PLANNING APPLICATIONS COMMITTEE

Date: Tuesday 25 May 2021

Time: 7.00 pm

Venue: Committee Room (B6) - Town Hall, , London, SW2 1RW*

*In line with legislation and continuing Covid-19 precautions, Committee Members will attend the meeting in person at Lambeth Town Hall. Officers, visiting Ward Members and members of the public are invited to attend virtually. Further instructions about joining the meeting, are provided overleaf.

Copies of agendas, reports, minutes and other attachments for the Council’s meetings are available on the Lambeth website. www.lambeth.gov.uk/moderngov

Members of the Committee

Councillor Scarlett O'Hara (Vice-Chair), Councillor Malcolm Clark, Councillor Jessica Leigh, Councillor Mohammed Seedat, Councillor Iain Simpson, Councillor Joanne Simpson (Chair) and Councillor Becca Thackray

Substitute Members

Councillor Liz Atkins, Councillor Jennifer Brathwaite, Councillor Marcia Cameron, Councillor Rezina Chowdhury, Councillor Paul Gadsby, Councillor Nigel Haselden, Councillor Maria Kay, Councillor Marianna Masters, Councillor Timothy Windle and Councillor Sonia Winifred

Further Information

If you require any further information or have any queries please contact: Farah Hussain, Telephone: 020 7926 4201; Email: [email protected]

Published on: Thursday 13 May 2021

Queries on reports

Please contact report authors prior to the meeting if you have questions on the reports or wish to inspect the background documents used. The contact details of the report author are shown on the front page of each report.

@LBLdemocracy on Twitter http://twitter.com/LBLdemocracy or use #Lambeth

How to access the meeting

In line with legislation, Committee members will attend the meeting in person at Lambeth Town Hall.

Due to public health guidance covering health, hygiene and social distancing, officers, visiting Ward Members and members of the public are invited to attend virtually. If this is not possible, strictly limited public access can be made available if you contact Democratic Services (details on the front sheet of the agenda) before the meeting.

For elected Members of the Council

Councillors who are not members of the committee but wish to make representations at the meeting must inform Democratic Services by 12 noon on the last working day before the meeting.

For Members of the Public

If you just want to watch the live broadcast, this meeting is available to view as a Microsoft Teams Live Event. If you are new to Microsoft Teams, clicking here will take you to the meeting page where you will be prompted to download the app or watch on the web instead. Please follow the instructions to watch on the web instead. On doing so, you can join our live event anonymously.

Can I make representations at PAC meetings?

You may speak in relation to planning applications and other applications that are to be decided by the Committee. Up to three supporters (including applicants), three objectors and the Ward Members can make representations to the meeting at the Committee’s discretion for a maximum of two minutes each.

If you would like to make representation, please contact the clerk (details on the front page of the agenda) or [email protected].

You must register your wish to make representations on any application by 12 noon on the last working day before the meeting. You are encouraged to participate online and should supply a written statement (approximately 300 words) outlining the points you wish to make to the committee. The written statement when read aloud must not take more than two minutes. If you are unable to participate online, strictly limited public access can be made available, however, due to continuing Covid-19 precautions, you should inform Democratic Services as soon as possible and before the deadline.

For further information please contact Democratic Services as soon as possible by telephoning 020 7926 2170 or emailing [email protected].

Where the number of requests to address the committee exceeds three, and/or it is clear the interested parties wish to make similar points, the interested parties will be asked to liaise so that all the points can be raised succinctly.

Where the Committee is hearing a Pre-application Development Presentation, you will not be able to register to speak in connection with that presentation. Pre-application Development Presentations relate to proposals that are still at the pre-application stage. Pre-application Development Presentations (explained further below) do not involve the determination of an application by the Committee.

What are Pre-application Development Presentations?

These are presentations to the Committee on proposed developments which have not yet been submitted as planning applications for formal determination. The purpose of the presentation is to make Committee members aware of the emerging proposal and to have an opportunity to ask questions of the

developer and to highlight issues to the developer that may require further consideration. The Committee does not make any decision about the proposals. Any proposal that is presented to the Committee through a Pre-application Development Presentation will still require a planning application to be submitted and determined in the usual way.

What is the process for hearing Pre-application Development Presentations?

Items involving Pre-application Development Presentations will be identified in the agenda papers. If an officer report has been prepared it will be published as part of the agenda papers and at the start of the item, the officer will briefly summarise their report.

The developer will then give a presentation to the Committee. This may involve the use of slides or images, which will be made available to Committee members and which people watching or attending the meeting will also be able to see. Committee members will then be invited to ask questions of the developer and will have an opportunity to highlight issues that may require further consideration by the developer. The item will be included in the minutes of the meeting.

Representation

Ward Councillors (details via the website www.lambeth.gov.uk or phone 020 7926 2131) may be contacted at their surgeries or through Party Group offices to represent your views to the Council: (Conservatives 020 7926 2213) (Greens 020 7926 2225) (Labour 020 7926 1166).

Digital engagement

We encourage people to use Social Media and we normally tweet from most Council meetings. To get involved you can tweet us @LBLDemocracy.

Audio/Visual Recording of meetings

Everyone is welcome to record meetings of the Council and its Committees using whatever, non- disruptive, methods you think are suitable. If you have any questions about this please contact Democratic Services (members of the press please contact the Press Office). Please note that the Chair of the meeting has the discretion to halt any recording for a number of reasons including disruption caused by the filming or the nature of the business being conducted.

Persons making recordings are requested not to put undue restrictions on the material produced so that it can be reused and edited by all local people and organisations on a non-commercial basis.

AGENDA

PLEASE NOTE THAT THE ORDER OF THE AGENDA MAY BE CHANGED AT THE MEETING

Page

Nos. 1 Declaration of Pecuniary Interests Under Standing Order 4.4, where any councillor has a Disclosable Pecuniary Interest (as defined in the Members’ Code of Conduct (para. 4)) in any matter to be considered at a meeting of the Council, a committee, sub-committee or joint committee, they must withdraw from the meeting room during the whole of the consideration of that matter and must not participate in any vote on that matter unless a dispensation has been obtained from the Monitoring Officer.

2 Minutes 1 - 20 To agree minutes of the meetings held on 23 February 2021, 30 March 2021 and 20 April 2021.

Town & Country Planning Act (1990), The Planning & Compensations Act (1991), The Town & Country Planning (Control of Advertisement) Regulations (1992), The Planning (Listed Buildings and Conservation Areas) Act (1990), The Town & Country Planning General Regulations (1990), The Rush Common Act 1806 and related legislation: Applications For information on documents used in the preparation of the reports contact the Planning Advice Desk, Tel: 020 7926 1180.

3 Pre Application - 72 Upper Ground (Bishop's) 21 - 32 No recommendation is made to the committee as this item is for a pre-application development presentation. Matters arising from discussions during the item will be recorded in the meeting minutes but will not be binding on the eventual decision- maker.

4 350 Lane (Princes) 20/04147/FUL 33 - 84 Officer Recommendations:

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

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

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

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

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

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

5 Kennington Park Business Centre () 19/04478/FUL 85 - 148 Officer Recommendations:

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

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

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

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

4. In the event that the Section 106 Agreement is not completed within 6 months of committee, delegated authority is given to the

Director of Planning, Transport and Sustainability to refuse planning permission for failure to enter into a section 106 agreement for the mitigating contributions identified in this report, addendums and/or the PAC minutes.

6 Appeals and Enforcement Decisions August 2020 149 - 154

7 Appeals and Enforcement Decisions September 2020 155 - 158

PLANNING APPLICATIONS COMMITTEE (PAC) FAQs - YOUR QUESTIONS ANSWERED

Who sits on the PAC? The Council has established a PAC, which consists of seven Councillors (elected Members).

Where and when do PAC meetings take place? In line with legislation, Committee members will attend the meeting in person at Lambeth Town Hall.

Due to public health guidance covering health, hygiene and social distancing, officers, visiting Ward Members and members of the public are invited to attend virtually. If this is not possible, strictly limited public access can be made available if you contact Democratic Services (details on the front sheet of the agenda) before the meeting.

The meetings are normally held on a Tuesday evening at 7pm and are held 1 or 2 times a month and are listed on the Council’s calendar of meetings at: http://www.lambeth.gov.uk/moderngov/mgCalendarMonthView.asp?GL=1&bcr=1

Can I attend PAC meetings? All PAC meetings are open to the press and public although on rare occasions the Committee may discuss a matter in private. The capacity of meetings is restricted due to Covid-19 safety considerations. If the capacity of the room is exceeded the meeting can be viewed live online. The link to the meeting can be found on the PAC page of the Council’s website.

How can I get a copy of any reports to be considered by PAC? The officer reports on applications to be considered are circulated to PAC Members and published on the Council’s website a week before the meeting. Papers for meetings can be viewed at: http://www.lambeth.gov.uk/moderngov/ieListMeetings.aspx?CommitteeId=600

Can I make written representations to the PAC meeting? Yes. Written representations, including any letters, petitions or photos should be:  Sent to the relevant case officer preferably by email; and,  Sent by 12 noon two clear working days before the meeting. Meetings are normally on a Tuesday, so the deadline would be 12 noon by the Thursday before the meeting.

Can I speak at PAC meetings? Yes. Up to three supporters (including applicants), three objectors and the Ward Members can make representations to the meeting at the Committee’s discretion for a maximum of two minutes each.

If you would like to make representation, please contact the clerk (details on the front page of the agenda) or [email protected].

You must register your wish to make representations on any application by 12 noon on the last working day before the meeting. You are encouraged to participate online and should supply a written statement (approximately 300 words) outlining the points you wish to make to the committee. The written statement when read aloud must not take more than two minutes. If you are unable to participate online, strictly limited public access can be made available, however, due to continuing Covid-19 precautions, you should inform Democratic Services as soon as possible and before the deadline.

For further information please contact Democratic Services as soon as possible by telephoning 020 7926 2170 or emailing [email protected].

Where the number of requests to address the committee exceeds three, and/or it is clear the interested parties wish to make similar points, the interested parties will be asked to liaise so that all the points can be raised succinctly.

Does the PAC consider applications in the order listed on the agenda? Not necessarily. The order of business is determined at the meeting taking into consideration:

1. Applications which are withdrawn, or which officers recommend should be deferred. 2. Applications where there are no notified interested parties wishing to address the committee and members have no questions to ask the applicant or officers. 3. Applications which have been deferred from a previous meeting or have been the subject of a site visit. 4. Applications for developments which would be in receipt of public funding and which are subject to deadlines affecting delivery and other applications subject to specific deadlines.

What is the process for considering an application at the meeting? Officers will introduce each application with a brief PowerPoint presentation which will usually include drawings and photographs of the application site. The Committee will then hear the representations from the interested parties. If the application is recommended for approval, then objectors’ representations will be heard first. This is reversed if the application is recommended for refusal. The merits of the application are considered taking into account the views of the interested parties and planning officers before the committee reaches a decision.

What time does the meeting come to an end? The meeting will be conducted in a business-like fashion and the Committee will endeavour to deal with reports as quickly as possible.

However, if there is a lot of outstanding business at 9.00pm the Chair will advise the meeting if and how the timetable for the meeting has to be revised, in order to deal with remaining business and finish the meeting at 10.00pm. At 10.00pm, if the meeting has not ended, the Committee will decide which business can be completed by 10.45pm and any business not reached by that time will be deferred to the next meeting.

What are site visits? The decision whether to have a site visit is made by the Chair of the Planning Applications Committee. Site visits are arranged by Planning Officers to allow the Committee and Ward Members to observe the site and gain a better understanding of the impact of the proposal. Where permission is needed to go on to private land, contact will be made with the owner by officers. Other than for reasons of access, the arrangements for site visits will not normally be publicised or made known to applicants, agents or third parties except in exceptional circumstances. In such circumstances, officers have discretion to invite one representative of the applicant to be present but only to answer any questions if Members require further context which the officer cannot provide. The applicant must notify the planning officer prior to the site visit who will be attending on their behalf.

Objectors are not to be invited, except in exceptional circumstances where the Chair of the Committee agrees that there is information which cannot be provided by officers, and which it is necessary to receive on site and which is only likely to be able to be provided by an objector.

In circumstances where the public may need to be involved; for example, to gain access to a property to view a site from a particular vantage point, officers will arrange this. Members of the public shall be present only to grant access to premises and to answer factual questions.

A site visit is not a part of the formal determination of the planning application and therefore the public in attendance are not able to lobby councillors or to engage in discussing the merits of the proposal.

When do site visits take place? A site visit will normally take place on the Saturday morning immediately before the committee which will consider the matter. An alternative date of the preceding Friday morning could be arranged

If I am unable to attend the PAC meeting, how can I find out the decision? You are able to watch the meeting by clicking the link provided on the PAC agenda. Following the meeting, videos remain available to view for 180 days. Decisions will be posted on Twitter from @lbldemocracy immediately as the decision is taken. You can also contact Democratic Services by telephone or email. The minutes from the meeting will also be available on the Council’s website after the meeting. Planning officers will send the applicant and any interested parties who have made written representations formal notification of the Committee decision.

Where can I get further information or advice? If you would like further information or advice, please contact:  Town Planning Advice Desk: Tel: 020 7926 1180, Email: [email protected]  Town Planning Webpage: https://www.lambeth.gov.uk/planning-and-building-control  Democratic Services: Tel: 020 7926 4201, Email: [email protected]

Abbreviations

ADF Average Daylight Factor AQA Air Quality Assessment AQMA Air Quality Management Area BNPP BNP Paribas (Financial Viability Advisors) BRE British Research Establishment BREEAM Building Research Establishment Environmental Assessment Method BSPD Brixton Supplementary Planning Document CAS Conservation Area Statement CHP Combined Heat and Power CIL Community Infrastructure Levy CEMP Construction and Environmental Management Plan MHCLG Ministry of Housing, Communities and Local Government DD Daylight Distribution EIA Environmental Impact Assessment ES Environmental Statement ESP Employment and Skills Plan EVCP Electric Vehicle Charging Point HE Historic England FTE Full Time Equivalent FVA Financial Viability Assessment HSE Health and Safety Executive GLA Greater London Authority LLP Lambeth Local Plan 2015 LVMF London View Management Framework MALP London Plan 2016 (formerly Minor Alterations to The London Plan) NPPF National Planning Policy Framework NPPG National Planning Practice Guidance OAPF Opportunity Area Planning Framework PAC Planning Applications Committee PPA Planning Performance Agreement PTAL Public Transport Accessibility Level PV Photovoltaic RICS Royal Institute of Chartered Surveyors RSS Regulatory Support Service – Environmental Health advisors S106 Section 106 of the Town and Country Planning Act 1990 SPD Supplementary Planning Document SPG Supplementary Planning Guidance TA Transport Assessment TfL Transport for London TLRN Transport for London Road Network TVIA Townscape and Visual Impact Assessment VSC Vertical Sky Component VSPD Supplementary Planning Document WSPD Waterloo Supplementary Planning Document

Approach to Heritage Assets

Legislative Framework Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 (“PLBCAA”) provides that in considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.

Section 72(1) of the PLBCAA provides that in the exercise, with respect to any buildings or other land in a conservation area, of any functions under or by virtue of (amongst others) the planning Acts, special attention shall be paid to the desirability of preserving or enhancing the character or appearance of the conservation area.

The South Lakeland District Council v Secretary of State for the Environment case and the Barnwell Manor case (East Northamptonshire DC v SSCLG) establish that “preserving” in both s.66 and s.72 means “doing no harm”.

National Policy Paragraph 8 of the NPPF sets out three overarching objectives, contained within the planning system, in order to achieve sustainable development. These objectives are interdependent and need to be pursued in mutually supportive ways and include the following (with detail provided on the most relevant objective to this section): a) an economic objective; b) a social objective; and, c) an environmental objective –to contribute to protecting and enhancing our natural, built and historic environment.

The NPPF defines a “heritage asset” as:

“A building, monument, site place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest”.

The definition includes both designated heritage assets (of which, Listed Buildings and Conservation Areas are relevant here) and assets identified by the local planning authority (including local listing)

“Significance” is defined within the NPPF as being:

“the value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic. Significance derives from a heritage asset’s physical presence, but also from its “setting”.

Paragraph 190 of the NPPF requires local planning authorities to identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting its setting), taking account of the available evidence and any necessary expertise. That assessment should then be taken into account when considering the impact of the proposal on the heritage asset, to avoid or minimise conflict between the heritage asset’s conservation and any aspect of the proposal.

Paragraphs 192 to 194 of the NPPF provide as follows:

192. In determining planning applications, local planning authorities should take account of:

a. the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; b. the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and c. the desirability of new development making a positive contribution to local character and distinctiveness.

193. When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.

194. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting) should require clear and convincing justification. Substantial harm to or loss of: a) grade II listed buildings, or grade II registered parks or gardens, should be exceptional; b) assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.

Paragraph 195 of the NPPF deals with substantial harm to or total loss of significance of significance of a designated heritage asset.

Paragraph 196 of the NPPF provides that where a development proposal will lead to less than substantial harm to the significance of the designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.

Paragraph 197 of the NPPF deals with non-designated heritage assets as follows:

197. The effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect directly or indirectly non designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.

Paragraphs 200 and 201 of the NPPF are as follows:

200. Local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites, and within the setting of heritage assets, to enhance or better reveal their significance. Proposals that preserve those elements of the setting that make a positive contribution to the asset (or which better reveal its significance) should be treated favourably.

201. Not all elements of a Conservation Area or World Heritage Site will necessarily contribute to its significance. Loss of a building (or other element) which makes a positive contribution to the significance of the Conservation Area or World Heritage Site should be treated either as substantial harm under paragraph 195 or less than substantial harm under paragraph 196, as appropriate, taking into account the relative significance of the element affected and its contribution to the significance of the Conservation Area or World Heritage Site as a whole.

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

Approach to Daylight, Sunlight and Overshadowing Where a proposed development may impact upon the sunlight and daylight received by an adjoining property, planning applications are often accompanied by a Sunlight and Daylight Assessment. These should be undertaken following the guidelines published by the Building Research Establishment ‘Site Layout Planning for Daylight and Sunlight’ (BRE Guidelines). This is a good practice guide which provides advice on site layout for good natural lighting within a new development, safeguarding of daylight and sunlight within existing buildings nearby a development and the protection of daylighting of adjoining land for future development. The guide is advisory and whilst it provides numerical target values, these need also to be considered holistically with the needs of the development and its surrounding context.

Two methods of measurement are recommended be used to measure daylight impacts: (1) Vertical Sky Component (VSC); and (2) Daylight Distribution (DD). VSC assesses the quantum of skylight falling on a vertical window and DD (also referred to as No Sky Line) the distribution of direct skylight in a room space.

VSC is calculated from the centre of a window on the outward face and measures the amount of light available on a vertical wall or window following the introduction of visible barriers, such as buildings. The maximum VSC value is almost 40% for a completely unobstructed vertical wall or window. The BRE guidance suggests that if the VSC is greater than 27%, enough skylight should still be reaching the window of the existing building. Any reduction below this level should be kept to a minimum. Should the VSC with development be both less than 27% and less than 0.8 times its former value, occupants of the existing building shall notice a reduction in the amount of skylight they receive. The guide says: “the area lit by the window is likely to appear gloomier, and electric lighting will be needed more of the time”.

The DD method is a measure of the distribution of daylight at the ‘working plane’ within a room. For the DD assessment the ‘working plane’ means a horizontal ‘desktop’ plane 0.85m in height for residential properties. The DD divides those areas of the working plane which can receive direct sky light from those which cannot. If a significant area of the working plane receives no direct sky light, then the distribution of daylight in the room will be poor and supplementary electric lighting may be required. The BRE Guidelines state that if the area of a room that does receive direct sky light is reduced by more than 20% of its former value, then this would be noticeable to its occupants.

Typically, it is recommended that VSC and DD are utilised for consideration on daylight losses resulting from the proposal to existing neighbouring residential since it is a comparative test.

Sunlight is measured using Annual Probable Sunlight Hours (APSH). Sunlight is measured using a sun indicator which contains 100 spots, each representing 1% of APSH. Where no obstruction exists, the total APSH would amount to 1486 hours and therefore each spot equates to 14.86 hours (for London) of the total annual sunlight hours. The number of spots is calculated for the Baseline and Proposed Development scenarios during the whole year and also during the winter period and a comparison made between the two. This provides a percentage of APSH for each of the time periods for each window assessed.

The 2011 BRE Guidelines note that sunlight is valued in living rooms at any time of day but especially in the afternoon. It is viewed as less important in bedrooms and in kitchens (the latter where people prefer it in the morning rather than the afternoon. All main living rooms of dwellings…should be checked if they have a window facing within 90° of due south. If the main living room to a dwelling has a main window

facing within 90° of due north, but a secondary window facing within 90° of due south, sunlight to the secondary window should be checked.

With regard to existing surrounding receptors, the BRE Guidelines provide that a window may be adversely affected if a point at the centre of the window receives - Less than 25% of the APSH during the whole year, of which 5% APSH must be in the winter period; and - Receives less than 0.8 times its former sunlight hours in either time period; and - Has a reduction in sunlight for the whole year more than 4% APSH.

Overshadowing is assessed through transient overshadowing plots which comprise an illustrative tool showing the changing levels of direct sunlight received by amenity space throughout the day on the dates assessed. The BRE ‘test’ for a development’s overshadowing impacts relates to the area of an amenity space that receives more than two hours of sunlight on 21 March (the Spring Equinox). The guide states:

“…for it to appear adequately sunlit throughout the year, at least half of a garden or amenity area should receive at least two hours of sunlight on 21 March. If, as a result of new development, an existing garden or amenity area does not meet the above, and the area which can receive two hours of sun on 21 March is less than 0.8 times its former value, then the loss of sunlight is likely to be noticeable”.

Approach to Air Quality There is a Lambeth wide Air Quality Management Area (AQMA) and Lambeth is also covered by the Non-Road Mobile Machinery (NRMM) Low Emission Zone.

The NPPF states within paragraph 181:

“…decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement…Planning decisions should ensure that any new development in Air Quality Management Areas and Clean Air Zones is consistent with the local air quality action plan.”

London Plan policy 7.14 states that development proposals should minimise increased exposure to existing poor air quality and make provision to address local problems of air quality, promote sustainable design and construction to reduce emissions from the demolition and construction of buildings, be at least air quality neutral, ensure that where provision needs to be made to reduce emissions from a development, this is normally made on-site, and where the development requires a detailed air quality assessment and biomass boilers are included, the assessment should forecast pollutant concentrations.

Page 1 Agenda Item 2

PLANNING APPLICATIONS COMMITTEE MINUTES

Tuesday 23 February 2021 at 7.00 pm Held via Microsoft Teams

PRESENT: Councillor Scarlett O'Hara, Councillor Ben Kind, Councillor Jessica Leigh, Councillor Mohammed Seedat, Councillor Joanne Simpson (Vice-Chair), Councillor Becca Thackray and Councillor Clair Wilcox (Chair)

1. DECLARATION OF PECUNIARY INTERESTS Although not a pecuniary interest, Councillor Jessica Leigh stated that she was employed by the House of Commons and that she was able to approach the application with an open mind.

2. ARCHES 107-122 BRAD STREET AND WOOTTON STREET (BISHOPS) 20/02677/VOC Case No. 20/02677/VOC (agenda item two, page one of the agenda pack, page one of the first addendum and page one of the second addendum).

The Planning Officer gave a presentation which included a summary of the report and subsequent first addendum that had been published on Friday 19 February 2021 and the second addendum on the day of the meeting. Members were advised that the planning application was originally intended to be reported to the Planning Applications Committee meeting on the 19th January 2021 and was deferred on that occasion on officer's recommendation. This was to enable a re-consultation to take place with an amended description of development. Following this exercise, two further letters of objection were received which were included in the addenda.

Members were advised of the key material planning issues for consideration which included the variation of condition 11 and insertion of new conditions to allow for additional collections (conditions 32 and 33) of the parent planning application (ref: 02/03247/FUL)) which was granted on 22nd September 2003 by the Planning Applications Committee for the change of use of railway arch units known as 107 to 122 Brad Street and Wootton Street. As also amended in respect of condition 18 (opening hours of the A3 use) within Arch by planning permission 04/00926/FUL granted in 2004 and as also amended in the same terms by appeal decision APP/N5660/A04/1146484 allowed in 2004.

The application seeks to vary condition 11 imposed by the parent planning applications and insert new conditions to allow for additional collections (conditions 32 and 33). This means that one additional collection between 5.45am and 8:00am Monday to Friday can occur. Permission is also sought to allow for one early morning collection between 5.45am and 8:00am on no more than 5 Saturdays per calendar year. To allow for this, a new condition is proposed described as condition 32. Officers advised Members that the early morning collections proposed under conditions 11 and 32 would secure the use of electric vehicles only. To secure this the conditions would require the applicant to maintain a log for the duration of the collection permitted which would contain information to include dates and timings of the collections, listing the vehicle type to include that the vehicle is electric and in the exceptional instance when it is not, why. The log would be made available to the local planning authority (LPA) at its request, and it would secure the collections would not operate in the absence of the said log. Page 2

Officer went on to advise that in the event that collections are required later than the consented 8:00am to 6:00pm service and delivery times, the applicant also seeks permission to undertake one evening collection no more than 20 times per calendar year from Wootton Street or Brad Street. This would be imposed by condition 33. It was not proposed to restrict the type of vehicles to be used for the evening collections in view of the proposed times of operation and limited number of times per year these collections would be carried out. However, the applicant would be required to keep a log of of such collections and the types of vehicles used. The noise assessments have been reviewed by the Council’s Noise specialist who advised that the results are what he would expect in this location. The applicant’s submitted noise assessment demonstrates that the proposed early morning collections would not result in unacceptable noise levels over and above existing ambient noise levels at this time in the morning. As such, the results of the noise survey illustrated that the components of the increased collections activity would not be readily noticeable to adjacent residential occupiers. It was explained that the safeguarding measures proposed are set out in the Servicing and Delivery Statement and would be secured by condition 35 and use of electric vehicles. In summary, Members were advised that the application does not seek a change of use to 7 Wootton Street, nor any other arches within the parent application site. Nor are any external changes sought as part of this application. The proposed amendments were considered minor by officers.

The original condition was imposed to protect the amenity of neighbouring residential properties. The variation of this condition is considered acceptable through the imposition of safeguarding measures to secure the use of electric vehicles and mitigation measures set out in the Servicing and Delivery Statement. In this urban context the increased collections were not considered to result in unacceptable noise impacts over and above the existing ambient noise levels and would therefore not result in unacceptable neighbour amenity impacts. The additional vehicle movements were reported by officers to not result in harm to the free and efficient movement of traffic or the safe operation of the local highway and footway network. Officers were therefore satisfied that the proposal is acceptable and recommended that the application be granted subject to conditions as set out in the officer report.

Following the officer’s presentation, the objectors raised the following concerns:  Existing train noise and the use of electric vehicle would not solve the objections of 92 residents.

 The area has 100 to 150 deliveries a year, but this application listed 18 times this number.

 There would be no limit on the type or amount of goods for the applicant or of future tenants.

 The nearby homes were listed, with single glazed windows and no mitigation measures had been offered by the applicant.

 There were over 400 vacant arches and the applicant should find alternative locations.

 The road was 4.2 metres wide, and therefore passing vehicles would need to mount the footway next to the back walls of residents’ gardens to pass.

 The report contained errors such as no permit parking in Brad Street and the Konditor bakery deliveries were to their door in Cornwall Road.

 The decision should avoid creating an adverse impact on health and quality of life.

 The sound generated would be 67 decibels and different to those of railway sounds.

Page 3

The applicant’s representatives then provided the following information in support of the application:

 The in-house print services within the Houses of Parliament needed to be relocated as the building was due to be repaired.

 Although the noise that would be made would not be audible over the sounds of the railway line in the morning, the applicant had listened to residents’ concerns and made a number of changes, including the use of an electric vehicle and a regular driver to monitor good behaviours.

 The applicant was committed to being a good neighbour and maintaining a dialogue with the current and future local community.

 The site had been vacant since spring 2018.

 Request for a degree of flexibility so that the occasional evening and Saturday collections could occur, however these would be rare.

 The noise report was conducted at 1:00am and 5:30 to 6:30am, based on a petrol vehicle and the background noise levels were recorded at eight decibels higher.

Councillor Jennie Mosely then spoke as Ward Councillor for Bishops Ward, stating the following:  Under the agent of change principle, noise nuisance no longer relied on acoustic readings as it did not register sound like the human ear and brain.

 The 215 new residents who would live in the new homes on Wootton Street, to the south of the site were not considered in this application.

 The officer report wrongly stated that Brad Street was completely private. There would not be any parking spaces for the deliveries, contrary to Lambeth Plan policies T6, T7 and T8 and London Plan policy T7.

 The proposal undermined the neighbourhood plan designation of Cornwall Road as a greenway and the Low Traffic Neighbourhood.

Florence Eshalomi then spoke as MP for Vauxhall, stating the following:  Wootton Street Arch was not a suitable location for alternative office space, as it was a conservation area and highly residential.

 In a non covid-19 time the street was extremely busy given its proximity to Waterloo Station, therefore parking would be insufficient.

 Local residents had found examples of current planning laws and standards that had not been properly followed.

 Questioned whether it was responsible to spend large amounts of public money pursuing a proposal which did not have the backing of the local community and when there were similar vacant premises nearby.

Officers and the LPA's specialist noise advisor then provided the following information in response to questions from Members:

 The 5:45 am slot was due to the logistics of delivering the papers to Parliament by 7:00am.

 There would be two electric vehicles available for delivery.

 The electric vehicle was a mitigation measure to address objections of noise. The Page 4

enforceability was assessed by the legal team who confirmed it to be acceptable.

 Conditions 11, 32 and 33 stated that staff would keep a daily log of deliveries. This had been previously accepted by the Committee for an application involving a helipad elsewhere in the borough. The log would be used if a complaint was raised.

 Enforcement was a reactive rather than proactive process.

 The applicant would keep a daily record of deliveries, which could be used if a complaint was made. The intent of the log would be to confirm there was not a breach of condition.

 Condition 35 would secure mitigation measures on noise in the form of a Servicing and Delivery Plan

 Idling of the vehicle would not be comparable to conventional vehicles as electric vehicles would be used.

 There would be a dedicated delivery driver, who would be aware of the mitigation measures.

 A barrow and dampeners would be used to transfer the boxes, not a supermarket trolley.

 The vehicle route was not submitted in the plans supporting the application as it was not a requirement.

The Committee considered the points raised by speakers and information provided by officers in conjunction with the report before making the following observations:

 The application was relatively simple with good mitigation measures.

 Some members were concerned that the enforcement would rely on a trust that the log was kept accurately, and electric vehicles were used.

 Members expressed their disappointment that the applicant did not explore arches further along.

 A condition that prevented the use of supermarket roller cages should be added.

 Requested that the applicant use rubber wheels and avoid the scraping of cages along the ground.

It was MOVED by Councillor Wilcox, SECONDED by Councillor Simpson, and

RESOLVED, unanimously

1. To GRANT conditional planning permission, subject to the following:

An additional condition that no deliveries shall be made to or received from the Brad or Wootton Street entrances to 7 Wootton Street using any form of wheeled roll cage trolleys between the hours of 5.45am and 8:00am daily for the duration of the use.

2. To delegate authority to the Director of Planning, Transport and Sustainability to finalise the recommended conditions as set out in the report, addendums and/or PAC minutes.

At 9:11pm the meeting was adjourned for nine minutes. 3. 23 HOADLY ROAD LONDON SW16 1AE (ST LEONARDS) 20/01319/FUL Case No. 20/01319/FUL (agenda item three, page 77 of the agenda pack, page nine of the Page 5 addendum and page six of the second addendum).

The Planning Officer gave a presentation which included a summary of the report and subsequent addenda that had been published on Friday 19 February 2021 and the day of the meeting. Members were advised of the key material planning issues for consideration which included that the site was located in a backland location, adjacent to rear gardens of Hoadly Road and Woodfield Avenue. The proposal was to demolish the existing building and erect five four-bedroom houses, with five off street parking spaces, private gardens and private and communal bin storage. There would be no change of land use but the increase in four houses would contribute to Lambeth’s housing supply. The financial viability, which was independently reviewed, concluded that the scheme would not be viable. Therefore, no financial contribution towards offsite affordable housing could be secured. A two-stage review mechanism was suggested in the S106 agreement to re-assess whether the development could be viable with an affordable housing contribution at later stages.

Members were shown comparisons to the previous site plan, computer-generated images of the current proposal, its context, proposed materials and design, and existing and proposed views. The reasons for the previous application’s refusal were discussed in the context of the current proposal. There was a general decrease in massing to that of the previous scheme, which improved the openness of the site, and a reduction in glazing on external elevations which were reasons given by the Inspector when dismissing the previous appeal. Members were informed that the Lambeth Local Plan was under partial review, and that relevant weight should be applied to the adopted and emerging policies. There would be nine trees removed on site (no category A or B trees removed) which would be offset by 24 trees being planted. The scheme was within daylight/sunlight BRE guidance and would retain acceptable levels of openness, privacy and amenity to surrounding properties.

Following the officer’s presentation, the objectors raised the following concerns:  The report consisted of errors which could materially affect Members’ consideration.

 The appeal inspector found that two storey houses “significantly eroded a sense of openness in spaciousness” and noted that objectors raised further matters but, as the scheme was already unacceptable, did not need to consider the matters on tree removal, cars in the back garden and noise.

 Compliance issues with Local Plan policy Q14 (openness, rear gardens and single- storey buildings) lacked proper analysis and should receive much weight despite it not being applied to the total redevelopment.

 Despite the weight given to draft policy Q14, the overdevelopment would still conflict with policies Q2, Q5 and Q7.

 It was an inappropriate development of a garden and not a backland site.

 Residents would lose a sense of openness, privacy and mature trees.

 The access road would be too narrow for a fire engine.

 There were no community benefits or contribution offered by the developer, despite an anticipated profit of 21%.

 Residents received site visits from an inspector but not the planning officer.

 A resident read a spoken word piece that encapsulated the above points.

The agent and architect then provided the following information in support of the application:  There were only two substantive issues upheld through the 2016 appeal, which were impact on the character of the area and impact on openness and consequently residential amenity. Both issues had been addressed by the current proposal, as stated Page 6

in the committee report.

 Although openness was no longer a consideration within the soon to be adopted policy, the applicant responded to the comments, which included building height, number of houses, distance between surrounding properties and scheme to maintain privacy, increase in the retention of existing garden, increased density, decreased built footprint and positively reflected the character of the area.

 Further consultations were held with stakeholders, and their views factored into the proposal. Five letters of support were received during the consultation period.

 The proposal benefits would include: net additional homes; high design quality; new habitats created resulting in increased net gain on biodiversity; exceeding urban greening factor requirements; removal of three dead trees and others of poor to moderate quality, which would be replace with 24 high quality trees; the development would be carbon neutral; cycle parking spaces; one car parking space per household, contribution to CPZ implementation, car club membership and electric car charging points and no daylight/sunlight impacts.

Councillor Nicole Griffiths and Councillor Scott Ainslie then spoke as Ward Councillors for St Leonards, stating the following:  Over 100 concerned neighbours had objected to the application.

 The location was a private garden and not backland.

 The manor house could be refurbished to create several flats, which would avoid the destruction of a home and garden in a low rise, open and green area of .

 The scheme would not have proper consideration of embodied carbon, would destroy wildlife habitat and was not designed as eco-homes.

 The Planning Inspector’s decision on the previous application, had identified the openness of the rear gardens and that the net gain of a few high-end houses did not outweigh the level of harm caused. It had also been identified that due to the unacceptable scale, bulk, design and impact on visual amenity and locally distinctive openness, there was no need to go into further detail on other areas of objection.

 Officers had not properly assessed the visual amenity and openness in respect of Local Plan policies, in particular Q2, Q5, Q7, Q9, Q10 and Q14.

 They requested that the Committee refuse the application.

At 10:00pm the committee elected to proceed with the meeting for a maximum of a further 45 minutes in order to conclude the remaining matters of business.

Officers then provided the following information in response to questions from Members:  The refusal for the previous application was on the openness of the area and the design appearance, as well as the loss of biodiversity and habitat. These issues had been addressed in the application.

 Officers did not consider the development to represent an overdevelopment of the site.

 The Legal officer reminded Members that the inspector’s decision was not binding, that it was a material consideration, and that Members would need to consider all elements in the scheme when making their decision.

 There would be an incursion into the root protection areas (RPAs) of retained trees of 3.8%, which was considered to have negligible impact on biodiversity and trees. Page 7

 It was the developer’s financial decision if they wanted to put forward a scheme that was not viable, and not a consideration for the Committee. Officers explained that a scheme being non-viable did not entail a financial loss to the applicant – the scheme’s viability assessment took into account a 17.5% profit, which would signify some profit and is considered reasonable on the site.

 The applicant clarified that the initial scheme of six units was based on a benchmarking data from BCIS costs. However, the scheme had an independent cost consultant to review the application, which concluded gross construction costs at £3.57m.

 The scheme was originally found to be viable but was reduced by one unit, resulting in a loss of c. 300sqm of gross internal area, but continued to maintain the original pricing per unit.

 The application had less removal of hedges than the previous scheme. Condition 13 would accommodate small mammals and hedgehogs.

 The landscaping plan would cover the low-level foliage.

 Emergency access was possible to enter/exit in first gear.

 The current scheme had a decidedly domestic character, which followed the character of the area and was contemporary as seen in the tiles and roof.

 Waste collection area was confirmed during the detailed design stage, and current images were limited. An informative could be added if Members so wished.

 Cycle parking would comply with Publication London Plan policy requirements. The officer showed where private cycle parking would be on the plan and short-term parking.

The Committee considered points raised by speakers and information provided by officers in conjunction with the report before making the following observations:  They requested that a late-stage review of viability within 24 months of the date that permission was given.

 Some Members questioned the need of one parking space per dwelling and whether it could be reduced, while others believed that the balance was justified due to the residential units being family dwellings.

 A Member was disappointed that the scheme did not go above the policy compliance with cycle parking.

It was MOVED by Councillor Wilcox, SECONDED by Councillor O’Hara, and

RESOLVED, by five votes for to two against

1. To GRANT conditional planning permission subject to the completion of an agreement under Section 106 of the Town and Country Planning Act 1990 (as amended) containing the planning obligations listed in the report and the following:

i. An informative that waste storage was not visible from the street through the use of soft landscaping or design.

2. To delegate authority to the Director of Planning, Transport and Sustainability to:

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

b. Negotiate, agree and finalise the planning obligations as set out in the report, Page 8

addendums and/or PAC minutes pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended).

3. In the event that the Section 106 Agreement is not completed within six months of committee, delegated authority is given to the Director of Planning, Transport and Sustainability to refuse planning permission for failure to enter into a section 106 agreement for the mitigating contributions identified in the report, addendums and/or the PAC minutes.

CLOSE OF MEETING

The meeting ended at 10.44 pm CHAIR PLANNING APPLICATIONS COMMITTEE Tuesday 25 May 2021

Date of Despatch: Tuesday 11 May 2021 Contact for Enquiries: Farah Hussain Tel: 020 7926 4201 E-mail: [email protected] Web: www.lambeth.gov.uk Page 9

PLANNING APPLICATIONS COMMITTEE MINUTES

Tuesday 30 March 2021 at 7.00 pm Held via Microsoft Teams

PRESENT: Councillor Scarlett O'Hara, Councillor Paul Gadsby (Substitute), Councillor Ben Kind, Councillor Mohammed Seedat, Councillor Joanne Simpson (Vice-Chair), Councillor Becca Thackray and Councillor Clair Wilcox (Chair)

APOLOGIES: Councillor Jessica Leigh

1. DECLARATION OF PECUNIARY INTERESTS There were none.

2. MINUTES RESOLVED: That the minutes of the previous meetings held on 19 January and 9 February 2021 be approved and signed by the Chair as a correct record of the proceedings.

