APPENDIX 4 – OFFLINE Consultation Responses (Waterloo & South Bank Public Realm Framework)

Represen REF. Comment made Officer response Proposed change tor #1 1 Foreword: Cllr Holland The Council and Publica sought to undertake a N/A Marylin The framework is the result of extensive consultation and engagement within the collaborative engagement process within the project Evers local area. It reflects the needs priorities and aspirations of a broad range of local scope, budget and resource. consultees. The project team aimed to have as many face-to-face Publica appeared to feel it was appropriate to allocate a very brief 30 minutes to meetings with strategic / commercial stakeholders as meetings with key stakeholders/businesses/organisations (the few they did meet) possible. As a result, 17 organisations were and that 30 minutes was adequate time to grasp the complexities, accommodated – which would have been significantly interdependencies and nuances of the area, or was it that Publica had no intention less if hour sessions were offered. of taking the time necessary to undertake thorough and rigorous research. The project team asked each stakeholder within the invitation and the meeting itself to submit any evidence to support the Framework and provide additional feedback to the team about their aspirations, plans and recommendations. 2 Some key stakeholders were omitted from the consultation, receiving no The community ‘drop-in’ sessions sought to capture N/A communication on the proposal for a public realm framework from Publica or from local resident’s views at a neighbourhood level. the local authority. Sessions were promoted via the council’s website and social media, with emails sent to stakeholders The public drop-in’ consultation sessions were not widely advertised to local people. requesting support in sharing with their networks. Information published by WCDG in April 2019 was the first local residents heard of Forty-four people attended the three sessions. In the draft public realm framework in many cases future we will advertise sessions more widely and further in advance and try to make provision for ‘offline’ communications.

3 Executive Summary Officers disagree with this comment. However, the Amendments have It provides an assessment of the existing public realm Executive Summary should provide a clearer content been made to the The public realm framework is founded on a rigorous baseline study of local streets and understanding of the Framework. Executive Summary and spaces. (pages 6-13) considering other It provides a superficial, flawed assessment of key, high profile public realm assets, a comments received poor basis for a comprehensive, well informed public realm framework. from respondents following the public consultation. 4 An aspirational project for Coral Street The meeting with Bankside Open Spaces Trust in Amendments have The proposals for Coral Street have given rise to concern and some bewilderment February 2018 lasted 45 minutes. been made to spatial on the part of the local community and local community organisations. ‘A more brief D1 – Coral Street seamless connection with Waterloo Millennium Green’. Publica held one of those Publica made notes of all engagement meetings and (pg. 94) to reflect brief 30 minute meetings with Bankside Open Spaces Trust in February 2018. sought to ensure that the very broad range of BOST’s masterplan Publica clearly forgot or disregarded the discussion with BOST, completely ignoring comment was reflected within the Draft PRF. aspirations. or misinterpreting the ownership, management and maintenance arrangement in relation to the Waterloo Green. The PRF does not include spatial briefs (detailed Clarifications on live descriptions and recommendations) of ‘live’ projects, projects and their including Bernie Spain Gardens or Waterloo inclusion in the PRF Millennium Green masterplan. This was a conscious provided in the decision to avoid cutting across emerging proposals updated Executive and planning processes. The risk of rendering the PRF Summary and out-of-date prior to publication was also a concern. It alongside the is clear that this decision has been perceived as a lack Development Context of regard and support for these projects, which was map. not the intention. Greater clarity should have been provided to avoid this misunderstanding and this will be addressed in an updated PRF.

The concept designs for Coral Street and Emma Cons Gardens are intended as high level, indicative and illustrative interventions only, representing Publica’s recommendations and professional advice for each site. They are not design proposals per se. 5 There is no indication of consultation and engagement with residents of Tanswell Any designs that come forward for ‘example projects’ Spatial brief D1 – Coral Estate in relation to this aspirational project for Coral Street. Local custodianship of (such as Coral Street) will be subject to separate due Street, second bullet the space and the closure of Coral Street to traffic present a major challenge in diligence; in which, conversations will be undertaken point (pg. 94) has been terms of the basic management practicalities for the local authority and the day to with interested parties, as well as dedicated design amended to: ‘Explore day lives of the residents of Tanswell Estate, and a challenge in terms of commissions and statutory public consultation and the opportunities to planning process, if required. relocate servicing and 2

consultation and engagement with those residents. The proposal appears to be refuse collection from misguided and misinformed. It is acknowledged that the status of the concept Coral Street with due designs could have been made clearer. This will be consideration to addressed in the update. authorised or essential access needs. Consider using access from Baylis Road.’ 6 This specific proposal and much of the draft public realm framework demonstrate Rough sleeping and homelessness are addressed A new sub-tactic has that the authors chose to overlook the longstanding challenge of the homeless within the ‘Key Issues and Opportunities’ section – been created within population, concentrated in this part of the Borough but increasing at pace across Evening and Night Time Economy (pg. 35) as per spatial brief C6 – Lambeth and the whole of the country. This must be a significant factor in the below: Emma Cons Gardens design and management of the public realm. A relevant and acceptable public (pg. 88): ‘Engage with realm framework must include management of the issue, including support for ‘Rough sleeping and homelessness remains a pressing partners and local ad vulnerable individuals using the public realm and support to the organisations concern in Waterloo and South Bank, especially at statutory stakeholders providing essential services and support. night and around the station. This reflects wider to address the London- trends that show the number of people sleeping rough wide challenges of in the UK is more than double what it was in 2010. rough sleeping and Local churches and charities, such as St. John’s and homelessness, which Webber Street, provide shelter to the homeless as are evident within this part of wider initiatives across the capital. space.’ 7 The evidence base for the Framework was established through comprehensive In future, Area Regeneration will include Waterloo N/A fieldwork and research, including on site public realm surveys and data collection.... Community Development Group as a key stakeholder. Engagement with the local community and stakeholders was central to the process. Stakeholder engagement has taken place in a variety of The community ‘drop-in’ sessions sought to capture ways...including...workshops. local resident’s views at a neighbourhood level. Sessions were promoted via the council’s website and Waterloo Community Development Group was not consulted. social media, with emails sent to stakeholders The public drop-in’ consultation sessions were not widely advertised to local people. requesting support in sharing with their networks. The report gives every impression of starting from a clean sheet, a fantasy fresh Forty-four people attended the three sessions. In start, taking little account of the lessons learned or of the work done previously, (for future we will advertise sessions more widely and example, a locally-led masterplan and design for Emma Cons Gardens agreed as part further in advance and try to make provision for of the overall improvements to The Cut and Lower Marsh and its renaissance as the ‘offline’ communications. shopping centre for the area, and was adopted by LBL in 2008, or the work currently in hand on Bernie Spain Gardens led by Coin Street Community Builders and local Reviewing and detailing lessons learned from previous residents). projects was not within the scope of the PRF.

During communication and engagement with stakeholders, the council and Publica asked stakeholders to supply relevant strategies, plans and

documents to support the emerging Framework’s evidence base.

The locally-led masterplan and design for Emma Cons Gardens produced in 2008 was not supplied to Publica or the Council during production of the Framework. The masterplan may retain merit and Lambeth would welcome sight of it. There is the risk, however, that eleven years on the context has changed. The more recent 2013 Waterloo SPD recommends reconfiguring Emma Cons Gardens to create a more attractive gateway to Waterloo and a space suitable for community events – which clearly aligns with the PRF.

8 Cycling is a popular transport mode in the area,… and there is a demonstrated Support for the prioritisation of walking and cycling is N/A demand for increased cycle infrastructure such as bike sharing docks and cycle lanes. adequately referenced within the PRF, particularly A bland, vacuous statement leading to little or no serious action in relation to within the following guiding principles and Spine prioritising cycling and the creation of uninterrupted, well planned cycle routes, for Route related spatial briefs below: example all the way along Chicheley Street, Belvedere Road and Upper Ground, a • Guiding principle #1, tactic b) route which currently provides an obstacle course for cyclists. • Guiding principle #3, tactics b) and d) • Guiding principle #6, tactics a) • Spatial briefs: - B1 – Belvedere Road at County Hall - B3 – Belvedere Road at Jubilee Gardens - B5 – Waterloo Bridge Undercrofts - B6 – Upper Ground at Coin Street 9 Guiding principles The six guiding principles reflect a wide range of N/A On the whole, the guiding principles add little to what is self-evident, already opportunities, challenges, issues and constraints happens, or is already well covered in London Plan and Lambeth Local Plan Policy. A identified by local stakeholders throughout the framework of public realm improvements should be founded on the following engagement process. They are based on themes principles, rather than the motherhood-and-apple-pie ‘guiding principles’ proposed identified by Publica as a result of their evidence (Celebrate and protect culture, heritage and design excellence etc). Growth in gathering and engagement. Waterloo must maintain the balance of residents, workers, commuters and visitors which has contributed to its current success. The public realm is a break from the A rigorous internal process within the council was also buildings and their separated uses: it is the place all stakeholders come together, so undertaken to review, amend and approve the guiding should facilitate that mix while protecting areas which would be damaged from the principles at draft stage. This exercise was undertaken mix (e.g. residential backstreets). Solutions work best which work with local at senior management level across multiple service knowledge and which are locally-owned, particularly future management and areas, including Area Regeneration, Planning Policy, maintenance. Design and Conservation, Transport, Highways and Parks. 4

Lambeth Local Plan (2015) • Section 3: Strategic Objectives focuses on promoting community cohesion and safe, liveable places whilst creating and maintaining attractive, distinct places. • Supports better accessibility, legibility and the prioritisation of walking and cycling within policies T1 Sustainable Travel, T2 Walking and T3 Cycling. • Encourages new and improved civic amenity and green infrastructure through policy EN1 Open Space & Biodiversity. • Policy EN4 Sustainable Design & Construction promotes high standards of sustainable design, encouraging proposals of non-residential developments to include a maintenance plan. • Policy Q3 Community Safety endorses designing-out crime within the public realm. • Policy Q5 Local Distinctiveness emphasises the preservation and reinforcement of cultural and historical places. • Policies Q6 Urban Design and Q7 Urban Design: New Development supports attractive, uncluttered, coordinated public realm that enhances the setting of and spaces between buildings whilst improving legibility and movement, reducing barriers; providing new / enhanced open space, robust street furniture, permeable paving and a high quality public realm that is built of durable, robust, low- maintenance materials that is both flexible and adaptable.

• Both policies Q9 Westminster World Heritage Site and Q20 Statutory Listed Buildings celebrate and protect culture, heritage and local character.

London Plan (2016) • Aims to sustain and enhance the vitality of London’s centres, encourages access by walking and cycling, promotes safety and security; and contributes towards an enhanced environment, urban greening, public realm and links to green infrastructure. The guiding principles strategically align with Chapter Two: London’s Places, Chapter Five: London’s Response to Climate Change, Chapter Six: Transport, and Chapter Seven: London’s Living Spaces and Places.

Healthy Streets for London, Draft Lambeth Transport Strategy (2019-2041) and Lambeth Air Quality Action Plan (2017-2022) advocate the prioritisation of walking and cycling, focus on accessibility and movement and support the provision of improved air quality. Further policy documents are outlined as evidence within the Draft Public Realm Framework on page 39.

The guiding principles also reflect the existing priorities set out within SoWN’s Draft neighbourhood plan, for example: • Green infrastructure, open space & air quality are reflected in Principle 1 with more detailed air quality actions outlined within Lambeth Air Quality Action Plan (2017 to 2022). • Social infrastructure and culture are reflected in Principle 2. • Development and management are considered in Principles 5 and 6. 10 A more equitable and workable result would be more likely if the key principles Producing economic and demographic analysis was N/A addressed the high levels of social exclusion and deprivation in the local residential not in scope of the PRF. community hidden by the wealth in the area, along with the frequent by-passing or

alienation of the local community from the decision-making process, despite a very The PRF does, however; seek to encourage public organised network of activists. realm that is inclusive and welcoming for all. 11 Do spatial briefs respond to/reflect the needs of the area Comment acknowledged. Belvedere Road and Upper First bullet point of Much of what is proposed is already being delivered, either via the Southbank Ground family of projects recognises the importance spatial brief B3 Place development or via the s278 funding from the development which is of the Spine Route as a sequence of spaces with the amended to read: currently being spent on Belvedere Road. The main ‘new legible route’ proposed potential to draw together the station area and the by Publica goes through the Southbank Centre service yard which cannot be a cultural institutions along the river. A section of the “Explore the potential publicly accessible space. Publica proposes activation of the railway arches lining route is currently being delivered through the s278 for improved access this route. A completely misinformed proposal demonstrating a complete funding of the Southbank Place development and this between South Bank ignorance of the very important and essential current intensive uses of the is recognised in spatial brief B2. Much of the and Waterloo Station railway arches and the SBC service road. remaining route still requires improvement. along the railway viaduct as a The Low Line concept links existing centres of activity continuation of the and enterprise by creating new attractive routes Low Line that runs alongside rail arches and viaducts and their associated from London bridge. spaces and streets. Consider activating the railway arches lining The Low Line routes will facilitate economic growth this route, for example and improve access and permeability along the rail with partnership with viaducts and will be referenced as policy within the cultural institutions.” Draft Revised Lambeth Local Plan. Image showing restricted Southbank Centre road removed to reflect text changes. 12 The ‘Opening up of new routes to South Bank from York Road’ is already the The PRF is not a delivery plan and does not set out N/A central feature of the new public realm in Southbank Place. However, the main investment requirements or funding streams – this central route through Southbank Place, from Waterloo Station, past the re- should be navigated via the progression of individual opened York Road tube station entrance, will create a new route to the river project sites. through Jubilee Gardens and add further to the footfall across the Gardens and to the cost of management and maintenance of the Gardens. Further pressure Currently there is a funding mechanism set up via the of this nature on areas of public realm not owned by the local authority confirms Visitor Management Group which allocates S106 funds the requirement to reinvest the proceeds of development in the neighbourhood. to Jubilee Gardens for management and maintenance.

13 Also see reference to the proposal for Coral Street, discussed above. No material changes required to the PRF – funding / N/A resource allocation is not within the scope of the Other priorities Framework. A significant proportion of S106 money (as well as Community Infrastructure Levy) is generated in Waterloo and the South Bank. Therefore, a commensurate proportion of the S106 funding accumulated by LBL (some £39m) should be allocated to 7

public/community projects in this area, but based on research undertaken for the Neighbourhood Plan and previous research/community consultation/ studies/master plans in relation to Waterloo and the South Bank, not on a fundamentally flawed report from an organisation with scant knowledge and understanding of the area.

14 The overwhelming local consensus is that where resources are needed most is in Funding / resource allocation is not within the scope Stronger emphasis on revenue expenditure on management and maintenance. High quality of the Framework. the importance of management and maintenance is critical to the overall quality of the public robust management realm, and ultimately a higher priority than most of the projects identified by the and maintenance Framework. Many of the public realm services in the busiest parts of the needs has been neighbourhood are provided by the private landowners of major areas of the reflected within the busiest public realm, many of these (Jubilee Gardens Trust, Southbank Centre, text of Guiding National Theatre, Coin Street Community Builders) with charitable status or not Principle 5. for profit organisations, or via services supported on a very large scale from sources other than core Council funding, that is S106 funds, private funds via BIDs and voluntary business contributions. 15 The need for high quality management and maintenance of all public areas, Detail on materials and palette of public realm Stronger emphasis on whether Council or privately owned, is a matter constantly raised by many local improvements / enhancements should be navigated as the importance of stakeholders. Yet one of the few references to management issues in the individual sites are brought forward and progressed. robust management document is to recommend the use of sustainable materials. Again, a principle and maintenance already well covered in the London Plan, the Lambeth Local Plan and the policies Sustainable materials are covered within Lambeth and needs has been of the local stakeholders and delivery agents. London policy. reflected within the text of Guiding Principle 5.

Stronger emphasis on sustainability has been reflected within Guiding Principle 1. 16 If the purpose of the Framework is to assist in prioritising resources (Cabinet Jubilee Gardens is given adequate reference within Amendments to spatial Member introduction, para 3) it is not consistent, well considered or helpful to omit the Framework – focused within spatial brief B3, brief B3 – Belvedere what is already agreed to be a top priority, as reflected in the Council’s own Local Belvedere Road at Jubilee Gardens. Road at Jubilee Plan. Specifically, the omission of the Jubilee Gardens extension, involving no Gardens have been Council owned land, which will increase the overall area of Jubilee Gardens by some Further reference and priority have been given to undertaken to update 40% (approx. 0.6 ha), a very significant increase in the overall green space in the Jubilee Gardens within the revised Framework. the information and neighbourhood. This important, high profile opportunity is virtually ignored by the alignment with the draft Framework. Lambeth’s policy.

Spatial brief B3 – Belvedere Road at Jubilee Gardens will be recognised as a priority project; thus, resulting in a total of six priority projects identified within the Public Realm Framework. 17 Areas where public realm remains poor are largely dominated by spaces where Victory Arch Square has its own spatial brief and is N/A redevelopment has failed to come forward (Elizabeth House, Royal St, Doon St, highlighted as one of the six priority projects within Cornwall Rd) or where the very heavy volumes of traffic have taken a heavy toll the Framework. Elizabeth House has been referenced (Stamford Street, Westminster Bridge Road). These neglected areas are given little as a ‘ongoing or proposed adjacent development’ for or no attention in the framework. Chicheley Street and Victory Arch and Mepham Street.

Royal Street has been referenced as is listed as a an ‘ongoing or proposed adjacent development’ for spatial briefs for Upper Marsh and Carlisle Lane.

Within Publica’s methodology, the evidence base for the Framework was established through comprehensive fieldwork and research, including on- site public realm surveys and data collection, mapping, policy and other analysis, photography, and research, as well as a public realm audit of key sites identified through the survey projects. The 18 spatial briefs were thus based on the spaces most in need of investment and improvement. 18 The Waterloo community would welcome a specific priority to ensure loss of trees is The provision and creation of green infrastructure is N/A prevented almost without exception, that all tree loss is replaced two for one, or adequately covered within guiding principle 1. better, and that a major tree planting programme is initiated without delay across Waterloo and the South Bank, with the use of relatively mature trees in most cases. The Framework is strategic guidance and does not set policy, therefore this request is out of scope. 19 Does your organisation support delivery of the PRF and public realm Publica made notes of all engagement meetings and N/A improvements in Waterloo and the South Bank sought to ensure that the very broad range of comment was reflected within the Draft PRF. The authors of the report clearly ignored key, critical elements of discussions with Invariably, this required the exercise of judgement in those they did meet. assessing and accommodating sometimes competing comments.

20 The report is misinformed. It makes proposals based on lack of understanding and Officers disagree with this statement. N/A misinformation, proposals which, therefore, cannot be implemented Within Publica’s methodology, the evidence base for the Framework was established through comprehensive fieldwork and research, including on- site public realm surveys and data collection, mapping, policy and other analysis, photography, and research, as well as a public realm audit of key sites identified through the survey projects. The 18 spatial briefs were thus based on the spaces most in need of investment and improvement. 21 What is presented as a Waterloo and South Bank Public Realm Framework does not The guiding principles and recommendations within N/A reflect key issues related to the privately owned but publicly accessible parts of the the Framework are applicable to both private and neighbourhood which comprise a high proportion of the busiest areas publicly owned spaces.

22 The draft Framework takes little account of the very extensive work by the local The Framework takes adequate account of the Further references business and resident community on the Neighbourhood Plan. Neighbourhood Plan. added throughout the document. Further information has been added to support this within the final version. Creation of a new double page spread titled ‘Policy Context and Partnership Working’ referencing previous frameworks / masterplans and stakeholder involvement (pages 40- 41)

Creation of a new double page spread titled ‘Relationship with policy Context’ (pages 60-61). 23 It is a matter of great concern as to why this work was commissioned when No material changes required to the PRF N/A many other documents set out public realm priorities and aspirations from the Local Plan onwards.

24 The Framework focuses on the Waterloo and South Bank public realm as a space The report identifies 3 space typologies: global, N/A to pass through from the perspective of a global or metropolitan user, as metropolitan and local, presented in the Space opposed to areas which fulfil a diverse range of requirements including the Typologies map. This categorisation is based on the convenience and wellbeing of the local residential community. user group that more heavily uses a particular space; it is not intended to identify the only user group of the space.

The guiding principles promote approaches to provide civic amenity, improve wellbeing for all (principle 1), and encourage the animation of spaces (principle 2). All these interventions are for the benefit of all user groups, including the local resident, and do not aim to create spaces where people will only pass through.

Additionally, the family of spatial briefs D (routes between local green spaces) focuses in particular on improvements to streets and spaces predominantly used by the local community. 25 The delivery of this specific public realm framework is not supported for the No material changes required to the PRF. N/A reasons identified in this response 26 Areas not covered An editorial judgement call was made to remove many Creation of a new Little reference to previous studies (research, consultations, frameworks, master local historic strategy references, which have been double page spread plans, proposals etc) discussed, consulted and agreed over the last twenty years in reviewed and have informed the PRF, from an earlier titled ‘Policy and relation to Waterloo and the South Bank. A report on the Waterloo and South Bank draft to keep the document to a manageable length. Partnerships’ – with Public Realm must start from the accumulated knowledge and understanding of the On reflection, we will seek to provide greater reference to previous area in the many existing studies and reports produced by local stakeholders/ recognition and acknowledgment of previous work in strategies and historic businesses/the local authority, etc, particularly the emerging South Bank and an updated Framework. documents (pages 40- Waterloo Neighbourhood Plan. 41). The guiding principles of the PRF reflect the existing priorities set out within SoWN’s Draft neighbourhood plan, for example: • Green infrastructure, open space & air quality are reflected in Principle 1 with more detailed air quality actions outlined within Lambeth Air Quality Action Plan (2017 to 2022). • Social infrastructure and culture are reflected in Principle 2. • Development and management are considered in Principles 5 and 6.

27 It demonstrates little understanding of the complex balance of social relations and Undertaking a socio-demographic review / analysis N/A needs which the public realm must seek to serve. was not in scope of the PRF.

The PRF does, however; seek to encourage a public realm that is inclusive and welcoming for all. 28 No initial engagement and consultation/communication with key local stakeholders, The Council and Publica sought to undertake a N/A for example WCDG, St John’s collaborative engagement process within the project scope, budget and resource.

The project team aimed to have as many face-to-face meetings with strategic / commercial stakeholders as possible. As a result, 17 organisations were accommodated – in which St John’s attended. The project team asked each stakeholder within the invitation and the meeting itself to submit any evidence to support the Framework and provide additional feedback to the team about their aspirations, plans and recommendations.

The purpose of undertaking a six-week public consultation was to enable the council to ensure a wider, more robust consultation – seeking views from residents, businesses, community and third sector organisations, landowners and others. 29 Jubilee Gardens Trust had to insist on a meeting with Publica. No invitation was No material changes required to the PRF N/A issued by LBL or Publica until after JGT contacted Publica/LBL to request a consultation meeting. 30 A major omission and a matter of serious concern is that the key public realm and The PRF does not include spatial briefs (detailed Clarifications on live open space project identified in the Lambeth Local Plan, the extension of Jubilee descriptions and recommendations) of ‘live’ projects, projects and their including Jubilee Gardens extension. This was a inclusion in the PRF 12

Gardens onto Hungerford Car Park, receives one passing and poorly-informed conscious decision to avoid cutting across emerging provided in the mention in the draft Public Realm Framework proposals and planning processes. The risk of updated Executive rendering the PRF out-of-date prior to publication was Summary and also a concern. It is clear that this decision has been alongside the perceived as a lack of regard and support for these Development Context projects, which was not the intention. Greater clarity map. should have been provided to avoid this misunderstanding and this will be addressed in an Amendments to spatial updated PRF. brief B3 – Belvedere Road at Jubilee Gardens have been undertaken to update the information and alignment with the Lambeth policy.

Spatial brief B3 – Belvedere Road at Jubilee Gardens will be recognised as a priority project; thus, resulting in a total of six priority projects identified within the Public Realm Framework. 31 Publica appears to have taken no account of the key points raised in responses to Within Publica’s methodology, the evidence base for Further policy and the 2018 draft Lambeth Local Plan, the Bishops Ward CLIPS consultations and the Framework was established through evidence references extensive, detailed consultations on the emerging South Bank and Waterloo comprehensive fieldwork and research, including on- added throughout the Neighbourhood Plan, nor of the master planning principles agreed by all key players, site public realm surveys and data collection, mapping, document. including the Council, for the redevelopment of Hungerford Car Park policy and other analysis, photography, and research, as well as a public realm audit of key sites identified Creation of a new through the survey projects. double page spread titled ‘Policy Context and Partnership Working’ referencing previous frameworks / masterplans and stakeholder involvement (pages 40- 41) 13

Creation of a new double page spread titled ‘Relationship with policy Context’ (pages 60-61).

Amendments to spatial brief B3 – Belvedere Road at Jubilee Gardens have been undertaken to update the information and alignment with the Lambeth policy.

Amendments to map references of Hungerford Car Park have also been amended in line with Planning Policy. 32 Little or no serious engagement with the local community, specifically the The purpose of undertaking a six-week public N/A communities likely to be affected by the proposals in the report, for example, consultation was to enable the council to ensure a residents of Tanswell Estate wider, more robust consultation – seeking views from residents, businesses, community and third sector organisations, landowners and others.

Ultimately, any designs that come forward for these sites will be subject to separate due diligence; in which, conversations will be undertaken with interested parties, as well as dedicated design commissions and statutory public consultation and the planning process, if required. It is acknowledged that the status of the concept designs could have been made clearer. This will be addressed in the update.

33 Little or no serious engagement with local businesses likely to be affected, for Sandell Street is a project underway and is being N/A example, The Wellington, in relation to the proposals for Sandell Street. subject to separate due diligence outside of the PRF scope, including conversations with interested parties. 14

34 The emerging South Bank and Waterloo Neighbourhood Plan, of critical importance The Framework takes adequate account of the Further references to the area, relegated to brief references, as opposed to central to future plans for Neighbourhood Plan. added throughout the Waterloo and the South Bank document. Further information has been added to support this within the final version. Creation of a new double page spread titled ‘Policy Context and Partnership Working’ referencing previous frameworks / masterplans and stakeholder involvement (pages 40- 41).

Creation of a new double page spread titled ‘Relationship with policy Context’ (pages 60-61). 35 South Bank and Waterloo Neighbourhood Forum not involved in initial The Council and Publica sought to undertake a N/A consultations. A serious omission which demonstrates the superficial and ill- collaborative engagement process within the project informed nature of the consultation and research scope, budget and resource.

The project team aimed to have as many face-to-face meetings with strategic / commercial stakeholders as possible. As a result, 17 organisations were accommodated – in which Ben Stephenson, Secretary of SoWN attended. The project team asked each stakeholder within the invitation and the meeting itself to submit any evidence to support the Framework and provide additional feedback to the team about their aspirations, plans and recommendations.

Forty-four people attended the three sessions; in which Ben Stephenson (Secretary, SoWN) and John Langley (Chair, SoWN) attended and had a discussion with the project team for over 30 minutes.

In future we will advertise sessions more widely and further in advance and try to make provision for ‘offline’ communications.

The purpose of undertaking a six-week public consultation was to enable the council to ensure a wider, more robust consultation – seeking views from residents, businesses, community and third sector organisations, landowners and others; whilst enabling the PRF to be cited as non-statutory guidance within the Draft Revised Lambeth Local Plan. SoWN included representations within this consultation also.

36 It barely references the local delivery bodies. There are 44 mentions of Lambeth Comment acknowledged. Creation of a new Council and 23 mentions of TfL. double page spread titled ‘Policy Context and Partnership Working’ referencing locally led bodies which have supported, managed and delivered public realm improvements (pg. 40- 41). 37 There is scant recognition of the complexities of land ownership and management Complex land ownership patterns are highlighted with Stronger emphasis on the ‘Development Context’ section (pg. 45). the importance of robust management Management and maintenance is adequately and maintenance referenced within the document and has been needs has been strengthened since public consultation comments reflected within the have been received. text of Guiding Principle 5. 38 Framework does not reflect key issues related to the privately owned but The guiding principles and recommendations within N/A publicly accessible parts of the neighbourhood which comprise a high proportion the Framework are applicable to both private and of the busiest areas. publicly owned spaces. 16

39 It ignores the current and proposed locally-led public realm improvements (Bernie The PRF does not include spatial briefs (detailed Clarifications on live Spain Gardens, Lambeth Bridge roundabout, at Lambeth North/Hercules Road descriptions and recommendations) of ‘live’ projects, projects and their junction, Millennium Green master plan etc) including Bernie Spain Gardens, Waterloo Millennium inclusion in the PRF Green masterplan, Lambeth Bridge roundabout etc. provided in the This was a conscious decision to avoid cutting across updated Executive emerging proposals and planning processes. The risk Summary and of rendering the PRF out-of-date prior to publication alongside the was also a concern. It is clear that this decision has Development Context been perceived as a lack of regard and support for map. these projects, which was not the intention. Greater clarity should have been provided to avoid this misunderstanding and this will be addressed in an updated PRF. 40 The critical issue of management and maintenance receives very little attention Management and maintenance emerged as a key Further referenced / in the document. priority for strategic and commercial stakeholders, addressed throughout was communicated through face-to-face engagement the Framework. meetings in addition to steering groups and strategic partnerships / forums. Publica and Lambeth Stronger emphasis on subsequently chose to dedicate one guiding principle the importance of (#5) solely to address this priority – promoting the robust management necessity of management and maintenance plans and maintenance has before public realm designs are confirmed and been updated to the delivered. As you are aware, this is an important text of Guiding deliverable within Lambeth’s South Bank Spine Route Principle 5. commission and will underpin the design and decision- making process.

Other references that portray the challenge and need for maintenance and management of the public realm are provided explicitly within the ‘Executive Summary’, the ‘Commercial and Strategic Stakeholders’ and ‘Local Aspirations’ sections – in addition to being addressed within Cllr Holland’s foreword.

The council understands the importance to produce public realm Delivery and Management and Maintenance Plans and will seek to produce these separately.

