Planning – Application Comments

Lambeth council, please stop destroying London for the local communities that live and work in the Borough. The obsession with build big has to be reconsidered. London needs to be able to breathe. The amount of unused office space and flats left empty begin sold off to foreign investment should be looked at and not continue to build more of the same

the proposed development on this site creates one of the ugliest buildings in London on a site of national and international significance,
right on the Thames. There is no need whatever for further office space in our Borough, especially after the Pandemic - as so many now work from home. The 'greening' of the building is laughably inadequate. There is a 'stuck on' concession for 'affordable housing' - no doubt put there to get this dodgy deal thru Planning. It does nothing to address the boroughs chronic shortage of council houses.
Many of us object strongly to this degrading of the environment to satisfy the whim of some multinational corporation.
It is time to call in the application and either green the site- by planting trees, or turn it into an extension of Vauxhall City farm.

I would like to object to the planning application at 72 Upper ground, South Bank by Mistubishi property developers, architects - Merry & Co - for an office block. This planning application is not only offensive to anyone who is sensitive to the need for aesthetic appropriateness of architecture it is also surprisingly commercially out of touch with the reality left by the Pandemic which has resulted in office space being thought of in a more creative manner.
It will not 'brings jobs and wealth' into our borough, but instead create a brutal, ugly structure. This is not in keeping with the vibrant, creative atmosphere of the South Bank.
There is no sign in the plan of any awareness at all of eco-values. there is even less sign of architectural sensitivity to the surrounding environment and no consideration of why people go to the South Bank and what they are using it for.
Local authority housing on this site is a far better idea, would cost less, would bring richness to Lambeth and help obviate the shrinking availability of accommodation to essential workers in Lambeth.
Please, rescind the application.

I would like to object to the planning application at 72 Upper ground, South Bank by Mistubishi property developers,
architects - Merry & Co - for an office block. After the Pandemic, with office space in London no longer being occupied,
and more people working from home - what is the need for this? It will sit empty. It will not 'brings jobs and wealth' into our borough, but instead
create a brutally ugly structure, which would not have looked cool even in the 70's, on a beautiful artistic site.
There is no sign in the plan of any awareness at all of eco-values. there is even less sign of archietectural sight-sensitivity.
Local authority housing on this site is a far better idea, would cost less, would bring richness to Lambeth and help our poorest citizens.
Please, rescind the application. Lambeth can do better,

Rowan Moore's Observer article about this proposed development is far too mild. This is an appalling proposal, and everyone concerned surely knows it.
This is one of the most prominent sites in London - indeed in the world - and the proposal, for no reason but profit, is to erect a building of surpassing ugliness, on an inhuman scale, that is not even of an original design. It would be a blight not only on the South Bank but on the views from Waterloo, Blackfriars and the Jubilee Bridges and from a large swath of the North Bank. Anyone who finds this attractive must be - well, an architect.
Refuse it, or go down in infamy as one of the councils that ruined yet another part of London through sheer greed. I have lived and worked on the South Bank for 30 years and have loved it as the heart of cultural London. This is out of character, would bring overcrowding, but most of all it would represent corporate greed belittling the public facilities all around it. More office space is clearly not needed now in London anyway, since demand is so low and offices in the City are half-empty.
It is simply a shameful proposal and must be turned down.

Dear Mr Oates

We are writing regarding the plans for wind mitigation for 72 Upper Ground. The develops are planning to use the trees below as part of their strategy:

Serviceberry
Ornamental dogwood
Birch
Field Maple
Sweet Gum
Honey Locust

However, the first two are quite small trees and will do little to protect against wind. They are all deciduous so will not have much effect on the wind in winter months. The field maple is a native and it is quite a dense tree with a lot of branches so it might give some protection from the wind.

Furthermore the proposal is to put these in planters underneath a canopy along the western elevation of the south building. This will mean that tree growth - and effectiveness - will be limited. There are no details in the Wind Mitigation document about the number of trees or size of planter/s. The trees will be in partial shade because of the canopy and will require substantial ongoing maintenance.

It's difficult to see how effective this part of the wind mitigation strategy will be.

[TEXT REDACTED]
Environment Tree Group
Southbank and Waterloo Neighbours (SoWN)

I am objecting to the proposals for 72 Upper Ground for several reasons. The sheer bulk of the development is inappropriate, completely overshadowing the neighbouring buildings. It will dominate this section of the South Bank which, up until now, has remained relatively low rise. The iconic river walk which passes this site is one of the most visited destinations in London and each building is of huge significance; but this proposed building is completely out of proportion.

I feel there has been insufficient information regarding the use of the building. The developers have emphasised 'cultural activities' but the actual proportion of the building designated for these activities is extremely small. The amount of office space proposed seems excessive given that office space is being created in many other buildings in the Waterloo area, also bearing in mind that many office buildings are currently laying empty as the trend for working from home increases. We have not had clarity on how much retail and restaurant space there will be nor where deliveries to the building will be made. There doesn't appear to be a service area or a vehicle entry point to the building from Upper Ground. This can only mean that deliveries will be made from vehicles parking along a residential street. If there are several restaurants and retail outlets, deliveries could be constant throughout the day.

Just a final point. This area is extremely popular and Bernie Spain gardens becomes crammed with locals, tourists and office workers from late Spring to early Autumn. This tiny precious piece of green space will now sit in the building's shadow, having more of its sunlight blocked. It will undoubtedly suffer from the huge increase of visitors and workers created by a building of this size.

Response to Planning Officer's Report from Mulberry Housing Co-op in
respect of 72 Upper Ground SE1 9LT for Planning Committee, 29th March
2022. REf. 21/021668/EIAFUL
Introductory Comment
Mulberry Housing Co-op residents are disturbed to receive news of the suggested
approval in the Planning Officer's report in respect of 72 Upper Ground. There are
professional reports and guidance that need to be properly heard to support major
concerns about the impact of the bulky/massive building on residents and
townscape/heritage and environment. Members of the Planning Committee need to
understand and appreciate fully the impact this proposed building will have and whether
the public benefit outweighs harm and adverse effects in so many areas.
Whereas we totally understand the need to develop the site for purposes of
employment/mixed use /residential we are concerned and many exceedingly anxious by
virtue of the massive bulk of the proposed building. Our immediate reaction is bound
to be the impact to housing on Upper Ground but by the same token we do not want
the iconic and internationally "town-scape" experience destroyed, whether it be on the
riverside walkway enjoying views or as we walk down the streets of Waterloo or across
the bridges.(5.12/5.31/5.32/5.34/5.35/5.36/) Our well being and mental health
is bound up with this as local residents. We are keenly aware of the need and use of
this area for the well being of Lambeth and Southwark residents in particular but by
people from all other London boroughs besides its national and international
significance which brings in 30 million visitors a year.
The South Bank brings in visitors and employment and also the proposed gardens on
the Queen's Walk beside this proposed development which was designed and agreed by
PAC as a needed peaceful space for what has become a very busy walking area much
enjoyed. Two pinch points affect this South Bank Conservation area as you pass the
listed buildings - IBM and the Oxo Tower and this needs to be considered when
considering a proposal suggesting retail development is a public benefit.
What actually is the "public benefit" when open space and wellbeing are being
destroyed in a borough and part of London that suffers " open space deficiency" ?
What exactly is the public benefit of "affordable" workspace when there is workspace
available in this neighbourhood that is cheaper. (Dorset House, Stamford St. is what we
are immediately thinking of).
We note that it is of significance that after full consideration of the facts our three local
councillors and Member of Parliament have all now submitted objections to this
development.
What is the real impact on the environment/open space when trees, plants, shrubs,
flowers, birdlife, wildlife will all suffer from the imposition of major shadowing? (5.1.1)
Looking again at the Officer Report we realise the dearth of consideration for
the effect on local ecology and biodiversity which will be seriously affected
by overshadowing issues. The richness of natural life in the heart of London
must continue to be nurtured for the health and wellbeing of its people. The
Site Visit should circuit the whole of the site and its environs and come to
fully appreciate the effect of overshadowing on Bernie Spain Gardens North
and South, the riverside walkway and beach. (We understand there will be a
response from CSCB which will undoubtedly comment on Section 5)
Community Engagement (Executive Summary iv)
We acknowledge that the sale of the site happened relatively shortly before the
pandemic but given the importance of this site and development there needed to be
much more purposeful engagement with the local community about the development of
the site. The local community could have shared many important insights in respect of
development in this neighbourhood. As it was the one on site consultation, which a
number of very local residents planned to attend, was cancelled because of Tier 2
Restrictions in October 2020.
The time scale of discussion with Lambeth Planning (April 2020 onwards) presented in
the report feels far more" real" than the presentations in leaflets and in meetings
initially homing in on the cultural use of the building and ignoring the physical
development. The request for projected views made at meetings and in writing were
not made available until the planning application was submitted and validated in July
2021.
Although the Site 9 SADPD process has not been completed, concern exists about the
bulk of buildings that could extend along this street, destroying the ambiance of the old
Narrow Wall and an industrial and rural heritage of a part of central London that was
the last to be developed with the building of Waterloo Bridge.
Soft Demolition started last summer with no information made available about what
was happening? How were people going to begin to feel there was any point engaging
with the Council's public consultation process running parallel. Many residents were in a
state of shock and indeed terror about what they heard rumoured.
24.3.1 Cultural/Working Spaces Public Benefits
We would agree with concerns of South Bank and Waterloo neighbours (SoWN) in
respect of their concerns about public benefit.
15.1.1. Daylight
Mulberry Housing Co-op acknowledges that Iroko faces the more devastating daylight
issues and are appalled the approval is suggested given "major adverse effect" on so
many windows. We would point out that 1 Coin St. is not dual aspect.
91 and 93 Upper Ground will also experience severe impacts by loss of daylight.
Indeed the remainder of Upper Ground and 1 Duchy St. will experience some degree of
daylight change variable by where they are in relation to the re - developed site. As
indicated in a previous response from Mulberry Co-op we will not have the real picture
of the full impact until a joint visitation is carried out. 3.3 Anstey Horne Report
It needs to be recognised by the committee that it is not only the pandemic which has
determined different uses for rooms in homes but the multi-generational use of homes
which will undoubtedly increase as the housing crisis in London continues. Families
where young people study through higher education will also determine the use of
rooms in the homes here.
10.5.2 Movement flow around building An existing route already exists between
72 (IBM)and 76 Upper Ground (TV Centre). It is not new.
Mulberry Co-op is not appreciative of the taking of the name of our co-op, created mid
-eighties and was an available name for legal purposes, along with Iroko, Palm and
Redwood, for the walkway. The site of the Youngs Pub - opened 1994 is on the site of
Studio Six used by TV Centre staff and their visitors.
Wind Mitigation: response to Consultation and Officer Report (21.3.2. - 2.3.6)
The wind factor is a significant issue to be considered in this land within the bend of the
river - especially at this particular point of the river.
The developers are planning to use the trees below as part of their wind mitigation
strategy. We are advised by the SoWN Environment Tree Group that the suggested
trees are probably not appropriate for the job on this site: " The first two are quite
small trees and will do little to protect against wind. They are all deciduous so will not
have much effect on the wind in winter months. The field maple is a native and it is
quite a dense tree with a lot of branches so it might be the best for some protection
from the wind.
The proposal is to put these in planters underneath a canopy along the western
elevation of the south building but there are no details in the Wind Mitigation document
about the number of trees or size of planter/s. Furthermore, the trees will be in
partial shade because of the canopy and will require substantial ongoing maintenance.
It's difficult to see how effective this part of the wind mitigation strategy will be."
Conditions: The Co-op expressed concern about Flooding, Wind, Demolition and
Construction in its initial comments. Rightly so, given we live close by with a communal
knowledge of the site. What becomes totally apparent in this process for this massive
and overwhelming development is that many of the concerns raised will not be dealt
with until after the PAC decision as Conditions such as 4,5,6,7,8,9,10,11,12,13,14,15,16,
17.18,22,42, would then be applied if approval to application given and would demand
further investigation and reports.
[TEXT REDACTED]
Community Link/Management
Mulberry Housing Co-op

The report has identified some "drastic light reductions" for houses neighbouring the former ITV site and the consultants state, "Those occupants that will be affected by the development will have good reason to object to the proposed development based on the daylight injuries to their properties." It is clear that the developers have indeed underestimated the effect on local residential properties and although not as obviously affected as Iroko Co-op, Mulberry is significantly impacted, as well maybe Palm and Redwood.