The Chair announced a provisional timetable for the meeting in accordance with Standing Order 9.9.1.

3. THE SOUTH BANK CENTRE, BELVEDERE ROAD (BISHOPS) 21/00454/FUL, 21/00456/ADV AND 21/00457/LB Case Nos. 21/00454/FUL, 21/00456/ADV and 21/00457/LB (agenda item 3, page 11 of the agenda pack).

The Planning Officer gave a presentation which included a summary of the report and Members were advised of the key material planning issues for consideration. The application was for a summer event that would celebrate the Royal Festival Hall’s 70th anniversary. This year the event, which was of a similar scale to annual summer events held on the site, including in 2020, proposed twelve pop up cafes and bars with associated seating, and artistic elements including sculptures on the Queen’s Walk, the first floor terraces and to the external elevations of the Southbank Centre buildings such as photographic vinyl’s. An interactive waterfall on the terrace of the first floor was proposed; however, the Southbank Centre had stated that it could not be operated safely under current national social distancing requirements and would not be implemented. Officers were satisfied that it was included on the proposed plans as this element would still be acceptable in terms of the planning application. Officers stated that the Event would be required to comply with Covid-19 restrictions the Coronavirus Act and other public safety measures such as space for social distancing. These requirements were not material planning considerations; however, officers had considered how the Event would operate under the restrictions and were satisfied that this could be achieved with an acceptable impact on the material considerations of the proposal and surrounding area. In relation to the noise resulting from the Event to the local neighbourhood, since the monitoring conditions had been introduced in previous planning approvals, no complaints had been made on the exhibits and similar conditions to previous applications had been recommended on this planning application. Officers highlighted that the Southbank Centre had a Planning Performance Agreement (PPA) in place with the Planning Department to facilitate prompt dialogue with officers to advise on any Page 10 unforeseen Covid-19 implications on the operation of the Event, such as the need for additional queuing management.

Officers provided the following information in response to Members’ questions:

- Officers confirmed that in relation to crowding issues, the Lambeth Local Plan required a six-metre width on the Queen’s Walk which would be provided and the event walking areas would be sufficient for two-way traffic plus social distancing requirements. - The site wide Covid Risk Assessment that the Southbank Centre conducted detailed the measures they would implement, and although cleaning of the toilets was not a material planning consideration, it would be enforced by the applicant. - With the exception of some security lights in the proposal, lighting would be turned off at 23:30 hours and the advertisements were required to be in line with Lambeth illumination guidelines. Officers noted that the area had a high amount of ambient lighting and was distanced or screened from nearby residential properties. - In relation to the materials used for the vinyl’s and whether it would be reusable or recyclable, Officers advised that this was not a material planning consideration. - In relation to whether there would be additional footfall and if that would impact the safety around the area, Officers stated that the health and safety of the venue from a Covid-19 standpoint, would need to adhere to the relevant rules; however, these do not fall under planning considerations and would be enforced by other bodies.

The Committee considered the information provided by officers in conjunction with the report before making the following observations: merits of application:

- Members stated that they were content with this being offered to residents, with this event being available to a wide diversity of people, providing free entertainment and that it was not undermining the Lambeth Local Plan.

21/00454/FUL:

It was MOVED by Councillor Wilcox, SECONDED by Councillor Simpson, And

RESOLVED, unanimously

1. To GRANT planning permission subject to the conditions as outlined in the officer’s report.

2. To delegate authority to the Director of Planning, Transport and Sustainability to finalise the recommended conditions as set out in the report, and/or PAC minutes.

21/00456/ADV:

It was MOVED by Councillor Wilcox, SECONDED by Councillor Simpson, And

RESOLVED, unanimously

1. To GRANT express advertisement consent.

2. To delegate authority to the Director of Planning, Transport and Sustainability to finalise the recommended conditions as set out in the report, and/or PAC minutes.

Page 11

21/00457/LB:

It was MOVED by Councillor Wilcox, SECONDED by Councillor Simpson, And

RESOLVED, unanimously

1. To GRANT listed building consent.

2. To delegate authority to the Director of Planning, Transport and Sustainability to finalise the recommended conditions as set out in the report, and/or PAC minutes.

CLOSE OF MEETING

The meeting ended at 7.43 pm CHAIR PLANNING APPLICATIONS COMMITTEE Tuesday 25 May 2021

Date of Despatch: Thursday 15 April 2021 Contact for Enquiries: Farah Hussain Tel: 020 7926 4201 E-mail: [email protected] Web: www.lambeth.gov.uk This page is intentionally left blank Page 13

PLANNING APPLICATIONS COMMITTEE MINUTES

Tuesday 20 April 2021 at 7.00 pm Held via Microsoft Teams

PRESENT: Councillor Scarlett O'Hara, Councillor Ben Kind, Councillor Jessica Leigh, Councillor Mohammed Seedat, Councillor Joanne Simpson (Vice-Chair), Councillor Becca Thackray and Councillor Clair Wilcox (Chair)

1. DECLARATION OF PECUNIARY INTERESTS There were none. 2. 10 PASCAL STREET (OVAL) 20/02331/FUL Case No. 20/02331/FUL, (agenda item two, page one of the agenda pack, and page one of the addendum).

The Planning Officer gave a presentation which included a summary of the report and Members were advised of the key material planning issues for consideration. The proposed development comprised of four buildings between five to 21 storeys. The site area was 0.65 hectare, located on the eastern side of Wandsworth Road and northern side of Pascal Street. The site was within the central activity zone, was not located in a conservation area and there would be no harm to the heritage assets or their settings. The site benefits from an extant planning permission, that was granted in 2016, which includes 332 residential units including 84 affordable, a commercial block and new public realm. The proposed development would deliver 479 Built to Rent units including 176 affordable units, new public realm and a commercial unit. There would also be access to cycle storage units in the basement levels of the building, which would be for residents’ use. The roof of the buildings would include amenity spaces, biodiverse green roofs and plant areas. Members were shown images of the site, its context, proposed materials and design, and existing and proposed views.

The proposed housing would be Built to Rent (BtR) and the covenant period would be compliant with Policy H11 of the London Plan. Affordable housing would be provided at 40% of all habitable rooms with 155 units provided at London Living Rent equivalents and 21 units at Lambeth Tenancy Strategy (LTS) equivalents. A review mechanism would be secured to increase the proportion of LTS units if viability improves. The proposed unit mix, when considered in the context of the extant permission as a material planning consideration, was more balanced than the previous scheme. The Council’s external daylight consultant outlined the key issues relating to daylight and sunlight and privacy mitigation measures were also shown. There would be 2189 square metres of internal and external amenity space, with 852 square metres of play space available to all residents. The development would be car permit free with the exception of blue badge holders, and the development includes a range of sustainable transport measures and would not cause harm to the transport network. There would be a 56% reduction in carbon emission beyond Part L of the 2013 Building Regulations and a financial contribution would be secured to achieve 0 carbon.

The applicant’s representatives then provided the following information in support of the application: - The proposal would provide genuinely affordable homes with high levels of occupancy. It was designed to create sustainable communities and build long term relationships with both residents and Lambeth as a whole. Page 14

- A number of indoor and outdoor amenity spaces would be provided along with a public children’s play space. The Community was at the heart of the plans and there would be dedicated on site staff and flexible tenancies. - The original plans had been redesigned to create more homes. The public realm had been designed for pedestrian routes through and around the site creating vital connections to the station. - Supportive feedback had been received from the local community. The development was powered by electrical and solar energy and was designed to achieve excellent sustainability credentials. Residents would benefit from cycle parking provision, a car club membership and cycle hire.

Officers provided the following information in response to Members’ questions: - In response to why the new proposed development did not include the angled roof from the initial plans, Officers indicated that the simplified roof form benefited the communal facilities. While the heights at the front of the site have been increased, there would be sufficient differentiation in the heights and the brick work to set the blocks apart. - Officers confirmed that the triangular layout of the blocks follows on the extant consent and the development incorporates angled windows and various projections to maximise the quality of accommodation. - Officers confirmed that the wheelchair accessible apartments would be spread throughout the development and would be near to the elevator for easy access. The circulation space would need to comply with Building Regulations. The size of the ground floor lobby would be small and residents would go straight up to the main deck with the reception, foyer and communal spaces. - Members questioned the wind tunnel effect on Wandsworth Road and Officers stated that wind specialists had assessed the area for the impact of the wind comfort level and confirmed that no mitigations measures were required at street level. Wind screens would be incorporated in the design of the roof terraces. - Members were concerned of the units facing the south of the building possibly overheating and Officers stated that the orientation and risk of solar gain in the south facing units would be mitigated by smaller window sizes and the balconies offering shade from the sun. The overheating strategy had also been assessed by the GLA and it was highlighted that the energy system incorporated would be able to temper temperatures in addition to provision of blinds. Officers confirmed that single aspects units include smaller unit sizes rather than family sized units. It was confirmed that access to the blocks would be secure for residents, with a 24-hour security covering all blocks and the applicant had discussed the safety aspect with the Metropolitan Police who were satisfied. - Access to the cycle stores would be through the elevator. The applicant had investigated reducing the number of doors residents would have to go through, however due to fire regulations, this had not been possible. - There would be CCTV throughout the building, however Officers were unsure as to whether they would be implemented in between the cycle stores. In relation to adapted cycles, Officers confirmed that a required percentage of cycle stands would include adapted bikes and that the proposed elevators can accommodate some types of non- standard cycles. A condition would secure further investigation into a possibility of delivering larger lifts. - Visitor cycle stands would comply with the new London Plan standards and would be easily accessible. Page 15

- In relation to the proposed development offsetting to reach carbon neutral, Officers confirmed that the application was accompanied by a Whole Life Cycle Assessment. Although it was not required for the application, as it was submitted before adoption of the London Plan, a sustainability consultant had confirmed that it followed the plan requirements and complied with the conditions. It was also highlighted by Officers that the proposed development contributed to 56% carbon reduction on site. Officers confirmed that the level of financial contribution to offset carbon emissions were proportionate to the scale of the development. - Officers confirmed that residents of all blocks would have access to all amenity areas. - The Lambeth Tenancy Strategy (LTS), which was adopted in 2020, provided guidance on the preferred housing products including for BtR schemes. The rent levels set out in LTS include target rents for family sized units and were more affordable than London Living Rents (LLR). The Committee considered the information provided by officers in conjunction with the report before making the following observations: - Members recognised the benefits of the new roof form, which outweighed the harm of the new design. The scheme optimised the use of the site and delivered benefits such as affordable housing, the uplift in three-bedroom family sized units and play spaces. - The tree planting, ecological features and improvements to the public realm were welcomed. Members liked the potential for a centralised energy source and heat reduction from the tube. - Members were disappointed with the large carbon offset contribution and stated that the building should have aimed to be built shorter. - Members thought the removal of the large penthouse units and the detailed design in materiality in bricks looked as if it was made of good quality, which would be a good contribution to the area. - Easy access for cyclists who wanted to store their cycles in the basement level was important and Officers in the design stages should be able to pursue the possibilities of doors that cyclists would have to go through to store their cycles. 20/02331/FUL:

It was MOVED by Councillor Wilcox, SECONDED by Councillor Kind, and

RESOLVED, unanimously

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

2. To agree to delegate authority to the Director of Planning, Transport and Sustainability to:

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

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

3. In the event that the Section 106 Agreement is not completed within 6 months of committee, delegated authority is given to the Director of Planning, Transport and Sustainability to refuse planning permission for failure to enter into a section 106 agreement for the mitigating Page 16

contributions identified in the report, addendums and/or the PAC minutes.

At 8:41pm the meeting was adjourned for five minutes.

3. CLAPHAM COMMON (CLAPHAM COMMON/CLAPHAM TOWN) 21/00180/RG3 Case No. 21/00180/RG3, (agenda item three, page 121 of the agenda pack, page one of the first addendum and page one of the second addendum).

The Planning Officer gave a presentation which included a summary of the report and Members were advised of the key material planning issues for consideration. The development proposed 11 events over a 52-day period, with four major event days across one weekend. The Common as a large public open space and this application was for solely for events on the Lambeth side of the common. There would be one major, three medium and seven small events.

The Common was classed as Metropolitan Open Land (MOL); only 10% of the common would be fenced off and the public would always have access to 90% of the common. The proposal would not harm the character and appearance of the Clapham conservation area and surrounding conservation areas. The proposal would not harm the setting or significance of the heritage assets. All events would be required to comply with the Event Lambeth Guidance on the Control of Sound at out-door events. This outlined 3 noise monitoring points for the major event, and condition 16 ensures a fourth noise monitoring point was secured at Notre Dame Estate. Furthermore, a noise management plan for Festival Republic was required to be submitted via condition 17.

All medium and major events would take place in areas of amenity grassland or hard standing, which would minimise their impact. Grass protection is carried out as part of the terms and conditions for hire. For each event, the level of any damage is determined during a site walk with the event organiser, the Council’s Parks team, and the Events team. Damage is assessed based on pre and post-event surveys. A proposed programme of reinstatement is drawn up. This discussion informs aspects of the proposal that could be improved in the future, and further measures that may be considered necessary. For each event, the organiser will be required to submit a bond to Event Lambeth.

Applications for events held on the Common were required to be accompanied by a waste management plan, which is assessed by EventLambeth as part of the event applications process. Furthermore, condition 6 requires all waste, refuse and recycling to be removed from the relevant event site and the area within 10m of the perimeter of the event site 1 day after completion of de-rig.

Following the officer’s presentation, objectors made the following points: - The online consultation records received 318 comments and 315 of them were against the proposals. It was clear that residents did not want a ‘blanket’ permission to be granted. - One proposed event involved the use of the Common for 29 consecutive days in the middle of the summer school holidays and could involve 320,000 visitors. - Other concerns expressed included noise, criminality and anti-social behaviour. - The volume of events on the Common had caused a significant amount of damage and some of the Common now seems irreparable. - The move to the redgra site and the fairground in Wandsworth was not considered a good idea because of their closeness to wildlife and the limited amount of access points. The site had been used recently without any consultation.

The applicant’s representatives then provided the following information in support of the Page 17 application: - This easily accessible space, aside from being used for events, was popular with dog walkers, recreational use, personal fitness, training sessions, bootcamps and organised sports games. It had become evident that this sports usage also impacted the ground conditions, without the maintenance that dedicated sports areas had. It was the cumulative result of all these activities that had led to the poor ground condition. - The only enhanced ground maintenance work in that location was from pre and post event work, funded by the events team and the event organisers. In 2018 the events team looked at allocating surplus income to a wholesale reconditioning project for this site. This was postponed to September 2020. - The reconditioning project has undertaken intensive ground decompaction, stripped vegetation and top layer of soil, amelioration – adding sand to clay soil to increase absorption and aid drainage, new top layer of nutrient rich soil, overseeding with a seed mix used in sports / high usage and fertilising. - This application is not one that permits EventLambeth “carte blanche” to hold events on Clapham Common and as in previous years does not include Electric Winter. - It was also clear that there had been some incorrect information circulated about this planning application. Even with planning permission there was no guarantee an event will be given permission to take place until they had met all the EventLambeth Criteria. The following representations were made by Ward Councillors:

Councillor Linda Bray made the following points: - Objected to the use of ‘blanket' permission and that major events would result in the common being out of use to residents. A ‘blanket’ permission was only appropriate if it related only to small events and the application included at least one major event. The Common was an especially important place this year as people were not able to go on holiday and there would be two major events on successive weekends. Councillor Joanna Reynolds made the following points: - She was not against the events but considered the ‘blanket’ permission unacceptable. Clapham Common had been particularly important for the community over the pandemic but had been fenced off for a long time. It was asked that the Committee look at the total impact of blanket events and the time the common would be out of use for the residents. Officers provided the following information in response to Members’ questions: - The term ‘blanket’ permission was mentioned by objectors and Officers advised that making one application enabled Members to see proposed events holistically and comprehensively. - The application was not seeking a ‘blanket’ permission in the sense of a permission for an unspecified number and duration of events. The application had clearly identified the events scheduled and the size of them. The events would last up to 56 days of the calendar year and the permission sought extended to the associated temporary installations. - Members discussed the issue of having information on the Lambeth events but not the Wandsworth events as it would still have an impact on biodiversity and noise pollution. Officers stated that the sound levels would be the same as previous years, as per Event Lambeth Guidance. - The number of cycle spaces for those attending the events would be decided depending on the size of the event and how much cycle space would be required. - The 2019 travel survey took note of how people travelled to the event, with sample sizes Page 18

of 4% and 9% out of 30,000 and 50,000 customers, respectively. - Officers found that it was best to conduct face to face surveys to capture people’s travel patterns, and the surveys demonstrated that cycling mode share was low and those who took part were not aware of the cycle parking available. There would be more promotional material used to advertise the cycle parking available for the events taking place in 2021. - There would be a reinstatement programme as part of the terms and conditions of the hire of the land, whereby the event organiser would submit a bond to cover the cost to repair the land. In the winter of 2020 and spring months of 2021 remediation measures had been put in place since there had been no events since August 2019. Officers had planned for the site to be used as soon as the work was completed. - Event Lambeth officers confirmed that if the ground was damaged after the event, they would carry out ad hoc repairs to improve the quality. The Events Team were working with Lambeth Parks team around the key measures for improving the ground quality. The income generated from the events could fund the ground maintenance programme for the year. The Committee considered the information provided by officers in conjunction with the report before making the following observations: - Reference to a ‘blanket’ permission had made in several of the representations to the Committee. - Members had differing views on the negative impact that the events would have on biodiversity. - A large festival event in Lambeth would bring individuals from other boroughs to support local businesses. - There was a strong argument for a single major event to be considered separately due to the number of days of the large event. - Members asked for more to be done to survey people who come to smaller events in relation to cycle parking usage. At 10pm the committee elected to proceed with the meeting for a maximum of a further 45 minutes in order to conclude the remaining matters of business.

21/00180/RG3:

It was MOVED by Councillor Wilcox, SECONDED by Councillor Simpson, and

RESOLVED, by six votes for to one against

1. To GRANT conditional planning permission.

2. To agree to delegate authority to the Director of Planning, Transport and Sustainability to finalise the recommended conditions as set out in the report, addendums and/or PAC minutes.

CLOSE OF MEETING

The meeting ended at 10.02 pm CHAIR PLANNING APPLICATIONS COMMITTEE Tuesday 25 May 2021

Date of Despatch: Tuesday 11 May 2021 Page 19

Contact for Enquiries: Farah Hussain Tel: 020 7926 4201 E-mail: [email protected] Web: www.lambeth.gov.uk This page is intentionally left blank Page 21 Agenda Item 3

Page 22

Address: The London Television Centre, 60 - 72 Upper Ground, London, SE1 9LT

Pre-application Development Presentation Case Officer: Ben Oates

Ward: Bishop’s Date Received: June 2020

Proposal: Demolition of all existing buildings and structures for a mixed-use redevelopment comprising offices, cultural spaces and retail uses with associated public realm and landscaping, servicing areas, parking and mechanical plant.

Applicant: Mitsubishi Estate / CO-RE Agent: DP9

RECOMMENDATION: No recommendation is made to the committee as this item is for a pre-application development presentation. Matters arising from discussions during the item will be recorded in the meeting minutes but will not be binding on the eventual decision-maker.

SITE DESIGNATIONS

Relevant site designations: Central Activities Zone (CAZ) North Lambeth Archaeological Priority Area Southbank And Waterloo (SOWN) Neighbourhood Area London Plan (2021) Waterloo Opportunity Area London Plan Thames Policy Area Protected Vista LVMF - Westminster Pier to St Pauls Cathedral - 8A.1 South Bank Conservation Area (CA38) Environment Agency Flood Risk Zone 3 Lambeth Local Plan (2015) Policy PN1: Site 9 – ITV Centre and Gabriel’s Wharf, Upper Ground

Adjacent to: IBM Building – Grade II Listed Building River Thames Site of Local Nature Conservation Importance (SINC)

LAND USE DETAILS

Site area (ha): 1.04 ha

NON-RESIDENTIAL DETAILS

Use Class Use Description Floorspace (m2) (Gross Internal Area) Existing Not defined Offices and television studios 40,359 m2

Proposed E1 Offices 81,500 m2 Retail (Restaurant / café / bar) 3,500 m2 Sui Generis Cultural / collaboration space 5,500 m2 Total 90,500 m2 proposed

Page 23

PARKING DETAILS

Car Parking Spaces Car Parking Spaces % EVCP Cycle parking (General) (Disabled) spaces Existing 105 Unknown 0 200 Proposed 0 2 100% 1,200 (long stay) 50 (short stay)

LEGAL SERVICES CLEARANCE

AUDIT TRAIL Consultation Name/Position Lambeth Date Sent Date Report Comments in department Received Cleared para: Susan Boucher, Legal Services 04.01.2020 05.01.2020 05.01.2020 Throughout Lawyer

Page 24

OFFICER REPORT

Reason for referral to Planning Applications Committee (PAC): This item is a Pre-application Development Presentation in accordance with the PAC’s terms of reference.

NOTE: A Pre-application Development Presentation is a presentation to the Committee by an applicant about a development proposal that has not yet been submitted for planning approval. The Committee’s terms of reference provide for the Committee to hear such presentations about strategic development schemes and for individual Members of the Committee to ask questions and highlight issues that may require further consideration by the applicant. Any pre-application proposal that is presented to the Committee will still require a planning application to be submitted and determined in due course. The Committee will not be making any determination of the planning merits of any matters that are presented to it in this Pre-application Development Presentation and accompanying officer report. Observations of the Committee in response to this item may be minuted but will not be binding on the eventual decision-maker. The purpose of this officer report is to provide a brief overview of the site and its planning history, the current development proposal, the pre-application process to date and relevant planning policies.

1 THE DEVELOPMENTSITE

1.1 The development site is situated in the South Bank area in the north-eastern corner of the Bishop’s Ward of Lambeth. The site is located immediately adjacent to the Queen’s Walk and the River Thames to the north and fronts Upper Ground to the south. The IBM Building is located to the west and Prince’s Wharf and Gabriel’s Wharf to the east. The site covers an area of approximately 1.04 hectares.

1.2 The existing building on site was the former home of broadcaster ITV until its departure from the borough in 2018. The site comprises ‘Kent House,’ a 25 storey (basement, ground, 22 upper floors and plant) office building and an adjoining four-storey podium. The building also includes six television studios, offices, editing suites, staff and ancillary accommodation. A basement level car park is accessed from Upper Ground, comprising 105 car parking spaces and approximately 200 cycle parking spaces.

1.3 Existing vehicular access is provided from three locations along Upper Ground - the West Gate; the car park access and the East Gate. The site also benefits from a private forecourt fronting Upper Ground, allowing for deliveries and access to the underground car park and service yard. The site has an ‘excellent’ level of accessibility to public transport (PTAL rating of 6B).

1.4 The site is within the South Bank Conservation Area, but not a listed or locally listed building. It is dissected by the LVMF 8A.1 viewing corridor from Westminster Pier to St Paul’s Cathedral. Please refer to the table under the heading ‘Site Designations’ for the full list of strategic and local planning designations relevant to this site. The site is also identified within a larger opportunity site in the Lambeth Local Plan 2015 (LLP), along with the Princes Wharf and Gabriel’s Wharf, but this is currently under review under the emerging Site Allocation Development Plan Document.

2 THE SURROUNDING AREA

2.1 The IBM building, which adjoins the site to the west, was recently designated as a Grade II listed building, whilst the Royal National Theatre (Grade II*) and a ‘Pride’ sculpture (Grade II) on Queen’s Walk are also located within close proximity to the Site. Other listed buildings of relevance to the Development include Somerset House (Grade I), and the Royal Festival Hall (Grade I). The adjoining property to the east at 58 Upper Ground also neither contains a listed or locally listed building, however Younger’s Building (the Neo-Tudor styled three storey building fronting onto Upper Ground) is considered to positively contribute to the Conservation Area. Page 25

2.2 Southbank Conservation Area which extends to the west and celebrates a row of contemporary, low- rise cultural buildings that front onto Queens Walk and the River Thames, including Royal Festival Hall, Queen Elizabeth House and the National Theatre. These buildings are typically moderately scaled with rich design that features sculptured and layered forms with a bold use of stone and/or concrete and surrounded by high quality public realm that provide viewing opportunities of London’s landmarks. The conservation area is unique for its inner London location in that its significance is centred on the post-war transition of the area and buildings that are relatively new compared to the nearby conservation areas on the opposite side of the Thames in Westminster and Temple. Notwithstanding this, these contemporary buildings and the surrounding public realm along the South Bank demonstrate state-of-the-art design and architecture for their time. The tall buildings within the clusters to the east and west are typically set behind lower buildings along the river and are of very different character.

2.3 The area to the south of the site is predominantly residential. Those immediately opposite the site (Mulberry Housing Co-Op and Iroko Housing Co-Op) were completed in the late 1980’s and early 2000’s respectively and consist of 3-5 storey perimeter buildings containing flats that enclose a central courtyard. Further to the south the residential properties are developed in the more traditional pattern of terraced housing and this is heavily influenced by the Georgian terraced dwellings within the Roupell Street Conservation Area.

2.4 The borough boundary with Southwark is a short distance away to the east where the OXO building sits within Southwark’s Old Barge House Alley Conservation Area. Further towards Blackfriars’s Bridge a cluster of tall buildings is emerging and a mixture of residential and office uses.

3 SITE PHOTOGRAPHS

Figure 1 - Aerial view of site (outlined in yellow)

Page 26

Figure 2 – Satellite image showing the application site and surrounding sites

Figure 3 – Photograph of site from Queens Walk

Page 27

4 PROPOSAL

4.1 Summary of the Proposal

4.2 The applicant is proposing a comprehensive redevelopment of the site to provide up to 90,000sqm of total floor space, which comprises: • Circa. 81,500 m2 of commercial floorspace including collaboration / affordable workspace, a co-working lobby at the ground level with function spaces and meeting areas: • Up to 5,500 m2 of cultural / collaboration space: and • Up to 3,500 m2 of retail (cafes and restaurants).

4.3 In addition, the proposal also includes circa. 3,900 m2 of public realm at ground level around the site, a communal open space for tenants at podium level and new connectivity for pedestrians across the site. This level of provision exceeds that of the extant planning permission on the site.

4.4 The applicant will provide a detailed presentation of the proposal.

5 Planning Performance Agreement

5.1 Mitsubishi Estate and CO-RE have entered into a Planning Performance Agreement plus (PPA+) with the Council. The PPA+ secures an enhanced pre-application process with a greater level of engagement. It consists of a number of key meetings:

• Meeting 1 – Developer meets Ward Councillors and planning officers to discuss the scheme and agree consultees and community representatives to invite to subsequent meeting • Meeting 2 – Ward Councillor and community representatives ask questions and provide comments on the scheme • Meeting 3 – Developer Presentation to PAC

5.2 There have been 20 pre-application meetings covering design, layout, massing, public realm / landscape, employment and cultural uses, daylight/sunlight impacts, sustainability, and transport. In addition, the following meetings have also taken place so far:

• 22 April 2020 – Growth Investment Panel (GIP) Meeting 1 • 18 August 2020 – Design Review Panel (DRP) 1 • 27 January 2021 – GIP Meeting 2 • 9 February 2021 – Ward Councillor Meeting • 23 February 2021 – DRP 2 • 25 March 2021 – Meeting with Ward Councillor and Community Representatives

5.3 The feedback from the above meetings is provided in Section 7 Consultations.

6 RELEVANT PLANNING HISTORY

6.1 Planning permission for redevelopment of the site was granted in May 2018, comprising:

Demolition of existing buildings and the construction of two new buildings (up to 14 storeys and 31 storeys in height with two basement levels) for the provision of circa. 44,434 sq.m of offices (Use Class B1), 3,634 sq.m of television studios (Sui Generis), 216 sq.m of retail (Use Class A1) and 213 residential dwellings (Use Class C3) with associated vehicle and cycle parking, access works, servicing and landscaping (ref: 17/03986/FUL)

Page 28

6.2 This was accompanied by an application for the adjoining site (Princes Wharf, 58 Upper Ground) for the demolition of existing temporary structures (external staircases, portacabin, bridge links and other structures) and making good to the fabric of the retained building.

7 CONSULTATIONS

7.1 Pre-application consultation has been undertaken by the Council as part of the enhanced PPA service and separately by the applicant.

7.2 Design Review Panel (DRP) 1

7.2.1 The applicant’s design team presented the proposal to the DRP. Below is the summary of the Panel’s advice:

• The Panel was comfortable with the proposed mix of uses. • The sophisticated architectural approach is appreciated. The design of the workspace, which was considered to be future proofed to changing working circumstances, is creative, innovative and responds to the site well. Openable windows were appreciated. • The Panel raised concerns about bulk and massing, particularly when viewed from Coin Street, Stamford Street and Waterloo Bridge. • The viewing platform was appreciated in terms of its use and public access, but concern was raised about it projecting out rather than being stepped back and this should be tested further. • The site was seen as permeable, providing worthwhile north-south connections, but the routes need to be ample, attractive, legible and need to draw people in. The Panel considered that the paths through the site may be too narrow and needs to be assured that they will work well day and night. • Concern was also raised about dependency on adjacent sites to deliver paths. The diagonal path was welcomed however further consideration should go into the Hub space, particularly dimensions and natural light. The function of the spaces should be considered further as well as their relationship to other surrounding public spaces.

7.3 Ward Councillor Meeting

7.3.1 The Council hosted a meeting between the applicant and ward councillors. The applicant presented the emerging proposal in detail and invited comments. No initial concerns were raised by ward councillors and recommendations were made on which local stakeholders to target for the next stage of engagement.

7.4 DRP 2

7.4.1 The applicant’s design team presented the updated proposal to the DRP for a second time. Below is the summary of the Panel’s advice:

• Overall the Panel commended the design approach that has the potential to result in a high quality development. The primary area of concern is the substantially increased quantum of development over the previous consented scheme, which despite the intelligent design approach leads to an overbearing and bulky building. Page 29

• The Panel acknowledged that many of the issues highlighted in the previous design review had been addressed; in particular the ground floor was progressing in the right direction by incorporating larger entrances and public realm to the north and south. However, there are concerns about the location and character of the community hub entrances and whether it’s entrance would be better suited to the north or the south location for increased visibility to optimise pedestrian engagement. For example, in relocating the hub entrance along Queen’s Walk the cultural offer would be more prominently presented in a way similar to other cultural uses in the Southbank CA. • The Panel see a tension between the covered hub as a collection of functions and as a space / route for promenade. The Panel suggested uncovering the space so that it is top lit. • The Panel has unease about the seemingly narrow width of the east and west routes; particularly on the IBM side where there are other challenges such as change in levels. The risk with narrow routes is that they are likely to have an adverse impact on pedestrian movement and flow and may not feel safe. • The Panel highlighted the importance of the proposals interface with Queen’s Walk as a busy promenade; it is important that the proposal works in relation to the flow of large volumes of people along Queen’s Walk. • The Panel suggested emphasising and celebrating the southern entrance point so that it is clearly visible from Upper Ground and draws people into the hub. • The Panel applaud the general approach to bio-diversity and are encouraged by the efforts to secure a good urban greening factor. • The majority of the Panel consider that the architectural strategy can produce a successful building that fits into the South Bank. However, whilst the articulation of the massing is successful, there are concerns that the quantum of development on the site results in a large and bulky building which is overtly dominant in its context. The panel suggests looking at options to reduce the quantum of floorspace - as a reduced mass would be beneficial in terms of both the impact on the setting and significance of designated heritage assets, townscape, and on neighbouring residential properties opposite the site. • The Panel supports the approach to materials which generally relate well to the character of the South Bank.

7.5 Meeting with Ward Councillor and Community Representatives

7.5.1 The Council hosted a meeting to allow the applicant to present the emerging proposals to a number of key local stakeholders. The following groups attended the meeting:

• IBM • BFI • Coin Street Community Builders • SoWN • Waterloo Community Development Group • Mulberry Housing Co-op • Iroko Housing Cooperative • Palm Housing Co-op • St Johns Church • LERA • Bishops Ward Labour

7.5.2 The following questions and comments were raised:

Office Use • Is there still a demand for office space? Page 30

• Will this quantum of office space change the character of the area? • What is the plan-b if the office space is not taken up – i.e. will it be converted to residential?

Cultural Space • Despite some support for the cultural offer in the proposal, groups asked for clarification of how this space would function, who would be the anchor tenant and how would it be maintained and managed? • The identification of cultural production and consumption generators on the map of this research suggests that the biggest creative centre is Somerset House. Doesn’t that accolade belong to the South Bank?

Retail / Restaurant Space • Is restaurant / café / bar the best use of the retail space in this location?

Design – bulk, scale, massing, form, architecture and materials • There is concern that the proposal is too big, bulky, overbearing and burdensome. Concern also raised that the architecture is not of high enough quality and will make a significant and permanent change on the character of the area. • Please clarify how the proposal reads as two separate blocks.

Design – public realm and open space • Despite some support for the public realm offer (including 40% of footprint of site as public realm), concern was raised that a lot of this includes edges of the building site. Can dimensions please be provided and comparable examples of similar public realm places be provided? • The active frontages onto the Riverwalk, which is a rare piece of quiet, uncommercialised green space on the riverside, has permission for landscaping improvements. Although active frontage is proposed in this location in the Local Plan, does the proposed public realm fronting Queens Walk conflict with the approved landscaping? • The proposed pedestrian link between the site and Princes Wharf creates a tunnel that may need to be closed at night. Please clarify this design strategy. • How many of the 5000 workers can the various terraces accommodate at lunchtime? Will this minimise the load on Bernie Spain Gardens and the river walk?

Design – verified views • Will there be more visuals / verified views of the proposal available when it is presented to the Planning Applications Committee (PAC) meeting? In particular: views from the south to indicate how it relates to neighbouring residential areas. • Please clarify how the proposal is smaller than those in the Blackfriars cluster when viewed from Waterloo Bridge. • Is there a physical model, and could it be shown during the next meeting?

Heritage • Please clarify how the proposal is respectful to the special architectural significance of the other buildings on the Southbank.

Daylight / Sunlight / Overshadowing • When will the details of the daylight, sunlight and overshadowing impacts be available?

Sustainable Design • There was support for the ambition towards sustainable design in the proposal. It was mentioned that the design will minimise its embodied energy impact and further offset emissions to ensure that the building would be operationally carbon neutral. Can this please be clarified and a commitment to it being contained in the planning application? Page 31

Scheme Benefits • Please clarify the package of benefits this scheme will offer.

7.6 Consultation undertaken by the applicant

7.6.1 In addition to the above meetings the applicant carried out their own public consultation in October 2020 and again in February – March 2021. To date the following have been undertaken:

• Set up of dedicated website https://www.givemyview.com/72upperground/news/sign-up-for- the-upcoming-72-upper-ground-webinars/5f6cb1dc342c4700041befff o This included a comprehensive community survey of over 1,890 people covering workers, residents, visitors and business owners • Distribution of two newsletters to 3,300 addresses within the South Bank and Waterloo area • 22 meetings including with local businesses, groups, and politicians • Four online consultation events that were attended by residents, workers, business owners and resident groups (two in October and two in February / March)

7.6.2 The application’s public engagement consultant advises that almost half of the respondents said that arts and culture was the most important feature of the Southbank, while sustainability was the development priority for three quarters of people. Three key themes emerged from the survey on the importance of the South Bank, they were: 1. Heritage & identity; 2. Location & atmosphere; and 3. Public spaces. There is a consensus that the area should introduce and preserve green space and be open and free to enjoy. Maintaining the South Bank’s clear identity is a key priority for the community and many respondents noted that all development should be in keeping with the iconic design of the area.

8 Key Planning Issues

• Land Use – the proposed redevelopment for an office led scheme (including affordable workspace) with a substantial offering of cultural space and ancillary retail units is supported by the Local Plan. The site is identified within a wider site allocation (SITE 9 - ITV Centre and Gabriel’s Wharf), which encourages a mix of uses including B1 offices, residential and active- frontage uses at ground-floor level.

Relevant policies: Policies ED2, ED3, ED7, ED11, ED14 and PN1 of the Lambeth Local Plan (2015); Policies HC5, SD4, E1, E2, E3, E9 and E11 of the London Plan (2021); Policies ED1, ED2, ED8, ED13 and PN1 of the Draft Revised Lambeth Local Plan (Jan 2020); P14 of the Southbank and Waterloo Neighbourhood Plan (2017 – 2032).

• Design and Conservation – The site is in a prominent location on the Thames riverfront, within the South Bank Conservation Area and the setting of several listed buildings. The site is also along LVMF 8A.1 viewing corridor from Westminster Pier to St Paul’s Cathedral. The massing and scale of the proposal has been led by the protection of these views and in reference to the surrounding context. The architectural form and façade treatment have been designed to reflect the unique heritage context of the South Bank Conservation Area and nearby listed buildings, which hold significance for the modern, high quality design of the buildings and their relationship with the river and public realm. Any residual heritage impact is likely to be considered to be ‘less than substantial harm’ based on an initial assessment by officers and Historic England. The applicant will need to demonstrate how the scheme’s public benefits would outweigh the harm.

Relevant policies: Policies Q1, Q3, Q4, Q5, Q6, Q7, Q8, Q9, Q10, Q19, Q20, Q22, Q23, 24, 25, Q26 and PN1 of the Lambeth Local Plan (2015); Policies D1, D3, D4, D5, D8, D9, D10, Page 32

D11, D12, HC1, HC2, HC3 and HC4 of the London Plan (2021); Policies Q1, Q2, Q3, Q4, Q5, Q6, Q7, Q8, Q9, Q10, Q19, Q20, Q22, Q24, Q25, Q26, Q27 and PN1 of the Draft Revised Lambeth Local Plan (Jan 2020); Policies P2, P4, P11, P12 and P18 of the Southbank and Waterloo Neighbourhood Plan (2017 – 2032); Paragraph’s 190 to 201 of the National Planning Policy Framework.

• Neighbouring Amenity – Whilst there are no neighbouring properties to the north of the site, the increased bulk of the proposal compared to the existing building is likely to have an impact on the amenity of the neighbouring properties. This includes residential properties opposite the site to the south. Officers have worked closely with the applicant’s project team to understand the full extent of impacts to these properties, which has led to a reduction in massing on the south elevation.

Relevant Polices: Policy Q2 of the Lambeth Local Plan and the Draft Revised Lambeth Local Plan (2020) and Policy D6 of the London Plan (2021).

• Transport – The proposal would be car-free with the exception of disabled parking bays and officers have discussed the logistics of servicing and deliveries with the applicant to uphold the ambitions for reduced traffic along the Spine Route. Cycling will be supported by the provision of long and short stay cycle parking facilities in the basement level and further visitor cycle parking spaces in areas of public realm.

Relevant Policies: Policies T1, T2, T3, T4, T6, T7, T8 of the Lambeth Local Plan (2015) and Draft Revised Lambeth Local Plan (2020); Policy T2, T4, T5, T6, T6.2, T7 of the London Plan (2021); Policy P18 of the Southbank and Waterloo Neighbourhood Plan (2017 – 2032).

• Sustainability – The applicant is targeting BREEAM ‘Outstanding’ and WELL ‘Platinum’ sustainability ratings with these ambitions evident at the forefront of the design process. This includes high performance façade design with optimised window to wall ratios, natural ventilation systems, energy efficient materials, renewable energy provision, green / biodiverse roofs and other urban greening initiatives. The site is also located within Flood Zone 3, although it benefits from flood defences, and the applicant has been encouraged to improve sustainable drainage initiatives.