41 Various specific projects are utterly misunderstood and misguided, for example at Comment acknowledged. Proposals to amend Content within Coral St/Millennium Green, and the Jubilee Gardens extension over the Hungerford elements of this brief have been received during spatial brief B3 Car Park, which recommends "exploring ways to create a distinction between public consultation and will be incorporated. amended to: Jubilee Gardens and proposals for its extension". A comment which ignores the ‘With reference to current situation in relation to plans for the extension of the Gardens. Lambeth have also aligned this spatial brief with the policy in the Draft updated information agreed for inclusion within the Revised Lambeth Local Draft Revised Lambeth Local Plan to reflect policy. Plan, ensure that the area of Hungerford Car Park that is Metropolitan Open Land (MOL) is used to extend Jubilee Gardens, creating a new public space that seamlessly integrates within the existing garden.’ 42 It does not mention residents or their views or meaningful engagement with The community ‘drop-in’ sessions sought to capture N/A resident bodies local resident’s views at a neighbourhood level. Sessions were promoted via the council’s website and social media, with emails sent to stakeholders requesting support in sharing with their networks. Forty-four people attended the three sessions.

In future, we will seek to advertise sessions more widely and further in advance and try to make provision for ‘offline’ communications.

Any designs that come forward for ‘example projects’ (such as Coral Street) will be subject to separate due diligence; in which, conversations will be undertaken with interested parties, as well as dedicated design commissions and statutory public consultation and the planning process, if required. 18

43 Publica appeared to feel it was appropriate to allocate a very brief 30 minutes to The Council and Publica sought to undertake a N/A meetings with key stakeholders/businesses/organisations (the few they did meet) collaborative engagement process within the project and that 30 minutes was adequate time to grasp the complexities, scope, budget and resource. interdependencies and nuances of the area, or, Publica had no intention of taking the time necessary to undertake thorough and rigorous research. The project team aimed to have as many face-to-face meetings with strategic / commercial stakeholders as possible. As a result, 17 organisations were accommodated – which would have been significantly less if hour sessions were offered.

The project team asked each stakeholder within the invitation and the meeting itself to submit any evidence to support the Framework and provide additional feedback to the team about their aspirations, plans and recommendations. 44 The ‘drop-in’ consultation sessions not widely advertised to local people. The community ‘drop-in’ sessions sought to capture N/A local resident’s views at a neighbourhood level. Sessions were promoted via the council’s website and social media, with emails sent to stakeholders requesting support in sharing with their networks. Forty-four people attended the three sessions. In future we will advertise sessions more widely and further in advance and try to make provision for ‘offline’ communications. 45 Information published by WCDG in April 2019was the first local residents heard of The community ‘drop-in’ sessions were held in July N/A the draft public realm framework in many cases 2018 and sought to capture local resident’s views at a neighbourhood level. Sessions were promoted via the council’s website and social media, with emails sent to stakeholders requesting support in sharing with their networks. Forty-four people attended the three sessions. In future we will advertise sessions more widely and further in advance and try to make provision for ‘offline’ communications. 46 Little reference to air quality and the dangerous air pollution which affects the Lambeth council is committed to respond to the Sub tactic added to public realm in Waterloo and the South Bank. declared climate change emergency. A number of Guiding principle 1. actions are included in the PRF such as the promotion “Deploy creative of greening initiatives, the use of sustainable thinking and new ways construction materials, and the incorporation of smart of working to deliver a city technologies. A further tactic will be added to robust climate change guiding principle 1 as part of the reviewed document. response, addressing 19

the Council’s declared climate change emergency”. 47 Stamford Street, one of the most traffic dominated and polluted roads in Waterloo A methodology was produced to identify sites to be N/A is not mentioned, not included as a priority and ignored in terms of public realm included as spatial briefs, and prioritise sites within improvements. Stamford Street is a hostile environment for pedestrians and the PRF. residents. This represents a fundamental unjustified omission from the proposed Public Realm Framework. A similar concern applies in relation to Baylis Road and The scope of the PRF did not include listing and Westminster Bridge Road. prioritising all streets and spaces within the boundary area; rather highlighting an appropriate representation of sites that align with the methodology and the set priority criteria, below. These selected sites emerged during the first stage of Publica’s work (evidence base) that focused on a public realm audit. Therefore, inevitably many sites have consciously not been included within the Framework.

Priority sites were based on the following criteria: • They evidence the need for improvement and investment • Their proposals align strongly with the six guiding principles • They reflect local and / or strategic stakeholder aspirations and priorities • The sites are strategic spaces with a broader impact across waterloo and South Bank 48 The process and the conclusion of the PRF are very disappointing. The report takes The PRF does not focus on or include spatial briefs Clarifications on live little account of the work already in progress by land owners in collaboration with (detailed descriptions and recommendations) of ‘live’ projects and their the local community. projects currently being developed by landowners in inclusion in the PRF collaboration with the local community, such as Bernie provided in the Spain Gardens and Waterloo Millennium Green updated Executive masterplan. This was a conscious decision to avoid Summary and cutting across emerging proposals and planning alongside the processes. The risk of rendering the PRF out-of-date 20

prior to publication was also a concern. It is clear that Development Context this decision has been perceived as a lack of regard map. and support for these projects, which was not the intention. Greater clarity should have been provided to avoid this misunderstanding and this will be addressed in an updated PRF. 49 Key/critical information given to Publica by knowledgeable organisations and Publica made notes of all engagement meetings and Creation of a new individuals simply ignored or not understood sought to ensure that the very broad range of double page spread comment was reflected within the Draft PRF. titled ‘Policy and Invariably, this required the exercise of judgement in Partnerships’ – with assessing and accommodating sometimes competing reference to previous comments. strategies and historic documents (pages 40- An editorial judgement call was made to remove many 41). local historic strategy references from an earlier draft to keep the document to a manageable length. On Amendments to spatial reflection, we will seek to provide greater recognition briefs and example and acknowledgment of previous work in an updated projects have also Framework. been made in conjunction with relevant / corresponding comments. 50 Waterloo Strategic Forum: no more than window dressing. No material changes required to the PRF N/A 51 The report does not relate to or clarify the status of the CLIP consultation The priorities set out in the emerging Draft Waterloo N/A undertaken by the local authority in the area. The conclusions reached as a result of Cooperative Local Investment Plan (CLIP) are not the CLIP consultation should be a key element of the report, however, there is no required to feature within the Public Realm evidence to the effect that the CLIP consultation has been taken into account in the Framework as they represent two separate work production of the report streams. The PRF does not seek to specify funding sources other than outlining four different funding mechanisms – partnership-led, Development-led, Lambeth Council-led and TBC. 52 The report should be withdrawn as fundamentally flawed. Many Waterloo groups Officers disagree that the report is ‘fundamentally Creation of a new have expressed alarm and profound concern at the report based on their knowledge flawed’. double page spread of and involvement in the many years of work and consultation undertaken by the titled ‘Policy and Waterloo community in relation to Waterloo and its environment, which is in stark Subsequent to receiving responses from the PRF Partnerships’ to reflect contrast with this less than impressive, inaccurate document. public consultation, a meeting was convened on the continued support 20.06.19 with Andrew Travers (CEO, London Borough and provision of Lambeth), Nic Durston (CEO, SBEG) and Lucy undertaken by key

Musgrave (Founding Director, Publica); the stakeholders (pages subsequent next steps were agreed: 40-41).

1. To coordinate a workshop with key community, business and landowner representatives which will: − Address issues raised by some organisations and identify matters for clarification / refinement, matters for amendment and matters that are out of scope. − Enable a collaborative process to inform the production of public realm Delivery and Management and Maintenance Plans.

2. The Council to update the Draft PRF considering the above and publish it online.

A PRF stakeholder session has since been held on 23.09.19 where Lambeth officers discussed how comments were being taken onboard and outlined next steps – with the agreement of incorporating amendments and seeking to publish the document. #2 53 We refer to Lambeth Council’s Draft South Bank and Waterloo Public Realm No material changes required to the PRF N/A South Framework which was published for consultation in March 2019. Bank Employers This collective response has been prepared by South Bank Employers’ Group (SBEG) ' Group and is supported by: SBEG and its members, South Bank Business Improvement District, We Are Waterloo Business Improvement District, South Bank and Waterloo Neighbours (SoWN), Waterloo Community Development Group (WCDG), Jubilee Gardens Trust (JGT), Bankside Open Spaces Trust (BOST) and Oasis. A number of these organisations were represented at a general meeting of Waterloo Community Development Group on 1 May 2019, where the strength of shared concerns about the draft Framework led to support from those present for SBEG to prepare this joint response. Each of these organisations will also be submitting their own responses directly addressing the elements of the draft Framework which are relevant to them.

OVERVIEW

We support the principle of developing a public realm framework and have lobbied for many years for improvements to the public realm in the South Bank and Waterloo area.

This unique area is highly fragmented by multiple landowners and divided by Waterloo Station making it unlike other parts of London where land is predominately owned by single and / or large estates (e.g. at Kings Cross). This level of fragmentation inevitably creates inherent challenges. As a result, South Bank and Waterloo has a strong history of activism and committed and passionate collaboration between corporate entities, local employers, grassroots organisations and residents, all working together, alongside Lambeth Council, to campaign, fundraise and deliver projects which have shaped the area and resulted in significant positive change for all. These long-established coalitions, formed over the past 40 years, have collectively achieved a great deal and addressed common concerns such as public realm quality, strategic planning and design, and green space provision and management, in a period when sufficient support from local government has often been absent.

Working from a commitment to not just improve the area for individual benefit these groups and organisations have continued to deliver for the greater good of the area and all those who use it. From the 1997 opening of the Spine Route project which was a powerful catalyst for wider development and regeneration in the area, and the creation of Waterloo Green to mark the millennium, to the Urban Design Strategy produced in 2002, innovative pilots such as Legible London in 2007 and the regeneration of The Cut in 2008, the diverse communities of South Bank and Waterloo have set the standard for joint working and innovative partnerships.

The last decade has seen this way of working continue to thrive, despite the funding gaps created by austerity and cuts to local government, and has witnessed the transformation of Jubilee Gardens, regeneration of Lower Marsh, the delivery of a significant set of Hostile Vehicle Measures, the introduction of the South Bank Clean Team service, and most recently the launch of the pioneering Accessible South Bank project.

Local stakeholders come together through South Bank Partnership (SBP), South Bank Forum (SBF), SoWN and multiple grassroots groups, to champion and improve the area. The 2018 South Bank Manifesto, led by SBP and endorsed by Lambeth Council, Southwark Council, the GLA and the Mayor of London, clearly outlines the environment and public realm as the number one priority focus to ‘make South Bank the best place in London for people to live, work, study and visit’. The 23

Neighbourhood Plan, developed by SoWN with extensive and commended local consultation, puts the physical environment and public spaces at the heart of its policies.

Local knowledge and experience is already being harnessed to address many aspects of South Bank and Waterloo’s future in line with the Manifesto and Neighbourhood Plan, including key projects such as the extension of Jubilee Gardens and regeneration of Bernie Spain Gardens and Waterloo Green. Likewise, commitments to the Spine Route and to phase two of the Hostile Vehicle Mitigation measures have already been secured from Lambeth and are in the early stages of development.

The Manifesto agenda of ‘a better South Bank for everyone’ unites South Bank’s corporate entities and Waterloo’s grassroots organisations - it is a unique confluence and one that is neglected at risk. 54 FEEDBACK Officers disagree that there are significant flaws in the N/A While we recognise that this document is still out for consultation, we have approach of Lambeth Council and Publica. identified significant flaws in the approach of Lambeth Council and Publica which have led to a wholly inadequate process and an unsatisfactory draft Framework. Officers disagree that this is a “wholly inadequate process and an unsatisfactory draft Framework”. As a result, it is our belief that Lambeth should now pause the process and take a step back, using the opportunity to engage in a truly collaborative process with the Subsequent to receiving this representation, a local community, leading to a review of the principles and projects in the draft meeting was convened on 20.06.19 with Andrew Public Realm Framework. Travers (CEO, London Borough of Lambeth), Nic Durston (CEO, SBEG) and Lucy Musgrave (Founding Director, Publica); the subsequent next steps were agreed:

To coordinate a workshop with key community, business and landowner representatives which will:

− Address the issues raised in your letter and identify matters for clarification / refinement, matters for amendment and matters that are out of scope.

− Enable a collaborative process to inform the production of public realm Delivery and Management and Maintenance Plans. Signatories to your letter will be invited. 24

− The Council to update the Draft PRF considering the above and publish it online.

A PRF stakeholder session has since been held on 23.09.19 where Lambeth officers discussed how comments were being taken on-board and outlined next steps – with the agreement of incorporating amendments and seeking to publish the document. 55 The key areas of concern are: The Council and Publica sought to undertake a N/A 1. INADEQUATE STAKEHOLDER ENGAGEMENT AND CONSULTATION collaborative engagement process within the project scope, budget and resource. This comprised a Key groups, including some of the signatories to this document, were not aware that comprehensive log that can be made available on this process was underway and were not included in the consultations with Publica, request. demonstrating a clear failure to understand the dynamics which operate in this area. Those that were invited to participate were offered only 30 minutes to input - Publica made notes of all engagement meetings and an inadequate amount of time - given the depth of their knowledge and experience sought to ensure that the very broad range of in the area. comment was reflected within the Draft PRF. Invariably, this required the exercise of judgement in Those who did have an opportunity to input found their views were not taken into assessing and accommodating sometimes competing account with no feedback given as to why not. Provision was not made to reach out comments. to residents’ groups, leaving many (particularly those who are not online) unaware of their opportunities to input into the development of the Framework. Owners of Both the Waterloo Steering Group (10th October 2018) neighbouring areas of public realm (e.g. in LB Southwark) were excluded from the and the stakeholder workshop (7th March 2019) research phase despite South Bank and Waterloo not existing in isolation and addressed how stakeholder feedback was reflected in spanning two boroughs. This means that it is impacted by development activity and the Draft Framework. In future, we will seek to publish investments made immediately outside of the Framework’s area of study. an on-line summary of comment received and ‘close the loop’ on engagement.

The purpose of undertaking a six-week public consultation was to enable the council to ensure a wider, more robust consultation – seeking views from residents, businesses, community and third sector organisations, landowners and others. 56 2. LACK OF ACKNOWLEDGEMENT OF WORK DONE ON KEY PROJECTS The spaces that have been identified as priority Creation of a new As a result of these failings of the consultation, the priority projects chosen do not projects include Emma Cons Gardens, Concert Hall double page spread adequately reflect the priorities of the local community. Existing work has been Approach, Waterloo Bridge Undercrofts, Victory Arch titled ‘Policy Context ignored (e.g. Bernie Spain Gardens, Waterloo Green), incorrectly interpreted (e.g. Square, Sandell Street and Jubilee Gardens at and Partnership the extension to Jubilee Gardens, which is supported by local businesses and Belvedere Road. Working’ referencing residents) or discarded entirely (e.g. Spine Route masterplan undertaken by Gross policy, strategies and Max) with no explanation or rationale. Reference is made in passing to the South Priority sites were selected based on the following historic documents Bank Manifesto and the Neighbourhood Plan, both of which were subject to broad criteria: (pg. 40-41). consultation and represent collaborative documents endorsed by local stakeholders, yet in neither case are the principles they set out reflected in the Framework. • They evidence the need for improvement and Spatial brief B3 – investment Belvedere Road at There is strong local feeling that the Framework should be led by the priorities of • Their proposals align strongly with the six guiding Jubilee Gardens will be the local community which are already documented in the Manifesto and Plan, and principles recognised as a priority the draft Framework does not currently meet that expectation. • They reflect local and /or strategic stakeholder project; thus, resulting aspirations and priorities in a total of six priority • The sites are strategic spaces with a broader projects identified impact across Waterloo and South Bank within the Public Realm Framework. A decision was made not to produce spatial briefs (detailed descriptions and recommendations) of ‘live’ Further information on projects including Bernie Spain Gardens or Waterloo not including live Millennium Green masterplan to avoid cutting across projects as spatial emerging proposals and planning processes. The risk briefs has been of rendering the PRF out-of-date prior to publication updated within the was also a concern. It is clear that this choice has been ‘Executive Summary’ perceived as a lack of regard and support for these (pg. 9). projects, which was not the intention. Greater clarity should have been provided to avoid this misunderstanding and this has been redressed within an update to the PRF.

crime, prevention and safety. Two areas in need of substantive improvement, also emphasised within the Manifesto) include the management and maintenance of the public realm and the improvement of air quality – these are both highlighted as challenges requiring action within several sections of the PRF (in addition to references within individual spatial briefs).

Substantial consideration for both the South Bank Manifesto 2018 and SoWN’s Draft Neighbourhood Plan was duly undertaken within the PRF and, as a result, directly shaped:

a. Publica’s evidence base b. Guiding principles and sub-tactics c. Spatial brief content and locations selected to represent Upper Ground, Belvedere Road and key connections d. Creation of the Spine Route family of spatial briefs e. Key recommendations within spatial briefs e.g. C2 – Cornwall Road reflects SoWN’s aspiration for a ‘greenway’ or linear amenity space along the route focusing on walking, cycling and improved air quality f. Executive Summary – The Opportunity (page 7) and Context (page 9) g. Two South Bank Spine Route locations featured as priority projects h. Local, Metropolitan and Global concept. SoWN’s neighbourhood plan highlights designing spaces with residents rather than tourists in mind as a ‘burning issue’ within previous consultation. 57 3. ABSENCE OF PLANNING FOR MAINTENANCE Management and maintenance emerged as a key Stronger emphasis on Management and maintenance have consistently been identified as critical to the priority for strategic and commercial stakeholders, the importance of quality and longevity of any public realm scheme implemented in South Bank and was communicated through face-to-face engagement robust management Waterloo and are central to the objectives of both the South Bank Manifesto and meetings in addition to steering groups and strategic and maintenance Neighbourhood Plan. Where public realm has not been properly managed and partnerships / forums. Publica and Lambeth needs has been maintained (e.g. stretches of the Spine Route and Emma Cons Gardens) the result is subsequently dedicated one guiding principle (#5) updated to the text of clear - degraded, unsafe and unappealing areas which are not befitting of such a solely to address this priority – promoting the Guiding Principle 5. high-profile part of the capital. The draft Framework does not address this issue necessity of management and maintenance plans properly. It calls for design to take account of ease of maintenance (which has in any before public realm designs are confirmed and 27

case been a strong feature of all the locally developed projects referred to in this delivered. This is an important deliverable within paper) but makes no mention of proper provision for the current and future Lambeth’s South Bank Spine Route commission and revenue resource required to manage and maintain a high quality public realm in will underpin the design and decision-making such a busy area. process.

We are clear that we will not support the Framework without the explicit inclusion Other references that portray the challenge and need of management and maintenance as one of the guiding principles. for maintenance and management of the public realm are provided explicitly within the ‘Executive Summary’, ‘Commercial and Strategic Stakeholders’ section and ‘Local aspirations’ section – in addition to being addressed within Cllr Holland’s Foreword.

Through receiving comments within the public consultation, it is clear that maintenance and management could be emphasised and referenced further within the guiding principles and the general Framework itself. Lambeth will ensure this is covered off in the final published report.

The council understands the importance to produce public realm Delivery and Management and Maintenance Plans. 58 4. FORMULAIC AND FLAWED GUIDING PRINCIPLES The six guiding principles reflect a wide range of Stronger emphasis on The six ‘guiding principles’ are lamentably generic and do not provide a tailored opportunities, challenges, issues and constraints the importance of Framework appropriate for protecting and enhancing this unique area. Crucially, as identified by local stakeholders throughout the robust management detailed above, the existing work on public realm in the area, along with the critical engagement process. They are based on thematic and maintenance issue of long-term management and maintenance, have not been addressed despite areas identified by Publica as a result of their evidence needs has been the latter being an extremely high priority for all stakeholders. This is the inevitable gathering and engagement. updated to the text of result of the lack of discussion and collaboration in the early stages of the A rigorous internal process within the council was also Guiding Principle 5. Framework’s development. Seeking buy-in at the development stage would have undertaken to review, amend and approve the guiding avoided the current situation where there is little support for the proposed principles at draft stage. This exercise was undertaken Principles. at senior management level across multiple service areas, including Area Regeneration, Planning Policy, As a result, the draft Framework takes a piecemeal approach to public realm across Design and Conservation, Transport, Highways and the area, focusing on place projects and individual designs rather than setting a Parks. broad strategy and approach to be applied to all future public realm work. There are serious disconnects between the guiding principles, the priority projects outlined, The priorities set out in the emerging Draft Waterloo and where significant sums of money have recently been allocated. In addition, the Cooperative Local Investment Plan (CLIP) are not approach appears to rely heavily on funding from new developments to deliver required to feature within the Public Realm Framework as they represent two separate work 28

projects in certain areas. Without clear standards and guides this will inevitably streams. The PRF does not seek to specify funding result in the continuation of a fragmented and inconsistent public realm. sources other than outlining four different funding mechanisms – partnership-led, Development-led, It is noted that the document is not intended to be a delivery plan. However, the Lambeth Council-led and TBC. inevitable reliance on the proceeds of development to fund new public realm means that the Bishop’s Ward CLIP proposals should also form a significant part of the context. The CLIPS work was reported as complete in October 2018 but to date no information about it has been released by the Council. 59 5. KEY PROJECTS AND ISSUES NOT ADDRESSED A decision was made not to produce spatial briefs Stronger emphasis on The use of principles settled upon with no consultation inevitably means that the (detailed descriptions and recommendations) of ‘live’ the importance of projects and priorities supposedly derived from them are equally flawed. For projects including Bernie Spain Gardens or Waterloo robust management whatever reason, key projects in Lambeth Council’s new draft Local Plan receive Millennium Green masterplan to avoid cutting across and maintenance only passing mention including: the Jubilee Gardens Extension; the IMAX emerging proposals and planning processes. The risk needs has been roundabout (with no consideration of the fact that the latter is also now identified of rendering the PRF out-of-date prior to publication updated to the text of as a site for development); public realm elements of the Royal Street development; was also a concern. It is clear that this choice has been Guiding Principle 5. and aspects of the ‘Low Line’. perceived as a lack of regard and support for these projects, which was not the intention. Greater clarity Content within Other projects omitted are the Bernie Spain Gardens improvements which have just should have been provided to avoid this spatial brief B3 received planning approval, and phase two of Hostile Vehicle Mitigation (HVM) misunderstanding and this will be redressed within an amended to: measures to ensure that significant parts of the South Bank are protected – the update to the PRF. ‘Explore the potential Council has already made a commitment to this and it is essential that it is delivered for improved access as a complete project and not just where enabling development permits. The The extension of Jubilee Gardens is highlighted within between South Bank integration of security measures as part of developments and improvements, to spatial brief B3 – Belvedere Road at Jubilee Gardens and Waterloo Station which the Framework refers, is already part of Lambeth planning policy and (pg. 76). Proposals to amend elements of this brief have along the railway practice. been received during public consultation and will be viaduct as a incorporated. Lambeth will also align this spatial brief continuation of the Likewise, the issue of air quality is not adequately addressed by the Framework with the updated information agreed for inclusion Low Line that runs despite this being a priority factor in both the South Bank Manifesto and the within the Draft Revised Lambeth Local Plan. from London Bridge. Neighbourhood Plan. Proper initial collaboration would have enabled the principles Consider activating the to focus on those projects, initiatives and ambitions that deliver to a better quality Hostile Vehicle Mitigation (HVM) plans for the South railway arches lining environment in terms of air quality including investing in the greening of public Bank were not explicitly referenced in detail due to this route, for example spaces. This issue also features strongly in the new draft Lambeth Local Plan. the sensitive and evolving nature of the issue. through partnerships with cultural Finally, while we support the identification of the three typologies; global, Significant investment has been made within open institutions.’ metropolitan and local, it is crucial that investment aligns with this. For example, spaces and the public realm in Waterloo and South where multiple typologies result in the heavy usage of a space, the investment must Bank by Lambeth and stakeholders, which has Spatial brief B3 – reflect the quality required to ensure longevity of any public realm developments. contributed to the development and growth of the Belvedere Road at area. Recently the Council has invested in Upper Jubilee Gardens will be Marsh and Carlisle Lane and completed major recognised as a priority improvements to the junction of Westminster Bridge project; thus, resulting 29

Road and Kennington Road. Improvements to in a total of six priority Chicheley Street and Belvedere Road are being projects identified undertaken, and the council continues to invest within the Public significantly on an annual basis in Jubilee Gardens Realm Framework. through the Visitor Management Group. The council is also committed to investing in the Spine Route and HVM.

Adequate reference to air quality is provided within the Framework.

The PRF provides support for several major themes emphasised by SoWN’s Draft Neighbourhood Plan – Green Infrastructure, Open Space and Air Quality; and Streetscape and Transport. The council and Publica also sought to ensure that the four project descriptions (intended to attract funding) put forward by SoWN (Pr1-Pr4) reflect and align with the Framework, which include an emphasis on management and maintenance of the public realm, identifying and implementing opportunities for green infrastructure, support for improved air quality and the creation of pedestrian routes to encourage walking.

The South Bank Partnership Manifesto 2018 identifies six priorities, in which four are directly linked to the PRF – the environment and public realm, inclusivity, managing growth and development and security, crime, prevention and safety. Two areas in need of substantive improvement, also emphasised within the Manifesto) include the management and maintenance of the public realm and the improvement of air quality – these are both highlighted as challenges requiring action within several sections of the PRF (in addition to references within individual spatial briefs).

Substantial consideration for both the South Bank Manifesto 2018 and SoWN’s Draft Neighbourhood

Plan has been duly undertaken within the PRF and, as a result, directly shaped:

An editorial judgement call was made to remove many local historic strategy references to keep the document to a manageable length. On reflection we will seek to reinfuse greater recognition and acknowledgment of previous work and strategic documentation into the revised Framework.

The Low Line concept links existing centres of activity and enterprise by creating new attractive routes alongside rail arches and viaducts and their associated spaces and streets.

The Low Line routes will facilitate economic growth and improve access and permeability along the rail viaducts and will be referenced as policy within the Draft Revised Lambeth Local Plan. 31

60 IN SUMMARY Officers disagree with this statement. Publica is an Creation of a new Overall, we believe this is a poor piece of work by Publica which has not had the award-winning urban design practice who have double page spread effective management needed from Lambeth Council. The lack of appropriate produced a tailored, evidence-led framework of titled ‘Policy Context engagement at the outset has set the foundations for a Framework which is not Waterloo & South Bank’s public streets and spaces – and Partnership reflective of the priorities of the community, which ignores significant existing work highlighting the need for improvements and Working’ referencing already done on developing public realm plans and which fails to address the key investment across the project boundary. locally led bodies issues of ongoing management and maintenance. which have supported, This project has been managed effectively within the managed and scope, resource and budget allocated. delivered public realm improvements (pg. 40- 41).

Stronger emphasis on the importance of robust management and maintenance needs has been updated to the text of Guiding Principle 5. 61 A RENEWED APPROACH Subsequent to receiving this representation, a N/A We propose a way forward which will build on the work already done, mitigate meeting was convened on 20.06.19 with Andrew concerns, and enable widespread buy-in for the Framework. Travers (CEO, London Borough of Lambeth), Nic The first step towards this would be for key stakeholders to meet with you, as the Durston (CEO, SBEG) and Lucy Musgrave (Founding Cabinet Member with responsibility for the Framework, and the Interim Strategic Director, Publica); the subsequent next steps were Director for Sustainable Growth and Opportunity to agree a renewed way of agreed: working which would ensure ongoing engagement, collaboration, and a commitment to partnership working across the existing structures and mechanisms To coordinate a workshop with key community, already in place in the area. business and landowner representatives which will:

We believe it is imperative that the local community is properly and fully involved, − Address the issues raised in your letter and and so propose a further round of engagement, capturing the full range of groups identify matters for clarification / refinement, active in the area, as well as a comprehensive review of the existing proposals and matters for amendment and matters that are out plans that are relevant to the public realm. of scope.

There is significant knowledge and experience available in the South Bank and − Enable a collaborative process to inform the Waterloo area which can support the development of a new, comprehensive and production of public realm Delivery and acceptable version of the Framework. Management and Maintenance Plans. Signatories to your letter will be invited. We advocate for a new period of deep collaboration and engagement, working together with Lambeth Council to recognise the limitations of resource available 32

and to seek ways to address this through local innovation, in order to move forward − The Council to update the Draft PRF considering with delivering truly great and long lasting public realm for the benefit of everyone. the above and publish it online.

#3 62 Waterloo Community Development Group has been the residential community’s No material changes required to the PRF N/A Waterloo planning group for over 45 years. We are a charity with a membership of local Communit residents, and we work closely with businesses and other groups to support the on- y going improvement of the area, particularly when it comes to public realm. Developm ent Group On 1st May we hosted a public meeting to which you were invited, to consider the draft Framework for which you provide the Introduction. The meeting was attended by around 60 people, and the draft Framework was set out briefly by a Lambeth regen officer. 63 The meeting was unanimous in condemnation of virtually all aspects of the draft The council invited stakeholders to provide feedback N/A Framework, particularly its commissioning and consultation, but also its numerous on the Draft PRF via a six-week on-line public factual errors and extraordinary oversights. consultation; the aim being to receive feedback and make improvements. To support the consultation an officer attended the WCDG meeting on 01.05.19 to present, answer questions and receive feedback. It is regrettable that the final agenda was only issued on the day and that the session tended towards hostility. The Head of Service for Waterloo & Streatham phoned and emailed Michael Ball after the event to discuss, but did not receive a response. 64 There is widespread support locally for improvements in public realm across Lambeth has been lobbied locally for several years to N/A Waterloo and the South Bank. However, it is not self-evident why the Council has improve and enhance streets and spaces, and to commissioned a public realm framework at this juncture. deliver improved public realm within Waterloo and South Bank. Before the council can consider allocating resources, robust evidence is required to identify need and begin the process of prioritisation. This is what the Draft PRF does. The PRF will also support the Draft Revised Lambeth Local Plan as evidence. To date, the PRF has been helpful in a number of ways:

• Evidence in support of a funding application to the Mayor’s Pocket Park Plus by BOST for Waterloo Millennium Green, supported by Lambeth Council. (BOST secured £24,520 for planting, staff time and physical improvements to the park). • Informed discussions with H B Reavis and their professional team, helping to shape the public realm proposals for Elizabeth House. • Supported the South Bank Spine Route technical transport survey and public realm design commissions, both of which secured member approval and in train. • Provided stimulus for Lambeth’s commitment to produce a delivery plan and management and maintenance plan. 65 In recent decades Lambeth Council has been happy to support and adopt various During communication and engagement with Creation of a new public realm studies, including SBEG’s Urban Design Strategy (2002), WCDG’s stakeholders, the council and Publica consistently double page spread Improving and Connecting Lower Marsh (2005), the Emma Cons Gardens asked stakeholders to supply relevant strategies, plans titled ‘Policy and masterplan and Stage D design (2006), as well as designs and interventions at and documents to support the emerging Framework’s Partnerships’ – with Westminster Bridge Rd, Jubilee Gardens, Hatfields, The Cut, Archbishops Park, evidence base. A small number were shared by some reference to previous Hercules Rd, Ufford St Rec Ground, and St John’s Churchyard. None of these are stakeholders, with oblique/partial references to strategies and historic even referred to in what is very clearly a Council-focused Framework. historic strategies provided by others. This ‘call out’ documents (pg. 40-41). yielded limited returns and is clearly an area where collaboration could have worked better.