I would certainly agree with the strong recommendation that a joint internal inspection of the affected properties takes place.

In our submission of 1st November 2021 we referenced the anticipated and now completed report from Anstey Horne made at the request of Coin Street Community Builders. In light of their highly disturbing findings Mulberry Housing Co-op would wish to highlight particular points:

3.3 The report has identified some "drastic light reductions" for houses neighbouring the former ITV site and the consultants state, "Those occupants that will be affected by the development will have good reason to object to the proposed development based on the daylight injuries to their properties." It is clear that the developers have indeed underestimated the effect on local residential properties and although not as obviously affected as Iroko Co-op, Mulberry is significantly impacted.

2.9 There are a number multigenerational families living on Mulberry where families have been creative in their use of space which means assumptions cannot be made about the use of rooms that are on plans as bedrooms. Even a one generational family where there is a family member who is studying may use rooms differently to a plan. Acknowledgement should be made also that age and disability are likely to affect how people use rooms.

2.18 It is clear that, for example, that at least 2 - 5 Duchy St, if not the full length, should be considered and we would also wonder at the effect on Palm Co-op. The author of this submission was personally amazed at how close the current building felt when she recently visited in the lower Palm flats on the Stamford St. side. We are also aware also that Redwood Co op residents have expressed some concern at the impact on residents in respect of daylight. The report certainly does reflect the local sense that the effect on daylight will be even greater than the developers have presented.

3.3 We would certainly agree with the strong recommendation that a joint internal inspection of the affected properties takes place. (2.8) We would also like to suggest that the number of properties likely to suffer adverse daylight effects are significantly higher than the Arup figure and that they should be included in any inspection.

Like many of my neighbours I know the site across the road must be redeveloped. We are aware how it affects the local economy. What we do want however is a building that we can live with and doesn't cause constant utility type issues during its building.

Those of us living on Upper Ground are keenly aware of this fact of life and the impact of a massive new development: which at the same time is totally out of keeping with the conservation area and sitting alongside listed buildings as it does. Indeed the site is iconic for many who have suggested this building should be listed as a building of its day.

The intended building is far too big for this sensitive sight and will dominant the skyline for miles around besides causing ill health and lack of well being among local residents because of issues of daylight in both our homes and the local green open space and biodiversity.

There is talk of increased public space through building and thoroughfare and greening within complex but this in no way compensates for all the ill that will come of the development in the immediate area.

Dear Sir
PLANNING APPLICATION REFERENCE 21/02668/EIAFUL
72 UPPER GROUND, FORMER ITV CENTRE
COIN STREET COMMUNITY BUILDERS
We write on behalf of Coin Street Community Builders (CSCB), following our review of the officer's
report to committee on the above planning application.
There is significant local opposition to the proposals covering a variety of concerns. Paragraphs 132 &
133 of the National Planning Policy Framework (NPPF) state that 'applicants should work closely with
those affected by their proposals to evolve designs that take account of the views of the community'
and that 'in assessing applications, local planning authorities should have regard to the outcome from
these processes'. There is no reference in the committee report to this guidance in the NPPF, to how
this has been weighed in the planning balance and guidance to members in this regard.
Also, The officer's report does not clearly set out the impacts to the Iroko and Mulberry co-operatives
housing adjoining, in particular the 14 homes suffering major adverse impacts and four more where
the impact is moderate adverse. It is very important that the Council take full account of
a) the fact that many of these homes are in multi generational use;
b) that changing work and study patterns as a result of the pandemic have affected room uses; and
c) that these properties are social housing where residents are placed rather than choosing to buy or
let.
It is both disappointing and unsatisfactory that the officer report does not comment on these
important points which have been raised in CSCB's objections. There will be significant adverse
impacts upon habitable rooms within these properties. It is accepted that many of these homes are
dual aspect but the officer's report does not make clear the vitally important point that the affected
rooms within these flats are predominantly single aspect. Indeed, it implies the opposite.
The officer's report also states that 'neighbouring properties would retain an overall good level of
residential amenity considering their inner London location and that as such officers consider that the
losses of daylight to properties are not unacceptable and that the application accords with the relevant
development plan policies on this matter.' In this regard, it is important to note that the Inspector
considering the appeal proposals at 8 Albert Embankment concluded that 'Although it is close to the
heart of London, some of the affected accommodation around the appeal site houses families with
vulnerabilities, who have little choice about where they live. Evidence that links daylight levels with
human health, including mental health and disease resistance was referred to by LV, and is more than
anecdotal?. Material reductions in daylight should not be set aside lightly.' In this case, the Inspector
and Secretary of State attached substantial weight to the harm to living conditions of residents and
refused the proposals. It is important that this is taken into account and that members are aware of
this previous relevant case.
The acknowledged major adverse losses of daylight are simply not acceptable and as such the
proposals are not in accordance with Policy Q2 of the Lambeth Local Plan.
The officer's report does mention that there is a deficiency in open space on the South Bank but does
not link this consideration to the effects of the proposals on the sunlight to be received by the existing
adjacent and nearby open spaces, i.e. the Riverside Walkway, and Bernie Spain Gardens, both north
and south parks. The pandemic showed very clearly how important these spaces are to the well-being
of local residents and use by visitors and local employees is now beginning to return to pre-pandemic
levels. The sunlight impacts may be within BRE guidelines but the report makes no mention of the
impacts at particularly busy times of day such as lunchtimes and mid-late afternoon. Significantly, no
reference is made to the consented plans under reference 19/00087/FUL. for the re-landscaping of
Bernie Spain Gardens north park and the creation of the new Queen's Walk Garden immediately to
the north of the proposed development site These approved plans contribute substantially to
Lambeth's biodiversity objectives. There will be real consequential impacts on Queen's Walk, and the
impact on the biodiverse improvements due to be made there under the consented scheme
The officer's report refers to the preferred land use across Site 9 in the adopted Lambeth Local Plan
as a whole as being 'mixed-use including offices, residential and active-frontage uses at ground-floor
level.' The report explains that the application proposal does not include residential use but adds the
application site only comprises part of the Site 9 allocation (approximately two-thirds) and therefore
the residential component could be captured in the remaining part of the allocation, which would not
be prejudiced by this application. This is also reflected in the draft SADPD. As such, the proposed
uses on this site are acceptable in line with the site's designations.' What isn't reported, however, is
CSCB's response to the Lambeth Local Plan and SADPD that CSCB's objectives for the remainder of
Site 9 are the building of a nursing home and public piazza on Gabriel's Wharf with an enabling
development on Prince's Wharf. The latter would be needed to fund the nursing home and is currently
envisaged as managed workspace. The outline designs for these two sites developed by Stanton
Williams Architects include active retail/café type uses on the ground floors of both developments,
basement servicing, and high-quality public realm. This demonstrates that the assumption by officers
that the residential component of the Site 9 allocation will be provided on the CSCB land is not sound.
CSCB focussed its heritage objections on the impacts on South Bank Conservation Area but fully
supports the National Theatre's strong objections on the impact on its grade 2* building. CSCB is
extremely concerned that these detailed and well substantiated objections are not referred to in the
officer report. The National Theatre state that the application does not meet the requirements of the
Planning (Listed Buildings and Conservation Areas) Act 1990 (the 1990 Act) which requires that special
regard is had to the setting and historical interest of the Grade II* National Theatre, which would be
adversely impacted by the proposed development. The NT conclude that the proposals are not
compliant with local and national planning policies.
It is our view that the officer's report is lacking and misleading in a number of areas, does not come
to the appropriate conclusions with regard to departures or otherwise from development plan policy
and as such does not apply the planning balance correctly. The conclusions it draws on harm are not
sound and the public benefits are not sufficient to outweigh the harm. The committee report needs
to be revised accordingly and our concerns brought to the attention of members.
Yours faithfully
[TEXT REDACTED]

CSCB wishes to respond further to the following documents related to the 72 Upper Ground
development posted on the Lambeth website on 23 February 2022 and 10 March 2022:

1. GIA response to CSCB objection
2. VSC and NSL effect elevations
3. ES Non-technical summary update Feb 2022
4. SCI addendum dated 9 February 2022 and added to website 10 March 2022.

Daylight Impacts.

Our main purpose in these further representations is to draw full attention to the fact that 18 flats and
houses, all of them social housing, in the Iroko and Mulberry Housing Cooperatives will suffer very
significant loss of daylight if this development proceeds, 14 of them suffering impacts classed as 'major
adverse' and 4 as 'moderate adverse'.

As these comments under the Regulation 25 re-consultation (which ends on 26 March) are made after
the publication of the Officer Report CSCB would expect them to be reported to members as part of a
supplementary report.

Comments on new and revised documents:

1. GIA Response to CSCB Objection.

CSCB wishes to make the following points:

a) Window maps - the window maps available on the Planning Website were incomplete, partial and
confusing. GIA state that window maps were provided to the planning officer on a number of occasions.
If these were more complete and usable than those available on the website they do not seem to have
been posted to the website. The more user-friendly window maps provided for the current second
Regulation 25 consultation have now enabled CSCB to link the worst affected windows to particular
homes as set out below. As this is a very serious issue in relation to the application, and particularly for
the residents affected, these clear window maps should have been available to all from the start.
Homes listed as major adverse below suffer Vertical Sky Component (VSC) losses in excess of 40%.
Those listed as moderate adverse suffer losses between 30% and 40%. The list also identifies where
the retained VSC is below (and in most cases well below) the BRE target figure of 27%. Losses under
the alternative NSL measurement are also included and losses of over 20%, the level at which BRE
advises daylight may be affected, are also identified.

1 Coin Street
- VSC reduction range is from 6.8% to 46%, so major adverse and noticeable to
occupants. Average retained VSC for affected windows 14.2%, so well below BRE
recommended target figure of 27%.

95A Upper Ground: windows W17, R16, F01 and F02
- VSC reduction 64-65%, so major adverse and noticeable to occupants. Retained VSC is 6.8%-7.1%
so well below BRE recommended target figure of 27%.
- NSL losses 42%-44.9% so major adverse. BRE advises if the reduction exceeds 20% daylight
may be affected.

95B Upper Ground: windows W16, R15, F01 and F02
- VSC reduction 61.9%-62.9% so major adverse and noticeable to occupants. Retained VSC is
6.9%-7.2%, so well below BRE recommended target figure of 27%.
- NSL losses 50%-52.4% so major adverse. BRE advises if the reduction exceeds 20% daylight
may be affected.

95C Upper Ground: windows W15, R14, F01 and F02
- VSC reduction 57%-58% so major adverse and noticeable to occupants. Retained VSC is 7.3%
-7.6% so well below BRE recommended target figure of 27%.
- NSL losses 46%-46.4% so major adverse. BRE advises if the reduction exceeds 20% daylight
may be affected.

95D Upper Ground: windows W14, R13, F01 and F02
- VSC reduction 49.7%-50.9% so major adverse and noticeable to occupants. Retained VSC is
8.3%-8.5% so well below BRE recommended target figure of 27%.
- NSL losses 17.4%-27.2% BRE advises if the reduction exceeds 20% daylight may be affected.

