8 Albert Embankment and Land to the Rear

Transcription

1 8 Albert Embankment and Land to the Rear Representations to Proposed Modifications to the Lambeth Local Plan (Proposed Submission) on behalf of London Fire and Emergency Planning Authority 12 January 2015

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3 8 Albert Embankment and Land to the Rear Representations to Proposed Modifications to the Lambeth Local Plan (Proposed Submission) on behalf of London Fire and Emergency Planning Authority 12 January 2015

4 Representations to Modifications to the Lambeth Local Plan for LFEPA Contents 1. Introduction The Site Land use policy considerations Tall buildings Conclusions and recommended way forward...26 Appendices 1. Planning application decision notice 2. Appeal decision 3. Fire station listing 4. Viability Appraisal 5. Statement by LFEPA 6. Economic Case & Employment Assessment Page 4

5 Representations to Modifications to the Lambeth Local Plan for LFEPA 1. Introduction 1.1 Nexus Planning, on behalf of the London Fire and Emergency Planning Authority ( LFEPA ), are submitting representations to the Proposed Modifications to the Lambeth Local Plan Proposed Submission (November 2014) ( Proposed Modifications ), in accordance with the Town and Country Planning (Local Planning) (England) Regulations The LFEPA own (as freeholder) the property at No.8 Albert Embankment ( Front Site ); land bounded by Whitgift Street, Lambeth High Street, the railway embankment and Southbank House ( Middle Site ); and land on the corner of Black Prince Road and Newport Street ( Rear Site ). Together, the three areas are referred to as the Site. 1.3 The Proposed Submission Draft Local Plan (November 2013) ( Submission Draft Local Plan ) includes a site allocation policy ( Policy Site 10 ), which relates to the Site. 1.4 The Submission Draft Local Plan, Policy Site 10 included a statement on preferred use: Retention/provision of an operational fire station. Mix of uses including residential and employment. Exceptionally, configuration of the site to include some residential within the KIBA boundary may be considered, if it can be demonstrated that this is necessary to achieve an acceptable scheme in all other respects [our emphasis]. The amount of replacement employment should be maximised and should include space for small and medium enterprises. 1.5 The Middle Site and Rear Site are located within the Southbank House and Newport Street Key Industrial and Business Area ( KIBA ). 1.6 The LFEPA did not make representations to the Submission Draft Local Plan. As landowner, the LFEPA was satisfied that Policy Site 10 provided suitable flexibility to consider a case of exceptional circumstances, where some non-kiba uses could be located on the Middle or Rear Sites if this were to be required to provide a development that (i) is viable and deliverable in regenerating the Site, (ii) can secure the restoration of the listed building and provision of an operational fire station as required by Policy Site 10, and (iii) can address all other Site constraints and policy requirements. 1.7 The opportunity to make such a case would be at the time of a future planning application. Page 5

6 Representations to Modifications to the Lambeth Local Plan for LFEPA 1.8 The LFEPA considered that the wording of Submission Draft Local Plan Policy Site 10 reflected the position of the Council and the appeal Planning Inspector, following the consideration of planning application 10/04473/FUL ( the Planning Application ) and subsequent appeal APP/N5660/A/12/ ( the Appeal Decision ). Notwithstanding that the application was refused and the appeal dismissed (for reasons of daylight amenity impact to residential properties on Whitgift Street), the principle of non-kiba development on the Middle and Rear Sites was accepted by the Council and the appeal Inspector due to the wider planning benefits of the proposed development. 1.9 The decision notice for the Planning Application is enclosed at Appendix 1, and the Appeal Decision is at Appendix In the Proposed Modifications, the statement on preferred use in Policy Site 10 is amended to read: Retention/provision of an operational fire station. Mix of uses including residential and employment but respecting the KIBA designation of part of the site. Exceptionally, configuration of the site to include some residential within the KIBA boundary may be considered, if it can be demonstrated that this is necessary to achieve an acceptable scheme in all other respects. The amount of replacement employment floorspace should be maximised and should include space for small and medium enterprises The Proposed Modifications also propose a new annex to the Submission Draft Local Plan ( Annex 11 ), which is a summary of the conclusions of the Lambeth Tall Buildings Study These representations relate principally to the following main modifications as set out in the Proposed Modifications: i. LP191 - p Policy Site 10 ii. LP190 - p Annex 11 (new) 1.13 With regard to the tests of soundness prescribed by the NPPF (paragraph 182), these representations will demonstrate that: i. Proposed Modifications to Policy Site 10, without suitable flexibility to enable development to be delivered, will render the Policy ineffective; the Policy cannot be justified as the most appropriate strategy for providing social infrastructure for the operational requirement of the LFEPA; and the Policy cannot be justified as the most appropriate strategy for delivering the purpose of the KIBA designation which is to provide employment and economic growth; Page 6

7 Representations to Modifications to the Lambeth Local Plan for LFEPA ii. Annex 11, in stating that the curtilages and immediate settings of listed buildings are inappropriate for tall buildings, is not consistent with national policy Accordingly, the Proposed Modifications are unsound and should be revised appropriately Two minor modifications are also sought that relate to matters of consistency within the Submission Draft Local Plan: i. On p158, the boundary for Policy Site 10 (Diagram 2) should be shown in full to include the Rear Site. This should be consistent with the main Policy Site 10 diagram on p.162 which includes the Rear Site. ii. The description of the Site Area within Policy Site 10 should reference the Rear Site so to be consistent with the Site Boundary on p.162. The Site Area should be amended to read: The site comprises 8 Albert Embankment (0.52 ha), the vacant workshop fronting Lambeth High Street (0.68 ha), and land on the corner of Black Prince Road and Newport Street (0.06 ha). Total site area 1.26 ha. Page 7

8 Representations to Modifications to the Lambeth Local Plan for LFEPA 2. The Site 2.1 The Site was formerly the headquarters of the London Fire Brigade. The central administrative function has since been relocated, but an operational fire station remains. 2.2 The whole Site extends to a total area of approximately 1.26 hectares, with the respective areas measuring some 0.52ha (Front Site), 0.68ha (Middle Site) and 0.06ha (Rear Site). Front Site 2.3 The Front Site is located at No.8 Albert Embankment, facing towards the River Thames, to the north of the junction with Black Prince Road and adjacent to the south of the International Maritime Organisation building at No.7 Albert Embankment. 2.4 The site is known as the London Fire Brigade Headquarters and served that purpose since its construction in 1937 until 2008 (when the London Fire Brigade relocated the majority of its functions from the Site to modern offices in Southwark). The nine storey building is Grade II listed. (The listing of the building is enclosed at Appendix 3.) 2.5 The basement to second floors of the building are still currently occupied by the LFEPA and utilised as an operational fire station (sui generis use). The other upper floors, that originally provided offices and purpose built residential accommodation for fire fighters, are now vacant. 2.6 To the rear of the southern part of the main building is a part three, part four storey 1970s concrete building, which was constructed as a Command and Mobilisation Centre. 2.7 In the space between the rear of the main building and the 1970s extension is an open yard with access onto Albert Embankment (to the north of the front building) and Lambeth High Street. Within the yard, there is a separate Grade II listed drill tower (listing also at Appendix 3). Middle Site 2.8 The Middle Site is located directly behind the Front Site, and faces onto Lambeth High Street which separates the two. The Middle Site is bounded by Whitgift Street to the north, by Southbank House to the south, and by the railway embankment to the east (rear). 2.9 Southbank House is a Grade II listed office building (five storeys plus setback attic), with a linear footprint along Black Prince Road. Along Whitgift Street are residential properties in the five storey Whitgift House and a modern flatted building at No.2. Page 8

9 Representations to Modifications to the Lambeth Local Plan for LFEPA 2.10 Beyond Southbank House to the south, is an area of new development, with commercial and residential uses located between Salamanca Place, Salamanca Street and at No.9 Albert Embankment. Salamanca Tower has a 17 storey height At No.81 Black Prince Road (between Salamanca Place and the viaduct), is a recently constructed 23 storey building (including basement), which comprises 1,770sqm of commercial floor space and 101 flats The Middle Site currently contains a four storey building at the front (with offices on the upper floors), with a large two storey workshop at ground floor level and behind, running the length of Whitgift Street to the railway viaduct. This building was occupied by the London Fire Brigade, who used it for administrative functions, parking and maintenance of vehicles, and storage. It is now vacant. Rear Site 2.13 The Rear Site is located on the corner of Black Prince Road and Newport Street, separated from the Middle Site by the railway viaduct. It currently comprises an area of vacant hardstanding. The site is bounded to the north by the former Ragged School at 22 Newport Street, currently used as the Beaconsfield Art Gallery. To the east, beyond the Rear Site, is predominantly low-rise residential accommodation two to four storeys in height. Page 9

10 Representations to Modifications to the Lambeth Local Plan for LFEPA 3. Land use policy considerations 3.1 The soundness of the Proposed Modification to Policy Site 10 (reference LP191; page163) is considered below in respect of the current policy context in relation to the following: i. Regeneration of Vauxhall ii Viability and deliverability of development iii. Community infrastructure/operational needs of the LFEPA iv. Local employment and economic objectives i. Regeneration of Vauxhall 3.2 Policy Site 10 must be considered in the context of its location: London Plan 3.3 The Front Site and Middle Site are within the London Plan Central Activities Zone ( CAZ ). Under London Plan Policy 2.11 (Central Activities Zone Strategic Function), for development proposals that increase office floorspace, boroughs should include a mix of uses including housing (unless in conflict with other policies i.e. the KIBA designation of the Site). 3.4 The whole Site is within the Vauxhall, Nine Elms & Battersea Opportunity Area, as defined by Local Plan Policy The Mayor will encourage the area s growth potential and seek to optimise residential and non-residential output and densities, provide necessary social and other infrastructure to sustain growth, and, where appropriate, contain a mix of uses (Policy 2.13 B(b)). 3.5 Annex 2 of the London Plan sets out that the Vauxhall, Nine Elms & Battersea Opportunity Area has scope for significant intensification with an indicative employment capacity of 15,000 and a minimum of 10,000 new homes, increasing to at least 16,000 with public transport improvements. Vauxhall Nine Elms Battersea Opportunity Area Planning Framework SPG 3.6 To support the London Plan, the Mayor has produced the Vauxhall Nine Elms Battersea Opportunity Area Planning Framework SPG (March 2012) ( OAPF ). This aims to realise the optimum development potential of the area with 16,000 new homes and 20,000 25,000 new jobs. Page 10

11 Representations to Modifications to the Lambeth Local Plan for LFEPA 3.7 The OAPF provides a land use strategy to deliver growth. The Site is located in an area in which High density mixed use housing-led intensification is anticipated (paragraph 4.2 and Figure 4.1 Land use strategy). These areas will come forward for housing-led development with a mix of commercial and community uses to support existing emerging communities (paragraph 4.2). 3.8 Also at paragraph 4.2, it is acknowledged that At Albert Embankment, Lambeth s employmentretention policies will continue to apply. But the important point to be made is that should reason be accepted why Lambeth s retention policies, on a particular site for specific individual material considerations, should not continue to apply, the appropriate use will be mixed use housing-led, consistent with the strategic vision for the area. 3.9 The OAPF land use strategy for office and commercial development is areas of commercial intensification around Vauxhall Cross and Battersea Power Station. Submission Draft Local Plan including Proposed Modifications 3.10 At paragraph 11.7, the Submission Draft Local Plan recognises that Vauxhall is part of the OAPF At paragraph 11.14: The level of development proposed in the OAPF is welcomed if it will deliver a radical uplift in the fortunes of the area and transform it into a successful place that will drive economic benefit for the borough as a whole And at paragraph 11.16: Vauxhall will be visibly transformed into a prestigious and high quality location with an accessible new district centre [around Vauxhall Cross]. Opportunities to strengthen economic activity and bring new employment will lie in attracting new business sectors such as health, telecommunications and media, and creative industries. New and affordable homes will complement this economic activity and reflect changing lifestyles across the capital The Submission Draft Local Plan clearly supports the regeneration objectives of the OAPF Policy PN2 promotes mixed use development (across the whole policy area) that contributes to a new district centre (in the southern part of the policy area) including retail, employment, housing and other uses in line with its OAPF. Policy PN2(a) seeks at least 8,000 new jobs (including construction jobs) and 3,500 new homes in the Vauxhall area. Page 11