Now 17 years old, the South Bank Urban Design Strategy (published in 2002) identifies eight fundamental goals, which include improving the environment and pedestrian accessibility; decluttering; high quality street furniture and landscaping; encouraging more street level activity; improved management and maintenance of the public realm; and supporting greater interaction between institutions and local people – all of which are reflected in one form or another in the PRF’s guiding principles, spatial briefs and general content.

Despite verbal requests, the Emma Cons Gardens masterplan and Stage D design (2006) was not supplied to Publica or the Council during production of 34

the Framework. The masterplan may retain merit and Lambeth would welcome sight of it. There is the risk, however, that eleven years on the context has changed. The more recent 2013 Waterloo SPD recommends reconfiguring Emma Cons Gardens to create a more attractive gateway to Waterloo and a space suitable for community events – which clearly aligns with the Draft PRF. 66 The draft Framework claims that it is required because Waterloo “is experiencing The Garden Bridge proposal is not material to the N/A significant development and economic growth”. But Waterloo has enjoyed strong scope and content of the PRF. economic and cultural growth for over 20 years, from the development of the Waterloo International Terminal (1995-2007) and the London Eye (2000) onwards. The scope of the PRF did not include lessons learned Public realm and its improvement was always a priority of the £19m SRB investment from previous / historic projects in the area (2000-2007). Economic growth and significant development, and the improvement of public realm, were officially recognised in the original designation of Waterloo as part of Central London and one of London’s first Opportunity Areas in 2002 (in the then draft London Plan).

So why a Lambeth-commissioned public realm framework now? The wretched folly of the Garden Bridge demonstrated the dangers of supporting ad hoc projects not rooted in a wider analysis of the public realm needs: perhaps Lambeth Council now regrets wasting huge amounts of public funding and goodwill locally in pursuing it? Depressingly, there is no mention in the draft Framework of this project – so recently championed by Lambeth Council as of the highest priority – or of the lessons learnt by this miserable debacle. The misguided enthusiasm for the Garden Bridge does not suggest that Lambeth have the capacity for maintaining a strategic approach and protecting Waterloo’s interests in the face of publicity-seeking developers offering baubles at purportedly little public cost. 67 Perhaps the Council has commissioned this Framework now because it has finally Considered and agreed to amend within the PRF. Amended text within recognised the importance of Waterloo to Lambeth Council, including its recent and Executive Summary (as on-going economic growth, which generates 40% of the borough’s business rates below) to reflect income? But this is a perspective only of importance to those whose primary collaboration between interest is Lambeth Council itself. Publica and all the stakeholders of One of the many flaws of the draft Framework is that it reflects and prioritises that Waterloo, including perverse perspective: the report proclaims that it has been developed “through a the Council. close collaboration between Lambeth Council and Publica”, rather than through the more appropriate “close collaboration” between Publica and all the stakeholders of ‘Developed through a Waterloo, including the Council. close collaboration between Lambeth and 35

publica and building on relationship with landowners, stakeholders, potential funders, businesses and residents, this Public Realm Framework aims to…’ 68 For the people of Waterloo – those who live there, work there, study there, play The Public Realm Framework produced by Lambeth N/A there, or pass through there – Lambeth Council’s priorities are simply irrelevant. Council and Publica aims to reflect the complex What matters is meeting the priorities of all of the communities of Waterloo, and interests of all stakeholders whilst setting out over- providing a public realm which is attractive and legible to all stakeholders, and of arching guiding principles that are relevant and the very highest quality (to reflect the complex requirements of the high-volume specific to the area. The PRF also provides key design multiple users), and which therein encourages further investment in the area. guidance in the form of tailored spatial briefs and Improvements and interventions tend to be piecemeal and incremental, which can highlights six priority spaces in need of improvement simply resolve immediate problems or serve only some of the stakeholder and investment. communities (such as the developers who may fund the interventions). For these reasons a public realm framework may be useful, provided it reflects the complex interests of all stakeholders: and provided that its prime purpose is to set over- arching principles relevant and specific to the area, key design guidance, and a flexible hierarchy of priorities. 69 The draft Framework fails to meet these objectives The Council and Publica sought to undertake a N/A it doesn’t reflect upon the complex interests of all stakeholders, because it has collaborative engagement process within the project failed to engage with those stakeholders to understand their perspective and scope, budget and resource which comprised a concerns comprehensive log provided to WCDG within the officer response letter dated 27.08.19.

The Framework aims to reflect the complex interests of all stakeholders and has undertaken this within the following sections: • Local, Metropolitan, Global (pg. 31) • Evening and Night Time (pg. 34-37) • Commercial and Strategic Stakeholders (pg. 39) • Policy Context and Partnership Working (pg. 40- 41) • Local Aspirations (pg. 42-43) • Development Context (pg. 44-45) 70 it doesn’t provide over-arching principles relevant and specific to the area, but The six guiding principles reflect a wide range of N/A proposes rather a list of the most nebulous aspirations (“celebrate and protect opportunities, challenges, issues and constraints identified by local stakeholders throughout the 36

culture, heritage and design excellence”; “maximise the positive impacts of engagement process. They are based on themes development and minimise disruption” etc); identified by Publica as a result of their evidence gathering and engagement.

A rigorous internal process within the council was also undertaken to review, amend and approve the guiding principles at draft stage. This exercise was undertaken at senior management level across multiple service areas, including Area Regeneration, Planning Policy, Design and Conservation, Transport, Highways and Parks.

The focus that the principles place on amenity, accessibility and wellbeing; culture, heritage and design; barriers and legibility; safety and security; maximising development and minimising disruption; and supporting growth are consistent with other strategies and policies 71 it doesn’t provide a flexible hierarchy of priorities, but instead attempts to foist a The spaces that have been identified as priority N/A bizarre list of aspirational projects to the front without sufficient explanation, often projects include Emma Cons Gardens, Concert Hall ignoring the facts and experience of previous attempts to implement similar Approach, Waterloo Bridge Undercrofts, Victory Arch projects. Square, Sandell Street and Jubilee Gardens at Belvedere Road.

Priority sites were selected based on the following criteria:

• They evidence the need for improvement and investment • Their proposals align strongly with the six guiding principles • They reflect local and /or strategic stakeholder aspirations and priorities • The sites are strategic spaces with a broader impact across Waterloo and South Bank

The scope of the PRF did not include lessons learned from previous / historic projects

72 To be specific, the draft Framework: Reviewed and agreed to list and include reference to Creation of a new doesn’t reference any of the frameworks or masterplans agreed over the past 20 many frameworks / masterplans agreed over the past double page spread years 20 years. titled ‘Policy Context and Partnership Working’ referencing previous frameworks / masterplans and stakeholder involvement (pg. 40- 41). 73 barely references any of the local delivery bodies (there’s 44 mentions of Lambeth Reviewed. Relevant stakeholders and delivery bodies N/A Council and 23 mentions of TfL, but no mention of any residents’ associations or have been adequately referenced throughout the friends groups, or even Southwark Council) document – specifically within the following pages: • Evening and Night Time (pg. 34-37) • Commercial and Strategic Stakeholders (pg. 39) • Policy Context and Partnership Working (pg. 40- 41) • Local Aspirations (pg. 42-43) • Development Context (pg. 44-45) • Matrix of Spatial Briefs (pg. 66-67) 74 fails to include the proposed and on-going locally-led public realm improvements – The Draft PRF does not include spatial briefs (detailed Clarifications on live at Bernie Spain Gardens, Lambeth Bridge roundabout, at Lambeth North/Hercules descriptions and recommendations) of ‘live’ projects, projects and their Rd junction, at Belvedere Rd, or the Millennium Green masterplan, or the Waterloo including Bernie Spain Gardens or Waterloo inclusion in the PRF Hub project, or the Lambeth Green masterplan etc Millennium Green masterplan. This was a conscious provided in the decision to avoid cutting across emerging proposals updated Executive and planning processes. The risk of rendering the PRF Summary and out-of-date prior to publication was also a concern. It alongside the is clear that this decision has been perceived as a lack Development Context of regard and support for these projects, which was map. not the intention. Greater clarity should have been provided to avoid this misunderstanding and this will be addressed in an updated PRF. 75 Misrepresents and misunderstands various specific projects - for example at Coral The concept designs for Coral Street are intended as Amendments to spatial St/Millennium Green, or the Jubilee Gardens extension over the HCP, where it high level, indicative and illustrative interventions brief B3 – Belvedere recommends "exploring ways to create a distinction between Jubilee Gardens and only, representing Publica’s recommendations and Road at Jubilee proposals for its extension": these are both wrong (see below) and fail to reflect the professional advice for each site. They are not design Gardens have been specific information provided by JGT and BOST proposals per se. undertaken to update the information and alignment with the Lambeth policy. 38

76 doesn’t mention residents or resident bodies or reflect their views or priorities Ultimately, any designs that come forward for these Further clarity sites will be subject to separate due diligence; in provided throughout which, conversations will be undertaken with document regarding interested parties, as well as dedicated design the purpose and status commissions and statutory public consultation and the of the concept designs. planning process, if required. It is acknowledged that the status of the concept designs could have been made clearer. This will be addressed in the update. 77 Fails to recognise the complexities of piecemeal land ownership and management, Not within PRF scope. N/A or the problems of revenue funding and maintenance of very high use public realm 78 Perhaps worst of all, in drafting the Framework, consultants Publica have failed to The Public Realm Framework has been developed in Creation of a new consider the wider context: the Opportunity Area Planning Framework, the two stages, beginning with the production of the double page spread development pressures, the delicate balance of uses and social needs, the purpose evidence base, which in turn provides the foundation titled ‘Policy Context and impact and design of the buildings sitting in the midst of all this 'public realm' for the strategic component of the Framework. and Partnership (everything that isn't buildings). The draft simply sees the spaces between buildings Working’ referencing in isolation. It demonstrates no understanding of the complex balance of social The evidence base for the Framework was established previous frameworks / relations and needs which all this land is required to serve. In fact the Publica draft through comprehensive fieldwork and research, masterplans and seems obsessed with seeing this public realm as space to pass through, particularly including on-site public realm surveys and data stakeholder as a 'global' or 'metropolitan' user. collection, mapping, policy and other analysis, involvement (pg. 40- photography, and research, as well as a public realm 41). audit of key sites identified through the survey process. Further information on policy documents used to inform the Framework are listed on pages 40- 41 and 60-61.

Different types of users and users have been duly considered and reflected within the ‘Local, Metropolitan, Global’ and ‘Overlapping patterns of Use’ sections. Spatial briefs have been produced that represent a selection of different uses and this is part of the criteria for identifying priority projects.

Reviewing and producing socio-demographic data was not within the scope of the PRF. 79 The consultants have started from the wrong place – a fantasy Year Zero, when they The scope of the PRF did not include lessons learned N/A were commissioned – taking no cognizance of the lessons learned or of the work from previous / historic projects. done previously. For example, a locally-led masterplan and design for Emma Cons Gardens (ECG) was agreed as part of the overall improvements to The Cut and During communication and engagement with Lower Marsh as a key part of the regeneration of the then District shopping centre, stakeholders, the council and Publica consistently and was adopted by LBL in 2008: despite the draft Framework prioritising ECG as a asked stakeholders to supply relevant strategies, plans 39

project, it never mentions the masterplan or the lessons learnt in its creation and and documents to support the emerging Framework’s the failure to deliver this proiect; indeed, Publica act as if they were unaware of the evidence base. A small number were shared by some project, and start again from scratch (but without stakeholder input) on yet again stakeholders, with oblique/partial references to re-designing ECG! historic strategies provided by others. This ‘call out’ yielded limited returns and is clearly an area where collaboration could have worked better.

Despite verbal requests, the locally-led masterplan and design for Emma Cons Gardens (produced in 2008) was not supplied to Publica or the Council during production of the Framework. The masterplan may retain merit and we would welcome sight of it. There is the risk, however, that eleven years on the context has changed. The more recent 2013 Waterloo SPD recommends reconfiguring Emma Cons Gardens to create a more attractive gateway to Waterloo and a space suitable for community events – which clearly aligns with the PRF. 80 From where should a Public Realm Framework for Waterloo start? Comment acknowledged and reflected in revised PRF. Creation of a new It could begin by recognising the unique plethora of locally led bodies which have double page spread delivered public realm improvements and continue to manage parts of the public titled ‘Policy Context realm: and Partnership Working’ referencing • Bankside Open Spaces Trust: owns and manages Millennium Green, Living Space locally led bodies and playgrounds which have supported, • Garden Museum: manages St Mary’s Gardens and environs, progressing managed and improvements to roundabout delivered public realm improvements (pg. 40- • Coin Street Community Builders: owns and manages Bernie Spain Gardens, the 41). riverside walk, Hatfields and Paris Gardens ball courts (through Colombo Centre)

• We Are Waterloo BID: manages Lower Marsh and The Cut, oversaw delivery of Further references improvements within ‘Executive • South Bank Employers Group: delivered and managed Belvedere Rd and other Summary’ section and improvements throughout of key • Southbank Centre: owns and manages riverside walk and spaces across their stakeholders and their estate supportive role within • Waterloo St John’s: owns and manages the Churchyard and spaces around Waterloo and South Bank. • Jubilee Gardens Trust: led the redevelopment, owns and manages the Gardens, leads on the extension

• Waterloo Community Development Group: advocated, designed and implemented the Millennium Green project, and initiated The Cut project, the Connecting & Renewing Lower Marsh project, and the Jubilee Gardens project.

There is widespread and longstanding agreement among these local stakeholders about the complexities and priorities for public space. Together we have produced a pile of frameworks and masterplans and detailed designs for public realm improvements and have delivered many. Together we have continuously assessed the impact and needs of existing and predicted pedestrian movement through the area – in the full cognizance of the specific difficulties of legibility in Waterloo caused by both the huge bend in the river and by the largest single built obstacle in central London, Waterloo Station itself. 81 As well as an audit of existing public realm, any baseline review should consider: The Public Realm Framework was established through N/A Recent public realm improvement projects, including lessons from them a comprehensive evidence base. The scope of the PRF did not include lessons learned from previous / historic projects. 82 Recent public realm analysis/ frameworks/masterplans/designs References to relevant strategies and historic Creation of a new documents have been reviewed following public double page spread consultation comments. Amendments and additions titled ‘Policy Context have been incorporated within the updated PRF. and Partnership Working’ referencing previous frameworks / masterplans (pg. 40- 41). 83 Failed or unimplemented projects, and the reasons for their failure (for example, The scope of the PRF did not include a review of failed N/A the reasons for the failure to progress and implement the agreed Stage D design for or unimplemented projects. Emma Cons Gardens discussed above) 84 Longstanding aspirations for public realm in the area (for example, the Jubilee The extension of Jubilee Gardens is highlighted within Amendments to spatial Gardens extension has been the highest priority for new open space in Waterloo spatial brief B3 – Belvedere Road at Jubilee Gardens brief B3 – Belvedere since at least 1990, when the Hungerford Car Park was first proposed to be (pg. 76). Road at Jubilee designated as Metropolitan Open Land) Gardens have been Proposals to amend elements of this spatial brief have undertaken to update been received during public consultation and have the information and subsequently been incorporated within the alignment with the Framework. Lambeth policy.

The information within this spatial brief has also been Spatial brief B3 – updated with the information agreed for inclusion Belvedere Road at within the Draft Revised Lambeth Local Plan. Jubilee Gardens will be recognised as a priority 41

project; thus, resulting in a total of six priority projects identified within the Public Realm Framework. 85 The built environment around the public realm, its use and function, and its impact The function and impact of the built environment is Additional sub-tactic (f) on public realm (for example, the impact of the Park Plaza and County Hall South highlighted and expressed where relevant within the added to Guiding Block on microclimate and air quality of the open space between those buildings, Framework e.g. Principle 1 – focusing including the recent upgrades to that space) • Context (pg. 17 onwards) on climate change (pg. • Evening and Night Time (pg. 34-37) 49). • Development Context (pg. 44-45) • Matrix of Spatial Briefs (pg. 66-67)

However, the scope of the Framework did not include the explicit review of the use and function of the built environment. 86 Aspirational or approved development projects and their likely impact on public The scope of the Framework did not include the N/A realm (for example, the impact on microclimate and air quality of major explicit review of the use and function of aspirational development along York Rd, as well as the many thousands of additional employees, or approved development projects. residents, shoppers and visitors) Where relevant, regard to future projects have been highlighted / expressed. 87 The capacity of local stakeholders to champion, lead, implement, and/or oversee The Matrix of Spatial Briefs (pages 66-67) lists both key Creation of a new the long-term management of any public realm improvements stakeholders and ongoing or proposed related double page spread developments for each spatial brief. titled ‘Policy Context and Partnership Lambeth acknowledges the often-extensive roles that Working’ to reflect the local groups and partnerships undertake within the continued support and area. provision undertaken by key stakeholders (pg. 40-41). 88 The complex patterns of land ownership and the potential to hinder public realm Emphasising the complex patterns of land ownership N/A improvements and its impact on the public realm is a detailed piece of work that was out of scope of this commission.

Lambeth will communicate this comment to Resident’s Services which may be picked up by the work to develop Delivery and Management and Maintenance Plans for the area.

89 There is virtually no evidence in the draft Framework and its ‘evidence base’ that Within the Framework’s methodology, Publica’s N/A these aspects have been considered at all. Nor is there any evidence in the PRF of baseline review comprised: the local experience of non-locally led public realm changes in Waterloo, including: • Review of existing information • Site surveys The loss of over 1ha of open space over the past 15 years • Publica realm audit • Stakeholder engagement

• Community consultations

Further information is provided within the document itself, particularly the Context section on page 17.

The PRF acknowledges there has been significant growth within previous years, resulting in changes to the local context and environment. 90 The threat and loss of trees and diminished maintenance of public spaces (eg ECG) The provision and creation of green infrastructure is N/A adequately covered within guiding principle 1.

The Framework is strategic guidance and does not set policy, therefore any potential threat of a reduction in trees or other green infrastructure should be navigated as individual sites progress and design and proposed.

Management and maintenance emerged as a key priority for strategic and commercial stakeholders, as communicated through face-to-face meetings in addition to steering groups and strategic partnerships / forums. Publica and Lambeth subsequently chose to dedicate one guiding principle (#5) solely to address this priority – promoting the necessity of management and maintenance plans before public realm designs are confirmed and delivered. This is an important deliverable within Lambeth’s South Bank Spine Route commission and will inform the design and decision- making process.

Other references that portray the challenge and need for maintenance and management of the public realm are provided explicitly within the ‘Executive summary’, ‘Commercial and Strategic Stakeholders’ and ‘Local 43

Aspirations’ sections – in addition to being addressed within Cllr Holland’s Foreword.

The council understands the importance to produce public realm Delivery and Management and Maintenance Plans and is seeking to undertake these as a separate project. 91 The reduction in carriageway and increase in pavement widths to accommodate The PRF is supportive of creating a public realm that is N/A increasing pedestrians... followed by their swift colonization by commercial accessible and inclusive for all. tables/chairs, permitted by Lambeth Many completed and live projects within Waterloo and South Bank have prioritised widening pavements to accommodate increasing pedestrians e.g. Lower Marsh public realm improvements, Waterloo City Hub and South Bank Spine Route public realm design project.

The PRF recommends de-cluttering within some spatial briefs. There needs to be a balance between street clutter and economic support / growth for local businesses. This will be treated on a case by case basis. 92 Improvements presaging increasing land prices, squeezing out of locally useful Not within PRF scope. N/A shops and the influx of coffee shops and chains 93 A steady and relentless increase in traffic since the imposition of congestion Publica acquired and included relevant evidence N/A charging in 2003 within the Framework; however, traffic and movement trends / analysis were not undertaken as part of the baseline. This should be undertaken when individual sites progress to ensure evidence-led detailed designs. 94 Traffic improvements which prioritise (and thereby encourage) the slowing down or Traffic and movement trends / analysis were not Additional sub-tactic (f) gridlocking of traffic (Stamford St, Baylis Rd, WBR) and the subsequent worsening of undertaken as part of the baseline. added to Guiding air quality (air quality isn’t even mentioned in the Framework!?) Principle 1 – focusing Air quality is adequately referenced throughout the on climate change (pg. Framework, with Guiding Principle 1 recommending 49). initiatives to improve air quality. 95 Another starting point for any PRF for Waterloo should be the lessons of 30 years of The Framework aims to reflect the complex interests N/A locally-led delivery of public realm: and needs of all stakeholders and has undertaken this within the following sections: • Local, Metropolitan, Global 44

The inherent complexity of the area and competing interests of stakeholders, and • Overlapping Patterns of Use the need to find solutions which address all those interests – residents, workers, • Evening and Night Time visitors, tourists, commuters, students, shoppers, health facility users, landowners, • Commercial and Strategic Stakeholders major public bodies, major private interests • Policy and Partnerships • Local Aspirations • Development Context 96 The inherent complexity and competing interests of multiple layers of decision- Not within PRF scope. N/A making bodies: two local authorities, TfL, Mayor of London, national government department and agencies (e.g. Arts Council, SRA), as well as landowners, developers and investors 97 The complex layers of land ownership and management Not within PRF scope. N/A

98 The exceptional development pressures reflected in problematic land values Not within PRF scope. N/A

99 The high levels of social exclusion and deprivation in the local residential Not within PRF scope. N/A community, particularly to the south, often masked by the conspicuous wealth in the area 100 The frequent and counter-productive by-passing or alienation of the local The Council and Publica sought to undertake a N/A community from the decision-making process, despite a very organised network of collaborative engagement process within the project activists scope, budget and resource. This included evaluating data / feedback from previous engagement (e.g. Draft Waterloo CLIP, Draft SoWN Neighbourhood Plan)

The council invited stakeholders to provide feedback on the Draft PRF via a six-week on-line public consultation; the aim being to receive feedback and make improvements.

101 The areas where public realm remains poor – largely dominated by spaces where The Framework features a spatial brief for Victory N/A redevelopment has failed to come forward (Victory Square, Royal St, Doon Arch Square (pg. 82), Cornwall Road (pg. 84), in St/Cornwall Rd) or where the very heavy volumes of traffic have taken a heavy toll addition to six spatial briefs along the South Bank Spine Route family of projects (in which the Doon Street site sits).

As the PRF does not include spatial briefs (detailed descriptions and recommendations) of ‘live’ projects, Royal Street has not been featured as a spatial brief. This was a conscious decision to avoid cutting across emerging proposals and planning processes. 102 The so-called ‘Guiding principles’ aren’t cognisant of the very obvious strategic The six guiding principles reflect a wide range of Refinements have priorities for Waterloo underpinning decisions about what should be done with the opportunities, challenges, issues and constraints been made to some public realm. Any Framework should start from at least the following four principles: identified by local stakeholders throughout the guiding principles and engagement process. They are based on themes sub-tactics based on 1. Waterloo needs to grow (to meet the aspirations of the London Plan for a more identified by Publica as a result of their evidence public consultation sustainable capital), and therefore to increase density significantly without losing gathering and engagement. responses. public realm or open space, but aiming to increase them A rigorous internal process within the council was also 2. Waterloo’s sustainable growth needs to maintain the balance of residents, undertaken to review, amend and approve the guiding workers, commuters and visitors in this highly mixed area, such balance being the principles at draft stage. This exercise was undertaken root of its successful regeneration in recent decades at senior management level across multiple service areas, including Area Regeneration, Planning Policy, 3. The public realm is a break from the buildings and their separated uses – it is the Design and Conservation, Transport, Highways and place all stakeholders come together – so it needs to facilitate that mix while Parks. protecting areas which would be damaged from the mix (e.g. residential backstreets) The focus that the principles place on amenity, accessibility and wellbeing; culture, heritage and design; barriers and legibility; safety and security; 4. Solutions work best which work with local knowledge and which are locally- maximising development and minimising disruption; owned, particularly given the demands of on-going management and maintenance. and supporting growth are consistent with other

strategies and policies, specifically aligning with the following:

Lambeth Local Plan (2015) • Section 3: Strategic Objectives focuses on promoting community cohesion and safe, liveable places whilst creating and maintaining attractive, distinct places.

• Supports better accessibility, legibility and the prioritisation of walking and cycling within policies T1 Sustainable Travel, T2 Walking and T3 Cycling. • Encourages new and improved civic amenity and green infrastructure through policy EN1 Open Space & Biodiversity. • Policy EN4 Sustainable Design & Construction promotes high standards of sustainable design, encouraging proposals of non-residential developments to include a maintenance plan. • Policy Q3 Community Safety endorses designing- out crime within the public realm. • Policy Q5 Local Distinctiveness emphasises the preservation and reinforcement of cultural and historical places. • Policies Q6 Urban Design and Q7 Urban Design: New Development supports attractive, uncluttered, coordinated public realm that enhances the setting of and spaces between buildings whilst improving legibility and movement, reducing barriers; providing new / enhanced open space, robust street furniture, permeable paving and a high quality public realm that is built of durable, robust, low-maintenance materials that is both flexible and adaptable. • Both policies Q9 Westminster World Heritage Site and Q20 Statutory Listed Buildings celebrate and protect culture, heritage and local character.

The four principles referred to within your letter are reflected in the Draft PRF’s guiding principles: 1. Meeting aspirations for a more sustainable capital; protecting an increasing public realm and open space – see Draft PRF guiding principles 1 and 6. 2. Maintaining the balance of users within the context of sustainable growth - see Draft PRF guiding principles 1, 2, 3, 4, 5 and 6. 3. Ensuring inclusivity of spaces for all stakeholders – facilitating a mix whilst protecting vulnerable areas i.e. residential back streets - see Draft PRF guiding principles 1, 3 and 5. 4. Management and maintenance solutions – see Draft PRF guiding principle 5. 103 The poor work and negligible consultation undertaken by consultants Publica have Officers disagree that the PRF project approach was N/A at least brought unanimity among local stakeholders that their approach was ‘inappropriate’. thoroughly inappropriate. I believe that there is a determination amongst us all to work in collaboration with Lambeth to get this Public Realm Framework right – and I The Council and Publica sought to undertake a look forward to working with you on this. collaborative engagement process within the project 48

scope, budget and resource which comprised a comprehensive log provided to WCDG within the officer response letter dated 27.08.19. #4 104 With regret I have to report that BOST, like every community-based organisation The Council fully supports Waterloo Millennium Green Spatial brief D1 now Bankside involved at Waterloo and South Bank have been very unhappy and proposals. The PRF does not include spatial briefs includes drawings of Open disappointed following the publication of the Waterloo and South Bank Public (detailed descriptions and recommendations) of ‘live’ the masterplan Spaces Realm Framework Report. I am sending this response to ward Councillors as well, projects, including Waterloo Millennium Green proposals for the Trust who have sadly been disengaged from the process. masterplan. This was a conscious decision to avoid Millennium Green and cutting across emerging proposals and planning there is a direct I have tried to issue a response via the survey monkey form online, but the format processes. The risk of rendering the PRF out-of-date mention of the given is very inflexible and does not give enough scope to properly detail the prior to publication was also a concern. It is clear that proposals in relation to concerns we have. Therefore, please accept this as BOST's submission. this decision has been perceived as a lack of regard the Coral Street brief. and support for this project, which was not the Our complete response is as follows. Our comments are also included in a intention. Greater clarity should have been provided Clarifications on live joint response being made imminently by SBEG on behalf of a number of key to avoid this misunderstanding and this is addressed in projects and their stakeholders in Waterloo and Southbank. the updated PRF. inclusion in the PRF are provided in the BOST's RESPONSE TO CONSULTATION ON THE SOUTH BANK AND WATERLOO The PRF is not a delivery plan and does not seek to updated Executive PUBLIC REALM FRAMEWORK AS PUBLISHED FOR CONSULTATION IN MARCH 2019 allocate funding to projects. Summary and alongside the Bankside Open Spaces Trust welcomes the opportunity to comment on the Development Context Southbank and Waterloo Public Realm Framework. map.

Whilst BOST is pleased to see a move to invest in the public realm of the area and to A new section has have been consulted on some of the issues, BOST was disappointed to see so many been created titled of our points raised (many on behalf of local residents and members of our ‘Policy Context and Waterloo Green and Living Space steering group) not addressed within the Partnership Working’ document. In particular: (pg. 40-41) which highlights the The redevelopment of Waterloo Green, which BOST has been working on with masterplan proposals Lambeth Council (indeed Lambeth Council sat on our interview panel when for the Millennium tendering for consultants) was only mentioned in passing. Green.