95E Upper Ground: windows W13, R12, F01 and F02
- VSC reduction 39.3%-41.5% so major adverse and noticeable to occupants. Retained VSC is
10.2%-10.3%, so well below BRE recommended target figure of 27%.

97 Upper Ground Flat 1: window W19, F01, R18.
- VSC reduction 62.2% so major adverse and noticeable to occupants. Retained VSC is 7.6%
so well below BRE recommended target figure of 27%.

97 Upper Ground Flat 3: window W19, F02, R18
- VSC reduction 65% so major adverse and noticeable to occupants. Retained VSC is 8.1% so
well below BRE recommended target figure of 27%.
- NSL loss 42% so major adverse. BRE advises if the reduction exceeds 20% daylight may be
affected.

97 Upper Ground Flat 6 windows W19, F03,R18; W30, F04, R29; W31, F04,R30
- VSC reduction 61.1%-63.6% so major adverse and noticeable to occupants. Retained VSC
8.6% -9.8% so well below BRE recommended target figure of 27%.
- NSL losses 18%-48% so major adverse BRE advises if the reduction exceeds 20% daylight
may be affected.
97 Upper Ground Flat 7 Windows W27 F04 and W17 F03 R16.
- VSC reduction 61.1%-63.5% so major adverse and noticeable to occupants. Retained VSC
7.5% - 8.4% so well below BRE recommended target figure of 27%.
- NSL losses 65.1%-63.8% so major adverse. BRE advises if the reduction exceeds 20%
daylight may be affected.

97 Upper Ground Flat 8 Windows W26 F04 and W16 F03 R15
- VSC reduction 63.4%-63.5% so major adverse and noticeable to occupants. Retained VSC
7.5% - 8.3% so well below BRE recommended target figure of 27%.
- NSL losses 63.8%-70% so major adverse. BRE advises if the reduction exceeds 20% daylight
may be affected.

97 Upper Ground Flat 9 Windows W23 F04 and W15 F03 R14
- VSC reduction 56.4%-58.9% so major adverse and noticeable to occupants. Retained VSC
7.8% -8.8% so well below BRE recommended target figure of 27%.
- NSL losses 64.4% -73.4% so major adverse. BRE advises if the reduction exceeds 20%
daylight may be affected.

97 Upper Ground Flat 10 Windows W22 F04 and W14 F03 R13
- VSC reduction 51.3%-51.7% so major adverse and noticeable to occupants. Retained VSC
8.7% -9.5% so well below BRE recommended target figure of 27%.
- NSL losses 48.5%-49.4% so major adverse. BRE advises if the reduction exceeds 20%
daylight may be affected.

97 Upper Ground Flat 11 Windows W19 F04 and W13 F03 R12
- VSC reduction 40.9%-42.9% so major adverse and noticeable to occupants. Retained VSC
10.4% - 11.7% so well below BRE recommended target figure of 27%.
- NSL losses 32.6%-42.8% so major adverse. BRE advises if the reduction exceeds 20%
daylight may be affected.

97 Upper Ground Flat 12 Windows W18 F04 and W12 F03 R11
- VSC reduction 33-33.8% so moderate adverse and noticeable to occupants. Retained VSC
13% -13.5% so well below BRE recommended target figure of 27%.
- NSL losses 18.6%-22.6%. BRE advises if the reduction exceeds 20% daylight may be affected.

91 Upper Ground
- VSC reduction 24.2%-29% therefore noticeable. Average retained VSC for affected windows
14.4%, so well below BRE recommended target figure of 27%.
- NSL losses 9.7% -30.5% therefore moderate adverse and noticeable. BRE advises if the
reduction exceeds 20% daylight may be affected.

93 Upper Ground
- VSC reduction 26.6%-32.6% therefore moderate adverse and noticeable. Retained VSC
13.7%, so well below BRE recommended target figure of 27%.
- NSL losses 9.7% -30.5% therefore moderate adverse and noticeable. BRE advises if the
reduction exceeds 20% daylight may be affected.

95F Upper Ground: windows W12, R11, F01 and F02
- VSC reduction 29.1% -31.7% so moderate adverse and noticeable to occupants. Retained VSC
is 12.9% so well below BRE recommended target figure of 27%.

95G Upper Ground: windows W12, R10, F01 and F02
- VSC reduction 21.4%-22.6% and therefore noticeable. Retained VSC is 15.8%-16.1% so well
below BRE recommended target figure of 27%.
97 Upper Ground Flat 13 Windows W15 F04 and W11 F03 R10
- VSC reduction 22% -23.5% so noticeable to occupants. Retained VSC 16.3% - 17.7% so well
below BRE recommended target figure of 27%.

b) Access to homes and room uses.

i) GIA repeat the statements in their previous report about assumptions on room layouts and uses and
comment in their response of 22 February 2022 that As Anstey Horne were appointed by CSCB they
would have had greater access. However, CSCB commented on the severe daylight impacts in its first
letter of objection (2 November 2021), and in its second letter of objection (19 January 2022) CSCB
and Anstey Horne recommended that a joint inspection of the affected properties be undertaken to
ensure that there would be full clarity before these issues were reported to members. It is extremely
disappointing that there has been no response to this recommendation and it was not taken up. It could
have contributed to the clarity members will need properly to assess the balance of harm on this
application.

ii) There has been no response by GIA to the material comments about room uses in the Anstey Horne
Report as follows:

The GIA Report states that many of the affected rooms are bedrooms where the expectation for natural
light may not be as great when compared to main living rooms. It should be borne in mind that the
architectural design of the Iroko building is such that rooms can be used for a number of different
functions, depending on the particular needs of the occupants. There are, for example, many examples
whereby rooms classified as bedrooms are currently being used as home offices, a common trend in
this day and age. Further, it is noted that there are many multi-generational families in occupation of
these properties and the daylight impacts will lead to changing patterns of use which will be long-lasting.
It is telling that there is no response from GIA or the developer on this important point. From that we
must conclude that Lambeth Officers and the developer accept the validity of this concern and we ask
for confirmation that the point is accepted.

iii) Dual aspect homes - the original GIA report contained the following wording:

5.7 Based on the information we have sourced, it is clear that the flats facing towards the Former ITV
Studios are dual aspect and receive light from within their internal courtyard also.
5.8 Based on the plans we have been able to obtain, we believe the main living space to the flats facing
onto Upper Ground is likely to face south into their internal courtyard, which will receive very good,
unobstructed, levels of daylight (likely 27% VSC or more).

For such an important issue, affecting residents' daily lives and amenity, this wording is extremely
unclear and it is not surprising that it led CSCB and Anstey Horne to believe that GIA had identified
rooms as dual aspect which are not. GIA have now stated that no mitigating windows to the rear of the
property have been taken into account, but their further statements on this matter e.g 'it is fully
acknowledged that rooms are predominantly single aspect' do not add to the clarity needed for the PAC
to take a balanced decision.

iv) comparable sites: GIA rejects CSCB's concerns about the comparable sites they bring into the
equation. It is worth quoting their comment:

4.26 Contextually similar to 95 Upper Ground, which sits to the direct south of the Former London
Television Centre, River Court has one façade overlooking a clear (river) aspect, with the other facing
onto a dense built up streetscape. The river facing façade of River Court experiences very high VSC
levels due to it's largely unobstructed view of the sky. Having reviewed the technical analysis submitted
as part of the 18 Blackfriars application, the southern façade of River Court sees much lower VSC
levels, generally ranging from circa 5% at ground level, rising to a maximum
of circa 23% at the highest levels.
CSCB's comments are

- The development was not built and a completely new scheme is now being prepared.
- Two other very large developments closer to River Court, South Bank Tower and One
Blackfriars must have already had a serious impact.
- Two wrongs do not make a right.
- GIA might equally have quoted the case of 8 Albert Embankment where, as set out in CSCB's
letter of 19 January 2022, the Inspector was sceptical of such comparisons and where less
severe daylight impacts on neighbouring properties were part of the reason for refusal,
commenting, at para 757 of his report:
-
'In my view, there is a danger in placing too much reliance on such comparisons. Although it is
close to the heart of London, some of the affected accommodation around the appeal site
houses families with vulnerabilities, who have little choice about where they live. Evidence that
links daylight levels with human health, including mental health and disease resistance was
referred to by LV, and is more than anecdotal?. Material reductions in daylight should not be
set aside lightly.'

In addition, it is important that the Council take full account of the fact that the properties
affected are social housing where residents are placed rather than choosing to buy or let. In
this regard, the comments of the Inspector and Secretary of State considering the 8 Albert
Embankment case are highly relevant.

In the case of 8 Albert Embankment, the Inspector and Secretary of State attached substantial
weight to the harm to living conditions of residents and refused the proposals.

2. VSC and NSL effect elevations

At a very late stage in this application, these have enabled CSCB to assess the impacts on individual
homes as set out above.

3. ES Non-technical summary update Feb 2022

This states that
The daylight effects from massing are considered significant adverse to six properties (our emphasis).
The daylight effects to all other surrounding properties are considered not significant.
The schedule above shows that there are major adverse impacts on 14 homes and moderate adverse
impacts on 4 more. The affected homes are mainly in the Iroko coop but 3 are in Mulberry.

4. SCI addendum dated 9 February 2022.

The purpose of this document is stated to be 'to outline the community engagement undertaken by the
applicant since the application was lodged'. It specifically refers to a letter sent to all Iroko residents
dated September 2021 in the following terms

The letter offered residents the opportunity to meet, given they are the closest neighbours to the site,
to hear their thoughts and questions about the possible impact the proposals could have on their home.
The letter provided details of how to contact the team.

The text is of the letter is provided in full in Appendix 2 of the SCI addendum and is reproduced below.
It is remarkable that it makes no mention whatever of any daylight impacts.
Letter sent to Iroko Residents.

Yours sincerely
[Text Redacted]

I write further to our letter of 18
th March 2022. It has come to our intention that one section of this
letter was incorrectly transcribed.

On page 2, the letter reads:
97 Upper Ground Flat 6 windows W19, F03,R18; W30, F04, R29; W31, F04,R30
- VSC reduction 61.1%-63.6% so major adverse and noticeable to occupants. Retained VSC
8.6% -9.8% so well below BRE recommended target figure of 27%.
- NSL losses 18%-48% so major adverse BRE advises if the reduction exceeds 20% daylight
may be affected.

However, it should read:
97 Upper Ground Flat 6 windows W19, F03,R18; W30, F04, R29; W31, F04,R30
- VSC reduction 61.1%-63.6% so major adverse and noticeable to occupants. Retained VSC
8.6% -9.8% so well below BRE recommended target figure of 27%.
- NSL losses 1.8%-35.2% moderate adverse. BRE advises if the reduction exceeds 20%
daylight may be affected.

Apologies for this correction.

