conditional planning permission granted

 Fundamental Planning and development issues not addressed

None of the fundamental issues and shortcomings of this proposed development in terms of the design, architecture, density, vehicle access, servicing, inadequate amenity for new residents and loss for existing residents, inadequate safeguarding of privacy and overlooking for new and existing residents have been adequately resolved or addressed.   The serious loss of daylight and sunlight for residents next to the site of these proposals remains unresolved.
In light of the most recent changes and as of  29 March 2023 there is not an updated viability appraisal open to public consultation to examine the viability of this latest version of the scheme. Its absence does and the opaque heavily redacted earlier versions have prohibited the public from examining why the developer needs to build 126 units (far beyond the circa 90 units that it could accommodate) on the site and why only 15.8% of those units will be marketed as "affordable". Also, there is no information to assess  whether the private/market or "affordable" market units will be realistically priced for residents in this area. 

We believe the latest changes in March 2023 coupled with the unaddressed fundamental issues and conflicts with planning policies do not and have not altered the balance in favour of development and planning permission should be refused. 

"THE PLANNING BALANCE"

In paragraph 11.10 of the Planning Statement Addendum (March 2023) the planning agent on behalf of the developer summarises the benefits of their development proposals and tries to reason that they outweigh the harms; coupling with some further reasons and sound planning grounds to grant planning permission. Taking those suggested benefits one by one below (developer assertions in italic ) we believe that there are reasons why this proposed development should not be approved and should be significantly revised. To be clear we are not opposed to any redevelopment of the site, but any redevelopment must be balanced in terms of its benefits and impacts/harms.

1. 126 units of housing which includes 21% affordable housing

Of the 126 units proposed, 106 (84%) of the units are market housing. This is an increase from the 102 units from the scheme submitted in 2021 at the expense of the original quota of "affordable " units proposed. It is wrongly claimed in paragraph 9.5.8 of the Planning Statement-Addendum March 2023 that 20% of units are earmarked as being "affordable". Of the 16% affordable housing units, only 13 units (down from 19% for the scheme submitted in 2021) are affordable rent units (social rented housing), with the remaining 7 which is down from the original 15% put forward) being “intermediate”. Additionally, most of the  the social rented provision is grouped together in Block F (affordable rented), and part of D (intermediate), which is contrary to development plan aspirations to co-locate all tenures in the same building. 

2. The regeneration of a previously developed site and its highly sustainable location 

The site of the former Woodlands Nursing Home requires redevelopment to provide much needed additional housing. However, the proposed development does not in any way seek to integrate with the surrounding neighbourhood. Instead it provides a 14 storey tower on a site of just 0.54 ha, massively out of scale with its immediate surroundings that will have a detrimental effect on existing listed buildings, and the amenity of dozens of existing homes, many of which, by the applicants own daylight and sunlight assessment would fail to meet the required standards that the proposed development has to meet. This is a development seeking to maximise profit, with the applicant acknowledging the proposal will cause harm to the many existing homes and the residents of those homes. This is not a development “integrating into the surrounding neighbourhood”. 

Paragraph 124 of the NPPF requires that “Planning policies and decisions should support development that makes efficient use of land, taking into account:… (d) the desirability of maintaining an area’s prevailing character and setting”. This development proposal does not maintain the area’s prevailing character and setting. 

The peripheral blocks present significant overlooking issues for existing residents, particularly on Renfrew Road. The architecture of the peripheral blocks is reminiscent of nearby poor design from the 1980s which is being demolished.

3. Economic benefits for the Borough 

Jobs and apprenticeships are to be welcomed but construction related employment would be transitory in nature and such employment would also be created by a smaller and more appropriately sized development which is respectful of its surroundings. The number of permanent jobs created by the operational phase of development is minimal - it is worth noting that the application form for the proposed development has the answer “no” to question 32: “Are there any existing employees on the site or will the proposed development increase or decrease the number of employees?”. 

The proximity to the borough boundary and, eventually, shopping and other facilities, will mean that any supposed “trickledown” will be lost from Lambeth to Southwark, even if, unlikely as it will be, everyone works from home in the blocks. The only economic benefit to the borough will be additional council tax receipts. This is not a reason to downgrade existing residents’ quality of life. 

