDF Energy Friends of Archbishop's Park Friends Of Lambeth High Street Recreation Ground Friends of Old Paradise Gardens Friends of Vauxhall Park Friends of Vauxhall Pleasure Gardens Greater London Assembly Heart of Kennington Residents' Association Housing Association/S106 Hsg I.M.P.A.C.T. Jubilee Walkway Trust Kennington Association Planning Forum Kennington Oval & Vauxhall Forum Kennington Park Road Residents' Association London Borough of Camden Oval & Kennington Residents Association Pearman Street Residents Association Society for Protection Ancient Bldgs South Bank and Waterloo Neighbours Southern Gas Networks St George Wharf Residents Association The Georgian Group Twentieth Century Society Vanbrugh Court Residents' Association Vauxhall 5 Chair of the TRA Vauxhall Gardens Estate Resident and Tenant Association Vauxhall St Peters Heritage Centre Victorian Society Vision for Vauxhall Waterloo Community Development Group Whitgift Estate Tenants Association We Are Waterloo Waterloo Community Development Group Walcot Estate Tenants Association

Appendix 3: List of relevant policies in London Plan, Lambeth Local Plan. Reference to SPGs, SPD and other relevant guidance

The London Plan (2016)

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

 Policy 1.1 Delivering the strategic vision and objectives for London  Policy 2.1 London in its global, European and United Kingdom context  Policy 2.9 Inner London  Policy 2.10 Central Activities Zone – strategic priorities  Policy 2.11 Central Activities Zone – strategic functions  Policy 2.12 Central Activities Zone – predominantly local activities  Policy 2.13 Opportunity Areas and Intensification Areas  Policy 2.15 Town Centres  Policy 3.1 Ensuring equal life chances for all  Policy 3.2 Improving health and addressing health inequalities  Policy 3.3 Increasing housing supply  Policy 3.4 Optimising housing potential  Policy 3.5 Quality and design of housing developments  Policy 3.6 Children & young people’s play and informal recreation facilities  Policy 3.8 Housing choice  Policy 3.9 Mixed and balanced communities  Policy 3.10 Definition of affordable housing  Policy 3.11 Affordable housing targets  Policy 3.12 Negotiating affordable housing on individual private residential & mixed use  schemes  Policy 3.13 Affordable housing thresholds  Policy 3.15 Coordination of housing development and investment  Policy 4.1 Developing London’s economy Economic sectors & workspaces  Policy 4.2 Offices  Policy 4.3 Mixed use development and offices  Policy 4.5 London’s visitor infrastructure  Policy 4.6 Support for and enhancement of Arts, Culture, Sport and Entertainment  Policy 4.7 Retail and Town Centre Development  Policy 4.8 Supporting a successful & diverse retail sector & related facilities & services  Policy 4.9 Small Shops  Policy 4.10 New and emerging economic sectors  Policy 4.11 Encouraging a connected economy  Policy 4.12 Improving opportunities for all  Policy 5.1 Climate change mitigation  Policy 5.2 Minimising carbon dioxide emissions  Policy 5.3 Sustainable design and construction  Policy 5.4 Retrofitting  Policy 5.4 A Electricity and gas supply  Policy 5.5 Decentralised energy networks  Policy 5.6 Decentralised energy in development proposals  Policy 5.7 Renewable energy  Policy 5.8 Innovative energy technologies  Policy 5.9 Overheating and cooling  Policy 5.10 Urban greening  Policy 5.11 Green roofs and development site environs  Policy 5.12 Flood risk management  Policy 5.13 Sustainable drainage  Policy 5.14 Water quality and wastewater infrastructure  Policy 5.15 Water use and supplies  Policy 5.16 Waste net self-sufficiency  Policy 5.17 Waste capacity  Policy 5.18 Construction, excavation and demolition waste  Policy 6.1 Strategic approach  Policy 6.3 Assessing effects of development on transport capacity  Policy 6.4 Enhancing London’s transport connectivity  Policy 6.7 Better streets and surface transport  Policy 6.8 Coaches  Policy 6.9 Cycling  Policy 6.10 Walking  Policy 6.12 Road network capacity  Policy 6.13 Parking  Policy 7.1 Lifetime neighbourhoods  Policy 7.2 An inclusive environment  Policy 7.3 Designing out crime  Policy 7.4 Local character  Policy 7.5 Public realm  Policy 7.6 Architecture  Policy 7.7 Location and design of tall and large buildings  Policy 7.8 Heritage assets and archaeology  Policy 7.9 Heritage-led regeneration  Policy 7.10 World Heritage Sites  Policy 7.11 London View Management Framework  Policy 7.12 Implementing the London View Management Framework  Policy 7.13 Safety, security and resilience to emergency  Policy 7.14 Improving air quality  Policy 7.15 Reducing and managing noise  Policy 7.18 Protecting open space and addressing deficiency  Policy 7.19 Biodiversity and access to nature  Policy 7.20 Geological conservation  Policy 7.21 Trees and woodlands  Policy 7.29 The River Thames  Policy 8.1 Implementation  Policy 8.2 Planning obligations  Policy 8.3 Community infrastructure levy  Policy 8.4 Monitoring and review