Yours faithfully
[Text Redacted]

REVIEW REPORT
on a
DAYLIGHT AND SUNLIGHT ASSESSMENT
for
72 UPPER GROUND LONDON SE1 9PR
1. INTRODUCTION
1.1 Anstey Horne has been commissioned by Coin Street Community Builders Limited to undertake a non-technical review of the daylight and sunlight effects on adjacent Coin Street residential properties associated with the proposed development of 72 Upper Ground, located within the London Borough of Lambeth ("the Proposed Development"). GIA have been appointed to advise on the amenity position and have submitted a standalone report dated 30th June 2021 ("The GIA Report"). GIA have also contributed to the Environmental Statement Chapter dated July 2021 and prepared by Arup ("The ES Chapter") which has been submitted to support a planning application, planning reference 21/02668/EIAFUL.
1.2 The planning application proposal is for the "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".
1.3 Our review has been completed based on the information detailed within the standalone daylight and sunlight report, dated 30 June 2021 and assembled by GIA and the ES Chapter dated July 2021 and prepared by Arup including overshadowing appendices. It is also noted that additional technical information has been provided which relates to daylight and sunlight and forms part of the re-consultation process. Specifically, a document entitled 'ES Non-Technical Summary Update' has been submitted which confirms that there will be significant adverse daylight effects to six neighbouring properties. Furthermore, additional technical information relating to a cumulative study was supplied as part of a document entitled 'Responses to CRE's Environmental Statement Review Report V2'. We agree that the cumulative scenario analysis does not materially change the classification of the light impacts to neighbouring properties
1.4 Central to our instruction and whilst reviewing the contents of the GIA report, we have focussed on the following: -
o Assessment of the assumptions underpinning the study as stated in the applicant's report, as to whether they are robust, and that the relevant surrounding residential properties have been assessed.
o Assessment of the impacts the proposal would have in terms of daylight/sunlight to surrounding residential properties, highlighting failures and degree of impact.
o A review of the methodology used and comments on the results based on BRE guidelines.
1.5 We have not been instructed to undertake a technical analysis to verify the results submitted within the report prepared by GIA, nor have we had sight of any source information used to produce the technical analysis model on which the submitted results are based. However, Anstey Horne did undertake a site inspection on 8th November 2021 to better understand the relationship between the proposed development and neighbouring residential receptors which could in turn experience a reduction in natural light.
1.6 This report has been prepared for the sole benefit of Coin Street Community Builders Limited and references to "you" and "your" refer to this client body. This report may be shared with other Coin Street Group companies and Primary Housing Co-operatives but may not be assigned or relied upon by any third parties without consent in writing by Anstey Horne.
2. ASSESSMENT REVIEW
2.1 The Executive Summary states the technical analysis has been completed in accordance with the guidelines BRE Report 209 Site Layout Planning for Daylight and Sunlight: A Guide to good practice (2011). Further explanation of the methodologies and the assessment criteria has been detailed in Appendix 02 of the GIA Report.
2.2 The assessment relies on results analysed within the GIA 3D digital model whereby the existing conditions (based on the source information referenced in the report and available at the time of their assessment) have been compared to those with the proposed scheme in place. The report notes the 3D analysis model is based on the following information: -
o Proposed scheme drawings by Make Architects (REF IR19-11.05.21-MAKE)
o Measured survey captured by GIA (undertaken 24/09/20)
o Valuation Office Agency (VOA) searches (undertaken 24/09/20)
o Full/partial floor plans for the following neighbouring properties - IBM Building, 95-97 Upper Ground, the Mulberry Bush.
2.3 Assumptions were made where no survey data was available, with window positions at neighbouring properties approximated where there was a lack of survey data - where possible the assumptions were based on observations made during GIA's visit to the area. When an assessment has been based on estimations and assumptions a tolerance should be applied as there is potential for inaccuracies to occur.
2.4 Ideally, window maps would have been included in the report to allow the reader to cross reference the window locations with the assessment results. However, the window labels are shown on the daylight distribution ("DD") drawings which enables appropriate cross referencing. Window maps were included in the Arup report appendices although do not appear to include all properties tested as part of the daylight and sunlight review.
Anstey Horne site visit
2.5 Anstey Horne undertook a physical inspection of several of the closest residential properties to the application site on 16/11/2021. This included the following properties within 95-97 Upper Ground (otherwise known as "the Iroko Building") and also 1 Coin Street:
o 95a Upper Ground (ground, first and second floors)
o 97c Upper Ground (ground, first and second floors)
o Flat 7 (third floor)
o Flat 16 (third floor)
o 1 Coin Street (ground, first and second floors)
2.6 The primary purpose of these inspections was to confirm the internal subdivision and usage of those rooms facing the application site.
2.7 According to the GIA Report, a set of lease plans have been secured and used as part of the internal modelling of the Iroko building. Whilst we have not had sight of the model to verify its accuracy, we have no reason to believe that the room layouts from the lease plans have not been adopted as part of the technical analysis. Further commentary is provided within the GIA Report to state that the flats facing the application site are dual-aspect and therefore also receive light from the direction of the internal courtyard. Having now gained access into a number of flats within this building, we can confirm that this is only true of the ground floor. The floors above are characterised by single-aspect rooms which are used as either living-kitchen-diners or bedrooms. Figure 01 below is an example of such a configuration.
Figure 01 - Example of single-aspect third floor bedroom/living room
2.8 It is therefore quite possible that the GIA Report has included mitigating windows on the rear-aspect of these flats where no window actually exists. This would have the effect of diluting the Daylight Distribution results whereby the changes could in reality be even greater than currently presented.
2.9 Furthermore, the GIA Report states that many of the affected rooms are bedrooms where the expectation for natural light may not be as great when compared to main living rooms. It should be borne in mind that the architectural design of the Iroko building is such that rooms can be used for a number of different functions, depending on the particular needs of the occupants. There are, for example, many examples whereby rooms classified as bedrooms are currently being used as home offices, a common trend in this day and age. Further, it is noted that there are many multi-generational families in occupation of these properties and the daylight impacts will lead to changing patterns of use which will be long-lasting.
2.10 In respect of 1 Coin Street, the GIA Report states that no information has been secured in terms of its internal arrangement. Reasonable assumptions are claimed to have been made, as is considered best-practice in the industry. Given the scale of the percentage alterations outlined, it would be prudent to undertake an internal measured survey of the property with a view to updating the 3D computer model and re-undertaking the various technical assessments.
Impact on the neighbouring properties
2.11 The sensitive receptors are discussed in Section 5 of the GIA Report and lists those neighbouring properties that warrant assessment in relation to daylight and sunlight. The following properties have been stated as being relevant for assessment:
o 95a-95h Flats 1-24-97-97a-97d Upper Ground
o 1 Coin Street
o 91 Upper Ground
o 93 Upper Ground
o Mulberry Bush (PH and flat above) 89 Upper Ground
o 85 Upper Ground
o 87 Upper Ground
o 81 Upper Ground
o 83 Upper Ground
o 77 Upper Ground
o 79 Upper Ground
o 73 Upper Ground
o 75 Upper Ground
o 1 Duchy Street
2.12 Furthermore, it is noted that the neighbouring IBM building, 72 Upper Ground (understood to be in commercial usage) has also been considered, at the request of the London Borough of Lambeth.
2.13 In terms of the scope of review, it is considered that the GIA report has tested the relevant properties surrounding the site which have a requirement for natural light and could, in turn, be affected by the Make Architects scheme proposal at 72 Upper Ground.
2.14 Overall, the GIA Report states that alternative target values have been used which are those akin to an urban setting and in particular the urban grain of 3 similar neighbouring development sites that are reflective of similar massing in an around the vicinity of 72 Upper Ground. This is supported by an independent third-party review of the GIA assessment by Delva Patman Redler LLP, a chartered surveying firm, who agree with this approach.
2.15 These neighbouring recent development sites are: -
o River Court - 18 Blackfriars (16/AP/5239),
o Shad Thames - Tower Bridge Court (19/AP/1975),
o Hobart House - Vauxhall Cross (17/05807/EIAFUL).
2.16 It is noted, however, that our client challenges the relevance of the above development sites to the current situation and the amenity position at the Coin Street residential properties.
Daylight
2.17 Based on the scope of review considered within the GIA Report, it is noted that the following properties will not experience daylight impacts beyond 10% former value of the BRE Guidelines' advisory levels and therefore we consider that the effects of the Proposed Development may not be noticeable to the occupants:
o 73 Upper Ground (VSC losses: 5.5%-7.7%, NSL losses: 0%-1.2%)
o 75 Upper Ground (VSC losses: 5.5%-7.7%, NSL losses: 0%-0.7%)
o 77 Upper Ground (VSC losses: 4.9%-6.9%, NSL losses: 0.1%-2.3%)
o 79 Upper Ground (VSC losses: 4.9%-6.3%, NSL losses: 0.1%-1.2%)
o 81 Upper Ground (VSC losses: 5.4%-7.9%, NSL losses: 0.4%-2.8%)
o 83 Upper Ground (VSC losses: 6.9%-9.2%, NSL losses: 0.1%-2.3%)
o 85 Upper Ground (VSC losses: 8.6%-11.6%, NSL losses: 0.1%-0.6%)
o 87 Upper Ground (VSC losses: 10.7%-14.2%, NSL losses: 0.6%-4.6%)
o 1 Duchy Street (VSC losses: 0%-2.2%, NSL losses: 0%)
o Mulberry Bush (PH), 89 Upper Ground (VSC losses: 0%-24.8%, NSL losses: 1.9%-18.8%)
2.18 There are a number of additional neighbouring properties that experience greater daylight impacts and therefore warrant a more detailed review and consideration:
95a-95h Flats 1-24-97-97a-97d Upper Ground
2.19 This residential block is situated directly south of the application site and contains a large number of windows/rooms within close proximity to the Proposed Development. Whilst assessed as a single neighbouring property within the GIA Report, it comprises of a number of maisonettes on the ground floor, with 21 separate flats located above.
2.20 The GIA Report notes that efforts have been made to secure accurate information detailing the internal subdivision of the building and it appears that lease plans have been used as the basis of the technical review. The assertion however, that all the flats facing the development site are dual aspect is incorrect. Based on the plans provided to Anstey Horne, whilst the ground floor flats do also receive light from the internal courtyard (facing away from the application site), the upper floors have a different internal configuration and rely on light from the direction of the application site.
2.21 The VSC results show that out of 104 windows tested, 41 will experience changes beyond 20% former value. There are 8 windows that record losses between 20%-30% former value. There are also 5 windows that will experience changes between 30%-40% former value with retained VSC values below the 'mid-teens' position put forward within the GIA Report. These losses of light are considered moderate adverse and will be noticeable to the occupants.
2.22 Furthermore, 28 windows will experience VSC reductions ranging from 40%-63.8% former value, at a scale whereby the occupants will notice a potentially unacceptable loss of light. In many instances, the retained levels of VSC are far below the alternative criteria relied upon to justify the amenity effects and in our professional opinion, are of a scale such that the occupants would notice the reduced availability of daylight within the affected spaces. The VSC impacts to these windows are considered major adverse with the retained levels of light below the alternative criteria relied upon within the GIA Report.
2.23 With regards to the NSL method of assessment, the GIA Report states that 57 out 78 rooms tested will not experience a reduction greater than 20% former value. Of the 21 rooms that do not comply with the BRE Guidelines, the losses range from reduction of 22.6%-73.5% compared to former value with 16 rooms experiencing a change greater than 40% former value. These are significant losses of daylight and are considered major adverse. The GIA Report further places some reliance on the retained area of the rooms that are able to see any direct sky across the working plane (taken at a horizontal section of 850mm above the finished floor level). Whilst there are 7 rooms that will achieve a retained NSL level of at least 50%, there are a further 14 rooms that are not able to reach this level such that their pattern of use could be materially affected.
2.24 Therefore, of the 30 rooms performing poorly for VSC which is a test for potential light, 13 of those rooms will also perform poorly when you assess how the potential for light penetrates the room through the NSL method. If the light is already below 50% in the existing scenario or reduced to below 50% in the proposed scenario then the impact is considered to be severe and noticeable to the occupant. The affected rooms are Ground Floor Room R6, First Floor Room R15, Second Floor Room R15, Third Floor Rooms R13, R14, R15 & R16, Fourth Floor Rooms R18, R21, R22, R25, R26 and R28. The GIA Report appears to justify these major adverse effects on the basis that the affected areas are believed to be used as bedrooms. Whilst this is a well-run argument and the BRE Guidelines does suggest that they not carry the same expectation for light when compared to living rooms, a review of the plans demonstrates that several living-kitchen-diners are also significantly affected by the Proposed Development. These comprise of Third Floor Rooms R12, R13, R14, R15 and R16. It is further noted that the original design of 95-97 Upper Ground was such that habitable rooms could be used in a multi-functional and flexible manner. For example, many of the bedrooms on the fourth floor are often used as home studies/ additional living space. Therefore, it would be incorrect to dismiss the amenity effects based on the fact that the majority of the rooms are bedrooms.
1 Coin Street
2.25 In terms of the VSC test, the losses range from 6.8%-46% former value according to the GIA Report. The scale of these reductions is considered major adverse and noticeable to the occupants. The average retained VSC for these windows totals 14.2% which is below the level one might expect even within an urban environment.
2.26 For NSL, the losses range from 5%-14.7% former value and the losses are considered negligible, in our professional opinion.
91 Upper Ground
2.27 In terms of the VSC test, the losses range from 24.2%-29% former value according to the GIA Report. The scale of these reductions is considered minor adverse and may therefore be noticeable to the occupants. The average retained VSC for these windows totals 14.4% which is below the levels one may expect to see within an urban environment.
2.28 For NSL, the losses range from 9.7%-30.5% former value and the losses are considered moderate adverse, in our professional opinion.
93 Upper Ground
2.29 In terms of the VSC test, the losses range from 26.6%-32.6% former value according to the GIA Report. The scale of these reductions is considered moderate adverse and therefore noticeable to the occupants. The average retained VSC for these windows totals 13.7% which is below the level one may expect to see within an urban environment.
2.30 For NSL, the losses range from 9.7%-30.5% former value and the losses are considered moderate adverse, in our professional opinion.
Sunlight
2.31 We agree with GIA's findings that there will be no impacts beyond a negligible impact on the adjacent residential properties. This is due to the orientation of the site located to the north of the neighbouring properties whereby the development will not obstruct direct sunlight to the south facing windows.
3. CONCLUSIONS AND RECOMMENDATIONS
3.1 As part of our instructions, we have reviewed the following specific requirements, discussed in detail below.
o Assessment of the assumptions underpinning the study as stated in the applicant's report, in that they are robust, and that the relevant surrounding properties have been assessed.
o Assessment of the impacts the proposal would have in terms of daylight/sunlight to surrounding residential properties, highlighting failures and degree of impact.
o A review of the methodology used and comments on the results based on BRE guidelines.
3.2 In conclusion, we largely agree with the results and conclusions of the daylight assessment except for the impacts reported for 95a-95h Flats 1-24-97-97a-97d Upper Ground. There are 13 rooms that fall short of VSC and NSL daylight requirements to the point that they are considered unacceptable even when perceived from an Urban Grain perspective which is an argument GIA have run with for justifying light losses within an existing compact urban environment. The occupants / owners / tenants of the 13 rooms affected will notice the drastic light reductions upon implementation of the Proposed Development.
3.3 Those occupants that will be affected by the development will have good reason to object to the proposed development based on the daylight injuries to their properties. The assumptions made within the GIA Report are also not fully accurate, based on a recent site visit to 95-97 Upper Ground (Iroko building) and 1 Coin Street such that a joint internal inspection of the affected properties is strongly recommended.
[TEXT REDACTED]
12th January 2022