Relevant policies: Policies EN1, EN3, EN4, EN5 and EN6 of the Lambeth Local Plan (2015) and Draft Revised Lambeth Local Plan (2020); Policies G1, G5, G6, G7, SI1, SI2, SI4, SI12 and SI13 of the London Plan (2021); Policies P3 and P5 of the Southbank and Waterloo Neighbourhood Plan (2017 – 2032).

9 Next Steps

9.1 Officers will continue to work with the applicant to refine the scheme. The applicant is aiming to submit the application at the end of June 2021.

10 RECOMMENDATION

1. No recommendation is made to the committee as this item is for a pre-application development presentation. Matters arising from discussions during the item will be recorded in the meeting minutes but will not be binding on the eventual decision-maker. Page 33 Agenda Item 4

Page 34

ADDRESS: 350 Kennington Lane, London, SE11 5HY Application Number: 20/04147/FUL Case Officer: Mr Mark Heaney Ward: Princes Date Received: 30.11.2020 Proposal: The temporary change of use for a 10-year period from Office (Class E(G)(i)) to Education (Class F1(a)) together with minor external elevational changes and other associated works. Applicant: Coventry University. Agent: Nathaniel Lichfields & Partners Ltd

RECOMMENDATION:

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

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

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

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

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

Page 35

SITE DESIGNATIONS

Relevant site designations: Central Activities Zone Central Activities Zone 3KCNA - Kennington Cross Neighbourhood Kennington Cross Neighbourhood Association Association NHP - Neighbourhood Planning Areas Kennington Oval And Vauxhall Forum (KOV) Conservation Area Vauxhall Conservation Area (CA32) Environment Agency Flood Zone Flood Risk Zones 2 & 3 Article 4 Direction Central Activities Zone - Article 4 B1a-C3 Opportunity Area London Plan Vauxhall Opportunity Area TPA - London Plan Thames Policy Area Thames Policy Area

LAND USE DETAILS

Site area (ha): 0.1025

NON-RESIDENTIAL DETAILS

Use Class Use Description Floorspace (m2) (Gross Internal Area) Existing E(G)(i)) Office Space 3037sqm

Proposed (Class F1(a)) University Teaching 3037sqm Facility

PARKING DETAILS

Car Parking Spaces Car Parking Spaces % of Bike Motor- (General) (Disabled) EVCP Spaces cycle Spaces Commercial Visitor Commercial Visitor Existing 0 0 0 0 Proposed 0 0 0 0 40 0

LEGAL SERVICES CLEARANCE

AUDIT TRAIL Consultation Name/Position Lambeth Date Sent Date Report Comments in department Received Cleared para: Peter Flockhart Legal Services 06/05/2021 10/05/2021

Page 36

EXECUTIVE SUMMARY

This application has been submitted by Coventry University which, supported by Guys and St Thomas’s NHS Trust foundation, seeks to establish its first educational facility in Lambeth. The application site is a vacant four-storey 3,037sqm office building with basement level (Use Class E(G)(i)) located on the north side of Kennington Lane. The building was recently fully refurbished under planning permission 19/01197/FUL. The building adjoins a residential block ‘Dexter House’ and ‘Muscovy House’ 4 to 8 Auckland Street to the north- west. The Kennington Lane Local Centre is approx. 11m to the east at No’s 316 to 348 Kennington Lane.

Coventry University seeks temporary planning permission of 10-years for a change of use of the entire building from office use to operate as a London based ‘satellite’ educational facility of Coventry University (Class F1(a)). The building would facilitate teaching for up to 300 students at any given time; however, the number of student placements on the site would be higher. All students would be studying for professional registered health qualifications including occupational therapy, nursing and physiotherapy, social work, and public health. At the end of the 10-year period the building would be able to revert to office use without a further planning permission..

The proposed temporary loss of the office use is a departure from Policy ED3 of the Lambeth Local Plan 2015 (LLP) and Policy ED1 of the Lambeth Draft Revised Lambeth Local Plan 2020 (DRLLP) because insufficient marketing evidence to justify the loss of the office use has been provided. Where a proposal is a departure from the development plan, planning permission can nonetheless be granted if there are material considerations that outweigh the departure in question.

In this case, those material considerations are the benefits to Lambeth (and London wide) residents from having access to additional professional registered health courses in the borough, and the expansion of the healthcare workforce through courses taught at the site. It is also material that there are no vacant Class F1 facilities of sufficient size within Lambeth or surrounding boroughs to host the proposed educational facility. The applicant has provided evidence of their search to find a suitable facility, and officers from the Council’s planning and regeneration teams have undertaken separate independent searches and have not been able to identify a suitable alternative Class F1 premises in Lambeth. The University needs a space to operate starting this September so building a new Class F1 facility is not a viable option. Although officers recognise the importance of protecting and delivering office space in the borough, it is considered that these material considerations are sufficient, in this instance, to outweigh determination of the application in accordance with Policy ED3 of the LLP and ED1 of the DRLLP.

The proposal complies with LLP Policy S2 of the LLP, by supporting a key healthcare sector within the borough. Letters of support have been provided by Guy’s and St Thomas’, Health Education England and the Salisbury NHS Foundation Trust.

Planning permission is also sought for the installation of 2 roof top condenser units and alterations to the rear elevation to replace a window and single door with double doors and installation of five louvred panels to serve mechanical heat recovery units. The replacement of the existing rear windows with five louvred panels is a necessary technical requirement in facilitating the efficiently heating the building which given their detailed design, would not adversely impact on the visual amenity of the area. The application site is considered to be too distant from the nearby heritage assets and the external works would be sufficiently discrete and sympathetic as to not impact on the surrounding Vauxhall Conservation Area to result in harm to its setting.

Page 37

The proposed use would only require two small condensing units to be installed on the roof of the building and, a new internal mechanical ventilation with heat recovery plant will be installed within the basement plant rooms. The plant within the basement is internal and so it does not require permission. However in light of the proposed roof top condensers, louvres and the change of use, planning conditions would ensure that noise mitigation measures would be in place to ensure the existing plant equipment would not result in significant adverse impacts on the residential amenity of neighbouring occupants. The development is considered to be acceptable in transport and highway terms; access to the building would be from existing entrances and conditions would ensure that there would be no unacceptable impact on the surrounding highway network. The site is located in an area with a high PTAL of 6(B) and a travel plan would be secured by condition to ensure sustainable healthy travel behaviour is promoted for users of the building.

Overall, officers consider that the change of use of 350 Kennington Lane would enable both strategic and local planning aspirations for the area to be achieved. The proposal has been assessed in accordance with Section 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, Section 70(2) of the Town and Country Planning Act 1990 and Section 38(6) of the Planning and Compulsory Purchase Act 2004, the NPPF and the development plan. In this instance, taking account of all the relevant material considerations, and notwithstanding the departure from the policy ED3 of the LLP, the proposal is considered to be acceptable in all other respects. As such, the weight of the material considerations considered are sufficient to justify a departure from the development plan in this instance such that the Council is able to support the proposed development.

Page 38

OFFICER REPORT

Reason for referral to PAC: The application is reported to the Planning Applications Committee in accordance with part (1)(A)(c) of the Committee’s terms of reference as it relates to a proposal which is a significant departure from the policies of the Council's Development Plan and part (1)(A)(b) as the change of use, by the development is 1,000 square metres or more.

The Terms of Reference can be found at the link below: http://moderngov.lambeth.gov.uk/mgCommitteeDetails.aspx?ID=600

1 THE APPLICATION SITE

1.1.1 The application site comprises a four-storey building with basement level with some ancillary external yard space and a ramp to the basement level accessed from Auckland Street. The building is a pastiche Regency style building dating from the 1990s. To the west of the site is the Grade II listed Royal Vauxhall Tavern, with Vauxhall Pleasure Gardens to the rear and west of the site. The building is adjoined to a residential block ‘Dexter House’ and ‘Muscovy House’ 4 to 8 Auckland Street to the north-west. The building is vacant, but the lawful use comprises 3037sqm of Class E(G)(i) office space.

1.1.2 The site is located within the Vauxhall conservation area. It is also within the Central Activities Zone, the Vauxhall, Nine Elms and Battersea Opportunity Area and the Thames Policy Area.

Figure 1: The application site.

Page 39

2 THE SURROUNDING AREA

2.1.1 The surrounding area comprises a mix of land uses including a range of residential and commercial/employment land uses.

2.1.2 The Application site adjoins Kennington Lane which forms part of the Transport for London Road Network; a crossing for Kennington Lane is located in close proximity to the site. As a result of its central location, the application site has a public transport accessibility level (PTAL) of 6b (best) and the entrance to Vauxhall train station is located approx. 70m to the south-west. Vauxhall bus station and underground station are located approx. 144m to the west. There are a number of TfL bus stops located to the front of the application site on Kennington Lane and also on Harleyford Road to the south.

2.1.3 The site is adjacent to Kennington Lane Local Centre which is approx. 11m to the east comprising of No’s 316 to 348 Kennington Lane.

2.1.4 On the opposite side of Kennington Lane (approx. 37m) are 3 Grade II listed buildings: 365 and 367 Kennington Lane, 363 (St Anne's House) Kennington Lane and Church of St Anne (RC) Kennington Lane. To the west (approx. 27m) is the locally listed Royal Vauxhall Tavern (Public House), No 372 Kennington Lane.

SITE PHOTOGRAPHS

Photo 1: View from Kennington Lane looking east.

Photo 2: View from Goding Street looking to the south-east Page 40

Photo 3: View from Kennington Lane looking west.

Photo 4: View from Glyn Street looking south west.

3 PROPOSAL

3.1.1 The application seeks the temporary change of use for a 10-year period from Office (Class E(G)(i)) to Education (Class F1(a)) together with minor external elevational changes and other associated works.

3.1.2 The building would operate as a London based satellite teaching facility of Coventry University supported by Guys and St Thomas’s NHS Trust foundation. The proposed courses the applicant seeks to offer would include, occupational therapy, nursing and physiotherapy, social work, public health.

3.1.3 Internal works are proposed which would subdivide the existing open plan office space at ground- third floors into smaller teaching spaces and staff spaces (office/staff room). At basement level it is proposed to create teaching rooms, it is noted that the plans appear to show an ‘apartment space’ within the basement level. The applicant has explained that this is a simulation apartment which would form part of the practical training for the students within a residential environment. It is recommended a condition (condition 10) is imposed to ensure that this unit would not become a residential unit.

3.1.4 The building would accommodate up to 300 students at any given time and 60 staff (45 FTE), split as 24 academic staff and 36 support staff.

Page 41

3.1.5 The scheme proposes limited external alterations which are shown at Figure 2. At ground floor level on the north elevation it is proposed to replace a single door and small window with a set of double doors at ground floor level. At ground-third floor level it is proposed to replace one window on each floor with a louvred opening comprising of black louvres to provide ventilation for air supply and exhaust to the new internally located MVHR (mechanical ventilation with heat recovery) units which are to be located at basement level. It is proposed to install two condenser units at roof level within the existing plant area.

Figure 2: Proposed North Elevation

Figure 3: Proposed Basement level Page 42

Figure 4: Proposed Ground Floor Plan

Figure 5 Proposed First Floor demonstrating teaching rooms Page 43

Figure 6: Third floor including staff areas

3.2 Amendment(s)

3.2.1 On the 18th of January the Applicant provided a revised plan ‘Ground Floor Proposed New Cycle Stands 2134-IDL-NA-GR-DR-A-11001 P00’ to show short stay cycle parking on the rear terrace.

3.2.2 On the 2nd of March the Applicant had provided further information regarding the marketing of the employment space and also details of alternative accommodation options the University has considered and the reasons for discounting those, this information is fully discussed within paragraph 7.3.21.

4 RELEVANT PLANNING HISTORY

4.1.1 19/01197/FUL – Planning Permission Granted – 11/11/2019 Replacement of windows, new window to replace existing door to reception lounge area, replacement of ground floor front entrance, new door to replace existing window (for terrace access) to rear elevation, new external gated entrance at rear and landscaped area at the rear. Removal of the car parking at basement level to provide additional office space and cycle storage for 40 cycles. Application permitted on the 11.11.2019.

4.1.2 18/00632/LDCE – Certificate of Lawfulness Existing Granted -22/06/2018. Application for a Certificate of Lawful Development (Existing) with respect of the property being used as offices (Use Class B1(a)).

Page 44

5 CONSULTATIONS

5.1 Statutory External Consultees

5.1.1 TFL Road Network Development - TfL have reviewed the updated Construction Logistics Plan and the Delivery and Servicing Plan and have raised no objections subject to the compliance with the CLP and DSP secured through conditions. With regard to the cycle parking TfL's concerns regarding the location of short-stay spaces still stand, but given the constraints of the site, TfL does not object to the cycle parking quantum on this occasion.

5.2 Internal Consultees

5.2.1 Design and Conservation – With regard to the proposed external alterations, the enlarged door is considered to be sympathetic to the building. No objections to the proposed louvres, subject to the imposition of a condition (Condition 5) secure further details of the set back of the louvres.

5.2.2 Transport – Lambeth Transport Planning initially raised issues relating to the cycle provision on site in terms of the quantity provided which would fall short of the required quantum by 13 spaces and due to its basement location including concerns as to the size of the lifts with respect to efficient cycle access.

Officer comment: The applicant has responded to the concerns by providing external short stay cycle parking which is accessible by a ramp. It is noted there are concerns regarding the quality of the access to the basement cycle parking, however it is noted that there is an existing cycle rail to the short flight of stairs to the basement. A condition will ensure that all cycle parking is to be implemented prior to the occupation of the building (Condition 8). Based on these changes the quantity and quality of the cycle parking is now acceptable.

5.2.3 Planning Policy - The proposal would result in the temporary loss of an office building, it is noted that marketing has been undertaken since February 2020 and consideration needs to be given the rigorousness of the marketing evidence in light of the one year marketing requirement of ED3 B i. Policy S2 of the Local Plan supports new higher education facilities, and it is considered that the scheme has potential to support a key healthcare sector within the borough.

Officer comment: The submitted marketing material was inadequate, and on this basis the proposed temporary loss of the office use is a departure from Policy ED3 of the Lambeth Local Plan 2015 (LLP) and Policy ED1 of the Lambeth Draft Revised Lambeth Local Plan 2020 (DRLLP). Officers consider that there are material considerations that are sufficient, in this instance, to outweigh determination of the application in accordance with Policy ED3 of the LLP and ED1 of the DRLLP. This is discussed at section 7.27.3 of this report.

5.2.4 Enterprise, Employment and Skills - No response received to date.

5.2.5 EHST Noise Pollution – No objection subject to a condition requiring the submission of an assessment of the acoustic impact arising from the operation of all internally and externally located plant and shall include a scheme of attenuation measures from all building services plant associated with the proposed use. This is secured as Condition 6.

5.2.6 Flooding (SUDS) - No response received to date.

5.2.7 Design Out Crime Officer - No objection subject to conditions regarding Secure by Design Certification. This is secured as condition 11.

Page 45

5.2.8 Regeneration Team (Lambeth’s Economy and Inward Investment Team) – Advised that they did not know of any suitably sized Class F1 premises in the borough that Coventry University could establish their proposed educational facility. However, they have advised that one of their priority growth sectors is health and life science and in this case they are supportive of this change of use.

5.2.9 Bioregional (sustainability) – Highlighted that no Sustainability Statement has been submitted to address policy EN4. A short statement to address the policy has now been submitted and considered to be acceptable given the scale of the development.

5.2.10 Lambeth Sustainability Team about Air Quality – Advised they were of the view the change of use would not impact on the air quality of the area. Advised that there were not different standards that needed to be applied between office to educational facility.

5.2.11 Veolia Waste Lambeth Planning App – No objection. The continued use of the existing refuse store with collections via private contractor is supported.

5.3 Other Consultees

5.3.1 Vauxhall Opportunity Area - No response received to date.

5.4 Adjoining owners/occupiers

5.4.1 A site notice was displayed from 09.04.2021 to 30.04.2021 and the application was advertised in the local paper on 09.04.2021. The formal consultation period ended on 30.04.2021.

5.4.2 No representations have been received.

6 POLICIES

6.1.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise. The development plan in Lambeth is the new London Plan (2021) and the Lambeth Local Plan (September 2015). This application is also subject to the heritage statutory provisions as set out in the agenda pack and heritage analysis of the report.

6.1.2 Following the successful completion of the Examination process and formal consent to publish by the Secretary of State, on 2 March 2021 the Mayor of London formally published the new London Plan which now has full weight in planning decisions.

6.1.3 The LLP is currently under partial review to ensure it complies with amendments to the National Planning Policy Framework (NPPF) and the new London Plan. The Draft Revised Lambeth Local Plan (DRLLP) underwent public consultation under Regulation 19 of the Town and Country Planning (Local Plans) (England) Regulations 2012 between 31 January and 13 March 2020 and was submitted to the Secretary of State for examination on 22 May 2020. The examination hearing took place between the 27 October and 13 November 2020. The Inspector’s proposed main modifications will be made available for public consultation between 15 February and 29 March 2021. With exception to DLLP policy ED2, those draft policies that are unaffected by proposed main modifications can be considered to have significant weight at this point, with moderate weight afforded to those policies that are subject to proposed main modifications.

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

Page 46

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

7 ASSESSMENT

7.1.1 The main planning issues are:

1. Whether the potential loss of the Use Class E(G)(i)) office space is acceptable 2. Whether Use Class F1(a)) is an acceptable use for the building 3. Whether the proposed external modifications are acceptable from a design and conservation perspective 4. Whether any amenity impacts can be acceptably mitigated 5. Whether any transport impacts can be acceptably mitigated

7.1.2 Other relevant matters that are also discussed in this report are:

• Skills, employment and training opportunities • Designing Out Crime • Sustainable design and construction • Flood risk • Fire safety • Land contamination • Planning obligations and CIL

7.2 LAND USE

7.3 Loss of Use Class E(g)(i)) Floorspace

7.3.1 The application has been advertised as a departure due to non-compliance with the tests in policy ED3, however the applicant has undertaken some marketing of the property and for completeness the details of the marketing are considered below against the tests established within policy. Officers are of the view that the application does not pass test 1 with regard to the amount of evidence submitted regarding the marketing exercise and the depth of the marketing information that is normally required. On this basis the application must be assessed as a departure from Policy ED3 of the LLP.

7.3.2 LLP Policy ED3 (b) states that proposals for change of use or redevelopment of large offices (offices over 1,000sqm in area) will be supported provided the tests outlined in the policy are met. The relevant tests for this application are as follows. For the loss of the office to be policy compliant the development would have to meet all three tests.

(i) there is no demand for the office floorspace as demonstrated by evidence that the floorspace has been vacant and continuously marketed for a period of at least one year; and

(ii) it would not be feasible and/or viable to refurbish, renew or modernise the offices in order to meet the requirements of existing or future occupiers as demonstrated through appropriate supporting evidence; and

(iii) it would not be feasible and/or viable to adapt the office floorspace as smaller business (B1) units to meet demand from small businesses. This should be demonstrated through marketing evidence and an independently validated viability assessment.

Each of these tests will be discussed in detail below.

Page 47

7.3.3 DRLLP policy ED1 (c) continues the above policy aims and states that proposals involving a complete loss of office floorspace will not be permitted unless the exception tests are met; these remain as per the current adopted Lambeth Local Plan albeit with an alteration to test (i) which changes the length of time for the marketing of the property from one year to two years. It is noted that both the LLP and DRLLP also contain the exception to policy which allows for the office floorspace to be lost if it is to be replaced within the vicinity and within Lambeth, however this is not relevant to the current case as no replacement office space is proposed.

7.3.4 The Council has also provided guidance about the implementation of LLP Policy ED3, including the extent and quality of marketing that is expected of applicants, in the document titled Marketing of Employment Premises and Sites Guidance Note (October 2015).

Test 1: there is no demand for the office floorspace as demonstrated by evidence that the floorspace has been vacant and continuously marketed for a period of at least one year

7.3.5 The application does not pass this test.

7.3.6 It is acknowledged that the site has been marketed to an extent (and vacant) since February 2020; which is more than one year however there are concerns about the demonstration of this marketing, and additionally this period does not meet the 2 year requirement within policy ED1(c)(i) of the DRLLP. It is officer view that the marketing campaign was not sufficiently rigorous to comply with the requirements of policy ED3 or the Marketing of Employment Premises and Sites Guidance Note (October 2015) for the following reasons.

7.3.7 Whilst the period of the marketing was sufficient, the application does not meet the requirements established within the Marketing of Employment Premises and Sites Guidance Note 2015. The general requirements from within section 3 of the Guidance Note have not been fulfilled to the level of detail that is normally expected. The evidence of marketing required to be submitted should ordinarily include a copy of the dated letter of instruction to the commercial agent, details and photos of onsite marketing boards which are constant throughout the period, dated records of web-based marketing, dated advertising within target publications, examples of comparative completed transactions on similar properties to demonstrate an asking price commensurate with market values, and a detailed log of all enquiries on the site.

7.3.8 The applicant submitted a Marketing Report dated March 2021 to support the application which demonstrates that since June 2019 marketing brochures and publicity for the office building have been prepared and available, however details of the circulation of this publicity has not been fully provided.

7.3.9 The agent advises that the site and letting information was shared on the website for the office building which was circulated to the London agency market, together with posters on the tube advertising the website. The website remains visible as does the listing on listings websites although it is shown as ‘under offer’.

7.3.10 The applicant has advised that the floorspace has been advertised on the basis that the floorspace could be let on a floor by floor basis alongside the whole building being let to an individual user. The recent fit out to ‘plug and play standard’ demonstrates that the property can be efficiently divided to accommodate a range of business sizes.

7.3.11 In regards to the rent levels, the applicant has provided a letter from JLL and Union Street Partners confirming that they were marketing the property and seeking reasonable rental levels, reflective of the market, this has not been supported with evidence of other similar properties, however it is noted that this assertion is made from a professional in the field. The applicant also advised that during the marketing period an offer was made and the agents had a willingness to accept competitive rental levels for the building for other occupiers, however this acquisition did not reach completion.

Page 48

7.3.12 Regarding the occupier interest, a detailed log of all interest was not submitted. The supporting information states that seven prospective viewings of the building took place since September 2019. Another offer was made in February 2020 but fell through as the tenant’s requirement was terminated. No other formal offers were made other than from Coventry University.

7.3.13 Whilst the property was marketed and details of a marketing campaign have been provided, Officers are of the view that this evidence does not sufficiently demonstrate the continuous and thorough marketing of the site for a period of 1 year in compliance with Policy ED3. Additionally, it is noted that the marketing evidence provided would further fall short in both time period and rigour of the 2 year requirement established within DRLLP policy ED1(c)(i). It is for this reason that the application is being considered as a departure from the development plan policy. Where a proposal is a departure from the development plan, planning permission can nonetheless be granted if there are material considerations that outweigh the departure in question.

Test 2 (ii) it would not be feasible and/or viable to refurbish, renew or modernise the offices in order to meet the requirements of existing or future occupiers as demonstrated through appropriate supporting evidence.

7.3.14 The application passes this test. The application site is a recently refurbished office building that has been built to “turn-key” standards. The applicant has provided evidence that they advertised the site to be fully or partially occupied. Therefore the site does not require refurbishment or modernisation, and the applicant has demonstrated flexibility in meeting the space requirements of potential occupiers.

Test 3: (iii) it would not be feasible and/or viable to adapt the office floorspace as smaller business (B1) units to meet demand from small businesses. This should be demonstrated through marketing evidence and an independently validated viability assessment

7.3.15 The application passes this test. Test (iii) requires adaptation for smaller business units and in light of the above, it is considered that the applicant has demonstrated that they have been flexible and sought to meet the demands of small and/or large businesses. The Union Street and Partners marketing website (extract in Figure 7 below) shows that the application site has been advertised for office space and advertised together, per floor to appeal to smaller businesses. The marketing brochures show that the floorplates could be occupied by a single user, and that the floors could be individually let. Officers consider that the applicant has advertised the building in a flexible arrangement to accommodate small E(g)(i) use.

Page 49

Figure 7: Demonstration potential subdivision of the office space

Departure from Policy ED3

7.3.16 On the basis that the application does not pass test 1, it was advertised as a departure from Policy ED3 LLP. Where a proposal is a departure from the development plan, planning permission can nonetheless be granted if there are material considerations that outweigh the departure in question.

7.3.17 In this case, those material considerations are: • The benefits to Lambeth (and London wide) residents from having access to additional professional registered health courses being taught in the borough, • The expansion of the healthcare workforce through courses taught at the site, and • The fact that there is not a suitably sized and vacant Class F1 facility in Lambeth of surrounding borough that Coventry University could occupy.

7.3.18 In addition, London Plan Policy S2 states that development proposals that support the provision of high quality new and enhanced health and social care facilities to meet identified needs and new models of care should be supported. Lambeth’s Economy and Inward Investment Team have advised that a priority growth sector for the borough is health and life science and as such they support the proposed development.

7.3.19 In support of the application and to advise of the benefits the scheme will offer the Applicant has advised that there are currently 47 students on a Level 5 Nursing Associate Apprenticeship who are being taught remotely with the practical elements taught at Guy’s & St. Thomas’s and it is hoped that these students will be transferred to the subject site for their teaching from September 2021. Coventry University are already delivering apprenticeships in health and social care for 15 employers in London. The applicant has advised that a number of these employers are within Lambeth or deliver commissioned services for the people of Lambeth, including Kings College Foundation Trust, Guys and St Thomas NHS Foundation Trust, Great Ormond Street, Homerton University Hospital. Additionally the applicant were commissioned by the Pan London ADASS group, which Lambeth is a key member, to deliver Occupational Therapy apprenticeships for London. The first group of London apprentices started in January 2021.

Page 50

7.3.20 The application has been supported by the Deputy Chief Executive of Guys and St Thomas’ NHS Foundation Trust who advises that one of the factors inhibiting their ability to proceed with their plans to develop a large new undergraduate programme is the access to learning space. Additionally the regional director for London NHS Health Education England have advised their support for the application which would enable Guys’ and Saint Thomas' NHS trust to realise their plans to expand their workforce. Furthermore the Lead for the Talent for Care Programme, Health Education England has advised that the proposed development is viewed as crucial to the successful delivery of, in the immediate need, the pan-London Occupational Therapist programme which has been commissioned jointly between the NHS and the London boroughs but also in the longer term to increase the capacity to train and support the future entrants into the Allied Health professions to meet the challenges facing the NHS and social care systems.

7.3.21 Officers requested the applicant to demonstrate whether there are alternative sites, within the borough or the required locality of the hospitals which could fulfil the needs of applicant whilst also retaining the office stock within the borough. Regarding the required location of the training centre, it is noted that the building is proposed to operate as a London based satellite teaching facility of Coventry University, offering courses for professional registered health qualifications supported by Guy’s and St Thomas’ NHS Trust foundation. The Trust has developed a partnership to a large new undergraduate programme to support the implementation of its Nursing Associates. Registered Nurses are required to undertake 50% of their training within the hospital, which they do in blocks of weeks. For Nursing Associate, Occupational Therapy and Physiotherapy apprenticeships, the students are required to attend campus one day per week and their workplace four days a week. There therefore is a requirement for a learning space which is local to Guy’s and St Thomas’ to facilitate the logistics of apprentices combining practical experience at the hospitals together with their education.

7.3.22 In January 2020 Avison Young was instructed to undertake a detailed site search to find a leasehold premises that would offer suitable accommodation.

7.3.23 The criteria for the search were as follows:-

• South of the Thames within a reasonably convenient travel distance of Guy’s and St Thomas’ hospitals; • 25,000 to 30,000sq ft depending on floorplate limits and design capacities; • An occupancy ratio of at least 1:10 - ideally 1:8m2; • A lease of 10- 15 years with tenant breaks for flexibility; • A rent limit of c. £50/sq. ft ex Vat due to a limit of overheads the business can sustain given fixed fee income per head from students; • Immediate availability to meet the university’s original timeframe of offering courses from January 2021; and • A building in reasonable condition with respect to structure and M&E to limit future service charge/maintenance liabilities.

7.3.24 Approximately twenty options were assessed, set out in the Table 1 at Appendix 5 of this report. It is noted that these were all current office spaces and as such would present a similar policy issue to the subject site. 5 of the sites were located within Lambeth. Avison Young widened the search parameters to examine alternative locations where office space is more abundant for example in Canary Wharf together with buildings just north of the River Thames. However many of these presented difficulties in practicalities for students in terms of the connection between practical work experience at the hospital and the learning requirement of the apprenticeship. The search concluded that there were no other suitable options that offered the space required in an accessible location and at the required rent levels. In addition, the subject site presented as an attractive option due to it being a newly refurbished building with new lifts, WCs and M&E and good size floorplates and occupancy levels (subject to the widening of fire exits).

Page 51

Figure 8: Venue Options considered within the site search (dark blue pins)

7.3.25 It is acknowledged that policy seeks to protect office space within the borough, however in this case it is considered that the proposal has specific and unique merits which must be considered in balance with the harm resulting from the loss of the office jobs. However, the scheme would provide employment for 60 staff (45 FTE), split as 24 academic staff and 36 support staff. It also provides a facility to allow for the training of up to 300 students at any one time, which would include up to 70 Occupational Therapy student apprentices with the Pan-London Consortium of Councils (including Lambeth) and circa 50 nursing associate student apprentices with Guys & St Thomas and Kings College. It is considered that as a result of the site search exercise the Applicant has demonstrated to Officers that there are no alternative options available to the university, either within the Borough or the wider locality. The application is supported by the local NHS Trust who explains there is a local and regional need for the use. Whilst not as thorough as required by the Planning Guidance Note, a marketing campaign has been undertaken which has gone some way to demonstrating that there is no immediate demand for the space as an office use. It is also noted that the proposal is for a temporary (10 year consent) after which the building would return to the boroughs’ office stock, without requiring further planning permission and this is secured by condition. The applicant is seeking a temporary permission to allow for the near immediate provision of a key healthcare sector within the borough by tackling the shortage of health workers in London within the proposed building whilst enabling the building to return to an office use at the end of its lease with the landowner. Officers consider that a temporary planning permission is appropriate to enable the temporary use (a ‘meanwhile use’) of this vacant building prior to any longer-term proposals coming forward whilst also ensuring that office building stock in Lambeth is retained in the long term.

7.3.26 In conclusion, although officers recognise the importance of protecting and delivering office space in the borough, it is considered that the material considerations discussed above are sufficient, in this instance, to outweigh determination of the application in accordance with Policy ED3 of the LLP and ED1 of the DRLLP.

7.4 Principle of Use Class F1(a) Establishing on the Site

7.4.1 The proposal is for a new educational facility and falls under the wider definition of a ‘community premises’ for the purposes of Policy of the LLP. Policy S2 (New or improved community premises) states that new or improved premises for higher and further education will be supported provided the tests outlined in the policy are met. These tests are:

I. the site is appropriate for their intended use and accessible to the community; II. the location, nature and scale of the proposal, including hours of operation, do not unacceptably harm the amenities of the area through noise, disturbance, traffic generation, congestion, local parking or negative impacts on road safety; and Page 52

III. the facilities are designed to be flexible, adaptable and sited to maximise shared community use of premises where practical.

7.4.2 Each of these tests are discussed in turn below;

a) Test 1: the site is appropriate for their intended use and accessible to the community

7.4.3 The site is within a PTAL rating of 6b which is considered the best and as the site is within walking distance of the Vauxhall District Centre it would be accessible for use by the local community. Given the nature of the use, and as detailed in paragraph 9.19 above, it is important to the use that the site is accessible by its future users; it is considered that the location in relation to Guy’s and St Thomas’ would meet this requirement. The lawful use of the site is already E(G)(i) commercial and the surrounding area is mixed-use in nature, therefore the site is considered acceptable for a community use.

b) Test 2: the location, nature and scale of the proposal, including hours of operation, do not unacceptably harm the amenities of the area through noise, disturbance, traffic generation, congestion, local parking or negative impacts on road safety.

7.4.4 The impacts of the development are discussed elsewhere within the report however in summary, officers conclude that subject to conditions restricting the types of F1(a) uses that can establish on the site, and conditions about noise and the management of the site that any amenity and transport impacts can be mitigated.

c) Test 3: the facilities are designed to be flexible, adaptable and sited to maximise shared community use of premises where practical.

7.4.5 The application site is an existing building and would be internally adapted to meet the required needs of the teaching facility. In respect of its proposed use, it could not be expected to utilise the building as shared community space due to the building being temporarily used as a medical teaching facility.

7.4.6 The proposal layouts would be reconfigured as shown on the proposed floor plans at Appendix 4 to accommodate the proposed F1(a) use. (please note such internal works do not require planning permission). As such the proposal would comply with policy outlined above.

7.4.7 In conclusion the proposed development passes all the tests set out in Policy S2 of the Lambeth Local Plan 2015 and Policy S2 of the Draft Lambeth Local Plan. The proposed use is acceptable for the application site.

7.5 Design and Conservation

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

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

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

Page 53

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

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

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

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

7.5.8 What follows is an officer assessment of the extent of harm which would result from the proposed development to the scoped heritage assets provided by the applicant as part of its submission. This includes Conservation Areas, and neighbouring Listed Buildings. In this case an individual assessment against each heritage asset is provided as a cumulative assessment is not required given the scale and nature of the proposal. Particularly as the alterations to the building are minor, the louvres are located on the rear elevation and the 2 roof top condensers are screened behind an existing roof parapet. would not be visible from Kennington Lane This individual assessment is then followed by an assessment of the heritage benefits of the proposals.

7.5.9 The proposals seek to replace a window and door with a new timber double door on the north elevation of the building. The mouldings and finish would match the existing doors.

Figure 9 Existing window and door (above left) and proposed doors (above right).

Page 54

7.5.10 On the left side of the rear elevation (visible from Vauxhall Pleasure Gardens) four windows would be replaced at levels ground floor to level 3 respectively with louvres set into the existing openings to serve mechanical heat recovery units. One ground floor window would have a louvre installed above it. The louvres would be finished in black (RAL 9005). The proposed louvres are required to allow supply and exhaust air to be circulated to the internally located MVHR units, these are new units to cater for the proposed use and would be located at basement level. The number and size of the louvres have been kept to a minimum and they have been arranged in a consistent manner that serves to reduce the overall impact on the rear elevation.

Figure 10: Proposed louvres installed on the North elevation.

7.5.11 At paragraph 2.50 of the Vauxhall Conservation Area Statement, No. 350 is identified as is a good office block dating from 1990s in a pastiche Regency style which sits well with its neighbours to the east and takes some of its architectural references from the RVT. Paragragh 3.2 provides guidance for alterations to existing properties and advises that details characteristic of the area should be retained and repaired wherever possible.

Figure 11: Proposed condenser units in the context of the existing plant.

7.5.12 It is only in this way that the special character (i.e. the buildings within the conservation area such as No. 350 as identified within the Vauxhall Conservation Area Statement above) and appearance of the area can be retained.

Page 55

7.5.13 LLP policy Q11 art (a)(ii) states that to ensure, wherever possible, that new or replacement plant or equipment (for example: meter boxes, pipes, cables, antenna, air conditioning units) are fully integrated into the building, are not placed on publicly visible elevations and, where integration is not an option, are adequately and robustly screened.

7.5.14 LLP policy Q20 states that development affecting listed buildings will be supported where it would (ii) not harm the significance/setting (including views to and from).

7.5.15 LLP policy Q22(a) states that development proposals affecting conservation areas will be permitted where they preserve or enhance the character or appearance of conservation areas by; respecting and reinforcing the established, positive characteristics of the area in terms of the building line, siting, design, height, forms, materials joinery, window detailing etc.

Impact on heritage assets: Conservation Areas

7.5.16 The Council’s Conservation and Urban Design team have reviewed the application and have raised no objection to the proposed change of use of the building from an office to a teaching facility, and are of the view that the external changes would not result in any harm to the character and appearance of the Vauxhall Conservation Area.

7.5.17 The Council’s Conservation and Urban Design Officer as raised no objections to the external alterations noting that the proposed enlarged door is sympathetic to the building and the louvres would be located to the rear of the site, would be aligned on each floor and painted black to match the window surrounds. It is considered that the proposed window louvres are neatly detailed. The Conservation Officers advised that the window louvres should be set within the window reveal to match the existing window location and not set forward in order to reduce their impact. Officers recommend imposing a condition (Condition 5) to secure further detailing of the louvres, including their placement within the window reveal to ensure they are acceptable.

7.5.18 Subject to this condition, officers consider that the proposed external alterations to the building would not result in any harm to the character and appearance of the Vauxhall Conservation Area.

Impact on heritage assets: Statutory Listed Buildings

7.5.19 As stated above, located on the opposite side of Kennington Lane (approx. 37m) are 3 Grade II listed buildings: 365 and 367 Kennington Lane, 363 (St Anne's House) Kennington Lane and Church of St Anne (RC) Kennington Lane. Given that the alterations to the building are minor, located on the rear elevation and would not be visible from Kennington Lane Officers consider that there would be no harm to the surrounding statutorily listed buildings.

Impact on heritage assets: Locally Listed Buildings/Structures

7.5.20 To the west (approx. 27m) is the locally listed Royal Vauxhall Tavern (Public House), No 372 Kennington Lane. Given that the alterations to the building are minor, discretely located on the rear elevation and would not be visible from Kennington Lane Officers consider that there would be no harm to the surrounding locally listed Royal Vauxhall Tavern.

Page 56

Impact upon heritage assets: Summary

7.5.21 Regarding all of the above, Officers consider that the proposed changes to the fenestration and doors are considered to preserve the character or appearance of the Vauxhall Conservation Area and setting of the surrounding statutorily and locally listed buildings and would not be contrary to the guidance within the Vauxhall Conservation Area Statement and LLP policies Q5, Q11, Q20, Q22 and Q23, DRLLP policies Q5, Q11, Q20, Q22 and Q23 and LP policies D4 and HC1.

7.6 Amenity for Neighbouring Occupiers

7.6.1 Policy Q2 of the LLP contains policies about ensuring developments do not inappropriately impact on amenity. Part (vii) of Policy Q2 states that service equipment (including lift plant, air handling/extract, boiler flues, meter boxes, gas pipes and fire escapes) is fully integrated into the building envelope or located in visually inconspicuous locations within effective and robust screening/enclosures, and does not cause disturbance through its operation.

7.6.2 LLP Policy S2(a)(ii) of the LLP states that proposals for new or improved premises for higher and further education, childcare, worship, health care (including hospitals), sports, recreation, affordable meeting space and other community uses will be supported where: (i) the site or buildings are appropriate for their intended use and accessible to the community; and (ii) the location, nature and scale of the proposal, including hours of operation, do not unacceptably harm the amenities of the area through noise, disturbance, traffic generation, congestion, local parking or negative impacts on road safety. With regard to the transport impacts of the development this is dealt with elsewhere within the report.

Visual Amenity

7.6.3 The applicant has provided full details of all external alterations proposed to the building and consider that the rear louvres would be discretely located on the building and would not compromise surrounding visual amenity. With regard to the 2 new roof top plant condensers which would be located in an area of roof and screened behind an existing parapet wall which accommodates existing roof top plant. Officers have reviewed this location and consider that there would no unacceptable impacts on the visual amenity of the surrounding area in compliance with LLP policy Q2(i).

Noise and service equipment.