There is no support given for the regeneration of the Green proposals which seems bizarre considering the deep involvement of Lambeth Council, and our previous meetings when Lambeth Council agreed to seek funding for the masterplan phases. 105 There is nothing about BOST's overall vision to redevelop the green and living space The PRF does not include spatial briefs (detailed Clarifications on live to create a sustainable community orientated hub. The evidence of the need for this descriptions and recommendations) of ‘live’ projects, projects and their Community facility has now been demonstrated beyond doubt. including Waterloo Millennium Green masterplan. This inclusion in the PRF was a conscious decision to avoid cutting across provided in the 49

emerging proposals and planning processes. The risk updated Executive of rendering the PRF out-of-date prior to publication Summary and was also a concern. It is clear that this decision has alongside the been perceived as a lack of regard and support for Development Context these projects, which was not the intention. Greater map. clarity should have been provided to avoid this misunderstanding and this will be addressed in an updated PRF. 106 The report categorizes the Green as a space for Metropolitan Users ignoring the The Space Typologies map shows the Millennium N/A local users. Green in a green colour. This colour identifies metropolitan/local spaces (see map key), in recognition of its important role for both type of users. 107 Disappointingly, Waterloo Green is not in the 18 projects, despite BOST providing The PRF does not include spatial briefs (detailed Clarifications on live ample proof that the Green is an intrinsic part of the public realm. Our gate descriptions and recommendations) of ‘live’ projects, projects and their counters last summers recorded over 170,000 visitors over a two-month period. including Waterloo Millennium Green masterplan. This inclusion in the PRF was a conscious decision to avoid cutting across provided in the emerging proposals and planning processes. The risk updated Executive of rendering the PRF out-of-date prior to publication Summary and was also a concern. It is clear that this decision has alongside the been perceived as a lack of regard and support for this Development Context project, which was not the intention. Greater clarity map. should have been provided to avoid this misunderstanding and this will be addressed in an updated PRF. 108 It is extraordinary and of great concern that on p.63 BOST is not mentioned in This was an oversight and has been corrected in the BOST has been added regard to the Waterloo Millennium Green ongoing project, despite BOST holding a updated version of the document. to the list of key 999-year lease of the Green. stakeholders for the Waterloo Millennium Green project. 109 BOST supports the creation of a pedestrian or shared surface of Coral St, however: The illustrative concept design for Coral Street The second paragraph represents an aspirational project and is not a design of spatial brief D1 has 1. There has clearly been no consultation with Tanswell Estate or the pub and as proposal for implementation. Coral Street has been been updated to stress such this 'top down' introduction of what looks like a worked up designed idea chosen as an example of how the guiding principles the need to pay due is woeful. can be translated into a potential design solution by consideration to 2. Although a good idea this is likely to antagonise locals who park their cars here considering the specific context. authorised and and have their rubbish removed and pub serviced. essential access needs 3. The proposal is not thought through and has little chance of being realised in its For these reasons the illustrations are not technical on Coral Street. present incarnation. drawing but rather high-level visualisations showing ways in which the street could be transformed into a 50

4. BOST queries why this project has been worked up to such a degree if it is space that can bring additional benefits to the local aspirational. It appears a waste of resource and money. community.

Any proposals coming forward for this space will need to ensure that the operational requirements of Coral Street are considered and any changes to those are agreed with the users and stakeholders of the street. 110 The Emma Cons project description does not take into consideration all the Within spatial brief C6 – Emma Cons Gardens, it states N/A different schemes and ideas that have been put forward before, ignoring the work ‘In coordination with adjacent traffic schemes, that invested Community groups have produced. Although there is a crossing point investigate long-term options to rationalise the to the Green mentioned here, there is no real relationship to the Green itself which junction with Waterloo Road to remove stopping is a lost opportunity. traffic from the front of The Old Vic and reduce crossing times. Consider holding traffic back to The Cut or making it one-way and introducing a diagonal crossing to better connect Emma Cons Gardens to the proposed entrance of Waterloo Millennium Green.’ This is also reflected on pg. 111 within the ‘Emma Cons - Example Project’.

In addition, ‘Explore options to consolidate wayfinding features and integrate directions to key local destinations into the public realm’. This would also help connect the Green with Emma Cons, complementing any physical intervention. 111 Regarding Hatfields, clearly the consultants have not spoken to Hatfield The purpose of undertaking a six-week public N/A stakeholders who are still dismayed over the process and the resulting consultation was to enable the council to ensure a refurbishment of the open space. The Framework report here reveals a wider, more robust consultation – seeking views from further inadequate approach to the task in hand. residents, businesses, community and third sector organisations, landowners and others.

Ultimately, any designs that come forward for individual sites will be subject to separate due diligence; in which, conversations will be undertaken with interested parties, as well as dedicated evidence gathering, design commissions, statutory public consultation and the planning process, if required. 112 Regarding the work already undertaken by Coin Street Community Builders, as one A number of organisations that have a continued and Updated content of CSCB's partners on the Bernie Spain Gardens project, BOST was disappointed to active involvement in the Waterloo and South Bank within the Executive see that the work already undertaken there has been entirely discounted. area are progressing live projects within Bishop’s Summary to reflect ward, including Coin Street Community Builders this. 51

reimagining of Bernie Spain Gardens and Bankside Open Spaces Trust’s masterplanning of Waterloo Millennium Green. Given the live status of these and similar initiatives, this Framework avoids delineating them in detail to evade cutting across emerging designs, plans and proposals or to pre-empt the planning process.

This approach applies to Council sponsored initiatives, such as the transport infrastructure and public realm improvements being developed by TfL as part of the Waterloo City Hub scheme. These ongoing projects are supported and recognised as a priority within the area due to their ambition to upgrade important streets and open spaces and unify disjointed areas of public realm. 113 BOST was alarmed to hear that neither SoWN of St Johns Church were not The Council and Publica sought to undertake a N/A consulted. This is a grave omission and undermines the legitimacy of the report. collaborative engagement process within the project scope, budget and resource.

The project team aimed to have as many face-to-face meetings with strategic / commercial stakeholders as possible. As a result, 17 organisations were accommodated. Both Canon Giles Goddard from St John’s and Ben Stephenson, Secretary of SoWN attended.

Stakeholders were asked within the invitation and the meeting itself to submit any evidence to support the Framework and provide additional feedback to the team about their aspirations, plans and recommendations.

representatives of SoWN attended and had a focused discussion with the project team for over 30 minutes.

In future we will advertise sessions more widely and further in advance and try to make provision for ‘offline’ communications.

The purpose of undertaking a six-week public consultation was to enable the council to ensure a wider, more robust consultation – seeking views from residents, businesses, community and third sector organisations, landowners and others. 114 BOST queries why, when there has been so much work undertaken previously by An editorial judgement call was made to remove many Creation of a new the many organisations in the area, that a thorough desktop study of these local historic strategy references, which have been double page spread initiatives was not the first step in compiling the report. Had it have been, the study reviewed and have informed the PRF, from an earlier titled ‘Policy Context would have begun on a much firmer footing. The emerging Neighbourhood Plan for draft to keep the document to a manageable length. and Partnership instance, appears to have been entirely ignored. On reflection, we will seek to provide greater Working’ – with recognition and acknowledgment of previous work in reference to previous an updated Framework. strategies and historic documents (pg. 40-41). The PRF guiding principles reflect the existing priorities set out within SoWN’s Draft neighbourhood plan, for example: • Green infrastructure, open space & air quality are reflected in Principle 1 with more detailed air quality actions outlined within Lambeth Air Quality Action Plan (2017 to 2022). • Social infrastructure and culture are reflected in Principle 2. • Development and management are considered in Principles 5 and 6. 115 BOST is aware that there have been numerous other responses to the report which No material changes required to the PRF N/A echo our own concerns and trust that Lambeth Council will recognise the overwhelming opposition to the proposals as drafted. Like the many other stakeholders in the area, BOST is keen to work alongside Lambeth Council to ensure that a sustainable public realm can be created in which all stakeholders can take pride. Transport 116 London Plan team comments Comment acknowledged and incorporated within the Healthy Streets Wheel for London revised PRF. image added to pg. 41.

Introduction, General - Reference should be made to the Healthy Streets Approach The Wheel also has a and Healthy Streets Wheel (see Appendix A below) in the introduction of this reference within the document. This will embed the Healthy Streets Approach into the Waterloo and Sandell Street – project South Bank public realm framework and will also enable active travel and public underway section (pg. transport to become the primary way to travel. The Healthy Streets Approach could 127). also be referenced more throughout the document. Healthy Street approach referenced within the newly created ‘Policy Context and Partnership Working’ section (pg. 40-41), ‘Relationship with Policy Context’ double page spread (pg. 60-61). 117 Introduction, General - No reference has been made to Vision Zero. Reference to Comment acknowledged and incorporated within the Vision Zero is Vision Zero strategy would support references to strategic improvements to safety revised PRF. referenced within the throughout the document. newly created ‘Policy Context and Partnership Working’ section (pg. 40-41), 118 Introduction – Guiding Principles, P.7 - Reference could be made for the need to Comment noted and addressed in the updated Text of guiding support ‘Good Growth’ in the 6th Guiding Principle. Text could be amended to read: version of the PRF. principle 6 amended as ‘Design and plan for an environment with the capacity to support good future suggested in the growth’ comment with specific reference to good growth. 119 Evening and Night time – Transport, P.36 - The Council should with partners to Comment noted and addressed in the updated The Transport support and manage a thriving and safe night time economy that is well-served by version of the PRF. paragraph of the safe and convenient sustainable night-time transport. Text should emphasise how Evening and Night night-time public transport will be safe, secure and well signposted, in order to Time section (pg. 34- make public transport and active travel modes the prominent way to travel in the 37) has been updated evening. and reads: “The level of footfall at night around Waterloo station has also increased since the arrival of the night tube on the Jubilee line 54

in 2016. The need for signposting to transport connections at night is particularly important.” 120 Guiding Principles 6, P.57 - Guiding principles could also reference the need to As public realm designs come forward, Lambeth N/A reduce the amount of on street parking. This could be amended to read: ‘Review intends to review the current parking provision and waiting and loading arrangements to ensure efficient use of road space and, assess opportunities for rationalising it. Interventions wherever possible, reduce the availability of on street parking and relocate parking could include the removal/conversion of parking / loading places from main roads to side roads.’ Parked cars represent a poor use of spaces. public space, with the potential for green infrastructure, parklets and cycle parking to be more efficient and worthwhile uses of the public realm. As per guiding principle 1, this encourages the creation and improvement of amenity spaces green infrastructure. 121 Guiding Principles 6, P.57 - Deliver developments using a high-quality construction Comment acknowledged, the PRF has been updated Principle 6, sub-tactic management plan with regard to reducing interruptions and minimising to support pedestrian safety. e. amended to read: construction traffic.’ Text could be amended to state that clear, safe and segregated ‘Deliver developments walking and cycle routes at all times during construction. Appropriate levels of cycle using a high-quality parking should be provided during construction. construction management plan with regard to reducing interruptions and minimising construction traffic and safeguarding pedestrians.’ 122 Upper Ground at on Street, P.75 - Reference should be made to provide good Comment acknowledged, the PRF has been updated Upper Ground and quality cycle parking where necessary. This should be in line with guidance set out in accordingly. Coin Street last bullet London’s Cycle Design Guidance. Text could be amended to read ‘Explore options to point reads: “Explore clearly indicate National Cycle Route 4 and provide good quality cycle parking options to clearly where necessary.’ NB the requirement for ‘Good quality cycle parking’ should be indicate National Cycle referenced every time cycle parking is mentioned in the document. Route 4 and provide good quality cycle parking where demand dictates.” 123 Victory Arch Square and Mepham Street, P.78 – We support the reduction of on As public realm designs come forward, Lambeth N/A street parking bays wherever possible. Parked cars represent a poor use of public intends to review the current parking provision and space, with the potential for green infrastructure, parklets and cycle parking to be assess opportunities for rationalising it. Interventions more efficient and worthwhile uses of the public realm. Text could be amended to could include the conversion of parking spaces.

read ‘In coordination with adjacent traffic schemes, explore options to rationalise As per guiding principle 1, this encourages the creation convert on street parking to more efficient uses of public realm…’ and improvement of amenity spaces green infrastructure. 124 Southwark Station Connection, P.82 – We support the reduction of on street parking As public realm designs come forward, Lambeth N/A bays wherever possible. Parked cars represent a poor use of public space, with the intends to review the current parking provision and potential for green infrastructure, parklets and cycle parking to be more efficient assess opportunities for rationalising it. Interventions and worthwhile uses of the public realm. Text could be amended to read ‘Consider could include the conversion of parking spaces. rationalisation the conversion of on street parking bays to more efficient uses of public realm…’ As per guiding principle 1, this encourages the creation and improvement of amenity spaces green infrastructure. 125 Hatfields, P.83 – We support the reduction of in street parking bays wherever As public realm designs come forward, Lambeth N/A possible. Parked cars represent a poor use of public space, with the potential for intends to review the current parking provision and green infrastructure, parklets and cycle parking to be more efficient and worthwhile assess opportunities for rationalising it. Interventions uses of the public realm. Text could be amended to read ‘Explore options to widen could include the conversion of parking spaces. pavements, rationalise convert on-street parking, reduce street clutter…’ As per guiding principle 1, this encourages the creation and improvement of amenity spaces green infrastructure. 126 Cab Road and Spur Road, P.86 - Taxi ranks should be located away from the main The PRF adequately covers designing options to Added text within entrance of stations to ensure active and sustainable modes are prioritised and the support pedestrians and cyclists within spatial brief C7 spatial brief C7 – Cab most convenient way to travel. They should also be designed so they do not cause – Cab Road and Spur Road as non-statutory guidance. Road and Spur Road: severance for people walking, cycling and using public transport. The PRF has been updated to strengthen air quality • Explore all and sustainable transport modes. opportunity to improve air quality. Encourage the reduction of stationary and / or idling vehicles. Consider employing initiatives to support and increase the number and priority of electric vehicles. 127 Green and Open Spaces within Estates, P.93 - We support the reduction of on street As public realm designs come forward, Lambeth N/A parking bays wherever possible. Parked cars represent a poor use of public space, intends to review the current parking provision and with the potential for green infrastructure, parklets and cycle parking to be more assess opportunities for rationalising it. Interventions efficient and worthwhile uses of the public realm. Text could be amended to read could include the conversion of parking spaces.

‘Consider rationalisation the conversion of on street parking bays to more efficient As per guiding principle 1, this encourages the creation uses of public realm …’ and improvement of amenity spaces green infrastructure. 128 Sandell Street, P.123 - ‘Deliver a range of improvements based on the Healthy Comment acknowledged, the PRF has been updated Sandell Street – Project Streets Matrix Wheel’ (See Appendix A below) accordingly. Underway (pg. 127) now reads: ‘Deliver a range of improvements based on the Healthy Streets Wheel’ 129 Sandell Street, P.123 - We encourage taxi ranks and coach parking to be located Some Sandell Street stakeholders i.e. Union Jack Club N/A away from the main entrance of stations and venues to ensure active and have identified key accessibility needs for customers / sustainable modes are prioritised and the most convenient way to travel. Text could patrons. be amended to read ‘Create a defined drop-off space for taxis and coaches away from the main entrance of stations to ensure active and sustainable modes are Concept designs of Sandell Street have therefore prioritised and the most convenient way to travel.’ identified and incorporated defined drop-off space for taxis and coaches to serve local needs. 130 Surface team comments Comment acknowledged, the PRF has been updated All text referring to accordingly. shared spaces in the Please find below comments from TfL in respect of the consultation draft Waterloo document has been and South Bank Public Realm Framework. I apologise for not using the prescribed amended in line with format, but given the detailed nature of the comments I though best to set out in an the current DfT email. I understand a separate response from TfL Commercial Development may directions. be submitted, focussing on TfL property interests. The comments below focus on transport policy and operational aspects, and interface with the Waterloo City Hub (WCH) scheme.

a) Comments from TfL Surface

There are some proposals in this consultation draft that raise a significant concern, particularly for TfL Buses.

The report follows what we have seen elsewhere from Publica in London focussed on walking and cycling and advocating shared spaces. No mention is made of the current DfT review of shared spaces (note the recent announcement that Exhibition Road in RBK&C will be remodelled).

131 The 6 objectives in the report are understood, and whilst Healthy Streets is Comment acknowledged. The following mentioned, Healthy Streets also includes Public Transport – noting that a large amendments have now proportion of walking trips are in association with Public Transport. However, there been incorporated into is no mention explicitly to the Mayor’s Transport Strategy (MTS) adopted in 2018, the PRF: 57

and policies for Good Growth, Healthy Streets (including Public Transport) and - Reference to Vision Zero. Mayor's transport strategy, Healthy Streets and Vision Zero action plan. - ‘Good growth’ wording added to guiding principle 6. 132 The draft mentions there has been stakeholder engagement, but this is not detailed The Council and Publica sought to undertake a N/A and it is unclear whether TfL as both a Highway Authority, Signalling Authority, collaborative engagement process within the project Public Transport Planning Authority, Taxi regulator, Cycle Hire operator and as a scope, budget and resource. funder through the Local Implementation Plan (LIP) has been consulted specifically. The project team aimed to have as many face-to-face meetings with strategic / commercial stakeholders as possible. As a result, 17 organisations were accommodated – in which St John’s attended. The project team asked each stakeholder within the invitation and the meeting itself to submit any evidence to support the Framework and provide additional feedback to the team about their aspirations, plans and recommendations.

Ultimately, as individual projects are brought forward for design, they will be subject to separate due 58

diligence; in which, conversations will be undertaken with interested parties, as well as liaison with key TfL teams, dedicated evidence gathering, design commissions, statutory public consultation and the planning process, if required. 133 There is very little mentioned throughout the draft on Freight, the potential of River Comments acknowledged. Reference to Policy 23 modes, or Taxis. As a major interchange with retail, the lack of any consideration of of the Mayor’s freight (both through freight and local servicing, including major land uses such as St Guiding principle 5, sub tactic f) states ‘Consider the Transport Strategy has Thomas’s Hospital), should be addressed. Enforcement is not mentioned or Street operational requirements and opportunities for freight been highlighted on Cleaning, both of which are ongoing revenue costs to be addressed. Feature Lighting and servicing consolidation within all future detailed page 61. is mentioned in locations such as Concert Hall Approach, but not the maintenance designs.’ costs associated with it which are often higher because this is non-standard. Maintenance costs will need to be identified and considered when individual projects come forward for design. Guiding principle 5 encourages management and maintenance of the public realm. 134 There is little in detail on cycling and no mention of cycle freight or Cycle Hire. Support for the prioritisation of walking and cycling is N/A adequately referenced within the PRF, particularly within the following guiding principles and Spine Route related spatial briefs below: • Guiding principle #1, tactic b) • Guiding principle #3, tactics b) and d) • Guiding principle #6, tactics a) • Spatial briefs: - B1 – Belvedere Road at County Hall - B3 – Belvedere Road at Jubilee Gardens - B5 – Waterloo Bridge Undercrofts B6 – Upper Ground at Coin Street

Guiding principle 5, sub tactic f) states ‘Consider the operational requirements and opportunities for freight and servicing consolidation within all future detailed designs.’ 135 Aside from photographs there is little evidence base in the draft in terms of existing An analysis of the current and future performance for N/A network performance for all modes, or estimated future performance. Some detail all modes, identification of pedestrian pinch points on pedestrian pinchpoints and collision hotspots would help. It is not though an and collision hotspots are not part of the scope of the overall Transport Study. PRF.

Any designs that come forward will be subject to separate due diligence; in which, further analysis will 59

be carried out, conversations will be undertaken with interested parties, as well as dedicated design commissions and statutory public consultation and the planning process, if required. 136 There are several references throughout the draft to hostile vehicle mitigation No material changes required to the PRF – funding / N/A (HVM) (understandably), but no mention of Government Guidance that these resource allocation is not within the scope of the measures should be funded by the user (frontager) in question and not from the Framework. public purse; this includes LIP funding. 137 The draft refers to regeneration and intensification in the area, but does not Although there may be a potential rise in the number N/A mention increasing working from home initiatives by several major local employers. of people working from home going forward, the PRF is not an economic strategy, but a Framework to identify streets and spaces for improvement and investment across Waterloo and South Bank.

Increasing use / movement projections may be addressed as individual projects are brought forward for detailed design, due diligence and potential movement / traffic evidence and analysis. 138 We are surprised that there is little mention of the Waterloo City Hub scheme in Comments acknowledged. Clarifications on live much detail, and particularly surprised that no Lessons Learned have been raised projects and their from previous schemes in the area – the condition of carriageway raised tables in The PRF does not include spatial briefs (detailed inclusion in the PRF The Cut is very poor to the point that conditions for walking across the road or descriptions and recommendations) of ‘live’ projects, provided in the cycling in the road is putting uses at risk of a trip or fall. Emma Cons Gardens has including Waterloo City Hub. This was a conscious updated Executive had an improvement scheme delivered within the last 10 years. decision to avoid cutting across emerging proposals Summary and and planning processes. The risk of rendering the PRF alongside the out-of-date prior to publication was also a concern. It Development Context is clear that this decision has been perceived as a lack map. of regard and support for these projects, which was not the intention. Greater clarity should have been provided to avoid this misunderstanding and this will be addressed in an updated PRF.

except for a brief mention of SUDS and planting more trees in abstract terms, with As projects are individually progressed, detailed design Principle 1 in relation no consideration of practical considerations that influence whether this is successful should take onboard PRF guiding principles to create to the delivery of a or not. sustainable streets and spaces that align with multiple robust climate change levels of policy. response.

EVs have been referenced in the spatial briefs recommendations. 140 There is no mention of the MTS’s 95% mode share for walking, cycling and Public Comments acknowledged. Policies of the Mayor’s Transport in this part of central London, or commitment in the Vision Zero Action Transport Strategy Plan to reducing speed limits on the TLRN (York Road, Stamford Street has already have been highlighted been done – with Lambeth Palace Road proposed). It is important to note that taxis on page 61 within the and coaches are not part of the 95% mode share target. Also, car clubs should not PRF – including Policy be promoted in the CAZ, as per draft London Plan policy. 23 (Mode shift, safe attractive environment, reduce carbon emissions, opening travel to all).

Reference to the Vision Zero action plan has been added to the PRF on page 40. 141 Use of the City Planner Tool would be helpful to set out a context of the area. Evidence of this level was out of the PRF’s scope. N/A Further evidence should be undertaken for specific sites as individual projects progress for further detailed design. 142 It is though with Buses where we find this draft most deficient. Page 57 does Lambeth Council is working in partnership with TfL on N/A mention the need to improve bus infrastructure which appears to be an the Waterloo City Hub scheme. The proposals for this afterthought as no detail is subsequently provided. The role of Night Buses is scheme include wider footpaths on Waterloo Road to mentioned in Waterloo Road as being important when the tube closes (pg 36) but it improve pedestrians’ and bus passengers’ is very surprising that the role of Buses during the day is not mentioned, particularly environment. how busy Waterloo Road is as a bus interchange. Waterloo Road really needs wider footways for the large numbers of waiting bus passengers in the AM peak period, perhaps enabled by making the road buses, cycles and taxis only 7am-7pm? 143 The operational requirements for Buses is unfortunately not considered at all. The The PRF does not include detailed design proposals, N/A proposals have an adverse impact on bus operations without these being mitigated. but rather guiding principles and recommendations Proposals to pedestrianise Concert Hall Approach mention relocation of the Route for specific sites. 77 stand, but do not detail to where (or what the impact on peak vehicle 61

requirement, and revenue this would involve). Cornwall Road bus garage is not The concept designs in the report are intended as high mentioned at all. Both Sandell Street and The Cut are needed as part of the run- level, indicative and illustrative interventions only, in/out of this bus garage. A redesign of Sandell Street needs to consider the swept representing Publica’s recommendations and path of buses and need for an alighting stop. We have never seen a Coach use professional advice for each site. They are not design Sandell Street, so we don’t understand why it is considered here. The remodelling of proposals per se. the junction of The Cut/Waterloo Road to offset stoplines (further back in The Cut and Cornwall Road) will result in long inter-greens in the signal method of control Any designs that come forward will be subject to that are unlikely to be a practical proposal. Proposals to improve the pedestrian separate due diligence; in which, conversations will be experience of the Cab Road need to acknowledge this is owned by Network Rail, and undertaken with interested parties, as well as whilst taxis are mentioned, the 2 bus routes that use it are not. dedicated design commissions and statutory public consultation and the planning process, if required.

Within spatial brief C3 – Sandell Street, adequate reference is given to allowing access to service vehicles and / or buses, and ensures consideration for all current transport needs. 144 Finally, there is no mention of details of specific traffic reduction measures, or As individual projects progress, a more detailed N/A initiatives such as car clubs, and whilst more efficient traffic signals (pg 57) is overview / assessment of the specific space will be understood, we would not want this to encourage more traffic in this part of Central required including due diligence and potential London. movement / traffic analysis and flows.

Guiding Principle 1 and other policy references promote sustainable transport modes, specifically walking and cycling. 145 b) Comments from Waterloo City Hub (WCH) project team Comments acknowledged. N/A

Family: Belvedere and Upper Ground / Future project: B5 - Waterloo Bridge Upper Ground, Belvedere Road and its connections Undercroft. The area extent of this future project is unclear as that particular are being progressed as a part of the South Bank Spine portion of the site works on two different levels (the bridge level and Belvedere Route public realm project – to ensure the Road/Upper Ground level). The document seems to only refer to the lower level and improvement and investment in these streets and does not mention the key connections to the bridge at the higher level nor the two spaces. The Ground level (under the bridge) is vehicular ramps located at either side of the bridge connecting these levels (this is included within this project scope. also apparent on the map on page 58). Also, when talking about the undercroft space it refers to the portion of street space underneath the bridge most of the For more information on the Undercroft spaces, times and only in the spatial brief it refers to the storage spaces to be refurbished please contact [email protected] for more and activated in the undercroft. Finally, there is no mention of the new link through information. the undecroft spaces and Belevedere Road/Upper Ground which is going to be introduced as part of the WCH scheme. The undercroft section of the spatial brief The PRF does not include spatial briefs (detailed should be expanded to talk about this key new connection and that an additional descriptions and recommendations) of ‘live’ projects, spatial brief should be developed for the higher level. The bullet point on page 74 including Waterloo City Hub. This was a conscious 62

about pedestrian routes from the IMAX at all levels and the consolidation of the decision to avoid cutting across emerging proposals ramp and stair network is unclear. and planning processes. The risk of rendering the PRF out-of-date prior to publication was also a concern. It is clear that this decision has been perceived as a lack of regard and support for these projects, which was not the intention. Greater clarity should have been provided to avoid this misunderstanding and this will be addressed in an updated PRF.

Lambeth Council is working with TfL as a key partner within the Waterloo City Hub scheme as a separate project. The Council has provided further design recommendations and due diligence directly to TfL. Please contact Lambeth’s WCH project manager for more information. 146 Family: Station Approaches. Future project: C1 – Victory Arch Square and Mepham Whilst spatial brief C1 does not specifically mention N/A Street. In the matrix table there is a specific mention of hard landscaping and no soft landscaping, proposals are expected to come soft landscaping is suggested for this site, despite the local aspirations map on page forward during detailed design that reflect the guiding 42 highlighting greening and trees for that location. principles, including #1; encouraging the provision of green infrastructure, along with more detailed sub- The penultimate bullet point on page 78 could be more specific about looking at the tactics. width of the pavement on the viaduct side and maximise its width if possible. Creating a footpath towards Waterloo Station could be more of a long term goal as Comment acknowledged. part of Waterloo Station development. 147 Concert Hall Approach – Illustrative concept design (p. 99). The use of the term Comment on shared spaces acknowledged, the PRF All text referring to shared space is controversial at the moment and the DfT has put a ‘pause’ on the has been updated accordingly. shared spaces in the implementation of shared spaces (as mentioned in section a) above). The example document has been on page 103 of Bond Street new Town Square with low kerbs and a continuous The concept designs in the report are intended as high amended in line with paving treatment throughout the street section might be a more suitable design level, indicative and illustrative interventions only, the current DfT solution to promote. representing Publica’s recommendations and directions. Emma Cons Gardens – Spatial brief and Illustrative concept design. In the spatial professional advice for each site. They are not design brief on page 84 there should be a mention of all the desire lines across the space, proposals per se. including diagonal desire lines from The Cut to Waterloo Station and from Cornwall Road to Lower Marsh. These diagonal desire lines are not catered for in the Any designs that come forward will be subject to illustrative concept design (p.107), the planter shapes could be relooked at to separate due diligence; in which, conversations will be accommodate those desire lines. The spatial brief mentions opportunities to undertaken with interested parties, as well as provide adequate cycle parking at a strategic location but no cycle parking is dedicated design commissions and statutory public identified in the illustrative concept design. consultation and the planning process, if required. 148 Principals for Concert Hall Approach compliment the WCH scheme, however the Comment acknowledged. N/A proposals would also encourage much higher cycle use on this road, and we don’t 63

believe the current design considered a significant uplift in cycles on this road –it The concept design for Concert Hall Approach is would be good to discuss the proposals in detail to see if there are any safety intended as high level, indicative and illustrative conflicts arising from this. interventions only, representing Publica’s recommendations and professional advice for each site. They are not design proposals per se.

Any designs that come forward will be subject to separate due diligence; in which, conversations will be undertaken with interested parties, as well as dedicated design commissions and statutory public consultation and the planning process, if required. 149 The lighting proposals for Waterloo Bridge Undercroft may not align with the Any designs that come forward will be subject to N/A changes we are making on the lower ground IMAX. separate due diligence; in which, conversations will be undertaken with interested parties, as well as dedicated design commissions and statutory public consultation and the planning process, if required. 150 Pedestrian and cycling priority on Mepham Street will conflict with the bus Any designs that come forward will be subject to N/A arrangements currently there – TfL buses will need to be consulted. separate due diligence; in which, conversations will be undertaken with interested parties, as well as dedicated design commissions and statutory public consultation and the planning process, if required. 151 Cornwall Road proposals may be a duplication of another piece of work we have Comment acknowledged. N/A been working on - it would be good to discuss what the timelines for this are and the potential impacts on the WCH scheme. The concept designs for Cornwall Road are intended as high level, indicative and illustrative interventions only, representing Publica’s recommendations and professional advice for each site. They are not design proposals per se.

