Lambeth 18/05425/FUL Higgs Industrial Estate, Road, London SE24 0AU This submission is made by the planning group of the Herne Hill Society. The Society is aware of the history of the site and the fact that there is an existing permission for development of the site. We think the applicants have failed to justify the amount of development on the site by an incorrect use of London Plan policies in relation to the PTAL rating and density ranges. More generally, we consider that any scheme for this site ought, if it is meet the aims of both of the current local plan and the draft new plan, create a scheme that includes the office building (now in use as a church) on the north of the site. For these reasons we object to the application. The application correctly assesses the PTAL rating as 3/4: the northern part of the site is in category 4, with a larger part, at the southern end as category 3. It also defines the area as ‘Central’, but with no reasons given for the definition. ‘Central’ is described in the London Plan as “areas with very dense development, a mix of different uses, large building footprints and typically buildings of four to six storeys, located within 800 metres walking distance of an International, Metropolitan or Major town centre comprising very dense development, with large building plots, characterised by buildings of 4-6 storeys”. ( is a Major town centre, according to the Plan but is in excess of 1km walking distance away.) In contrast ‘Urban’ is described as “areas with predominantly dense development such as, for example, terraced houses, mansion blocks, a mix of different uses, medium building footprints and typically buildings of two to four storeys, located within 800 metres walking distance of a District centre or, along main arterial routes”.

Almost all of the surrounding area is made up of 2-3 storey, with some limited 4- storey development. The site for the proposed development is clearly ‘Urban’, not ‘Central’. The density matrix in the London Plan for ‘Central’ sites with PTAL rating 4-6, i.e. 650–1100 habitable rooms per hectare (hr/ph). The actual figure for this site in the proposed development (see p.51 of the D&A) is 1,036 hr/ph. The density range for ‘Urban’ sites with PTAL 4-6 is 200–700 hr/ph and 200–450 hr/ph for sites with PTAL 2-3. As this site has an agreed PTAL rating of 3-4, the appropriate density range is near the top of the 3-4 category, i.e. 450. The lower range of an area with a 4-6 rating would be 650. Therefore, in the view of the Society, the proposal to redevelop on the basis of 1,036 hr/ph represents a considerable over-development of the site.

The decision to maximise the density of the site and to have all commercial/ industrial space above ground has resulted in increases in the height of the proposed blocks, not least the 17-floor block next to the railway. This contrasts with 8 storeys maximum in the consented scheme. There is also an increase in the height of the blocks along Herne Hill Road. Policy 7.4 of the London Plan draws attention to Local Character. This is reflected in Policy Q7 of the Lambeth Plan. New development should have “a bulk, scale/ mass, siting, building line and orientation which adequately preserves or enhances the prevailing local character; or, in the case of regeneration and opportunity areas where the context is changing, it respects and contributes towards the intended future character of the area”. The draft new Lambeth Plan refers to new development needing to be “respectful of the prevailing local character; or, where the context is changing, contribute towards the intended future character of the area.” It is not our understanding of the Lambeth Plan (or the new draft plan) that Loughborough Junction is intended in future to be an area of high-rise buildings. The established local character of Loughborough Junction is one where the prevailing building height does not exceed 4 storeys at most. The 11 storeys of the Loughborough Estate blocks do not provide a precedent. They are distinct from the old urban centre of Loughborough Junction, standing on a purpose-built site with a spacious character very different from the constrained site available in this proposal. The Society is especially concerned about the height of the blocks along Herne Hill Road. These buildings, by their position, can be said to impact more on the local community than the tower block which is set away from the road. In their height they adopt a form that is not only over-dominant but conflicts with the local urban grain. The Society has not seen any viability assessment for the site, and would not want to see any reduction in the amount of affordable housing in order to reduce the overall density, but is concerned that the current proposal represents a considerable over-development of the site and asks the committee to reject this application and invite the applicant to consider a reduction in the amount of development on the site. If the requirement to provide non-residential floorspace were removed or more were provided below ground, this could make the scheme viable at a lower density, still with active uses on the ground floor of Herne Hill Road but overall a reduced height. Servicing arrangements: it is not clear what the arrangements for access to the site will be when the concierge is not on site. Thus, can cyclists use the perimeter road when the gates are locked, how will any of the non-residential uses be able to service their premises, and indeed if residents need to arrange out of hours deliveries, how will that be arranged? It is not clear whether the church car park will be available to others at certain times or whether 4 parking spaces for disabled users is enough for the 13 units proposed. Questions are also bound to be raised about the capacity of Loughborough Junction to cope with increased use. It should not simply be assumed, as the application appears to do, that there is capacity. Further, although it remains an aspiration in the Lambeth Plan and in the draft new plan to have a new station at Loughborough Junction on the Overground we are not aware of any tangible prospect of this coming about. In the Society’s view, a historic opportunity is being lost to make a coherent improvement to this part of Loughborough Junction through the retention of the office building (and its car park) at the Herne Hill Road/ junction. There is a complete disconnect between the proposed development and this 2-storey building. It is a building with no architectural qualities, built to its boundary in such a way as to create hazards for pedestrians, particularly on Coldharbour Lane. The objectives in both the Lambeth plan and the new draft plan refer to supporting Loughborough Junction as a local centre with “a clear identity and sense of place”. With the proposed development identity and sense of place remain confused and difficult to read. The corner office building creates a physical and visual block that, if removed and sensitively redeveloped as one combined site with the current application site, could contribute to a coherent and far more attractive local centre for Loughborough Junction and act as a catalyst for further improvements to the surrounding area. This could include “increased permeability and navigability of the area”, as encouraged in the draft local plan, and, for example, a second station entrance could be made, reducing the stress on the single current entrance, a stress which will only increase when new residents arrive on the Higgs Estate. To achieve such a goal would probably require the exercise of compulsory purchase powers and we can only urge the council to consider their use in this case.

5 March 2019