12 Representations to Modifications to the Lambeth Local Plan for LFEPA 3.15 The Site is located within a character sub-area defined by Policy PN2 Lambeth Gateway. Development that is appropriate to the characteristics and role of this location (Policy PN2(k)) will include those that embrace the appearance and character of Albert Embankment, with active ground floor frontages and an expanded range of employment and residential uses At Policy PN2(i), new development should respect strategic views and local contextual considerations including heritage assets, existing character, and neighbouring residential amenity At Policy PN2(o), it is stated that single use buildings will not be supported under any circumstances except in the KIBA. It is clear that the KIBA constraints run contrary to the more flexible mixed use development promoted throughout the Vauxhall Policy PN2 area Policy Site 10 is one of just four site allocations within the Vauxhall Policy PN2 area. The Council recognises the potential of the Site for redevelopment; and this must be in the context of and consistent with the OAPF, otherwise it would be inappropriate for the site to be included in the OAPF Policy Site 10 seeks a mix of uses on the Site, including residential and employment This element of the Policy is certainly consistent with the OAPF. However, Policy Site 10 also requires that any use respects the KIBA designation of the Middle Site and Rear Site, effectively limiting residential to just the Front Site Then Policy Site 10 requires that the amount of employment floorspace (across the whole Site) be maximised, which is not consistent with (i) the first part of the preferred use section of the Policy which seeks for residential and employment and (ii) the design principles and key development considerations part of the Policy which confirms that the Council will support residential development that provides an acceptable mix, tenure split/distribution of residential accommodation. LBL Vauxhall SPD (January 2013) 3.21 The SPD translates the OAPF and Submission Draft Local Plan Policy PN2 into a level of detail that can be realised at a more local level The Site is located within the Lambeth Gateway subarea. At paragraph 5.12, Lambeth Gateway will include: around 340 new homes and provide at least 630 new jobs (including Page 12

13 Representations to Modifications to the Lambeth Local Plan for LFEPA construction) ; strengthening the mix and concentration of uses ; and proposals for the Fire Station will need to be carefully considered given its special character and visibility on the riverside At Figure 5.12, the Front Site is shown suitable for residential/employment; and the Middle Site is shown suitable for residential. Effectiveness of Policy Site 10 in Delivering Regeneration 3.24 Policy Site 10 is not clear in what development is intended to happen over the life of the plan and where this will occur Regard is had to the NPPG (Reference ID: , paragraph 002), which requires that a Local Plan must make clear what is intended to happen in the area over the life of the plan, where and when this will occur and how it will be delivered The purpose of Policy Site 10 is to deliver regeneration development. Taking just the Front Site, the Policy is inconsistent with itself by requiring both (i) the maximum amount of employment floorspace and (ii) a mix of uses including residential. To maximise employment floorspace, it follows that 100% employment is required across the whole Site. It is unclear how much (if any) residential use would be appropriate In the Submission Draft Local Plan, Site Policy 10 sought that the amount of replacement employment should be maximised. This provided appropriate flexibility to take into account the number of jobs and employment densities, rather than a more simplistic measure of floorspace as now proposed Across the Middle and Rear Sites, in accordance with Policy Site 10, there is no flexibility to provide a mix of uses. This emphasises the inconsistency within the policy. It is not possible to reconcile the KIBA requirement, or to maximise the amount of employment floorspace, with a deliverable mixed use development The LFEPA is not going to develop the Site itself. It is dependent on a third party to bring forward development under a commercial agreement with the LFEPA. For there to be such an agreement, there must be a known and consistent planning policy position for the Site it must be clear what development is appropriate and where on the Site it can be delivered. Currently, Policy Site 10, as a site allocation, is ambiguous, without the necessary clear what or where. Page 13

14 Representations to Modifications to the Lambeth Local Plan for LFEPA 3.30 Accordingly, in light of the Proposed Modifications to Policy Site 10, the fallback position of the LFEPA is likely to simply hold onto the land until the planning position is made clear. This would be at some unknown point in the future, and likely to be subject to a further Local Plan review The Site will be sterilised and is highly likely to remain vacant. Policy Site 10 will not deliver the redevelopment of the Site within the plan period. The regeneration benefits sought by the London Plan and emerging Local Plan, including new homes, affordable housing, new jobs, active ground floor uses, a more attractive built and landscaped environment, will not be delivered Site Policy 10 is not sound because it is not effective. ii. Viability and deliverability of Development 3.33 In the preparation of a Local Plan, the NPPF (paragraph 173) is clear that: Pursuing sustainable development requires careful attention to viability and costs in planmaking and decision-taking. Plans should be deliverable. Therefore, the sites and the scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable Policy Site 10 places significant requirements on any development. These include: Retain/provide an operational fire station; Restoring/reusing the listed buildings, without radical alteration or extension; Respecting the silhouette of the former headquarters building as viewed from across the river; Retaining the ventilation obelisk on the Site; An appropriate scale and massing in context of neighbouring buildings, townscape and heritage sensitivity; The need to protect residential amenities; The provision of active frontages along Black Prince Road and Lambeth High Street; Page 14

15 Representations to Modifications to the Lambeth Local Plan for LFEPA Public realm improvements to Albert Embankment, Lambeth High Street, Black Prince Road and Whitgift Street; Space for small and medium enterprises; An acceptable mix, tenure split, and distribution of residential accommodation; The potential to connect to a future district-wide combined head and power network Under Policy Site 10 of the Submission Draft Local Plan, there was suitable flexibility (as an exceptional provision if it is necessary to achieve an acceptable scheme in all respects ) to include some residential within the KIBA boundary (on the Middle Site and/or Rear Site) An acceptable scheme in all respects must include viability considerations to allow the deliverability of development The policy wording in the Submission Draft Local Plan made provision to enable a viability assessment to be carried out at the time of a planning application, and for this to inform the appropriate and optimum mix of uses across the whole Site The Proposed Modifications to Policy Site 10 do not allow any flexibility to consider non-kiba uses on the Middle or Rear Sites, even if such uses (predominantly residential) are necessary to provide a viable and deliverable development The Council has prepared a Draft Lambeth Local Plan 2013 Viability Study (February 2013), which has tested the impact of the Council s affordable housing policies and other requirements sustainability, Lifetime Homes, CIL and Mayoral CIL on the deliverability of development. The Viability Study carried out a policy sifting exercise of the Submission Draft Local Plan, but did not include any viability assessment of Policy Site For the Proposed Modifications to Policy Site 10, no further viability work has been carried out by the Council A viability appraisal ( Viability Appraisal ), to consider the viability and deliverability of development in accordance with Proposed Modifications Policy Site 10, has been carried out by JLL on behalf of the LFEPA (Appendix 4) The approach taken by the Viability Appraisal has been to identify the greatest potential scale of building, to maximise floorspace, which could be accommodated on the Site. To do this, the Viability Appraisal has had regard to the floorspace quantum of an alternative development scheme ( Revised Scheme ) that was drawn up by Native Land to address the reason why the Page 15

16 Representations to Modifications to the Lambeth Local Plan for LFEPA Appeal was dismissed for reason of daylight impact to neighbouring residential properties. Although this Revised Scheme was not pursued as a further planning application, it is considered suitable as an illustrative maximum floorspace for the purposes of the Viability Appraisal Using this illustrative maximum floorspace, the Viability Appraisal tests two options: (i) the mix of employment and residential uses as provided by the Revised Scheme and (ii) a KIBA compliant scheme ( KIBA Scheme ) with 100% workshop/office space on the Middle and Rear Sites The construction costs of the Revised Scheme were derived by the appellant at that time (November 2013), which included the re-provision of a Fire Station on the Front Site, and took account of the planning policy requirements at that time. The construction costs for the KIBA Scheme are less The Viability Appraisal concludes that for the KIBA scheme, a negative land value of minus 13,500,000 is produced. The build cost rate is higher than the capital value; therefore the development is unviable and cannot be delivered For the KIBA Scheme, the Viability Appraisal includes sensitivity analysis with different levels of KIBA rent. Even if all KIBA compliant floorspace was let for 25 per sq ft, the land value remains severely impacted In comparison, the Viability Appraisal for the Revised Scheme, with a mix of uses, including some residential in the KIBA designated Middle and Rear Sites, shows the Site to have a land value of 43,000, Accordingly, the Viability Appraisal demonstrates that some residential land use, because of its greater value, has to be provided on the Middle or Rear Site if development is to be viable and deliverable As such, the Proposed Modifications would render Policy Site 10 ineffective because a viable development, in accordance with the Policy, could not be delivered over the plan period. For this reason, Policy Site 10 is unsound Further, given that the scale of obligations and policy burdens required by Policy Site 10 severely threatens the ability for the Site to be developed viably, Policy Site 10 is also unsound because it is inconsistent with national planning policy (NPPF paragraph 173). Page 16

17 Representations to Modifications to the Lambeth Local Plan for LFEPA iii. Community infrastructure/operational needs of the LFEPA 3.51 The existing fire station on the Site (Lambeth fire station) is an element of social/community infrastructure. The London Plan (2011) specifically identifies fire stations in this way (paragraph 3.86) The NPPF (paragraph 7) identifies the social role of sustainable development, which should provide local services that reflect the community s needs and support its health. A core planning principle (NPPF paragraph 17) is that planning delivers sufficient community facilities and services to meet local needs. Planning policies should plan positively for the provision of local services to enhance the sustainability of communities (NPPF paragraph 70) In the London Plan (2011), Policy 3.16 requires social infrastructure provision to meet the needs of its growing and diverse population The LFEPA has provided a statement regarding Lambeth fire station (Appendix 5), in which it is clear that a fire station on the Front Site has to be re-provided, with significant investment for it to meet modern requirements. Key matters in this statement are set out: Lambeth fire station is of key importance to the London Fire Brigade; Lambeth is the only fire station within the Government Security Zone; Its location provides effective operational deployment; The fire station s risk profile will increase with wider developments in the Vauxhall and Nine Elms regeneration area; Lambeth fire station hosts the Rapid Response Team which has key terrorist attack response capabilities; Lambeth fire station needs to be maintained and re-provided as part of any redevelopment of the Site. Alternative site searches have been undertaken, but no suitable sites found; One of the key objectives of the LFEPA s Asset Management Plan is to provide fire station facilities fit for the 21 st century; The demands on the fire station continues to alter with changing risks facing London such as terrorist threats, increased risk of flooding and population growth; Fire vehicles are larger and more specialist; Lambeth fire station is nearly 80 years old and requires significant modernisation. It has many primary deficiencies and is not fit for purpose; The LFEPA s Corporate Property Project is aimed at releasing the latent value in the Site so to re-provide a fire station and reinvest any uplift in the rest of the LFEPA s estate; Page 17

18 Representations to Modifications to the Lambeth Local Plan for LFEPA The LFEPA has an approved Standard Fire Station Design Brief which would need to be met to ensure the re-provided fire station meets modern requirements; LFEPA s resources are stretched. It has not proved possible to provide sufficient investment to enable the required refurbishment and redevelopment of fire stations to be met; A retained/re-provided fire station must be located to provide suitable accessibility, ingress and egress onto the highway network direct access onto Albert Embankment is necessary The ability for the LFEPA to re-provide a fit for purpose, operational fire station on the Front Site is an essential part of any redevelopment for operational needs and capacity of the LFEPA. This is reflected in the Proposed Modifications to Policy Site 10 that maintain an operational fire station as the preferred use. The opportunity to release the latent value of the Site, to fund the required fire station social infrastructure in this location, is a key element of the LFEPA s Corporate Property Project and Asset Management Plan For a fit for purpose fire station to be provided, Policy Site 10 must be effective in allowing a viable and deliverable redevelopment to come forwards. It is demonstrated that the Proposed Modifications to Policy Site 10 will not deliver the redevelopment of the Site and wider regeneration benefits because (i) the Policy is ambiguous, without a clear what development is appropriate and where on the Site is can be delivered; and (ii) the development in accordance with the Policy is unviable if restricted to a KIBA compliant land use across the Middle and Rear Sites Accordingly, the Proposed Modifications to Policy Site 10 will also be ineffective at delivering the re-provision of an operational fire station and for this reason are unsound Given the great emphasis of the NPPF to the social dimension of sustainable development, where planning should deliver sufficient community facilities and services to meet local needs, the Proposed Modifications to Policy Site 10 are also unsound because (i) it is not justified as the most appropriate strategy in delivering community infrastructure and (ii) it is inconsistent with national policy. iv. Local Employment and Economic Objectives 3.59 The Middle Site and Rear Site are located within Southbank House and Newport Street KIBA, as currently designated under Lambeth LDF Core Strategy (adopted January 2011) Policy S3. Page 18

19 Representations to Modifications to the Lambeth Local Plan for LFEPA The KIBA is proposed to be retained in the Submission Draft Local Plan, designated under Policy ED The purpose of the KIBA designation is to provide employment and economic growth. To achieve economic prosperity and opportunity for all, the strategic objectives of the Submission Draft Local Plan are to: 2. Support the growth of key economic sectors and innovation through the development of new shops, offices and visitor accommodation, by maintaining a varied supply of business premises and through plans for town centre regeneration. 3. Increase the number and variety of job opportunities for local people by protecting land for commercial use within neighbourhoods and seeking contributions to employment and skills support programmes. (Submission Draft Local Plan, p.33) 3.61 Within a KIBA, Policy ED1 states: Development in KIBAs will be permitted only for business, industrial, storage and waste management uses, including green industries and other compatible industrial and commercial uses (excluding large scale retail) that are ancillary to, or providing for, the needs of the KIBA The Policy clarifies (Submission Draft Local Plan, paragraph 6.5) that business, industrial and storage uses include all B use classes. The Policy does not make any provision, either through criteria or identified exceptions, for other uses (including residential) within a KIBA It has been shown that for development on Policy Site 10 to be viable and deliverable, a mix of uses, including some residential, is necessary on the Middle and Rear Site The fallback position is that significant regeneration development on the Site will not happen the requirements of Policy Site 10 cannot be delivered because development is unviable. In this situation, the LFEPA may do nothing with the Site because there is no viable option, or, as an interim measure, may choose to refurbish and reuse the existing buildings on the Middle Site in a manner that is KIBA compliant. Such refurbishment/reuse development could be attractive because it would not prejudice future comprehensive development of the Site (at a time when different planning policies would allow this) and could be implemented without triggering the greater requirements of Policy Site An Economic Case and Employment Assessment ( ECEA ) has been provided (Appendix 6), which illustrates that a flexible mixed use development will make a greater contribution towards Page 19