7.6.4 It is noted that the building is directly adjoined to a residential block ‘Dexter House’ and ‘Muscovy House’ 4 to 8 Auckland Street to the north-west. The supporting plans show the existing plant on the roof as well as plan showing the two new rooftop plant condensers and their specification. Officers recommend a condition to require an acoustic compliance report. The report should make clear the previous any attenuation measures to ensure the rating level of noise emitted from all building services plant associated with this use is 5 dbA less than background noise. This condition would ensure that the plant does not cause disturbance to surrounding occupiers through its operation.

7.6.5 As such should permission be granted then a noise condition would be imposed to ensure amenities of adjoining occupiers and the surrounding area are protected in compliance with Policy Q2 of the Lambeth Local Plan (2015), Policy Q2 of the Lambeth Draft Local Plan and Policy D14 of the London Plan (2021).

Page 57

Noise and Disturbance from Use

7.6.6 The proposed use would have up to 300 students at any one time on site, in addition to the staff. The nearest residential uses are located to the rear of the site fronting Auckland and Glyn Street. The main entrance to the building is accessed from the corner of Kennington Lane and Glynn Street. The site is located on a busy road in the Central Activities Zone and adjacent to a local centre. It is considered that the area is mixed use in nature. It is considered that the change of use would lead to an increase in visitors to the site and activity around the building, however it is considered that this would not be out of context in the surrounding area. The internal layout would contain large lecture halls within the building and as such there will not be the exist of large groups of students at one time. In addition, the main source of activity would be focussed on the entrance on Kennington Lane which is away from the neighbouring residential uses and the site does not contain external communal gathering areas. As such it is considered that the development would comply with Policies S2 and Q2 of the Lambeth Local Plan (2015), Policies S2 and Q2 of the Lambeth Draft Local Plan and Policy D14 of the London Plan (2021).

7.7 Transport

7.7.1 LLP Policies T3, T6, T7 and T8 seek to ensure that proposals for development have a limited impact on the performance and safety of the highway network and that sufficient and appropriate car parking and cycle storage is provided whilst meeting objectives to encourage sustainable transport and to reduce dependence on the private car.

7.7.2 The application site has a PTAL score/classification of 6(b) of ‘excellent’. The site is close to Vauxhall Tube and railway station and Vauxhall TfL bus station which it is envisaged would be used by the majority of students and staff.

Access, Traffic, Parking:

7.7.3 The building is located within the controlled parking zone (CPZ) and the teaching facility is required to be secured as (business) permit free (s106). The applicants have agreed to this in principle.

7.7.4 With respect to fully accessible (i.e. Blue Badge Holder Only) parking, the Applicant has stated that an existing accessible car parking bay is present on Auckland Street and Blue Badge holders would be able to park on the single yellow lines on Auckland Street for up to three hours. It is also noted that the previous application secured a financial contribution to be used by the Council for the provision of an on-street disabled car parking space. The Transport Planner has not raised an objection to the accessible parking of the scheme in light of this existing provision.

Travel Plan

7.7.5 Policy T6 of the LLP requires Travel Plans to accompany all major planning applications to promote sustainable travel and minimise the number of trips by car.

7.7.6 A total of 45 FTE staff would be based on-site and the building would facilitate teaching for up to 300 students at any given time. Students would typically comprise apprentices attending the site once a week for teaching whilst working elsewhere for the remainder of the week. The supporting information to the application estimates that 85% of users of the facility would travel by public transport, with the remaining 15% travelling by active modes. This target would aim to increase the uptake of active modes of travel by 10% in 5 years. The Travel Plan would also monitor the use of cycle parking annually which is welcomed. Officers consider that the Travel Plan would promote sustainable, healthy travel behaviour which would encourage walking, cycling and use of public transport. The Council’s Travel Plan Officer have reviewed the Travel Plan and welcome its monitoring and review processes; however, it is recommended that a finalised Travel Plan is secured by condition 9 this would include a baseline survey and an action plan detailing how the objectives would be achieved.

Page 58

Cycle parking

7.7.7 The proposed educational facility would operate as car-free in line with the existing situation and there is a TfL cycle docking station within Arch 58 located approx. 65m to the west. TfL have advised that a minimum of 27 long-stay and 43 short-stay cycle parking spaces are required to comply with LP policy T5 for this application.

7.7.8 A total of 40 cycle parking spaces are proposed to be provided within a secure cycle store of approx. 61sqm located at lower ground floor level, and a further 16 short stay cycle spaces are provided on an external terrace at ground floor to the rear of the building (shown in Figure 12 below).

7.7.9 With regard to the quantum of cycle parking the current plans show a shortfall of 13 short stay spaces which TfL have not objected to given the constraints of the site and Lambeth’s Transport Planner has not objected to recognising TfL’s comments, the site constraints and the local provision of public cycle parking. Additionally, a travel plan monitoring condition would be imposed to monitor the demand on the cycle storage provided within the site and secure an uplift to a policy compliant quantum when demand requires it. This approach has been agreed with the Council’s Transport team.

7.7.10 With regard to the location and accessibility of the cycle parking, it is noted that despite being located on the lower ground floor, the cycle store would be visible from the rear of the Auckland Street entrance (shown in Figure 12Figure 12 below) through clear signage allowing the store to be easily located by users.

7.7.11 The Council’s Transport Officer has raised concerns due to proposed long term cycle store being located at basement level due to its access using stairs. The short term cycle parking is stair free. It is noted that the cycle store was approved in the basement under application 19/01197/FUL where a cycle rail was installed to the side of the stairs. Showers and lockers are located within the basement which is accessible through lifts. It is considered that whilst the accessibility of the cycle parking is not ideal through the short stay and basement cycle store provision and considering the constraints of the site the cycle provision would not warrant the refusal of the application.

. Figure 12: Proposed short stay cycle parking located on the rear terrace.

Page 59

Figure 13: Rear gated access to 350 Kennington Lane.

Delivery & Servicing.

7.7.12 The applicant has submitted a delivery and servicing management plan that states no servicing will take place from Kennington Lane and that the building would continue to be serviced from the rear via Auckland Street in line with the existing arrangements. The Council’s Transport Officer has not raised an objection to the proposed Delivery and Servicing Plan, and as such it is recommended that compliance with the delivery and servicing management plan should be secured by condition 7.

Waste

7.7.13 The application is supported by a waste and recycling statement which provides details that the existing waste located to the rear of the plot in a secured ventilated sheltered space would be utilised for the new proposed use of the building. It states that separate bins would be provided for general waste, recycling and specialist waste and sharp object and specialist waste bins would be provided given the nature of the teaching facility. All servicing and deliveries would be from Auckland Street at the rear of the property the same as the existing arrangement.

7.7.14 The Council’s Environmental Waste consultant has reviewed the application and has raised no objection to the continued use of existing refuse store with collections via private contractor. Nevertheless, Officers recommend a condition (Condition 7 to ensure compliance with the submitted Waste and Recycling Strategy.

Construction:

7.7.15 The submission states that only minor external alterations are proposed. However, it is noted that the proposed change of use would require internal works, together with the fitting of the new internal plant and louvres. The Council’s Transport Officer has advised that a construction management plan (CMP) should be secured by condition. As the Applicant has now updated construction logistics plan to address TfL’s outstanding queries. The condition would require compliance with the updated CLP plan ref. 77447 Rev03 dated 29 April 2021.

7.7.16 Therefore compliance with the above CLP plan would be secured by condition 4 to ensure the development is acceptable in transport terms should this planning application be approved.

Page 60

7.8 Skills, Employment and Training

7.8.1 Policy ED14 of the LLP states that the Council will support employment and training schemes to maximise local employment opportunities and help address skills deficits in the local population. Part (c) of this policy states that the council, working with local training providers, will aim to ensure that residents are given access to the right skills training so that they can take advantage of opportunities created by new development. This includes jobs both during the construction phase and in the completed development.

7.8.2 An Employment Skills Plan (‘ESP’) has been submitted which demonstrates that local employment and educational opportunities would be maximised where possible to ensure that Lambeth benefits from the proposed development. Coventry University’s philosophy is based on local education, training and employment for local people and the University is committed to supporting LBL’s objective of providing employment and training opportunities as well as promoting social inclusion. It states that Coventry University is already delivering apprenticeships in health and social care for 15 employers in London and that some of these are within LB Lambeth or delivered through commissioned services for the people of Lambeth, including Kings College Foundation Trust, Guy’s and St Thomas’ NHS Foundation Trust, Great Ormond Street and Homerton University Hospital.

7.8.3 The ESP states that Coventry University was commissioned by the Pan London ADASS group, of which Lambeth is a key member, to deliver occupational therapy apprenticeships for London with the first group of London apprenticeships having started in January 2021. The recruitment for these apprenticeships is led by the employers and all are local people working in London. The University is already working within Lambeth on introducing physiotherapy, assistant practice and public health apprenticeships in the next wave of programmes from September 2021 onwards. Most students that would be trained within facility would be apprentices and they would be employed by local health and social care employers whilst undertaking their training. The University has expressed that it is keen to work with these employers and schools and colleges to understand what further education pathways need to be co-developed to ensure that local people can progress onto health and social care apprenticeships.

7.8.4 Furthermore, to address the shortage of health and social care workforce, it is critical that career pathways and locally delivered educational courses are in place to reduce inequalities and educational disadvantage. To address this, the University has already approached and made links with local colleges and plan to make contact and provide some bespoke health career insight sessions to local schools.

7.8.5 However it is noted that the use of planning obligations to formalise procedures to ensure small and medium sized local enterprises have access to tender opportunities for the procurement of goods and services generated by the development both during and after construction, and to ensure that job opportunities and apprenticeships are notified to the council or appropriate nominated agencies so that suitable local people can be given the opportunity is only for major developments; the subject application does not constitute a major development and as such no s106 heads of terms are recommended with this regard.

7.8.6 Overall, the proposed scheme would seek to maximise employment and training in the healthcare sector and would help to address skills deficits in the local population in accordance with Policy ED14 of the LLP.

7.9 Designing Out Crime

7.9.1 DLLP Policy Q3 states that in order to create a safe borough for all, the Council will expect a proposal to design out opportunistic crime, anti-social behaviour, violence and fear of crime in a site- specific manner, based on an understanding of the locality and likely crime and safety issues it presents; pay particular regard to shared public spaces and communal areas within developments (particularly cycle stores and refuse stores); and ensure that materials and construction details are robust, durable and resistant to malicious damage.

Page 61

7.9.2 The Council’s Designing Out Crime Officer has advised that the proposed change of use for educational use in this location would potentially mean additional pedestrian footfall in the area. The Designing Out Crime Officer noted that there may be issues with the students within the facility crossing Kennington Lane to reach the amenities of the Local Centre. However, it is considered that there are a number of crossing points within the vicinity of the subject site and recent highway works have rationalised the street furniture and clutter within the vicinity of the site. It is noted that TfL and the Council’s Transport Planner did not raise concerns about pedestrian safety.

7.9.3 Should Planning permission be granted for this development, the Council’s Designing Out Crime Officer requests that pre-commencement and pre-occupation conditions are imposed to ensure end- to-end compliance with the standards and objectives of the Secured by Design initiative.

7.10 Sustainable Design and Construction

7.10.1 Policy EN4 of the LLP states that all development, including construction of the public realm, highways and other physical infrastructure, will be required to meet high standards of sustainable design and construction feasible, relating to the scale, nature and form of the proposal.

7.10.2 Regarding the proposed development, it is noted that whilst the proposal constitutes a change of use of the building, the scale of refurbishment and interventions required to change the building are minimal, with changes requiring planning permission relating to the new external door and louvres. The building was refurbished in 2019 to “turn-key” standards and is ready for occupation by an office use. The internal subdivision of the floorplates as proposed, does not require planning permission and it is noted that these works could be undertaken by any incoming office user without making any planning application. The applicant has submitted a Sustainability Statement which demonstrates that sustainable values and standards are integral to the operation of the development and include heat recovery within the mechanical ventilation of the building and occupancy detection/automatic daylight dimming within the lighting system. It is considered that this is sufficient to meet the requirements of policy EN4 in this case.

7.10.3 As such the proposals would not be contrary to policy EN4 of the London Borough of Lambeth Local Plan (2015), and policy EN4 of the London Borough of Lambeth Draft Local Plan.

7.11 Flood Risk

7.11.1 LLP policy EN5 requires a Flood Risk Assessment (FRA) for all development within Flood Zones 2, 3a and 3b, or where the development may be subject to other sources of flooding. The FRA should be proportionate with the degree of food risk posed to and by the proposed development; consider the impact of climate change on food risk to and from the development using the latest government guidance; and take account of the advice and recommendations set out in the SFRA and Local Flood Risk Management Strategy (LFRMS). The Flood Risk Assessment must consider the risks of both on and off-site flooding to and from the development for all sources of flooding including fluvial, tidal, surface run-off, groundwater, ordinary watercourse, sewer and reservoir.

7.11.2 The applicant has submitted an FRA which concludes that, with consideration to the existing Thames flood defences, the risk of flooding on the site is low or negligible for all types of flooding. Officers note that the proposed works would not alter the physical impact of the building on flooding, nor does the proposed change of use result in more vulnerable development within the flood zone. As such Officers consider that the future occupants and users of the education facility would be exposed to only a low risk of flooding.

7.11.3 As such, it has been demonstrated by the submitted flood risk assessment that the proposals comply with LLP policy EN5, DLLP EN5 and LP policy SI 12.

Page 62

7.12 Fire Safety

7.12.1 LP policy D12 states that in the interests of fire safety and to ensure the safety of all building users, all development proposals must achieve the highest standards of fire safety. This includes providing a suitable and convenient means of escape, and associated evacuation strategy for all building users. evacuation strategy for all building users. Part 1 of policy D12 also requires the Applicant to identify suitably positioned unobstructed outside space a) for fire appliances to be positioned on b) appropriate for use as an evacuation assembly point.

7.12.2 The Applicant has provided a Fire Occupancy Study to accompany this application. The Fire Occupancy Study demonstrates that fire safety has been considered from the outset by the Applicant and ensures that the existing and proposed doors and fire exit doors are sufficient for the proposed total capacity of the building. The ground floor has an additional double door fire exit of 1365mm providing a capacity of 270 persons. The basement (studio) has its own means of escape and is therefore not dependant on the main circulation. Staircase A provides capacity for 340 persons and Staircase B provides a capacity of 380 persons.

7.12.3 As such Officers consider that the application complies with LP policy D12 in this respect.

7.13 Land Contamination

7.13.1 The Council’s Environmental Officer has stated that the building was on the site of a former printer works and although the risk is considered low has recommended that the Applicant should submit a phase 1 desk study secured by condition to demonstrate that they have considered the potential impacts of historical contamination. This study should show that all work has been carried out by a suitably qualified person and should include a site walkover in accordance with the UK contaminated land regime.

7.13.2 Officers consider that such a condition to be onerous in light of the proposal; the application seeks to change the use of the building for a temporary period from an office to a place of education. There would not be significant interventions into the ground and there would not be a significant change in the nature of the site with regard to the contamination risk. As such it is not recommended that such a condition is imposed should the application be found to be acceptable.

7.14 Planning Obligations and CIL

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

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

7.14.3 The proposed obligations to be secured through the S106 Agreement are as follows:

Item Details Transport (Business/educational facility) car parking permit free) Other Monitoring Travel Plan Monitoring fee (£5,300 + £500) = £5,800 s106 Monitoring fee – amount to be reported by addendum

Page 63

7.14.4 If the application is approved and the development is implemented, a liability to pay the Lambeth Community Infrastructure Levy (CIL) will arise.

7.14.5 Expenditure of the majority of a future CIL receipt will be applied towards Borough infrastructure needs in accordance with the applicable policies and procedures relating to expenditure decisions.

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

8 CONCLUSION

8.1.1 This application has been submitted by Coventry University which seeks temporary planning permission of 10-years for a change of use of the entire building from office use to operate as a London based ‘satellite’ educational facility of Coventry University (Class F1(a)) supported by Guys and St Thomas’s NHS Trust foundation. The building would facilitate teaching for up to 300 students at any given time; however, the number of student placements on the site would be higher. All students would be studying for professional registered health qualifications including occupational therapy, nursing and physiotherapy, social work, and public health. At the end of the 10-year period the building would revert to office use.

8.1.2 The proposed temporary loss of the office use is a departure from Policy ED3 of the Lambeth Local Plan 2015 (LLP) and Policy ED1 of the Lambeth Draft Revised Lambeth Local Plan 2020 (DRLLP) because insufficient marketing evidence to justify the loss of the office use has been provided. However, in this case, it has been demonstrated that material considerations are the benefits to Lambeth (and London wide) residents from having access to additional professional registered health courses in the borough, and the expansion of the healthcare workforce through courses taught at the site. It is also material that there are no vacant Class F1 facilities of sufficient size within Lambeth or surrounding boroughs to host the proposed educational facility.

8.1.3 Although officers recognise the importance of protecting and delivering office space in the borough, it is considered that these material considerations are sufficient, in this instance, to outweigh determination of the temporary change of use application in accordance with Policy ED3 of the LLP and ED1 of the DRLLP.

8.1.4 The proposal complies with LLP Policy S2 of the LLP, by supporting a key healthcare sector within the borough. Letters of support have been provided by Guy’s and St Thomas’, Health Education England and the Salisbury NHS Foundation Trust.

8.1.5 The proposed installation of 2 roof top condenser units and alterations to the rear elevation to replace a window and single door with double doors and installation of five louvred panels to serve mechanical heat recovery units are considered acceptable. With regard to sustainability the replacement of the existing rear windows with five louvred panels is a necessary technical requirement in facilitating the efficiently heating the building. In addition, given their detailed design, would not adversely impact on the visual amenity of the area. The application site is considered to be too distant from the nearby heritage assets and the external works would be sufficiently discrete and sympathetic as to not impact on the surrounding Vauxhall Conservation Area to result in harm to its setting.

8.1.6 The proposed development would not result in any other unacceptable amenity impacts including impact on visual amenity and noise impacts. Officers consider that noise arising from the use of the building and associated plant can be adequately controlled through condition.

Page 64

8.1.7 The development is considered to be acceptable in transport and highway terms with access to the building would be from existing entrances and conditions would ensure that there would be no unacceptable impact on the surrounding highway network. The site is located in an area with a high PTAL of 6(B) and a travel plan would be secured by condition to ensure sustainable healthy travel behaviour is promoted for users of the building.

8.1.8 Overall, officers consider that the change of use of 350 Kennington Lane would enable both strategic and local planning aspirations for the area to be achieved. The proposal has been assessed in accordance with Section 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, Section 70(2) of the Town and Country Planning Act 1990 and Section 38(6) of the Planning and Compulsory Purchase Act 2004, the NPPF and the development plan. In this instance, taking account of all the relevant material considerations, and notwithstanding the departure from the policies ED3 of the LLP and ED1 of the DLLP, the proposal is considered to be acceptable in all other respects. As such, the weight of the material considerations considered are sufficient to justify a departure from the development plan in this instance such that the Council is able to support the proposed development.

9 EQUALITY DUTY AND HUMAN RIGHTS

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

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

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

10 RECOMMENDATION

10.1.1 Resolve to grant conditional planning permission subject to the completion of an agreement under Section 106 of the Town and Country Planning Act 1990 (as amended) containing the planning obligations listed in this report.

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

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

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

Page 65

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

Page 66

APPENDICES

Appendix 1: Draft Decision Notice

Your Ref: Our Ref: 20/04147/FUL

Coventry University. c/o Miss Nuala Wheatley Nathaniel Lichfield & Partners Ltd The Minster Building 21 Mincing Lane LONDON EC3R 7AG United Kingdom

Date TBC

DRAFT DECISION NOTICE

Dear Coventry University.

TOWN AND COUNTRY PLANNING ACT 1990.

PERMISSION FOR DEVELOPMENT

The London Borough of Lambeth hereby permits under the above mentioned Acts and associated orders the development referred to in the schedule set out below subject to any conditions imposed therein and in accordance with the plans submitted, save in so far as may otherwise be required by the said conditions.

In accordance with the statutory provisions your attention is drawn to the statement of Applicant’s Rights and General Information attached.

Application Number: 20/04147/FUL Date of Application: 30.11.2020 Date of Decision:

Proposed Development At: 350 Kennington Lane London SE11 5HY

For: The temporary change of use for a 10-year period from Office (Class E(G)(i)) to Education (Class F1(a)) together with minor external elevational changes and other associated works.

[this application is a DEPARTURE APPLICATION: it is a departure from Policy ED3 of the Lambeth Local Plan (2015)]

Approved Plans Page 67

The Studio Existing GA 2134-IDL-NA-LG-DR-A-00011 P01, The Studio Proposed 2134-IDL-NA-LG-DR-A- 10011 P01, Ground Floor Existing GA 2134-IDL-NA-GF-DR-A-00012 P01, Ground Floor Proposed GA 2134- IDL-NA-GF-DR-A-10012 P01, First Floor Proposed GA 2134-IDL-NA-01-DR-A-10013 P01, Second Floor Existing GA 2134-IDL-NA-02-DR-A-00014 P00, Second Floor Proposed GA 2134-IDL-NA-02-DR-A-10014 P01, Third Floor Existing GA 2134-IDL-NA-03-DR-A-00015 P01, Third Floor Proposed GA 2134-IDL-NA-03- DR-A-10015 P01, Existing Cross Section 2134-IDL-NA-ZZ-DR-A-04001 P00, Proposed Cross Section 2134- IDL-NA-ZZ-DR-A-14001 P00, Roof Existing GA 2134-IDL-NA-RF-DR-A-00016 P01, Roof Proposed GA 2134-IDL-NA-RF-DR-A-10016 P01, External Elevations Existing 2134-IDL-NA-ZZ-DR-A-06003 P01, External Elevations Existing 2134-IDL-NA-ZZ-DR-A-06004 P01, External Elevations Proposed 2134-IDL-NA-ZZ-DR- A-16002 P01, External Elevations Proposed 2134-IDL-NA-ZZ-DR-A-16003 P01, Design and Access Statement 20-2134/Rev01, IDL Waste and Recycling Strategy dated 18th November 2020, Flood Risk Assessment ref. 77447-CUR-00-XX-RP-C-92001 Rev P02, Transport Statement ref: 77447 Rev04, Travel Plan ref: 77447 Rev03, Delivery and Servicing Management Plan ref: 77447 Rev03, Construction Logistics Plan 77447 Rev03, Planning Statement dated November 2020, Cover Letter ref: 62234/01/NG/NWh/19119256v1, Briefing note ref: 62234/01/NG/NWh dated March 2021, Copy of the Hudson Brochure, Copy of the Hudson advertisement poster, 1 x photograph of the Hudson advertisement poster displayed, Ground Floor Proposed New Cycle Stands 2134-IDL-NA-GR-DR-A-11001 P00, Roof Level Coordinated Services Layout SAP/11071/ME/305 RD, Roof Mechanical Layout 4790/M/505 RevT1, Mitsubishi Electric R2 Series Standard (22-45kW) Specification Brochure, Nuaire Air-Volve Specification Brochure, VES Technical Specification Sheet, Mitsubishi Electric PUZ-ZM50VKA Service Manual, Email from Agent dated 30/04/2021 clarifying delivery times/loading bay location and cycle facilities. Email from Agent dated 30/04/2021 agreeing to cycle monitoring surveys to be included in travel plan, Sustainability Statement.

Conditions:

1. This permission shall be for a limited period only, expiring 10 (ten) years from the date of this decision notice. On or before that date the use hereby permitted shall be discontinued and any buildings or works carried out under this permission shall be removed thereafter.

Reason: To enable the Local Planning Authority to review the suitability of the development in the light of circumstances prevailing at the end of the above period and to maintain a stock of sites in business use across the borough in accordance with Policies D1, D2, D5, ED2, ED3 and T6 of the Lambeth Local Plan (2015), Policies D1, D2, D5 and ED1 of the Lambeth Draft Local Plan and Policies SD5 and E1 of the London Plan (2021).

2. The development hereby permitted shall be carried out in accordance with the approved plans listed in this notice.

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

3. The use hereby permitted shall be restricted to F1(a) Provision of education - (not including residential use) use only.

To enable to local authority to fully assess the suitability and transport impact of any future change of use (Policies D2, T6 and T7 of the Lambeth Local Plan (2015), Policies D2 and T6 of the Lambeth Draft Local Plan (2015) and Policies SD1, T4 and T7 of the London Plan (2021).

4. The development hereby approved shall be carried out in accordance with the Construction Logistics Plan 77447 Rev03 dated 29 April 2021.

Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally, and to avoid unnecessary hazard and obstruction to the public highway (Policies Q2, T6, T7 and T8 of the Lambeth Local Plan (2015), Policies Q2, T7 and T8 of the Lambeth Draft Local Plan and Policies D14 and T7 of the London Plan (2021). Page 68

5. Prior to the commencement of the relevant works and notwithstanding the details shown on the drawings hereby approved, detailed construction drawings at a scale of 1:5 and 1:20 (including section plans) of all louvres to demonstrate an appropriate setback within their reveals shall be submitted to and approved in writing by the Local Planning Authority.

Reason: To ensure that the external appearance of the building is satisfactory and that it protects or enhances the character and appearance of the Vauxhall conservation area (Policies Q2, Q11 and Q22 of the Lambeth Local Plan (2015)), Policies Q2, Q11 and Q22 of the Lambeth Draft Local Plan (2015) and Policies D4 and HC1 of the London Plan (2021)).

6. Prior to occupation of the development hereby approved an assessment of the acoustic impact arising from the operation of all internally and externally located building services plant shall be submitted to and approved in writing by the local planning authority. The assessment of the acoustic impact shall be undertaken in accordance with BS 4142: 2014 (or subsequent superseding equivalent) and other relevant measures and shall include a scheme of attenuation measures to ensure the rating level of noise emitted from all building services plant associated with this use is 5 dbA less than background.

b) Within three months of occupation of the development hereby approved any necessary mitigation measures approved in a) above shall be implemented on the externally located building services plant associated with the approved use, and a post-installation noise assessment confirming compliance with the approved noise criteria shall be submitted to and approved by the Local Planning Authority. The scheme shall thereafter be permanently retained and maintained in working order for the duration of the use and their operation.

Reason: To protect the amenities of adjoining occupiers and the surrounding area (Policy Q2 of the Lambeth Local Plan (2015), Policy Q2 of the Lambeth Draft Local Plan and Policy D14 of the London Plan (2021).

7. The use hereby permitted shall be carried out in accordance with the Delivery & Servicing Management Plan 7747 Rev 03 dated 29 April 2021 and IDL Waste and Recycling Strategy dated 18th November 2020.

Reason: To protect the amenities of adjoining occupiers and the surrounding area and to limit the effects of the increase in travel movements (Policies Q2, T6, T7 and T8 of the Lambeth Local Plan (2015), Policies Q2, T7 and T8 of the Lambeth Draft Local Plan and Policies D14 and T7 of the London Plan (2021).

8. Prior to the occupation the cycle parking, showers and lockers shown on plans (The Studio Proposed 2134-IDL-NA-LG-DR-A-10011 P01 and Ground Floor Proposed GA 2134-IDL-NA-GF-DR-A-10012 P01) shall be implemented in full in accordance with the approved details before the use hereby permitted commences and shall thereafter be retained solely for its designated use.

Reason: To ensure adequate cycle parking is available on site and to promote sustainable modes of transport (policies T1, T3 and Q13 of the London Borough of Lambeth Local Plan (2015), policies T1, T3 and Q13 of the London Borough of Lambeth Draft Local Plan and policies T1 and T5 of the London Plan (2021)).

9. Prior to the occupation of the building, an updated Travel Plan shall be submitted to the Local Planning Authority. The Travel Plan shall be approved in writing within three months of first occupation of the Page 69

building and the development shall thereafter operate in full accordance with all measures identified within it.

Reason: To ensure that the travel arrangements to the site are appropriate and to limit the effects of the increase in travel movements (Policies T1 and T6 of the Lambeth Local Plan (2015), Policy T1 of the Lambeth Draft Local Plan (2015) and policy T1 and T4 of the London Plan (2021)).

10. The basement studio unit labelled apartment on plan 2134-IDL-NA-LG-DR-A-1011 rev P01 hereby approved shall not be occupied at any time other than for purposes ancillary to the main educational use of the building and shall not be used as an independent residential unit.

Reason: In the interest of sustainable planning and to prevent substandard residential accommodation (policies D2, Q2, H5 and EN5 of the London Borough of Lambeth Local Plan (2015), policies D2, Q2, H5 and EN5 of the London Borough of Lambeth Draft Local Plan and Policies D6, D14 and SI 12 of the London Plan (2021)).

11 The development shall be constructed and operated thereafter to ‘Secured by Design Standards’. A certificate of accreditation to Secured by Design Standards shall be submitted to the local planning authority for approval in writing within 3 months of occupation of the development.

Reason: To ensure that the development maintains and enhances community safety (policy Q3 of the London Borough of Lambeth Local Plan (2015), (policy Q3 of the London Borough of Lambeth Draft Local Plan) and policy D11 of the London Plan (2021).

Notes to Applicants:

In dealing with this application the Council has implemented the requirement in the National Planning Policy Framework (2019) to work with the applicant in a positive and proactive manner. The council has made available on its website the policies and guidance provided by Lambeth Local Plan (2015) and its supplementary planning documents. We also offer a full pre-application advice service in order to ensure that the applicant has every opportunity to submit an application that’s likely to be considered acceptable.

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

2. If, after the expiry of this consent, you wish to apply for a further temporary time period, you will need to submit a further planning application to the Local Planning Authority. The case will be assessed on the circumstances prevailing at the time of the application.

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

4. Your attention is drawn to the need to comply with the requirements of the Control of Pollution Act 1974 concerning construction site noise and in this respect you are advised to contact the Council's Environmental Health Division.

5. You are advised of the necessity to consult the Principal Highways Engineer of the Highways team on [email protected] in order to gain necessary prior approval for undertaking any works within the Public Highway including Scaffold, Temporary/Permanent Crossovers, Oversailing/Undersailing of the Highway, Drainage/Sewer Connections and Repairs on the Highways, Hoarding, Excavations, Temporary Full/Part Road Closures, Craneage Licences etc. You are advised to contact the Highways team at the earliest possible opportunity.

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

Page 70

7. You are advised that in order to discharge the travel plan condition above, an annual cycle monitoring report must be submitted starting from 12 months of occupation. If the cycle monitoring survey identifies additional cycle parking is required, then the additional 13 short stay spaces required in line with London Plan standards shall be provided within the rear courtyard of the site within 3 months of this identified need.

Yours sincerely

DRAFT DECISION

Rob Bristow Assistant Director Planning, Transport & Development Growth, Planning and Employment Directorate

Date printed: TBC

Page 71

INFORMATION FOR APPLICANTS GRANTED PLANNING PERMISSION SUBJECT TO CONDITIONS, OR WHERE PERMISSION HAS BEEN REFUSED.

General Information

This permission is subject to due compliance with any local Acts, regulations, building by-laws and general statutory provisions in force in the area and nothing herein shall be regarded as dispensing with such compliance or be deemed to be a consent by the Council thereunder.

Your attention is drawn to the provisions of the Building Regulations 1985 and related legislation which must be complied with to the satisfaction of the Council’s Building Control Officer, PO Box 734, Winchester SO23 5DG.

The Council’s permission does not modify or affect any personal or restrictive covenants, easements, etc., applying to or affecting the land or the rights of any person entitled to the benefits thereof.

STATEMENT OF APPLICANT’S RIGHTS ARISING FROM THE REFUSAL OF PLANNING PERMISSION OR FROM THE GRANT OF PERMISSION SUBJECT TO CONDITIONS.

Appeals to the Secretary of State

If the applicant is aggrieved by the decision of the local planning authority to refuse permission or approval for the proposed development or to grant permission or approval subject to conditions, he may appeal to the Secretary of State in accordance with Section 78 of the Town and Country Planning Act 1990 within six months from the date of this notice. Appeals must be made on a form which is obtainable from The Planning Inspectorate, Room 3/13 Temple Quay House, 2 The Square, Temple Quay, Bristol BS1 6PN. Alternatively an Appeal form can be downloaded from their website at www.gov.uk/government/organisations/planning- inspectorate. The Secretary of State has power to allow longer period for the giving of a notice of appeal but he will not normally be prepared to exercise this power unless there are special circumstances which excuse the delay in giving notice of appeal. The Secretary of State is not required to entertain an appeal if it appears to him that permission for the proposed development could not have been granted by the local planning authority, or could not have been so granted otherwise than subject to the conditions imposed by them, having regard to the statutory requirements, to the provisions of the development order, and to any directions given under the order.

Purchase Notice

If permission to develop land is refused or granted subject to conditions, whether by the local planning authority or by the Secretary of State for the Environment, and the owner of the land claims that the land has become incapable of reasonably beneficial use in its existing state and cannot be rendered capable of reasonable beneficial use by the carrying out of any development which has been or would be permitted, he may serve on the London Borough of Lambeth a purchase notice requiring that Council to purchase his interest in the land in accordance with the provisions of Section 137 of the Town and Country Planning Act 1990.

Compensation

In certain circumstances, a claim may be made against the local planning authority for compensation, where permission is refused or granted subject to conditions by the Secretary of State for the Environment on appeal or on a reference of the application to him. The circumstances in which such compensation is payable are set out in Section 120 and related provision of the Town and Country Planning Act 1990. Page 72

Appendix 2: List of Neighbours Consulted

Residential Accommodation The Royal Vauxhall Tavern 372 Kennington Lane London SE11 5HY

10 Auckland Street London SE11 5AD

Flat 30 Muscovy House 8 Auckland Street London SE11 5AB

Flat 29 Muscovy House 8 Auckland Street London SE11 5AB

Flat 28 Muscovy House 8 Auckland Street London SE11 5AB

Flat 27 Muscovy House 8 Auckland Street London SE11 5AB

Flat 26 Muscovy House 8 Auckland Street London SE11 5AB

Flat 25 Muscovy House 8 Auckland Street London SE11 5AB

Flat 24 Muscovy House 8 Auckland Street London SE11 5AB

Flat 23 Muscovy House 8 Auckland Street London SE11 5AB

Flat 22 Muscovy House 8 Auckland Street London SE11 5AB

Flat 21 Muscovy House 8 Auckland Street London SE11 5AB

Flat 20 Muscovy House 8 Auckland Street London SE11 5AB

Flat 19 Muscovy House 8 Auckland Street London SE11 5AB

Flat 47 Muscovy House 8 Auckland Street London SE11 5AB

The Royal Vauxhall Tavern 372 Kennington Lane London SE11 5HY

Flat 6 Muscovy House 8 Auckland Street London SE11 5AB

Flat 5 Muscovy House 8 Auckland Street London SE11 5AB

Flat 4 Muscovy House 8 Auckland Street London SE11 5AB

Flat 3 Muscovy House 8 Auckland Street London SE11 5AB

Flat 2 Muscovy House 8 Auckland Street London SE11 5AB

Flat 1 Muscovy House 8 Auckland Street London SE11 5AB

Flat 18 Muscovy House 8 Auckland Street London SE11 5AB

Flat 17 Muscovy House 8 Auckland Street London SE11 5AB

Flat 16 Muscovy House 8 Auckland Street London SE11 5AB

Flat 15 Muscovy House 8 Auckland Street London SE11 5AB

Page 73

Flat 14 Muscovy House 8 Auckland Street London SE11 5AB

Flat 13 Muscovy House 8 Auckland Street London SE11 5AB

Flat 12 Muscovy House 8 Auckland Street London SE11 5AB

Flat 11 Muscovy House 8 Auckland Street London SE11 5AB

Flat 10 Muscovy House 8 Auckland Street London SE11 5AB

Flat 9 Muscovy House 8 Auckland Street London SE11 5AB

Flat 8 Muscovy House 8 Auckland Street London SE11 5AB

Flat 7 Muscovy House 8 Auckland Street London SE11 5AB

Flat 46 Muscovy House 8 Auckland Street London SE11 5AB

Flat 45 Muscovy House 8 Auckland Street London SE11 5AB

Flat 44 Muscovy House 8 Auckland Street London SE11 5AB

Flat 43 Muscovy House 8 Auckland Street London SE11 5AB

Flat 42 Muscovy House 8 Auckland Street London SE11 5AB

Flat 41 Muscovy House 8 Auckland Street London SE11 5AB

Flat 40 Muscovy House 8 Auckland Street London SE11 5AB

Flat 39 Muscovy House 8 Auckland Street London SE11 5AB

Flat 38 Muscovy House 8 Auckland Street London SE11 5AB

Flat 37 Muscovy House 8 Auckland Street London SE11 5AB

Flat 36 Muscovy House 8 Auckland Street London SE11 5AB

Flat 35 Muscovy House 8 Auckland Street London SE11 5AB

Flat 34 Muscovy House 8 Auckland Street London SE11 5AB

Flat 33 Muscovy House 8 Auckland Street London SE11 5AB

Flat 32 Muscovy House 8 Auckland Street London SE11 5AB

Flat 31 Muscovy House 8 Auckland Street London SE11 5AB

Page 74

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

London Plan (2021) policies Policy SD1 Opportunity Areas Policy SD4 The Central Activities Zone (CAZ) Policy SD5 Offices, other strategic functions and residential development in the CAZ Policy D4 Delivering good design Policy D5 Inclusive design Policy D8 Public realm Policy D11 Safety, security and resilience to emergency Policy D12 Fire safety Policy D13 Agent of Change Policy D14 Noise Policy S1 Developing London’s social infrastructure Policy S2 Health and social care facilities Policy S3 Education and childcare facilities Policy E1 Offices Policy E2 Providing suitable business space Policy E3 Affordable workspace Policy HC1 Heritage conservation and growth Policy SI 1 Improving air quality Policy SI 2 Minimising greenhouse gas emissions Policy SI 12 Flood risk management Policy T4 Assessing and mitigating transport impacts Policy T5 Cycling Policy T6 Car parking Policy T7 Deliveries, servicing and construction Policy T9 Funding transport infrastructure through planning Policy DF1 Delivery of the Plan and Planning Obligations

London Plan Supplementary Planning Guidance (SPG) Central Activities Zone (March 2016) Social Infrastructure (May 2015) Accessible London: Achieving an Inclusive Environment (October 2014) Town Centres (July 2014) Character and Context (June 2014)

Lambeth Local Plan (2015) policies Policy D1 Delivery and monitoring Policy D2 Presumption in favour of sustainable development Policy D4 Planning obligations Policy ED2 Business, industrial and storage uses outside KIBAs Policy ED3 Large offices (greater than 1,000 m2) Policy ED6 Town centres Policy S2 New or improved community premises Policy T1 Sustainable travel Policy T2 Walking Page 75

Policy T3 Cycling Policy T4 Public transport infrastructure Policy T5 River transport Policy T6 Assessing impacts of development on transport capacity Policy T7 Parking Policy T8 Servicing Policy EN5 Flood risk Policy Q1 Inclusive environments Policy Q2 Amenity Policy Q3 Community safety Policy Q5 Local distinctiveness Policy Q6 Urban design: public realm Policy Q7 Urban design: new development Policy Q8 Design quality: construction detailing Policy Q11 Building alterations and extensions Policy Q12 Refuse/recycling storage Policy Q13 Cycle storage Policy Q15 Boundary treatments Policy Q20 Statutory listed buildings Policy Q21 Registered parks and gardens Policy Q22 Conservation areas Policy Q23 Undesignated heritage assets: local heritage list Policy Q24 River Thames Policy PN2 Vauxhall

Lambeth Supplementary Planning Documents (SPDs) and guidance Building Alterations and Extensions SPD (2015) Advertising & Signage Guidance (2016) Marketing of Employment Premises and Sites Guidance Refuse & Recycling Storage Design Guide Waste Storage and Collection Requirements - Technical Specification

Draft Lambeth Local Plan policies

Policy D1 Delivery and monitoring Policy D2 Presumption in favour of sustainable development Policy D4 Planning obligations Policy ED1 Offices (B1a) Policy ED5 Work-live development Policy ED11 Local centres and dispersed local shops Policy ED15 Employment and training Policy S2 New or improved social infrastructure Policy T1 Sustainable travel Policy T2 Walking Policy T3 Cycling Policy T4 Public transport infrastructure Policy T7 Parking Policy T8 Servicing Policy T10 Digital connectivity infrastructure Page 76

Policy EN3 Decentralised energy Policy EN4 Sustainable design and construction Policy EN5 Flood risk Policy Q1 Inclusive environment Policy Q2 Amenity Policy Q3 Safety, crime prevention and counter terrorism Policy Q5 Local distinctiveness Policy Q8 Design quality: construction detailing Policy Q11 Building alterations and extensions Policy Q12 Refuse/recycling storage Policy Q13 Cycle storage Policy Q15 Boundary treatments Policy Q20 Statutory listed buildings Policy Q21 Registered parks and gardens Policy Q22 Conservation areas Policy Q23 Undesignated heritage assets: local heritage list Policy Q24 River Thames Policy PN2 Vauxhall Page 77

Appendix 4: Other relevant Plans and Photos

Figure A: The Studio Proposed 2134-IDL-NA-LG-DR-A-10011 P01

Figure B: Ground Floor Proposed GA 2134-IDL-NA-GF-DR-A-10012 P01

Page 78

Figure C: Ground Floor Proposed New Cycle Stands 2134-IDL-NA-GR-DR-A-11001 P00.

