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.