20 Representations to Modifications to the Lambeth Local Plan for LFEPA the strategic objectives of the Submission Draft Local Plan to (i) support the growth of key economic sectors and (ii) increase the number of job opportunities for local people than the alternative fallback position Although the Appeal Scheme was dismissed, the development that was proposed is taken as a benchmark example, as a viable (at that time) mixed use scheme for the Site. Growth of key employment sectors 3.67 The ECEA also details (paragraph 2.3) that KIBAs were originally designated in the Lambeth Unitary Development Plan 2007 to protect employment sites, particularly in the manufacturing sector. However, the ECEA demonstrates (paragraph 2.1) that overall industrial and manufacturing employment in Lambeth has decreased from 3.4% in 2001, to 2% in 2008, and to 0.9% today. The decline in manufacturing is most evident in the Lambeth Employment Land Review Update (2013) - in the low growth forecast, manufacturing is projected to reduce by between a third and two thirds under any scenario (ECEA paragraph 4.4). The ECEA concludes (paragraph 4.3) that this decline is structural, not reflective of the business cycle Further, given the adjacency of the Site to residential properties, it is considered that B2 industrial uses and B8 storage and distribution uses, including waste management uses, would be inappropriate due to impacts upon these neighbouring amenities. B8 uses would also be constrained by the road network covering the actual KIBA site, which are unsuitable for HGV access (ECEA paragraph 5.8) The ECEA details (paragraph 4.3) that the Lambeth Employment Land Review Update (2013) reveals that the borough s growth sectors are predominantly business services, communications, construction, hospitality and health Some of these uses fall within a B use class and are KIBA compatible. However, some are clearly in other uses classes, such as A2, A3, C1, D1 and D2, which cannot be accommodated within a KIBA. The ECEA identifies (paragraph 4.4) that KIBA compatible uses are evidently not matched to the growth sectors of the local Lambeth economy Where there is alignment between growth sectors of key economic sectors and KIBA compatible uses is with some B1(a) business services uses. However, analysis in the ECEA (paragraphs ) demonstrates that the successful growth of office based businesses is not dependant, nor predicated, upon KIBAs. Estates Gazette Interactive 2012 identifies that there is 203,246sqm of vacant B1(a) floorspace in the borough, with 98% of this in non-kiba Page 20

21 Representations to Modifications to the Lambeth Local Plan for LFEPA locations. The ECEA notes (paragraph 3.9) that the Lambeth Employment Land Review Update (2013) reveals that the South Bank, Waterloo and Vauxhall had the largest quantity of vacant B class floorspace Against this supply, the London Office Floorspace Projections 2014 (Peter Brett 2014) is the most recent in a series of independent reviews of office market trends commissioned by the GLA (ECEA paragraph 3.10). This derives a 25 year office space demand forecast based on office employment projections. The projection for Lambeth is for 149,000sqm additional office floorspace from 2011 to 2036, an average of 5,960sqm per year For offices on the Site, the Viability Appraisal (Appendix 4) identifies that there is a relatively low commercial value driven by limited demand for workspace in the area, ample supply of space in the vicinity and the high volume of KIBA space Given (i) that the provision and growth of B1(a) offices has occurred outside of KIBAs and (ii) that the location of the Site is weak in supporting large scale office development, any policy which seeks to safeguard the KIBA for office employment is questioned With regard to what would be an appropriate and optimum mix of uses on the whole Site, it would be for a planning application to make the case at the time of its submission In summary: i. many KIBA uses are unsuitable for the Site because they are bad neighbour uses; ii. B8 uses are constrained by the local road network; iii. office supply is not dependent on the KIBA; iv. the KIBA does not cater for all of the growing sectors of the local economy and hence is constrained as an employment generation policy; v. growing employment sectors tend to be more neighbourly uses that can be readily accommodated as part of mixed use developments Accordingly, a flexible mixed use policy for the Site would be more compatible with the strategic objective of supporting the growth of key employment sectors, than the inflexibility inherent in the reference to the KIBA designation in the Proposed Modifications to Policy Site 10. Number of jobs 3.78 The Middle and Rear Sites, designated in the KIBA, do not currently generate any jobs. The Middle Site is vacant, whilst the Rear Site has not generated any jobs for many years. Page 21

22 Representations to Modifications to the Lambeth Local Plan for LFEPA 3.79 With regard to the benchmark Appeal Scheme for a mixed use development, the ECEA at Figure 11 identifies a total employment yield (direct and indirect jobs) of 1,188 on the Middle Site. In comparison, KIBA compliant uses on the Middle Site would provide only 272 jobs less than 25% of the mixed use scheme Such a significant increase in employment can be achieved through maximising employment provision through far greater employment densities and optimising the amount of employment floorspace in the context of a deliverable development With regard to jobs for local people, the ECEA makes reference (paragraph 3.12) to detailed analysis conducted for a report submitted in support of the Planning Application - 8 Albert Embankment and Adjoining Sites Economic Case & Employment Assessment (Hunt Dobson Stringer 2010). In this report it is detailed that only 9.8 per cent of jobs in this KIBA were held by Lambeth residents. This was by far the lowest proportion of any of Lambeth s KIBA sites. The other KIBA locations range from 15.7 per cent to 72.1 per cent of jobs in each area going to local residents, with the average being around 23 per cent. The existing KIBA is not fulfilling its purpose of providing jobs for local people For new major development, the Council, through its S.106 Planning Obligations SPD, will require various employment and training measures. These will provide training opportunities for local labour in construction; a financial contribution towards local general employment training to ensure access to the labour market by all Lambeth residents; and small business start-up space or community based workshops in developments as appropriate Through working with the Council, in the context of its adopted SPD, new development on the Site would seek to deliver significantly more jobs and employment opportunities for local people than the current situation A deliverable mixed use scheme would be more compatible with the strategic objective of increasing the number of jobs overall and the employment opportunities for local people than the fallback position which would result if the Proposed Modifications to Policy Site 10 are adopted. Conclusion 3.85 Accordingly, it is demonstrated that the KIBA designation on the Site cannot be justified as the most appropriate strategy in delivering economic growth through (i) supporting the growth of key Page 22

23 Representations to Modifications to the Lambeth Local Plan for LFEPA economic sectors and (ii) increasing the number and variety of job opportunities for local people The KIBA designation of the Middle and Rear Site, given that it does not allow a flexible mix of uses to provide a deliverable development, cannot be justified as the most appropriate strategy for delivering the purpose of the KIBA designation which is to provide employment and economic growth. For this reason, Policy Site 10 is unsound. Page 23

24 Representations to Modifications to the Lambeth Local Plan for LFEPA 4. Tall buildings 4.1 The Lambeth Tall Building Study (final draft August 2014) ( Tall Building Study ) was produced in 2012 to provide an evidence base in support of the Submission Draft Local Plan, in particular Policy Q26 Tall and large buildings. 4.2 The approach taken by the Tall Building Study is to identify areas within the Borough that are appropriate, sensitive or inappropriate for tall development. 4.3 The Submission Draft Local Plan (paragraph ) takes the definition of a tall building from the London Plan as those that are substantially taller than their surroundings, cause a significant change to the skyline, or are larger than the threshold sizes for the referral of planning applications to the Mayor. 4.4 The Front Site and Middle Site are located within the Thames Policy area, where the threshold height for referral to the Mayor is 25m. In this location, it follows that any building greater than 25m would be classified as a tall building. 4.5 The Tall Building Study (Appendix 3) identifies the whole of Vauxhall SPD Area as sensitive to tall buildings, but not inappropriate. Where an area is sensitive, the Tall Building Study (paragraph 4.111) sets out that in some locations a large or tall building will be appropriate, and in others such a building may be inappropriate. These matters need to be considered on a case by case basis using the relevant planning policy framework. 4.6 The Proposed Modifications include, at new Annex 11, sections of the Tall Building Study: a definition of immediate setting and wider setting in respect of heritage assets, and its conclusions/recommendations. 4.7 At Annex 11, in the definition of immediate setting it is stated that for built heritage new large or tall development in the immediate setting (foreground, background and adjoining) would generally be inappropriate ; and at 5.13, Annex 11 states that the curtilages and immediate settings of listed buildings are considered inappropriate for tall building development. 4.8 These blanket statements, that the curtilages and immediate settings of listed buildings are inappropriate for tall buildings, do not accord with national planning policy. 4.9 The NPPF (paragraph 129) requires that local planning authorities should assess the particular significance of any heritage asset (including its setting) that may be affected by a proposal. In Page 24

25 Representations to Modifications to the Lambeth Local Plan for LFEPA considering a proposal, great weight should be given to the assets conservation (NPPF paragraph 132); but, where a proposal will lead to less than substantial harm, this can be weighed against the public benefits of the proposal, including securing an optimum viable use (NPPF paragraph 134) In respect of what is substantial harm, the Revised Early Minor Alterations to the London Plan (published 11th October 2013) ( REMA ) states that: Substantial harm to or loss of a designated heritage asset should be exceptional, with substantial harm to or loss of those assets designated of the highest significance being wholly exceptional. Where a development proposal will lead to less than substantial harm to the significance of a designated asset, this harm should be weighed against the public benefits of the proposal, including securing its optimal viable use. (paragraph 7.31A) 4.11 In the Glossary section of the REMA (page 38), it is clarified that for a grade II listed building the definition of substantial harm is exceptional As such, in accordance with the NPPF and REMA, the appropriateness of a tall building in respect of a heritage asset, where the impact is less than exceptional, should be based on an assessment its merits, on a case by case basis, including its particular impact on the setting of a heritage asset, weighed against public benefits With regard to the Appeal Decision, where the proposed development included a building of 8 storeys on the Front Site and 15 storeys on the Middle Site, it is evidently possible for a tall building within the immediate setting of the listed buildings, to be considered as having less than substantial harm Accordingly, it is only correct that the impact of any further development on the Site, which may or may not include a tall building (defined as greater than 25m), must be considered again on its merits, with regard to the NPPF and the London Plan, at the time of an application This is not the approach taken by Annex 11 of the Proposed Modifications, which simply states that a tall building is inappropriate. Annex 11 is unsound because it is inconsistent with national policy. Page 25

26 Representations to Modifications to the Lambeth Local Plan for LFEPA 5. Conclusions and recommended way forward Land use policy considerations 5.1 The amendment to the preferred use statement in Policy Site 10 by the Proposed Modifications effectively takes away the flexibility to consider an appropriate mix of uses across the whole Site, where some non-kiba uses could have been located on the Middle or Rear Sites if this was necessary to achieve an acceptable scheme in all other respects. Policy Site 10 is now unsound for the following reasons: 5.2 Policy Site 10 is unable to deliver the benefits of regeneration development as intended. The Policy is ambiguous without being clear on what development is appropriate and where on the Site it can be delivered. As a result, the Site will be sterilised and will remain vacant. Policy Site 10 will not deliver the redevelopment of the Site within the plan period; and for this reason it is unsound because it is not effective. 5.3 Given the significant requirements placed by Policy Site 10 on any development, the Viability Appraisal (based on an illustrative maximum floorspace across the whole Site) demonstrates that a compliant KIBA Scheme would produce a negative land value of minus 13,500,000. The Proposed Modifications would render Policy Site 10 ineffective, and thus unsound, because a viable development, in accordance with the Policy, could not be delivered over the plan period. 5.4 Policy Site 10 is also unsound because the scale of obligations and policy burdens required severely threatens the ability of the Site to be developed viably, which is inconsistent with national planning policy (NPPG paragraph 173). 5.5 Policy Site 10 seeks the re-provision of a fire station on the Site. Given that the LFEPA is reliant on the latent value of the Site for this re-provision (a fit for purpose operational fire station that will meet the modern needs of the fire service in this location), the Proposed Modifications to Policy Site 10 are unsound because they are ineffective at delivering such a fire station. 5.6 Given the great emphasis of the NPPF in the social dimension of sustainable development, where planning should deliver sufficient community facilities and services to meet local needs, the Proposed Modifications to Policy Site 10 are unsound because they are not justified as the most appropriate strategy in delivering community infrastructure and are inconsistent with national policy. Page 26