Figure D: First Floor Proposed GA 2134-IDL-NA-01-DR-A-10013 P01

Page 79

Figure E: Second Floor Proposed GA 2134-IDL-NA-02-DR-A-10014 P01

Figure F: Third Floor Proposed GA 2134-IDL-NA-03-DR-A-10015 P01

Page 80

Figure G: Roof Proposed GA 2134-IDL-NA-RF-DR-A-10016 P01

Figure H: Proposed Cross Section 2134-IDL-NA-ZZ-DR-A-14001 P00

Page 81

Figure I: External Elevations Proposed 2134-IDL-NA-ZZ-DR-A-16003 P01

Page 82

Figure J: Extract from the Hudson Brochure

Figure K: Screenshot of the Hudson advertisement website

Page 83

Figure L: 1 x photograph of the Hudson advertisement poster displayed

Page 84

Appendix 5: Coventry University Site Search

Table 1: Coventry University Site Search Page 85 Agenda Item 5

Page 86

Chester, Salisbury, Norfolk, Worcester, Winchester, Hereford, And Gloucester House ADDRESS: London, SW9 6EJ Application Number: 19/04478/FUL Case Officer: Michael Cassidy

Ward: Vassall Date Received: 02/12/2019

Proposal: Demolition of Salisbury House, Norfolk House, Worcester House, Winchester House, Hereford House and Gloucester House within Kennington Park Business Centre and the erection of three buildings, ranging from three to five storeys with part basement, to provide flexible business floorspace comprising light industrial and office floorspace (Class B1 a-c), light industrial floorspace (Class B1c and B8), a flexible commercial unit (Class A1/A2/A3/A4/B1), wheelchair accessible car parking, cycle parking and associated public realm and detailed landscape enhancements and the removal of two storey addition on the north facade of Chester House. Applicant: Workspace Management Limited Agent: Rolfe Judd

Drawing Numbers and Supporting Documents: Refer to Appendix 4

Supporting Documents: Appendix 1 – List of conditions and informatives Appendix 2 - List of Consultees (Statutory and Other Consultees) Appendix 3 - List of relevant policies in London Plan, Lambeth Local Plan. Reference to SPGs, SPD and other relevant guidance Appendix 4 – List of drawing numbers and supporting documents

RECOMMENDATION:

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

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

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

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

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

Page 87

SITE DESIGNATIONS

Designation: Description: Policy Kennington Business Park Key Industrial Business Area (KIBA) Listed Building No (the site is locally listed) Conservation Area (CA) No (the site adjoins St Marks Conservation Area to the north west and Vassal Road to the east) Protected views/vistas Yes - Primrose Hill to the Palace of Westminster (View 4A.2) Local Views Yes – Local Views 19 Brixton Panoramic and 22 Norwood Park and Millbank to Vauxhall Bridge Archaeological Priority Area Yes - part of the site, the frontage to Brixton Road, is within an archaeological priority area. Flood Risk Area Yes - The north-east of the site is in tidal Flood Zone 3 Creative Enterprise Zone No Air Quality Management Area Yes

LAND USE DETAILS

Site area (ha): 1.58 Hectares

NON-RESIDENTIAL DETAILS

Use Class Use Description Floorspace (m2) (Gross Internal Area) Existing Flexible B1 (a-c) Business 1,596sqm B1 c Light Industrial / Workspace 3,042sqm B8 Storage & Distribution 2,366sqm Flexible B1/D1 Offices / Education & Training 1,455sqm Total 8,459sqm

Proposed Flexible B1 (a-c) Business 17,479sqm B1 c Light Industrial / Workspace 5,408sqm Flexible B1/D1 Offices / Education & Training 1,455sqm A1/A2/A3/A4/B1 Flexible Commercial Unit 330sqm Total 24,672sqm

PARKING DETAILS

Car Parking Spaces Car Parking Spaces % of Bike Motor- (General) (Disabled) EVCP Spaces cycle Spaces Commercial Visitor Commercial Visitor Existing 189 0 7 0 0 119 0 Proposed 0 0 6 0 0 414 0

LEGAL SERVICES CLEARANCE

AUDIT TRAIL Consultation Name/Position Lambeth Date Sent Date Report Comments in department Received Cleared para: Peter Flockhart On behalf of Legal 08/05/21 08/05/21 10/05/21 Various Services

Page 88

EXECUTIVE SUMMARY

The proposed development would provide new high-quality business/workspace buildings, providing a significant uplift and enhancement in employment floorspace (an increase of 16,213sqm in floorspace and an uplift of 192% on the existing) on the site. The uplift is anticipated to provide an additional 344-1351 new jobs for the borough (calculated using the HCA Employment Density Guide).

The proposal would provide up to 219 flexible business units (former Use Class B1a-c), complementing the existing flexible business use of the Kennington Park Business Centre, and would fully reprovide the existing industrial floorspace (former Use Class B1c and B8), to be located within Block C, which has been specifically designed to be used for a range of industrial uses, in accordance with the New London Plan.

The employment use proposed would permit a range of office, research and development and light industrial uses falling under former Use Class B1a, B1b and B1c and provides flexible workspace suitable for occupation by a range of business sizes, which is welcomed. The design and layout of the proposal has been specifically tailored to be suitable for micro, small and medium sized creative enterprises engaged in light industrial manufacturing and design activities.

The group of buildings proposed are of an appropriate scale and height and have been carefully considered in terms of their architectural language. Overall, the design and appearance of proposed blocks are considered to be acceptable and will contribute positively to the streetscene and local context. The proposal would cause no harm to strategic, local views or heritage assets and would preserve and enhance the appearance of the character of the St Marks and Vassall Conservation Areas.

Given the distance and orientation to the nearest residential properties, and the inclusion of appropriate mitigation measures, the proposal would not result in any significant material impact in terms of overlooking, loss of privacy or sunlight/daylight or undue noise and disturbance to neighbouring residential properties.

The development would have a sustainable construction, meeting all of the relevant sustainability standards. The scheme has been designed to significantly improve the environment and amenity across the site, in order to create a more welcoming, usable and biodiverse place of work. scheme provides significant landscaping and ecological enhancement is to improve the legibility, permeability and external amenity space across the site for the enjoyment of existing future employees of the KIBA.

As such, the proposal is considered to be acceptable when judged against national, London wide and local plan policy and guidance and all relevant material considerations and is recommended for approval.

OFFICER REPORT

Reason for referral to PAC: The application is reported to the Planning Applications Committee in accordance with (1A) (a) (ii) of the Committee’s terms of reference as it relates to a major application for the provision of a building of more than 3,500 square metres.

1. THE APPLICATION SITE AND SURROUNDING AREA

1.1 Kennington Park Business Centre is 2.5 hectares in size and bounded by New Road to the north, Brixton Road to the east, Cranmer Road to the south and Foxley Road to the east. It comprises 11 buildings, between two and four commercial storeys in height, with the tallest being Cranmer House, located on the corner of Brixton Road and Cranmer Road and Lincoln House, located towards to the north of the Business Park fronting Camberwell New Road. Canterbury Court, in the centre of the site, is three storeys in height. The building towards the east of the site, Gloucester House, is a single storey 1950’s warehouse style brick building with pitched roof. The buildings on the southern part of the site are two storeys in height.

1.2 The application site itself is 1.58 hectares and comprises 6 of the 11 buildings within the business centre: Worcester House, Norfolk House, Salisbury House, Winchester House, Hereford House, and

Page 89

Gloucester House. Also within the site is the northern façade of Chest House, the central courtyard, the external area to the front of Canterbury Court and the section of car parking between Canterbury Court and Camberwell New Road as shown in Figure 1 below.

Figure 1 – Site and Surroundings

1.3 The business centre is an Edwardian commercial development in Queen Anne style comprising several attractive stock brick buildings with red brick and stone dressings. The complex also includes a 1950’s single storey brick building (Gloucester House) along Camberwell New Road and Foxley Road. The site was originally used for residential purposes but the buildings, which were constructed in 1905, were built by the General Motor Cab Company to provide garaging, servicing and administrative back-up for motor taxis serving London. There have been several additions and changes to the estate over the years; however, the main form of the 3 key redbrick buildings of Canterbury Court, Lincoln House and Chester House/Chichester House/Cranmer House remaining the same. An aerial view of the site is shown in Figure 2 below.

1.4 There are no statutory listed buildings on the site. The existing buildings are, however, locally listed and therefore considered a non-designated heritage asset. The site is also sandwiched between two conservation areas; St Marks (CA11) that lies north of the site and Vassal Road (CA7) directly east of the site along Foxley Road. Kennington Park, a Grade II Registered Park is north of the site. There are also several statutory and locally listed buildings in the vicinity of the site.

1.5 The site is a designated Key Industrial and Business Area (KIBA) and part of it, the frontage to Brixton Road, is within an archaeological priority area. It is located within a mixed-use area, comprising retail, residential, leisure and sports uses and open space. The surrounding context is varied with a Victorian shopping parade along the western stretch of Brixton Road, the low-rise Holland Town Estate to the south and the 19th century terraces of the Vassall Road Conservation Area to the south east of the site. To the north are the landscaped gardens and sports facilities of Kennington Park, whilst the Grade II* listed St Mark’s Church and its grounds are situated just north west of the site.

1.6 Both Brixton Road and Camberwell New Road form part of the Transport for London Road Network (TLRN). The nearest London Underground Station is Oval, situated 200m to the north east of the site and served by the Northern Line. There are a number of bus stops in close proximity of the site

Page 90

serving several routes. Based on these public transport connections, the site achieves a Public Transport Accessibility Level (PTAL) of 6a, where 0 represents the lowest accessibility level and 6b the highest.

Figure 2 – Aerial View of Site

2 PROPOSAL

2.1 The application proposes the demolition of 6 existing buildings on-site (Salisbury House, Norfolk House, Worchester House, Winchester House, Hereford House and Gloucester House) and the erection of 3 replacement buildings (Buildings A, B and C as shown in Figure 3 below), ranging from 3 to 5 storeys with part basement, to provide flexible business floorspace comprising light industrial and office floorspace (Class B1 a-c), light industrial floorspace (Class B1c) and a flexible commercial unit (Class A1/A2/A3/A4/B1). The remaining 5 buildings on the site (known as Canterbury Court, Lincoln House and Chester House) would remain unchanged.

Figure 3 – Proposed Site Plan

2.2 The breakdown of floorspace proposed, as shown in Table 1 below, is as follows:

Page 91

Uses Existing Proposed Uplift (reference is to former Use Classes) Floorspa Floorspace ce (sqm) (sqm) GIA GIA Flexible Business (Class B1 (a-c) 1,596sqm 19,146sqm 15,883sqm

Light Industrial / Workspace (Class B1 3,042sqm 5,408sqm Full re-provision of c) existing Storage & Distribution (Class B8) 2,366sqm

Offices / Education & Training (Flexible 1,455sqm 1,455sqm Full re-provision of B1/D1) existing, proposed as flexible B1/D1 Flexible commercial unit (Class A1/A2/ 0sqm 330sqm 330sqm A3/A4/B1) Total 8,459sqm 24,955sqm 16,213sqm Table 1 – Existing & Proposed Floorspace

Figure 4 – Proposed Aerial View of Site

2.3 The proposed buildings, as shown in Figure 4 above, will comprise the following:

• Building A comprises a range of business units with a total GIA of 9,899sqm of business floorspace. Building A has a height of five storeys and has a central courtyard to provide light and ventilation to all units. A lobby area within the courtyard identifies the entrance to the building, where there are informal ‘break out’ areas for tenants and visitors to utilise. Formal meeting rooms are located at ground floor level and can be booked for use.

• Building B comprises a range of business units with total GIA of 8,494sqm of business floorspace. Building B is part three, part four, and part five storey building and comprises a longer façade which is architecturally articulated, giving the appearance of three differing buildings.

• Building C comprises a range of business units with a total GIA of 6,562sqm of business floorspace. Building C has a height of four storeys with the fourth storey set back on the corner of Camberwell New Road. Building C has been designed to be specially occupied by light industrial uses (former Use Class B1c). The ground floor can be adapted to provide double height units and all units are provided with a dedicated riser and the ability to install extraction

Page 92

facilities. A dedicated loading bay and goods lift has been allocated for the building, so all servicing can be undertaken on site. The ground floor units can be altered to provide either a glaze shopfront or a roller shutter, dependent on the tenants needs.

2.4 Each building has bookable meeting rooms for more formal meetings, there are also break out areas internally and external seating areas for more informal meetings, networking opportunities and event spaces. A flexible/alternative commercial unit (former Use Class A1/A2/A3/A4/B1) is proposed within Building C, primarily to be used by tenants and visitors of the KIBA, to provide for the estimated uplift of between 351-1370 employees on site over the existing situation.

2.5 The application also proposes the removal of 2 storey addition on north facade of Chester House; the provision of 414 cycle parking spaces; 6 disabled car parking spaces (an increase of 5 spaces on the 7 existing) and the removal of all of the 189 general car parking spaces to help facilitate the following enhancements to pedestrian access and landscaping on the site:

• ‘Canterbury Yard’- primarily a pedestrian access point to Kennington Park, proposing a flexible yard space with a planted ramp terrace, titled lawns and tree planting. Improving the accessible step free route from the main pedestrian access down to the rest of the courtyard and site and providing additional green amenity space;

• ‘Walled Garden’- replacing the car parking spaces between Canterbury Court and Camberwell New Road with a woodland inspired rain garden. Glass pod meeting rooms are situated within the woodland area and movable external furniture is provided for amenity;

• ‘Central Yard’ – located between Block A and B comprises a series of terraces incorporating play/game elements, seating and lawns with cycle parking amongst the spaces;

• ‘Games Yard & Rubble Garden’- located to the east of the site, adjacent to Building C is a flexible space which is designed to host events and outdoor games such as boules and table tennis; and

• 1,457sqm of green space and the planting of 116 trees, providing a net gain of 84 trees across Kennington Park.

3 PLANNING PERFORMANCE AGREEMENT

3.1 The applications are subject to a Planning Performance Agreement agreed on the 18 April 2019 and remaining in force until the determination of the planning application.

3.2 During the pre-application stage the proposal was presented to the Council’s Strategic Panel on 22nd May 2019.

4 AMENDMENTS

4.1 During the course of the application, the following amendments were made:

Transport amendments • Reduction in disabled car parking from 12 spaces to 6, at the request of TfL and to be in line with the New London Plan (draft at the time). This also allows for a better-quality layout and public realm within the scheme; • Slight change to the cycle parking figures to 363 long-stay and 38 short-stay cycle parking spaces, to reflect slight changes to floorspace figures; • Confirmation of the proposed works to the highway (S278);

Page 93

Changes to Block C (29th May 2020) • A Mezzanine floor across first floor level, which will allow the units at ground floor to be double storey if required and can accommodate tenants with larger machinery; • Refined layout to incorporate more Class B1c units within Block C; • A large goods lift proposed at ground floor immediately adjacent to one of the loading bays, all corridors are wide enough to transport goods around the building; • Each unit is flexible and capable of being amalgamated to create bigger units or sub divided to allow for a range of business sizes and types; • Each unit is fitted with risers/ducts which can be connected into and will discharge at roof level; • The frontage of the ground floor units can be altered to a roller shutter style door or can remain as glazing; • Minor change to the basement layout, pulling this back from the site boundary;

Changes to Block A and Cranmer Road entrance (12th (August 2020) • New ramp layout simplified and shortened at entrance- entrance is exclusively for service, maintenance, and cycles; • Changes to the material of the yard to clearly separate the pedestrian path from the vehicle route; • Disabled parking bays rotated for better access; • Green buffer introduced to soften the transition between the ramp and Block A;

Further changes to Block C (December 2020) • Change to brick colour of Block C to show a browner tone; • Change to boundary fence to show a more detailed corrugated fence with the potential for landscaping against this, boundary details to be conditioned; • Fritted glazing incorporated into the lower part of the windows of Block C above ground floor, to be conditioned;

Energy Strategy • A number of revisions to the GLA spreadsheet were made confirming the agreed strategy with the GLA; and • Clarification provided to sustainability questions raised by Blew Burton.

4.2 Given the relatively minor nature of the above amendments, with no changes made to the height, scale, massing and general design of the proposal, it was not considered necessary to formally re- consult on these changes.

5 RELEVANT PLANNING HISTORY

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

• 15/06124/FUL - Removal of existing garage door, roller shutter, timber shutter and external lighting and installation of a new entrance door, glazed panel and sliding security door. Bricking up the pedestrian door opening – Refused on 12th February 2016.

• 10/04188/FUL - Redevelopment works to Kennington Park Business Centre comprising of the following: Change of use to the ground floor of Canterbury Court to provide 2,085sqm (GIA) either Retail, Financial Services and Restaurant floorspace (either use classes A1/A2/A3,), 2,015 sqm (GIA) leisure floorspace (use class D2) and 365sqm (GIA) commercial (use class B1) floorspace with associated external alterations to include the installation of shop fronts to the Camberwell New Road frontage and associated elevational changes, change of use to the first floor of Canterbury Court to provide 2,382sqm (GIA) commercial (use class B1) floorspace and alterations to the main entrance to Canterbury Court from the existing courtyard. Change of use to the ground floor of Chester House to provide 115sqm (GIA) of either Retail, Financial Services and Restaurant floorspace (either use classes A1/A2/A3) and the erection of a new

Page 94

single storey extension to Chester House to provide 47sqm (GIA) Retail, Financial Services and Restaurant floorspace (either use classes A1/A2/A3) and third floor roof extension to Chichester House to provide 866sqm (GIA) commercial (use class B1) floorspace and associated alterations. Demolition of existing entrance block to Chichester House and Chester House and the erection of a new 4 storey entrance extension, provision of an external metal staircase, alterations and enlargement of existing fenestration. Provision of a new landscaped public realm accessed from Brixton Road, new boundary treatment and reduction of 56 car parking spaces and provision of cycle parking – Granted on 21st April 2011.

• 10/02689/FUL - Demolition of existing entrance block and the erection of a new 4 storey entrance extension, provision of an external metal staircase, alterations and enlargement of existing fenestration along with alterations to existing car parking spaces involving the loss of 13 spaces, provision of hard landscaping and associated alterations – Granted 29th October 2010.

• 10/00381/FUL - Change of use of the ground floor to Vocational training centre (Use Class D1) or Business/General Industrial/Storage & Distribution (Use Classes B1/B2/B8) – Granted 8th April 2010.

• 10/02283/FUL - Application for variation of a condition 4 (The proposed new use hereby permitted shall only be open to students between the hours of 0830-2000 Monday-Friday) of planning permission ref:10/00381/FUL (Change of use of the ground floor to Vocational training centre (Use Class D1) or Business/General Industrial/Storage & Distribution (Use Classes B1/B2/B8) granted 08/04/2010. The variation is to allow the training centre to be open on Saturdays between the hours of 0830 and 1600 – Granted 27th August 2010.

• 09/03485/FUL - Change of use of first floor to an employment training centre (Use Class D1) – Granted 15th February 2010.

6 CONSULTATIONS

6.1 A list of all those consulted is provided in Appendix 2. The following were consulted on the application and the responses received are summarised below:

6.2 Statutory and External Consultees

5.2.1 The Greater London Authority (GLA) (Stage 1 received 15 June 2020) The GLA have made the following comments on the application:

• Principle of development: For the principle of development to be acceptable in land use terms, the existing quantum of industrial floorspace should be re-provided in full and should be fully fit for purpose. The existing quantum of D1 floorspace should also be confirmed and fully replaced within the scheme. The provision of affordable workspace offer should be confirmed and secured within the s106 agreement. The provision of offices and a flexible commercial unit is acceptable.

• Urban design: Overall the scheme is of good quality. However, the design of the courtyard is cluttered and would benefit from rationalisation. It also appears that there is increased opportunity for pedestrian and vehicular conflict as a result of the intensification of the site, this should also be addressed fully. The impact of the development on the LVMF view from Primrose Hill to the Palace of Westminster background assessment area should be assessed.

• Heritage: It is not possible to undertake a full assessment of impact until the verified views are updated. However, it is likely that the demolition of the locally listed buildings on Cranmer Street would give rise to some harm albeit to the lower end of the scale which would need to be weighed against the public benefits of the scheme.

Page 95

• Inclusive access: The Design and Access Statement does not currently set out how the development would promote accessibility for disabled people and should be updated to provide this detail. The Fire Strategy should be revised to meet the necessary information requirements of Policy D12 of the London Plan. Confirmation is required that fire evacuation lifts would be provided throughout the scheme as necessary.

• Energy: The energy strategy for the scheme is broadly acceptable however, the applicant must provide the following additional information and revisions in order to confirm compliance with relevant London Plan, ItP London Plan policies and current GLA Energy Assessment Guidance including: submitting the GLA’s carbon emissions excel spreadsheet; providing further information on the site’s connection to a district heating network; details of the route network and location of the energy centre; further information required on PV potential; and further information is required regarding the proposed heat pumps and how the energy generation has been maximised from this source.

• Air quality: The applicant should demonstrate that building emissions would be air quality neutral and an assessment of the gas boilers should be required prior to occupation to ensure no adverse impacts on existing air quality. Both should be secured by condition.

• Flood risk and drainage: The Flood Risk Assessment provided complies with London Plan Policy. However, the surface water drainage strategy would need to be revised. The applicant should also consider water harvesting and reuse to reduce consumption of wholesome water across the entire development site. This can be integrated with the surface water drainage system to provide a dual benefit.

• Urban greening: The scheme should aim to achieve a UGF of 0.3.

• Transport: Contributions will be sought towards Road Safety schemes, bus capacity enhancements and cycle hire. Further detail is required to ensure that the cycle parking is designed and laid out in accordance the London Cycling Design Standards (LCDS).

Officer comment: the application has been amended to re-provide the existing quantum of industrial floorspace and further information has been provided to address the matters raised in relation to affordable workspace requirement, heritage, energy and transport as set out in the ‘Assessment’ section of the report below. Appropriately worded conditions along with s106 Heads of Terms (HoTs) are recommended to address the issues raised. The amendments made will be considered by the GLA in their Stage II response.

Environment Agency 5.2.2 No response received.

Historic England (Archaeology) 5.2.3 No response received.

Transport for London (TfL) (received 25th June 2020) 5.2.4 TfL requests that further information is provided before we can fully assess and be supportive of the proposed development. Specific mitigation measures and further work are summarised below:

1. A contribution of £450k (£90k pa for five years) towards bus services, £15k towards TfL’s road safety scheme and £50k towards the expansion of the Cranmer Road cycle hire docking station to be secured through s106. 2. The applicant needs to confirm how cycle storage will be accessed, particularly in Block B, and demonstrate that routes to cycle storage are free of obstacles and well located. 3. Car Parking Management Plan to be secured by condition. 4. Travel Plan, Construction Logistics Plan and Delivery and Servicing Plan to be secured by condition.

Page 96

Officer comment: appropriately worded conditions and s106 Heads of Term are recommended as set out in the ‘Planning Obligations and CIL’ section below.

London Ecology Unit 5.2.5 No response received.

London Fire Brigade 5.2.6 No response received.

Thames Water 5.2.7 No response received.

6.3 Internal Consultees

LBL Building Control (Basement Impact Assessment) (received 16th June 2020) 5.3.1 No objection. The Basement Impact Assessment submitted is satisfactory.

LBL Building Control (Fire Safety) (received 15th June 2020) 5.3.2 No objection. The outline fire strategy appears satisfactory given the early design stage, covering key design issues. A more detailed strategy to accompany the design would usually be submitted as part of the Building Regulations application to the chosen Building Control Body (BCB). It is that BCB who will consider compliance of the scheme including any proposed deviations, relaxations, compensatory measures etc.

Officer comment: were permission to be granted, a condition would be applied requiring a detailed Fire Statement to be produced by an independent third party. The submitted details would be assessed by the Council’s Building Control department.

LBL Conservation & Urban Design (received 23rd April 2021) 5.3.3 No objection to the proposal. The layout, scale and mass relate positively to the existing context and as such would not appear dominant in the streetscene or context. Overall, the proposal would preserve and enhance the appearance of the character of the St Marks and Vassal Road Conservation Areas and would have no adverse impact on the setting of locally listed buildings. The impact of the proposal on the setting of statutory listed buildings has been carefully considered and no harm has been identified to these designated heritage assets. Overall, the design and appearance of proposed blocks are considered to be acceptable and will contribute positively to the streetscene and context.

Conditions requiring detailed drawings (at a scale of 1:10) showing all external construction detailing and design features; refuse and cycle stores; wayfinding and signage; landscaping and details of the re-instatement of the original sandstone plaques on Worcester House should be attached to any permission granted.

Officer comment: appropriately worded conditions are recommended as set out in the ‘Design and Conservation’ and ‘Conditions’ sections below.

LBL EHST Noise Pollution (received 22nd May 2020) 5.3.4 No objection subject to conditions securing a construction and environmental management plan; flues and extraction plant details; noise and vibration attenuation of ventilation plant; noise from light industrial activity; maintenance details; operating hours; customer management plan; delivery and servicing management plan; and external lighting being secured by condition.

Officer comment: appropriately worded conditions recommended if the committee is minded to approve the application.

Page 97

LBL Enterprise, Employment and Skills (received 28th February 2020) 5.3.5 No objection to the proposal subject to Employment and Skills obligations in line with the Council’s Employment and Skills SPD being secured by s106.

Officer comment: appropriately worded conditions and s106 Heads of Terms recommended if the committee is minded to approve the application.

LBL Flooding 5.3.6 No response received.

LBL Highways Team (received 20th April 2020) 5.3.7 No objection subject to s278 highway works to upgrade the footway around the site, which is in a poor state, being secured by s106 legal agreement.

Officer comment: were permission to be granted, the highway works would be secured by s106 legal agreement.

LBL Parks & Open Spaces (received 19th March 2020) 5.3.8 Support for the application. The proposals for a number of landscaping and ecological enhancements are welcome.

Officer comment: appropriately worded conditions are recommended as set out in the ‘Ecology, Trees and Landscaping’ section below.

LBL Planning Policy (received 27th February and 5th November 2020) 5.3.9 No objection to the proposal subject to the existing quantum of industrial floorspace being re- provided. Given the flexible nature of the existing permission (B1/D1) relating to the community floorspace on site, this replacement community space can be provided in the form of a flexible B1/D1 permission. This aspect of the proposal should seek to re-provide the existing quantum of flexible floorspace.

As the site does not lie within a town centre, the proposed flexible ancillary retail/commercial unit should be assessed against the sequential test and impact assessment. Notwithstanding the results of this, on balance, the proposed flexible unit intended primarily to serve the needs of those working in and visiting the KIBA is acceptable in principle if the aforementioned industrial floorspace capacity requirements are met.

Officer comment: The scheme has since been amended to fully re-provide the existing B1c and B8 floorspace (within Block c) and will be secured as flexible B1c/B8 (industrial) floorspace. The re- provision of industrial floorspace and proposed land uses are considered in detail in the ‘Land uses’ section below.

LBL Sustainability Team on Air Quality (received 17th March 2020) 5.3.10 No objection subject to conditions relating to an Air Quality and Dust Management Plan; Air Quality Neutral Assessment emissions; final CHP Plant and gas boiler system details; Method of Demolition and Construction Statement and emissions from Non-road Mobile Machinery (NRMM) being attached to any permission granted and a s106 requirement for a Carbon Offset Payment to be made.

Officer comment: were permission to be granted, conditions and informatives would be included.

LBL Transport (received 3rd April 2020) 5.3.11 No objection to the proposal subject to conditions relating to Delivery and Servicing Plan, Cycle Parking, disabled car parking, Car Club, Travel Plan, Construction Environmental Management Plan being attached to any permission granted and a commitment being provided to enter into a s106 and S278 agreement for pedestrian and cyclist improvements within the vicinity of the site and mitigation

Page 98

measures as set out in the ‘Transport Section’ below.

Officer comment: appropriately worded conditions and s106 Heads of Terms recommended if the committee is minded to approve the application.

Blew Burton 5.3.12 No objection subject to further information being confirmed in relation to BREEAM, water use, and the final energy strategy.

Officer comment: further information has been provided by the applicant in relation to the above matters. Appropriately worded conditions and s106 Heads of Terms recommended if the committee is minded to approve the application.

Design Out Crime Officer (Metropolitan Police) (received 3rd March 2020) 5.3.13 No objection subject to ‘Secured by Design’ conditions being attached to any permission granted.

Officer comment: appropriately worded conditions are recommended if the committee is minded to approve the application.

Veolia Waste (received 9th March 2020) 5.3.14 Support waste collection plans as outlined in delivery and service plan.

Ward Councillors 5.3.15 No response received.

5.4 Other

Brixton Society (received 29th April 2020) 5.4.1 Objection. The Brixton Society’s main concerns are as follows:

• Lack of Design & Access Statement: despite over 80 documents being provided with the application, no Design and Access Statement has been provided. This has made it very difficult to obtain an overview of the applicant’s intentions and priorities. The application should not have been validated in the absence of such a basic requirement.

• Conservation & Townscape: The Heritage & Townscape Report includes some interesting material, but rather underplays the site’s historic significance as the first major development of the former Brixton Estate Company. More critically, we expected to see more detail about the streetscape and the relationship with the Vassall Road Conservation Area. The existing roofline on the Cranmer Road frontage has some original features of particular interest. If all this is to be lost, we would prefer to see some interest or variety added to highlight the entrances to the repetitive street frontage presently proposed for blocks A and B.

• Accommodating existing businesses: the Brixton Society is sympathetic to the provision of new business floorspace, because so much has been displaced by high-density residential development in recent years. However, it needs to match the needs of a range of local business types, including some uses or processes which will generate noise or fumes, or require the storage or recycling of special waste products. Providing undifferentiated desk- space for start-ups is insufficient for a development of this scale. Too many growing enterprises have had to move away from the Lambeth area because of a lack of suitable local premises to expand into, reducing local employment opportunities. To allow existing tenants to relocate within the larger site, the development should be carried out in phases.

• Noise Impact on nearby dwellings: Operating hours and vehicle access arrangements need to respect the amenity of nearby residential property in Cranmer Road and Foxley Road.

Page 99

• Extract Ventilation: The design of extract ventilation is often a critical factor in how acceptable industrial processes will be in proximity to residential accommodation. External ducts should be sited in relatively unobtrusive positions. On the Cranmer and Foxley Road frontages, they should only discharge above the main roof level. Flues should include odour filters and soundproofing.

Officer comment: A Design and Access Statement has been submitted with the application and is available to view on the Council’s website. The concerns raised are addressed in the ‘Design and Conservation’ and ‘Amenity of neighbouring occupiers’ section below.

5.5 Adjoining owners/occupiers

5.5.1 Public consultation was undertaken in accordance with statutory and council requirements, including 551 individual letters sent to neighbouring properties within the vicinity of the site, publication of a press advert and site notices being displayed on 6th March 2020. The public consultation period formally ended on 6th April 2020 although representations continue to be accepted up until the time of determination.

5.5.2 In total, 1 individual objection has been received as summarised in Table 2 below:

Summary of objections Response Amenity • Likelihood of undue noise and Refer to ‘Amenity of neighbouring occupiers’ fumes section below • Loss of sunlight/daylight Refer to ‘Amenity of neighbouring occupiers’ section below • Loss of privacy Refer to ‘Amenity of neighbouring occupiers’ section below

Table 2 – Summary of objections

6 POLICIES

6.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise. Section 72 of the Planning (Listed Buildings and Conservation Area) Act 1990 as amended advises that the Council has a duty to respect any building or land in conservation areas in exercise of planning functions and advises that special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area.

6.2 The development plan in Lambeth is the new London Plan (2021) and the Lambeth Local Plan (September 2015). Following the successful completion of the Examination process and formal consent to publish by the Secretary of State, on 2 March 2021 the Mayor of London formally published the new London Plan which now has full weight in planning decisions. The Lambeth Local Plan (LLP) is currently under partial review to ensure it complies with amendments to the National Planning Policy Framework (NPPF) and the new London Plan.

6.3 The Draft Revised Lambeth Local Plan (DRLLP) underwent public consultation under Regulation 19 of the Town and Country Planning (Local Plans) (England) Regulations 2012 between 31 January and 13 March 2020 and was submitted to the Secretary of State for examination on 22 May 2020. The examination hearing took place between the 27 October and 13 November 2020. The Inspector’s proposed main modifications were made available for public consultation between 15 February and 29 March 2021. Those draft policies that are unaffected by proposed main modifications can be considered to have significant weight at this point, with moderate weight

Page 100

afforded to those policies that are subject to proposed main modifications.

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

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

7 ASSESSMENT

7.1 Land uses

7.1.1 The proposal would provide 24,672sqm (GIA) of flexible industrial and employment floorspace (former Use Class B1a-c and B8) with an increase of 16,213sqm (192% uplift) proposed on site. The principle of the proposed uses is discussed in full below.

Industrial and employment floorspace

7.1.2 The application site lies within the Kennington Oval area, where, through Policy PN8 of the LLP and DRLLP, the council will support its role as an important residential and employment area. Policy PN8 notes that there are opportunities to increase the vitality and attractiveness of the Brixton Road centre through the provision of active frontages in the Kennington Park. The Local Plan considers that appropriate proposals that achieve these objectives and result in no net loss of employment floorspace will be supported.

7.1.3 The site also lies within the designated Kennington Business Park Key Industrial and Business Area (KIBA), which is referenced as a Locally Significant Industrial Site (LSIS) within Policy E6 of the London Plan. The application site comprises 1.58ha of the overall 2.5ha Business Centre containing 8,459 sqm of floorspace in former Use Class B1a-c use.

7.1.4 Policies E4 and E7 of the London Plan seek to ensure there is sufficient industrial capacity across the capital to meet current and future demand. Policy E4 states that the provision of industrial capacity should be retained and enhanced in locations such as this, which provide capacity for micro, small and medium sized enterprises. Policy E7 also states that the redevelopment of Locally Significant Industrial Sites such as this can be supported where industrial floorspace is re-provided as part of an industrial intensification, co-location and substitution scheme.

7.1.5 Policy ED1 of the LLP further advises that development in KIBA’s will only be permitted for ‘business, industrial, storage and waste management uses, including green industries and other compatible industrial and commercial uses (excluding large scale retail) ancillary to, or providing for, the needs of the KIBA’. Policy ED3, part b) of the DRLLP encourages the intensification of industrial uses in former Use Classes B1b, B1c, B2 and B8 and industrial sui generis use, in accordance with Policy E7, Section A of the London Plan. Development proposals of this type should have regard to operational requirements (including servicing) and mitigate impacts on the transport network where necessary.

7.1.6 As set out in Table 1 above, the proposal would re-provide the full existing quantum of former Use Class B1c light industrial floorspace, including the former Use Class B8 floorspace (5,408sq.m), which is supported. This would be secured by condition in any permission granted. The proposed floorspace would not compromise any surrounding industrial uses, in terms of their function, operation and access, and has been designed to be fully fit for purpose in accordance with Policy E2 of the London Plan and the GLA’s minimum specifications for industrial uses.

7.1.7 The proposed former Use Class B1c floorspace units within Building C would be flexible, with the ability to be made larger or smaller to suit the occupier (these range from circa 30-100sqm) with a

Page 101

range of floor to ceiling heights with the ground floor units having a floor to ceiling height of 3.6m under the part mezzanine floor, the remainder of the ground floor (double height section without the mezzanine floor) having a floor to ceiling height of circa 7m. The part mezzanine floors within the ground floor units give the occupier the option of installing larger machinery in part of the unit and an ancillary storage or office space within the mezzanine, if desired. The other floors within the Block are circa 3.1m in height. The corridors would have a minimum width of 1800mm, and a goods lift is proposed within Block C. All units would have a lockable door and a minimum opening width of 0.9m. The yard space is also appropriate for the building and the number of units. The detailed specification and functionality of the light industrial / workspace, in terms of fit out, layout, access and servicing would be secured by condition were permission to be granted.

7.1.8 The development also proposes a significant uplift in business floorspace with an increase of 16,213sqm (192% uplift) proposed on site. The employment use proposed would permit a range of office, research and development and light industrial uses falling under former Use Class B1a, B1b and B1c and provides flexible workspace suitable for occupation by a range of business sizes, which is welcomed.. The design and layout of the proposal has been specifically tailored to be suitable for micro, small and medium sized creative enterprises engaged in light industrial manufacturing and design activities. Policy E1 of the London Plan supports increases in office provision in certain locations, in outer and inner London, this includes focusing office development in town centres and existing office clusters. In this regard, the site is an established business park with a large proportion of existing office floorspace. On this basis, the provision of business uses on site is acceptable in principle,

Affordable workspace

7.1.9 Policy E3 of the London Plan encourages the provision of affordable workspace, the specifics of which should be defined in local development plans. In this regard, Policy ED2 of the DRLLP states that the council will apply requirements for affordable workspace in (i) Waterloo/Southbank and Vauxhall, (ii) Oval, Kennington and Clapham and in the (iii) Brixton Creative Enterprise Zone. The supporting text to the policy explains that the areas referred to in Policy ED2, part a) i) and ii) correspond to CIL charging zones A (Waterloo/ Southbank and Vauxhall) and B (Kennington, Oval and Clapham). The application site lies in Charging Zone C and therefore this policy does not apply to this site and the proposal is not required to provide a percentage of Affordable Workspace.

7.1.10 Notwithstanding this, this site will continue to operate as per the applicant’s existing business model which provides floorspace for SME, including access to onsite facilities providing support for micro and small businesses at an affordable rent and flexible leasing agreements which can be adapted as businesses grow.

Flexible retail / commercial unit

7.1.11 The scheme proposes one unit (330sqm) as a flexible/alternative commercial use, comprising either former Use Classes A1/A2/A3/A4 or B1 floorspace. This unit is proposed to be located within the north east corner of the site, within the ground floor of Building C. This flexible unit is described as an ‘ancillary facility to the KIBA, to cater for the significant uplift in employees on the site’. The applicant’s aspiration for this unit is to provide a facility which is related to the use of the KIBA, such as a small-scale café or a bar/taproom. The applicant states that whilst they expect the facility would primarily serve those working and visiting Kennington Park, both future and existing, it would also be open to the general public. The principle frontage of the unit will face internally to the courtyard and KIBA but would also be accessible from the corner of Foxley Road. The proposed unit will have direct access to the external amenity space proposed within the courtyard, where seating and a games area are proposed as part of the landscaping strategy. The applicant estimates that the whole of the development proposal when complete will be occupied by between an additional 351-1370 employees.