153 No inclusion of the space on Waterloo Bridge, junction with Stamford Street (in A methodology was produced to identify sites to be N/A front of King’s College) – we have asked the Council to consider this space and made included as spatial briefs, and prioritise sites within some suggestions on pedestrian improvements in this, as it is out of the scope for the PRF. the WCH scheme but directly interfaces with it. The scope of the PRF did not include listing and prioritising all streets and spaces within the boundary area; rather highlighting an appropriate representation of sites that align with the methodology and the set priority criteria, below. These selected sites emerged during the first stage of Publica’s work (evidence base) that focused on a public realm audit Therefore, inevitably many sites have consciously not been included within the Framework.

Stamford Street comprises a further complicating factor in that it is classed as a Transport for London Road Network Area (TRLN), also known as a ‘red route’ in which TfL have their own design guidance. Jubilee 154 1.1 The Jubilee Gardens Trust is a registered charity whose prime charitable No material changes required to the PRF N/A Gardens objective is to ‘provide a park and facilities at Jubilee Gardens, for the benefit of Trust the public…’ The Trust’s membership structure reflects the mix of the South Bank/Waterloo community - members are drawn from resident organisations in the area, local enterprises and adjoining landowners.

1.2 The new Jubilee Gardens was created in 2011-12, with the capital cost funded by s106, Mayoral grant and private donations. It was a condition of the s106 funding that the Gardens should become the responsibility of a local community-based Trust, and in 2012 Southbank Centre granted the Jubilee Gardens Trust a long lease (until 2138) including full responsibility for the management and upkeep of the Gardens.

1.3 Jubilee Gardens is one of the most intensively used public spaces in the country. Sample visitor counts provide a reliable estimate of annual footfall of some 7million to 8 million on an area of only 1.5ha, (comparable to the numbers using Regent’s Park which is 166ha). As a measure of pressure on the Gardens, litter collected rose by some 60% in the Trust’s first five years of operation. In 2018 it amounted to some 70 tons. The playground is used by more than 1500 children on busy days.

1.4 In 2016 the Trust carried out extensive user research, with over 400 interviews on the Gardens, 100 interviews with local residents and 200 responses from local residents and employees to web surveys. The results were extremely positive from users in all categories – 98.5% rated the Gardens as ‘good’ or ‘very good’, with high levels of approval for management, maintenance and safety.

1.5 The research provided evidence of the importance of the Gardens to the local community and economy. 95% of respondents saw the Gardens as good/very good for the local community and 97% agreed/strongly agreed that they improve the quality of the South Bank area. 98% agreed or strongly agreed that ‘The greenery of Jubilee Gardens is a welcome relief from the busy South Bank’. The Gardens were also shown to be the local open space used most frequently by local residents.

1.6 The same survey also asked a number of questions about the Gardens extension and gathered in a broad and clear range of responses which will be used to inform the extension design.

1.7 The Trustees are grateful for the opportunity to comment on the draft Public Realm Framework but, as will be evident from the comments below, their general view is that Publica have created a piece of work which is flawed in many respects. 155 2. General Comments Lambeth has been lobbied locally for several Amendments to spatial 2.1 The Trust is not clear why this work was commissioned. Many other years to improve and enhance streets and spaces, brief B3 – Belvedere documents set out public realm priorities and aspirations from the Local Plan and to deliver improved public realm within Road at Jubilee downwards. It is a matter of serious concern that the key public realm/open Waterloo and South Bank. Gardens have been space project identified in the Local Plan, the extension of Jubilee Gardens onto undertaken to update

Hungerford Car Park, receives one passing and poorly-informed mention in the the information and draft Framework. Before the council can consider allocating alignment with the resources, robust evidence is required to identify Lambeth’s policy. need and begin the process of prioritisation. This is what the PRF does. The PRF will also be cited within the Draft Revised Lambeth Local Plan as non-statutory guidance. To date, the PRF has been helpful in a number of ways:

• Informed discussions with H B Reavis and their professional team, helping to shape the public realm proposals for Elizabeth House.

• Supported the South Bank Spine Route technical transport survey and public realm design commissions, both of which secured member approval and;

• Provided stimulus for Lambeth’s commitment to produce a delivery plan and management and maintenance plan. 156 1.2 As the guardians of the most heavily used and central public green space in the Comments acknowledged. Amendments to spatial area covered by the draft framework, and as one of the key stakeholders in brief B3 – Belvedere plans to extend the Gardens the trustees had already set out their priorities and Publica made notes of all engagement meetings Road at Jubilee concerns in responses to Neighbourhood Plan consultations, the Bishop’s Ward and sought to ensure that the very broad range Gardens have been undertaken to update CLIPS consultation, and the 2018 Local Plan consultation. Publica appear to of comment was reflected within the PRF. the information and have taken no account of the key points raised in these responses, nor of the Invariably, this required the exercise of masterplanning principles agreed by all key players, including the Council, for alignment with the judgement in assessing and accommodating the redevelopment of Hungerford Car Park. Lambeth’s policy. sometimes competing comments.

Spatial brief B3 – Although the chair of the Trust met with Publica and the Council during the work Belvedere Road at on the Framework, none of the points he raised at that meeting appear to have Jubilee Gardens will be found their way into the draft which is now out for consultation. recognised as a priority project; thus, resulting in a total of six priority projects identified within the Public Realm Framework.

Specific maps within the PRF have been amended to reflect Hungerford Car Park boundary. 157 2.3 We understand that many other organisations with interests in the public The guiding principles reflect the existing priorities set N/A realm in South Bank and Waterloo, several of whom are represented on the out within SoWN’s Draft neighbourhood plan, for Jubilee Gardens Trust, have formed a similar view of the quality of the draft example: Framework. In addition, the Trust has been closely involved in the work on the • Green infrastructure, open space & air quality are draft South Bank and Waterloo Neighbourhood Plan. Many local opinions about reflected in Principle 1 with more detailed air quality public realm and areas needing attention had already been identified in the early actions outlined within Lambeth Air Quality Action Neighbourhood Plan consultations. The draft Framework takes little account of Plan (2017 to 2022). the very extensive work by the local business and resident community on the • Social infrastructure and culture are reflected in Neighbourhood Plan. Principle 2. • Development and management are considered in Principles 5 and 6. 158 2.4 In the light of these points trustees think it reasonable to ask The Council and Publica sought to undertake a N/A i. What evidence was collected of the views of those local stakeholders collaborative engagement process within the project and residents who were consulted during the preparation of the scope, budget and resource. strategy? ii. Does it support the consultants’ claim that their work took account of The project team aimed to have as many face-to-face stakeholder and resident views? meetings with strategic / commercial stakeholders as iii. What feedback was there in the cases of those who were consulted possible. As a result, 17 organisations were locally but whose input appears to have been ignored? accommodated – which would have been significantly less if hour sessions were offered. The project team asked each stakeholder within the invitation and the meeting itself to submit any evidence to support the Framework and provide additional feedback to the team about their aspirations, plans and recommendations.

Publica made notes of all engagement meetings and sought to ensure that the very broad range of comment was reflected within the Draft PRF. Invariably, this required the exercise of judgement in assessing and accommodating sometimes competing comments.

Both the Waterloo Steering Group (10th October 2018) and the stakeholder workshop (7th March 2019) addressed how stakeholder feedback was reflected in the Draft Framework. In future, we will seek to publish an on-line summary of comment received and ‘close the loop’ on engagement. 159 2.5 As the draft Framework recognises, very large parts of the South Bank public Within Publica’s methodology, the evidence base for N/A realm are privately owned and managed. These include some of the busiest the Framework was established through areas, including those round County Hall and the London Eye; the Southbank comprehensive fieldwork and research, including on- Centre, National Theatre and Coin Street sections of the Riverside Walkway, and site public realm surveys and data collection, mapping, Jubilee Gardens. However, of the eighteen projects identified in the draft policy and other analysis, photography, and research, Framework, all but four are on land owned by the Council, and three of those as well as a public realm audit of key sites identified four include land owned by the Council. The Trust clearly has no objection to the through the survey projects. The 18 spatial briefs were Council producing a framework and priorities for its own land in Waterloo. It is thus based on the spaces most in need of investment however concerned that what is presented as a Waterloo and South Bank Public and improvement. Realm Framework does not reflect key issues related to the privately-owned but publicly accessible parts of the neighbourhood which comprise a high proportion Priority projects have been selected based on the of the busiest areas. The draft Framework gives rise to some doubt as to following criteria: whether the consultants have fully understood important issues of ownership, • They evidence the need for improvement and governance and management. investment • Their proposals align strongly with the six guiding principles • The reflect local and/or strategic stakeholder aspirations and priorities • The sites are strategic spaces with a broader impact across Waterloo and South Bank 160 2.6 This is particularly evident in the omission of the extension to Jubilee The PRF does not include spatial briefs (detailed Clarifications on live Gardens (which involves no Council-owned land) from the list of projects. If the descriptions and recommendations) of ‘live’ projects, projects and their purpose of the Framework is to assist in prioritising resources (see Cabinet including Jubilee Gardens extension. This was a inclusion in the PRF Member’s introduction, para 3) it cannot be helpful to omit what is already conscious decision to avoid cutting across emerging provided in the agreed to be a top priority, as reflected in the Council’s own Local Plan. The proposals and planning processes. The risk of updated Executive extension will increase the overall area of Jubilee Gardens by some 40% (approx. rendering the PRF out-of-date prior to publication was Summary and 69

0.6 ha), a very significant increase in the overall green space in the also a concern. It is clear that this decision has been alongside the neighbourhood. This huge opportunity is virtually ignored by the draft perceived as a lack of regard and support for these Development Context Framework. projects, which was not the intention. Greater clarity map. should have been provided to avoid this misunderstanding and this will be addressed in an updated PRF. 161 2.7 The overwhelming local consensus is that where resources are needed most Comment acknowledged and addressed in the Stronger emphasis on is in revenue expenditure on management and maintenance. High quality updated version of the PRF. the importance of management and maintenance is critical to the overall quality of the public robust management realm, and ultimately a higher priority than many of the projects identified by and maintenance the Framework. Many of the public realm services in the busiest parts of the needs in the updated neighbourhood are provided either: text of Guiding i) by the private landowners of major areas of the busiest public realm - notably Principle 5. many of these (Jubilee Gardens Trust, Southbank Centre, National Theatre, Coin Street Community Builders) are charities or non-profit organisations, or ii) via services supported on a very large scale from sources other than core Council funding, i.e. S106 funds, private funds via BIDs and voluntary business contributions. The Trust’s need for more revenue funding has been consistently flagged up by the trustees in all previous relevant consultations – there is a particular problem in that legal constraints prevent commercial activities on Jubilee Gardens. The need for high quality management and maintenance of all public areas, whether Council or privately owned, is a matter constantly raised by many local stakeholders. Yet the only references to management issues in the document are to recommend the use of sustainable materials. This principle was fully adopted in the design for the re- landscaping of Jubilee Gardens (led by the Jubilee Gardens Steering Group and subsequently the Trust) and is already established as a key principle by the stakeholders in the design of the future extension. 162 3. Specific comments Resource allocation is not within the scope of the N/A 3.1 Executive Summary (pp6-14) Framework. a) The Summary highlights that Waterloo and South Bank provides 40% of borough's business rates income – in the Trust’s view this is why Lambeth should The Council and Publica sought to undertake a be investing in South Bank and Waterloo, both revenue and capital, including collaborative engagement process within the project ensuring that planning gain, s106 and CIL, is focussed for reinvestment in the scope, budget and resource. neighbourhood, according to locally developed priorities. In its response to the Bishop’s Ward CLIPS consultation the Trust made a very strong case for the The project team aimed to have as many face-to-face allocation of planning gain to support its management of the busiest public meetings with strategic / commercial stakeholders as green space in the area, for which it receives no core Council funds. The draft possible. As a result, 17 organisations were Framework refers later (on p15) to the 'emerging Waterloo Cooperative accommodated – which would have been significantly Investment Plan', as a key data source. Although the CLIP was reported to The less if hour sessions were offered. 70

Lambeth Cabinet in October 2018 as having been completed, it is not yet publicly available, and the Trust has received no feedback to its representations. The project team asked each stakeholder within the It seems odd that the draft Framework, which is intended to set priorities invitation and the meeting itself to submit any including projects which will no doubt be funded by CIL, has been issued for evidence to support the Framework and provide consultation with no public knowledge of the local CLIP proposals. additional feedback to the team about their b) p7, final paragraph, states that the Framework was 'developed through a aspirations, plans and recommendations. close collaboration between Lambeth and Publica'. The trustees’ response to this is to ask where is the close collaboration with the landowners, stakeholders, The community ‘drop-in’ sessions sought to capture potential funders, businesses and residents that would reflect the frequently local resident’s views at a neighbourhood level. stated commitment to partnership, cooperation and engagement by the Council. Sessions were promoted via the council’s website and social media, with emails sent to stakeholders requesting support in sharing with their networks. Forty-four people attended the three sessions. In future we will advertise sessions more widely and further in advance and try to make provision for ‘offline’ communications.

- the issue raised by 'many stakeholders' related to revenue expenditure not text of Guiding capital. Principle 5. - the issue of management and maintenance in any case receives very little attention in the document. 164 3.2 Guiding Principles (pp47-60) Comments acknowledged. Guiding principle 5, The whole document rests on a new series of Guiding Principles , enlisted to sub-tactic 5 amended categorise and prioritise projects. In general the trustees view is that most of The six guiding principles reflect a wide range of text in relation to them add little to what is self-evident, already happens, or is already well opportunities, challenges, issues and constraints custodianship. “As part covered in London and Lambeth Local Plan Policy. Apart from this general identified by local stakeholders throughout the of planning new comment, direct concerns of the Trust are engagement process. They are based on themes developments, include Principle 5 (p55) identified by Publica as a result of their evidence a management Bullet 1 - materials to minimise maintenance costs - self-evident, but this will not gathering and engagement. strategy for publicly- always be compatible with reducing capital costs. This is particularly important accessible streets and for the Jubilee Gardens extension. Robustness of design, both in the hard A rigorous internal process within the council was also spaces, exploring local landscaping and particularly in the quality of soils and grass, was a key factor in undertaken to review, amend and approve the guiding stewardship where achieving a new Jubilee Gardens which would stand up to the exceptional principles at draft stage. This exercise was undertaken appropriate.” footfall the Gardens receive. It will be essential to achieve this with the at senior management level across multiple service extension, in a climate where less capital and revenue funding is available. areas, including Area Regeneration, Planning Policy, Bullet 5 Design and Conservation, Transport, Highways and a) a management strategy for publicly accessible spaces in private developments Parks. is always required by planning b) privately owned publicly accessible spaces in the South Bank are normally The focus that the principles place on amenity, maintained to a high standard by their owners; the significance of 'local accessibility and wellbeing; culture, heritage and custodianship is not clear. What needs local custodianship and proper funding, is design; barriers and legibility; safety and security; the management and maintenance of all busy public spaces in the area, whether maximising development and minimising disruption; in private or Council ownership. and supporting growth are consistent with other strategies and policies. 165 With its challenging experience of managing one of the busiest playgrounds in The Framework is objective, and evidence based. It is N/A London the Trust would also question the practicality of Bullet 3 of Principle 1 not a delivery plan providing guidance rather than (p47). This expresses the worthy aim of ‘including formal and informal play prescription. The management, maintenance and spaces and playable features where possible’. It does not identify where the delivery of public realm improvements will be resources will come from to keep such spaces safely maintained. Playground addressed through separate dedicated plans – maintenance is a particular concern of the Trust and its costs have been including the identification and application of internal regularly highlighted in making the case to the Council for increased support / external funding streams. from CIL/s106 funds. 166 3.3 Spatial Briefs (pp61ff) Comment acknowledged. Belvedere Road and Upper Clarifications on live The Trust’s immediate concerns relate to ‘Spatial Brief B3’ (p72) Belvedere Road Ground family of projects recognises the importance projects and their at Jubilee Gardens. Comments are: of the Spine Route as a sequence of spaces with the inclusion in the PRF potential to draw together the station area and the provided in the cultural institutions along the river. A section of the updated Executive 72

a) much of what is proposed is already being delivered, either via the route is currently being delivered through the s278 Summary and Southbank Place development or via the s278 funding from the funding of the Southbank Place development and this alongside the development which is currently being spent on Belvedere Road. is recognised in spatial brief B2. Much of the Development Context remaining route still requires improvement. map. b) the ‘Opening up of new routes to South Bank from York Road’ is already the central feature of the new public realm in Southbank Place. It is however The Low Line concept links existing centres of activity First bullet point of worth noting that the main central route through Southbank Place, from and enterprise by creating new attractive routes spatial brief B3 Waterloo Station, past the re-opened York Road tube station entrance, will alongside rail arches and viaducts and their associated amended to read: create a new route to the river through Jubilee Gardens and add further to spaces and streets. the footfall across the Gardens and to the Trust’s management costs – a “Explore the potential prime example of how development adds to the pressure on the area and The Low Line routes will facilitate economic growth for improved access the need to reinvest the proceeds of development in the neighbourhood. and improve access and permeability along the rail between South Bank viaducts and will be referenced as policy within the and Waterloo Station c) the main ‘new legible route’ proposed by Publica goes through the Draft Revised Lambeth Local Plan. along the railway Southbank Centre service yard which cannot be a publicly accessible space. viaduct as a One of the arches along this route is in use by the Trust for servicing and a continuation of the continued presence there will be essential when the extension is realised. Low Line that runs from London bridge. d) Virtually all the railway arches, except those which are needed for servicing, Consider activating the are already activated. railway arches lining this route, for example e) ‘Create a new public space as part of the Jubilee Gardens extension': with partnership with This paragraph is seen by the Trust as particularly unsatisfactory. First, the cultural institutions.” Jubilee Gardens extension will be a major new public space. Secondly, the comment 'explore ways to create a distinction between the Jubilee Image showing Gardens and proposals for its extension', fails to take account of: restricted Southbank - Consultation about the extension in a major survey by the Jubilee Centre road removed Gardens Trust in 2016, with over 700 responses, which overwhelmingly to reflect text changes. supported continuing the style of the current Gardens into the extension Amendments to spatial - Masterplannng principles for the site, agreed after much discussion, by brief B3 – Belvedere all major stakeholders, including the Council. Though these were Road at Jubilee agreed in 2016-17, most of them are still current. Gardens have been - The fact that Jubilee Gardens and its extension will be managed as one undertaken to update space. the information and - The comment is in conflict with the consultant’s own emphasis in bullet alignment with the 1 of Principle 5 concerning unified public realm. Lambeth policy. 167 4. Conclusion The Council and Publica sought to undertake a N/A Jubilee Gardens is perhaps the public realm space under the greatest pressure in collaborative engagement process within the project the whole neighbourhood. It is also a space which contributes massively to the scope, budget and resource. 73

quality of the neighbourhood and the experience of its visitors, workers and residents. The benefits it provides are delivered by a small local charity using The project team aimed to have as many face-to-face resources of volunteer trustee time and much private funding to the benefit of meetings with strategic / commercial stakeholders as the South Bank and Waterloo, and Lambeth as a whole. possible. As a result, 17 organisations were accommodated – including Jubilee Gardens Trust. In this context, the trustees feel strongly that the Council and its consultant should have engaged much more closely with the Trust. The Trust was not Publica made notes of all engagement meetings and invited to participate; it had to request time with Publica and this led to a short sought to ensure that the very broad range of meeting. However key points raised at that meeting are not reflected in the draft comment was reflected within the Draft PRF. Framework. Invariably, this required the exercise of judgement in assessing and accommodating sometimes competing comments.

The purpose of undertaking a six-week public consultation was to enable the council to ensure a wider, more robust consultation – seeking views from residents, businesses, community and third sector organisations, landowners and others. 168 Previous consultation responses have set out the case for the Jubilee Gardens Trust Subsequent to receiving responses from the PRF N/A to receive further support from CIL and s106 to ensure the proper maintenance of a public consultation, a meeting was convened on crucial piece of infrastructure. Without such support there will be a significant 20.06.19 with Andrew Travers (CEO, London Borough threat to the quality of public realm in the South Bank and Waterloo of Lambeth), Nic Durston (CEO, SBEG) and Lucy neighbourhood. Additionally, the Gardens extension is considered by many locally Musgrave (Founding Director, Publica); the and in the Council to be the top priority public realm project in the neighbourhood. subsequent next steps were agreed: For the consultant to have dealt with it in the passing manner described above would seem to cast doubt on the value and approach of the draft Framework as a whole. 74

3. To coordinate a workshop with key community, In this context, if the Council were minded to withdraw the draft Framework, or business and landowner representatives which at the very least to undertake a fundamental review of it, the Trust would be will: happy to participate in the process with the Council and other South Bank and − Address issues raised by some organisations Waterloo organisations. The trustees would bring to this process and identify matters for clarification / - a deep knowledge of how public realm projects in the South Bank are refinement, matters for amendment and best brought to fruition with full participation and engagement by all matters that are out of scope. interested parties. − Enable a collaborative process to inform the - extensive experience of the intense management and maintenance production of public realm Delivery and pressures on the busiest areas of the neighbourhood and what is Management and Maintenance Plans. needed to address them. full commitment to and understanding of what many believe to be the key public 4. The Council to update the Draft PRF considering realm project in the area – the extension of the Gardens. the above and publish it online.

A PRF stakeholder session has since been held on 23.09.19 where Lambeth officers discussed how comments were being taken onboard and outlined next steps – with the agreement of incorporating amendments and seeking to publish the document. We Are 169 Thank you for the opportunity to comment on the Draft Waterloo and South Bank The Council and Publica sought to undertake a N/A Waterloo Public Realm Delivery Framework. This representation is submitted on behalf of collaborative engagement process within the project BID WeAreWaterloo Business Improvement District. scope, budget and resource.

The project team aimed to have as many face-to-face WeAreWaterloo is a Business Improvement District (BID) operating in the Waterloo meetings with strategic / commercial stakeholders as area of central London. The BID was established in 2006 following a vote of local possible. As a result, 17 organisations were businesses, one of London’s first Business Improvement Districts. We were renewed accommodated – which would have been significantly for a second five-year term in 2011, and for a third five-year term in 2016. The BID less if hour sessions were offered. represents some 430 businesses in the Waterloo area, and the operational arm of The project team asked each stakeholder within the the BID supports these businesses in various manners, including but not limited to invitation and the meeting itself to submit any evidence to support the Framework and provide public realm improvements such as additional green infrastructure, street cleaning, additional feedback to the team about their street lighting and public art projects, free & subsidised recycling for all businesses, aspirations, plans and recommendations. and crime and security measures. The community ‘drop-in’ sessions sought to capture 1.1. General Comments local resident’s views at a neighbourhood level. As a process to direct and inform the council to areas of regenerative need, we are Sessions were promoted via the council’s website and supportive of the idea of a framework. In terms of the contents of this framework social media, with emails sent to stakeholders requesting support in sharing with their networks. produced - we are supportive of some but not all of the conclusions drawn from the Forty-four people attended the three sessions. In 75

plan. For example, we agree that Emma Cons Garden is long overdue regeneration, future we will advertise sessions more widely and and needs to be a priority project. further in advance and try to make provision for ‘offline’ communications.

Our main cause for concern lies within the process by which the framework has Publica made notes of all engagement meetings and been created. In the draft document, there appears to be little reference to the sought to ensure that the very broad range of SoWN Neighbourhood Plan and little evidence of consultation of key members in comment was reflected within the Draft PRF. the area. Invariably, this required the exercise of judgement in assessing and accommodating sometimes competing comments.

The guiding principles reflect the existing priorities set out within SoWN’s Draft neighbourhood plan, for example: • Green infrastructure, open space & air quality are reflected in Principle 1 with more detailed air quality actions outlined within Lambeth Air Quality Action Plan (2017 to 2022). • Social infrastructure and culture are reflected in Principle 2. • Development and management are considered in Principles 5 and 6. 170 We are aware of a number of organisations, businesses and residents groups who We have reviewed and updated the stakeholders’ list Added Bourne Capital feel they were not fully incorporated into the framework and their years of in the Matrix of spatial briefs based on further as a stakeholder to C3 experience and history should not be forgotten in the creation of this document. considerations and on additional consultation Added Waterloo Estate comments received regarding the Matrix. (Bourne Capital) to This is evident on page 63 of the framework, where residential and business group ongoing or proposed appear to be listed sporadically as “key stakeholders”. developments to C3 Added Union Jack Club There are a number of projects where we would consider ourselves key as stakeholders to C6 stakeholders, but have been omitted. There is a lack of acknowledgement of other Added WeAreWaterloo key stakeholders which we feel needs to be addressed appropriately. as a stakeholder to D1

Added BOST as a stakeholder in relation to Millennium Green Project – C6. 171 Indeed, we are aware that Lambeth ran workshops to consult with the community, The Council and Publica sought to undertake a N/A but we think that more work needs to be done to fully understand the views, collaborative engagement process within the project experiences and knowledge of the local community. scope, budget and resource.

The community ‘drop-in’ sessions sought to capture local resident’s views at a neighbourhood level. Sessions were promoted via the council’s website and social media, with emails sent to stakeholders requesting support in sharing with their networks. Forty-four people attended the three sessions. In future we will advertise sessions more widely and further in advance and try to make provision for ‘offline’ communications. 172 We do not believe that the time invested in the length of the workshops was The Council and Publica sought to undertake a N/A sufficient enough to understand and process the quantity and diversity of collaborative engagement process within the project information that the relevant stakeholders have to offer. scope, budget and resource.

The project team aimed to have as many face-to-face meetings with strategic / commercial stakeholders as possible. As a result, 17 organisations were accommodated – which would have been significantly less if hour sessions were offered. The project team asked each stakeholder within the invitation and the meeting itself to submit any evidence to support the Framework and provide additional feedback to the team about their aspirations, plans and recommendations.

5. To coordinate a workshop with key community, business and landowner representatives which will: − Address issues raised by some organisations and identify matters for clarification / refinement, matters for amendment and matters that are out of scope. − Enable a collaborative process to inform the production of public realm Delivery and Management and Maintenance Plans.

6. The Council to update the Draft PRF considering the above and publish it online.

The PRF is a live document. As the area changes, Lambeth will seek to refresh and review improvement and investment priorities. 175 In addition, the integration of security features described in the framework, such as Comments acknowledged. N/A Hostile Vehicle Mitigation, should not be a “bolt-on” to planned regenerative work. Instead, these need to be priority, stand-alone projects. It seems that only when Guiding principle 4 recommends that security features should be integrated early on within the design these regenerative works in the public realm draft framework are completed will process. additional security features be required - but in our view, it is imperative that security features protect heavy footfall areas in the now. Placing HVM and other security features into crowded places needs to be proactive, not reactive, and not subject to larger scale projects. As a BID, we neighbour both Better Bankside and South Bank BID, both of whom were drastically affected by the Westminster Bridge and Borough Market attacks. We are acutely aware of the risks of the current climate and both we and the businesses that we represent believe that we are long overdue protection of heavy footfall areas such as (although not limited to) Emma Cons Gardens, The Cut and Lower Marsh, and numerous places on the South Bank. The more time that passes, the more we are exposed to such a threat, and if such an attack were to come to fruition, we will have failed to adequately protect our community from a known potential threat in a high risk area. Both South Bank BID and WeAreWaterloo are primed to support and manage the installation of such security features and we would urge the council to strongly consider taking this away from our response and acting upon it as a separate matter. 176 2.1. Guiding Principles Comments acknowledged. Guiding principle 1 2.1.1. Principle 1: Encourage the provision of civic amenity and green infrastructure Sub-tactic 5, supporting accessibility, health and wellbeing for all replacement of the word ‘create’ with

‘facilitate’. a) We agree with and support the promotion of green initiatives within the Waterloo area. Included in this is the promotion of clean air walking routes (known as Greenways) which the BID has and is spending time and resources

promoting. We appreciate the council’s continued support for the projects that we run which promote and improve the air quality in Waterloo.

b) We would like to see an increase of green space available to the public with all new public realm improvements. Ideally the green infrastructure will be selected on it’s air quality benefits, and as a principle, the enhancement and addition of further green space comparatively to what was in situ previously represents the view of local businesses and also aligns with SoWN plan (Policy P1.3).

c) If indeed this is adopted as a guiding principle, we would urge the council to consider whether it would be appropriate to facilitate and not to provide adequate interventions for public realm improvements which directly contradict this principle. Specifically, the TfL Imax Roundabout redevelopment which by its very nature, will increase traffic flow along a designated Greenway and quietway on Cornwall Road. For the council to endorse WeAreWaterloo’s successful grant funding application for capital to promote Cornwall Road as a clean air walking route, and yet also, concurrently allow an increase in vehicular traffic contradicting this, has put into question the council’s commitment to this principle. We would like to see this principle adopted as a holistic approach to all projects, not only when it is easy to do so. 177 Comment acknowledged. N/A 2.1.2. Principle 2: Celebrate and protect culture, heritage and design excellence. Any public realm design that come forward will be In order to achieve this principle in an efficient way, the BID requests that the subject to separate due diligence; in which, conversations will be undertaken with interested council support the BID in its inititaives that specifically accomplish Principal 2, parties, as well as dedicated design commissions notably through the formation of localised and specialist engagement groups that and statutory public consultation and the planning are composed of interested local businesses who provide unique insights into the process, if required. use and management of public realm spaces within Waterloo. 178 2.1.3. Principle 3: Address the perceived barriers to movement, accessibility and No material changes required to the PRF N/A legibility across the area.