Lambeth Local Plan (2015) policies:

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

 D1 Delivery and monitoring  D2 Presumption in favour of sustainable development  D3 Infrastructure  D4 Planning obligations  D5 Enforcement  ED1 Key Industrial and Business Areas  ED3 Large offices (greater than 1,000 m2)  ED6 Town Centres  ED7 Evening economy and food and drink uses  ED10 Local Centres and dispersed local shops  ED11 Visitor attractions, leisure, arts and culture uses  ED12 Hotels and other Visitor Accommodation  ED14 Employment and training  EN1 Open space and biodiversity  EN3 Decentralised energy  EN4 Sustainable design and construction  EN5 Flood risk  EN6 Sustainable drainage systems and water management  EN7 Sustainable waste management  H1 Maximising housing growth  H2 Delivering affordable housing  H4 Housing mix in new developments  H5 Housing standards  H8 Housing to meet specific community needs  PN2 (Vauxhall)  Q1 Inclusive environments  Q2 Amenity  Q3 Community safety  Q4 Public Art  Q5 Local distinctiveness  Q6 Urban design: public realm  Q7 Urban design: new development  Q8 Design quality: construction detailing  Q9 Landscaping  Q10 Trees  Q11 Building alterations and extensions  Q12 Refuse/recycling storage  Q13 Cycle storage  Q15 Boundary treatments  Q18 Historic environment strategy  Q19 Westminster World Heritage Site  Q20 Statutory listed buildings  Q22 Conservation areas  Q23 Undesignated heritage assets: local heritage list  Q24 River Thames  Q25 Views  Q26 Tall and large buildings  S1 Safeguarding existing community premises  S2 New or improved community premises  T1 Sustainable travel  T2 Walking  T3 Cycling  T4 Public transport infrastructure  T6 Assessing impacts of development on transport capacity  T7 Parking  T8 Servicing

Regional Guidance

Relevant publications from the GLA include:

 Affordable Housing and Viability SPG (August 2017);  Housing SPG (March 2016);  Central Activities Zone (March 2016)  Social Infrastructure (May 2015)  Accessible London: Achieving an Inclusive Environment (October 2014)  The control of dust and emissions during construction and demolition (July 2014)  Character and Context (June 2014)  Sustainable Design and Construction (April 2014)  Use of planning obligations in the funding of Crossrail, and the Mayoral Community Infrastructure Levy SPG (2013)  Shaping Neighbourhoods: Play and Informal Recreation SPG (Sep 2012)  London View Management Framework (March 2012)

Local Guidance / Supplementary Planning Documents

Relevant local guidance and SPDs for Lambeth include:

 Development Viability SPD  Employment and Skills SPD  Vauxhall SPD  Albert Embankment Conservation Area, Conservation Area Character Appraisal, May 2017  Parking Survey Guidance Notes  Refuse & Recycling Storage Design Guide  Waste Storage and Collection Requirements - Technical Specification  Air Quality Planning Guidance Notes