27 Representations to Modifications to the Lambeth Local Plan for LFEPA 5.7 For Policy Site 10 to be effective (and sound) a mix of uses including some residential, is necessary across the whole Site. This requirement conflicts with the KIBA designation. However, when the KIBA compliant fallback position that either nothing happens or the existing buildings on the Middle Site are simply reused is considered against the Appeal Scheme, it is shown that a flexible mixed use policy for the Site would be more compatible with the strategic economic objectives of the Submission Draft Local Plan of (i) supporting key employment sectors, and (ii) increasing the number of jobs overall and employment opportunities for local people. 5.8 The KIBA designation of the Middle and Rear Site, cannot be justified as the most appropriate strategy for delivering the purpose of the KIBA designation, which is to provide employment and economic growth. For this reason, Policy Site 10 is unsound. 5.9 To address these issues of soundness, Policy Site 10 should be further amended to allow a flexible mix of uses across the whole Site. The number of jobs on generated by development on the Site could be maximised, but this must be in the context of an optimised scheme, which will be viable and deliverable, to provide the many other requirements of Policy Site 10. To allow this flexible mix of uses, the Site should be removed from the Southbank House and Newport Street KIBA. Tall buildings 5.10 The blanket statements at Annex 11 in the Proposed Modifications, that the curtilages and immediate settings of listed buildings are inappropriate for tall buildings, do not accord with national planning policy. The NPPF (paragraph 134) requires that where a proposal will lead to less than substantial harm, this can be weighed against the public benefits of the proposal, including securing an optimum viable use The Appeal Scheme evidently shows that it is possible for a tall building, within the immediate setting of the listed building on the Site, to be considered as having less than substantial harm. It is only correct that the impact of any further development on the Site must be considered on its merits at the time of an application with regard to the NPPF Annex 11 of the Proposed Modifications, which simply states that a tall building is inappropriate, is unsound because it is inconsistent with national policy To rectify this matter, the first paragraph of Immediate Setting in Annex 11, and paragraph 5.13 ( Listed Buildings ) of Annex 11 should be amended to be consistent with national policy. Page 27

28 Representations to Modifications to the Lambeth Local Plan for LFEPA 5.14 Likewise, on the same basis, paragraph (iv) in the Design principles and key development considerations section of Policy Site 10 in the Submission Draft Local Plan should be revised so that it is consistent with how Annex 11 should be amended. Rather than saying that the heritage sensitivity of the site makes it is inappropriate for tall building development, it should instead say that the heritage assets on the site make it sensitive for tall building development. Page 28

29 APPENDIX 1 Planning application decision notice

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37 Appeal Decisions Inquiry held on February, 1 March, 5-6 March & March 2013 Accompanied site visits made on 21 February & 7 March 2013 by Terry G Phillimore MA MCD MRTPI an Inspector appointed by the Secretary of State for Communities and Local Government Decision date: 13 May 2013 Appeal Ref: APP/N5660/A/12/ (Appeal A) 8 Albert Embankment and Adjoining Sites, London SE1 7SD The appeal is made under section 78 of the Town and Country Planning Act 1990 against a refusal to grant planning permission. The appeal is made by Albert Embankment LLP and London Fire and Emergency Planning Authority against the decision of the Council of the London Borough of Lambeth. The application Ref 10/04473/FUL, dated 21 December 2010, was refused by notice dated 3 February The development proposed is: Refurbishment, alteration and extension to the grade II listed fire station to provide a fire station and associated functions for the London Fire Brigade (sui generis) on part basement and ground floors, with residential (class C3) above, including demolition of the communication mobilising centre. Demolition of the brigade workshop/office buildings to the rear of the fire station. Construction of 7 new buildings ranging in height from 1 to 15 storeys for mixed use purposes, including residential dwellings (class C3); office/business space (class B1); ground floor units for shops, financial and professional services, restaurants and cafes, and/or drinking establishments (classes A1, A2, A3 and/or A4); and ancillary facilities. Refurbishment and internal alterations to the grade II listed drill tower associated with the new fire station. Construction of basements to provide servicing, parking, energy centre, plant and storage. Creation of areas of open space and alterations to the existing vehicular and pedestrian accesses and highway arrangements within and around the site. The development would provide a total of 265 residential units, a 2,721 sqm fire station, 8,554 sqm of commercial floorspace (use Class B1), 696 sqm of retail/a Class floorspace and 92 car parking spaces. Appeal Ref: APP/N5660/E/12/ (Appeal B) 8 Albert Embankment and Adjoining Sites, London SE1 7SD The appeal is made under section 20 of the Planning (Listed Buildings and Conservation Areas) Act 1990 against a refusal to grant listed building consent. The appeal is made by Albert Embankment LLP and London Fire and Emergency Planning Authority against the decision of the Council of the London Borough of Lambeth. The application Ref 10/04475/LB, dated 21 December 2010, was refused by notice dated 3 February The works proposed are: Refurbishment, partial demolition, extensions and alterations to fire station and drill tower including: demolition of modern rear extension, erection of a rear extension at fourth to ninth levels and single storey roof extension. External cleaning and repair, creation of ground floor entrance on south flank, alterations and extension to basement, works associated with connection of covered wash down area to rear of building connecting at first floor level. Internal alterations to provide residential accommodation on first to tenth floors, and fire station and ancillary facilities at basement and ground floors. Refurbishment and internal alterations to the drill tower, and works associated with connection of a building on east flank of the listed building at

38 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ ground floor level and connection of a single storey building on the north flank of the listed building. Appeal Ref: APP/N5660/E/12/ (Appeal C) 8 Albert Embankment and Adjoining Sites, London SE1 7SD The appeal is made under sections 20 and 74 of the Planning (Listed Buildings and Conservation Areas) Act 1990 against a refusal to grant conservation area consent. The appeal is made by Albert Embankment LLP and London Fire and Emergency Planning Authority against the decision of the Council of the London Borough of Lambeth. The application Ref 10/04476/CON, dated 21 December 2010, was refused by notice dated 3 February The demolition proposed is: Demolition of brigade workshop/office buildings on land bounded by Lambeth High Street to the west, Whitgift Street to the north, Southbank House to the south and railway viaducts to the east. Decisions 1. The appeals are dismissed. Procedural Matters 2. The proposal was amended including by way of a partial reduction in height prior to the Council s decisions, and I consider the appeals based on the revised scheme as set out in the above description of the development. 3. The applications were accompanied by an Environmental Statement and the proposal is Environmental Impact Assessment development under the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations All of the environmental information is taken into account in my consideration of the proposal. 4. At the inquiry an agreement and a unilateral undertaking containing planning obligations pursuant to section 106 of the Act were provided in final draft form. Signed documents were submitted following the close of the inquiry and have been taken into account. Main Issues 5. The main issues are: a) whether the scheme pays adequate regard to local employment and economic objectives; b) whether the proposed level of provision of affordable housing is acceptable; c) the effect the proposal would have on the character, special interest and settings of listed buildings, the character and appearance of the Albert Embankment and Vauxhall Gardens Conservation Areas and of the surrounding locality; d) the impact the proposal would have on the living conditions of nearby residential occupiers by reason of loss of daylight and sunlight. 2

39 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ Reasons Introduction The site 6. The site comprises front, middle and rear parts. 8 Albert Embankment is in the front (western) part facing the River Thames. It is a building of basement plus 8 storeys dating from 1937 with a 3 storey part-width 1980s rear extension. It was previously the headquarters of the London Fire Brigade, but is now only partially occupied as a fire station with the remainder vacant. Also in this front part of the site, in the north-east corner of the rear open yard, is a Drill Tower structure of the same era as the main building. 7. Lambeth High Street separates the front and middle parts of the site. In the latter part are vacant workshop and office buildings of 2 and 4 storeys, also contemporary with the original front site building and previously occupied by the London Fire Brigade. Alongside to the east is an elevated railway viaduct. Beyond this is the detached rear part of the site, comprising an open area of hardstanding used by the Fire Brigade for informal car parking. Statutory and policy designations 8. A number of statutory and policy designations affecting the site are relevant to the main issues, with the key ones as follows Albert Embankment and the Drill Tower are Grade II listed buildings. The front and middle parts of the site are within the Albert Embankment Conservation Area. The rear part is within the Vauxhall Gardens Conservation Area. 10. The front and middle parts fall within the Central Activities Zone as designated in the London Plan The whole site is within the Vauxhall, Nine Elms and Battersea Opportunity Area, also designated in the London Plan. Opportunity areas are the capital s major reservoir of brownfield land with significant capacity to accommodate new housing, commercial and other development. 11. The Lambeth Core Strategy 2011 includes policy PN2 which relates specifically to Vauxhall. The site is shown within the Albert Embankment Quarter of the Vauxhall Opportunity Area. Also in the Core Strategy, the middle and rear parts of the site form part of a designated Key Industrial and Business Area (Southbank House and Newport Street). 12. A saved element of the Lambeth Unitary Development Plan 2007 relates to Major Development Opportunity sites on Albert Embankment. One of these is MDO4, which is London Fire Brigade Headquarters, 8 Albert Embankment - Area 1 Ha. 13. A partnership of the Greater London Authority, Lambeth Council, the London Borough of Wandsworth, Transport for London and English Heritage has issued the Vauxhall Nine Elms Battersea Opportunity Area Planning Framework 2012 as supplementary planning guidance to the London Plan (the OAPF). 14. The Council has prepared a Vauxhall Supplementary Planning Document, which was agreed for adoption in January 2013 (the Vauxhall SPD). 3

40 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ The proposal 15. The buildings in the proposal are labelled A to G. Building A is the retained original 8 Albert Embankment. A roof extension would be added, together with an infill extension at the rear from fourth to ninth floor levels. The accommodation above ground floor incorporating the extensions would be converted to residential flats. A replacement fire station would occupy the ground floor, extending below a new podium level, with parking and service facilities at basement level. 16. The existing rear extension would be replaced by Building B, comprising 8 storeys and dropping down to 5 storeys along Lambeth High Street. This would include ground floor fire station accommodation, with a single storey link to Building A. There would also be an element of Class A use at ground floor level. The upper floors would be residential units. 17. Building C would be of single storey and located along the north edge of the front site. It would provide concierge and fire station accommodation. The Drill Tower to the east of this would be restored and retained. 18. The middle site would be fully redeveloped and replaced by 4 new buildings in a courtyard arrangement around a first floor podium garden. On the west side Building D would be of 15 storeys. The ground floor would provide Class A units, with a public piazza created along Lambeth High Street in front of the building. Opposite across the courtyard, but angled to follow more closely the alignment of the viaduct, Building F would be of 13 storeys. Building E(N) of 3 storeys and Building E(S) of 5 storeys would abut the two taller buildings. The upper floors of these courtyard buildings would provide business floorspace and residential flats, with some business use also in ground floor areas. Below the podium and at basement level would be car parking and ancillary facilities. 19. On the rear site, Building G of 5 storeys would comprise all residential flats. Viability 20. Viability considerations are relevant to a number of the main issues, and I deal with this as a preliminary matter. According to the National Planning Policy Framework, pursuing sustainable development requires careful attention to viability and costs in plan-making and decision-taking. To ensure viability, the costs of any requirements likely to be applied to development, such as for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable. 21. Viability assessment was carried out by the appellants at application stage, with further assessments at appeal stage. The statement of common ground records that there is agreement between the Council and the appellants on the method of calculating viability and the value of the components utilised therein. The appellants appraisals employ both the Development Control Toolkit model developed for the Greater London Authority by Three Dragons, and ProDev which is a commercially available development appraisal software package. The application assessment was reviewed by the Council s consultant (BNP Paribas) using Argus Developer, another commercially available software package. The methodology is a fixed land price residual appraisal undertaken at current costs and values. The appraisal tests the ability of the development 4

41 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ to generate a required profit level. The agreed target profit level is 20% of the private residential value and commercial value, and 6% of the cost of provision of affordable housing, giving a required blended profit of around 19.6% of the total development value for the submitted scheme appraisal. This appraisal (as amended August 2011) gave a profit level equivalent to 17.6% of the total development value, and therefore because this was less than the required profit the proposal was agreed to be unviable. 22. The further appraisals carried out comprise an Updated Appraisal (which assesses the scheme as revised prior to determination of the applications). In this version the required blended profit is 19.83% and the result is 14.64%. A Revised Appraisal tests provision of affordable rented housing instead of social rented in accordance with current expectations for delivery of this element of the scheme. This generates a residual profit of 15.39% compared with a required blended profit of 19.67%. 23. No adverse comments are made by the Council with respect to the Updated or Revised Appraisals. Therefore there is agreement between the main parties on the testing that has been undertaken and on the conclusion that the testing shows the appeal scheme to be unviable. The Council s case as made at the inquiry relies on the potential viability of variations of the scheme, and these are dealt with below where relevant to the main issues. Third parties, in contrast, have challenged the appraisals, questioning the assumptions and methodology. 24. With respect to the values of the scheme components, criticisms are made that these underestimate potential returns on the private housing and commercial floorspace. These criticisms are generally based on comparisons with identified examples with higher values. However, the values in the appellants appraisals have been accepted by the Council s independent expert adviser. There is no compelling alternative evidence based on specialist market knowledge that takes into account the particular factors relevant to values in individual cases such as to establish that these cannot be relied upon. With regard to market trends and potential future values, the use of current prices in the agreed methodology provides for consistency and certainty. This is notwithstanding other estimates that have been given for the scheme s value. The build costs used in the appraisals have also been criticised as being too high, but they have been prepared by specialists for the particular development and accepted by the Council s adviser. Again, the objections do not justify serious doubts on the agreed figures. 25. An input into the appraisals is an assumed existing value of the site of zero, said to reflect the objective of re-provision of a fire station within the scheme. Other figures have been put forward for the existing value of the site, including the appellants own recent current use valuation of 10m. In addition, third parties refer to evidence indicating agreement on a substantial capital payment to the Fire Authority from the other appellant party for purchase of the site. Figures for this ranging from 20m to 41.88m are quoted. Good practice advice on viability assessment methodologies refers to the relevance of site purchase price as contextual information. Objectors argue that such a purchase price in this case undermines the credibility of the appraisals which are based on an assumed zero site value, given that the effect of allowing for a land value above zero in the appraisals would be to reduce further the assessed viability of the scheme. 5