4. Improvements to the immediate surroundings and setting of The Master’s House 

The claim of enhancement of the Master’s House (home of The Cinema Museum) is not borne out by the quality of the architecture which will be within the setting of this listed building. The Master’s House will be marred by a hard and unrelenting wall of red brick that has no reference in the Master’s House. It is also difficult to understand how the pastiche of Spanish colonial style architecture that is used in the Block A tower block can be said to enhance the setting of the Master’s House. 

The materials of the peripheral blocks will present a hard and unrelenting wall of bright red brick, and metal cladding that has no reference in the Master’s House or other heritage buildings. The design of the lower peripheral blocks is poor and reminiscent of council or office blocks from the 1980s. 

The setting of the Water Tower has not been referenced by the applicant here. It is not clear how the developer and its consultants are able to justify that the 14 storey tall tower in close proximity to, and in the immediate setting of the principle views of 7 storey grade II listed Water Tower building. It is telling that the developer did not provide any visualisations of the view of the Water Tower from Dante Road with the proposed tower completed. It is also telling that the planning application documents to not show visuals indicating the full extent of the effect of the tower on the Master’s House. 

5. Environmental improvements to the site 

Removal of existing trees, significant additional traffic related to deliveries and servicing, overshadowing of substantial areas for significant parts of every day cannot be in any way considered as environmental improvements. 

6. Increasing permeability around The Master’s House and the Water Tower Development 

There will be an additional route from Dugard Way to Dante Road, but it is impractical and unsafe and it will be shared with refuse and delivery vehicles, in amongst an overwhelming expanse of planting and benches that will provide opportunities for loitering and the hiding of negative behaviour. The attractiveness of this ’new’ route is questionable, particularly at night. 

The pedestrian link between the tower environs and Dugard Way will be in front of Master’s House, on a ‘shared space’ , shared with delivery and service vehicles and vehicles turning (the application documents predict 20 vehicle trips a day visiting the site, but going from the experience of “Uncle” more likely to be 100 or more per day). The pedestrian and cycle connections provided will simply replicate those already available through the Water Tower development and will not improve on these which already consist of a segregated pedestrian only route. 

The route through the development is appears to feature planting along the road route which will quickly become either a mess of mud and dust or will be removed completely. The paved area being shared with heavy vehicles using it regularly is likely to lead to damage to the paving. The route is also set amongst an overwhelming expanse of planting and benches that will provide opportunities for loitering and the hiding of negative behaviour. The attractiveness of this ’new’ route is questionable. 

There are existing safe, permeable routes for pedestrians through the Water Tower development. If anything, the proposal, with the predicted 20 vehicle trips a day visiting the site (but going from the experience of “Uncle” more likely to be 100 or more per day), will make existing walking routes less safe by introducing more vehicle pedestrian conflicts, particularly with additional large vehicles during construction and once completed vehicles both delivering and existing through the narrow roads and gateway along Dugard Way. 

7. Car free credentials of the development

The development may be ‘car free’ but it will not be vehicle free. There is rightly the mandatory amount of parking for vehicles adapted for residents who have accessibility requirements. However, for the substantial number of delivery and servicing vehicles there is only one parking bay which will lead to congested parking on and off site particularly with taxi vehicles coming to collect or drop off residents. 

8.Retention of the Cinema Museum 

The retention of the Cinema Museum is listed as having moderate weight in paragraph 11.5 of the Planning Statement Addendum (March 2023); however the Planning inspector did not consider this matter as a planning benefit for consideration as part of the planning balance exercise for any decision maker. The uncertainty about the status of the Cinema Museum has been entirely Lifestory Group/Anthology’s doing since the site was purchased. In the period during which the previous planning application for a taller tower on site was being determined, Anthology stated in a letter that, if there was a planning appeal then Anthology would need to use money previously allocated to the Cinema Museum on that appeal. 

As it currently stands the Cinema Museum has been granted a 4 year lease with the option to buy the building at £1 million (confirmed on the Cinema Museum website http://www.cinemamuseum.org.uk/). It would appear therefore that the retention of the Cinema Museum is no longer relevant as a reason for granting this application. It would also follow therefore that the retention of the Cinema Museum should no longer form part of the description of the application, and that the site area should exclude the Master’s House in which the Cinema Museum is housed.