Vauxhall Park friends object to "true horrors and dangerous precedents" of Keybridge House application

The Friends of Vauxhall Park have submitted to Lambeth Council a formal objection to the Keybridge House planning application.

Friends of Vauxhall Park board members Helen Monger and Polly Freeman say:

This application has been hanging around for some time – but the true horrors and dangerous precedents this project proposals have not been fully realised by us  until recently having read the application.

• The Financial Viability Assessment is being kept confidential and the Council Officers are agreeing massively reduced planning gain because of the placement of a primary school on site so that there is no additional infrastructure contribution other than affordable housing of 2.4% on this development as opposed to the recommended 40%.
• Worse still, Council Officers are agreeing to present to the planning committee for decision a full application without securing the planning gain by using a hybrid application process.
• Much of the documentation is flawed – eg. the transport survey and lacking material to demonstrate what overshadowing will result from the development
• Consultation has been meaningless
• Vauxhall Park is being overlooked for any financial contribution (along with any other infrastructure needs) despite bearing the brunt of the increased population density when it comes to open space. No additional green space provision is being made on site. If this application is allowed to proceed on this basis then all othe proposals within VNEB will be able to adopt this hybrid service and commute their planning gain indefinitely.

Please support us and write in.

The case officer is Richard McFerran - RMcFerran@lambeth.gov.uk - and the deadline is today!

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Letter in full:


Re: London SW8 1RG – Keybridge House, 80 South Lambeth Road 13/03935/OUT

We are writing on behalf of the Friends of Vauxhall Park to strongly object to this application. 

The Friends of Vauxhall Park suggest the following reasons for rejection.

The project is in breach of the London Borough of Lambeth (LBL) Local Development Framework Core Strategy adopted January 2011 which contains several strategic objectives, amongst which they state that: “… of strategic importance is a need to develop and sustain stable neighbourhoods with a high quality, liveable residential environment, respect for local amenity …” because:

1. It will not deliver a stable neighbourhood, as there is insufficient affordable housing to meet local demand. 
2. It will not provide a high quality liveable residential environment with overcrowding of local open space and public transport provision as a result of an inappropriately sited primary school. The 420 place school with a caged roof as a playground will result in roughly 300 children commuting from offsite. 
3. It does not demonstrate respect for local amenity. London Borough of Lambeth policy further specifies that new projects improve local open spaces. Residents of the scheme and pupils of the primary school will naturally wish to use Vauxhall Park the nearest public green space which is becoming overwhelmed with the number of people it has to accommodate. There is no on-site provision of play space, creation of green space or money available for mitigating the impact of these users thus resulting not only in a lack of improvement but actually being detrimental to the Park which breaches Lambeth policy too. 

The background for our conclusions follows:

Consultation
I can confirm that prior to the submission of this application, the developers met with us to discuss their proposals and we made the following observations:

• We acknowledged that the scheme had kept within the height restrictions recommended for the VNEB and that the design of the tallest tower was slimmer and further away than the existing building, thus reducing some of the visual impact on our park. We also accepted it would improve the setting of St Anne’s Church. However, we asked if the designs could consider moving the tallest element of the design further to the North and West of the site to reduce the impact still further. 
• We made the point that this was a very large development increasing the population of the area and that we would expect a substantial donation to the park to help us make adaptations to cope with the numbers. We reminded the developers that, at the Bondway inquiry the Planning Inspector had noted that the park was at a tipping point in terms of overcrowding and since then other developments had been approved. 
• We asked that the site expand the public open space available, as Oval is an area of open space deficiency. We suggested that the open space should include a green area rather than the current proposals – EIA Volume 3 “5.29. The new piazza (St Anne’s Square) would be predominantly hard landscaped with two clusters of three trees and seating at either end….”. 
• The developer informed us at our meeting that Lambeth’s Regeneration Officer, Ms Sandra Roebuck, had requested a 2 form intake primary school be located on their site which would offset some other planning gain requirements. We acknowledge the need for better infrastructure – the community in 2008 at the Lost Theatre had clearly articulated the need for schools (more importantly at secondary level) to Ms Roebuck prior to any VNEB developments being agreed. However, the selection of this location (some years after a whole host of developments have already been signed off) without discussion with local residents is wrong as it is immediately adjacent to a pre-existing primary school, Wyvil. There are two reasons for the inappropriateness of this suggestion. First, it will cause too much congestion at key points in the day (morning drop off and afternoon pick up) so close to the Vauxhall Gyratory. Second, from the Park’s perspective, the design for the school currently has no provision for outside space, other than a caged roof, resulting in severe impacts for Vauxhall Park as the likely location for games, PE, external learning opportunities and other activities on top of the existing users including Wyvil School. A caged roof is not best practice for playgrounds and we recommend planning officers consider the expert guidance given by Landscape through Learning. 
• Last we asked for the Park to be given free wifi for the benefit of all park users as a suitable legacy of BT’s occupancy of this site. 

We left on the understanding that the developers would contact us when they had completed their consultation to negotiate how best to mitigate impacts on the park. Since then no word has been received. Given what has been presented, our cautious note of optimism has been exaggerated and there is no evidence that our proposals have been given any consideration. Consultation has therefore not been done in a meaningful way with key stakeholders.

Misrepresentation by Lambeth Council
Lack of consultation has been exacerbated by the misrepresentation of this planning application. Despite what is said on the Lambeth Planning database, not a single notice has been seen in Vauxhall Park telling residents of these proposals. A single poster was noticed on the South Lambeth Road, which was removed before 23 September and therefore before the consultation period had ended.