42 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ However, the appellants correctly point out that the purpose of such appraisals in decision making on planning proposals is to assess a scheme independently of the deals reached by individual developers. Such deals could involve agreement to a price which is excessive or subject to renegotiation, and could be based on assumptions about future changes in values. In this context viability testing is a tool rather than necessarily representing the actuality of property deals and investment decisions. In the particular circumstances of the current proposal, the modelling that has been undertaken based on a fixed land value and calculating residual profit as enabled by the toolkit appears to be an appropriate method. 27. The firm evidence of the appellants is that the appeal scheme would proceed even with the unviable level of profit shown in the appraisals and that this would not be unusual in the current market. This has not been disputed by the Council. The assumption that a grant of permission would be used merely as the basis for an alternative scheme to be brought forward carries little weight, and any different future scheme would need to be assessed on its own merits. I have taken into account other criticisms made of the appraisals but consider these to be reasonably robust, with scope to deal with future changes in values through a contingent liability planning obligation as addressed below. 28. Therefore there is no reason to depart from the position agreed between the appellants and the Council on the viability of the submitted scheme, and regard is had to this in considering the main issues. Issue a) whether the scheme pays adequate regard to local employment and economic objectives 29. This issue and issue b) on affordable housing are linked because they involve interrelated land use considerations. I deal with them before the assessment of impact on heritage assets (issue c) since they raise further matters with respect to viability which are relevant to the latter. 30. Policy S3 of the Core Strategy commits the Council to support local economic development, Lambeth s contribution to the central and wider London economy and a range of local business and job opportunities, by giving priority to a diverse range of economically beneficial uses in appropriate locations. Among means to achieve this is (a) Safeguarding Key Industrial and Business Areas (KIBAs) for business, industrial, storage and waste management uses, including green industries, and other compatible commercial uses, excluding large scale retail. 31. As stated above, much of the site is within the Southbank House and Newport Street KIBA. The 2010 Examination into the Core Strategy considered as part of an economic development issue the argument that confining KIBAs to employment use would mean that future development in this KIBA cannot reflect the mixed use character of the wider locality, and restrict redevelopment of sites within the KIBA in conjunction with the listed Fire Station building. The Inspector noted that removal of the KIBA designation would clearly overcome this obstacle and allow future development to reflect that in the surrounding area. However, she found there to be no compelling evidence to demonstrate that retaining this KIBA makes the Core Strategy unsound. 6

43 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ The appeal proposal is for a mixed use development, and would introduce a substantial amount of residential accommodation into the parts of the site covered by the KIBA designation, with only residential use on the rear part. The London Plan in policy 4.3 promotes mixed use development generally and in the Central Activities Zone. Policy PN2 of the Core Strategy similarly supports mixed use development at Vauxhall including for employment and housing, in line with its Central Activity Zone designation and as part of the wider Vauxhall/Nine Elms/Battersea Opportunity Area. The OAPF anticipates high density mixed use housing-led intensification on Albert Embankment among other areas. Nevertheless, the latter notes that at Albert Embankment Lambeth s employment retention policies will continue to apply. Given the specific nature of the KIBA policy in the Core Strategy, the residential content proposed within the KIBA in the appeal scheme amounts to a departure from the development plan, despite the general policy support for mixed use. 33. The statement of common ground records that the lawful use across the front, middle and rear parts of the site is sui generis. The fire station, which is outside the KIBA, currently provides around 90 jobs. This would be increased to some 120 jobs with the proposal. The existing floorspace of the middle site is around 6,860m 2. The proposal would provide 8,126m 2 of B1 floorspace on the middle site, thus increasing employment floorspace, together with 661m 2 of class A floorspace spread between the front and middle sites. The class B1 floorspace would have the potential to accommodate some 677 jobs and the class A uses some 35 jobs, giving a total potential of around 832 jobs. The B1 floorspace would comprise modern adaptable units for small and medium enterprises, for which there is an identified need within the Borough. 34. The viability of alternative employment floorspace scenarios for the site was reviewed by the Council s consultant at application stage in the light of supporting information provided with the applications. As set out in the Council s Committee report, all options considered were found to be unviable, (including the appeal proposal). A warehouse or open storage scheme on the front and rear sites, with residential uses on the front site, would potentially generate a better value than the appeal scheme, but would provide fewer jobs and involve more risk due to sales values being less likely to increase. A KIBA compliant office scheme on the middle and rear sites would generate a substantial deficit of much greater magnitude than the appeal scheme, and increasing the quantum of office accommodation within this would have a detrimental impact upon viability. The conclusion reached was that the employment floorspace has been optimised within the development presented, having regard to the financial viability of the scheme, and that the development could not reasonably be expected to provide any increase in employment floorspace from that proposed across the KIBA parts of the site. There is no evidence to counter these conclusions based on expert assessment. The position recorded in the statement of common ground is that the matter of the KIBA is not at issue between the main parties. 35. Third parties nevertheless question the compatibility of the proposal with the KIBA designation. Various points are put forward, including the relatively low vacancy rate of commercial premises in this KIBA other than on the appeal site, information on new development taking place in KIBAs, potential interest by a specific manufacturing business in the site, and concern about the impact of the proposal on existing business activity in the KIBA. I have also taken into account the absence of evidence on marketing of the site for a development 7

44 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ involving only a KIBA use, and that the KIBA policy is not aimed only at employment creation. 36. However, on balance the departure from the KIBA objective of policy S3 is justified by the common ground position on viability and optimum provision of employment floorspace, the employment and wider economic benefits of the proposal, and the contribution it would make towards regeneration and vitality in the local area (also dealt with further below) by way of an intensive mixed use development with active street frontages. 37. While taking into account the employment objectives of policy 23 of the UDP for non-kiba sites, I consider that the mixed use of the front site is also acceptable having regard to the previous use, the fire station re-provision and the overall content of the development. Issue b) whether the proposed level of provision of affordable housing is acceptable 38. Policy 3.11 of the London Plan seeks to maximise affordable housing provision. Policy 3.12 includes that the maximum reasonable amount of affordable housing should be sought when negotiating on individual private residential and mixed use schemes, having regard to among other factors the need to encourage rather than restrain development and the need to promote mixed and balanced communities. 39. The affordable housing content of the scheme is 19 units or 7% of the total. This is well below the target of 40% in policy S2 of the Core Strategy, and also falls significantly short of the lower target of 15% set out as applicable in some circumstances in the OAPF. However, the policy S2 target includes a proviso relating to independently validated evidence of viability. Based on the agreed viability position, and as recorded in the Committee report, the independent expert advice to the Council is that the scheme provides more than the maximum viable quantum of affordable housing and financial planning obligations and as such the level of provision can be regarded as being optimal. The demonstration that the maximum reasonable amount of affordable housing is being proposed, in accordance with policy 3.12 of the London Plan, has been accepted by the Greater London Authority. 40. It was further noted in the Committee report that the level of overall affordable housing provision directly results from maximisation of the overall provision of employment floorspace within the development, which itself has come about in direct response to the local KIBA policy context. 41. In this agreed context the Council s case, made in support of its reason for refusal which alleges that the proposal would provide an unacceptably low level of affordable housing, argues in favour of an alternative development with a greater housing and a lesser commercial content. This is explored by way of a viability scenario in which the middle part of the site is reconfigured to allow greater levels of affordable housing to be produced, with retention of commercial floorspace only on the ground floor. The demonstration of the scope for increased affordable housing provision in this way is not specifically disputed. 42. A further matter is whether the appeal scheme would promote a mixed and balanced community, as sought by policy 3.12 of the London Plan. The Vauxhall SPD identifies a danger that the Vauxhall area could become over- 8

45 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ dominated by investor buy-to-let schemes where residents may lack any social commitment to the life of the area. The approach set out in the London Plan Housing Supplementary Planning Guidance 2012 is for tenure comparisons to be undertaken at a neighbourhood level, and not within an individual site. In this case there is an existing predominance of social rented housing in the neighbourhood area. The appellants argue that the neighbourhood would become more mixed as a result of the proposal due to the addition of market housing. 43. Notwithstanding the differing views on these points, there is a substantial unmet need for affordable housing including family housing in the area, as reflected in the policy objectives at various levels. The provision of more affordable housing on the site would be in accordance with these objectives. 44. Nevertheless, there is a balance to be struck with other land use objectives for the site. While elements of the development plan give support to mixed use development including residential accommodation, as set out above there is a strong specific policy favouring commercial use within the KIBA. The Council s proposition of increasing affordable housing at the expense of commercial use through its scenario runs counter to this objective. Having regard to this, and viability considerations, the level of affordable housing in the appeal scheme is acceptable, and would not harmfully conflict with the objective of mixed and balanced communities. This is regardless of the proportion of affordable housing that has been achieved in other developments. 45. The submitted unilateral undertaking contains a planning obligation relating to an affordable housing review. It includes a clause that the obligation would take effect only if found in this decision to meet the tests of Regulation 122 of the CIL Regulations, one being necessity. The obligation would provide for a review of the affordable housing provision by way of an updated viability assessment if the development is not implemented by 20 months after the date of permission. 50% of any net surplus above a 20% profit would be paid towards affordable housing, up to maximum of 40% provision. Contingent liability obligations on affordable housing are envisaged in policy 3.12 of the London Plan, and also in the Vauxhall SPD. While this is not strictly a phased development, given its size, nature and the potential effect on viability of changes in values in this case, such an obligation is necessary to meet the requirement for maximum reasonable provision of affordable housing. There is no convincing evidence that the need for the review would inhibit financing of the scheme, and the review would take into account the headroom for value growth in the previous viability assessment. The 20 month period equates to the alternatives of a short term permission or a trigger for a review of viability set out in the London Plan Housing Supplementary Planning Guidance. The scheme is, however, not of a scale or likely duration of development that a post-implementation review of the type advocated by the Council is justified or reasonable, with no clear policy basis for this. 9

46 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ Issue c) the effect the proposal would have on the character, special interest and setting of listed buildings, the character and appearance of the Albert Embankment and Vauxhall Gardens Conservation Areas and of the surrounding locality Listed building works Albert Embankment is the subject of a lengthy list description. This identifies that it was built in 1937 by the London County Council to the design of EP Wheeler, Architect to the LCC, as the Headquarters of the London Fire Brigade. It was part of a complex that incorporated the administrative headquarters of London fire fighting, residential quarters, a working fire station with a range of staff facilities, a drill parade ground, a drill tower, and a training school and maintenance workshops at the rear also combined with flats. After its opening the grandstand like rear elevation of the main building incorporating tiers of balconies accommodated large crowds of spectators to watch fire-fighting displays on the drill tower. There was also a river fire station with pontoon, which is still in use but rebuilt. The capital s fire-fighting operations were run from the site during World War II, when an underground control room was constructed. 47. The description identifies that the 1980s rear extension to the main building is not of special interest, nor are the former training school and workshops. The Drill Tower is separately listed, and has group value with the main building. The description ends with a list of the principal reasons for the Grade II designation of the main building, as follows: Of special architectural interest as a well-composed and externally unaltered 1930s building which, while in the streamlined Moderne idiom, upholds the Arts and Crafts ideal of collaboration between architecture and sculpture; A landmark building on the south bank of the River Thames; Important sculptural reliefs, most notably by the distinguished 20 th century sculptor Gilbert Bayes; Interior features of interest, including the main entrance hall and sculpture; Of special historic interest as the headquarters of the London Fire Brigade, the most important fire brigade nationally and the third largest in the world. The building was the centre of London s fire-fighting operations in WWII. 48. There is extensive inquiry evidence on the significance of the building as a designated heritage asset, including historic photographs, but in my opinion the above constitute the main elements of importance. This significance encompasses the full range of possible heritage interest identified in the NPPF covering archaeological, architectural, artistic and historic value, with this including the cultural links of the building with the community. 49. The building retains an active fire station use on the ground to second floors but the remainder is vacant after it ceased to be the Fire Brigade headquarters in The scheme includes replacement of the fire station within the front part of the appeal site. The English Heritage/London Fire Brigade Joint Guidance document on London s historic fire stations (2010) refers to the historical association of continued active use as a valuable asset, and retention of use as a priority. In this case, given the particular elements of fire service 10