Further on in our response, we have detailed our perspective and aspirations for the areas of the Draft Framework which fall within our remit. As a whole, we are supportive of wayfinding and placemaking projects, and we feel it is vital to be

included within the design and implementation processes throughout each area. For Waterloo, it would be important to have a unified wayfinding approach which adds to the identity of the area. 179 2.1.4. Integrate security features early in the design process to create coherent, safe The focus of Guiding principle 4 is to ensure spaces N/A streets and spaces are safe and secure, with a focus on incorporating solutions early in the design process for new public We would like to point out our previous comments in section 1.1, detailing our realm. concerns with this principle. It appears to suggest that only newly redeveloped public realm works will be entitled to receive security measures, when in fact The Council is supportive of any Hostile Vehicle there is a current need for them in spaces which are already due to be Mitigation measures and is investing in a project redeveloped. Notably, Lower Marsh has been developed over the last few years, within the South Bank. and now has a revitalised feel, without having lost any of the characterful heritage that previously existed. However, the addition of security features were completely omitted from this redevelopment. Lower Marsh now suffers from a minor threat of road traffic incidents, where pedestrians do not realise that the street is open to vehicular traffic, and therefore do not check the road for cars whilst walking. This could (and has) lead to minor or major accidents between vehicles and pedestrians. The more pressing issue is that the entire street is vulnerable to the use of vehicle as a weapon. The Draft Framework wording suggests that now Lower Marsh will not be eligible for HVM, when in fact, a number of council members and Met Police employees understand and are supportive of the implementation of HVM on Lower Marsh. The plan needs to revisit this wording and if there is a necessary need for HVM throughout any area, regardless of redevelopment, it should be implemented. 180 2.1.5. Principle 5: Maximise the positive impacts of development and minimise Comment acknowledged. N/A disruption. Any public realm design that come forward will be subject to separate due diligence; in which, The BID is excellently positioned and thoroughly experienced in delivering such conversations will be undertaken with interested meanwhile spaces and temporary public art works for projects as mentioned in this parties, as well as dedicated design commissions principle. The local network we have provides the council with the ideal vehicle to and statutory public consultation and the planning link into local business and form projects for that are created and enjoyed by local process, if required. people. We would welcome any conversation regarding future public art projects and meanwhile space creation and management, as we have further detailed later on in our response. 181 2.1.6. Principle 6: Design and plan for an environment with the capacity to support Comments acknowledged. Sub-tactic (f) has future growth. been added to Relevant changes have been made to the PRF guiding principle 5: accordingly. 81

We are in support of the principle of high quality construction management plans, • Consider the and would like to continue working in the same manner of previous developments. operational Here, the council involved the BID on key issues which ensured the survival and requirements and protection of Lower Marsh Market and local businesses. opportunities for

freight and We also believe that future developments must encourage and facilitate the use of servicing cargo bikes and freight consolidation programmes. Local businesses that we consolidation represent are vastly in favour of such programmes, but the infrastructure isn’t within all future necessarily in place to support them. Again, this is something that we could work detailed designs. with the council on to ensure the betterment of the area, for all. Sub-tactic (f) has

been added to guiding principle 1: • Deploy creative thinking and new ways of working to deliver a robust climate change response, addressing the Council’s declared climate change emergency. Have regard to Policies EN1 (Open space, green infrastructure and biodiversity); EN4 (sustainable design and construction); EN5 (Flood risk), EN6 (sustainable drainage systems) in the Lambeth Local Plan.

182 3.1. Spatial Briefs Comments acknowledged and reflected within the The following PRF. changes have been We believe that a number of key business and residential organisations have been made: C7 – We Are Waterloo are already included as a • C3 – Bourne omitted from the “key stakeholder” section of the spatial briefs pages (p. 62/63). key stakeholder Capital has been These include but are not limited to: added • C6 – The Union • C3 - Capital Towers Jack Club has • C6 - The National Theatre, The Union Jack Club been added • C7 - Lower Marsh Market • D1 – We Are • D1 - WeAreWaterloo Waterloo have been added

We would recommend for a subsequent round of extensive consultation to include these members and also, to revisit those memebers that did not have a chance to comment on the first round of consultation. 183 4.1. Priority Areas No material changes required to the PRF N/A

Specifically in reference to the geographic areas that we as a BID represent, we would agree with the council’s decision that Emma Cons Garden is an important priority project. The site could be considered the centrepiece of Waterloo, and is directly in front of both Waterloo Station and a number of businesses, including the prominent Old Vic Theatre. At present, it is clearly not fit for purpose and we will detail our thoughts and comments further on in our response.

In addition, Sandell Street has the potential to welcome commuters into Waterloo in a much more appealing way than which is currently present; as has been proposed by the council. We also agree with the decision to regenerate this area, and are looking forward to continuing to work closely with the council to provide additional green encouraging infrastructure to the proposed scheme, to further complement and enhance the proposed work.

5.1. Partnership work

As representatives of the local business community, we have worked closely with the council on countless occasions to bring about positive change to Waterloo. This

is a fruitful relationship and we are eager to continue working in such a way with the council. We are able to support and work in partnership in a variety of manners.

5.1.2. Engagement & Project Direction

We have proved a practical solution for the council to engage with local business and residential stakeholders. The link we have into the local business network has proven efficient and powerful for the council to quickly and effectively speak to the necessary representative within organisations.

Based on this engagement of local businesses and understanding of the area, we have given insights into the future uses of public realm space based on business needs. We are able to utilise our specialist business groups to advise, critique and comment on various works to further assist the councils direction with public realm improvements. These opinions give an excellent “eyes on the ground” approach, as more often than not these groups consist of the very people who use these public realm spaces on a day-to-day basis, and therefore have first hand experience and specialist knowledge of improvements that can be made.

Ultimately we are able to act as an excellent conduit between businesses and the council - linking in the two, saving the council time/providing detailed consultations. In addition, this system works two-ways and we appreciate the council’s ability to link us in with relevant parties at the appropriate level. We would like this partnership work to continue.

5.1.3. Use of Space whilst in Construction

Whilst projects are in construction, the BID is keen to aid or solely manage the creation and operation of meanwhile spaces (occupied by local businesses) or public art projects. Construction is often unappealing to the public, whereby shoppers and commuters will avoid routes which are loud, dusty, difficult to navigate and visually unattractive. Therefore, we find that surrounding businesses experience loss of footfall and therefore revenue due to construction. We would therefore like to propose that (as has frequently occurred in the past) the council continues to allows the BID to create meanwhile spaces and public art projects to encourage footfall back into these

areas affected by construction. The BID is committed to sourcing local businesses and artists to fulfil these projects, in keeping with the independent business nature of the area. This aspiration ties directly in with the fifth principle of the draft framework. 5.1.4. Providing Additionality

The BID is perfectly placed to provide further improvements to regeneration projects. We would consider this the “icing on the cake” - and can be achieved through many methods. Previously we have provided additional lighting, additional greenery, public art, wayfinding and much more to regeneration projects. We would like to state that it is important to note we will provide additionality above and beyond the plans laid out by the council if there is scope to do so (i.e. if lighting is proposed we would not offer an addition nor an alternative), only infrastructure that has not been planned but there is a need for within the proposed scheme.

5.1.5. Summary of Partnership Work

Overall, we are able to facilitate and support the council in accomplishing the preceding. However, as a matter of course it would be mutually beneficial if the council could support the BID in new ways, and could continue to support the BID via the way in which it already does. New support could be achieved by simplifying and fast-tracking collectively advantageous aspects of joint projects. This would save the BID time and funding, hence, paving the way to fund and promote fresh and supportive work.

6.1. Locations covered within the plan

Within the Draft Framework, we are in agreement with a number of the areas designated for regeneration, and have detailed evidential reasons and aspirational improvements below. We have only commented on the areas within Waterloo as per our BID remit, but would like to state that other areas (such as the Spine Route) are indeed in need of regeneration. The general public are not necessarily privy, nor aware of BID boundaries, and to be blind to other necessary improvements within the entire area would be reductionist and potentially detrimental to the businesses that we represent.

6.2. C1 Victory Arch & Mepham street 85

As identified by the council, Victory Arch and Mepham Street require significant improvement.

6.2.1. Victory Arch

Victory Arch is an historic Grade II listed monument, dedicated to the lives of the 585 LSWR employees who lost their lives during WWI. There is a real need for improvement to improve access to the station, and to showcase Victory Arch in a way that fulfills its historic significance. As a path into and out of Waterloo Station, Victory Arch is poorly signposted, is congested and is a confusing entry and exit point with actual access requiring a complex navigation of roads and cycle lanes. There are a variety of obstructions present along the path into the station, and overall this does not support the flow of pedestrians into or out of the station.

As a first impression into the area, we believe that the current layout does not encourage visitors to explore the Waterloo side of the neighborhood. We would like to see this made into a priority project to support the TfL Imax Roundabout redevelopment scheme.

The area in front of Victory Arch would ideally be turned into a plaza - allowing multiple uses of the site, but importantly, to allow footfall to flow into the station uncongested. There is an opportunity to incorporate green space into the area (of which there is currently none), and to introduce directional signage to Waterloo (of which there is also none). In addition, this would allow HVM to be built into the site (again, of which there is currently none), which we believe to be of vital importance to an area with such high footfall. This redevelopment could complement the TfL Imax Roundabout redevelopment scheme, and would provide a fitting entrance into both Waterloo and the South Bank.

We also believe it would be appropriate to have more information present around Victory Arch, regarding its significance and purpose. At present, this would only add to the clutter found around the entrance, so would only be acceptable once the redevelopment works were complete.

6.2.2. Mepham Street

Mepham Street currently acts as an entrance into Waterloo. For those who turn right out of Victory Arch, their first impressions of Waterloo will be tainted by this poorly lit and extremely unclean road. The road is used as a bus stand, and a freight entrance for Waterloo Station. As the street is often full of large vehicles during the day time, those new to the area may be uncertain as to where they are going - as visibility is frequently limited by the excess of large vehicles. In addition, there are many archways which have the potential to become retail or office space, but at present, there is minimal interest to do so. If both the council & network rail were to implement improvements to the street such as better lighting and street care, there will be a much higher demand for the use of these units. In addition, the pavement width at present does not support Mepham Street as a walking route.

Ultimately, we think that Mepham Street is less of a regeneration issue, but more of an issue of responsibility. There should be immediate and low cost improvements such as better street care and lighting. As the street acts at the border between Network Rail owned land, and council owned land, there seems to be a lack of ownership and ultimately, a lack of provision. However, as mentioned, the street does act as a walking route into Waterloo, and should therefore not be neglected. 184 6.3. Cornwall Road In response to concerns from residents and local N/A businesses that the Waterloo City Hub scheme will We support the council’s motion to support pedestrian and cycling priority on lead to increased levels of rat-running through the borough roads, and following extensive Cornwall Road. The BID is currently in the process of making various improvements engagement with key stakeholder groups, the along Cornwall Road, to highlight the route as a Greenway (a clean air walking Council be implementing an intervention to restrict route). The BID has, and will be adding further green infrastructure, art murals and traffic access. lighting projects to showcase the area and to ensure that commuters and visitors find the street attractive to walk along. All the work on Cornwall Road will be This will be subject to the confirmation of waste completed by the end of this financial year, and the project as a whole is acting as a collection arrangements and other highway pilot for other Greenways within the BID area, which could use the same type of considerations such as emergency services access, and will be undertaken as a trial in the first improvements. instance. Monitoring will be undertaken before an assessment is made as to whether or not the We would like to work alongside the council on any planned work on Cornwall Road, intervention should be made permanent. so that we can work in tandem to achieve the same goals.

Our final point on Cornwall Road regards TfL’s Imax Roundabout redevelopment. It is known that the redevelopment will inevitably increase the number of vehicles that access Cornwall Road, perhaps by as much as 200 per day. If the council is committed to the spatial brief provided, then we feel it’s imperative the council takes measures to minimise and manage the increase of vehicles which will no doubt come from the TfL Imax Roundabout redevelopment scheme. 185 6.4. Sandell Street No material changes required to the PRF N/A

The BID is pleased that redevelopment of Sandell Street is going ahead. This work is complementary to the works that the BID is completing on Cornwall Road, as part of the Greenways project. Having spoken to the businesses that we represent, we believe that the council has engaged well with the local community and we are happy to further support the scheme by adding uplighting to the three planned trees which will form the green infrastructure aspect of the project. This will improve safety and visibility for those within the night time economy, and will act as a safe route of passage from Cornwall Road to Waterloo Station. 186 6.5. Emma Cons Garden Council officers met with and discussed alternate N/A and/or meanwhile uses within Emma Cons Gardens As identified, Emma Cons Garden is not fit for purpose, and we are supportive in the (ECG) with We Are Waterloo BID in summer 2019. At that time, the Council was in the process of appointing notion that this has been designated as an immediate priority project. a Commercial Development Officer to maximise the return of Council managed public spaces. It was The Draft Framework is described as “directive but not prescriptive”. From this we agreed with the BID that time would need to be understand that long-term change may be years away, and are of the belief that allowed for this new post to assess options for ECG Emma Cons Garden in its current state is more detrimental than enriching. The area and that the BID’s proposal would be revisited in circa could and is by many, seen as the centrepoint of Waterloo, but at present, there is six months’ time. nothing of note or anything appealing to visitors and commuters about Emma Cons Garden. Therefore, we believe it to be entirely appropriate to look at meanwhile space usages for the space. There are numerous examples of successful meanwhile spaces around London, and the BID is perfectly placed to implement and manage a new meanwhile space for Emma Cons Gardens. This could be in the form of new seating and lighting, a public events space, public art and green infrastructure. All of the above would be modular, so the BID would be able to rehouse all aspects of the meanwhile space to new locations throughout Waterloo. Additionally, this offers a “trial” period whereby the BID would be able to try out and test new ideas and new infrastructure for Emma Cons Garden, without ultimately committing aspects of the

space to a long term purpose. This, in turn, would provide evidence in purposing areas of Emma Cons Garden when funding does become available for a large scale regeneration project. The BID would welcome a conversation with the council, as we are happy and well positioned to manage the implementation and running of a meanwhile space in Emma Cons Garden. In addition, this suggestion aligns with the second guiding principle, second bullet point, of the Draft Framework: Co-ordinate with local stakeholders to encourage animation of spaces with arts and culture, creative lighting and events programmes. 187 Again, prior to a long-term regeneration plan, Emma Cons Garden is vulnerable Reference to the prevention of Hostile Vehicle N/A to the use of a vehicle as a weapon and we believe this issue needs addressing Mitigation (HVM) has been addressed within: immediately. • C6 Emma Cons Gardens spatial brief (pg. 88) • Emma Cons Gardens example project recommendations (pg. 111) 188 We have viewed the proposed designs for Emma Cons Garden, and whilst we Comment acknowledged. N/A appreciate these are artist’s impressions and are not anywhere near the final design, we feel it appropriate to state from the outset that the final designs must Any public realm design that come forward will be be representative of Waterloo. That is, that it would be entirely inappropriate subject to separate due diligence; in which, for a nondescript, municipal plaza to be created. conversations will be undertaken with interested parties, as well as dedicated design commissions Waterloo is a thriving creative neighbourhood full of fringe ideas and artistic and statutory public consultation and the planning culture. The new space that is created must reflect Waterloo in this way; process, if required. representing a tribute to the unique left-field culture to the area. In addition, we believe part of this must include a tribute to Emma Cons herself - in some form or another. This is part of, not only the BID’s strategic plan (objective two: The BID will promote Waterloo as a visitor destination with a concrete identity), but the Draft Framework’s second guiding principle (celebrate and protect culture, heritage and design excellence). The aspect of identity is key here; Waterloo is characterised by fringe theatre, independent businesses and a place where creative boundaries can be pushed - we would like to see future designs represent this aspect of Waterloo.

We recognise that this is still a long way off, and would like to reiterate our commitment to improving Emma Cons Garden by the introduction of a meanwhile space - of which we would like to begin a conversation with the council at their earliest convenience. 189 6.6. C7 Cab Road & Spur Road Officers have reviewed and considered the Spatial Brief C7 – Cab comments. Road and Spur Road Cab Road and Spur Road are two streets which we strongly believe should be an (pg. 86 – third paragraph, third bullet 89

immediate priority for regeneration. We wholly disagree with the designations given The PRF has been updated to strengthen air quality point) Amended to by Publica on pages 62/63 of the Draft Framework, and firmly feel that none of the and sustainable transport modes. read: guiding principles feature on either of these streets in any form whatsoever. Explore all

opportunities to From the outset, as a direct route to Waterloo and Lower Marsh the street itself is improve air quality. congested with commuters and is ultimately ugly. The pavements are too narrow Encourage the egressing from the station and are not fit for purpose during rush hour. reduction of the Furthermore, smokers encouraged to congregate directly outside the entrance onto number of stationary Cab Road. To access Lower Marsh at ground level, one has to turn right, then left and / or idling vehicles. across the zebra crossing, then left down the hill on Spur Road and finally one will Consider employing initiatives to support arrive at Lower Marsh/Baylis Road. There is no signage which is recognisable and and to increase the helpful, and Spur Road itself looks and feels more like a car park than a through number and priority of route to a thriving neighbourhood. This confusion will and does cause visitors to electric vehicles. reassess whether they wish to visit Waterloo.

The most significant and glaring public health issue regarding Cab Road is the progress from all parties to tackle the pollution caused by idling taxis. During our own research, WeAreWaterloo discovered that on ten out of ten days recorded, the air quality levels exceed EU regulations by five times the accepted limit (of which the limit should only 35 days per year breaching these limits per year; the remaining 330 days should be under this threshold). This is utterly attributable to the scores of taxis which idle outside the station on “Cab Road” for hours and hours on end. In a city which has introduced the world’s first Ultra Low Emission Zone to combat pollution, the fact that forty to fifty taxi’s can sit idling all day, every day on Waterloo’s doorstep is a real dereliction of duty by all.

The above factors contribute to an incredibly poor first impression of Waterloo; an impression which is significantly behind any other region within our city. Why would any visitor to Waterloo want to explore our neighbourhood when their first impressions are of a congested, polluted and confusing neighbourhood?

We suggest that Cab Road and Spur Road are made priority projects immediately. There is a real need for better access and wayfinding to Waterloo, including Lower Marsh. In the meantime, idling vehicles must be managed and penalised for polluting the area. Further, we suggest creating a quick or priority lane for electric 90

vehicles around the station as part of the regeneration project. This will discourage petrol and diesel usage, and promote the use of more environmentally friendly methods of transport. 190 6.7. Carlisle Lane & Upper Marsh No material changes required of the PRF N/A

As mentioned in the Draft Framework, the BID would welcome further conversations with the council to improve both streets with additional lighting and public art projects. 191 6.8. Coral Street Coral Street is not identified as a priority project. N/A

Whilst the BID recognised there would be potential to improve Coral Street as per The 6 priority projects listed within the PRF are: - Belvedere Road at Jubilee Gardens the council’s Draft Framework, we do not believe this to be a priority project at this - Concert Hall Approach time, and would urge the council to acknowledge there are more pressure issues in - Waterloo Bridge Undercroft the Waterloo area which relate to the visitor experience, and first perceptions of - Victory Arch Square and Mepham Street Waterloo via the multiple entrances to the area. - Sandell Street - Emma Cons Gardens

Coral Street is included as an ‘example project’ to further illustrate more detailed recommendations, options and precedents. The four example projects have been selected to convey a variety of local, metropolitan and global spaces that would require different approaches to delivery, 192 7.1 Locations not covered within the plan Comments reviewed and acknowledged. Amendments to C2 – Cornwall Road to 7.2 - Alaska Street A methodology was produced to identify sites to be reflect ‘adjoining included as spatial briefs, and prioritise sites within roads’ and other At present, Alaska Street is poorly lit, dark and dingy. Yet it is a through route to the PRF. points across the Cornwall Road and Roupell Street. The route could be used to ease commuter PRF i.e. rough pedestrian traffic. The storage of waste on Alaska Street unfortunately attracts a The scope of the PRF did not include listing and sleeping and high rough sleeping population and anti-social behaviour. prioritising all streets and spaces within the boundary homelessness, area; rather highlighting an appropriate management and Additional lighting would immediately improve Alaska Street, and make it representation of sites that align with the maintenance. somewhat fit for purpose. In addition, street cleaning and maintenance needs to be methodology and the set priority criteria. These concentrated on the area, as it is presently neglected. Aspirationally, we would selected sites emerged during the first stage of Publica’s work (evidence base) that focused on a recommend regeneration works which are complementary with Mepham Street as public realm audit. Therefore, inevitably many sites

both streets share similar problems at present, and a holistic approach would have consciously not been included within the significantly improve the both streets. Framework.

Instead of producing a separate spatial brief for Please do not hesitate to contact me regarding any clarification required on any Alaska Street, wording has been tightened of the points raised. We look forward to continuing this conversation with the throughout the PRF to reflect the concerns raised. council, as well as on the points raised which must be addressed separately to the Draft Framework. South 193 As will be clear from the Neighbourhood Plan (NP) any attempt to improve the No material changes required of the PRF N/A Bank & Public Realm within the South Bank and Waterloo (the area) is extremely welcome. Waterloo Public Spaces, their environment and air quality are at the heart of the NP. We Neighbour therefore fully support the principle and necessity of a Public Realm Framework (the s Framework).

Our comments, whilst expressing concerns about the way the Framework was been developed, are intended to assist in resolving the way forward. One of the reasons we were established was to create a strong collaborative partnership of the various groups in Waterloo, and not least with the London Borough of Lambeth.

We know we are not alone in holding these concerns and endorse the views expressed by members of the South Bank and Waterloo community of residents and businesses, who are all equally united in the desire to see the public realm improved.

As an umbrella body representing the residential and business community we endorse the specific views and comments made by the South Bank Employers’ Group, South Bank Improvement District, We Are Waterloo Business Improvement District, Waterloo Community Development Group, Jubilee Gardens Trust and Bankside Open Spaces.

194 Our comments are made whilst the NP is still undergoing Examination, and the Close liaison with Lambeth’s Planning Policy team Amendments made result of the Examination is unknown. We would therefore request the opportunity has been undertaken to ensure alignment with the throughout the PRF to review our comments once the outcome of the Examination, and indeed the Neighbourhood Plan and policy since the outcome to coordinate the referendum, is published. We would urge that the final version of the Framework of the referendum. Amendments have been NP with the PRF. and final version of the NP are fully co-ordinated. worked into the revised PRF to reflect this. 195 We acknowledge that until Examination and Referendum phases are complete the No material changes required of the PRF N/A NP does not come into full force. However, we would point out that the NP is a result of extensive and appropriate consultation and community engagement (as noted in the Pre-examination Review of the NP in December 2016). It is probably the most consulted upon document in an area which prides itself on consultation. It

particularly took note of the previous public realm work that had already been carried out by others. Also it set out to be based on strong evidence. 196 The NP is a piece of serious consultation, so even in the current state of affairs, it is No material changes required to the PRF. N/A a document to be taken seriously and not just acknowledged. It should be fully reflected in all planning documentation relating to the area. We cannot emphasise enough the need for full co-ordination.

If, of course, the NP is approved in a referendum, then is will be a document with statutory weight. 197 Whilst there are some good things in the Framework, our concerns are in the Detailed responses to each of these points N/A following areas provided in the sections below. • Insufficient consultation over the Framework • Insufficient acknowledgement of and referencing to the historical work on the Public Realm undertaken by various groups, not least the NP • How these various documents will work together in the future in order to provide clarity for those responsible for proposing and implementing works • How the under-investment of the past is addressed, and the situation is regarded as extremely urgent • The lack of a comprehensive plan to raise the standard of the public realm across the whole area to an appropriate standard reflecting the importance and needs of the area • No acknowledgement of the importance of maintenance and its funding 198 Consultation The Council and Publica sought to undertake a N/A SoWN was not consulted at all about the Framework, and barely knew of the collaborative engagement process within the project process until it was within a couple of weeks of its publication. We were not even scope, budget and resource. provided with the inadequate 30 minute consultation meeting made available to others. The project team aimed to have as many face-to-face meetings with strategic / commercial stakeholders as We find this lack of consultation incomprehensible given the status of the NP as set possible. As a result, 17 organisations were out above, and we would wish to be reassured that this does not recur in the future accommodated – in which Ben Stephenson, Secretary development of the Framework. of SoWN, attended and focused on WeAreWaterloo BID’s priorities.

In future we will advertise sessions more widely and further in advance and try to make provision for ‘offline’ communications.

The purpose of undertaking a six-week public consultation was to enable the council to ensure a wider, more robust consultation – seeking views from residents, businesses, community and third sector organisations, landowners and others; whilst enabling the PRF to be cited as non-statutory guidance within the Draft Revised Lambeth Local Plan. SoWN included representations within this consultation also. 199 Historical Work carried out in the area An editorial judgement call was made to remove Creation of a new The Public Realm has been of great concern in the area for decades, and much good many local historic strategy references, which have double page spread work has been carried out to address this. This work must not just be acknowledged been reviewed and have informed the PRF, from titled ‘Policy but should form an integral part of the Framework. There is good experience from an earlier draft to keep the document to a Context and which the Framework would benefit. manageable length. On reflection, we will seek to Partnership provide greater recognition and acknowledgment Working’ – with of previous work in an updated Framework. reference to previous strategies and historic documents (pg. 40- 41). 200 Clarity in the future Comment acknowledged. Further clarity and Further clarity has The Framework does not make it clear how it will work with the documents referred information have been added to the PRF to show been provided to above, including the NP. Without this clarity, it is likely to cause confusion. It the interdependencies with the Neighbourhood throughout the needs to be addressed in future iterations of the Framework. Plan and other policy / strategy documents. report – particularly within the As non-statutory guidance the Framework is Executive Summary intended to support the forthcoming updated and newly created 94

Lambeth Local Plan and other strategic documents. ‘Policy Context and The PRF will also provide strategic guidance to Partnership both the public and private sectors, help to secure Working’ sections. partnership support and funding from a variety of public and private sources, and act as a catalyst for the improvement and investment necessary to support growth, resilience, independence and place in the form of improved public realm. 201 Past under investment The PRF Foreword highlights the need for Partnership The Framework needs to acknowledge that there has been under investment in the investment and improvement in the area. working is past and that ways need to be found to address this. mentioned in the Partnership working is also a key focus in the PRF Foreword (pg. 5), document and has been mentioned in additional ‘Executive sections of the updated report. Summary’ (pg. 6- 13), ‘Commercial The Matrix of Spatial Briefs suggests where the and Strategic delivery should be council-led, development-led or Stakeholders’ partnership-led. Additionally, six priority sites have section (pg. 39), been identified which can have an immediate and in the new major impact on the quality and experience of the ‘Policy Context and public realm in the area. Partnership Working’ section As projects progress, internal and external funding (pg. 40-41). sources will be explored to identify revenue / capital. 202 A comprehensive approach Publica’s study has identified three different space N/A Further work needs to be carried out to ensure that the public realm is typologies present in the area (Global, comprehensively brought up to a standard that reflects the area’s international and Metropolitan and Local), recognising the special national status as well as providing an appropriate environment for those who live, and overlapping pattern of uses of Waterloo and work or study in the area, visit or pass through the area. The Framework needs to the South Bank. be developed to incorporate this and the urgency of the situation. This analysis has informed the guiding principles and the spatial brief with suggestions aimed at creating a public realm which is robust, functional and responds to the needs of a multitude of user groups. 203 Ongoing maintenance Comment acknowledged; however, funding / N/A It has long been acknowledged that maintenance of the public realm is as important resource allocation is not within the scope of the as the quality of its construction. The use of the section 106 money from the London Framework. Eye demonstrates how important this is, and the real benefits it has brought. This 95

needs to be replicated going forward. Money should not just be set aside for planned maintenance, but also speedy resolution of emergency repairs and good quality day to day maintenance and supervision. This needs to be incorporated in the Framework. 204 The NP lays great emphasis on the need for CIL to be spent in the area, and No material changes required to the PRF – funding N/A particularly on Public Realm. The Framework should acknowledge that the Public / resource allocation is not within the scope of the Realm is a priority call on its allocation. Framework. 205 Ongoing Consultation No material changes required of the PRF N/A We trust that the responses to this consultation will be embraced. Real and serious consultation should now be established to ensure that this Framework meets the aspirations of the many concerned about the Public Realm. The opportunity should not be lost in making it a key driver in bringing the state of the Public Realm to a position that is commensurate with the importance of the area, and one of which all stakeholders can be proud. We are keen to play our full part in this. Guy’s and 206 Thank you for giving us the opportunity to comment on the Draft Waterloo and No material changes required of the PRF N/A St South Bank Public Realm Framework March 2019. We write on behalf of a Thomas’ partnership comprising Stanhope Plc, The Baupost Group and Guy’s and St Thomas’ Charity Charity (from here on referred to as ‘the Partnership’ for the purposes of this representation) who are seeking to bring forward the Royal Street site for redevelopment. This note is intended to supplement the response we have submitted in line with your online questionnaire.

Established over 500 years ago, the Charity’s purpose is to improve the health of people in the London boroughs of Lambeth and Southwark, two of the UK’s most diverse and deprived areas. This is achieved through the Charity working with a range of partners to identify, test and scale new approaches to health and healthcare, and by supporting Guy’s and St Thomas’ NHS Foundation Trust through a combination of fundraising and the Charity’s own philanthropic support.

Stanhope, alongside their investment advisor The Baupost Group, are a developer with over 30 year’ experience of working in partnership with communities, landowners, investors, occupiers, designers and contractors, and are experts in assembling, leading and delivering complex and successful mixed use developments.

Stanhope and The Baupost Group were recently selected by Guy’s and St Thomas’ Charity as the preferred Development Partner for the Royal Street site in the London Borough of Lambeth.

With regards to the development potential of the Royal Street site, the Charity, over the last 12 months, has engaged with the Council through its pre-application planning advice service. As part of these discussions, improvements to the public realm and the connections that could be made through the comprehensive redevelopment of the Royal Street site were discussed at length. With Stanhope and The Baupost Group selected as the development partner we welcome the opportunity to continue these strategic discussions with the Council and look forward to engaging in the detail in due course.

We submit this note to you in order to gain clarification on the following matters: 1. The relationship between the Royal Street Site and the A1 Thames Path/ Queens Walk spatial brief area. 2. Expected funding for spatial briefs C8 and D2. 3. The relationship between the Royal Street Site and spatial brief D3. 4. Details of the extent of the Charity’s ownership and the Royal Street site.