Prior to reading the full documentation, given the lack of notices posted in the park, and the fact that Lambeth Officers chose not to notify us of receipt of this application despite being the nearest public green space, we assumed this was due to it being in outline. However, we are shocked to see the covering letter submitted by the applicants’ agents GL Hearn, stating the following:

A hybrid planning application for the demolition existing buildings on the site and retention of basement to provide a mixed use development comprising full planning permission for 5 blocks (of 4, 9 (2 no.), 22 and 36 storeys) which includes 415 dwellings (Class C3), 2,652 sqm GIA employment floorspace (Class B1), 802 sqm GIA retail (Class A1-A5) associated basement car parking, storage and servicing, new public realm and open space; and outline planning permission for a two form of entry primary school (Class D1) 8,600 sqm GEA (maximum) and associated servicing and means of access.

The planning application is submitted as hybrid, with full planning permission sought for the residential and commercial space and outline planning permission (with all matters reserved bar access) sought for a primary school. The scope and form of the planning application was agreed at the pre-application stage…

This is a highly illogical situation to present to Lambeth Planning Committee. Either the scheme includes the primary school and is a full application, or it is an outline application with everything up for discussion. Given that the majority of planning gain is reliant on delivery of the school, we question the legality of this hybrid procedure particularly as the Financial Viability Assessment (FVA) submitted to the Council is not available on the planning portal, so cannot be scrutinised but must be taken on trust.

The Affordable Housing Statement says:

3.4 A Financial Viability Assessment is being submitted to the Council to justify the level of affordable housing. A draft report has already been submitted to the Council’s advisors, BNP Paribas. It was previously agreed with Officers that due to the provision of land for a primary school within the development, the affordable housing element could be reduced.
3.5. Given the small number of affordable housing units, it is proposed that these would be all for affordable rent tenure.

The net result is that instead of 40% provision of affordable units there will be only 10 affordable rent units, out of 415 units in total – meaning an affordable provision of just 2.4%. The FVA should be in the public domain as it is of critical interest given that all other infrastructure in the area is losing out. The case of the developer being able to reduce the affordable housing element of Sky Gardens must not be repeated by allowing planning permission to proceed without securing a binding commitment to providing the elements of planning gain needed and promised.

Inadequate application materials

Further, the application material submitted is flawed on the following key points outlined below:

Daylight and Sunlight Assessment

Fails to enclose a set of plans showing the impact of overshadowing on the park throughout the day and relies instead on the following statements:

5.18 This local park was assessed for overshadowing impacts by application of the BRE ‘time in sun’ analysis.
5.19 The assessment indicated that 99.58% of its area would receive in excess of 2 hours of sun on the assessment day of March 21st, greatly in excess of the BRE recommended minimum of 50%.
5.20 Vauxhall park is therefore considered to retain adequate access to sunlight with the proposed development in place.

All other proposals submitted have always included full plans showing both cumulative and individual overshadowing at the equinox, midsummer and mid-winter at critical intervals throughout the day from sunrise to sunset. Why is this proposal any different?

Transport Assessment 
The baseline data was taken on 5th June – a sunny summer day when more people are likely to walk – what would the scenario be on a wet winter day? Peak hours in the afternoon are defined as from 1600-1900. This avoids one of the critical timeframe of concern to local residents, ie from 14.30 to 1600 which is when school children are being collected. The report acknowledges minor adverse effects on Wyvil Road and Miles Street assuming that all traffic to the school will go there – but only considers the residential traffic as additional. So all conclusions are flawed on the likely impacts.

Adverse effects
The developer has noted in the Cumulative Impacts (EIA Volument 17) but failed to address through mitigation any of the following:

Secondary Education
17.22. The completed Development is estimated generate 8 secondary school aged children. This, together with the Cumulative Schemes, could result in a significant increase in secondary school aged children, totalling some 93 children. Given the current limited availability of secondary school places in Lambeth, this is assessed to be a minor adverse effect at the District level.

Health
17.23. Insufficient up to date information is available with regard to primary health provision to accurately assess the effects in the context of existing GP capacity. It has been assumed that new or expanded healthcare facilities would be required to support the population increase associated with the Cumulative Schemes and the Development and it is therefore likely that this would have a moderate adverse effect at the district level until new facilities become available.

Open Space
17.24. Insufficient information is available to accurately quantify open space and play space provision in the cumulative schemes. The baseline assessment identifies that a new park is required and that a linear park is proposed in the OAPF. The open space and childcare requirements generated by the Cumulative Schemes and the Development are likely to be a moderate adverse effect at the District level until new facilities become available”

The effects on open space have been played down and it should be substantial adverse effect at District Level given that no new park is being created and the Linear Park is no more than a path with marginal vegetation through the high rise developments. The Mayor's plan requires age appropriate equipment for the under 5s and 5-11 with this last age group also requiring a kick about space. There is no evidence of any provision for this on the plans despite a questionable child yield estimate for 415 units showing 28 children living on-site under 5 years old, 14 children from 5-11 years and 8 children of 12 years and above.

This objection should be circulated to the Planning Committee in its entirety given that we are now restricted to 2 minutes presentation and the arguments we present are complex. If our comments are summarized we assume we will be given additional time to make our presentation at the planning meeting to explain the full arguments and correct any misunderstanding resulting from a shortened version and trust you will notify us accordingly.


Yours sincerely

Etc