47 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ linkage in the historic interest of the building, such retention of an active fire station on the site would help sustain this aspect of its significance. 50. With respect to the proposed creation of residential flats on the upper floors of the building, there is broad agreement that this use is an appropriate one, which is consistent with the living quarters use of those floors while in Fire Brigade use. 51. The proposed uses would therefore help preserve the significance of the building in terms of its historic purpose and association. The works of refurbishment in the appeal scheme would assist in also preserving physical aspects of the structure s value, with elements of enhancement where the existing condition of the fabric would be improved. At the same time the scheme includes some fairly substantial alterations and interventions, and the effect that these changes to the fabric would have on the significance of the building also falls to be considered. 52. The exterior of the original building is clad in brick with elements of Portland Stone decoration and granite base courses. To the front are the ground floor appliance bays with folding wooden doors. The building is characterised by a severe geometry, with a flat roof and strong horizontal emphasis. It has a symmetrical façade of 9 storeys with the top 2 storeys stepped back apart from the central 5 bays of the eighth storey, which form a centrepiece. From first to third floors are central stone reliefs by Gilbert Bayes illustrating fire service related scenes. At roof level is a central set back tower with an elaborate stone cornice, iron railings and flagstaff above, and a large carved LCC coat of arms crest in stone. 53. The appellants contend that the roof level of the building is not well resolved in architectural terms, and question the description of the central tower as a watch tower, with no evidence that it ever functioned as such. Nevertheless, the tower is clearly the top central marker of the building as part of the symmetrical arrangement and, with the brickwork, cornice and railings carried round to its sides and rear, is a distinctive three dimensional feature. 54. The proposed additional floor on the existing roof of the building would be a glazed structure. In architectural terms the extension has a number of positive aspects. It would add a modern element of high quality which would be readily distinguishable from the original fabric. Parallels are drawn with the rooftop additions erected on the Oxo and Tate Modern buildings, which also have a River Thames frontage and are landmark structures brought into new uses. The current proposal would similarly be a visual expression of a new chapter in the history of the building, in this case marking the change from the previous full Fire Brigade use. The extension would also reinforce the visual prominence of the building as a landmark on the waterfront in the context of the increasing height of new development in the surroundings, referred to further below. 55. While these merits of the proposal are argued by the appellants to be potential enhancements of the building, in terms of the effect of the roof addition on the significance of the heritage asset I regard them as mitigating what would nevertheless be a harmful impact. The extension would be of lightweight form and materials, and therefore contrast with the original building, but it would detract from the unaltered quality of the 1930s structure which currently retains its architectural purity. Although the extension would follow the existing tiering by being set in at the sides, it would be close to the front 11

48 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ parapet, and also rise slightly above the central tower. In addition, the side lift overruns at the outer edges of the roof would be raised to above the height of the tower. The extension would therefore also diminish the prominence of the tower as the crest of the building, obscuring the returns of this and interfering with the roof silhouette. As a result of these effects on the composition of the building as originally designed and constructed, the extension would therefore detract from its significance. 56. At the rear the building has balconies on all floors, the lowest three with cast iron balustrading and designed as display platforms overlooking the rear drill yard. The building diminishes in depth above third storey level, with projections at the sides creating return elements. There is a built-in canted bay observation post to one side at first floor level, and an asymmetrically positioned external brick pole shaft rising to all floors. The proposed rear extension, with new external balconies, would largely infill the recess between the returns above third floor level. I agree with the appellants that, apart from the elements specific to the Fire Brigade occupation, the rear residential floors with balcony access are typical of public housing schemes of the period as well as many fire stations, and only of moderate interest. However, the extension would infill almost the full depth of the return ends which give the original rear elevation a more distinctive architectural interest. While a replacement pole housing type design feature would be created, the original would be lost as an external structure, and some elements of the viewing platforms would also be removed. There would be an erosion of significance from these losses of original Fire Brigade related fabric. 57. A partial decking over of the rear drill yard is proposed, in order to provide environmental separation between the replacement fire station and new residential accommodation above and a covered wash down area for the fire station. The glazed edge to this would clearly demarcate the new from the old fabric. The existing hard surfaced space is not attractive, but there would be a further erosion of significance from loss of the original open nature of the drill yard. 58. Internally, there is no dispute that much of the fabric of the building has been previously altered or is very plain. This applies in particular to the upper floors, and the conversion of these would not involve loss of fabric of special interest. Conditions could appropriately be used to deal with the details of works relating to more important features that are proposed to be retained and the treatment of the interface between old and new fabric and structural works. This includes with respect to the culturally valuable Fire Brigade memorials and sculptures, and the panelling of the first and second floor function rooms, with some relocation of fabric proposed. The memorials are proposed to be retained within a publicly accessible entrance space, but the unfortunate subdivision of the existing memorial hall as intended would detract from its spatial character, even with careful detailing of the divide. Similarly, the isolation of sections of shafts and poles within individual flats would involve an erosion of the integrity of these features linked to the historic use. This would also be the result of the loss of other sections of poles and the truncation of the existing staircase from the appliance room to the first floor. Harm to the significance of the building would therefore arise from some effects of the proposal on interior features of interest. 12

49 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ The Drill Tower is proposed to be refurbished and retained in fire station use, with a positive effect on its significance. Listed building settings and Conservation Areas 60. The linear Albert Embankment Conservation Area follows a section of the River Thames. The main features of its special interest are identified in the Council s designation report. This interest arises from the historic importance of Albert Embankment itself as a major piece of mid Victorian engineering and urban planning. It also encompasses a number of buildings. Two are major landmark buildings on the Embankment, one of which is no. 8 at the northern end of the Area and the other the 1990s post-modern MI6 building by Terry Farrell towards the southern end. In the vicinity of no. 8 the Area s boundary projects away from the River to take in no. 8 itself (the front part of the appeal site), the training school and workshops to the east of Lambeth High Street (the middle part of the appeal site), the Grade II listed Southbank House which lies to the south of this, and the Windmill public house which is to the north of the Drill Tower. Southbank House was built in 1878 as the Doulton pottery works, and is an outstanding example of High Victorian Gothic with a wealth of exuberant brick and red and buff glazed terracotta decoration, a corner oriel turret corbelled out over the street, and tall pyramidal tiled roofs. Along Black Prince Road is a later wing which is simpler in elevational treatment but shares the same proportions, scale, height and redbrick facing material. The Windmill is an 1886 public house with a longer history of such use on its site, and is a fragment of the old Lambeth High Street pre-dating the Fire Headquarters. 61. In addition to these structures and buildings a key aspect of the Conservation Area is views. These include outward views of the riverscape of the north bank (Pimlico, Millbank and the Palace of Westminster) which forms a backdrop to the Area, creating an unfolding panorama for the whole length of the riverside walk. There are also important views along and out of Black Prince Road, and towards the Embankment from Vauxhall Bridge, Lambeth Bridge and the riverside on the north bank of the River. 62. The 1980s control room extension to no. 8 has a negative effect on the listed building, and also on the setting of Southbank House and on some Conservation Area views, by reason of its incongruous materials and detailing, intrusive massing and lack of street level animation. Proposed Building B would obscure more of the rear of no. 8 due to its height and width, and some views of the Drill Tower, but be of a much higher architectural quality, introduce activity at street level, and improve views of Southbank House. Overall this would have a positive effect on the heritage assets. 63. It is common ground that the training school and workshop buildings have a neutral effect on the Conservation Area, and there is no objection in principle to their removal. The proposed new group of buildings (D, E(N), E(S) and F) are interestingly detailed and would introduce new public space and activity. Their heights and massing would not intrude unduly in short distance views given the context of existing buildings in the vicinity and the relationships to street frontages and spaces. Sunlight studies indicate that there would be no significant increase in overshadowing of the nearby Lambeth High Street Recreation Ground or breach of policy 50 of the UDP in this respect. The heights of the buildings would be well below the limit of 80-90m for Albert Embankment set out in the OAPF and Vauxhall SPD, and there would be no conflict with policy 7.7 of the London Plan or policy 40 of the UDP on tall 13

50 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ buildings. The Council agrees that the new buildings would present a high quality of architecture. In the immediate vicinity this aspect of the development would be an enhancement of the Conservation Area, contributing to a distinctive and legible new quarter, consistent with the urban design objectives in policies 7.4, 7.5 and 7.6 of the London Plan, policy S9 of the Core Strategy and policy 33 of the UDP. 64. Longer distance views of no. 8 can be obtained from Vauxhall and Lambeth Bridges and from the north bank of the River. To varying degrees in these views, but particularly in those facing more directly towards its front façade, the building is seen against a background of sky, this feature emphasising its prominence on the Embankment and the distinctive nature of its silhouette. From some positions there are also open sky gaps to the sides of the building. These aspects of setting add to the significance of the listed building and its contribution to the Conservation Area. 65. In distant views from the south, including from Vauxhall Bridge and the south end of Millbank, the higher part of the adjacent building to the north appears behind no. 8 and its roof profile is not readily apparent. From this angle proposed Building D would be seen to the right side of no. 8, but moving closer both this building and Building B would fill the existing sky gap adjacent to the south side of no. 8. Further northwards again, Building D would increasingly appear behind no. 8, with Building F seen behind Building B. From a position directly opposite no. 8, where its symmetry is most apparent, Building D would appear in line behind no. 8, slightly to the left side. Moving northwards, where the Drill Tower appears in the sky gap adjacent to the north side of no. 8, Building D would increasingly be viewed as behind this and less to the rear of no. 8 itself. From Victoria Tower Gardens to the north of Lambeth Bridge, and moving eastwards across the Bridge, it would eventually appear as well to the left of no. 8, with other buildings being seen behind no The kinetic nature of these views was considered by an Inspector in 2009 in allowing an appeal against refusal of permission for a proposal involving the erection of a 23 storey building (including basement) on the site of 81 Black Prince Road (ref APP/N5660/A/09/ ). He observed that the key relationship of no. 8 is to the River, and that this elevation has a horizontality which is emphasised by the central Portland Stone decoration and the stepped roofline. He noted that in some views from Milbank it is seen with a sky gap on either side, but that the building is viewed by people moving around the area, and not from a single point. With views changing as the observer moves, the Inspector recorded that moving south towards, and then onto, Lambeth Bridge the proposed tower would align increasingly with the centre of the front elevation of no. 8. He nevertheless considered that the verticality of the tower would contrast with the horizontality of no. 8. He agreed that it would break the continuity of scale along Albert Embankment but would be perceptibly in the background of the Fire Brigade building, not challenging it. From directly opposite the symmetrical front elevation of no. 8, the proposed tower would be well to the right of it, and the sky gaps on either side would be preserved. The Inspector concluded that the tower would have an insignificant effect on the listed building s key relationship to the River or on its setting, and would also preserve the settings of Southbank House, the Drill Tower and the two Conservation Areas. The approved development is currently under construction. 14

51 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ In the section of view from Lambeth Bridge and the garden immediately to the south-west of the Bridge, the open sky behind the silhouette of no. 8 will therefore in future already be broken by the new tower. In other oblique views the tower will appear in the existing sky gaps. With the current proposal that effect would be extended to more of the vista, including by the intrusion of built form in the currently open sky above the silhouette of no. 8 when viewed from directly opposite across the River. While not a purposefully designed viewpoint or one protected by policy, it is from this position that the overall profile of the building with sky gaps on either side is most apparent. Although the sky gaps from this position would be maintained, as seen from other parts of the vista they would be diminished. In addition, as seen behind no. 8 the width of Building D as well as its height would be apparent, and with the horizontality in its design treatment it would to some extent challenge that quality of no. 8. This would result in a degree of conflict with policy 41 of the UDP on views, which includes reference to landmark buildings and silhouettes, and policy 43 on urban design in the River Thames policy area. 68. Offsetting these concerns, when the separating effects of distance and parallax are taken into account, Building D (and Building F in views in which this is seen) would be perceived as set well to the rear of no. 8, detracting from its symmetry and silhouette to a lesser extent than suggested by simple elevations. The contrasting nature of the proposed roof extension, while itself being harmful as set out above, would provide an element of visual capping to the listed building and further disassociate the structures. Existing views of the refurbished Drill Tower would remain unobscured, and as set out above the visibility of Southbank House would be improved, albeit the background setting of these listed buildings in some views would change. 69. The Council s Albert Embankment Conservation Area designation report describes the existing buildings lining the Embankment and not included in the Area as generally monotonous and architecturally mundane office blocks of the 1950s and 1960s. Current townscape policy as set out in policy PN2 of the Core Strategy, and in the OAPF and Vauxhall SPD, seeks to avoid the creation of a wall effect through ensuring variation in roofline and sufficient gaps between buildings. Permissions have been granted for developments along the Embankment to the south that reflect this approach. In adding depth to the River frontage as perceived in views across the River, and marking a new quarter within the Conservation Area, the proposal would be consistent with these aims. This is a factor to be balanced against the harm that would result from the visibility of the proposed new buildings in the setting of no The Vauxhall Gardens Conservation Area lies on the east side of the railway viaduct. It includes the tunnel under the viaduct at Black Prince Road and the adjacent road frontages, forming a projection from the main part of the Area, which is to the east and south. The Area takes in 20 th century housing estate developments, and these together with associated open spaces and surviving older buildings, including a number of public houses, define its main features. The former Ragged School on Newport Street near Black Prince Road adjoins the rear part of the appeal site. Proposed Building G on this currently vacant site would be taller than other buildings in the immediate vicinity. The viaduct forms a divide in townscape character, with taller buildings beyond to the west, but the proposal would be seen in the context of these, and on this site its scale would not appear excessive. As part of the townscape corner to one side of the Ragged School, the proposal would not be unduly dominant in relation to 15