THE LONDON TELEVISION CENTRE 60 - 72 UPPER GROUND LONDON SE1 9LT
APPLICATION REFERENCE: 21/02668/EIAFUL
This letter follows an objection dated 2 November 2021 submitted to the above planning application on
behalf of our clients Coin Street Community Builders (CSCB), freehold owners of Prince's Wharf /
Gabriel's Wharf, Mulberry, Iroko, Palm and Redwood housing cooperatives, Coin Street neighbourhood
centre and the Doon Street development site, and leasehold owners of Bernie Spain Gardens and of
the Riverside Walkway from the National Theatre to Oxo Tower Wharf. As previously raised, a number
of these sites are seriously adversely affected by the above planning application.
Impacts on daylight and sunlight of neighbouring occupiers
When we wrote in November 2021, we commented that the impacts on daylight received by adjacent
CSCB housing co-operatives, especially Iroko, will be severe. We advised that a technical report had
been commissioned, and we now attach to this letter the completed report by Anstey Horne. The report
has also had regard to the documents the current subject of re-consultation which include updates to
the ES. It is particularly noteworthy that the updated ES cites the daylight effects from the massing as
'significant adverse'.
Anstey Horne's scope has been to review the planning application document prepared by GIA for the
applicants (dated 30 June 2021), and assessments from GIA incorporated in the relevant Environmental
Statement Chapter (dated July 2021). Anstey Horne were especially asked to review:
o the assumptions underpinning the aforementioned GIA work for their robustness and that the
relevant surrounding residential properties have been assessed; together with
o the impacts the application proposals would have in terms of daylight/sunlight to surrounding
residential properties, highlighting failures and degree of impact.
The Anstey Horne report raises a range of serious issues which need to be addressed by the applicant,
reviewed by officers of the Council, and clearly drawn to the full attention of the Planning Applications
Committee. We would specifically highlight the following:
a) relating to 95-97 Upper Ground, part of the Iroko Housing Cooperative, comprising maisonettes
on the ground, first, and second floors, and 21 duplex flats above:
Para 2.7: According to the GIA Report, a set of lease plans have been secured and used as part of
the internal modelling of the Iroko building? Further commentary is provided within the GIA Report
stating that the flats facing the application site are dual-aspect and therefore also receive light from
the direction of the internal courtyard. Having now gained access into a number of flats within this
building, we can confirm that this is only true of the ground floor. The floors above are characterised
by single-aspect rooms which are used as either living-kitchen-diners or bedrooms.
Para 2.8: It therefore appears that the GIA assessments have taken account of windows on the
rear-aspect of these flats where no windows actually exist. This would have the effect of diluting
the Daylight Distribution meaning that the impacts will be worse than those concluded by GIA.
Para 2.19: The GIA Report notes that efforts have been made to secure accurate information
detailing the internal subdivision of the building and it appears that lease plans have been used as
the basis of the technical review. The assertion, however, that all the flats facing the development
site are dual aspect is incorrect. Based on the plans provided to Anstey Horne, whilst the ground
floor flats do also receive light from the internal courtyard (facing away from the application site),
the upper floors have a different internal configuration and rely on light from the direction of the
application site.
Para 2.21: The VSC results show that out of 104 windows tested, 41 will experience changes
beyond 20% former value.
Para 2.22: Furthermore, 28 windows will experience VSC reductions ranging from 40% - 63.8% of
their former value, at a scale whereby the occupants will definitely notice a significant loss of light.
In many instances, the retained levels of VSC are far below the alternative criteria relied upon to
justify the amenity effects and in our [Anstey Horne's] professional opinion, are of a scale such that
the occupants would notice the reduced availability of daylight within the affected spaces. The VSC
impacts to these windows are considered major adverse with the retained levels of light below the
alternative criteria relied upon within the GIA Report.
b) relating to 1 Coin Street, and 91 and 93 Upper Ground
Para's 2.25 - 2.30: The report highlights impacts which are 'moderate adverse' and with resulting
daylight levels 'below the level one might expect even within an urban environment'. There is further
comment on 1 Coin Street
Para 2.10: In respect of 1 Coin Street, the GIA Report states that no information has been secured
in terms of its internal arrangement. Reasonable assumptions are claimed to have been made, as
is considered best-practice in the industry. Given the scale of the percentage alterations outlined,
it would be robust to undertake an internal measured survey of the property with a view to updating
the 3D computer model and re-undertaking the various technical assessments.
c) There is additionally an important point about room uses, particularly as a result of homeworking
and home-study as a result of the pandemic:
Para 2.9: The GIA Report states that many of the affected rooms are bedrooms where the
expectation for natural light may not be as great when compared to main living rooms. It should be
borne in mind that the architectural design of the Iroko building is such that rooms can be used for
a number of different functions, depending on the particular needs of the occupants. There are, for example, many examples whereby rooms classified as bedrooms are currently being used as home
offices, a common trend in this day and age. Further, it is noted that there are many multigenerational
families in occupation of these properties and the daylight impacts will lead to changing
patterns of use which will be long-lasting.
d) As a general comment, the AH report highlights that:
Para 2.4: Ideally, window maps would have been included in the report to allow the reader to cross
reference the window locations with the assessment results.
e) The report concludes:
Para 3.2: ?There are 13 rooms that fall short of VSC and NSL daylight requirements to the point
that they are considered unacceptable even when perceived from an Urban Grain perspective
which is an argument GIA have run with for justifying light losses within an existing compact urban
environment. The occupants / owners / tenants of the 13 rooms affected will notice the drastic light
reductions upon implementation of the Proposed Development.
Para 3.3: Those occupants that will be affected by the development will have good reason to object
to the proposed development based on the daylight injuries to their properties. The assumptions
made within the GIA Report are also not fully accurate, based on a recent site visit to 95-97 Upper
Ground (Iroko building) and 1 Coin Street such that a joint internal inspection of the affected
properties is strongly recommended.
There are two additional issues CSCB wishes to draw attention to in relation to the residential daylight
impacts:
i) the affected properties are occupied by social housing tenants who are not in a position
to move away in the face of severe daylight impacts if the application is approved.
ii) the applicant has used alternative target values to justify daylight losses which go well
beyond BRE guidelines by reference to the urban setting and in particular the urban
grain of three similar neighbouring developments that are claimed to be reflective of
similar massing in the vicinity of 72 Upper Ground. These neighbouring recent
development sites are:
o River Court - 18 Blackfriars (16/AP/5239). In our view, this development, which has
not been built, is the only one of the three actually in the vicinity, and is far less bulky
and considerably further away from the impacted residential properties.
o Shad Thames - Tower Bridge Court (19/AP/1975),
o Hobart House - Vauxhall Cross (17/05807/EIAFUL).
CSCB challenges the relevance of the above development sites to the current situation
and the amenity position at the Coin Street residential properties
With regard to both i) and ii) above, it is important to recall that the Inspector considering the 8 Albert
Embankment case noted that 'Dr Littlefair did not accept the applicant's view that the 27% 'target' for
VSC is more appropriate to a suburban location, rather than an inner London Opportunity Area where
there are strong policy drivers for achieving greater housing densities. The Judge in the Rainbird case noted that there is nothing in the BRE guidelines that states that this value is derived from a suburban
development or that indicates that its guidelines are only applicable to developments outside an 'inner
city urban environment' ([2018] EWHC 657 (Admin) paragraph 112).'
The Inspector was also sceptical about using other schemes for appropriate comparisons. He
commented, at para 757:
'In my view, there is a danger in placing too much reliance on such comparisons. Although it is close to
the heart of London, some of the affected accommodation around the appeal site houses families with
vulnerabilities, who have little choice about where they live. Evidence that links daylight levels with
human health, including mental health and disease resistance was referred to by LV, and is more than
anecdotal?. Material reductions in daylight should not be set aside lightly.' The Inspector and Secretary
of State attached substantial weight to the harm to living conditions of residents and refused the
proposals.
CSCB submits that this planning application cannot be reported to Committee until all the outstanding
technical points have been resolved; to do otherwise would mean that Officers would be reporting and
Members would be determining an application without accurate information on the impacts and without
being able to weigh the planning balance correctly.
Once the accurate information has been collated and revised assessments undertaken, a further
consultation will be necessary under Regulation 25 of the EIA Regulations as the information 'is
necessary for the statement to be supplemented with additional information which is directly relevant to
reaching a reasoned conclusion on the likely significant effects of the development described in the
application in order to be an environmental statement' (Reg 25(1)). Residents, the CSCB co-ops, CSCB
itself and Anstey Horne can then review and provide further comments in response.
Re-consultation
Whilst writing, we wish to place on record our concern that this current re-consultation has taken place
between 16 December 2021 and 15 January 2022. It is not best practice for a consultation to take
placed over the Christmas and New Year holiday period, when people are away and busy with the
festivities. This is especially the case for an application as controversial as this one.
You will be aware of paragraph 126 of the NPPF which states that 'effective engagement between
applicants, communities, local planning authorities and other interests are fundamental to the creation
of high quality, beautiful and sustainable buildings and places'.
National Theatre Objection
In our letter of 2nd November 2021, we stated:
'As a consequence of the excessive scale and bulk, harm is identified to differing degrees on
surrounding heritage assets. These are namely the South Bank conservation area, IBM Building (grade
II listed), the Royal National Theatre (II*), Pride Sculpture (II), Somerset House (I) and Royal Festival
Hall (I).
We will leave it to others to consider and make representations on the impacts on the listed buildings
mentioned above.'
The National Theatre has subsequently submitted its objections to the scheme, covering many of the
same points CSCB has made, but also highlighting the damage to the setting of this Grade 2* listed
building. CSCB strongly supports the National Theatre's objection.
Additional Planning Policy Issues
Since the submission of our letter of 2nd November 2021, the Council has released a new draft Site
Allocations DPD for consultation. Whilst this new document is a material consideration, it will not have
significant weight until much later in its preparation. The adopted local planning policy, and the London
Plan, remain the primary documents, including Policy PN1 and Site 9 of the Lambeth Local Plan, and
thus the policy requirements for Site 9. The stated design principles and key development
considerations for Site 9 include being sensitive to the surrounding context, improving both the quality
of the built form and public realm and avoiding significant overshadowing of Bernie Spain Gardens. It
is our view that these policy principles are not being met.
Conclusions
Daylight Impacts
CSCB submits that this planning application cannot be reported to Committee until all the outstanding
technical points have been resolved; to do otherwise would mean that Officers would be reporting and
Members would be determining an application without accurate information on the impacts and without
being able to weigh the planning balance correctly.
Once the accurate information has been collated and revised assessments undertaken, a further
consultation will be necessary. Residents, the CSCB co-ops, CSCB itself and Anstey Horne can then
review and provide further comments in response.
In addition, and in any event, it is important that the Council need to take full account of the very severe
impacts on certain neighbouring properties including social housing where residents are placed rather
than choosing to buy or let. In this regard, the comments of the Inspector and Secretary of State
considering the 8 Albert Embankment case are highly relevant.
Strength of Local Objections and Re-consultation
Since the submission of CSCB's objection on 2nd November 2021 significant numbers of other
objections from local people and businesses have been submitted, many of them on similar grounds to
those expressed in CSCB's correspondence. This is clearly a controversial and extremely unpopular
development.
CSCB, and no doubt many of the other objectors, will wish to review and properly assess the revised
amenity assessments and updated ES and so it is vital that the Council allow proper statutory time for
the next re-consultation. As stated above, there is concern that the current consultation being over the
Christmas period has now allowed for thorough local engagement
Additional Planning Policy Issues
Notwithstanding the release of the recent new draft Site Allocations DPD for consultation, the adopted
Lambeth Local Plan, including Policy PN1 and Site 9 remains the primary up to date policy document
and as such the policy requirements to be sensitive to the surrounding context, improve both the quality of the built form and public realm and avoid significant overshadowing of Bernie Spain Gardens. None
of these policy requirements are met.
We look forward to liaising with you further with regard to the points made above.
Yours sincerely
[TEXT REDACTED]