Page 102

7.1.12 The site is not within a designated town centre. However, a local centre lies immediately to the west of the site along Brixton Road. The proposals are for 330sqm of flexible former Use Classes A1/A2/A3/ A4 or B1 uses which is to be located in a unit to the north east of the site, furthest from the local centre and therefore in an out of centre location. Policy SD7 of the London Plan and Policy ED6 of the LLP and DRLLP require the sequential test to be applied to applications for main town centre uses, requiring them to be located in town centres in the first instance. Out of centre sites should only be considered if it demonstrated that no suitable sites are available within the town centre or edge of centre locations and applications that fail to demonstrate this should be refused. Notwithstanding this, given the relatively small size of the unit and the fact that it would serve as a complementary function to the business park, the provision of a small flexible retail unit is considered acceptable on balance.

Social Infrastructure

7.1.13 The existing site currently contains an element of former Use Class D1 floorspace comprising educational and training floorspace according to the applicant’s submission. This has been defined as existing flexible office/ educational floorspace (1,455sq.m) which it is understood is currently occupied by the University of Wales as offices and teaching/ training facilities in Winchester House.

7.1.14 Uses involving teaching and training cannot lawfully be accommodated under former Use Class B1 use. Policy S3 of the London Plan and Policy S1 of the LLP and DRLLP seek to ensure development proposals result in no net loss of education or childcare facilities, unless it can be demonstrated that there is no on-going or future need.

7.1.15 The planning permission (ref. 09/03485/FUL) for the first floor approved the change of use of 1,637sqm to former Use Class D1 use. It is acknowledged, however, that a condition attached to this particular permission states that should this use cease, it is required to be reinstated to Class B1. However, if it is still in active use, this floorspace should be re-provided under the provisions of the policies. The proposals would re-provide this use in its entirety which would satisfy the requirements of Policy S3 of the London Plan and Policy S1 of the LLP and DRLLP.

7.1.16 Given the flexible nature of this permission and requirement to reinstate the use back to Business use, it is not deemed appropriate to secure a solely Storage or Distribution use within the proposal, this use would also not be an appropriate use within a KIBA under policy. As such, 1,455sqm would be secured as flexible Class D1/B1 use were permission to be granted.

7.2 Design and conservation

7.2.1 Good design is central to all objectives of the London Plan and LLP and DRLLP planning policies. Policies D1 to D4 of the London Plan place greater emphasis on a design-led approach to ensure development makes the best use of land, with consideration given to site context, public transport, walking and cycling accessibility and the capacity of surrounding infrastructure. The higher the density of a development the greater the level of scrutiny there should be of the proposed built form, massing, site layout, external spaces, internal design, and ongoing management.

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

7.2.3 The Business Centre is locally listed and therefore considered a non-designated heritage asset. The site is also sandwiched between two conservation areas; St Marks (CA11) that lies north of the site and Vassal Road (CA7) directly east of the site along Foxley Road. Kennington Park, a Grade II Registered Park is north of the site. There are also a number of statutory and locally listed buildings in the vicinity of the site.

7.2.4 This section of the report considers design and conservation (heritage) matters arising from the proposed development and incorporates the Council’s Design and Conservation Team’s comments on

Page 103

the proposals. It is set out under the following sub-headings:

• Scale, massing, layout and appearance • Strategic and Local Views • Impact on heritage assets

7.2.5 The Council’s Design and Conservation Team’s comments have been incorporated into this section of the report.

Scale, massing, layout and appearance

7.2.6 The scale of development in the surrounding context is relatively modest ranging between two and four storeys in height. The retained buildings on the site (Lincoln House, Canterbury Court, Chichester House and Chester House) are substantial occupying a large footprint and standing at four storeys making an impression within the streetscene. The proposal is for three buildings - Block A (five storeys along Cranmer Road), Block B (part three, four and five storeys along Cranmer Road) and Block C (four storeys on Foxley and Camberwell New Road). The proposed blocks would be of a comparable scale and mass to existing blocks on site and as such would not appear dominant or out of place within the surrounding context. The scale of development is considered to be in keeping with the established character of the commercial complex.

7.2.7 The proposal would increase in height and mass noticeably along Cranmer Road. However, at a maximum of four storeys fronting Cranmer Road, as shown in Figure 5 below, the proposal would not overbear the street and the generous gaps between Block A, B and C ensures that development will not appear as a continuous canyon like development.

Figure 5 – Proposed view looking northwest from Foxley Road and east along Cranmer Road

7.2.8 In addition to appropriate scale, the proposed Block building lines respond positively to the established building lines of retained buildings Cranmer House and Canterbury Court which assist in the proposal fitting into the streetscene successfully. The layout, scale and mass would relate positively to the existing context and as such would not appear dominant in the streetscene or context.

7.2.9 The architectural approach is based on a contemporary warehouse aesthetic. Officers consider this an appropriate design approach as it resonates strongly with the character of the retained locally listed commercial/warehouse buildings. Each of the proposed buildings have robust brick elevations with regular punched window openings.

7.2.10 The group of buildings proposed has been carefully considered in terms of their architectural language. The architectural detailing provides individuality to each block whilst the consistent use of brick creates a clear and coherent visual appearance that unifies the complex. Brick detailing and the use of contrasting and complimentary materials also adds another layer of interest and texture. The material palette is also well considered with brick the predominate material which relates positively to the other buildings within the complex and the surrounding context and gives the buildings a robust

Page 104

quality. Overall, the design and appearance of proposed blocks are considered to be acceptable and will contribute positively to the streetscene and context.

7.2.11 Whilst officers are supportive of the principle and style of boundaries along Cranmer Road, there is concern in relation to the potential height of these railings, which should be lowered where possible. As such, a condition requiring details of boundary to be agreed is considered to be appropriate.

Strategic and Local Views

7.2.12 The site is within the strategic view of Primrose Hill to the Palace of Westminster background assessment area (view 4A.2) and also within local views, including Local Views 19 Brixton Panoramic and 22 Norwood Park and Millbank to Vauxhall Bridge Given the relatively low scale of the development, the Townscape and Heritage assessment undertaken and officers, conclude that there will be no impact or harm to either strategic or local views.

Impact on Heritage Assets

Locally Listed Buildings

i) Kennington Business Centre; Demolition of Salisbury House, Worcester House, Winchester House, Hereford House and Gloucester House

7.2.13 The business complex is locally listed for its architecture, history and townscape. Policy Q23, part (c) of the LLP and DRLLP advise that the council will: ‘i) resist the destruction of assets on the local heritage list (or harm their settings) and expect applicants to retain, preserve, protect, safeguard and where desirable, enhance them when developing proposals that affect them; ii) require proper investigation and recording of archaeological remains and publication and archiving of results to advance understanding.; and iii) apply London Plan policy HC1D’.

7.2.14 Paragraph 197 of the NPPF further states that ‘the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application’. In weighing applications that directly or indirectly affect non-designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.

7.2.15 The significance of the locally listed complex lies within the architectural, historical and townscape value of blocks fronting onto Brixton Road (Lincoln House, Canterbury Court, Chichester House, Chester Court and Cranmer House). These Edwardian blocks are striking in their appearance and scale, comprising highly ornamental and detailed brick and sandstone elevations. In contrast to these decorative buildings, the remaining blocks to be demolished, although having competent facades, are lower in scale and grandeur with a more utilitarian appearance and modest embellishment. In the case of Winchester House and Gloucester House they were of later construction; the façade of Winchester House was substantially rebuilt in 1992 and Gloucester House was built in circ.1950 therefore they do not have any heritage value. Similarly, there is evidence that suggests that Hereford House façade was also constructed at the same time as Gloucester House as the current façade is not apparent in a 1934 aerial photograph.

7.2.16 As detailed within the Design and Access Statement, there is also evidence that a number of the buildings are experiencing leakage in the roofs, internal water damage creating mould and unknown substances beginning to surface within the ground floor levels, likely as a result of historic uses of the site. Internally, the buildings have cramped and challenging layouts which have been altered over time in an attempt to cater and accommodate the changing and differing needs of businesses.

7.2.17 For these reasons, no objection is raised to the loss of Salisbury House, Norfolk House, Worcester House, Winchester House, Hereford House and Gloucester House. Furthermore, the replacement buildings will be of high architectural quality that sympathetically responds to the retained locally listed buildings and reinforces the character of the complex.

Page 105

7.2.18 Overall, whilst officers recognise that parts of the locally listed complex will be lost this would not affect the significance of the complex as its value derives from the retained buildings on site. Officers are also of the view that the proposed Blocks will enhance the setting of the locally listed complex particularly in views from Camberwell New Road, Cranmer Road and Foxley Road.

ii) No 60 Camberwell New Road

7.2.19 The Kennington is a three-storey public house built in circa1900 in the Queen Anne style and located along Camberwell New Road at the junction with Foxley Road. The pub marks the corner, boasting Dutch gables with copper dome and its elevations are faced in red brick with stone dressings. Currently, the site/Gloucester House are seen within the setting of The Kennington Pub from various vantage points along Camberwell New Road and Foxley Road. Gloucester House is located directly opposite The Kennington and is considered to be an unremarkable utilitarian 1950’s commercial block which has a neutral impact on the setting of the locally listed pub. However, Block C which is proposed to replace Gloucester House would stand at a comparable height to The Kennington, be faced in brick and would have attractive appearance which would enhance the setting of the pub.

Figure 6 – Proposed view looking northwest along Camberwell New Road

7.2.20 Overall, it is considered the replacement high quality Block C would improve the setting of the pub.

Conservation Areas

i) Vassall Road Conservation Area (CA07)

7.2.21 The conservation area is located to the east and south-east of the site and is characterised by formal terraces and semi-detached villas built for the burgeoning middle classes when this area was made accessible following the construction of the Vauxhall Bridge after 1816. The site fronts onto Foxley Road which lies within the conservation area. The 2016 conservation character appraisal describes Foxley Road as a:

‘…relatively broad road has a quiet residential character. Detached and semi-detached villas and a grand terrace are supplemented by sympathetic 1970s infill development. The use of stock brick and stucco unifies the street, as does repeated use of 6/6 sash windows and flat gauged arch heads. The

Page 106

presence of large trees and mature hedges gives it a leafy domestic atmosphere. Looking south the view terminates in the commanding spire of St John the Divine. There are excellent views of the rear elevations of terraced houses at nos 95 – 113 Vassall Road, which make an important contribution to the area’s historic character.

On the west side, tall villas (three storeys over a semi-basement) with overhanging eaves create a strong rhythm; these have narrow gardens and a close relationship to the street. Across from these is a smart terrace with tall flanking and central pavilions creating a symmetrical composition. The front gardens are now landscaped communally, re-graded to form a gentle slope to the basement area; they are no longer enclosed. These alterations cumulatively weaken their historic integrity. A large, well-planted open space near the junction with Vassall Road contributes to the street’s leafy quality. The pair of 1970s infill bungalows may at first seem incongruous with these surroundings, but their low scale allows for a sense of spaciousness.’

7.2.22 Foxley Road also contains a number of statutory listed properties the impact on these listed properties is assessed later on in my comments. The impact of Block C on Vassal Road Conservation Area is considered to be a positive and beneficial one. Its proposed height of four storeys provides appropriate enclosure and definition to the street a key character of Foxley Road whilst its quality detailed design relates to listed villas on the street. Block C is considered a marked improvement to the current Gloucester House which does not have any architectural or townscape value.

7.2.23 Overall, the proposal would enhance the appearance and character of Vassal Road Conservation Area.

ii) St Marks Conservation Area (CA11)

7.2.24 The St Mark's Conservation Area (CA) is characterised by smart terraced housing dating from the early 19th century onwards. Of particular note is Hanover Square. The imposing St Mark's Church is its principal landmark and is grade II* listed. The impact on St Marks church is assessed separately in the ‘Statutory Listed Building’ section.

7.2.25 Although St Marks CA is located close to the site on the west side of Brixton Road the impact of the proposal on the conservation area is limited as Blocks A, B and C are located within the southern portion of the site some distance from the CA. In views from St Marks CA towards the site, the retained blocks from Brixton Road would screen proposed Blocks A, B and C and where they are glimpsed, they would not appear dominate or distracting. Similarly, where Block C can be seen in views looking north west along Camberwell New Road towards St Marks CA it would moderate in scale and not detract of harm the appearance or character of the conservation area.

7.2.26 Overall, the proposal would preserve and enhance the appearance of the character of the St Marks Conservation Area.

Statutory Listed Buildings

i) Kennington Park (Registered Historic Park and Garden)

7.2.27 The impact on Kennington Park would be similar to St Marks. Block C would be seen in the setting of the park (eastern boundary) in the view looking northwest along New Camberwell Road. The moderate scale of Block C would not detract from the setting of the registered park. In officer’s view there would be an improvement to the parks setting.

ii) St Marks Church

7.2.28 St Marks’ is a grade II* listed church located along Kennington Park Road. Built 1822-24 to the design of A B Clayton with frontages onto Clapham Road, Brixton Road and Prima Road. The church is in Greek revival style with sandstone elevations and Portland stone tetrastyle Doric porch in antis with pediment and a square tower bearing octagonal drum and open round ionic stage with cupola above.

Page 107

Nos 22 & 24 Brixton Road is a pair of houses dating from the early C19 in brown stock brick and is also listed (grade II). Both St Marks church and Nos 22 & 24 are located along Brixton Road and directly opposite the site.

7.2.29 The site lies within the backdrop of St Marks Church when looking south east from Clapham Road. The siting of Blocks A, B and C in the southern part of the site and being a similar height to retained buildings means that they would be mostly screened by retained blocks and where they may be visible taking into account seasonal changes their proposed height being similar to retained blocks means that they would not appear dominant. The church would the focal point in the view. In the view from Brixton Road looking north west towards the church, the proposal would not be seen in the setting of the church and as such there would be no impact. There would also be no impact on the setting of Nos 22 & 24 which when viewed from Brixton Road.

iii) Foxley Road and Camberwell New Road

7.2.30 Block C has frontages onto Camberwell New Road and Foxley Road which both contain a number of listed buildings close to the site, which are as follows:

Listed Buildings along Camberwell New Road and Foxley Road: • No.64-76 Camberwell New Road (Grade II) • No.78-82 Camberwell New Road (Grade II) • No.84-90 Camberwell New Road (Grade II) • No.15-19 Foxley Road (Grade II) • No.32-48 Foxley Road (Grade II) • No.21-37 Foxley Road (Grade II)

7.2.31 As such, Block C would be seen in the streetscene and within their settings in views along Camberwell New Road and Foxley Road. Unlike Gloucester House which has no architectural value, Block C has pleasing proportions that take inspiration from the rhythms and patterns of listed villas along Foxley Road. As a result, the scale, mass and detailed design relates positively to the listed buildings and character of the street. Where Block C turns the corner onto Camberwell New Road its defined brick parapet and setback upper storey responds to the massing and form of Canterbury House and therefore fits into the streetscene successfully.

7.2.32 Overall, Block C would be a positive addition to the street which would enhance the setting of listed buildings along Foxley Road and Camberwell New Road. The proposal would have a similar beneficial impact in the view looking south along Foxley Road where St John the Divine Church (Grade I listed and built 1870-74 to the designs of G E Street) which spire terminates the vista and the church is located on Vassal Road. The high-quality appearance of Block C would improve the appearance of the street and the foreground of the view.

Conclusion

7.2.33 To conclude, officers have carefully considered the impact of the proposal on the setting of statutory listed buildings and no harm has been identified harm to these designated heritage assets. The proposal would therefore comply with Policy Q20 of the LLP and DRLLP.

7.3 Inclusive Design

7.3.1 Policy D5 of the London Plan requires that all new developments achieve the highest standards of accessible and inclusive design and can be used safely, easily and with dignity by all; are convenient and welcoming with no disabling barriers; are flexible and response; and realistic. This requirement is reiterated in Policy Q1 of the LLP and DRLLP.

7.3.2 Blocks A and B are accessed from the internal courtyard/landscaped area and Block C has a direct entrance from the road and from the rear courtyard. The proposed buildings all have step free access. All entrances to the buildings will be step free, fully accessible and clearly distinguishable from the rest

Page 108

of the façade. All entrance doors will have clear openings greater than 800mm in order to facilitate wheelchair access.

7.3.3 There are 6 disabled parking bays proposed on site, all of which will have electrical charge points. The areas dedicated to disabled car parking and loading bays are located off the main vehicle route. These will be identified by the use of graphics painted on the concrete paving.

7.3.4 Internally, lift access is available to all floors which will accommodate wheelchair users with room for standing passengers.

7.3.5 As such, the proposal would provide a high standard of accessible and inclusive design that can be used safely and easily by all in accordance with Policy D5 of the London Plan and Policy Q1 of the LLP and DRLLP.

7.4 Fire safety

7.4.1 Policy D12 of the London Plan states that major applications should be accompanied by a fire statement, prepared by a suitably qualified third-party assessor, demonstrating how the development proposals would achieve the highest standards of fire safety, including details of construction methods and materials, means of escape, fire safety features and means of access for fire service personnel. Policy D5 further seeks to ensure that developments incorporate safe and dignified emergency evacuation for all building users. In all developments where lifts are installed, as a minimum, at least one lift per core (or more subject to capacity assessments) should be a suitably sized fire evacuation lift suitable to be used to evacuate people who require level access from the buildings.

7.4.2 An outline Fire Strategy has been submitted with the application which sets out the overall approach to fire safety. This has been reviewed by the Council’s Building Control section and is considered to be satisfactory given the early design stage, covering the key design issues. A more detailed strategy to accompany the design would usually be submitted as part of the Building Regulations application to the chosen Building Control Body (BCB). It is that BCB who will consider compliance of the scheme including any proposed deviations, relaxations, compensatory measures etc.

7.4.3 A condition would be applied to any permission granted requiring a detailed Fire Statement to be produced by an independent third party. The submitted details would be assessed by the Council’s Building Control department and the proposal would therefore meet policy.

7.5 Amenity for neighbouring occupiers

7.5.1 One of the core planning principles (paragraph 17) in the NPPF is that decisions should “always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings”.

7.5.2 Policy Q2 of the LLP and DRLLP only supports development if visual amenity from adjoining sites and from the public realm is not unacceptably compromised, acceptable standards of privacy are provided, adequate outlook is provided, while undue sense of enclosure and overlooking is avoided, and daylight and sunlight levels to both the host property and surrounding properties are not compromised.

Daylight, sunlight and overshadowing

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

7.5.4 The BRE guidelines are not mandatory; they do however act as a guide to help understand the impact

Page 109

of a development upon properties and other spaces, while acknowledging that in some circumstances, such as that of an urban environment or where the existing site is only previously partially developed some impact may be unavoidable. It should be further noted that the BRE guide considers level of daylight, sunlight and overshadowing tests based on an expectation of reasonable levels of light within a suburban context and this should be kept in mind when considering a central London context as is the case for the application site.

7.5.5 The nearest residential properties to the site are located in Cranmer Road, Bowhill Close and Minerva Close to the south; Camberwell New Road and Foxley Road to the east; and Camberwell New Road to the north as shown in Figure 2 above.

7.5.6 The Council has sought an independent review of the report findings in respect of possible impacts of the new development on surrounding sites and within the development itself. This review was undertaken by Schroeders Begg. Their assessment review considers several tests:

• The 25-degree line: Properties will very likely retain good levels of daylight and sunlight if new development does fall below a 25-degree line to the horizontal drawn from the centre of the lowest window; • Vertical Sky Component (VSC): A measure of the amount of skylight available at the centre of a habitable room window (ratio compared to horizontal plane) to serve a habitable room. The BRE guide states that daylighting may be affected if the VSC calculation is less than 27% and less than 0.8 times its former value; • Annual Probable Sunlight Hours (APSH): Is a measure of the average number of hours per year in which direct sunlight is received by a window. The BRE guide states that rooms may be affected if they receive less than 25% APSH for the year and 5% APSH for the winter; and less than 0.8 times former value; • Daylight Distribution / No skyline test (NSL): A measure that calculates the amount of area (at the working plane) of a habitable room which receives direct skylight and how much does not. The BRE guide highlights if less than 0.8 times former value, reductions will be noticeable; and • Shadowing: The BRE guide recommends that at least half the area of an amenity space should receive at least 2hrs of sunlight on the Spring Equinox (21 March).

7.5.7 In terms of daylight analysis, applicable reductions to habitable rooms in both VSC and daylight distribution / NSL meets BRE target criteria for the following properties and therefore, the review does not comment further on these;

• Nos 3-13 (odds) Foxley Road • Nos 39-57 Camberwell New Road • Clarson House, 59-61 Camberwell New Road

7.5.8 The review undertaken concludes that the proposal would result in some very limited reductions to a window or room which is considered as effectively / very close to meeting target and this is summarised as follows;

No 2 Bowhill Close

7.5.9 This bungalow property has 2 No rooms with windows facing north / opposite the development site; a conservatory and dual aspect living room which have daylight VSC reductions to some isolated windows with reductions exceeding BRE Guide default target criteria. For the conservatory, there are 2 No isolated windows with a VSC reduction each of 22%; however, given the numerous windows within the conservatory, in consideration of the average VSC reduction for this room, BRE Guide target criteria would be readily met. Similarly, for the dual aspect living room, this is served by a window and glazed door facing site and rear window / not facing site; in considering an average VSC reduction for this living room, the reduction would equate to 18% thus within BRE Guide target criteria. A third room has also been analysed (bedroom) albeit windows are perpendicular to site and for the small reductions applicable in daylight VSC, these meet target criteria. For any reductions in daylight

Page 110

distribution to all 3 No rooms considered, these readily meet BRE Guide target criteria. Thus, in terms of daylight reductions, in considering the analysis in context of dual aspect arrangements, there is considered to be no adverse effect overall to this property.

The Kennington, 60 Camberwell New Road

7.5.10 The likely residential upper parts of this property have been analysed. All reductions in daylight VSC and daylight distribution meet target criteria with the isolated exception of a window to a 1st floor window (window W7 potentially serving a kitchen having a VSC reduction of 29%); however, given that this window forms part of a bay arrangement and is not the central window (often the main / primary window considered) and equally, the average VSC reduction for the room would readily meet BRE Guide default target criteria, we consider that there is no adverse effect overall. In addition, there is also a 1st floor room (ref R3, potentially a dining room) which is served by 2 No windows and whilst reductions will exceed BRE Guide target criteria, the retained VSC value to both of these windows is 26.3 thus very close to a VSC threshold value of 27 (VSC reductions not being considered until falling below a VSC value of 27). In summary, it is considered there is effectively no / negligible adverse impact on daylight to this property for the anticipated residential habitable rooms.

7.5.11 In respect of the remaining properties, there are reductions in daylight VSC and / or daylight distribution there are a number of windows (and / or in some isolated instances, greater reductions) not meeting BRE Guide default target criteria and we upon these as follows:

Swift House (Nos 25-38 inclusive), Cranmer Road

7.5.12 This property comprises flats / maisonettes and based upon indicative layout details, it appears that typically, bedrooms and small / medium size kitchens have windows in the north elevation / facing the site (living rooms, typically appearing to rear of the property facing south, away from the proposal).

7.5.13 For the western half of this property (Nos 25–32 Swift House), for any applicable reductions in daylight VSC and / or daylight distribution, these meet BRE Guide default target criteria.

7.5.14 For the eastern half of this property (Nos 33- 38 Swift House), from the analysis, there are typically ‘minor adverse’ reductions in VSC (2 No windows having reductions at 30% reduction thus borderline of ‘minor / moderate’ adverse reductions). However, in all instances, retained VSC values for these particular windows range 19.4 to 26.6 thus considered a reasonable VSC for an urban context.

7.5.15 In terms of daylight distribution, all reductions meet BRE Guide default target criteria with the isolated exception of 4 No rooms; 2 No rooms with ‘minor adverse’ reductions and 2 No rooms having ‘moderate adverse’ reductions; these rooms being at the eastern end. However, in respect of the retained daylight distribution value, these are; 61%, 66%, 74% & 75% respectively, which again are considered reasonable for an urban context.

7.5.16 In summary, the majority of rooms have reductions in daylight distribution meeting target criteria and for daylight VSC, circa half of windows applicable for review have reductions meeting target criteria and for the remaining eastern half, reductions are typically, ‘minor adverse’ and relating to bedrooms or kitchens and in consideration of retained levels, these are considered reasonable for an urban context.

Nos 6-30 (evens) Cranmer Road

7.5.17 For these townhouses, based upon indicative layout details, it appears that typically bedrooms have windows in the north elevation / facing site (living rooms, typically to the rear of these townhouses with windows facing south, away from the proposal).

7.5.18 For Nos, 6, 8 & 10 Cranmer Road, effectively reductions in daylight VSC and daylight distribution meet BRE Guide default target criteria.

Page 111

7.5.19 For Nos 12, 14, 16, 18, 20, 22, 24, 26, 28 & 30 Cranmer Road, in terms of windows facing site that are serving habitable rooms (in this instance considered typically bedrooms), all windows have ‘minor adverse’ reductions in VSC. The applicable retained VSC values are ranging 16.5 to 26 (average retained VSC for this particular range being 22.2) which again, could be considered reasonable for an urban context and in consideration that typically the habitable rooms appear bedrooms which the BRE Guide recognises for which daylight as being less important (when compared to say a living room / similar). For the same property range, in terms of daylight distribution, typically, it is the lower ground floor rooms with reductions not meeting BRE Guide default target criteria and to such rooms, reductions are typically ‘major adverse’.

7.5.20 However, it is noted that all rooms as existing scenario, effectively have 100% daylight distribution to these rooms and for the given reductions, these rooms would still retain a daylight distribution of 59% or above (with the isolated instance of one room with a proposed daylight distribution of 55% and 1 No room at 58%). To highlight, these reductions in daylight distribution relate to the lower ground floor rooms and almost all reductions in daylight distribution at upper ground and 1st floor meets BRE Guide default target criteria.

7.5.21 On balance, in consideration of the extent and adversity, retained values and room uses affected (typically bedrooms), general dual-aspect arrangement of these residential properties etc, it is considered that such an impact to daylight should be considered reasonable for an urban context.

Nos 36-50 (evens) Cranmer Road

7.5.22 These townhouses appear of similar arrangement to Nos 6-30 (evens) Cranmer Road, namely, typically bedrooms having windows in the north elevation / facing site (living rooms, typically to the rear of these townhouses with windows facing south, away from the proposal).

7.5.23 In terms of windows facing site serving habitable rooms, windows have typically ‘moderate adverse’ reductions in VSC (part opposite the slightly higher part of proposed Block B). Consideration of the applicable retained VSC values are ranging 15.2 to 26.8 (average retained VSC for this particular range being 21.4); indeed, given this retained average, it is highlighted that there are a limited 9 No windows (out of 23 No for this range) with a VSC below 20.

7.5.24 For the same property range, in terms of daylight distribution, typically, it is the lower ground floor rooms with reductions not meeting BRE Guide default target criteria and to such rooms, reductions are typically ‘major adverse’.

7.5.25 However, it is noted that almost all rooms as existing scenario, effectively have 100% daylight distribution to these rooms and for the given reductions, these rooms would still retain a daylight distribution of 59% or above (with the isolated instances of 4 No rooms in the proposed scenario with respective retained daylight distribution values of 50%, 52%, 55% & 57%). To highlight, this relates to the lower ground floor and almost all reductions in daylight distribution at upper ground and 1st floor meets BRE Guide default target criteria.

7.5.26 On balance, in consideration of the extent and adversity, retained values and room uses affected (typically bedrooms), general dual-aspect arrangement of these residential properties etc, it is considered that such an impact to daylight should be considered reasonable for an urban context.

No 6 Minerva Close

7.5.27 This bungalow property has 3 No bedrooms with windows facing north / opposite the development site (includes a larger bedroom appearing dual aspect with a small window in the rear elevation). In addition, there is a front living room albeit the windows appear perpendicular to the proposal / not directly facing and not analysed (there would be minimal reduction to these particular windows from the proposal).

7.5.28 In consideration of the 3 No bedrooms, in terms of daylight VSC, the reductions exceed BRE Guide

Page 112

default target criteria with reductions considered as close to the threshold of ‘minor/moderate adverse’ reductions. In terms of daylight distribution, reductions are limited and readily meet BRE Guide target criteria. Such reductions in VSC for this urban context should be considered acceptable, especially, that these relate to bedrooms.

Nos 54-62 (evens) Cranmer Road

7.5.29 These residential properties are arranged at 2nd and 3rd floor above the Oval Ambulance Station and comprise 5 No maisonettes accessed from the deck-access walkway at 2nd floor. It appears that a kitchen at 2nd floor and a bedroom at 3rd floor are the habitable rooms with windows in the north elevation / facing site (living rooms appearing to the rear of the property with windows facing south / away from the proposal).

7.5.30 In terms of windows facing site serving these habitable rooms, all reductions in both daylight VSC and daylight distribution meet the BRE Guide default target criteria with the exception of VSC reductions to the 5 No kitchen windows at 2nd floor level.

7.5.31 In terms of these kitchen windows, they are recessed within the deck-access since the bedroom at 3rd floor projects out above these kitchen windows thus forming a soffit above these kitchen windows which inherently obstructs daylight. In such instances, sometimes a theoretical analysis of ‘without balconies / soffits’ is undertaken to assist in consideration of the sensitivity of this inherent arrangement to changes in obstruction / the proposed massing.

7.5.32 However, given that the actual shift in VSC loss is limited (in value terms, as opposed to percentage terms), then this is less benefit for consideration of ‘without balconies / soffit’ analysis and equally, it can be readily seen that the windows on the immediately floor above (which whilst benefitting from being slightly higher, do project further forward / closer to the proposal), have quite limited reductions of just up to 9% reduction. These kitchen windows, whilst having a percentage reduction ranging from 21% at the east and 46% at the west end, actually have a limited VSC shift loss, equating to a VSC loss of 2.1 at the east and 4.6 at the west end, which can be considered as quite limited losses in real terms.

7.5.33 In summary, daylight reduction to these properties meets target criteria with the exception to the recessed 2nd floor kitchen windows facing the proposal in terms of daylight VSC. It is considered that a ‘without balconies / soffit’ analysis for these windows would more likely indicate that it is the inherent projecting soffit above the window resulting in the sensitivity, rather than an adverse proposal, especially based upon the limited VSC reductions to the windows immediately above on the 3rd floor.

Nos 1 & 1a Foxley Road

7.5.34 For these semi-detached properties, 6 out of 10 windows would have reductions greater than BRE Guide target criteria ranging 21% to 28% / ‘minor adverse’. However, in all instances the retained VSC value is not less than 23.6 which is considered a good VSC for an urban context.

7.5.35 In terms of daylight distribution, all reductions meet BRE Guide target criteria with the isolated exception of one ground floor room with a reduction still very close to BRE Guide target criteria at a 22 % reduction.

Nos 62-72 (evens) Camberwell New Road

7.5.36 The rear elevation of these terraced properties have windows serving rooms that are oblique to site. In terms of daylight VSC, all reductions meet BRE Guide default target criteria.

7.5.37 In terms of daylight distribution, all reductions meet BRE Guide target criteria with the isolated exception of one lower ground floor room (potentially bedroom) with a 31% reduction / ‘moderate adverse’ daylight distribution reduction (retained daylight distribution of circa 57%).

Page 113

7.5.38 In summary, consideration of the daylight analysis of the reductions to both VSC and / or NSL/ daylight distribution, the majority of reductions meet or are close to default BRE Guide target criteria and in those instances that reductions are beyond target criteria, then such reductions could be considered as more typically ‘minor adverse’ (plus a relatively smaller number of greater impacts / reductions of ‘moderate adverse’ / ‘major adverse’).

7.5.39 On balance, in consideration of the extent and adversity, retained values and rooms, uses affected (typically bedrooms which the BRE Guide recognises as daylight being less important), dual-aspect arrangement of many of these residential properties etc, it is considered that such impact to daylight should, overall be considered reasonable for an urban context / arrangement.

7.5.40 In relation to the review undertaken of the impact of the proposal on sunlight to neighbouring windows / rooms, a significant proportion of these properties are not applicable for sunlight review to windows since the windows are ‘north facing’ (not facing within 90 degrees of south); this is primarily applicable to the properties south of the site along Cranmer Road etc.

7.5.41 For the remaining properties that do have windows serving habitable rooms facing within 90 degrees of south, in consider of the analysis results for both Annual Probable Sunlight Hours (APSH) and winter sunlight, the reductions effectively all meet BRE Guide default criteria / there is no adverse impact and should be considered acceptable.

7.5.42 In relation to sunlight to neighbouring amenity / rear garden areas, it is noted that there is no submitted assessment of sunlight reduction to neighbouring amenity areas which primarily would relate to rear garden areas for assessment. However, similar to sunlight to windows, given that a significant proportion of these properties have gardens that are south of the proposal along Cranmer Road etc, there would be a limited number of properties for consideration.

7.5.43 For those properties for initial consideration, the rear gardens are to the rear of the neighbouring property in question thus not facing site and for this massing, there could only be limited affect as the actual neighbouring property / immediate surrounding properties would be driving the availability of sunlight / associated shadowing to the amenity area. The only properties which do have gardens facing / open to the proposal relate primarily to the rear gardens of Nos 62 – 66 (evens) Camberwell New Road; however, in consideration of the orientation of site to these particular gardens (site is south-west / west of these gardens), any applicable increased shadowing would not be for the morning and restricted for part afternoon / early evening sunlight, resulting from proposed Block C. Even though some increased shadowing is anticipated to the rear garden to these particular properties, given the availability of sunlight in the earlier part of the day (which could not be affected by the proposal), it is anticipated that these gardens would still readily meet the 2-hour BRE Guide amenity test (at the 21st March equinox standard review).

7.5.44 For the majority of neighbouring amenity areas there would be either no or extremely limited affect. For the isolated closest amenity areas with context for potential reductions, it is anticipated that for such reductions, these would still readily meet the 2-hour BRE Guide amenity test (at the 21st March equinox standard review).

7.5.45 In summary, it is considered that the proposed development would have a limited effect on the daylight and sunlight amenity received to neighbouring properties. The majority of living areas tested will comply with BRE guidelines and where they are exceeded, the majority of these windows would retain levels of daylight that are consistent for the local area and an inner urban location.

Outlook, privacy and overlooking

7.5.46 Policy Q2 of the LLP and DRLLP requires development to provide adequate outlooks avoiding where possible any undue sense of enclosure or unacceptable levels of overlooking (or perceived overlooking).

7.5.47 The application site already comprises commercial buildings with windows facing outwards from the

Page 114

site towards the neighbouring residential uses on Cranmer Road, Foxley Road and Camberwell New Road. No additional windows are proposed on the Cranmer Road, Foxley Road and Camberwell New Road elevations and the building line will be no closer in proximity to the existing surrounding residential properties when compared with the existing situation.

7.5.48 The distance between the proposed building on Foxley Road and the façade of the nearest residential properties would be circa 21metres and the distance between the proposed buildings and the façades of the properties along Cranmer Road would be circa 17 metres, with Cranmer Road running between the buildings.

7.5.49 The proposal is also appropriately designed and positioned to ensure no undue overlooking or loss of privacy to the nearest residential properties on Cranmer Road, Foxley Road and Camberwell New Road. Given the separation distances proposed and positioning of the proposed windows, communal and terrace areas, the proposed development would not result in any undue overlooking or loss of privacy to neighbouring residential occupiers. As such. the proposal would be contrary to Policy Q2 of the LLP and DRLLP.

Noise and vibration

7.5.50 Policy D14 of the London Plan seeks to reduce, manage and mitigate noise. This is reiterated in Policy Q2 of the LLP and DRLLP.

7.5.51 A Noise Assessment report, prepared by Max Fordham LLP, has been submitted with the application which details the environmental noise issues at the site and makes appropriate recommendations regarding noise impacts from building services and light industrial activity. Using the background noise level taken within the long-term environmental noise survey, the noise emissions from the plant equipment required will be 5dB below the representative background level when measured outside the window of the nearest noise sensitive premises. The report concludes that is it unlikely that noise from plant or activity on the site would have an adverse impact to the surrounding neighbouring amenity.

7.5.52 No objection has been raised by the Council’s Environmental Health Section to the proposal. Conditions are proposed in relation to noise and vibration attenuation to ensure the appropriate mitigation and control measures proposed in the Noise Assessment report are implemented. Subject to these conditions, the proposal would not have any undue impact on neighbouring residential occupiers in accordance with Policy D14 of the London Plan and Policy Q2 of the LLP and DRLLP.

7.6 Designing Out Crime

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

7.6.2 For a development of this nature, the main considerations would relate to counter terrorism, access to the building and the areas of public realm around the building. No objection has been raised by the Designing out Crime Officer to the proposed development which would incorporate principles of Secured by Design. Conditions securing Secured by Design accreditation would be attached to any permission granted.

7.7 Ecology, trees and landscaping

7.7.1 Policies EN1 and Q9 of the LLP and DRLLP promote opportunities for greening, as well as protection and enhancement of existing biodiversity, and support the use of landscaping to provide strong boundary treatments, together with access routes and parking areas compliant with safety standards and minimum parking standards.

7.7.2 A Preliminary Ecological Appraisal, including a Phase 1 Habitat Survey of the site, produced by Ashgrove Ecology, has been provided with the application. This confirms that the site is not covered

Page 115

by any statutory or non-statutory nature conservation designations. The appraisal finds that it is unlikely that the site would be used by anything other than a low number of birds and foraging bats and the proposed new areas of soft landscaping could provide opportunities for bird and bats. The impacts of the scheme on ecology are therefore predicted to be negligible and non-significant.

7.7.3 The appraisal makes a number of recommendations for the proposed scheme. Biodiverse roofs are proposed on all new buildings where this is possible. A rain garden is proposed within the centre of the site and within the landscaped pathway along Camberwell New Road. As well as providing areas for wildlife to drink, the rain gardens provide a sustainable way of conserving water, filtering pollutants from runoff and create a habitat for further wildlife.

7.7.4 The appraisal recommends the installation of two nest boxes suitable for black redstarts under the eaves of the new buildings and the suggestion of four bat boxes. The Landscaping Strategy proposes bird/bat/bug habitats across the site and boxes on the walls and under the eaves of the new buildings, including the provision of two nest boxes suitable for Black Redstarts, as suggested within the appraisal.

7.7.5 The Council’s Parks and Open Spaces Section support the proposals and the areas of 'green roof' on the roofs for Block A and Block B are welcomed as these will contribute significantly to the biodiversity value of the site and address any potential adverse ecological impacts from any proposed building demolition/disturbance. They strongly advocate for these roofs to be biodiverse 'living green roofs', designed with a high ecological value. This is especially important given the potential for local use by protected species like black redstart and foraging bats, as such a green roof type will provide appropriate nesting and foraging opportunity. Further details on the proposed green roofs, including a planting and maintenance plan, would be secured by condition in any permission granted.

7.7.6 A full landscaping strategy has been prepared by Spacehub, which details the proposed landscaping, lighting strategy and ecology strategy for the development. The existing site is dominated by car parking and as a result comprises predominantly hard standing, with very little amenity or green spaces. The scheme has been designed to significantly improve the environment and amenity across the site, in order to create a more welcoming, usable and biodiverse place of work.