52 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ this. The masonry form and detailing respond appropriately to the features of the Conservation Area, and the new development would repair the current gap site. On balance the character and appearance of the Area would be preserved, including in terms of its setting as a result of the proposed buildings on the front and middle parts of the appeal site. 71. The proposal would have no effects of any importance on the settings of other Conservation Areas in the surrounding area. It is common ground that there would be no harm to designated strategic views or conflict with policy 7.11 of the London Plan on these. Overall impact on significance of heritage assets 72. Taking into account all of the above, an assessment can be made of the overall impact of the proposal on the significance of the heritage assets in terms of both direct effects and changes to their settings. 73. There would be some aspects of preservation and enhancement with respect to the proposed use of no. 8, the refurbishment of no. 8 and the Drill Tower, the removal of the 1980s extension, improvement of views of Southbank House, and creation of a new high quality quarter with street level activity within the Albert Embankment Conservation Area. There would be harm to no. 8 from the dilution of its unaltered original form, the loss of some fabric and integrity, and the intrusion on its skyline profile and landmark quality arising from this. Due to the contribution of the building to the character and appearance of the Albert Embankment Conservation Area, associated harm to this would also result. In these respects there is some conflict with the heritage asset objectives of policy 7.8 of the London Plan and policies 45 and 47 of the UDP, and with policy 36 of the UDP on alterations and extensions as a result of the effects of the roof and rear extensions to no The heritage harm is limited by a number of factors as well as offset by the positive effects. In particular, these are the relative robustness of the original architecture of no. 8, the continued legibility of this which would largely preserve its monumental and landmark qualities, the extent of retention of original fabric, and the high quality of design in the proposed new works. As a result I assess that the degree of residual harm to the heritage assets of no. 8 and the Albert Embankment Conservation Area would be less than substantial. Balancing benefits and whether optimum viable use 75. According to the NPPF, where a development proposal would lead to less than substantial harm to the significance of a designated heritage asset, as in this case, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use. 76. The appellants case with regard to optimum viable use is based on the appropriateness of the proposed mix of uses and the agreed position on viability of the appeal scheme, as dealt with above. 77. The Council in its written evidence put forward an alternative test development scenario involving the front site alone and with the roof extension removed, but in all other respects being the same as this element of the appeal scheme with the inclusion of affordable housing. This was claimed to be able to generate a residual land value of 0.74m- 1.34m (rather than zero) on the basis of previously agreed profit targets. However, tested at the inquiry it was 16

53 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ accepted that incorrect assumptions about cost inputs had been made, and it was conceded that this scenario is not viable. This confirmed a position that had previously been explored by the appellants at application stage and agreed by the Council. 78. Subsequently, in cross examination of the appellants financial witness a further variation of this scenario was raised involving the omission of affordable housing. Again it appears that various incorrect assumptions were made in the figures supporting this option, in particular by removing the cost of providing affordable housing but not amending other consequential increased costs. As corrected, the maximum profit would be around 13%, and could be as low as 9%, depending on assumptions made about off-plan sales discounts in particular. While not greatly below the profit level at which the appellants contend the appeal scheme would proceed, the overall total development value would be substantially less. Furthermore, this option involves what is the most complex part of the whole site to deal with in terms of requiring the adaptation of an existing listed building. The risk involved in developing this in isolation would be correspondingly greater. No evidential case was made to justify the proposition that such a scheme would be proceeded with, this merely being suggested by submission. 79. A further supposition was made that the viability of a whole site development that omitted the roof extension could be improved by reducing the commercial content and increasing the residential content on the middle part of the site, thereby in effect providing a cross subsidy. This equates to the Council s alternative land use scenario, considered above under issue b). However, I have already concluded that the commercial content of the scheme is an appropriate response to the economic and employment objectives for the site. As such the appeal scheme strikes an acceptable balance in this respect between the land use objectives, which make conflicting demands on the scheme given the limited viability. This suggested option is therefore not well founded. 80. Another arm of the Council s case is that the optimum viable use might not include re-provision of a fire station on the site. There are two aspects to this. Firstly, that the original use is not necessarily the most compatible with the long-term conservation of a heritage asset. Secondly, the costs associated with provision of the fire station would not need to be carried by the scheme were this element replaced by another use. 81. I have already dealt with the appropriateness of the proposed uses in terms of preserving the historic purpose and association of the building, and hence sustaining an aspect of its significance. Given the concern about loss of Fire Brigade related fabric, it is also difficult to envisage a potentially viable use that would be more compatible with such fabric than a fire station. The continued fire station use is consistent with the aspirations of the English Heritage/London Fire Brigade guide. In addition, the proposed uses would bring full occupation of a building that is currently largely vacant and redundant from its former use, and secure its long term future. 82. Conversely, the Council argues that housing the fire station use on the first as well as the ground floor would enable more fabric to be retained. While this might be possible in functional terms, this would reduce the accommodation available for conversion to residential use and raise issues with respect to 17

54 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ containment of fire station impact on residential amenity. Such an option would hence result in a reduced viability. 83. Having regard to all the available evidence, I therefore consider that the proposal can reasonably be regarded as the optimum viable use of no. 8, despite is limited viability. As such this represents an important heritage benefit, in addition to those already identified above. 84. The replacement of the fire station would also be a public benefit in more general terms. While the fire station is able at present to function and meet its operational targets, the evidence identifies some clear deficiencies against current standards as a result of the relatively aged nature of its accommodation. The aspects of concern are consistent with the limitations of fire stations operating within historic buildings identified in the English Heritage/London Fire Brigade guide. These deficiencies would be addressed with the proposed replacement facility. Although this might not be an urgent need, the securing of the improvements through provision of a modern fire station would be a beneficial outcome of the development. 85. Policy 7.9 of the London Plan encourages heritage-led regeneration. Specific regeneration objectives for this location are set out in the London Plan, the Core Strategy, the OAPF and the Vauxhall SPD. Consistent with these, the proposal would introduce an intensive mix of uses onto an underused site in a development of high architectural quality, while retaining important aspects of the heritage assets, and as such is supported by the Greater London Authority. It would in particular bring animation into street frontages, especially Lambeth High Street, which are currently poorly addressed by surrounding development and to a large extent have an unattractive and sterile environment, including at the rear of the fire station. This is in accordance with policy MDO4 of the UDP and policy PN2 of the Core Strategy. 86. In addition, the gain in commercial floorspace and residential accommodation, including affordable housing, would help meet land use objectives and bring economic benefits consistent with the development plan and Government policy. 87. Given the statutory requirements relating to consideration of proposals affecting listed buildings and conservation areas and their settings, the residual harm to the heritage assets carries substantial weight, and I accord it such. However, the public benefits in this case would be of considerable value, and I consider that these outweigh the identified harm and the conflicts with policy that arise. Issue d) the impact the proposal would have on the living conditions of nearby residential occupiers by reason of loss of daylight and sunlight 88. Policy 33 of the UDP is that all development should be of a high quality design and contribute positively to its surrounding area. This includes part (d) that development should protect the residential amenity for existing and future residents by, among other things, having an acceptable impact on levels of daylight and sunlight. Policy 40 on tall buildings includes a requirement that the amenities and development possibilities of surrounding sites should not be impaired. Similarly, policy 7.6 of the London Plan includes that buildings and structures should not cause unacceptable harm to the amenity of surrounding land and buildings. 18

55 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ Of relevance to neighbouring amenity in this case is that the area of the appeal site is subject to a policy led expectation of new development which would be an intensification of that which currently exists. The residential properties around the site presently neighbour the relatively low buildings on the middle part and the vacant plot of the rear part. In this context some inevitability of change from the baseline conditions with respect to residential amenity is to be reasonably anticipated, as acknowledged by the Council. Nevertheless, the OAPF says it is essential that development in the Opportunity Area does not compromise the amenities or environment of existing communities in and around the Area. The appeal proposal would affect the light levels to a large number of neighbouring properties. Indeed, for those living in Whitgift House, which is immediately to the north of the middle part of the site, the appellants accept that there would be an undoubted significant and noticeable reduction in daylight. The issue on neighbouring living conditions therefore divides into, firstly, the degree of harm from such impact, and secondly the significance of the harm in the overall balance of considerations. 90. Subsidiary matters arise in evaluating the degree of harm. These relate to the appropriate assessment techniques to apply, and what can be concluded from comparisons with other examples. The BRE guide on Site layout planning for daylight and sunlight (2011) provides criteria in relation to two indicators for use in assessing existing daylight and the effects of development on existing buildings. Vertical Sky Component (VSC) is a measure of the amount of light at the window wall, and the No Sky Line (NSL) is a measure of distribution of light within a building. According to the BRE, a room can experience an adverse effect if either guideline is not met in terms of change from the existing situation. The BRE guide is not itself policy but widely used by planning authorities in assessing impact, and is referred to as such in the UDP. 91. In addition to the BRE criteria, analysis has been carried out by the appellants of Average Daylight Factor (ADF), which is calculated for individual rooms and depends on window and room characteristics as well as the amount of light at the external wall. ADF is cited as a measure of general illumination from skylight in BS :2008 Lighting for buildings. In most circumstances an occupier is restricted in changing ADF, such that external obstructions determine loss of light, and it is not used as a criterion in the BRE guide. Similarly, the BS cross-refers to the advice in the BRE guide with respect to loss of light to existing buildings from new development. However, as a measure of the actual light within a room the ADF is also a useful indicator, including with respect to change in this. This is particularly so given the agreed position of the main parties in this case that there should be a reasonable expectation of some loss of light, and therefore absolute levels within affected rooms are important. 92. With respect to comparables, the appellants have put forward various examples of light assessments carried out for developments both in the vicinity and elsewhere in Central London. These confirm the common use of ADF as an indicator. However, for the reasons given by the Council the cases cited fall well short of establishing a strong evidential base in support of reductions to specific levels of light for the buildings around the appeal site. There are many variables involved: the before and after light levels as measured by the different criteria, the numbers and proportions of rooms/properties affected, the extent of breaches of criteria and degrees of change, whether the affected properties are part of a new development, and detailed configurations of 19

56 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ windows and balcony arrangements. The examples presented were absent of a detailed commentary such as to justify or assist an understanding of quantitative conclusions applicable to the current case that can be drawn. The comparisons made with typical London streets also lack contextual reference and robustness. As a result little weight can be placed in detailed terms on the appellants allusion as to what has been found acceptable in other cases based on central London experience or in an inner urban environment. 93. The approach I take is therefore to make an overall judgement of impact using all the information available and having reference to both the BRE and BS guidelines and the particular site context, while also having regard to the policy led development aspirations. This acknowledges that the criteria are to be applied flexibly and to help rather than constrain design. I deal in turn with the residential buildings around the site where the Council has contended there would be a moderate or greater adverse impact on daylight. 94. Whitgift House (1-24) is a five storey block of flats. There are 60 windows in the south elevation facing towards the appeal site, with a total of 66 windows tested. Existing VSCs mostly exceed or are very close to the 27% level which the BRE guide suggests provides adequate daylight reaching a window. While proposed Building E(N) directly opposite Whitgift House would be a relatively low structure, the latter s south facing windows would be substantially affected by the size and proximity of Buildings D and F. With the development the VSCs for all of these windows would fall below 27%. For virtually all windows (64 of 66) the reduction would be to less than 0.8 times the former value (i.e. more than 20% loss), therefore breaching the BRE guideline for a noticeable impact. The losses mostly exceed 40% of the former value, with resultant VSCs all below 20% and nearly half (28 windows) falling to below 16% VSC. 95. With respect to ADF, almost all rooms currently exceed the 2% criterion which the BS states is necessary to achieve a predominantly daylit appearance. With the proposal 27 out of 30 living rooms would fall below this level, with virtually all room losses exceeding or near to 30% of the existing value. The ADF of many living rooms would fall to only just above or slightly below the minimum level of 1.5% which the BS recommends even if a predominantly daylit appearance is not achievable. With respect to daylight distribution, the BS advises that uniformity of daylight is considered to be unsatisfactory if a significant part of the working plane (normally more than 20%) lies behind the no sky line. With the proposal that would apply to many living rooms, with almost half of these falling to less than 0.8 times the existing value (i.e. more than 20% reduction), and therefore according to the BRE with a likely adverse effect on the distribution of light. There is no support in the guidance for the appellants use of an alternative 50% room proportion behind the working plane as an indicator of unsatisfactory daylight distribution. 96. The effect of the proposal on Whitgift House is that the accommodation in almost all flats would appear markedly gloomier and there would be a substantially increased reliance on electric light. While most rooms would exceed the BS minimum ADF levels, given that for many living rooms these would only just be met or missed, coupled with the degree of loss of light and the unsatisfactory distribution in many cases, this in itself does not make the impact acceptable. 97. Existing daylight to the Whitgift House flats is at fairly good levels as measured by VSC and ADF. However, the building was erected contemporaneously with 20