REPRESENTATIONS BY COIN STREET COMMUNITY BUILDERS (CSCB) CONCERNING PRIORITIES FOR THE S106 AGREEMENT RELATING TO THE ABOVE APPLICATION.
1. CSCB has made representations strongly objecting to the above proposed development, on the following grounds:
o The scale, bulk and siting of the proposed development is excessive, overbearing and overly dominant.
o The proposal would not preserve or enhance the character or appearance of the South Bank Conservation Area or its setting.
o It is contended within the planning application documentation that any 'less than substantial harm' is outweighed by public benefits. We strongly disagree that the 'public' benefits listed within the application are sufficient to justify the scale of the proposed development and the harm it will cause the Conservation Area.
o The impacts on daylight received by adjacent CSCB housing co-operatives, especially Iroko, will be severe.
o Instead of improving nearby green open spaces, the proposals cause significant harm through their overbearing nature and through much increased overshadowing of the riverside walkway, especially the site of the consented Queen's Walk Gardens, and of Bernie Spain Gardens.
These objections are also being expressed by many other local stakeholders, both directly and via SoWN (the authors of the statutory South Bank & Waterloo neighbourhood plan), and by local residents.
2. If, despite the extent of local objections to the scheme, the Council is nevertheless minded to approve the proposed development, CSCB asks that very serious and detailed consideration is given to what is needed in the detail to make the development acceptable in planning terms in relation to its very substantial local impacts. Legislation requires that planning obligations must be:
o necessary to make the development acceptable in planning terms;
o directly related to the development; and
o fairly and reasonably related in scale and kind to the development.
We contend that because of these very substantial local impacts any s106 agreement must give far more priority to mitigation in the immediate physical vicinity of the development than has been the case with other recent major applications in South Bank and Waterloo. For example, the s106 agreements for Elizabeth House and the IBM site have given overwhelming priority to affordable workspace and employment and skills with very little money left for local green infrastructure and immediate local mitigation, the latter of which clearly meets all the bullet point tests above.
3. We appreciate that the Council has policies in relation to affordable workspace and employment and skills, but we are not aware of any requirement that these elements be given priority over immediate 'local improvements to mitigate the impact of the development' (Local Plan Policy D4). We also base this submission on our understanding of the three pillars of Council policy on these matters, as set out to SOWN by Cllr Matthew Bennett at a recent meeting: affordable workspace, employment and skills, and the climate emergency (our emphasis). The need to address the latter suggests to us that the creation and improvement of green infrastructure, within the parameters of s106 guidance, should thus be the absolute priority of any s106 agreement from this enormous development. The approach to the s106 agreement being sought in these representations is well supported in Policy D4 of the adopted Local Plan, which identifies, alongside other priorities:
ii. local public realm improvements including streetscape, local public open space, play facilities and community safety;
xix. green infrastructure;
xxi. other sustainability measures, including mitigation of impacts on and/or enhancement of biodiversity and wildlife habitats.
4. Two important CSCB projects, the re-landscaping of Bernie Spain Gardens north park, and the creation of Queen's Walk Gardens, both of which have received planning approval from Lambeth, closely match these headings i.e item ii - local public open space, item xix - green infrastructure, and item xxi - enhancement of biodiversity and wildlife habitats.
Please note that we are using the NPPF definition of green infrastructure here:
Green infrastructure: A network of multi-functional green space, urban and rural, which is capable of delivering a wide range of environmental and quality of life benefits for local communities.
4. CSCB is an active member of SoWN and has been encouraged by reports of the recent productive discussions between SoWN and the Council about priorities expressed in the updated SoWN projects list. As the Council is aware, this includes the two public open green space projects referred to above: the consented improvements to Bernie Spain Gardens north and the new Queen's Walk Gardens. CSCB was particularly encouraged by the references to these two projects in a Lambeth presentation to a meeting between Cllr Mathew Bennett, senior officers and SoWN representatives on 29 April this year. On slide 5 of the LBL presentation to that meeting, in response to the project headings for these two green open space projects, the Council's responses (in italics) were
Improvements to Bernie Spain Gardens north: ITV s106 to be "pooled" for general open space contribution and then allocation made through conversation with SoWN as revenue/ capital contribution to deliver.
Queen's Walk Gardens: Interface with IBM & ITV schemes.
Both SoWN and CSCB made strong representations concerning the low priority given to mitigation in the form of green open space contributions in the s106 for the IBM site consent. We understand that prioritising such improvements in the 72 Upper Ground s106 agreement would receive strong support from SoWN also.
5. We are aware that the proposed new 'cultural facilities' included in the 72 Upper Ground proposals are supported by the Council but would like to make the following points in relation to this particular development.
a) the local objections to this development primarily relate to scale, bulk, and daylight and sunlight impacts. We understand that the cultural (i.e. affordable workspace) component of the development amounts to 11% of the total space. We believe that the affordable workspace component of the development, which the s106 agreement is required to make acceptable in planning terms, is actually adding 11% to the bulk and volume - which is the essence of many objections and most requires mitigation.
b) the affordable workspace policy and the value of the discounts calculated from it are based on the space being used in this way for only 15 years. The green open space and biodiversity benefits of the open space improvements CSCB wishes to see prioritised are permanent - as are the climate, community, public health, and amenity benefits they will deliver.
c) we disagree that the public realm within the development and its greening will meet the necessary obligations for mitigation. CSCB's case is that most of the new 'public' realm provided is in any case necessary for the functioning of the development, and most of the upper areas to be greened will be accessible only to occupiers of the development. This is fully set out in CSCB's main objections to the proposal. There is no doubt, even with the terrace provision, that most occupiers and visitors to the proposed development will also use local green spaces. The ground floor commercial outlets will also draw to the riverside walkway and Bernie Spain Gardens new visitors who will not have access to the terraces.
d) where developments have the effect of intensifying usage of local green spaces, this normally regarded as a case for s106 revenue support in line with Local Plan policies EN1 and ED13B. However, as the Council will be aware, CSCB currently funds the management and maintenance of the riverside walkway and Bernie Spain Gardens and is committed to continuing to do so after the improvements to Bernie Spain Gardens north and Queen's Walk Gardens (for which the Council has granted consent) have been made. The need for capital improvements is both to deliver improved quality and biodiversity, and to provide a more resilient infrastructure to withstand the increased usage caused by neighbouring developments and densification permitted by Lambeth and Southwark Councils. Capital contributions to these spaces will have a more lasting impact than time-limited revenue contributions. Such capital investments are fully supported in para 9.10 of the Local Plan in areas of open space deficiency.
e) In the recently published GLA green infrastructure map data https://apps.london.gov.uk/green-infrastructure/ the vicinity of this development is already in the highest category of need in relation to access to public open space. Even if the cultural facilities proposed are of a different nature than provided by existing South Bank cultural organisations, it cannot be argued that there is any shortage of cultural facilities in this local neighbourhood.
6. CSCB was pleased to note in the recent (5 July 2021) Lambeth Cabinet Report on CIL and S106 the following references:
Para 1.1 'the S106 based contributions which provide capital funding to fund the local impacts of development'. It is these kinds of contributions which are necessary to make increased floorspace on this site acceptable in planning terms. Such contributions used to be a very strong feature in earlier s106 agreements for major developments in South Bank and Waterloo. CSCB believes that this previous approach urgently needs to be reinstated in any agreement to allow densification at 72 Upper Ground.
Para 2.4 and table 12 refer to the results of the Council's survey of residents in Bishop's Ward. This identified three main priorities for planning gain: young people; employment and skills; and Parks, Open Space & Air Quality.
Para 2.13 (a) states:
S106 negotiations - Planning officers will become more aware of the specific needs of local areas that will be impacted by new development. This will help identify more targeted mitigation measures that may be needed to address the impact of new development on local areas?
Note: this has not so far led to any kind of local engagement by planning officers with CSCB or SOWN on the priorities for the 72 Upper Ground s106.
7. CSCB asks that the case set out above is given serious consideration in the negotiation of the s106 agreement for 72 Upper Ground, and that it should be taken fully into account by planning officers negotiating this agreement, in the spirit of para 2.13(a) of the 5 July Cabinet paper above. It hopes that this will lead to priority being given to local public open green space improvements to mitigate the very severe local impacts of any intensification of uses at 72 Upper Ground.
Yours faithfully
[text redacted]