We respond against each head below. 207 The relationship between the Royal Street Site and the A1 Thames Path/ Queens Comment noted and addressed in the updated Guys and St Walk spatial brief area version of the PRF. Thomas’ Charity has been removed Spatial Brief A1 relates to an area of Riverside Walk on the eastern of the Thames as a key between Lambeth Bridge and Jubilee Gardens. stakeholder from The Matrix of Spatial Briefs on Pages 62 & 63 of the draft framework document spatial brief A1. identifies Guy’s and St Thomas’ Charity as a Key Stakeholder. Given the that Spatial Brief A1 is not connected to, and does not therefore directly relate to the Royal Guys and St Street site, we have assumed that the identification of the Charity as a key Thomas’ NHS stakeholder is in error and in fact this should relate to Guy’s and St Thomas’ NHS Foundation Trust Foundation Trust. We would welcome clarification on this matter. has been added as a key stakeholder Should we have incorrectly assumed that the Council had not meant to identify the to spatial brief A1. Charity we would welcome further discussions on this matter. 208 Expected funding for spatial briefs C8 and D2 Comment noted and addressed in the updated Royal Street added version of the PRF. to C8 as ‘proposed The Partnership fully support the delivery of Spatial Briefs C8 and D2. related development’ in The Matrix of Spatial Briefs identifies Guy’s and St Thomas’ Charity as a key the Matrix of stakeholder for both briefs but the proposed Royal Street development is only spatial briefs. identified within Brief D2. We assume that this is an oversight and the Royal Street project should be identified as a ‘proposed related development’ for C8 also.

209 Whilst supportive of these ambitions in principle, the Partnership is keen to gain a No material changes required to the PRF. N/A greater understanding of the Council’s intentions to fund such works and what is expected of ‘key stakeholders’. Given that the projects identified could be classified as infrastructure we trust they would be identified on the Council’s CIL Regulation 123 list. We would welcome further clarity on this matter. 210 The relationship between the Royal Street Site and spatial brief D3 Comment noted and addressed in the updated Royal Street version of the PRF. removed from D3 Spatial Brief D3 relates to ‘Green and open spaces within estates’. The estates as ‘proposed identified are Greenham Close, the Tanswell Estate and the William Blake Estate and related the brief is intended to transform these areas in to a set of dynamic, multi-use development’ in pocket parks while enhancing their function to the residential community and the Matrix of maintaining their local character. spatial briefs.

The Partnership supports the Council’s ambitions as set out. However, the Royal Oasis Academy Street site has been identified as a ‘proposed related development’ to Spatial Brief Johanna added to D3 within the matrix. Given the separation distances from the Royal Street site to D3 as ‘proposed these areas we would suggest that any link between the two is limited and there related should not therefore be any reliance on the Royal Street site to contribute to the development’ in delivery of these improvements. the Matrix of spatial briefs. 211 Details of the extent of the Charity’s ownership and the Royal Street site Comment noted and addressed in the updated GSTT boundary version of the PRF. updated on There are a number of occasions within the document where the land ownership of Development Guy’s and St Thomas’ Charity is not represented as accurately as it could be. Context map and Notably, Page 40, Figure 7 – Commercial and Strategic Stakeholders of the draft Commercial and framework identifies St Thomas’ Hospital as “Guy’s + St Thomas’ Charity + NHS Strategic Foundation Trust”. This is potentially misleading as the Charity and the NHS Stakeholders map. Foundation Trust are entirely separate entities and should be considered as such. In

this instance, the Charity should not be identified as a Commercial Stakeholder for the hospital site. Commercial and Strategic In order to clarify these matters please see the map appended which details the Stakeholders map land within the Charity’s ownership and which is being promoted by the Partnership updated with for re-development. correct stakeholder label for the We trust the above representations are clear and thank you again for considering hospital site. the points made. We look forward to engaging with the Council more extensively on such matters in the foreseeable future.

We would be grateful for confirmation of receipt of these representations. 98

Please do not hesitate to contact us on the details at the head of this letter should you require any further information. BFI 212 Tulley Bunting acts on behalf of BFI, which operates BFI Southbank and the IMAX. No material changes required to the PRF N/A We have reviewed the Waterloo and South Bank Public Realm Framework and have the following comments to make. We have also completed the online survey.

Background

The Strategy has been produced by Publica for LB Lambeth and provides an assessment of existing public realm and identifies opportunities for public realm improvements across the study area which is focused on the Bishops Ward.

The aim of the document is to provide direction on the various initiatives, identifying priority projects and informing the Local Plan process.

In the context of BFI Southbank and the IMAX, BFI supports the following relevant priority projects, subject to comments set out on these and other projects below:

Victory Arch Square – developer led (C1) Waterloo Bridge Undercroft – developer led (B5) Concert Hall Approach - council-led (B4)

BFI also supports the six guiding principles identified which focus on:

• Civic amenity and green infrastructure • Culture/heritage • Accessibility • Security • Maximizing positive impacts and minimising disruption • Design for future growth

In the introductory sections BFI Southbank is shown as having a ground floor mix of the following uses: arts/, offices, F&B, retail frontage (along Theatre Avenue). The IMAX is shown as being in arts/culture use.

The spaces around the BFI Southbank are shown as being global spaces (i.e. used by global/international audience), whilst the areas around the IMAX are shown as metropolitan/global, due to the importance of the routes for commuters, workers and visitors.

213 Various sites are identified for future development. The BFI Southbank is not The IMAX site has been identified as a potential tall Figure 8 – identified. The area around the IMAX is shown as a future public realm project – i.e. building site within the new Lambeth Local Plan. Development the Waterloo City Hub. The IMAX itself is not singled out for future development Context map has (although there is later reference to IMAX being a potential future development, see been amended to below). represent the IMAX as a building development that is identified as ‘potential / to be brought forward’ (page 44). 214 In terms of the function of the key routes through the area, Upper No material changes required to the PRF N/A Ground/Belvedere Road is shown as a metropolitan and global strategic connection, with Queens Walk shown as a global strategic connection. There are several more minor cross links to the river and station, including to Waterloo Bridge and Hungerford Bridge. The IMAX roundabout is shown as a key intersection.

215 Comments on Specific Projects The spatial brief for The Queen’s Walk focuses on N/A the section south of the London Eye, as this is Queens Walk where there is potential to improve connections from South Bank to Vauxhall and to enhance the Of the projects identified in the document the following are of direct relevance to immediate setting of the Westminster World BFI. We set out BFI’s comments in relation to each. Heritage Site.

Project A1 – Thames Path and Queens Walk. The project area is restricted to the area south and north of Westminster Bridge (including the area around County Hall) with the key aims including improvements to the underpass, wayfinding, lighting, accessibility, historical setting (including the World Heritage Site) and decluttering.

Whilst this project is supported by BFI, a key question remains concerning the treatment of the rest of Queens Walk, which in the document is identified as a global connection in its entirety. The public realm strategy is silent on any projects for the rest of Queens Walk. This includes several areas around the Southbank Centre, including the Hungerford Bridge undercroft and around BFI Southbank.

Many of the issues identified in the area around County Hall including proliferation of signage, wayfinding, placement of kiosks and temporary structures, lighting equally apply to the whole of Queens Walk, i.e. it would benefit from a comprehensive public realm strategy in its entirety.

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The Strategy recognises that Queens Walk is of global significance in its entirety and creates a key pedestrian route along the river linking all the arts/cultural institutions. It is a key route which would benefit from a consistency of approach and represents a significant opportunity for public realm improvements.

BFI thus considers there should be a family of projects for the Queens Walk global connection in its entirety, which has been the approach taken to the Belvedere Road and Upper Ground family of projects which encompasses several projects/areas along this “Spine Route” which is fully supported by BFI. 216 Belvedere Road and Upper Ground – the Spine Route Any public realm designs that come forward will be The following bullet subject to separate due diligence; in which, point has been BFI fully supports the Belvedere Road and Upper Ground family of projects (B conversations will be undertaken with interested added to guiding projects) which includes several spaces. Via a series of phased public realm parties, as well as dedicated design commissions principle 5: improvements, the projects seek to draw together all the cultural institutions along and statutory public consultation and the planning • Consider the the river with the station and Coin Street residential area. process, if required. operational requirements Of direct relevance to BFI are the following B projects. and opportunities Project B4 - Concert Hall Approach – Key aims include traffic calming with for freight and pedestrian and cycle priority, improved design quality of the HVM (vehicle bollards servicing outside Festival Hall), junction improvements and upgrades to wayfinding and consolidation lighting. within all future detailed The key issue here for BFI is to ensure that the current function of Belvedere designs. Road/Upper Ground is maintained as part of the traffic calming to maintain vehicle servicing access the existing facilities, including BFI Southbank. Therefore, BFI supports the aim which seeks to enhance strategic connections along Belvedere Road, at the same time as significantly upgrading the public realm. 217 Project B5 Waterloo Bridge Undercroft – Key aims include improved wayfinding, Any public realm designs that come forward will be N/A accessibility and urban character, creative lighting, decluttering, activation of the subject to separate due diligence; in which, undercroft, and material upgrades. conversations will be undertaken with interested parties, as well as dedicated design commissions BFI is shown as a key stakeholder in the context of the B5 site. The B5 site also and statutory public consultation and the planning includes reference to the Waterloo City Hub, Doon Street and the IMAX as part of process, if required. the consideration of this area.

The development of this area seeks to enhance the undercroft space, create active uses, and draw together adjacent developments including providing more active frontages along Upper Ground, which is supported.

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BFI supports the proposals which include improving the legibility of routes and level changes using creative signage, lighting and paving and reducing street clutter. The proposal to coordinate servicing, coach parking, bus routes and large deliveries is also supported; however, full servicing access must be maintained to BFI Southbank and IMAX.

The project assumes the Waterloo City Hub goes ahead with the objectives of that scheme delivered as part of the development of the area. BFI’s key priority in this area is to ensure that BFI Southbank and the IMAX enjoys full and enhanced accessibility and that this is not compromised by any emerging proposals. BFI has already engaged with TfL on the details of the City Hub scheme on this basis. On the basis that there is further engagement and consultation on the details of the B5 project, BFI supports the principles set out in the strategy. 218 Station Approaches No material changes required to the PRF N/A

C1 Victory Arch Square and Mepham Street is relevant to BFI. The key objectives for this area include rationalise the public realm to create a new public square and improve orientation and connections from Waterloo Station. The detail behind these objectives is supported including improving linkages through the railway arches to link to the Waterloo City Hub. The objectives for this area are supported in the context of improving linkages to Waterloo Station and dealing with the barriers that currently exist which restrict pedestrian movement and thus accessibility to key South Bank destinations, including BFI Southbank and the IMAX.

In conclusion there are no great surprises in this document although I do consider that further emphasis should be placed on the importance of Queens Walk and its improvement. The other projects include fairly predictable objectives, many of which should be supported.

Overall BFI is very supportive of the objectives and projects set out in the Waterloo and South Bank Public Realm Framework and is keen to engage further with the Council in relation to the proposed projects in the context of how BFI can contribute to delivering the projects and also to ensure that the operation and servicing of the existing BFI facilities is protected and enhanced as a result of the emerging proposals.

Please can you keep us informed on updates of the Waterloo and South Bank Public Realm Framework at the email address below.

If you have any queries do not hesitate to be in contact. 102

Environme 219 Thank you for consulting the Environment Agency on the above. To manage further The Framework is objective and evidence based. It N/A nt Agency intensification in the borough urban areas will require improvements to a range of is not a delivery plan providing guidance rather infrastructure and services to meet the additional needs and avoid detrimental than prescription. The management, maintenance effects on the quality of life and the environment. Capital funding sources must be and delivery of public realm improvements will be identified and a clear commitment shown to the provision of infrastructure before addressed through separate dedicated plans – new development is allowed to proceed so as to mitigate the impact and not make including the identification and application of any deficiencies worse. internal / external funding streams. 220 Waterloo and South Bank is bounded by the River Thames, the largest strategic The PRF context analysis highlights how the river N/A open space in London. For the most part, the council does not capitalise on its Thames is one of Waterloo and South Bank’s generous river frontage, despite the riverside walk being fairly continuous from greatest assets. Lambeth Palace to Battersea Park. There are, however, short stretches of the riverside where connection cannot be made along the river frontage and no Within the extent of the area covered by PRF the alternative routes are provided. riverside walk is continuous and suggestions are made for its enhancement.

In particular, improvements to the river frontage area are suggested in the spatial brief for the River Walk (A). 221 A key principle of the public realm strategy is to improve the quality, character and Comments acknowledged. N/A continuity of the Thames Path. Existing pockets of open space adjacent to the riverside would benefit from improved hard and soft landscaping, lighting and new Increasing and improving green infrastructure is street furniture. New development on the riverside should activate its edges and highlighted within Guiding Principle 1. deliver substantial public realm improvements that complement existing riverside activities, protect the ongoing operation of the wharves and enhance biodiversity. Substantial public realm improvements proposed through new developments will be navigated through site specific planning applications and will be required to complement existing riverside activities amongst other requirements. 222 We have attached more detailed comments below for your consideration. Please do The PRF aims to improve the quality and character N/A not hesitate to contact me should you wish to discuss this further. of streets and spaces across Waterloo and South Bank – including the Thames Path. This is reflected Guiding Principles within the guiding principles and spatial brief A1. Key issues a. To improve the quality, character and continuity of the Thames Path, Substantial public realm improvements proposed accepting that some areas will remain as safeguarded wharves through new developments will be navigated b. To improve access for communities facilities and opportunities within the through site specific planning applications and will area and to the river be required to complement existing riverside c. To ensure that each development delivers a good quality public realm on activities amongst other requirements. its own site and also contributes to the overall public realm strategy for the wider area 103

d. To deliver public realm improvements at Vauxhall that support the Vauxhall is not within the boundary scope of the emergence of a new urban area in terms of improved connectivity, PRF. increased footfall and transport interchange movements. e. To ensure that the public realm strategy links important community Increasing and supporting routes and connections facilities and places of interest including the riverfront, parks, schools, play within Waterloo and South Bank is key to the PRF. areas, shops, post offices, public transport and other social infrastructure such as health centres and childcare facilities within and outside. The integration of tall buildings will be navigated f. To ensure that tall buildings are fully integrated with the public realm through relevant planning applications on a case strategy and enable delivery of a high quality environment that is safe and by case basis. convenient for pedestrians and cyclists. 223 TE2100 Plan and the London Borough of Lambeth No material changes required to the PRF N/A There are high quality public paths on most of the frontage including the Albert Embankment and South Bank. The ground level in much of the floodplain is between 1 and 3m AOD whereas the level on the Thames frontage is generally higher (typically 4m AOD). The river walls consist of mainly masonry structures. The flood defence walls are generally small, typically 1m above local ground level, and some of the riverside paths are raised to flood defence level. 224 As the flood defences are improved it will be important to ensure that there is Any designs that will come forward will be subject N/A collaboration between adjacent council areas on the planning, design and to separate due diligence; in which, conversations construction of improvements to the flood defences and the riverside. When will be undertaken with interested parties, as well defences are raised, it is likely that footpaths and other public access will also as dedicated design commissions and statutory require raising in some areas. Actions involving cross-boundary working between public consultation and the planning process, if local councils should therefore consider the following: required.

• A consistent approach to improving the flood defences and the riverside at the boundary between the London Borough of Lambeth and the London Borough of Wandsworth at Nine Elms. • A consistent approach to improving the flood defences and the riverside at the boundary between the London Borough of Lambeth and the London Borough of Southwark near the Royal National Theatre, which is a very busy public thoroughfare. 225 Specific actions in the TE2100 Plan that refer to the London Borough of Lambeth Guiding principles 1, 2 and 3, align with the N/A are as follows: riverside strategy approach detailed in the • To maintain, enhance or replace the existing river defence walls/banks and flood Environment Agency response in relation to public control structures; realm. • To implement a programme of defence raising through central London in about 2065; Any designs that will come forward will be subject • To incorporate the Riverside Strategy concept into local plans, strategies and to separate due diligence; in which, conversations guidance documents; will be undertaken with interested parties, as well

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• To agree a programme of managing flooding from other sources in the defended as dedicated design commissions and statutory tidal floodplain; public consultation and the planning process, if • To inform the development and revision of local council strategic flood risk required. assessments (SFRAs) and flood plans; • To agree partnership arrangements and principles to ensure that new development in the tidal flood risk area is safe and where possible applies the NPPF to reduce the consequences of flooding; • To agree partnership arrangements for floodplain management; • To agree a programme of floodplain management. 226 Priorities Guiding principles 1, 2 and 3, align with the Further emphasis Riverside strategy approach riverside strategy approach detailed in the has been placed on The Thames Estuary 2100 Plan promotes a riverside strategy approach “to ensure Environment Agency response in relation to public the importance of that future changes to the riverside take place in a planned and integrated way realm. partnership which maximise the potential environmental, social, cultural and economic working to improve benefits.” Partnership working is also a key focus in the PRF the public realm in document and has been mentioned in additional the Waterloo and a. We would like a riverside that is accessible to everyone, enhances the sections of the updated report. South Bank area. In unique and varied environment of the Thames and protects from flood risk, particular, promoting sustainable growth throughout the estuary. partnership b. This supports the ambitions of the Government’s 25-year Environment working is Strategy by increasing the natural capital of the Thames, protecting against mentioned in the flood risk, and enhancing the value of the river to society. Foreword (pg. 5), c. But we can’t deliver this alone. To be successful, we need to work with the ‘Executive organisations who are shaping the riverside. This includes local planning Summary’ (pg. 6- authorities, developers, and other organisations with a planning remit, 13), ‘Commercial such as the Greater London Authority. and Strategic Stakeholders’ section (pg. 38-39), and in the new ‘Policy Context and Partnership Working’ section (pg. 40-41).

227 The aspirations of the riverside strategy approach Comment acknowledged. N/A • Flood defences are raised to the recommended height, as set out in the Plan, achieving our recommended flood risk policies Any designs that will come forward will be subject • Development is setback from the river, in order to provide space for to separate due diligence; in which, conversations maintenance, future raising of defences, people, and the environment will be undertaken with interested parties, as well as dedicated design commissions and statutory 105

• Land needed now or in the future for flood defences is identified and public consultation and the planning process, if available when required required. • Development is not negatively impacted by flood defences (now and as a result of future raising) through holistic and innovative design • Development is not encroaching into the river, ensuring no loss of flood storage capacity and negative impacts upon important estuarine habitats • The riverside best serves the needs of its communities and the environment, providing integrated environmental, social, cultural and economic benefits. Intertidal habitat across the Estuary is created where appropriate • The Thames and its riverside provides increased natural capital and supports local authorities’ growth ambitions to be delivered in a sustainable way • Local communities and river users have high quality and un-interrupted access to the riverside, with a Thames Path running continuously along the Estuary 228 Partnership Comments acknowledged. No material changes are N/A The role Environment Agency required to PRF. We are committed to helping our partners deliver the riverside strategy approach. We are able to help you develop, promote and implement it, and we will commit our time and effort to do so. More specifically, we can: • Advise where defences will need to be raised in the future, by what time and to what height • Advise on where land is required for our inspection and maintenance of flood defences, including flood walls and flood gates • Advise on where land is required for other flood risk management purposes such as a future Thames Barrier or to provide intertidal habitat creation for biodiversity and flood management benefits • Provide a facilitation role to support the development of strategies and implementation of the approach (i.e. running of workshops to enable partners start thinking about this approach) • Advise where works to defences are likely to take place under the Thames Estuary Asset Management 2100 (TEAM2100) current programme of works • Help to co-ordinate conversations between councils where their riverside visions meet • Seek and create opportunities for partnership working to develop shared visions for the riverside with stakeholders such as; the Greater London Authority, local planning authorities and landowners. • Share successes from elsewhere in the Estuary

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229 Choices for improving the flood defences Comments acknowledged. N/A There are opportunities to create a better place when new flood risk management interventions are implemented. The following are suggested requirements for When new flood risk management interventions creating a better place: are implemented, individual sites will need to take • There is continuous public access along the defences in areas where public this information / guidance onboard when specific access is possible. design proposals come forward. • Where defences are raised, adjacent public footpaths are also raised so that views of the estuary are not affected. Access to the defences is linked Spatial brief A1: Thames Path and The Queen’s with public open spaces including parks and pedestrian precincts. Walk includes: • Access to public jetties and the foreshore is improved, and raised defences ‘Ensure that future infrastructure improvements, do not adversely affect river users. such as flood defences, prioritise the role of the • Good access to viewpoints and heritage sites is provided. Embankment as a public space within London’s • The river frontage can be improved including the creation of high quality urban landscape. public open space and better access. • River frontage buildings are integrated into the flood defences in an environmentally sensitive way • The defences enhance the landscape. Consideration should be given to providing sloping frontages when defences are improved, and reduce dependence on vertical walls. • Where riverside areas are redeveloped, opportunities are taken to enhance the appearance and public realm of the riverside. • Opportunities can be taken for habitat creation. • Defences have space for inspection, maintenance and future upgrading. Please be aware that any works within 16 metres of the landward extent of the defence may require a Flood Risk Activity Permit (FRAP). For further information on FRAPs, please visit: https://www.gov.uk/guidance/flood-risk-activities- environmental-permits or contact our Partnership and Strategic Overview team at the following email address: PSO.SELondonandNKent@environment- agency.gov.uk Connect 230 On behalf of our client, Harmony Properties (UK) Limited, Grandseal Limited and No material changes required to the PRF N/A Properties Connect Properties Limited (Bourne Capital), the owners of the above properties, Limited we wish to make representations pursuant to the draft Waterloo and South Bank (Bourne Public Realm Framework. Capital) Our client’s site comprises the above properties, collectively known as the Waterloo Estate, currently accommodates office, retail and leisure uses and presents a significant development opportunity to extend and improve the employment floorspace, provide enhanced retail opportunities, and improve the public realm through enhancements to Emma Cons Gardens and a new public through-route from Waterloo Road to Cornwall Road. 107

These representations are made pursuant to the Public Realm Principles and the spatial briefs for both Emma Cons Gardens and Cornwall Road.

Context Our client supports the recognition of Emma Cons Gardens as being a key gateway into Waterloo, a strategic location and a pivotal space to draw together the different areas of Waterloo.

Our client is also pleased to be recognised as a key stakeholder for influencing and delivering public realm improvements within Waterloo.

Public Realm Principles Our client is broadly supportive of public realm principles 3, 5 and 6 which seek to improve pedestrian space and connections, maximise the positive impacts of development and relocate parking/servicing off-road.

Emma Cons Gardens and Cornwall Road Spatial Briefs Our client is broadly supportive of the spatial briefs for both Emma Cons Gardens and Cornwall Road and consider that the proposed development at Waterloo Estate can act as a catalyst to help bring forward the envisioned public realm improvements.

Concluding Remarks In conclusion, our client is broadly supportive of the draft Waterloo and South Bank Public Realm Framework and consider the proposed development at Waterloo Estate the catalyst to help bring the above anticipated public realm improvements forward.

We look forward to receiving acknowledgement of these representations and request that we be notified of further opportunities to comment on the draft Waterloo and South Bank Public Realm Framework accordingly. If you require any further information or clarification on these representations, please contact Barnaby Collins or Daniella Marrocco at this office. Southbank 231 We are writing on behalf Southbank Centre (SC) in response to the Draft Waterloo No material changes required to the PRF N/A Centre and South Bank Public Realm Framework consultation.

Southbank Centre is located within Bishop’s Ward, Lambeth and this area is the focus for the Draft Public Realm Framework. The 5.3 hectare site is one of the UK’s leading international cultural and tourist destinations. Southbank Centre is also one 108

of the largest land owners within the area. It is within this context that Southbank Centre recognise the importance of the Draft Public Realm Framework and welcomes the opportunity to comment on this important local planning policy document. 232 It is understood that once adopted, this Draft Public Realm Framework will be used The PRF provides non-statutory strategic guidance Additional to inform Lambeth’s Local Plan Review, although the document does not explicitly to help direct future investment and improvement references to refer to the Local Plan. in the Bishop’s ward area. Lambeth’s revised Local Plan have been included, for example: • Foreword (pg. 5) • Executive Summary (pages 6, 11, 12) • Introduction (pg. 15) • Context (pg. 17) • Policy Context and Partnership Working (pg. 40) • Guiding Principles 233 We have recently submitted representations on behalf of SC on the Draft Revised No material changes required to the PRF N/A Lambeth Local Plan October 2018 and South Bank and Waterloo Neighbourhood Plan 2017 – 2032 consultations.

1) Background

Southbank Centre is a world-famous, multi-venue arts centre providing year-round arts and culture events and programming. The site includes the Grade I Royal Festival Hall, the Queen Elizabeth Hall, Purcell Room, Hayward Gallery and the National Poetry Library. SC’s wider estate also includes land at the Hungerford Car Park and land beneath the Waterloo Bridge / IMAX roundabout.

Approximately 27 million people a year visit the site to experience the 5,000+ events that Southbank Centre host, featuring artists from around the world. SC employ approximately 500 people across a range of different professions and work in conjunction with over 1,000 artists on an annual basis. In 2018 it was the country’s fifth most popular visitor attraction with a 32% increase in visitors from

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the previous year, following the re-opening of the Hayward Gallery, Queen Elizabeth Hall and Purcell Room.

In addition to the core arts and cultural facilities, the site also comprises a number of complementary uses that contribute to the site as an international tourist destination, such as restaurants, shops and public realm.

As you will be aware, SC work meticulously to maintain and improve their estate, including the public realm spaces between the buildings, despite continued budgets cuts across the last few years. Consequently, SC welcome the preparation of the Draft Public Realm Framework and the proposed visions for improving the public realm areas in and around the SC estate.

The structure of this letter is informed by the consultation survey questions on the Council’s website, but it only reviews and comments on the proposals that relate directly to SC and their interests. It is understood that South Bank Employers’ Group (SBEG) will be providing separate comments that relate to the whole document on behalf of the organisations it represents. 234 2) Guiding Principles No material changes required to the PRF N/A SC support the six Guiding Principles around which the Draft Public Realm Framework is structured. Given SC’s importance as a national arts and culture destination and its strong heritage links, SC strongly support the principle to “celebrate and protect culture, heritage, and design excellence”. 235 3) Coverage and Spatial Briefs Comment acknowledged and considered. The N/A coverage of the Thames Path and Queen’s Walk The Draft Public Realm Framework identifies 18 public realm projects across four has not been extended as this section is able to ‘families’ and SC largely supports the area coverage as illustrated on Figure 10 focus on the spaces south of the London Eye, as ‘Spatial Briefs’. There are four projects which are of particular relevance to SC this is where there is potential to improve include: connections from South Bank to Vauxhall and to enhance the immediate setting of the Westminster • A1 – Thames Path and the Queen’s Walk World Heritage Site. • B3 – Belvedere Road at Jubilee Gardens • B4 – Concert Hall Approach • B5 – Waterloo Bridge Undercroft

In general, SC considers it important for the Framework to have sufficient regard for the strategic function and importance of the public realm in this area. The Framework provides an opportunity to help facilitate fundamental improvements to these areas (e.g. Concert Hall Approach) which should be fully realised.

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SC are supportive of the design principles outlined in spatial brief A1 (Thames Path and Queen’s Walk), although consider there to be an opportunity to extend the coverage along the full length of Queen’s Walk, including the section within the SC estate.

The ‘B’ family of projects relating to ‘Belvedere Road and Upper Ground’ are most relevant to SC and include land within SC’s ownership. As such, SC have several comments relating to the coverage and detailed wording of the spatial briefs that they wish to highlight. These are summarised in the table below: 236 Comment acknowledged and considered. The N/A Spatial Area A1 (Thames Path and the Queen’s Walk) coverage of the Thames Path and Queen’s Walk Page 60: Figure 10 ‘Spatial Briefs’ has not been extended as this section is able to As you will be aware, the Thames Path and the Queen’s Walk extends along the focus on the spaces south of the London Eye, as whole length of the River Thames frontage within the identified study area. this is where there is potential to improve However, despite this, Figure 10 illustrates spatial brief A1 as only relevant to the connections from South Bank to Vauxhall and to section of Queen’s Walk between St Mary’s Garden and the London Eye (adjacent to enhance the immediate setting of the Westminster Jubilee Gardens). The section of the Queen’s Walk along the front of the Jubilee World Heritage Site. Gardens, between Hungerford Bridge / Golden Jubilee Bridge and Waterloo Bridge, and between Waterloo Bridge and Blackfriars Bridge has been excluded from spatial brief A1.

Given the discussions that have taken place with Lambeth over the past few years regarding the Queen’s Walk during the consideration of applications for summer and winter events at SC, it is surprising that the section of Queen’s Walk between Hungerford Bridge / Golden Jubilee Bridge and Waterloo Bridge has been omitted from this spatial brief. SC suggest and would support the extension of the spatial brief A1 area so that it covers the full length of Queen’s Walk including the section along the front of Southbank Centre’s estate, given the strategic importance of this key pedestrian route. 237 Spatial Area B3 (Belvedere Road at Jubilee Gardens) Comment acknowledged. Content within Page 72: “Explore options to create a new pedestrian route connecting South Bank spatial brief B3 with Waterloo Station through Southbank Place along the railway viaduct.” The Low Line concept links existing centres of activity amended to: and enterprise by creating new attractive routes ‘Explore the This proposed pedestrian route cannot be sited along the railway viaduct as this alongside rail arches and viaducts and their associated potential for area is owned by SC and is the principal service road for the SC estate. SC are spaces and streets. improved access supportive of the principle of a pedestrian route linking Waterloo Station and between South the South Bank, but the proposed alignment would need to be routed through The Low Line routes will facilitate economic growth Bank and Waterloo publicly accessible areas, consistent with the broader objectives for extending and improve access and permeability along the rail Station along the Jubilee Gardens. viaducts and will be referenced as policy within the railway viaduct as a Draft Revised Lambeth Local Plan. continuation of the 111

Low Line that runs The Low Line will be a new walking destination for from London London along the length of the mighty Victorian rail Bridge. Consider viaducts spanning Bankside, London Bridge and activating the Bermondsey. It will connect diverse neighbourhoods railway arches and communities in south London, linking existing and lining this route, for new hubs of creativity, entertainment, and industry example through along its course. The Low Line celebrates the heritage partnerships with of the railway arches which have been a part of the cultural area for over 150 years, shaping places of interest institutions.’ along the way and unlocking their potential. 238 Page 72: “Consider activating the railway arches lining this route, for example Comment acknowledged. Content within through partnerships with cultural institutions.” spatial brief B3 amended to: SC have already considered the activation of the railway arches. The arches are used ‘Explore the to meet SC’s operational and servicing requirements including production get- potential for ins/get-outs for performances, outside broadcast trucks, catering deliveries, waste improved access management. Fire exits doors from Level 2 catering units are also in this area. As between South part of the management of the area, all pedestrian users have to wear high-visibility Bank and Waterloo clothing for safety reasons. Station along the railway viaduct as a continuation of the Low Line that runs from London Bridge. Consider activating the railway arches lining this route, for example through partnerships with cultural institutions.’ 239 Page 72: “With reference to recommendations in the Draft Lambeth Local Plan, Comment acknowledged. Proposals to amend Content within explore opportunities to ensure that any new public space on the area of Hungerford elements of this brief have been received during spatial brief B3 Car Park that is Metropolitan Open Land integrates with the distinctive sequence public consultation and will be incorporated. amended to: spaces along this section of South Bank. In particular, explore way to create ‘With reference to distinction between the Jubilee Gardens and proposals for its extension.” Lambeth have also aligned this spatial brief with policy in the Draft the updated information agreed for inclusion Revised Lambeth This statement is in direct conflict with adopted and emerging Local Plan policy within the Draft Revised Lambeth Local Plan to Local Plan, ensure which seeks a “coherent public space of metropolitan value” through the extension reflect policy. that the area of 112

of the gardens onto Hungerford Car Park. The proposals for Jubilee Gardens are to Hungerford Car extend the existing Gardens and integrate the extended part within the existing Park that is part, not to create a distinction. SC suggest this wording is amended to reflect Local Metropolitan Open Plan policy. Land (MOL) is used to extend Jubilee Gardens, creating a new public space that seamlessly integrates within the existing garden.’ 240 Page 72: Image on the right Comment acknowledged. The image in question has been SC query the inclusion of this image as it shows the area SC service road for the SC replaced with one estate. Access is restricted to this area and pedestrians are not encouraged to use at Jubilee Gardens this route to access the South Bank. As such, SC suggest that this image is removed, – providing views of and a better image may be the front of the arches. adjacent attractions, such as the London Eye and the Westminster World Heritage Site. 241 Spatial Area B4 (Concert Hall Approach) No material changes required to the PRF N/A Page 73: “Explore options to upgrade the public realm as appropriate to its use as a local, metropolitan and global route, in line with the proposed improvements to Waterloo City Hub.”