7.7.7 ‘Canterbury Yard’ is the primary pedestrian entrance to the site and currently comprises predominantly hardstanding. The landscaping strategy proposes two lawns and movable seating to provide amenity space immediately outside the entrance to Canterbury Court. The current ramp down to the car park is step and uneven, a new more gradually sloping ramp is proposed with terraced planting and seats built into steps alongside this, improving the accessibility of the site and areas to relax in.

7.7.8 The frontage of Canterbury Court alongside Camberwell new Road is a dark and narrow space used for a number of car parking spaces. The landscaping strategy seeks to make this space usable by proposing glass ‘pod’ meeting rooms within a walled garden, comprising woodland, movable furniture and a raingarden. Between Buildings A and B is a ‘Central Yard’ comprising seating, wheelchair accessible car parking spaces, a rain garden and amenity spaces with games/play elements. Towards the east of the site, the scheme, as shown in Figure 7 below, proposes a ‘rubble garden’ and games yard, both of which are flexible spaces which can be used for outdoor games such as boules and ping pong, with outdoor seating. This space can be used by users of the ancillary facilities within Building C, for occupants of workspace and to host events.

7.7.9 Policy Q10 of the LLP and DRLLP seek to protect existing trees and will not permit development that would result in the loss of trees of significant amenity, historic and conservation value or give rise to the wellbeing of such trees.

7.7.10 An Arboricultural Impact Assessment has been prepared by Tamla Trees in support of the application. The site is not located within a conservation area and there are no Tree Protection Orders on site. In order to develop the site, 32 trees are required to be removed, these trees are internal to the site and are mostly car park trees. These trees are considered to be low quality and of minimal wider amenity value given their size and location and are classed as Category C and Category U trees within the AIA

Page 116

which are lower quality and trees which are in such a condition that they would be lost within 10 years.

Figure 7 – Proposed Landscape Masterplan

7.7.11 The proposal also requires the crown reduction to four street trees, located on Cranmer Road, in order to facilitate the redevelopment of these buildings. 128 trees are proposed to be planted, resulting in a net gain of 96 trees. The species of trees to be planted have been informed by the Ecology Appraisal and include the planting of native shrubs to further attract wildlife. The proposal therefore provides a significant net gain in trees, amenity value of the site and biodiversity value to the site.

7.7.12 The Council’s Parks and Open Spaces Section welcome the landscaping proposals, including ground level planting of trees, shrubs and planters, and the installation of bat and bird boxes are recommended in the planning statement, ecological appraisal and as indicated on submitted plans. Conditions securing the hard and soft landscape planting and installation of bat and bird boxes would be attached to any permission granted to ensure the quality and suitability of such enhancements is secured.

7.7.13 In accordance with Policies EN1 and Q9 of the LLP and DRLLP, the scheme has maximised the opportunities for greening, providing improved boundary treatment, a significant increase in planting and amenity areas, enhancing the appearance of the site.

7.8 Transport

7.8.1 Policies T1, T3 T4 of the London Plan seeks to ensure that the impacts of development in transport capacity and the transport network are fully assessed. Policies T3, T6, T7 and T8 of the LLP and Policies T3, T7 and T8 of the DRLLP seek to ensure that proposals for development will have a limited impact on the performance and safety of the highway network and that sufficient and appropriate car parking and cycle storage is provided whilst meeting objectives to encourage sustainable transport and to reduce dependence on the private car. If development will have an unacceptable transport impact, it should be refused in the absence of mitigation measures to make the development acceptable.

Page 117

Site context

7.8.2 The site is bound by Brixton Road to the west, Camberwell New Road to the north, Foxley Road to the east and Cranmer Road to the south. Brixton Road and Camberwell New Road are part of the Transport for London Road Network (TLRN), for which TfL is the Highway Authority.

7.8.3 The site is well placed for public transport, being within a 3–5-minute walking distance of seven bus routes and a 6-minute walking distance of the Oval London Underground station. As a result, the site has an excellent Public Transport Access Level (PTAL) of 6a, on a scale from 0 to 6b where 6b is the highest.

7.8.4 The site is also well connected to the cycle network with Cycle Superhighway 7 running along Clapham Road, east of the site. In addition, two new cycleways are proposed nearby; Cycle Future Route 14 on Camberwell New Road and Cycle Future Route 15 on Brixton Road.

Access

7.8.5 At present, the site is accessible to pedestrians, cyclists and vehicles via a number of access points from Brixton Road, Camberwell New Road, and Cranmer Road.

7.8.6 The proposal seeks to reorganise the internal courtyard to prioritise pedestrians and cyclists over the private vehicle with the removal of all general car parking and this element of the proposal is very much welcomed. The proposal also recognises the need to accommodate all servicing off-street (i.e., within the red line boundary) and as such to position loading locations in logical and clearly apparent areas which is supported. The proposal has been designed to reduce car dominance within the public realm, minimise pedestrian and cyclist conflict with their comfort prioritised and offering a more attractive, accessible area for employees, visitors and local residents.

7.8.7 Brixton Road is located along the Site’s western frontage and provides the main access point into the Site. There are three access points to the Site from Brixton Road; two of which form vehicular crossovers. The northern vehicular access is limited to pedestrians, cyclists and emergency vehicles whilst the southern vehicular access allows egress only via an automated gate. A gated pedestrian access is in between, provided offering the main access into the Site for those travelling to/from Oval Station.

7.8.8 Camberwell New Road is located along the Site’s northern frontage and operates westbound to Brixton Road / Harleyford Street junction and eastbound to Camberwell. Opposite the Site there is a gated access to Kennington Park. A single vehicular crossover into the Site is provided from Camberwell New Road, located within the Site’s north-eastern corner. A second vehicular access point into the Site from Camberwell New Road is located to the north-west of the Site, however this is currently unused.

7.8.9 Cranmer Road bounds the Site to the South. Cranmer Road accommodates 4 vehicular crossovers associated with the Site. The most easterly access provides entry / exit solely into a warehouse building and its forecourt. Two vehicular crossovers provide entry / exit into the Site’s car park area, and finally there is a crossover for the sub-station, located central to the Site’s frontage on Cranmer Road.

7.8.10 Finally, Foxley Road bounds the Site to the east. One vehicle access is provided to Foxley Road into the Site, this is currently operating as exit only for the taxi service building.

7.8.11 Pedestrians are well provided for in the vicinity of the development site with footways along both sides of all roads. Pedestrian specific way-finding signage is present and offers directions to local public transport services and sites of interest.

7.8.12 The nearest controlled crossing point is located on the Site frontage to Brixton Road. This crossing is two-stage with dropped kerbs, tactile paving and rotating cones for visually impaired pedestrians,

Page 118

offering a route to Oval Station.

Sustainable travel and cycle parking

7.8.13 Based on the uplift in floorspace proposed, the Transport Assessment provided predicts the development will generate an uplift of 80 and 76 bus trips in the AM and PM peak hours respectively. According to TfL and the GLA in their Stage 1 response, several bus routes are already at capacity in the vicinity of the site. As such, a contribution of £450k (£90k pa x 5 years) has been requested towards bus services. This would be secured by s106 in any planning permission granted.

7.8.14 A total of 414 cycling parking spaces, including 358 long and 56 short-stay cycle parking spaces, are proposed which accords with standards of the London plan (2021). The long stay cycle stores would be located within or close to each new building and would be secure and covered. The short stay cycle spaces would be located within the landscaped areas around the buildings and comprise easily accessible Sheffield stands. Changing and shower facilities would also be provided within each new building. The Cycle parking is required to be designed and laid out in accordance with the guidance contained in Chapter 8 of the London Cycling Design Standards (LCDS). This would be secured by condition.

7.8.15 The nearest cycle hire docking station is on Cranmer Road, located on the south west corner of the site. Given the car-free nature of the proposed development and TfL’s objectives to increase sustainable and active travel, it is considered that the cycle hire docking station on Cranmer Road will need to be expanded. TfL have requested that a contribution of £50k towards the expansion of the existing docking station is secured through the s106 agreement, along with 3 years of free cycle hire membership for employees of the business units being secured.

Trip Generation and Impacts

7.8.16 A robust multi-modal trip generation exercise has been provided within the Transport Assessment submitted which concludes that the proposal will result in an increase in trip generation when compared to the existing use of the site, including increases in bus, rail and active mode trips which reflects the increase commercial floorspace. A further shift towards sustainable modes of transport will be promoted through the implementation of dedicated Travel Plans.

7.8.17 However, it is also acknowledged that there were 125 private cars/vehicles parked on-site on the day of the parking survey and that this application will see the removal of all casual (i.e., employee) car parking spaces, which will be further controlled by a Business Car Parking Permit Free agreement secured by s106 legal agreement.

7.8.18 The overall upgrade to the public realm and removal of general parking is expected to result in a mode shift for the entire site and therefore, the overall 24,672sqm of employment space has been assessed. It can be concluded that the vast majority of additional trips resulting from the proposed development will be by public transport. The net change in car driver trips is forecast to reduce significantly with circa 495 less vehicle trips (not accounting for the 39 arrival and 39 departure increase in servicing vehicle movements). Net increases in cycle trips of circa 16 two-way movements are forecast for the AM peak hour, 30 in the PM peak hour, with a corresponding 272 additional daily cycle movements.

7.8.19 To summarise, the trip generation assessment indicates that the uplift in commercial floorspace as part of the development will result in 324 additional trips during the AM peak and 341 additional trips during the PM peak with the vast majority making use of the site’s excellent accessibility to public transport. This is counteracted by a significant reduction in vehicle trips following the removal of the car park (excluding 12 disabled spaces, 9 loading areas and a car club bay). As a result, those working and visiting the site will no longer be able to travel by car (other than those with a blue badge) and will instead be required to adopt more sustainable modes.

7.8.20 The trip generation exercise predicts 491 fewer vehicle trips and 84 fewer motorcycle trips per day travelling to and from the site. The proposal would therefore result in a significant reduction in

Page 119

vehicular traffic that will be removed from the surrounding streets and strategic network which is welcomed and is seen as a major benefit of the scheme from a transport and highways perspective and aligns with LLP and London Plan objectives.

Pedestrian Environment Review System (PERS)

7.8.21 A Pedestrian Environment Review System (PERS) audit has been submitted which studies a large area from an accident/collision history perspective, and whilst this is welcomed, it presents challenges with respect to identifying themes/clusters. The study assessed a five-year period, working back from September 2018. With respect to the most vulnerable road users. Reflecting this large collision study area, it is noted that a total of 1,536 accidents were recorded with 268 involving pedestrians and 547 involving cyclists.

7.8.22 The majority of accidents involving vulnerable road users took place across large junctions, generally at crossings, or just outside crossings, and in cycle lanes. The causes of recorded incidents are predominantly linked to pedestrians, cyclists and vehicle users not looking properly, or obeying traffic signals or traffic regulations according to the audit. Having reviewed the locations referenced in the recorded collision study, the Council’s Transport Section are unable to identify anything that might be linked to an obstructed sightline, for example, something which would be potentially directly linked to recorded collisions/incidents.

7.8.23 The ‘Active Travel Audit’ and ‘PERS Audit’ undertaken indicate that walking and cycling links in the vicinity of the site are good to excellent with wide and well-lit footways, pedestrian crossings and cycle lanes present in the vicinity of the site. Furthermore, there are a range of local amenities within a short distance of the site, ensuring a range of day-to-day facilities can be easily reached by either walking or cycling. This is helpful as regards the identification of (potential) mitigation and incorporated a detailed analysis of the ‘local’ roads in line with the PERS Assessment criteria, this is in order to identify and improve specific issues local to the site, benefitting both the local community and users of the Site.

7.8.24 The assessment area considered the primary walking routes from the application site to local public transport services and amenities including Oval Station, Vauxhall Station and bus services along Brixton Road, Clapham Road, Camberwell New Road and Kennington Park Road. The scope of the survey was agreed with the council prior to it being undertaken. Due to the convenient location of Oval Station, it is likely most public transport users will utilise this station. However, Vauxhall Station is located within the 20-minute Active Travel Zone and provides step-free access from the street to the train for the Victoria line and rail links, provides step-free access from street to train; and has therefore, been included within the PERS audit area.

7.8.25 The findings of the PERS Audit found all crossings to be at a ‘good’ level (green), other than the crossing from Foxley Road to Cranmer Road (C3), which was rated ‘poor’ (red). The average score for crossings was 50 (43%), with only C3 scoring (significantly) below this. The Cranmer Road / Foxley Road crossing has limitations relating to legibility for sensory impaired people, dropped kerbs and maintenance. Deficiencies in public footways were also identified.

7.8.26 The development itself, which proposes to improve remove all general car parking, will significantly increase cycle parking and enhance the pedestrian environment on site by landscaping the courtyard would contribute to an improved environment for pedestrians. A number of redundant crossovers will be removed as well as improvements to the footways in the immediate vicinity of the site as part of the proposal. This will include all existing footway crossovers to be stopped up; all areas of adjacent /local footway improved; and other pedestrian improvements, to be secured/delivered on the back of the PERS/Healthy Streets Audit.

7.8.27 It is considered appropriate that the applicant enter into a s278 Agreement with the council to undertake the necessary highway work / footway improvements along Cranmer Road and Foxley Road identified. This would be secure by s106 legal agreement in any permission granted.

Page 120

Car Parking

7.8.28 The proposed development is car-free with the exception of 6 disabled parking spaces, having been reduced down from 12. This quantum is now considered acceptable and should facilitate improvements to the quality and layout of the public realm within the scheme. Disabled persons’ parking should also include infrastructure for electric or other Ultra-Low Emission Vehicles. A Car Park Management Plan would need to be secured by condition. The applicant will be required to enter into a section 278 Agreement under the Highways Act 1980, for the works on TfL’s highway associated with the scheme.

Car Clubs

7.8.29 There are several existing car club vehicles in the vicinity of the Site; the closest 3 vehicles are operated by Zipcar and are located within an 800m walk from the Site.

7.8.30 The applicant has engaged car club operators and is willing to fund the provision of a car club vehicle (most likely a van) within the site that can be used by employees at the site, along with providing access to the wider general public. The provision of a car club will support the car parking strategy, which seeks to reduce the need for car ownership through car parking restraint, and thus limit the traffic and associated air quality effects of the scheme. An “outline/framework Car Club agreement” (with free corporate car club membership for all on site businesses - for a minimum of three years) would be secured by s106 legal agreement.

Servicing, including Refuse and Recycling

7.8.31 A draft Delivery and Servicing Plan (DSP) has been provided which identifies that all servicing will be undertaken off-street within the car park area which is welcomed. Currently, there are no dedicated servicing bays with vehicles stopping informally within car parking spaces. The proposal will provide dedicated bays for deliveries and servicing suitably located throughout the site. This will increase the safety and efficiency of servicing vehicles.

7.8.32 The proposal is for a shared space approach, which will assist in reducing driver speed and increasing driver awareness of pedestrians whilst the proposed one-way arrangement will reduce mean that need for reversing within the site (which can occur at present) is negated. The delivery arrangement seeks to improve the safety and efficiency of servicing and deliveries within the site and as per the existing situation, all servicing (including deliveries and refuse collection) will be undertaken within the site i.e., not on the public highway. This approach is welcomed. The majority of delivery vehicles will make use of a one-way servicing route going from the eastern crossover to the western crossover on Cranmer Road. Any other delivery vehicles will enter and egress the site on Brixton Road, or enter on Cranmer Road and egress on Camberwell New Road in forward gear. It is welcomed that a ‘Goods-In Manager’ will be appointed to ensure that vehicles load and unload in line with the proposed delivery arrangements. Consolidation of freight should be considered to reduce the number of vehicular trips generated by delivery and servicing and a final Delivery and Service Plan would be secured by condition in any permission granted.

7.8.33 No objection has been raised by Veolia Waste to the proposal and the intended refuse store arrangements, with three refuse collection points, marked (a), (b) and (c), being provided on site are considered to be acceptable. The Council has published and adopted a guide on the design of refuse and recycling storage and the final waste and recycling arrangement should comply with the council’s “Waste & Recycling Storage & Collection Requirements – Technical Specification for Architects & Developers” (October 2013) supported by Policy Q12 of the LLP and DRLLP. Conditions relating to final waste and recycling storage and a Waste Management Strategy would be secured by condition in any permission granted.

Page 121

Healthy Streets

7.8.34 The Healthy Streets Approach seeks to inform design, management and use of public spaces in order to place people and people’s health at the forefront of development decisions. The following assessment is based on the document ‘Guide to the Healthy Streets Indicators – Delivering the Healthy Streets Approach, November 2017’.

7.8.35 The approach is set out within the Mayor’s Transport Strategy (2018) and puts human health and experience at the centre of planning. The aims of the strategy are to encourage all Londoners to do at least 20 minutes of active travel each day by 2041. To this end, TfL have defined 20-minute walking and cycling distances as an Active Travel Zone (ATZ).

7.8.36 Pedestrians are well provided for near to the site with footways along both sides of all roads. Pedestrian specific way-finding signage is present and offers directions to local public transport services and sites of interest. The nearest controlled crossing point (Pelican crossing) is located on the Site frontage to Brixton Road. This crossing is two-stage with dropped kerbs, tactile paving and rotating cones for visually impaired pedestrians, offering a route to Oval Station.

7.8.37 The proposed re-development will see an increase in pedestrian and cycle trips to/ from the site and the local area. Whilst the redevelopment includes the removal of 189 existing car parking spaces on site and the provision of improved public realm and cycle parking, no improvements are proposed beyond the site. TfL are currently developing two Road Safety schemes within close proximity of the site and would seek a contribution towards these schemes. A contribution of £15,000 towards developing a road safety scheme at the junction between Camberwell New Road and Foxley Road to improve cycling and pedestrian safety has been requested by TfL and GLA in their Stage 1 response. Such a contribution would be secured by s106 legal agreement.

Construction

7.8.38 Policy T8 of the LLP and DRLLP requires planning applications to be accompanied by a construction and logistics plan, demonstrating arrangements for construction traffic and how environmental, traffic and amenity impacts would be minimised.

7.8.39 An outline Construction Management and Logistics Plan (CMLP) has been provided which outlines that vehicles associated with the construction will enter the site via the western crossover on Cranmer Road and either exit through the eastern crossover on Cranmer Road or Camberwell New Road in forward gear. A delivery management system will be used to schedule deliveries and that an early doors agreement will be put in place to have construction vehicles arrive on site before morning peak hours which is welcomed. However, the CMLP should also include measures on how construction vehicles will avoid afternoon peak hours between 16:00 and 18:30.

7.8.40 Final Delivery and Servicing Management Plan and Construction and Environmental Management Plan would be secured by way of conditions and both should focus on pedestrian and cycle safety and the free movement of all road users along the four key adjoining roads - throughout future associated construction works – and minimising impacts on air quality, for example by requiring use of FORS silver-registered haulage contractors, using HGVs with 2-star or greater Direct Vision Standard (DVS) and maximising deliveries by bike and electric vehicles. To mitigate the impacts of numerous construction works in the area, the applicant should seek to co-ordinate works with other sites by consolidating deliveries, where possible.

Travel Plan

7.8.41 A draft Employee Travel Plan (TP) has been submitted with the application, which sets out targets for increasing cycling and walking to and from the site. The measures included within the TP should be appropriate to deliver the Mayor’s strategic mode shift target. A final Travel Plan would be secured by condition and subsequent monitoring by s106 legal agreement in any planning permission granted.

Page 122

Mitigation

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

• Construction, Environmental Management Plan; • Delivery and Service Management Plan; • Travel Plan and monitoring • Car Park Management plan; • Enter into s278 agreement for highways works and improvements within the vicinity of the site; • Travel plan and monitoring fee of £5,000; • Parking permit free development for employees; • Securing of blue badge car parking spaces; • Healthy Route Network contribution of £15,000 towards developing a road safety scheme at the junction between Camberwell New Road and Foxley Road to improve cycling and pedestrian safety; • Bus Capacity Enhancements contribution of £450,000 (£90,000 per annum for up to five years); • Cycle Hire docking station contribution of £50,000 to expand the existing station on Cranmer Road; • 3yrs free cycle hire membership for employees of the business units; • Provision of 1 Car club bay on-street within the vicinity of the site (£10,000);

7.8.43 No objection has been raised by the Council’s Transport and Highways Sections to the proposals. Subject to the above mitigation measures, the proposals would be in accordance with Policies T1, T2, T3, T4, T5 and T6 of the London Plan and Policies T3, T6, T7 and T8 of the LLP and Policies T3, T7 and T8 of the DRLLP.

7.9 Sustainable design and construction

7.9.1 Policy SI 2 of the London Plan states that development proposals should be net zero-carbon. Policy EN3 of the LLP and DRLLP further require development to utilise decentralized heating, cooling or power networks in the vicinity of the site, or future proof for planned energy networks.

7.9.2 Policy SI2 of the London Plan introduces a requirement to calculate the whole life-cycle emissions of the development through a nationally recognised Whole Life-Cycle Carbon Assessment. Whole Life- Cycle carbon assessment includes not only the regulated emissions considered under current energy assessments but also the following:

• Unregulated emissions, i.e., those associated with cooking and small appliances • Embodied emissions, i.e., those associated with raw material extraction, • manufacture and transport of building materials and construction • Emissions associated with maintenance, repair and replacement as well as dismantling, demolition and eventual material disposal

7.9.3 The Mayor intends to publish guidance on the approach to whole life-cycle carbon emissions assessments, including when they should take place, what they should contain and how information should be reported. The application pre-dated this policy requirement so a whole life-cycle assessment has not been undertaken and the GLA has not requested this in this case.

7.9.4 At the time of submission of the application (November 2019), the application was not required to be supported by a Circular Economy Statement or a Life Cycle Carbon Analysis, which is only now a requirement under the recently adopted New London Plan. As stated within the Whole Lifecycle Carbon Assessment Draft Guidance (October 2020), these reports are required at pre-application stage, as the proposal was designed and submitted a year prior to this guidance, these reports were not required to accompany the pre-application discussions or the application submission. These reports were also not required by the GLA at Stage one and the GLA have now confirmed acceptability of the energy strategy.

Page 123

7.9.5 However, the application was supported by a sustainability statement which details how sustainability has been a key part of the design of the scheme. As part of the Sustainability Statement and BREEAM pre-assessment, a Circular Economy Strategy and Life Cycle Assessment were undertaken in order to meet the relevant BREEAM credits. Page 11 of the attached details how the scheme was designed to reduce the embodied carbon of the design, implementing the best performing superstructure and substructures and landscaping materials. This has resulted in the scheme achieving an ‘Excellent’ BREAAM rating (77.5%).

7.9.6 In accordance with Policy SI2 of the London Plan, the applicant has submitted an Energy Statement which is compliant with the London Plan and Energy Assessment Guidance (2018) energy Hierarchy. Based on the Energy Strategy, the proposal would achieve a 37% site wide reduction in CO2 emissions compared to Building Regulations Part L on the non-domestic element. This would be achieved through the use of renewable energy technology in the form of Water Source Heat Pumps and photovoltaic panels alongside a range of energy efficiency and demand reduction measures. This overall strategy is supported by both the Council and GLA.

7.9.7 Whilst the site is not within an area currently served by a District Heat Network (DHN), the scheme should be designed to facilitate connection of the buildings to a future DHN. The remaining shortfall in reductions in CO2 emissions on the residential element should be secured via a carbon offset payment to be secured by s106 legal agreement.

7.9.8 The sustainability statement shows a 25% reduction in water consumption will be achieved over baseline water consumption. This exceeds the London Plan requirement of 12.5%. Details of the proposed capacities and flowrates have been provided. This would be secured by condition in any permission granted.

7.10 Other Environmental Matters

Flood risk and drainage

7.10.1 Policies SI.12 and SI.13 of the London Plan and Policy EN5 of the LLP and DRLLP expect development in Flood Zones 2, 3a and 3b to contribute positively to reducing the flood risk. In accordance with Policy EN5, a Flood Risk Assessment (FRA) and Sustainable Urban Drainage Strategy (SUDS), prepared by GTA, accompanies the application.

7.10.2 The north-east of the site is in tidal Flood Zone 3 but benefits from existing flood defences and is considered by the Environment Agency to have an extremely low residual risk. The FRA concludes that the proposed office buildings do not change the existing vulnerability classification which remains Less Vulnerable, and no further mitigation is necessary.

7.10.3 The drainage strategy for the site preserves the existing site catchments and outfalls to the public sewer, attenuation storage will be provided in the form of underground tanks, permeable paving and surface ponding in extreme events. The FRA and SUDS states that a betterment of 67% has been achieved compared to the existing scenario.

7.11 The FRA provided complies with Policy SI.12 of the London Plan and Policy EN5 of the LLP and DRLLP. In their Stage 1 response, the GLA advised that the proposed development did not fully comply with Policy SI.13 of the London Plan, as it did not give appropriate regard to the drainage hierarchy and greenfield runoff rate. Further details on how Suds measures at the top of the drainage hierarchy will be included in the development and an updated greenfield runoff calculation have now been provided and will be considered further by the GLA at the Stage 2 stage.

7.12 The development generally meets the requirements of London Plan. The GLA, in their Stage 1 response, also requested that the applicant consider water harvesting and reuse to reduce consumption of wholesome water across the entire development site. This information has now been provided and can be integrated with the surface water drainage system to provide a dual benefit.

Page 124

7.13 Overall, taking into account the site circumstances and constraint and subject to the further information provided being agreed by the GLA, the proposal would comply with the drainage hierarchy and would be in accordance with London Plan, LLP and DRLLP policies.

Air quality

7.14 The site falls within an Air Quality Management Area in relation to a breach of nitrogen dioxide and particulate matters objectives as specified in the Air Quality Regulations 2000. Policy SI 1 of the London Plan and Policy T1 of the LLP and DRLLP require development to support measures that reduce levels of local air pollution and improve air quality.

7.15 An Air Quality Assessment, prepared by Waterman, has been submitted with the application which provides an assessment of the air quality impacts associated with the proposal. The scheme is predicted to have a net reduction in car traffic flows on the highway due to the removal of all general car parking across the site. The effect of operational traffic is predicted to be not significant on local air quality at relevant receptors. The development is considered to include measures which will benefit local air quality, including the cycle parking provision, limiting car access and car parking.

7.16 The Air Quality Assessment states that based on the detailed dispersion modelling the effect of the development will have no significant effects at all existing sensitive receptors considered. The main likely effects on air quality during construction relates to dust however a range of mitigation measures would be implemented to reduce the effects from dust emission to be not significant.

7.17 During the construction works, a range of best practice mitigation measures would be implemented to reduce dust emissions and the overall effect would be ‘not significant’; appropriate measures have been set out in the report and these would be included in the final Air Quality and Dust Management Plan for the works that would be secured by condition.

7.18 Overall, the construction and operational air quality effects of the proposal are judged to be ‘not significant’. The proposal has also been shown to meet the London Plan’s requirement that new developments are at least ‘air quality neutral’.

7.19 No objection has been raised by the Council’s Sustainability Section to the proposals. A condition would therefore be attached to any permission granted requiring the implementation of appropriate mitigation measures to ensure the proposal is air quality neutral. The residual effects of the proposed development are considered to be negligible for NO2 and particulate matter and the overall effect of the proposed development on local air quality is not considered to be significant.

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

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

Ground conditions and contamination

7.22 Whilst the LLP and DRLLP do not contain specific policies on land contamination, the supporting text to Policy EN4 notes that a remediation strategy should be submitted prior to commencement of development in instances where contamination exists. No objection has been raised by either the Council’s Building Control or Environmental Health Section to the proposal.

7.23 A Land Contamination Assessment, prepared by Furnis Group, has been undertaken for the site to

Page 125

inform the proposal. The Assessment finds that there are potential sources of contamination on site. It is recommended by the assessment that a Phase II Intrusive investigation should be undertaken and that a pre-demolition and refurbishment asbestos survey will be required. This was would be secured by condition in any permission granted.

Archaeology

7.24 Part of the site, the frontage to Brixton Road, is located within an Archaeological Priority Area. Policy Q23 of the LLP and DRLLP require the investigation and recording of archaeological remains and publication of results to assist understanding. In accordance with the priorities of this policy, the application is supported by an Archaeological Assessment, prepared by MOLA. The report concludes that there is uncertain but probably low potential for remains of prehistoric, Roman, medieval or early post-medieval date on this site.

7.25 Subject to a pre-commencement condition requiring the submission and approval of a written scheme of investigation being attached to any permission granted, the proposal is considered to be in accordance with Policy Q23 of the LLP and DRLLP.

Employment and training

7.26 The completed development is estimated to support an additional 344-1351 jobs (calculated using the HCA Employment Density Guide).

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

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

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

7.29 Subject to this agreement, the development would be compliant with Policy E11 of the London Plan and Policy ED4 of the LLP and DRLLP.

Planning obligations and CIL

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

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

Page 126

7.32 The proposed obligations to be secured through the s106 agreement have now all been confirmed with the applicant and are as follows:

• Employment and training contribution (tbc); • Employment and skills plan; • Enter into s278 agreement for highways works and improvements within the vicinity of the site; • Travel plan and monitoring fee of £5,000; • Parking permit free development for employees; • Securing of blue badge car parking spaces; • Healthy Route Network contribution of £15,000 towards developing a road safety scheme at the junction between Camberwell New Road and Foxley Road to improve cycling and pedestrian safety; • Bus Capacity Enhancements contribution of £450,000 (£90,000 per annum for up to five years); • Cycle Hire docking station contribution of £50,000 to expand the existing station on Cranmer Road including free membership for business employees for 3 years; • Final Energy statement for future energy network connection, and identify value of any carbon off- setting contribution (estimated currently to be £484,500); • 3yrs free cycle hire membership for employees of the business units; • Provision of 1 Car club bay on-street within the vicinity of the site (£10,000); and • Administration and implementation fee (tbc)

7.33 If the application is approved and the development is implemented, a liability to pay the Mayoral and Lambeth Community Infrastructure Levies (CIL) will arise. On the basis of the information supplied with the applications, the Mayoral CIL is estimated to be £972,780. The Lambeth CIL contribution is estimated to be nil. Expenditure of the majority of a future CIL receipt will be applied towards Borough infrastructure needs in accordance with the applicable policies and procedures relating to expenditure decisions.

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

8 CONCLUSION

8.1 The proposed development would provide new high-quality business/workspace buildings, providing a significant uplift and enhancement in employment floorspace on the site. The uplift is anticipated to provide an additional 344-1351 new jobs for the borough (calculated using the HCA Employment Density Guide).

8.2 The proposal would complement the existing flexible business use of the Kennington Park Business Centre and would fully reprovide the existing industrial floorspace on the site. The employment use proposed would permit a range of office, research and development and light industrial uses and provides flexible workspace suitable for occupation by a range of business sizes, which is welcomed. The design and layout of the proposal has been specifically tailored to be suitable for micro, small and medium sized creative enterprises engaged in light industrial manufacturing and design activities.

8.3 The group of buildings proposed are of an appropriate scale and height and have been carefully considered in terms of their architectural language. Overall, the design and appearance of proposed blocks are considered to be acceptable and will contribute positively to the streetscene and local context. The proposal would cause no harm to strategic, local views or heritage assets and would preserve and enhance the appearance of the character of the St Marks and Vassall Conservation Areas.

8.4 Given the distance and orientation to the nearest residential properties, and the inclusion of appropriate mitigation measures, the proposal would not result in any significant material impact in terms of overlooking, loss of privacy or sunlight/daylight or undue noise and disturbance to neighbouring residential properties.

Page 127

8.5 The development would have a sustainable construction, meeting all of the relevant sustainability standards. It has been designed to significantly improve the environment and amenity across the site, in order to create a more welcoming, usable and biodiverse place of work, and would provide significant ecological, landscape and pedestrian/cycle enhancements.

8.6 As such, the proposal is considered to be acceptable when judged against national, London wide and local plan policy and guidance and all relevant material considerations and is recommended for approval.

9 PROCEDURAL MATTERS

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

10 EQUALITY DUTY AND HUMAN RIGHTS

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

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

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

11 RECOMMENDATION

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

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

2.1 Finalise the recommended conditions as set out in this report, addendums and/or PAC minutes; and 2.2 Negotiate, agree and finalise the planning obligations as set out in this report, addendums and/or PAC minutes pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended).

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

Page 128

order to meet the requirement of the Planning Inspector.

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

Page 129

APPENDICES

Appendix 1: List of Conditions and Informatives

Standard Conditions

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

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

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

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

Pre-commencement Conditions

Drainage scheme 3. No development shall commence on site until the detailed design for the surface water drainage system and associated pipework referred to in the Flood Risk Assessment and Sustainable Urban Drainage Strategy, prepared by GTA, has been submitted to and approved in writing by the local planning authority. The approved for the surface water drainage scheme shall be carried out in accordance with the approved details before the development is first put into use/occupied and thereafter maintained for the lifetime of the development.

Reason: To ensure the development is provided with a satisfactory means of drainage and in the interests of securing a more sustainable development and to reduce the impact of flooding both to and from the development and third parties in accordance with Policy SI 13 of the London Plan (2021) and Policy EN6 of the Lambeth Local Plan (September 2015).

Contamination 4. Notwithstanding demolition and site clearance on site, no development shall take place until the following components of a scheme to deal with the risks associated with contamination of the site have been submitted to and approved in writing by the local planning authority:

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

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

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

Page 130

Basement Construction Method statement 5. Notwithstanding demolition and site clearance on site, no development shall commence until full details of the proposed basement construction methodology, in the form of a Construction Method Statement, is submitted to and approved in writing by the local planning authority. The Construction Method Statement shall be written by a suitably qualified person and shall include details of:

a) The basement excavation methods of demolition and construction; b) Measures to prevent mud and debris on the public highway; c) Details of the phasing of construction; d) Details of other measures including movement monitoring and reporting for nearby premises or structures that may be affected by the excavation and e) Measures to ensure ground stability and avoid adverse impacts on nearby premises or structures

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

Reason: Development must not commence before this condition is discharged to avoid hazard and obstruction being caused to users of the public highway and to ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally and avoid hazard and obstruction to the public highway. (Policies T1, T6, T7, Q2 of the Lambeth Local Plan (2015)).

Piling Method Statement 6. No impact piling or other penetrative foundation work shall take place until a Piling Method Statement has been submitted to and approved in writing by the Local Planning Authority. The Piling Method Statement shall include details of: a) The depth and type of piling to be undertaken; b) The methodology by which such piling will be carried out; c) Measures to prevent and minimise the potential for damage to subsurface water infrastructure; d) Measures to ensure there is no resultant unacceptable risk to groundwater as a result of the work; and e) The programme for the works.

Any piling or other penetrative works must be undertaken in accordance with the terms of the approved Piling Method Statement, unless the written consent of the Local Planning Authority is received for any variation.

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

Construction and Environmental Management Plan 7. No development shall commence until a Construction and Environmental Management Plan (CEMP), including the method of demolition, has been submitted to and approved in writing by the local planning authority.

The CEMP shall include details of the following relevant measures:

(i) An introduction consisting of construction phase environmental management plan, definitions and abbreviations and project description and location; (ii) A description of management responsibilities. (iii) A description of the construction programme which identifies activities likely to cause high levels of noise or dust; (iv) Site working hours and a named person for residents to contact; (v) Detailed Site construction logistics arrangements;

Page 131

(vi) Details regarding parking, deliveries, and storage; (vii) Details of an air quality and dust management plan; (viii) Details regarding dust and noise mitigation measures to be deployed including identification of sensitive receptors and ongoing monitoring; (ix) Details of the hours of works and other measures to mitigate the impact of construction on the amenity of the area and safety of the highway network; (x) Measures to prevent the deposit of mud and debris on the public highway; and (xi) Communication procedures with the LBL and local community regarding key construction issues.

The development shall thereafter be carried out in accordance with the details and measures approved in the CEMP for the duration of the construction period, unless the written consent of the local planning authority is received for any variation.

Reason: This is required prior to demolition and construction to avoid hazard and obstruction being caused to users of the public highway and to safeguard residential amenity during the whole of the construction period (Policies T6 and Q2 of the Lambeth Local Plan (2015)).

Air Quality and Dust Management Plan 8. No demolition or development shall commence until full details of the proposed mitigation measures for impact on air quality and dust emissions, in the form of an Air Quality and Dust Management Plan (AQDMP), have been submitted to and approved in writing by the local planning authority. In preparing the AQMDP the applicant should follow the guidance on mitigation measures for medium Risk sites set out in Appendix 7 of the Control of Dust and Emissions during Construction and Demolition SPG 2014 for demolition, earthworks and construction and high risk for track out. Both ‘highly recommended’ and ‘desirable’ measures should be included. The AQDMP shall include the following for each relevant phase of work (demolition, earthworks, construction and track out):

a) A summary of work to be carried out; b) Proposed haul routes, location of site equipment including supply of water for damping down, source of water, drainage and enclosed areas to prevent contaminated water leaving the site; c) Inventory and timetable of all dust and NOx air pollutant generating activities; d) List of all dust and emission control methods to be employed and how they relate to the Air Quality (Dust) Risk Assessment; e) Details of any fuel stored on-site; f) Details of a trained and responsible person on-site for air quality (with knowledge of pollution monitoring and control methods, and vehicle emissions); g) Summary of monitoring protocols and agreed procedure of notification to the local authority; and h) A log book for action taken in response to incidents or dust-causing episodes and the mitigation measure taken to remedy any harm caused, and measures employed to prevent a similar incident reoccurring.

Automatic continuous PM10 monitoring should be carried out on site. Baseline monitoring should commence at least three months before the commencement of the demolition phase and continue throughout all construction phases. Monitors should be used at locations in use by sensitive receptors and construction traffic for the duration of the development. Details of the equipment to be used and its exact positioning should be submitted to the Council as part of the Air Quality Dust Management Plan and approved prior to use. Data should be available for download by the local authority on request. An annual summary report of continuous monitoring data should be provided to the council for the duration of the development.

No demolition or development shall commence until all necessary pre-commencement measures described in the AQDMP have been put in place and set out on site. The demolition and development shall thereafter be carried out and monitored in accordance with the details and measures approved in the AQDMP.

Page 132

Reason: Development must not commence before this condition is discharged to manage and mitigate the impact of the development on the air quality and dust emissions in the area and London as a whole, and to avoid irreversible and unacceptable damage to the environment (Policy SI 1 of the London Plan (2021) and the London Plan SPGs for Sustainable Design and Construction and Control of Dust and Emissions during Construction and Demolition).

Air Quality Neutral Assessment 8. No development shall commence until a full Air Quality Neutral Assessment in accordance with the GLA Sustainable Design and Construction Supplementary Planning Guidance has been undertaken and submitted to and approved in writing by the local planning authority. Where Air Quality Neutral benchmarks cannot be met a scheme of mitigation must be submitted which includes on site mitigation that is part of the proposed development and may also include off-site offsetting. The details as approved shall be implemented prior to occupation of the development and thereafter be permanently retained.

Reasons: To minimise increased exposure to existing poor air quality and make provision to address local problems of air quality (particularly within AQMAs) (Policy SI 1 of the London Plan 2021).

Internal water use 9. Prior to the commencement of the development, details shall be submitted to and approved in writing by the Local Planning Authority to demonstrate that the internal water consumption will achieve the 12.5% improvement over the baseline performance standard, achieving the BREEAM Excellent standard for the Wat 01 category and to demonstrate that the development has incorporated measures such as smart metering, water saving and recycling measures, including retrofitting, to help to achieve lower water consumption rates and to maximise future-proofing through the provision of post- construction BREEAM evidence used to sign off credits Wat 02 and Wat 03.

Reason: To ensure the development would achieve an acceptable standard of water efficiency (Policy SI 1 of the London Plan (2021)).