We write on behalf of our clients Coin Street Community Builders (CSCB), freehold owners of Prince's Wharf / Gabriel's Wharf, Mulberry, Iroko, Palm and Redwood housing cooperatives, Coin Street neighbourhood centre and the Doon Street development site, and leasehold owners of Bernie Spain Gardens and of the Riverside Walkway from the National Theatre to Oxo Tower Wharf. A number of these sites are seriously impacted by the above planning application, and we wish to strongly object to it.
You will be aware that the NPPF 2021 contains the following guidance:
126. The creation of high quality, beautiful and sustainable buildings and places is fundamental to what the planning and development process should achieve. Good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities. Being clear about design expectations, and how these will be tested, is essential for achieving this. So too is effective engagement between applicants, communities, local planning authorities and other interests throughout the process.
130. Planning policies and decisions should ensure that developments:
a) will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development;
b) are visually attractive as a result of good architecture, layout and appropriate and effective landscaping;
c) are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities);
d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;
e) optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks; and
f) create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.
132. Design quality should be considered throughout the evolution and assessment of individual proposals. Early discussion between applicants, the local planning authority and local community about the design and style of emerging schemes is important for clarifying expectations and reconciling local and commercial interests. Applicants should work closely with those affected by their proposals to evolve designs that take account of the views of the community. Applications that can demonstrate early, proactive and effective engagement with the community should be looked on more favourably than those that cannot.
Having regard to the above, the applicant's proposals do not take account of the views of the community, which opposes the application in vigorous terms, and have not reconciled commercial and local interests. The proposals:
o are not sympathetic to the built environment, setting and heritage assets;
o do not create an attractive place for workers, residents or visitors;
o do not result in a high standard of amenity for future users; and
o undermine quality of life, community cohesion and resilience.
The reasons for the objection are as below.
Scale, Bulk and Siting
The scale, bulk and siting of the proposed development is excessive, overbearing and overly dominant. The site is prominently located on the South Bank, visible from adjoining bridges, from the Victoria Embankment and areas further to the north of the River Thames. The site forms a vital piece of townscape in London and is positioned in an area of high cultural importance. It is paramount that the redevelopment achieves the objective of delivering the highest quality scheme possible. To do so all aspects of the new buildings must be acceptable, without compromise. The building must stand the test of time and comply with all adopted policy objectives. Regrettably, these high-quality standards have not been achieved in the scheme as proposed.
The volume of the proposed development would create a domineering bulk and massing which would be overbearing for the size of the site. The proportions of the two towers, both individually and when combined, together with the extent of site coverage are excessive and should be reduced in order to achieve a satisfactory outcome. As presently proposed, the planning application fails to satisfy Lambeth Local Plan Policy Q2 Amenity i. by unacceptably compromising visual amenity from adjoining sites and from the public realm and Policy Q7 Urban design: new development ii. which identifies the importance of bulk, scale/mass, siting, to adequately preserve or enhance the prevailing local character.
The proposed development would greatly exceed the proportions of existing buildings, with the effect of dominating its surrounds. The submission documents demonstrate that the proposal would dominate the context of this prominent location. The proposal adversely impacts on the setting of the surrounding townscape, causing harm to the setting, character and appearance of both the South Bank conservation area and adjoining grade II listed IBM Building, and dominating the adjoining Prince's Wharf /Gabriel's Wharf. The proposed height, scale, massing and siting does not satisfactorily consider the relationship with the future redevelopment of the adjoining Princes Wharf/Gabriel Wharf. The proposal fails in the requirement to be sensitive to the surrounding context and fails to improve the quality of the built form and public realm.
Lambeth Local Plan Policy Q24 River Thames applies, and the proposed development fails to satisfy its requirements. As currently proposed, for the reasons explained above, the application scheme fails A i. to enhance the character of the river frontage, views from the river and from the opposite bank; ii. preserve the setting and approaches of the Thames bridges; iii. maintain and create publicly accessible spaces / routes along the river for a continuous riverside walkway.
Lambeth Local Plan Policy Q26 Tall Buildings, supported by Annex 10, identifies the southern part of the site, 'Location 10', as being suitable for a tall building.
Policy Q26 defines tall buildings to be over 45m at this location. The northern element of the proposed development fronting onto Queens Walk, (60.1m) would be categorised as a tall building, along within the southern element (109.4m), to form two towers. It should be noted that 'Location 10' for provision of a tall building does not include the northern part of the site, separated from the southern part of the site by Protected View 8A.1 from Westminster Pier to St Paul's Cathedral. Therefore, criteria within Q26 A applies to the southern tower and Q26B applies to the northern tower.
As a consequence of the scale, bulk and siting of the proposed buildings, the 109.4m tower would fail policy Q26A's criteria i. adverse impact on local views; ii. design excellence; iii. townscape; iv. principles of group composition such as noticeable stepping down in height around cluster edges.
Policy Q26 B states "Outside the locations identified in Annex 10 or as identified in site allocations, there is no presumption in favour of tall building development."
Lambeth Local Plan allocation Site 9 - Design principles and key development considerations does not repeat Annex 10 but rather states "Any proposal for tall buildings on the site will need to be sensitive to the surrounding context and seek to improve the current arrangement/design to improve both the quality of the built form and public realm."
Policy Q26 B continues: "Should tall buildings be proposed outside the locations identified in Annex 10 or as identified in site allocations, the applicant will be required to provide a clear and convincing justification and demonstrate the appropriateness of the site for a tall building having regard to the impact on heritage assets, the form, proportion, composition, scale and character of the immediate buildings and the character of the local area (including urban grain and public realm/landscape features) and ensure points (a) (i) - (vi) are met." The 60.1m tower would, for reasons specified above, also fail policy Q26A criteria i. adverse impact on local views;. ii. design excellence; iii. townscape; iv. principles of group composition such as noticeable stepping down in height around cluster edges.
The 60.1m tower is outside the location identified for a tall building. That is not to say a tall building at this location is not acceptable, but that the policy requirements must be addressed so that any development that comes forward must be to the highest quality standard.
It is acknowledged that the Council granted ITV planning permission for some tall buildings as part of their new studio development in May 2018 (but not as tall or as bulky as those now proposed). That consent was made personal to ITV having regard to the retention of a unique user within the borough and 'the synergies that occur through being co-located in the Cultural Quarter, delivering significant economic and cultural benefits not just for this part of London, but for the city as a whole' (officer report to committee). The proposed development does not retain ITV and bring such synergies. The ITV consent has in any case lapsed and is no longer extant.
The current application needs to be judged against current new policy context, and a proper planning balance needs to be applied to these proposals.
Impacts arising from scale and bulk
As a consequence of the excessive scale and bulk, harm is identified to differing degrees on surrounding heritage assets. These are namely the South Bank conservation area, IBM Building (grade II listed), the Royal National Theatre (II*), Pride Sculpture (II), Somerset House (I) and Royal Festival Hall (I).
We will leave it to others to consider and make representations on the impacts on the listed buildings mentioned above. CSCB wishes to focus on the impact on the South Bank Conservation Area of which its estate forms a large part. The degree of harm caused to the setting of the South Bank Conservation Area would be substantial and the public benefits given are not considered to be of a level to justify the harm. Thus, the test in paragraph 200 of NPPF has not been met.
The planning application documentation refers to pre-application comments from Historic England and the Greater London Authority supporting the proposals, of the possible degrees of harm to heritage assets and to public benefits. However, their actual written correspondence is not immediately evident following a search of the submission documents although the GLA Stage 1 report does identify that less than substantial harm will be caused by the proposal and that they consider the proposal could deliver substantial public benefits.
It is contended within the planning application documentation that any 'less than substantial harm' is outweighed by public benefits. We strongly disagree that the 'public' benefits listed within the application are sufficient to justify the scale of the proposed development and the harm it will cause on the Conservation Area as a consequence.
The scale, bulk and massing of the proposed development would not preserve or enhance the character or appearance of the South Bank Conservation Area or its setting, contrary to Policy Q22 Conservation Areas.
As a consequence of the excessive massing and bulk identified, the application fails to respect the character of the river frontage and surrounding views, contrary to Lambeth Local Plan Policy PN1: Waterloo and South Bank criterion H v.
These policies could be met by reducing the massing and bulk of the proposed development. The matter of public benefits is dealt with below.
Public Benefits
We question the value of the public benefits listed being sufficient to accept the harm caused by the proposed development which would be substantial at this prominent site due to the proposal's scale and permanence.
We do not agree that the provision of new employment space in the CAZ, including affordable workspace, is of sufficient public benefit given the extent of existing employment space within Central London when considered against the scale of harm to heritage assets. The NPPF requires the harm caused to heritage assets to be balanced against public benefits. We have concluded that the claimed 'public' benefits are primarily private benefits for occupants of the building, and much of the harm is to existing public realm, existing heritage assets, and existing adjacent residential properties.
That harm would be reduced by limiting the excessive bulk and massing of the building. A building of reduced scale and massing could still achieve the public benefits identified, such as opening up the frontage to Queen's Walk and the circulation routes to the east and west of the proposed development. These are seen as prerequisites to achieve a good development and capable of being delivered by a less substantial building than that currently proposed.
The extent of public benefits would be more credible if the development supported improvements in line with community priorities such as improving and extending existing green infrastructure. This would somewhat mitigate the impact of the proposed development, particularly the increased use of the riverside walkway and Bernie Spain Gardens that will inevitably result. Such offsets would be tangible, accessible and meet the needs of a wider proportion of society than the so-called 'public' benefits identified within the planning application.
Residential impacts - daylight
The impacts on daylight received by adjacent CSCB housing co-operatives, especially Iroko, will be severe. The application fails to meet Policy Q2 Amenity iv. as the proposals would have an unacceptable impact on levels of daylight and sunlight on adjoining property. We have commissioned a technical report which will be submitted when finalised.
Overshadowing of Public Realm
The Applicant's Environmental Statement Vol. 1 section 8 Daylight, sunlight, overshadowing and light pollution identifies that increased overshadowing of Bernie Spain Gardens and The Queen's Walk Gardens will occur. Irrespective of the advisory targets within BRE Guidelines for sunlight and daylight, harm will be caused as a consequence of the proposed development. This will be to the detriment of those places as being both public open spaces and being within the public realm, enjoyed by the public as incidental and recreational areas. The application is supported by claims as to the extent of wider public benefits, but such impacts on the public realm would completely undermine those perceived public benefits. As presently proposed, the application fails to protect and maintain open space as required by A. of Policy EN1: Open space, green infrastructure and biodiversity Policy Q2 Amenity iv. as it would have an unacceptable impact on levels of sunlight on adjoining outdoor spaces.
The slides taken from the applicant's own material, show very significant overshadowing: (1 & 2) on 21 March, Queen's Walk to the north of the proposed development currently enjoys sunshine throughout the lunchtime peak but would be cast into shadow by the proposed development; (3 & 4) by 3pm the development is still overshadowing a large part of the riverside walkway, including the popular observation platform. It is now also overshadowing a substantial area of Bernie Spain Gardens north park; (5 & 6) by 5pm the proposed development casts all of Bernie Spain Gardens north park into shadow. These are key times for local workers, for local residents and for visitors. The same overshadowing impacts will be felt in September, albeit an hour later due to BST. (The 12 noon March overshadowing impact shown in the applicant's material is similar to the 1pm slide annexed to this letter).
Even at the height of summer, 21 June , the proposed development casts into shadow areas of the riverside and Bernie Spain Gardens that currently enjoy sunshine: (7 & 8) there is currently virtually no overshadowing of the Queen's Walk at 1pm but the proposed development will cast a shadow over a significant part of the riverside, including the benches and flowerbeds of the consented Queen's Walk Gardens; and (9 & 10) by 6pm the development casts most of Bernie Spain Gardens south park into shadow. The impacts will not just be felt by people but by trees and plants. In the winter, when trees have lost their leaves and sunshine is most valued by those using the riverside walkway and gardens, the shadows cast by the proposed development will be longer than any of the annexed slides.
In conclusion, instead of improving nearby public realm, the proposals significantly harm these spaces. This is not just a local issue: the South Bank riverside walkway is currently one of the most visited areas of London. The wanton disregard of one of London's most popular amenities is unacceptable and short-sighted.
New Public Realm and Access Routes
The supporting text to Lambeth Local Plan Policy Q6 Urban design: public realm identifies that "High-quality design is key to delivering sustainable development: it creates successful places, encourages civic pride and can discourage crime. It raises the quality of our environment. The council is committed to securing high-quality design and construction across the borough, especially in opportunity areas".
Lambeth Local Plan allocation 'Site 9 ITV Centre and Gabriel's Wharf, Upper Ground SE' states "The council will support development that: iii. improves pedestrian linkages between Upper Ground and Queen's Walk."
Provision of a new public route is made to the east boundary with Prince's Wharf/Gabriel's Wharf, however, due to its location and configuration its attractiveness will be compromised. The route would be narrow on its south approach to Upper Ground and subject to a 'pinch-point' which would obscure the river setting. It is located adjacent to the proposed service bay, with a dead frontage of solid wall against its southern entrance.
For the above reasons the proposed development fails to satisfy the criteria of Lambeth Local Plan allocation 'Site 9 ITV Centre and Gabriel's Wharf, Upper Ground SE1, and specifically the following criteria: iii. pedestrian linkages between Upper Ground and Queen's Walk; v. reflects the transitional role of Gabriel's Wharf between Bernie Spain Gardens and the river and avoids significant overshadowing of Bernie Spain Gardens;
Claimed public benefits
The applicant claims that, under its proposals, 40% of the site would become 'public realm'. CSCB believes that this overextends the definition of new 'public realm' and exaggerates the benefits being offered. Most of the proposed 'public' realm is in any event necessary for access, circulation and escape within the development and for its setting. The main new internal SW-NE route passes under the centre of the building, is not therefore open to the sky, and would presumably be closed at night (or if not would be unsafe at night). Other sections are to serve retail frontages. Many of the green benefits are offered on spaces only accessible to occupiers of the building. Access arrangements for the top floor of the riverside tall building are not clear.
The 'new' public realm cannot be claimed as a proportionate or satisfactory mitigation of the impact of the scale of the building, the increased occupancy, and the resultant pressure on Bernie Spain Gardens, in particular, that will arise as a consequence.
CSCB is particularly concerned about the interface between the retail element of the development on the riverside and the consented Queen's Walk Gardens. The latter were designed and approved on the principle that they would provide a relaxed space with colourful planting and extensive seating as an escape from the busiest part of the riverside walkway. The application is silent on how its retail proposals will safeguard the aims of this consented scheme.
Impact on Prince's Wharf/Gabriel's Wharf
The proposed development's siting, scale, mass and bulk is excessive with consequential adverse impacts on Prince's Wharf/Gabriel's Wharf. For the reasons detailed above, the proposed development fails to satisfy the criteria of Lambeth Local Plan allocation 'Site 9 ITV Centre and Gabriel's Wharf, Upper Ground SE'.
Furthermore, the proposal is contrary to Policy Q7 Urban design: new development, criteria x. which requires that new proposals "do not prejudice the optimum future development of, or access to, adjoining plots by ? avoiding unacceptable overshadowing or undue sense of enclosure."
It is noted that a detailed daylight and sunlight assessment of future receptors has been scoped out of the Environmental Statement Vol. 1 section 8 Daylight, sunlight, overshadowing and light pollution, as it is claimed no significant effects are anticipated (8.4.6). Prince's Wharf/Gabriel's Wharf adjoins the application site immediately to the east and paragraphs 8.7.41 - 8.7.43 identify that the proposed development would lead to overshadowing at each of the tested dates. Prince's Wharf/Gabriel's Wharf forms part of the Lambeth Local Plan site allocation - Site 9 and, accordingly, the Council must consider the prospect of such impacts upon that future site.
Conclusions
Coin Street Community Builders strongly objects to planning application ref. 21/02668/EIAFUL for the following reasons:
o The scale, bulk and siting of the proposed development is excessive, overbearing and overly dominant.
o The proposal would not preserve or enhance the character or appearance of the South Bank Conservation Area or its setting.
o It is contended within the planning application documentation that any 'less than substantial harm' is outweighed by public benefits. We strongly disagree that the public benefits listed within the application are sufficient to justify the scale of the proposed development and the harm it will cause on the Conservation Area.
o The impacts on daylight received by adjacent CSCB housing co-operatives, especially Iroko, will be severe.
o Instead of improving nearby public realm, the proposals significantly harm these spaces. This is not just a local issue: the South Bank riverside walkway is currently one of the most visited areas of London. The wanton disregard of one of London's most popular amenities is unacceptable and short-sighted.
o The new public route running north south through the proposed development (to the east boundary with Prince's Wharf/Gabriel's Wharf) is not acceptable in its form. It is narrow on its south approach to Upper Ground and subject to a 'pinch-point' which would obscure the river setting. It is also located adjacent to the proposed service bay, with a dead frontage of solid wall against its southern entrance.
o The proposed development's siting and excessive scale, mass and bulk will have adverse consequential adverse impacts on Prince's Wharf/Gabriel's Wharf.
In our opening comments in this letter, we referred to the proposals not meeting paragraphs 126, 130 and 132 of the NPPF. Above, we have referred to many instances where the proposals do not meet the policies of the newly adopted Lambeth Local Plan.
The applicant's proposals do not take account of the views of the community, which opposes the application in vigorous terms, and have not reconciled commercial and local interests. The proposals:
o are not sympathetic to the built environment, setting and heritage assets;
o do not create an attractive place for workers, residents or visitors;
o do not result in a high standard of amenity for future users; and
o undermine quality of life, community cohesion and resilience.
The proposals do not accord with an up-to-date development plan, the proposals create harm that is not outweighed by public benefits, and CSCB and the local community are vigorously against them.
Yours sincerely
[text redacted]