SC are particularly supportive of this point and Lambeth’s vision to consider the proposed projects strategically, i.e. linking improvements to Concert Hall Approach with the Waterloo City Hub improvements.

242 Page 73: “Consider removing or repurposing existing flagpoles along Concert Hall Comment acknowledged, however, Publica and N/A Approach as part of this strategy to enhance the view towards the Festival Hall.” Lambeth Council agree that whilst consistent with the historic festive character of the area, the flagpoles The flagpoles referenced here belong to SBEG. The flags add visual interest to the currently obstruct and mitigate the view and sense of Concert Hall Approach consistent with the historic festive character of the area, and arrival of the river front and Festival Hall. assist in advertising the arts and culture programme on offer at the South Bank. As such, SC object to this wording and would request that this is removed. This bullet point is a recommendation set to inform the development of future public realm proposals and 113

designs, providing a starting point for local stakeholders considering next steps. 243 Page 73: “Explore opportunities to enhance the relationship between the Comment acknowledged. Lambeth Council is currently N/A Whitehouse Apartments garden with the surrounding streets. In collaboration with pursuing an enforcement case regarding the S106 stakeholders, consider ways to improve views into the space, such as improved agreement to open the Whitehouse Apartments planting along its borders.” gardens to the public.

SC strongly endorse proposals to enhance the relationship between Whitehouse Apartments garden with the surrounding area. It is understood through a Section 106 agreement that this area was due to be open for public access. To date, it appears to remain segregated from the surrounding public realm. SC are keen to see this public realm asset integrated into the streetscape, and that removal of the existing railings is given careful consideration. 244 Page 73 (General Comment) No material changes required to the PRF N/A Aside from the comment regarding the flagpoles, SC strongly support the Concert Hall Approach Spatial Brief and are pleased that this project has been selected as a priority to be taken forward immediately. 245 Page 94: Figure 15 ‘Overview of Example Projects’ No material changes required to the PRF N/A SC support the extent of the project illustrated on Figure 15. Figure 15 identifies a larger area along Concert Hall Approach (including the Whitehouse Apartments garden) which is key to providing comprehensive improvements and realising the full potential of this space. 246 Pages 94 – 103: Concert Hall Approach Illustrative Concept Design Comment acknowledged and considered. Figure 8 – Development Context Given the immediate proximity of this location to SC, the reliance on some land map has been which is within SC’s ownership, the importance of this area of public realm and the amended to represent need to improve it substantially, SC is keen to work with LBL and other stakeholders the IMAX as a building to ensure that the design of Concert Hall Approach is progressed suitably and development that is realises the full potential of this area. identified as ‘potential / to be brought Spatial Area B5 (Waterloo Bridge Undercroft) forward’ (page 44). Page 60: Figure 10 ‘Spatial Briefs’ In terms of spatial brief B5, it is apparent from the text within the Draft Public Realm Framework that this project includes the IMAX site on the roundabout at the convergence point of Waterloo Road, York Road, Stamford Street and Waterloo Bridge. However, Figure 10 ‘Spatial Briefs’ does not include the IMAX within the blue area coverage indicated for spatial brief B5.

SC suggest that the coverage of spatial brief B5 should be extended on Figure 10 (and any other relevant plans / references) to accurately illustrate the full extent of 114

the brief and to ensure that the importance of the IMAX site is recognised in the implementation and delivery of this project. The ‘blue area’ should include all of the pedestrian undercroft up to and around the IMAX. 247 Page 74: “Investigate opportunities to provide active uses within the existing Comment acknowledged. Spatial brief B5 – undercroft units that prioritise creative and digital businesses and affordable, Waterloo Bridge innovative workspaces.” Language was amended to include rather than Undercroft amended SC endorse the provision of active uses within the existing undercroft units but prioritise these uses. to: consider it not appropriate to prioritise creative and digital businesses. The units ‘Investigate should be promoted generally for active uses and businesses that are considered Creative and digital businesses are important to the opportunities to appropriate for this location; therefore, flexibility should be retained with regard to borough, hence Lambeth’s Creative and Digital provide active uses use to enable to space to develop organically. Industries Strategy which supports affordable within the existing workspace for start-ups and SME’s. undercroft units that include creative and digital businesses and affordable, innovative workspaces.’ 248 Page 74 (General Comment) No material changes required to the PRF N/A Aside from the above comment, SC support the design principles identified in relation to the Waterloo Bridge Undercroft. 249 4) Priorities The Framework is objective and evidence based. It is N/A not a delivery plan providing guidance rather than SC are supportive of the inclusion of Concert Hall Approach as one of the two prescription. The management, maintenance and priority projects identified to be taken forward immediately. In view of this delivery of public realm improvements will be immediate timeframe for progressing the Concert Hall Approach project, SC would addressed through separate dedicated plans. be keen to understand how the proposed works are being funded and what Lambeth’s next steps are for delivering and implementing these works.

SC are also pleased that Waterloo Bridge Undercroft, which we consider to link in with the Concert Hall Approach proposals, is also identified as a priority project. Unlike Concert Hall Approach, there are no timescales indicating when Lambeth expect to be able to bring forward the Waterloo Bridge Undercroft improvements.

There generally seems to be an absence of information within the Draft Public Realm Framework relating to funding and the timescales for delivering these identified projects. Without this information, there could be a danger that the document appears to be aspirational since it is unclear how and when these projects will be implemented, and who will be responsible for obtaining the necessary statutory approvals (e.g. planning permission) and delivering the projects. Given the importance of public realm in this area, and the high levels of footfall, SC is keen to work with the Council and other stakeholders to ensure that the public 115

realm is managed in a proper and befitting way, with due consideration given to operational implications for SC’s estate, including additional management costs, potential traffic / delivery disruptions etc.

SC would welcome the inclusion of timetable that identifies the anticipated commencement dates for each of the projects, as this would enable SC to plan for any potential disruptions. In addition, more detail should be included within the Framework relating to how the Council is intending to fund these projects in order to demonstrate that the projects are deliverable. 250 5) Partnership and Delivery No material changes required to the PRF. N/A

The Draft Public Realm Framework survey identifies that improvements to the public realm cannot be delivered by a single body alone. It recognises that collaborative partnership working is necessary to deliver investment and improvement. As identified above, SC are one of the largest land owners within the study area and, as such, are keen to support and assist in the delivery of these projects where possible. However, given the significant reductions in arts funding, SC is also reliant on utilising funding streams available to the Council and other stakeholders, for example in relation to new and improved hostile vehicle mitigation measures.

To date, SC have not been directly consulted about the public realm proposals, despite some of these projects including land within their ownership. Therefore, SC are keen to pursue discussions with Lambeth prior to any improvements being agreed or implemented to ensure that their aspirations align.

As an important stakeholder in the Waterloo and South Bank area, Southbank Centre are encouraged by the content of the Draft Waterloo and South Bank Public Realm Framework and are eager to engage further with the Council and its consultants to help realise the potential of this special area.

We would be very pleased to meet with you to discuss these matters further and provide any further information to assist this important work. Historic 251 Thank you for consulting Historic England on the proposed framework to improve No material changes required to the PRF N/A England the public experience of the roads and footways around Waterloo.

As the Government’s advisor on the historic environment, Historic England is keen to ensure that the conservation and enhancement of the historic environment is fully taken into account when considering works to the public realm. Accordingly, we have reviewed this consultation in the context of the National Planning Policy 116

Framework (NPPF) and its core principle that heritage assets be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations. Having done this, Historic England can offer the following advice. 252 General advice No material changes required to the PRF N/A The initiative is welcomed and will help promote economic vitality and a safer, healthier and attractive environment. Many of the target areas have suffered from the on-going impacts of extensive development and heavy traffic, and while increased visitor numbers and footfall have generated greater opportunities they have also placed pressure on the public realm and existing communities.

As one of London’s busiest gateways and the hub of other transport opportunities including foot, bus, or bicycle, the current condition of much of the public realm does not always encourage or provide a positive experience. Recent initiatives underpinning the emerging London Plan, such as Healthy Streets and the Transport Strategy provide a stronger framework for tackling health and wellbeing through accessibility. Historic England supports these aims and the importance of access to culture and heritage and the wider benefits this can bring. We are therefore keen to promote the identification and initiatives to enhance the setting and enjoyment of heritage assets and the historic environment. Our approach to public realm and the historic environment, including examples of best practice, are set out in our Streets for All Advice. https://historicengland.org.uk/images-books/publications/streets- for-all/heag149-sfa-national/

With this in mind we have the following observations and recommendations: 253 We greatly welcome Guiding Principle 2. Celebrate and Protect Culture, Heritage Comment acknowledged. Ultimately, any designs that N/A and Design Excellence. However, our principle observation is that the Framework come forward for individual sites will be subject to should be based on a sound and up to date understanding of the areas development separate due diligence; in which, conversations will be and its designated and undesignated historic resources and local character. We note undertaken with interested parties, as well as that the borough’s current evidence base for the historic environment, in respect of dedicated evidence gathering, design commissions, relevant conservation area appraisals, is now increasingly dated and it is unclear to statutory public consultation and the planning what extent the Framework has been supplemented by new analysis (beyond Fig 01 process, if required. in the Appendix). We would therefore recommend that in developing site specific schemes, existing heritage assets and the opportunities to enhance local character and distinctiveness are identified and updated at the earliest stage. 254 There is a clear potential for the Framework to set out a methodology for applying Comments acknowledged. N/A the six guiding principles, including identifying the significance of heritage assets affected, local character and the contribution made by their setting. This can then be used to consider how and where the public realm can incorporate and enhance the significance of heritage assets, local character, and encourage cultural activity. 117

In addition, the Borough may wish to consider developing a Heritage Interpretation Strategy for the proposed Public Realm Framework. This approach has been successfully implemented as one of the requirements for the delivery of the Thames Tideway Tunnel, informing both the public realm and the site specific public art strategy. The Interpretation Strategy sets out the requirements for the associated public realm schemes but also a matrix of historic information and themes which can be drawn upon to enrich understanding and interpretation.

The Strategy can be viewed here. https://www.tideway.london/benefits/art-on- the-tideway/.

While the proposed Framework does suggest this approach in respect of the commemoration of Emma Cons, it is unclear to what extent analysis underpins the illustrative precedents. Setting out the wider and site specific themes would help identify local characteristics and also inform schemes as they develop. Such themes can cover the wider relationship to Palace of Westminster WHS, local significance, and archaeology such as the Civil War fortifications. 255 Not within scope of the PRF. N/A We would also suggest reference to the areas archaeological legacy and the requirements for new development in respect of the Archaeological Priority Areas. https://historicengland.org.uk/services-skills/our-planning-services/greater-london- archaeology-advisory-service/greater-london-archaeological-priority-areas/ 256 We hope you find the above comments helpful in developing the planning No material changes required to the PRF N/A framework.

We would like to stress that this opinion is based on the information provided by you. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, where Historic England consider it appropriate to do so.

In the meantime, if you have any queries in respect of this response please do not hesitate to contact me. Natural 257 Thank you for your consultation on the above Strategic Planning Consultation, dated No material changes required to the PRF N/A England 26th March 2019. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

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Natural England have no comments to make on this consultation.

For any new consultations, or to provide further information on this consultation please send your correspondences to [email protected] Coin 258 Coin Street Community Builders No material changes required to the PRF N/A Street 1. Coin Street Community Builders (CSCB) is a company limited by guarantee Communit established by local residents in 1984. The company is controlled by a Board, y Builders elected by CSCB members. Only people living locally can become CSCB members. The Board employs staff to manage the company on a day to day basis. Profits are not distributed but are ploughed back into CSCB’s public service objective. 259 2. CSCB has transformed a largely derelict 13-acre site into a thriving mixed-use No material changes required to the PRF N/A neighbourhood by creating new co-operative homes; shops, galleries, restaurants, cafes and bars; a park and riverside walkway; and sports and community facilities - including a neighbourhood centre. It organises festivals, markets and events; provides childcare, family support, youth and community programmes, 1:1 advice, and training and employment opportunities. Income is generated from a variety of sources including leasing property, venue hire, fees for services, and managing businesses – including conferences, a gallery, and joint ventures. 260 3. CSCB manages and maintains the South Bank riverside walkway between the No material changes required to the PRF N/A National Theatre and Sea Containers House as well as Bernie Spain Gardens and other areas of public realm. It is a founder member of South Bank Employers’ Group, Jubilee Gardens Trust, South Bank BID, South Bank & Waterloo Neighbours (SoWN), and a number of collaborative local organisations. 261 4. Current development projects include the consented Doon Street mixed No material changes required to the PRF N/A development which incorporates the completed Rambert headquarters and dance studios, housing and a public swimming and indoor leisure centre, and an office and new town square. Following public consultation and a landscape design competition, CSCB submitted in December 2018 plans for the re-landscaping of Bernie Spain Gardens north and Queen’s Walk Gardens (between the riverside walkway and the former London Television Centre). Planning consent for these works was granted by Lambeth on 17 April this year. Since 2012 CSCB has also been developing proposals for the redevelopment of Prince’s Wharf and Gabriel’s Wharf. 262 5. CSCB has considerable experience of designing, managing and maintaining public No material changes required to the PRF N/A realm on the South Bank – and not only on its own site. CSCB project managed (before South Bank Employers’ Group employed staff) the original Llewelyn-Davies South Bank Environmental Improvement Project published in 1994. This report set out an urban design strategy for the wider South Bank, including 33 costed projects capable of being implemented as land and resources became available. In response to an invitation from the newly-formed Government Office for London, CSCB put together a bid to Government, major businesses based on the South Bank, and 119

others for contributions towards selected priority projects. Lambeth Council also selected projects from the report for its bid under the first round of the Single Regeneration Budget. These bids were successful and the majority of the 33 projects were subsequently implemented. The basis of this success was widespread consultation, collaboration and partnership between public, private and community organisations, and recognition that different stakeholders had different priorities but all could be mobilised in pursuit of a shared vision for the area. 263 Summary of CSCB’s responses to the draft Public Realm Framework The Public Realm Framework takes into consideration N/A 5. Lambeth Council’s interest in the Waterloo and South Bank public realm is the existing context of Waterloo and South Bank, greatly welcomed but this draft framework is deeply flawed: including its open green spaces, its architectural heritage and the experience of the area at night. • The definition of public realm is perverse: parks appear not to be included whereas ‘publicly-accessible indoor spaces’ apparently are. The draft framework The management of this project followed adequate claims to be evidence-based but it is not. There is a serious disconnect between project management processes. what local people say they want and what the consultants propose. • The management of this project fails to follow basic project management The consultants were appointed as a result of a processes. competitive tender process in line with Lambeth’s best • The suitability of the consultants and their proposed solutions are questioned. practice and procurement guidelines. 264 7. In paragraph 20, CSCB sets out its own priorities, and then suggests how a No material changes required to the PRF N/A framework with greater local support and engagement might be achieved. 265 What is meant by ‘public realm’? No material changes required to the PRF N/A 8. Publicly-accessible parks and gardens where people can relax away from traffic noise and fumes are highly valued by local residents, local workers – particularly during lunchtimes and after work, and visitors. Properly managed, they are probably one of the key components of an ‘attractive area’. There is certainly evidence [City of London: a global leader symposium, September 2018] that decisions on where large businesses locate are increasingly taken on the attractiveness of an area and its local facilities – particularly parks – rather than the qualities of a building. This is because of intense competition for ‘millennials’ - who now form the overwhelming majority of new recruits. 266 9. When people ask for ‘green spaces’ they usually mean more than hard- The Public Realm Framework takes into consideration N/A landscaped areas with some planters, and more than street pavements with an the existing context of Waterloo and South Bank, occasional tree. ‘Greening’ of roofs and along heavily trafficked roads to improve air including its open green spaces, its architectural quality is certainly welcome but does not substitute for parks and gardens where heritage and the experience of the area at night. local residents, workers (including students), and visitors can go to relax and enjoy. But the draft framework appears not to recognise parks and gardens as public realm: the need to improve and extend these green spaces is overlooked and all the attention is given to ‘Routes between local green spaces’ (p11) and how to ‘connect’ them (p92) as if touring local green spaces was a regular habit of users – whether local, metropolitan or global. 120

267 10. When we look at the first ‘guiding principle’ advanced by the draft framework The Public Realm Framework takes into consideration First tactic within we find that, although parks and gardens apparently do not qualify as public realm, the existing context of Waterloo and South Bank, Guiding Principle 1 ‘public and publicly-accessible indoor spaces’ apparently do (p47). Somehow ‘civic including its open green spaces, its architectural amended to: amenity and green infrastructure’ excludes parks and gardens but includes indoor heritage and the experience of the area at night. ‘Promote a variety of spaces: a perverse interpretation of public realm bound to cause confusion. It is greening initiatives unlikely that the 37% of responses reported as falling into the ‘improving green and Green infrastructure is a network of multi-functional such as sustainable open spaces, and supporting air quality projects’ category (p43) had in mind indoor green space and other green features, urban and rural drainage systems spaces. Anyone with even a passing understanding of local concerns would know which can deliver quality of life and environmental (SuDS) and the the value people attach to improving and extending parks and gardens and other benefits to communities. Green infrastructure includes creation and truly ‘green’ spaces. It would be easy to assume that guiding principle 1 was parks, open spaces, playing fields, woodlands – and enhancement of public referring to such projects but amazingly it does not and none of the 18 proposed also street trees, allotments, private gardens, green amenity spaces across future projects respond to those concerns. Although claiming to be ‘evidence roofs and walls, sustainable drainage systems (SuDS) the area to create a based’, the recommendations are anything but: there is a serious disconnect and soils. It includes rivers, streams, canals and other more welcoming and between what local people say they want and what the consultants propose. water bodies, sometimes called ‘blue infrastructure’. vibrant place to visit, live and work.’ 268 Failure to follow basic project management processes. Comment acknowledged. Clarity on the scope 11. It is not clear from the main report what the brief and scope of the study was and brief has been and whether these had been discussed with stakeholders. It may be that the brief The Public Realm Framework takes into consideration further addressed excluded parks and gardens from the definition of ‘public realm’ but it would be the existing context of Waterloo and South Bank, throughout the helpful if future studies of this kind could involve local stakeholders – particular local including its open green spaces, its architectural Executive Summary community groups and land owners – at the start of the process. heritage and the experience of the area at night. and Introduction. 269 12. It would be better to involve landowners and immediate neighbours in the The Council and Publica undertook collaborative N/A evolution of projects so that their input is taken into account at that stage rather engagement with strategic / commercial stakeholders than in a general public consultation after a draft report has been published. Such a and the public within earlier phases of the project process is more likely to offer insights and opportunities that speed implementation prior to the six-week public consultation. and avoid much frustration and wasted time. The project team ensured that the very broad range of comments received were reflected within the PRF. Invariably, this required the exercise of judgement in assessing and accommodating sometimes competing comments.

Earlier engagement comprised: • 17 face-to-face meetings with strategic / commercial stakeholders. The project team asked each stakeholder within the invitation and the meeting itself to submit any evidence to support the Framework and provide additional feedback to the team about their aspirations, plans and recommendations. 121

• Three community ‘drop-in’ sessions were organised to capture local resident’s views at a neighbourhood level. Sessions were promoted via the council’s website and social media, with emails sent to stakeholders requesting support in sharing with their networks. Forty-four people attended the three sessions. • Engagement with landowners, businesses and partners was also undertaken within the scope of Waterloo Steering Groups and Waterloo Strategic Forums. 270 13. It is clear that certain opportunities should have led to more holistic studies: The concept design for Coral Street is intended as high The drawings for there is little point in developing a scheme for landscaping the spur road in Coral level, indicative and illustrative interventions only, spatial brief D1 have Street without a clearer context for what is proposed at Millennium Green, The representing Publica’s recommendations and been updated to Living Space, and (perhaps Johanna primary school). professional advice for the site. This is not a design reflect BOST’s proposal per se. Millennium Green masterplan. Caption Any designs that come forward for ‘example projects’ now reads: ‘3D (such as Coral Street) will be subject to separate due drawing of the baseline diligence; in which, conversations will be undertaken proposals for Coral with interested parties, as well as dedicated design Street, showing a commissions and statutory public consultation and the pedestrian-priority planning process, if required. route, child-friendly crossings and a It is acknowledged that the status of the concept reconfigured entrance designs could have been made clearer. This will be into Waterloo addressed in the update. Millennium Green, including the indicative Further details on Millennium Green masterplan are proposed layout of the also included in the updated PRF. masterplan for the garden led by BOST’. 271 14. Before coming up with specific proposals it is surely essential to look at impacts Any designs that come forward from ‘example N/A on neighbouring areas. The consultants’ answer to every space looked at is ‘remove projects’ will be subject to separate due diligence; in the traffic’. This may be a great idea but some assessment of feasibility and knock- which, conversations will be undertaken with on impacts is imperative. interested parties, feasibility studies developed, as well as dedicated design commissions and statutory public consultation and the planning process, if required. 272 15. Particularly in view of local comments and well-known views, any proposals We recognise that the topic of public realm Stronger emphasis on should have a clear management and maintenance strategy. The before and after management and maintenance can be strengthened in the importance of 122

images of Emma Cons Gardens – which has been re-landscaped unsuccessfully many the document, this will be addressed in the updated robust management times over the past 40 years without having any such strategy – suggest how version of the PRF. and maintenance fruitless another re-landscaping will be. If the answer is to devote some of the space needs has been to outside seating for an adjacent restaurant which undertakes cleaning and The concept design for Emma Cons is intended as high updated in the text of gardening of the overall space then this should be presented as a coherent project. level, indicative and illustrative interventions only, Guiding Principle 5. representing Publica’s recommendations and professional advice for the site. This is not a design proposal per se.

Any designs that come forward from ‘example projects’ will be subject to separate due diligence; in which, conversations will be undertaken with interested parties, as well as dedicated design commissions and statutory public consultation and the planning process, if required. 273 16. Outline cost estimates for each proposed scheme should be available before Priority projects have been selected based on the N/A ‘prioritisation’ takes place. following criteria: • They evidence the need for improvement and investment • Their proposals align strongly with the six guiding principles • The reflect local and/or strategic stakeholder aspirations and priorities • The sites are strategic spaces with a broader impact across Waterloo and South Bank

Detailed designs and cost estimates were not within the scope of the PRF. 274 17. It is surely incumbent on consultants working for the Council to take account of The focus that the PRF guiding principles place on N/A Local Plan proposals (e.g. the proposed pedestrian route linking Upper Ground and amenity, accessibility and wellbeing; culture, heritage the riverside walkway between Prince’s Wharf and the former London Television and design; barriers and legibility; safety and security; Centre site) and sensible to take account of previous consultant studies (e.g. Gross maximising development and minimising disruption; Max studies of the ‘South Bank spine route’) in formulating proposals? In addition, and supporting growth are consistent with other the SoWN draft neighbourhood plan has involved extensive work and should surely strategies and policies, specifically aligning with the form an important source for the framework. following:

Lambeth Local Plan (2015) • Section 3: Strategic Objectives focuses on promoting community cohesion and safe, liveable

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places whilst creating and maintaining attractive, distinct places. • Supports better accessibility, legibility and the prioritisation of walking and cycling within policies T1 Sustainable Travel, T2 Walking and T3 Cycling. • Encourages new and improved civic amenity and green infrastructure through policy EN1 Open Space & Biodiversity. • Policy EN4 Sustainable Design & Construction promotes high standards of sustainable design, encouraging proposals of non-residential developments to include a maintenance plan. • Policy Q3 Community Safety endorses designing- out crime within the public realm. • Policy Q5 Local Distinctiveness emphasises the preservation and reinforcement of cultural and historical places. • Policies Q6 Urban Design and Q7 Urban Design: New Development supports attractive, uncluttered, coordinated public realm that enhances the setting of and spaces between buildings whilst improving legibility and movement, reducing barriers; providing new / enhanced open space, robust street furniture, permeable paving and a high quality public realm that is built of durable, robust, low-maintenance materials that is both flexible and adaptable. • Both policies Q9 Westminster World Heritage Site and Q20 Statutory Listed Buildings celebrate and protect culture, heritage and local character.

• Development and management are considered in Principles 5 and 6. 275 Suitability of selected consultants Officers disagree with this statement. Publica is an N/A 18. It is difficult, in the light of the above, not to question the suitability of the award-winning urban design practice who have appointed consultants to undertake this specific work. We question the value of produced a tailored, evidence-led framework of their rather pointless attempt to categorise ‘local’, ‘metropolitan’ and ‘global’ Waterloo & South Bank’s public streets and spaces – spaces (p31) and we question their understanding of what makes a successful highlighting the need for improvements and space. investment across the project boundary.

This project has been managed effectively within the scope, resource and budget allocated. 276 19. Their approach to Sandell Street is a good example. Having turned their back on The bottom image (pg. 122) is an indicative N/A trees on the Union Jack Club side of the street because of “the significant area of visualisation created by Urban Movement, who were shade created by the Capital Tower”, they recommend introducing street furniture commissioned to undertake public realm designs for “to create space for people to use the street as a stopping place” (then illustrated in Sandell Street. the proposed Urban Movement scheme with a person happily sitting in the area unsuitable for trees). As anyone who uses this street regularly knows, its key The Sandell Street project is evolving and more features are that (1) there are piercingly high winds through much of the year, (2) information about the scheme can be found here. Lambeth has regularly planted trees along the street which have regularly been knocked over by buses trying to squeeze between parked cars on the north side of the street and the trees on the south, and (3) the pavement to the north is too narrow and is used by the adjacent businesses to leave out their bags of rubbish. [One of our employees had to be taken to A&E after cutting his leg on broken glass left in one of these black bags]. Remarkably the cars parking to the north remain in the illustrated proposal, trees are planted in the already inadequate pavement, and benches for sitting in the windy shade have been magically fitted in on the south side. 277 What CSCB believes are priorities A number of organisations that have a continued and Updated content 20. (1) Invest in the improvement and extension of local parks e.g. Bernie Spain active involvement in the Waterloo and South Bank within the Executive Gardens, Jubilee Gardens, Queen’s Walk Gardens, Millennium Green, and Hatfields. area are progressing live projects within Bishop’s Summary to reflect We have recently been granted planning consent for the re-landscaping of Bernie ward, including Coin Street Community Builders this. Spain Gardens (north) and the creation of Queen’s Walk Gardens. We are about to reimagining of Bernie Spain Gardens and Bankside launch a fundraising campaign for the capital costs of these schemes and it is deeply Open Spaces Trust’s masterplanning of Waterloo unhelpful to find them not referenced in the draft strategy. Millennium Green. Given the live status of these and similar initiatives, this Framework avoids delineating (2) Properly manage and maintain existing publicly-owned pavements. them in detail to evade cutting across emerging (3) Work in partnership with local stakeholders: this has been the basis of South designs, plans and proposals or to pre-empt the Bank’s success over the past 30 years. planning process. (4) Invest a proper proportion of the CIL, section 106, and rates generated by the area in the area. 125

(5) Ensure that major developments create publicly accessible pocket parks and soft This approach applies to Council sponsored initiatives, landscaped areas at ground level as well as above ground communal open spaces such as the transport infrastructure and public realm for their staff and residents. improvements being developed by TfL as part of the (6) There is a lot of talk of ‘de-cluttering’ in this report but along the south side of Waterloo City Hub scheme. These ongoing projects Upper Ground Lambeth has recently licenced an advertising ‘monolith’ in the are supported and recognised as a priority within the pedestrian pavement and, for over a year, has permitted a metal hoarding under area due to their ambition to upgrade important Waterloo Bridge in which no works have been undertaken for over a year and which streets and open spaces and unify disjointed areas of forces pedestrians into the traffic lane. Get rid of such unwarranted blockages to public realm. pedestrian pavement!

278 21. It is tragic that so much work has been spent on a framework without following No material changes required to the PRF. N/A basic project management principles. The draft framework is unlikely to attract great local support or engage stakeholders that need to be engaged if projects are to be brought to a successful conclusion. There is a danger that further funds will be committed without good effect unless the proposals are put on hold and a serious engagement strategy is pursued. There are many important improvements to the public realm that Lambeth could and should support but this should be done in real partnership with local interests.

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