NRMM Low Emission Zone 10. No demolition or development shall commence until all non-road mobile machinery (NRMM) to be used on site has been registered at ‘https://nrmm.london/user-nrmm/register’ and that all registered NRMM is compliant with the NRMM Low Emission Zone requirements.

Reason: To ensure that air quality is not adversely affected by the development Reason: To ensure that air quality is not adversely affected by the development in line with Policy SI 1 of the London Plan (2021) and the Mayor’s SPG: The Control of Dust and Emissions during Construction and Demolition.

Method of demolition and construction statement 11. No demolition or construction shall commence until full details of the proposed demolition and construction methodology, in the form of a Method of Demolition and Construction Statement, has been submitted to and approved in writing by the Local Planning Authority. The Method of Demolition and Construction Statement shall include details of:

a) The notification of neighbours with regard to specific works; b) Advance notification of road closures; c) Details regarding parking, deliveries, and storage; d) Details regarding dust mitigation; e) Details of measures to prevent the deposit of mud and debris on the public highway; f) Details of a temporary lighting strategy, including details of temporary lighting of all public areas and buildings showing acceptable positioning and levels of glare; g) Details of the hours of works and other measures to mitigate the impact of demolition and construction

Page 133

on the amenity of the area. The hours of deliveries associated with demolition and construction activity should work around the core school hours at nearby schools; h) Any measures to mitigate the impact of demolition and construction upon the function and safety of the surrounding area for cyclists; and i) Any other measures to mitigate the impact of demolition and construction upon the amenity of the area and the function and safety of the highway network.

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

Reason: This is required prior to demolition and construction to avoid hazard and obstruction being caused to users of the public highway and to safeguard residential amenity during the whole of the demolition and construction period. (Policies T6 and Q2 of the Lambeth Local Plan 2015).

Flues and extraction plant 12. The uses hereby permitted shall not commence until details and full specifications of flues extraction and filtration equipment, and ongoing maintenance plan (including elevational drawings) have been submitted to and approved in writing by the local planning authority. The use hereby permitted shall not commence until the approved details are fully implemented. The approved flues, extraction and filtration equipment shall thereafter be retained and maintained in working order for the duration of the use in accordance with the approved details. Reason: To protect the amenities of adjoining occupiers and the surrounding area (Policy Q2 of the London Borough of Lambeth Local Plan (2015)).

Land contamination and drainage maintenance

Land Contamination 13. Prior to the occupation of any part of the development, a verification report demonstrating completion of the works set out in the approved remediation strategy and the effectiveness of the remediation shall be submitted to and approved in writing by the local planning authority.

The report shall include results of sampling and monitoring carried out in accordance with the approved verification plan to demonstrate that the site remediation criteria have been met. It shall also include any plan (a “long-term monitoring and maintenance plan”) for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action, as identified in the verification plan, and for the reporting of this to the local planning authority.

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

Reasons: Development must not commence before relevant parts of this condition are discharged to safeguard future users or occupiers of this site and the wider environment from irreversible risks associated with the contaminants which are present by ensuring that the contaminated land is properly treated and made safe before development. (Policies 5.21 of the London Plan (2015) and EN4 of the Lambeth Local Plan (2015)).

Drainage, Infrastructure, Management and Maintenance 14. No part of the development shall be brought into use/occupied until a Drainage Infrastructure Management and Maintenance Plan including the foul and surface water management system and associated pipework has been submitted to and approved in writing by the local planning authority.

Page 134

The plan must consider the management and maintenance for the lifetime of the development which shall include the arrangements made to secure the operation of the scheme. The approved plan shall be implemented in full in accordance with the agreed terms and conditions and thereafter retained as such for the lifetime of the development.

All provisions for drainage must be undertaken in accordance with the details approved, unless the written consent of the local planning authority is received for any variation.

Reason: To ensure the development is provided with a satisfactory means of drainage and in the interests of securing a more sustainable development and to reduce the impact of flooding both to and from the development and third parties in accordance with Policy SI 13 of the London Plan (2021) and Policy EN6 of the Lambeth Local Plan (2015) and to ensure there are clear arrangements in place for ongoing maintenance over the lifetime of the development (Government ministerial statement HCWS161).

Design Details

External Materials 15. Prior to the commencement of building works above ground of the development hereby permitted, the following details of the external elevations of the building shall be submitted to and approved in writing by the local planning authority:

a) A technical specification schedule of the materials; and b) Sample panels to be made available on site (or another convenient local location), at a scale of 1:1, for inspection showing ‘typical’ façade construction and illustrating the materials and their construction detailing.

The development shall be carried out in accordance with the approved details and thereafter retained as such for the lifetime of the development.

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

Fine Detailing 16. Notwithstanding the details shown on the drawings hereby approved, no development shall take place until drawings (at 1:10 scale [including sections] showing all external construction detailing), for the relevant part of the development have been submitted to and approved by the Local Planning Authority in writing, unless otherwise agreed in writing by the Local Planning Authority. The drawings shall include details of:

a) Detailed elevations b) Details of windows (including technical details, elevations, reveal depths, plans and cross sections) c) Details of terraces, balustrades and privacy screens d) Details of entrances and external doors (including technical details, elevations, reveal depths, plans and sections) e) Details of roof treatments, cills and parapets f) Details of rainwater goods and pipes (including location and fixings) g) Details and location of flues and vents h) Details of works to Chichester House i) Details of wayfinding and signage

The development shall be carried out in accordance with the approved details and retained for the lifetime of the development.

Page 135

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

Re-instatement of Sandstone plaques 17. Prior to the commencement of building works above ground of the development hereby permitted, details of the of the reinstatement of the original sandstone plaques on Worcester House shall be submitted to and approved in writing by the local planning authority:

The development shall be carried out in accordance with the approved details and retained for the lifetime of the development.

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

Plumbing 18. No vents, plumbing or pipes, other than those approved, shall be fixed to the external faces of the building.

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

Amenity

Noise and Vibration attenuation of ventilation plant 18. Prior to the occupation of the uses hereby permitted, or the operation of any building services plant, an assessment of the acoustic impact arising from the operation of all internally and externally located plant shall be submitted to and approved in writing by the local planning authority.

The assessment of the acoustic impact shall be undertaken in accordance with BS 4142: 2014 (or subsequent superseding equivalent) and current best practice and shall include a scheme of attenuation measures to ensure the rating level of noise emitted from the proposed building services plant is 10dB less than background.

The uses hereby permitted, or the operation of any building services plant, shall not commence until a post-installation noise assessment has been carried out to confirm compliance with the noise criteria. The scheme of attenuation shall be implemented in accordance with the approved details and attenuation measures, and they shall be permanently retained and maintained in working order for the duration of the use and their operation.

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

Site Maintenance and Management

Fire Statement 20. Prior to the commencement of above ground works, a Fire Statement shall be submitted to and approved in writing by the local planning authority. The Fire Statement shall be produced by a suitably competent and qualified person which shall detail the building’s construction, methods, products and materials used; the means of escape for all building users including those who are disabled or require level access together with the associated management plan; access for fire service personnel and equipment; ongoing maintenance and monitoring and how provision will be made within the site to enable fire appliances to gain access to the building. The development shall be carried out in

Page 136

accordance with the approved details, and to the satisfaction of current Building Regulations and the measures and means shall thereafter be retained for the lifetime of the building hereby approved.

Reason: In order to provide a safe and secure development in accordance with Policy D12 of the London Plan (2021).

Operating hours. 21. Customers are not permitted in the retail, restaurant and café and community and leisure uses hereby permitted other than within the following times:

- 08:00 Hours to 23:00 Hours – Monday through to Thursday. - 08:00 Hours to 00:00 Hours – Fridays and Saturdays. - 10:00 Hours to 23:00 hours – Sundays, Bank or Public holidays.

Reason: To ensure that no nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers or of the area generally.

Maintenance of flues and extraction plant 22. The restaurant/café uses hereby permitted shall not commence until details of an ongoing maintenance plan for the fume extraction and filtration equipment have been submitted to and approved in writing by the local planning authority. The approved fume extraction and filtration equipment shall thereafter be retained and maintained in working order for the duration of the use in accordance with the approved details.

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

Customer Management Plan 23. The restaurant/café uses hereby permitted shall not commence until a Customer Management Plan has been submitted to and approved in writing for each use by the local planning authority. This should include but not be limited to, hours of operation, management responsibilities during all operating hours, measures to control noise from live and amplified music (including the screening of sporting events and public address systems) and minimising the effects of patrons coming and going from site and demonstrating how customers leaving the building will be prevented from causing nuisance for people in the area. The uses hereby permitted shall thereafter be operated in accordance with the approved details for the lifetime of the development.

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

Waste and recycling storage 24. Prior to the occupation of the uses hereby permitted, details of waste and recycling storage (including detail on ventilation of refuse stores) for the development shall be submitted to and approved in writing by the local planning authority. The waste and recycling storage shall be provided in accordance with the approved details prior to the commencement of any of the uses hereby permitted and shall thereafter be retained solely for its designated use. The waste and recycling storage areas/facilities should comply with the Lambeth's Refuse & Recycling Storage Design Guide (2013), unless it is demonstrated in the submissions that such provision is inappropriate for this specific development.

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

Page 137

Waste Management Strategy 25. Prior to the occupation of the uses hereby permitted, a Waste Management Strategy shall be submitted to and approved in writing by the local planning authority. The development hereby permitted shall be built in accordance with the approved details and shall thereafter be retained solely for its designated use. The uses hereby permitted shall thereafter be operated in accordance with the approved Waste Management Strategy.

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

Provide Disabled parking spaces 26. Prior to the commencement of the use hereby permitted, the parking spaces shall be laid out in accordance with the approved plans, and the disabled/accessible parking spaces shall be retained for the duration of the use. No vehicles, other than blue-badge holder vehicles and operational vehicles for the users of the site, shall park on the site. Vehicles shall only park within the designated spaces shown on the approved plans, and on no other part of the site.

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

Cycle Storage 27. Prior to the occupation of the development hereby permitted, details of the provision to be made for 414 cycle parking spaces on the site shall be submitted to and approved in writing by the Local Planning Authority. The cycle parking shall thereafter be implemented in full in accordance with the approved details before the uses hereby permitted commence and shall thereafter be retained solely for its designated use for the lifetime of the development.

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

Delivery and Servicing Management Plan 28. The uses hereby permitted shall not commence until a Delivery and Servicing Management Plan, including details of freight consolidation and confirming that all servicing will be undertaken off-street within the service yard, has been submitted and approved in writing by the local planning authority. The use hereby permitted shall thereafter be operated in accordance with the approved details for the lifetime of the development. The submitted details must include the following:

a) Frequency and timings of deliveries to the site; b) Frequency and timings of other servicing vehicles, such as refuse collections; c) Dimensions of delivery and servicing vehicles; d) Proposed loading and delivery locations; and e) A strategy to manage vehicles servicing the site.

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

Car Parking Management Plan 29. Prior to the occupation of the development hereby approved, a Car Park Management Plan shall be submitted to and approved in writing by the local planning authority. The Plan submitted shall include details of car parking allocation for residential and commercial occupants. The development shall be carried out in accordance with the approved details.

Page 138

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

Landscaping scheme 30. Prior to the occupation of any part of the development hereby permitted, a soft and hard landscaping scheme and ecological enhancement strategy shall be submitted to and approved in writing by the local planning authority. The specifications shall include details of the quantity, size, species, position and the proposed time of planting of all elements of the landscape design (together with details of their anticipated routine maintenance and protection) to demonstrate that the Urban Greening Factor of 0.3 has been achieved.

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

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

Green roofs 31. Prior to the occupation of any part of the development hereby permitted, a detailed specification of the green roofs shall be submitted to and approved in writing by the local planning authority. The specification shall include details of the quantity, size, species, position and the proposed time of planting of all elements of the green roof, together with details of their anticipated routine maintenance and protection. The green roofs shall only be installed and thereafter maintained in accordance with the approved details for the lifetime of the development.

Reason: In order to introduce high quality soft landscaping in and around the site in the interests of the ecological value of the site and to ensure a satisfactory landscaping of the site in the interests of visual amenity (Policies EN4 and Q9 of the Lambeth Local Plan (2015) and Policy G1 of the London Plan (2021).

Landscaping Scheme and Ecological Enhancements Strategy implementation 32. Within six months of first occupation of any part of the development, evidence to demonstrate that the net biodiversity gains (secured under the Ecological Enhancements details approved as part of the discharge of Condition 30) have been achieved shall be submitted to and approved in writing by the local planning authority. In the event that these gains have not been achieved, a scheme of mitigation to achieve the shortfall shall be submitted to and approved in writing by the local planning authority. The approved scheme shall be implemented within the first planting season following the scheme being approved and shall thereafter be retained for the lifetime of the development.

Reason: In the interests of the ecological value of the site and to ensure a satisfactory landscaping of the site in the interests of visual amenity (Policies EN4 and Q9 of the Lambeth Local Plan (2015) and Policy G1 of the London Plan (2021).

Landscaping Timescales 33. All planting, seeding or turfing comprised in the approved details of soft landscaping shall be carried out in the first planting and seeding season following the occupation of the development hereby permitted. Any trees, hedgerows or shrubs forming part of the approved landscaping scheme which within a period of five years from the occupation or substantial completion of the relevant phase die, are removed or become seriously damaged or diseased shall be replaced in the next planting season

Page 139

with others of similar size and species, unless the local planning authority gives written consent to any variation.

Reason: In order to introduce high quality soft landscaping in and around the site in the interests of the ecological value of the site and to ensure a satisfactory landscaping of the site in the interests of visual amenity (Policies EN4 and Q9 of the Lambeth Local Plan (2015) and Policy G1 of the London Plan (2021).

Lighting Scheme 34. Prior to occupation a lighting scheme must be submitted for the approval of the Local Planning Authority in accordance with the Institute of Lighting Professional’s Guidance notes for the reduction of obstructive light. The scheme must be designed by a suitably qualified person in accordance with the recommendations for environmental zone E3 in the ILP document “Guidance Notes for the Reduction of Obtrusive Light GN01:2011.

Before commencement of operation of the approved lighting scheme the applicant shall appoint a suitably qualified member of the institute of lighting professionals (ILP) to validate that the lighting scheme as installed conforms to the recommendations for environmental zone E3 in the ILP document “Guidance Notes for the Reduction of Obtrusive Light GN01:2011.

The development should be implemented in accordance with the approved details and retained and properly maintained thereafter for the lifetime of the development.

Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and to ensure the external appearance of the building is satisfactory and does not detract from the setting of the nearby conservation areas (Policies Q2, Q6, Q7, Q8 and Q22 of the Lambeth Local Plan (2015)).

Sustainability and Energy

BREEAM – Post Construction Certificate 35. Within six months of first occupation of any part of the development, a BREEAM Post Construction certificate and summary score sheet should be submitted to and approved in writing by the Local Planning Authority demonstrating that a rating of ‘Excellent’ has been achieved for the development. The summary score sheets for the assessment should demonstrate that the actions proposed to reduce waste during construction and water during operation are undertaken in line with the approved Sustainability Statement.

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

Photovoltaic panels 36. Prior to above ground construction works commencing, plans, elevations and sections of the roof(s) showing the location of the proposed photovoltaic array(s) should be submitted for approval to the Local Planning Authority. The photovoltaic array(s) shall be implemented in accordance with the approved details and retained and properly maintained permanently thereafter.

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

Operational impacts 38. Prior to installation, the proposed energy centre should meet the emission standards set out in the GLA’s Sustainable Design and Construction Supplementary Planning Guidance 2014 (or any superseding requirements). Full details of the final proposed CHP plant and gas boiler system should

Page 140

be submitted to the Council for approval. Details of the proposed CHP should be provided using Combined Heat and Power System information request form.

Reason: To ensure that air quality is not adversely affected by the development in line with Policy SI 3 of the London Plan and the Mayor’s SPG: Sustainable Design and Construction

Travel Plan 39. Prior to the uses hereby approved commencing, a Travel Plan relating to those uses shall be submitted to and approved in writing by the local planning authority. The measures approved in the Travel Plan to be implemented before occupation shall so be implemented prior to the use commencing and shall be so maintained for the duration of the use, unless the prior written approval of the Local Planning Authority is obtained to any variation.

Reason: To ensure that the travel arrangements to the site are appropriate and to limit the effects of the increase in travel movements (Policy T4 of the London Plan (2021) and Policies T1 and T6 of the Lambeth Local Plan (2015)).

Secure by Design Measures 40. The development hereby permitted shall incorporate security measures to minimise the risk of crime and to meet the specific Security needs of the development in accordance with the principles and objectives of Secured by Design. Details of these measures shall be submitted to and approved in writing by the local planning authority prior to commencement of the development and shall be implemented in accordance with the approved details prior to occupation.

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

Secure by Design Certification 41. Prior to occupation, a satisfactory Secured by Design inspection must take place. The resulting Secured by Design certificate shall be submitted to and approved by the local planning authority.

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

Employment and Commercial floorspace 42. No less than 5,408sqm sqm of Class E (g) (iii) and B8 light industrial / workspace floorspace shall be provided within the development. Prior to the occupation of the Class B1 use hereby permitted, full details of the internal layout of this floorspace, including which units will be provided for Class E (g) (iii) and B8 use, shall be submitted to and approved in writing by the local planning authority.

The development shall be carried out in accordance with the approved details.

Reason: to ensure an appropriate level of light industrial floorspace is re-provided on the site in accordance with Policy ED7 of the London Plan (2021).

Informatives

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

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

Page 141

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

4. The property numbers of all ground floor units with external doors hereby approved shall be clearly and permanently displayed at their entrance.

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

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

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

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

- name a new street - name a new or existing building - apply new street numbers to a new or existing building

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

9. For information on the NRMM Low Emission Zone requirements please visit ‘http://nrmm.london/nrmm’

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

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

11. The latest Sustainable Design and Construction SPG can be found on the GLA’s website https://www.london.gov.uk/what-we-do/planning/implementing-london-plan/supplementary-planning- guidance. The Combined Heat and Power System information request from can be found in the air quality resource section of Lambeth Air Quality webpage www.lambeth.gov.uk/AirQuality

Page 142

Appendix 2: List of Consultees (Statutory and Other Consultees)

Statutory

Environment Agency Greater London Authority Historic England - Archaeology London Ecology Unit London Fire Brigade London Transport Buses Thames Water Transport for London

Internal/Consultants

Blew Burton Design Out Crime Officer LBL Arboricultural Officer LBL Building Control LBL Conservation & Urban Design LBL EHST Noise Pollution LBL Enterprise, Employment and Skills LBL Flooding LBL Highways Team LBL Parks & Open Spaces LBL Planning Policy LBL Public Protection & Regulatory Services LBL Regeneration Team LBL Sustainability Team LBL Transport Veolia Waste Ward Councillors

Other

Kennington Oval and Vauxhall Forum Kennington Association Planning Forum London Borough of Southwark Met Office & Licensing Minet Conservation Association Park Residents Association Vassall And Coldharbour Forum

Page 143

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

London Plan (2021) policies:

• GG1 Building strong and inclusive communities • GG2 Making the best use of land • GG3 Creating a healthy city • GG6 Increasing efficiency and resilience • D1 London’s form, character and capacity for growth • D2 Infrastructure requirements for sustainable densities • D3 Optimising site capacity through the design-led approach • D4 Delivering good design • D5 Inclusive design • D8 Public realm • D11 Safety, security and resilience to emergency • D12 Fire safety • D14 Noise • E3 Affordable workspace • E4 Land for industry, logistics and services to support London’s economic function • E6 Locally Significant Industrial Sites • E7 Industrial intensification, co-location and substitution • E11 Skills and employment for all • HC1 Heritage conservation and growth • HC3 Strategic and Local Views • HC4 London View Management Framework • HC5 Supporting London’s culture and creative industries • G1 Green infrastructure • G5 Urban greening • G6 Biodiversity and access to nature • G7 Trees and woodlands • SI 1 Improving air quality • SI 2 Minimising greenhouse gas emissions • SI 3 Energy infrastructure • SI 4 Managing heat risk • SI 5 Water infrastructure • SI 6 Digital connectivity infrastructure • SI 7 Reducing waste and supporting the circular economy • SI 8 Waste capacity and net waste self-sufficiency • SI 12 Flood risk management • SI 13 Sustainable drainage • T1 Strategic approach to transport • T2 Healthy Streets • T3 Transport capacity, connectivity and safeguarding • T4 Assessing and mitigating transport impacts • T5 Cycling • T6 Car parking • T6.5 Non-residential disabled persons parking • T7 Deliveries, servicing and construction • T9 Funding transport infrastructure through planning • DF1 Delivery of the Plan and Planning Obligations

Page 144

Regional Guidance

• Social Infrastructure (May 2015) • Accessible London: Achieving an Inclusive Environment (October 2014) • The control of dust and emissions during construction and demolition (July 2014) • Character and Context (June 2014) • Sustainable Design and Construction (April 2014) • Use of planning obligations in the funding of Crossrail, and the Mayoral Community Infrastructure Levy SPG (2013) • London View Management Framework (March 2012) • London Cycle Design Guide (2014)

Lambeth Local Plan (2015) policies

• D1 Delivery and monitoring • D2 Presumption in favour of sustainable development • D3 Infrastructure • D4 Planning obligations • ED1 Key Industrial and Business Areas (KIBAs) • ED2 Economic Development, Retail and Town Centre Uses • ED3 Large Offices (greater than 1,000m2) • ED7 Evening economy and food and drink uses • ED14 Employment and training • EN1 Open space and biodiversity • EN3 Decentralised energy • EN4 Sustainable design and construction • EN5 Flood risk • EN6 Sustainable drainage systems and water management • EN7 Sustainable waste management • Q1 Inclusive environments • Q2 Amenity • Q3 Community safety • Q5 Local distinctiveness • Q6 Urban design: public realm • Q7 Urban design: new development • Q8 Design quality: construction detailing • Q9 Landscaping • Q10 Trees • Q12 Refuse/recycling storage • Q13 Cycle storage • Q15 Boundary treatments • Q18 Historic environment strategy • Q20 Statutory listed buildings • Q21 Registered parks and gardens • Q22 Conservation areas • Q23 Undesignated heritage assets: local heritage list • Q25 Views • Q27 Basement development • PN8 Kennington/Oval • S1 safeguarding existing social infrastructure • T1 Sustainable travel • T2 Walking • T3 Cycling

Page 145

• T4 Public transport infrastructure • T6 Assessing impacts of development on transport capacity • T7 Parking • T8 Servicing • T10 Digital connectivity infrastructure

Draft Revised Lambeth Local Plan Proposed Submission Version (January 2020)

• D1 Delivery and monitoring ▪ D2 Presumption in favour of sustainable development ▪ D3 Infrastructure ▪ D4 Planning obligations • ED1 Offices (B1a) ▪ ED2 Affordable workspace ▪ ED3 Key Industrial and Business Areas (KIBAs) ▪ ED8 Evening economy and food and drink uses ▪ ED15 Employment and training • EN1 Open space and biodiversity • EN3 Decentralised energy • EN4 Sustainable design and construction • EN5 Flood risk • EN6 Sustainable drainage systems and water management • EN7 Sustainable waste management • Q1 Inclusive environments • Q2 Amenity • Q3 Safety, crime prevention and counter terrorism • Q5 Local distinctiveness • Q6 Urban design: public realm • Q7 Urban design: new development • Q8 Design quality: construction detailing • Q9 Landscaping • Q10 Trees • Q12 Refuse/recycling storage • Q13 Cycle storage • Q15 Boundary treatments • Q18 Historic environment strategy • Q20 Statutory listed buildings • Q21 Registered parks and gardens • Q22 Conservation areas • Q23 Non-designated heritage assets: local heritage list • Q25 Views • Q27 Basement development • PN8 Kennington/Oval • S1 safeguarding existing social infrastructure ▪ T1 Sustainable travel ▪ T2 Walking ▪ T3 Cycling ▪ T4 Public transport infrastructure ▪ T7 Parking ▪ T8 Servicing ▪ T10 Digital connectivity infrastructure

Page 146

Local Guidance / Supplementary Planning Documents (SPD):

• Employment and Skills SPD • Parking Survey Guidance Notes • Refuse & Recycling Storage Design Guide • Waste Storage and Collection Requirements - Technical Specification • Air Quality Planning Guidance Notes

Appendix 4 - List of drawing numbers and supporting documents

Existing Drawings

Document Rev Title BB20201 P01 Block B Existing Elevations BB20100-B P01 Block B Existing Ground Floor Plan Part B BB20100-A P01 Block B Existing Ground Floor Plan Part A BA20202 P01 Block A Existing Elevations Sheet 2 BA20201 P01 Block A Existing Elevations Sheet 1 BA20101-B P01 Block A Existing First Floor Plan Part B BA20101-A P01 Block A Existing First Floor Plan Part A BA20100-B P01 Block A Existing Ground Floor Plan Part B BA20100-A P01 Block A Existing Ground Floor Plan Part A B91301 P01 Existing Site Sections B91201 P01 Existing Site Elevations B91100 P01 Existing Site Plan

Proposed Drawings

Document Rev Title TCH20100 P2 Chester House, Proposed Demolitions , and External Works TC20301 P2 Block C , Proposed Sections TC20201 P3 Block C , Proposed Elevations TC20104 P3 Block C, Proposed Fourth Floor Plan TC20103 P3 Block C, Proposed Third Floor Plan TC20102 P3 Block C, Proposed First Floor Plan TC20101 P3 Block C, Proposed First Floor Plan TC20100 P3 Block C, Proposed Ground Floor Plan TC20099 P3 Block C, Proposed Basement Floor Plan TB20301 P2 Block B, Proposed Sections: B1, B2, B3 & B4 TB20201 P2 Block B, Preposed Elevations: North, East, South and West TB20105 P2 Block B, Proposed Roof Plan TB20104 P2 Block B, Proposed Fourth Floor Plan TB20103 P2 Block B, Proposed Third Floor Plan TB20102 P2 Block B, Proposed Second Floor Plan TB20101 P2 Block B, Proposed First Floor Plan TB20100 P2 Block B, Proposed Ground Floor Plan TB20099 P2 Block B, Proposed Ground Floor Plan TA20302 P2 Block A , Proposed Sections A3 & A4 TA20301 P2 Block A , Proposed Sections A1 & A2 TA20202 P2 Block A , Proposed North & East Elevations TA20201 P2 Block A , Proposed South & West Elevations TA20105 P4 Block A , Proposed Roof Plan TA20104 P3 Block A , Proposed Fourth Floor Plan TA20103 P3 Block A , Proposed Third Floor Plan TA20102 P3 Block A , Proposed Second Floor Plan TA20101 P3 Block A , Proposed First Floor Plan TA20100 P4 Block A , Proposed Ground Floor Plan T92200 P3 Proposed External Cycle Stores Ground Floor Plan, Elevations & CGI View

Page 147

T91301 P2 Proposed Site Sections T91201 P2 Proposed Site Elevations T91105 P2 Proposed, Fifth Floor Site Plan T91104 P3 Proposed, Fourth Floor Site Plan T91103 P3 Proposed, Third Floor Site Plan T91102 P3 Proposed, Second Floor Site Plan T91101 P3 Proposed, First Floor Site Plan T91100 P4 Proposed, Ground Floor Site Plan T91099 P3 Proposed, Basement Site Plan

Supporting Documents

• Design & Access Statement prepared by Rolfe Judd Architecture • Air Quality Assessment prepared by Waterman • Arboricultural Impact Assessment prepared by Tamla Trees • Construction Management and Logistics Plan prepared by Caneparo Associates • Daylight and Sunlight Assessment prepared by Consil • Energy Assessment prepared by Max Fordham (this document was not updated, but Appendix E- the GLA Carbon emissions reporting spreadsheet was updated a number of times following Stage 1 comments (last updated 25th Feb 2021) • Flood Risk Assessment and SUDS prepared by GTA (including Lambeth SUDs Pro Forma) • Townscape and Heritage Statement prepared by Tavenors • Historic Environment Assessment prepared by MOLA • Land Contamination Assessment prepared by Furnis Group • Landscaping and Lighting Strategy (within Design and Access Statement) prepared by Space Hub (200812 Planning Response Document was submitted by Spacehub as a further document) • Noise Impact Assessment prepared by Max Fordham • Preliminary Ecological Appraisal prepared by Ashgrove Ecology • Servicing and Delivery Management Plan prepared by Caneparo Associates • Statement of Community Involvement prepared by MPC • Sustainability Statement prepared by Max Fordham • Transport Assessment prepared by Caneparo Associates • Travel Plan- prepared by Caneparo Associates • Ventilation and Extraction information prepared by Max Fordham. • Fire Strategy prepared by JGA (dated 31st January 2020). In addition: • Fire Strategy Block A R4 Issue 2 • Fire Strategy Block B R5 Issue 2 • Fire Strategy Block C R6 Issue 2 • Basement Impact Assessment prepared by Furness Partnership (dated Feb 2020) • Planning Statement prepared by Rolfe Judd Planning

This page is intentionally left blank PLANNING APPEAL DECISIONS RECEIVED BETWEEN 01/08/2020AND 31/08/2020

Council ref. Appeal type Address Proposal Decision Officer Decision date Appeal type recommendation decision

19/02814/FUL Refusal - Town 70 Strathbrook Road Erection of dormer windows to side and rear Delegated Refuse Permission 11.08.2020 Appeal Planning London roof-slopes with one rooflight to the side dormer, Decision Dismissed SW16 3AZ facing the front of the property.

The appeal relates to a two-storey dwelling located in the Streatham Lodge Estate Conservation Area. The appeal property is one of a pair of properties that have a notable symmetrical form created by their hipped roofs, prominent chimney stacks, front porches and consistent fenestration composition. The design features give the houses a pleasant appearance, which makes a positive contribution to the character and appearance of the Conservation Area (CA).

The Inspector stated that the proposed side dormer window, because of its excessive size which is evidenced by not being set down from the ridge of the main roof and its extension close to the boundary with the neighbouring property at 68 Strathbrook Road, would not appear subordinate to the host dwelling. It would appear bulky and would unbalance the symmetrical form of Nos 70 and 72. Furthermore, the proximity of the proposed side dormer window to No. 68 would significantly reduce the sky background of the chimneys between Nos 68 and 70 thereby diminishing the prominence of the chimneys within the roofscape to the detriment of the character and appearance of the CA.

The Inspector also decided against the size of the rear dormer, which covered nearly the full height of the main roof and was not set down from the ridge. These two elements rendered the extension bulky and out of scale and proportion with the main roof. Whilst acknowledging the appellant’s case that this dormer would not be visible from the public realm, the Page 149 Inspector opined that the lack of visibility from the public realm does not obviate the need to achieve good design.

The inspector noted that whilst some of the neighbouring roof alterations are bulky and have disrupted the balance of buildings, they should not be replicated or used as precedents due to the harm that would be caused to the character and appearance of the CA.

The inspector concluded that whereas the proposal would cause less than substantial harm to the character of the CA, the benefit of the extension affording the appellant more habitable accommodation does not outweigh the harmful impact of the extension on the character and appearance of the host dwelling and the CA and would not comply with LLP. The appeal was accordingly dismissed. Agenda Item 6 19/03555/FUL Refusal - Town 42 Streatham Erection of single storey ground floor rear Delegated Refuse Permission 25.08.2020 Appeal Planning Common North extension. (Flat 1) Decision Allowed London SW16 3HS

The Inspector considered the main issues of this appeal to be the effect of the proposal on the character and appearance of the area which is partly included in the Streatham Common Conservation Area.

The Inspector referenced the Council’s 2017 Appraisal of the CA in which the appeal site is located, noting its description as being “… an eclectic mix of historic housing lining the perimeter of an historic open space…it illustrated the piecemeal suburban development of Streatham as London expanded in the late 19th and early 20th centuries.” He considered the recent conversion of the property into flats and the appeal scheme to constitute a further chapter in the suburban piecemeal development of this part of Streatham.

1 PLANNING APPEAL DECISIONS RECEIVED BETWEEN 01/08/2020AND 31/08/2020

Council ref. Appeal type Address Proposal Decision Officer Decision date Appeal type recommendation decision

On this basis, the Inspector considered that by virtue of its single storey nature and location at the rear of the property, the proposal would have no effect on the low-rise form of and unaltered silhouette of the appeal site, which is recognised within the Conservation Area Appraisal, as the key contribution of the host building to the conservation area. The Inspector further concluded that the proposal would have negligible impact upon the amenity, habitat value or soft landscaped setting of the property within the conservation area. In respect of the impact of the extension on the host dwelling itself, the Inspector noted the presence of the existing infill conservatory, the size of the property in terms of its height and depth and the visibility of the rear of the property from the street.

In this context, Inspector concluded that the proposal would have no practical effect on, and so would preserve, the character or appearance of the Streatham Common Conservation Area and that the proposal would have an acceptable effect on the character of the building itself and on the street scene. Accordingly, the Inspector allowed the appeal.

19/04593/FUL Refusal - Town 45 Strathbrook Road Erection of a rear dormer roof extension and Delegated Refuse Permission 27.08.2020 Appeal Planning London installation of 3 front rooflights. Decision Dismissed

SW16 3AT Page 150

The appeal relates to a two-storey dwelling, forming part of a terrace that originally comprised six symmetrically arranged houses whose symmetry has been modified in several ways including replacement of windows and porches with contemporary rather than matching designs. The appeal site is located within the Streatham Lodge Estate Conservation Area. This part of the CA is a later period of development of the CA whose architectural features are simplified when compared to the architectural richness of the middle-class suburban housing that typifies most the area. The area has been subject to an Article 4 Direction, which restricts permitted development that are considered to have eroded the original character of the CA.

In reaching his decision on the appeal proposal, the Inspector had regard to the provisions of the Council’s 2015 Supplementary Planning Document – Building Alterations and Extensions, which has a presumption against the installation of rooflights on the front roofs of heritage assets or on roofs with gables, hips or turrets. In this case, whilst accepting the small size and symmetrical alignment of two of the three conservation grade rooflights proposed, the Inspector considered the third rooflight to be too large and located with little or no relationship to any other architectural feature on the appeal property. As such it failed to meet the relevant criterial of Policy Q11 of the LLP and the SPG.

In relation to rear roof extension, the Inspector considered its size and rectangular design and, height in relation to the existing ridgeline, to be out of scale and keeping with the original roof form. “There would be only be vestigial elements of the original roof remaining”, he stated. In the Inspector’s opinion, the appearance of the rear of the property would change from a two-storey house with a pitched roof to a three-storey house with a flat roof. The fenestration design within the extension, was also considered objectionable because it would not relate to the composition of the windows on the floors below, in terms of size or proportion.

Noting the differences between the approved roof extensions at Nos. 37 and 47 Strathbrook Road, the Inspector concluded that whilst “dismissal of this appeal may seem harsh in light of the somewhat similar extension which exists at number 37, which is a material consideration, but I agree with the Council that the proposal would do further harm to the character and appearance of the Conservation Area. The consistent facts of the more recent adoption of the Local Plan, the adoption of the Article 4 Direction, the preparation of a well-judged supplementary planning document and the example set by the dormer windows at number 47 compel me to dismiss the appeal.”

2 PLANNING APPEAL DECISIONS RECEIVED BETWEEN 01/08/2020AND 31/08/2020

Council ref. Appeal type Address Proposal Decision Officer Decision date Appeal type recommendation decision

Allowed Dismissed Mixed

Month total 1 2 0

Financial year to date 5 16 0

Page 151

3 This page is intentionally left blank PLANNING ENFORCEMENT APPEAL DECISIONS RECEIVED BETWEEN 01/08/2020 AND 31/08/2020

Council ref. Address Breach of planning control Notice type Decision date Appeal decision

18/00115/3CND 12 Cooper's Yard Without planning permission the intentional unauthorised Enforcement Notice 28.08.2020 Appeal Allowed London erection of a 2 storey brick building to the rear of the premises (OD) SE19 1TN (“the unauthorised 2 storey building”) used as a work-live unit comprising 1 bed accommodation on the 1st floor and office use on ground floor (‘the unauthorised work-live use’).

The appeal was made against the service of an enforcement notice regarding the unauthorised erection of a 2 storey live/work building. The notice was issued as the development had not been regularised via a planning application requiring an affordable housing and car-free assessment.

The appeal was made under ground (a) 'that planning permission should be granted', and ground (f) 'that steps required by the notice were excessive'.

The main issues for the ground (a) appeal are: i) whether the development is exempt from a contribution to affordable housing; and ii) whether the development should be car-free

On issue i) the appellant provided a small sites affordable housing assessment and the Inspector agreed that the development was justified as being exempt from a requirement to make a contribution as this would render the development unviable. Therefore the development complies with local plan Policy H2, which requires a financial appraisal where affordable housing Page 153 provision is less than the specified policy requirement.

On issue ii) the Inspector noted that there was no evidence of any form of parking restrictions upon the previous workshop use of the site. Nevertheless, policy considerations were clear that development should have regard to public transport accessibility in considering parking provision, with minimal provision in areas with good accessibility. The appellant submitted a draft Unilateral Undertaking to secure the development as car free. Accordingly, the inspector concluded that the Undertaking satisfies a justified requirement for the development to be car-free, having regard to the Policy T7. Additionally, the council secured a condition requiring that the recessed area at the front of the premises be kept for refuse/recycling storage.

For the reasons given above, the Inspector allowed the appeal on ground (a) - subject to the sign-off of the unilateral undertaking making the development car-free. The ground (f) was redundant.

Allowed Dismissed Mixed

Month total 1 0 0

Financial year to date 3 0 1

1 This page is intentionally left blank PLANNING APPEAL DECISIONS RECEIVED BETWEEN 01/09/2020 AND 31/09/2020

Council ref. Appeal type Address Proposal Decision Officer Decision date Appeal type recommendation decision

18/03876/FUL Refusal - Town Land At The Rear Of Demolition of 3 derelict garages to the rear of Delegated Refuse Permission 19.09.2020 Appeal Planning 72 Lewin Road the property and erection of a 2 storey dwelling Decision Dismissed London house with access onto Eucalyptus Mews, SW16 together with the provision refuse and cycle storages.

The Inspector considered the main issues of the appeal to be: i) whether the proposal would effectively safeguard an existing mature oak tree on the boundary of the site; ii) whether the proposal should provide a contribution towards off site affordable housing provision; iii) the effect of the proposal on the character and appearance of the area; and iv) the effect of the proposal on the living conditions of the occupiers of 70 Lewin Road in relation to potential overlooking and whether the proposal would prejudice future development potential of land at that site.

On the first issue the Inspector was not satisfied that the root protection area of the oak would be adequately safeguarded and therefore the scheme did not meet Policy Q10 of the LLP. Page 155

On the second issue the Inspector reviewed the build costs and agreed with the applicant that higher build costs were justified, and on this basis found the scheme was not viable to pay an affordable housing contribution.

On the third issue the Inspector referenced other mews developments in the area and the poor appearance of the buildings on site, and found that the scheme would be acceptable in terms of its effect on the character and appearance of the area.

On the fourth issue the Inspector did not agree with officers that the proposal would have an unacceptable impact on the outlook of the residents of 70 Lewin Road.

Agenda Item 7 The Inspector dismissed the appeal on the first issue only.

Allowed Dismissed Mixed

Month total 0 1 0

Financial year to date 5 17 0

1 This page is intentionally left blank PLANNING ENFORCEMENT APPEAL DECISIONS RECEIVED BETWEEN 01/09/2020 AND 30/09/2020

Council ref. Address Breach of planning control Notice type Decision date Appeal decision

No Enforcement Appeals decided this month

Allowed Dismissed Mixed

Month total 0 0 0

Financial year to date 3 0 1

Page 157

1 This page is intentionally left blank