The Twentieth Century Society is the National Amenity Society charged with the protection of post-1914 heritage. We write to object to the proposed development. Please find our statement for the Planning Applications Committee below:
London's South Bank is home to some of the finest post-war buildings and public spaces, and its heritage significance is recognised in numerous listings and in its designation as a conservation area. As outlined in the designation report for the conservation area (1982): "it is important that care is taken to ensure sensitive changes to existing buildings and spaces" here. In the Society's view, the proposed development (which reaches up to 26 storeys) would be an over-development of a site within a sensitive historic environment. The development's substantial size and heavy, riverfront-loaded massing would impact on close views of post-war listed buildings from the Queen's Walk and would impede wide views, particularly of the Grade II* National Theatre from Blackfriars Bridge to the east. It is this that is of most concern to the Society: the National Theatre is one of the UK's most significant modern buildings and its relationship to its exceptionally prominent site is intrinsic to its special interest. It was conceived as an 'urban landscape' whose terraces connected directly with the surroundings, and whose location commanded the bend of the river. The wide views up- and downstream are therefore crucial to its heritage value. The massing of its flytowers must continue to be the dominant feature of views from the adjacent bridges. The Society feels that this would no longer be the case if the scheme, in its current form, gained consent.
To summarise, the Society maintains that the proposed development would seriously harm the character of the conservation area and settings, and therefore significance, of key designated heritage assets nearby, particularly the National Theatre. The scheme contravenes local and national policies regarding the conservation of heritage assets and should not be permitted for these reasons.
Yours sincerely,
[TEXT REDACTED]

The Twentieth Century Society has been alerted to the above application for planning permission for the '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.' The Society was consulted at pre-application stage and provided written feedback on 21 May 2021, outlining the thoughts of our Casework Committee which met to discuss the case on 17 May. We understand that the scheme is unchanged and therefore several of the points made in our letter in May are repeated here.
Background
The site is home to the London Television Centre which was completed in 1978-74 by Alan Roberts of CH Elsom and Partners and which the Society has identified in the past as a non-designated heritage asset. It is situated within the South Bank Conservation Area and is prominent in extensive key views of listed 20th-century buildings. A previous scheme for the site by Hopkins architects for ITV was granted planning permission by Lambeth council on 3 May 2018. This sought the demolition of the existing building and construction of two new buildings, up to 14 and 31 storeys in height, to provide offices, television studios and retail space. The Society objected to this previous scheme's "greatly increased height and generic mass", concluding that It will lead substantial harm to the conservation area, harm to the setting of the Grade II* National Theatre and harm to non-designated assets through the total loss of the London Television Centre and the impact on the IBM Building. We consider that it will seriously compromise the special qualities of the area as set out in the CA statement. In 2018 when this scheme was given consent, the IBM was a non-designated heritage asset. It has since been Grade II listed.
The developers for this new scheme are Mitsubishi Estate and CO-RE, employing Make Architects and the engineer Arup. The proposal includes a 26 storey office tower and lower buildings of 13 to 16 storeys, so similar in height to the consented scheme.
Comments
The Society's casework committee considers the currently proposed new building to be an over-development of a site within a sensitive historic environment. Compared to the existing building, the massing of the proposed new building will be further forward on the riverfront side. The new development will impact close views of the listed buildings from the Queen's Walk and it will also impede wide views, particularly views of the National Theatre from Blackfriars Bridge to the east (we refer to the applicant's Project Vista 04 Blackfriars Bridge).
It is also believed that the proposed new building will limit views from the National Theatre's terraces across the river towards Blackfriars Bridge. The National Theatre is one of the UK's most significant modern buildings and its relationship to its exceptionally prominent site is intrinsic to its special interest. It was conceived as an 'urban landscape' whose terraces connected directly with the surroundings, and whose location commanded the bend of the river. The wide views up- and downstream are therefore crucial to its heritage value. The massing of its flytowers must continue to be the dominant feature of views from the adjacent bridges. Committee members felt that this would no longer be the case if the current proposals gained consent. A higher mass to the rear of the plot would be less problematic.
Lambeth's South Bank Conservation Area Statement (2007) states that the area makes a positive contribution to the character of the Thames and is highly visible in views across the river from the north, from the river, and from the east and south (p.11). The conservation area statement quotes a Town Planning Committee Report from 27th July 1982 which states that "it is important to ensure sensitive changes to the buildings and spaces and that new development is of appropriate quality to the status and appearance of the area" (emphasis added) (p.6).
The London View Management Framework (2012) identifies 27 views and major landmarks in London which should be protected. One such view is the river prospect from Blackfriars Bridge, including southwest views of the South Bank and Grade II* National Theatre (Viewing Location 14A, Assessment Point 14A.1, 'Blackfriars Bridge; upstream'). It notes that
any development on or behind river frontages "should be mindful of the contribution made by the prominent buildings within the view, their prevailing scale and height, and their relationship with the river [?] It should not dominate the relationship that buildings have with the river." (p.130).
Lambeth's Local Plan (2015) states that developments affecting listed buildings will be supported where they do "not harm the significance/setting (including views to and from)" (Policy Q20, Statutory listed buildings). It outlines that developments within conservation areas will be permitted if shown to be "protecting the setting (including views in and out of the area)" (Policy Q22, Conservation Areas). It also notes that "The council will resist harm
to the significance of strategic views" (Policy Q25, Views).
Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 (the Listed Buildings Act) and the National Planning Policy Framework (NPPF, 2021) both outline the desire to preserve the significance of designated heritage assets which includes their setting.
Summary
The Society's Casework Committee believes the proposed new building in its current form would harm the setting of the listed buildings on the site and harm the special character and appearance of the riverfront site, which is both a designated conservation area and positive contributor to a strategic view in London. We therefore urge the local authority to refuse planning permission, and encourage the applicant to revise the design to substantially reduce the building's front massing.

This is a proposal for a vast new clump of steel and glass. It is too massive for the riverfront, not in scale with the surroundings, and domineering.