19/04280/FUL

Demolition of existing retail and industrial buildings and erection of a car free, part 3, part 20, part 29-storey mixed-use podium building comprising 2073m2 of employment floorspace (Use Class B1 a) and c)) with ancillary sandwich bar/café (Use Classes A1/A3) and site caretaker’s accommodation, an industrial yard of 55m2 and 170 dwellings with associated disabled car parking, cycle and bin stores, and hard and soft landscaping.

The Camberwell Society objects to this application.

The Camberwell Society monitors all applications London SE5, commenting on any of concern, taking account of significant applications in adjacent postcodes.

We object to these proposals and agree with the Herne Hill Society and Brixton Society.We summarise and add to their objections in stating our objections.

1. National Planning Policy: The application is inconsistent with the overarching principles of the National Planning Policy Framework (section 12).

2. London Plan and Lambeth Plan: Contrary to the principles in Policies D1 and D2 of the new (draft)London Plan and Lambeth Plan Q5 and Q7 and Q5 of the new (draft) Lambeth Plan, two towers rising to 29 and 20 storeys are not a positive, or contextual, response to the character of the area. They are wilfully antagonistic to that character, creating densely congested structures with an overbearing presence out of any reasonable scale with neighbouring buildings. The rationale of the design stems solely from the maximisation of housing capacity on a small site, not from any response to local context.

3. Excessive Height and Visual Impact: There is nothing in the Lambeth Plan, or in the proposed Loughborough Junction Masterplan, identifying the site as a location suitable for tall buildings. The repeated attempts to justify by reference to the Higgs Estate proposal is misconceived because (i) the towers show a 25% and 80% increase in height over the tallest building proposed on the Higgs Estate (ii) the two sites are simply not comparable (iii) the latter proposal is a poor precedent, having relied on incorrect application of density criteria and having not taken into proper account the absence of any identification of the site as suitable for tower blocks.

The London Plan and the Lambeth Plan both stress that tall buildings require excellent design. Architectural quality should be of "exemplary standard". The towers stand out for their gross incongruity in the local context not for any outstanding design quality or distinct architectural expression.The scale and height of the proposal also would not fit into the local streetscape and the visual impact would be overwhelming

The proposal will seriously harm heritage assets, dominating and overshadowing the Loughborough Park Conservation Area, the Brockwell Park Conservation Area and the Listed Ruskin Park and the views therefrom. The visuals relied upon are selective, thus undermining the professed objectivity of the Townscape Heritage and Visual Assessment.

The application fails to comply with London Plan Policy 7.7 (new Policy D8) and Lambeth Plan Policies Q25 and Q26.

4 (i).Density: The high density proposed is inappropriate because: (i) The site is in an area mainly comprising 19th century 3-storey housing (some 2-storey) and low-rise industrial units.

4 (ii). Transport Capacity:(ii) City-bound train services stopping at Loughborough Junction Station are at full capacity and would not be able to cope with the significant increase in resident numbers (and the station overcrowded and lacking a lift). Local bus routes are also already overloaded and will become more overstretched with the Higgs Estate development.The development is car free and residents would not have the option of driving to work either.

4 (iii). Infrastructure: There will be increased pressure on local infrastructure (education, health, retail provision) but no indication in the application how this will be dealt with. Another massive increase in resident numbers would cause more pressure on these services and it is questionable if existing schools and surgeries would have enough space to expand.

4 (iv).Overcrowding and Safety: The Higgs Estate proposal already presents a pedestrian safety issue at the junction with Coldharbour lane. This application will exacerbate the problem and create a further problem with a potentially dangerous pinch-point along Hinton Road towards Coldharbour Lane. There are no suggestions for how these problems can in practice be avoided.

5. Daylight and Sunlight: There will be an unacceptable impact on levels of daylight and sunlight, contrary to Lambeth Plan Policy Q2. The normal BRE guidelines for 2- or 3-storey, low-density housing should be followed. It is wrong, as the applicants seek to do, to characterise the area as high-density inner-city urban and thus apply the guidelines "flexibly".

6. Affordable Housing: Policies E7 and H6 of the draft new London Plan state Fast Track proposals which involve the development of industrial sites for mixed use should both retain industrial capacity AND meet a higher 50% threshold for affordable housing. In proposing 35% affordable housing the application fails to meet the threshold.

7. Industrial v Residential: The proposed scheme is likely to lead to loss of industrial floorspace and a detrimental effect on existing industrial activities in the railway arches in Hardess Street, contrary to Policy E7. E2 of the draft new London Plan. The proposed new residential use above the industrial floorspace will not comply with the Agent of Change principle introduced by Policy D12 of the new London Plan.

Conclusion:

The Camberwell Society objects to the proposed development because of the severely deleterious effect that it will have on the adjoining SE5 area, dominating and overshadowing public spaces, in no way complimenting or fitting in with the character and scale of the surrounding buildings. As set out, the proposed development does not comply with various Lambeth’s planning policies which taken together with the reasons stated, we submit that permission for this application should be refused.