57 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ the Fire Brigade development, and therefore this has been the position since it was first occupied around 70 years ago. Although located to the west of the railway viaduct, the nature of its setting and outlook in terms of access to daylight does not appear to differ significantly from other social housing estate flat blocks in the vicinity. The appellants assertion that Whitgift House enjoys unusually beneficial daylight for its location is therefore not established. 98. I have nevertheless already noted that some reduction in daylight can reasonably be expected as a consequence of development aims for the area. The BRE suggests that in special circumstances a local planning authority may wish to use different target values, for example in an historic city centre or in an area with modern high rise buildings where a higher degree of obstruction may be unavoidable if new developments are to match the height and proportions of existing buildings. One approach is for targets to be set for a mirror image building of the same height and size and equal distance away from the other side of the boundary. The appellants analysis of such a building on the appeal site has not been correctly undertaken in that it does not comply with these criteria, and therefore exaggerates the impact on Whitgift House of a true mirror image building. However, even with a building existing in this exaggerated form the VSCs to Whitgift House would almost all exceed 20% and most living room ADFs would exceed 2%. By comparison with this, the light levels resulting from the appeal scheme development would be significantly worse. 99. Taking all the above into account, the impact of the proposal on daylight to Whitgift House would go beyond what can reasonably be expected to be borne by the occupiers, in particular of those flats with the most affected living rooms. This would amount to a substantially harmful diminution in the quality of living conditions, notwithstanding improvements that the proposal would bring to the wider amenity of the area Whitgift Street (also described as former car park) is a recently built 6 storey block of flats. The flank of proposed Building F would be directly opposite its south elevation, where there are living rooms and bedrooms facing the appeal site. There are multiple windows to each room, with those to the living rooms set below balconies (some windows face northwards). Despite the effect of the balconies on daylight, all living rooms currently have more than one window exceeding 27% VSC, and all have an ADF well above 2%. Percentage reductions in VSC would be substantial, with many considerably exceeding 50%, and all 36 windows would fail the BRE criterion for noticeable impact. Although all 6 living rooms would exceed or be fairly close to an ADF of 2%, those for all 4 affected bedrooms would fall to below 1% (the suggested minimum for such a room in the BS). Despite that daylight distribution would remain relatively good, with no windows failing the BRE test for loss, this is not a measure of the amount of daylight, and there is no sound justification for weighing the assessment towards this criterion. Although the flats have the benefit of balconies, and this building was constructed at the time that proposals for the appeal site were in preparation, the Council s assessment of the degree of adverse impact is correct, and this amounts to substantial harm Lambeth High Street (also described as Block 17) is a two storey building used as a hostel. Its rear windows face obliquely towards the middle part of the appeal site. 8 of 24 windows would lose more than 20% of VSC, but existing levels to these are low. Only 4 losses of ADF would exceed 20%, 21

58 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ and in each of these rooms ADFs are already well below 2%. Daylight distribution would generally not be seriously affected. The noticeability of the daylight losses to this building would therefore be limited. The Council judges the impact to be moderate adverse, and I consider that within the overall context the harm would be acceptable. 6 windows would fail the BRE guidance in terms of loss of sunlight, but these would retain above 20% annual probable sunlight hours, and in this location the reduction is acceptable. The garden area would also not be seriously affected by loss of sunlight Newport Street comprises a 3 storey block of flats on the east side of the railway embankment. 11 of 20 windows would lose more than 20% of existing VSC, but the highest reduction would be 25%. All ADF losses would be below 20%, and of 3 NSL losses above 20% the highest would be 25.7%. The Council assesses the impact to be moderate adverse, and again in context I consider that the harm would be acceptable Black Prince Road is a 4 storey block of flats to the east of the railway embankment facing the rear part of the appeal site where Building G is proposed. 14 of 17 windows would breach the BRE criterion on VSC, with reductions up to 49.13% of existing. However, VSCs would mostly continue to exceed 20%, and all rooms tested, most of which appear to be bedrooms, would exceed or be very close to 1% ADF. Taking into account that this building fronts immediately onto a footway, and currently faces a vacant site, the harm would be acceptable despite the effects also on daylight distribution Queens Head Public House also lies on Black Prince Road opposite the location of proposed Building G. Of 7 windows, 4 would fail the BRE criteria on VSC with the proposal. However, daylight as measured by VSC and ADF overall would remain at reasonable levels to the 4 rooms, with only 1 room also more significantly affected in terms of distribution. Again, bearing in mind the location, the harm would be acceptable Windmill Public House lies to the north of the appeal site on Lambeth High Street. 10 of 20 windows would fail the BRE criteria with the proposal, but all rooms with the highest losses would retain at least one window with over 20% VSC except one case at 18.29%. Similarly, rooms with higher ADF losses would retain significantly more than 2% ADF (except for one case), and there are no NSL failures. The Council judges the impact to be moderate to substantial adverse, but the harm would be acceptable Overall, therefore, I assess that, while the effects on other buildings in the vicinity would be within acceptable limits, there would be harm to the living conditions of the occupiers of Whitgift House and 2 Whitgift Street as a result of loss of daylight which would be a substantial loss of amenity. This includes taking into account the context of those buildings and the policy led expectation of development, and the wider benefits to the neighbourhood from the proposal. I note that the daylight and sunlight impact of the proposal on surrounding properties was considered by Council officers at application stage to be acceptable. This followed advice received in an independent expert review of the submitted impact assessment. However, that advice was restricted in concentrating on the urban location of the site, and lacking reasoning as to the detailed basis for acceptability having regard to the particular impacts I have set out. In addition, countering this conclusion is the expert evidence given for the Council at the inquiry in support of its reason for refusal on this ground. 22

59 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ The identified harm to Whitgift House and 2 Whitgift Street would be a significant breach of the relevant development plan and supplementary policies on amenity and carries substantial weight to be taken into the overall balance. I further note that there is insufficient evidence on alternative configurations of development to justify the assertion that it would be impossible to develop the appeal site satisfactorily with a lesser impact, or more generally meet London s housing needs without an acceptance of the degree of impact that the appeal proposal would have. Conclusions 108. I have found the proposal to be acceptable on three of the four main issues, including having regard to viability considerations. It would secure the future of the listed buildings, and have regeneration and economic benefits including the provision of a large amount of residential accommodation. In many respects it would be a sustainable development. However, one of the core planning principles set out in the NPPF is always to seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings. The harm to the living conditions of Whitgift House and 2 Whitgift Street does not comply with this objective, and represents a shortcoming in achieving a fully sustainable development I have taken all other matters into account, including the planning obligations and proposed conditions and the budget position of the Fire Authority. However, the harm identified on the last main issue outweighs the benefits, and warrants refusal of planning permission (Appeal A) In the absence of an approved redevelopment that would deliver the benefits of the scheme, listed building consent should also be withheld (Appeal B). Similarly, and to prevent a harmful gap site in the Conservation Area, conservation area consent for demolition should not be granted (Appeal C) For the reasons given above I conclude that the appeals should be dismissed. T G Phillimore INSPECTOR 23

60 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ APPEARANCES FOR THE LOCAL PLANNING AUTHORITY: Matthew Reed of Counsel He called: Anthony Lee BSc(Hons) MSc(Econ) MA(TP) PhD MRTPI MRICS Paul Littlefair MA PhD CEng MCIBSE MSLL Douglas Black BSc MSc MRTPI IHBC Gillian Nicks BA MA MSc Brian Hurwitz Instructed by Head of Legal Services, London Borough of Lambeth Director, BNP Paribas Real Estate Principal Lighting Consultant, BRE Team Leader, Conservation and Urban Design Team, L B Lambeth Principal Officer, North Team, L B Lambeth Sharpe Pritchard FOR THE APPELLANTS: Russell Harris QC Instructed by Clyde & Co LLP He called: Alex Lifschutz BSc(Hons) Ron Dobson CBE QFSM FIFireE Dr Chris Miele IHBC MRTPI FRHS FSA Professor Robert Tavernor BA DipArch PhD RIBA Susan Cocking Jerome Webb MRICS Matthew Gibbs BSc(Hons) MA MRTPI Ian Ginbey Director, Lifschutz Davidson Sandilands London Fire Brigade Commissioner Senior Partner, Montagu Evans Principal, Tavernor Consultancy Partner, Knight Frank LLP Partner, Gordon Ingram Associates Partner, DP9 Planning Consultants Clyde & Co 24

61 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ INTERESTED PERSONS: Rule 6 Parties Michael Ball George Turner David Boardman Others Kate Hoey MP Councillor Mark Harrison Eileen Bagg Maureen Johnston Michael Copeman Visakha Sri Chadrasekera A Hassan Jerrand Brown Darren Bowler Linda Davidson Angus Boag David Hughes Paschal Tiernan Waterloo Community Development Group Whitgift Estate Tenants and Residents Association and Friends of Lambeth High Street Recreation Ground Kennington Association Planning Forum Member of Parliament for Vauxhall Lambeth Council Member for Princes ward Local resident Local resident Local resident Local resident Local resident Local resident Windmill Public House ehealth Media Ltd Workspace Group Plc Local resident and surveyor James Knight of Mayfair DOCUMENTS SUBMITTED AT THE INQUIRY 1 Opening statement by the Appellants 2 Opening statement by the Council 3 Opening statement by Waterloo Community Development Group, Whitgift Tenants and Residents Association and Friends of Lambeth High Street Recreation Ground 4 Opening statement by the Kennington Association 5 Appeal decision APP/X5210/A/12/ Letter from Angus Boag, Workspace Group Plc dated 25 February Letter from Dr Miele to L B Lambeth dated 15 June 2011 with attachments 8 Dr Lee s replacement appendices 9 Appellants bundle of daylight/sunlight results on other developments 10 Mr Boardman s Appendix K15 11 L B Lambeth Planning Applications Committee report on Vauxhall Square (extract) 12 L B Wandsworth Planning Applications Committee report on New Covent Garden Market (extract) 13 BS :2008 Lighting for buildings - Part 2: Code of practice for daylighting 14 Lambeth Fire Station Redevelopment Design Brief - Accommodation Schedule 15 Extracts from L B Lambeth and L B Hackney Planning Committee reports submitted by Appellants 16 L B Lambeth Housing Implementation Strategy February PPS5 Planning for the Historic Environment Practice Guide June L B Lambeth Local Development Framework Proposals Map (2no) 19 Mr Boardman s Appendix K16 (Native Land website extract) 20 Census local area figures submitted by Mr Ball 25

62 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ LFEPA Briefing Note dated 12 October Appraisal Summary - Southwark CIL Study submitted by Mr Ball 23 Statement by Maureen Johnston with attachment 24 GIA Transient Overshadowing illustrations 25 Statement by David Hughes 26 Mr Hughes s build costs assessment information 27 Statement by Visakha Sri Chadrasekera with attachments 28 Statement by Michael Copeman for 9 Albert Embankment Residents Association 29 Statement by Linda Davidson, ehealth Media Ltd 30 Letter from Darren Bowler dated 28 February Draft s106 Agreement 32 from Mr Boardman to the Council dated 15 February 2013 re: planning contributions 33 Draft conditions with appellants amendments 34 Figure 2.1 from VNEB Development Infrastructure Funding Study Final Report October Council s suggested Travel Plan condition 36 Statement by Kate Hoey MP 37 exchange submitted by Kate Hoey MP 38 Errata to Dr Miele s proof 39 English Heritage Enabling Development 40 Albert Embankment LLP Members Report and Accounts 31 October Mr Reed s cross examination note on Front Site Only Appraisal 42 from Dr Lee dated 12 March Ms Cocking s Qualifications and Experience 44 Appeal decision ref APP/N5660/A/10/ with Mr Ball s note 45 RTPI s response to RICS consultation on financial viability document 46 Appellants revisions to figures in Mr Reed s cross examination note on Front Site Only Appraisal 47 Appeal decision APP/V5570/A/11/ Appeal decision APP/N5660/A/11/ Park Plaza Riverbank Hotel Daylight and Sunlight Report November Mr Webb s street sections 51 Dr Littlefair s table of ADF failures 52 Lambeth LDF Core Strategy Topic Paper 2: Key Industrial and Business Areas 53 Lambeth Planning Guidance Note: Marketing of Employment Premises and Sites 54 Extract from s106 for Vauxhall Island 55 Agreed CIL Regulation 122 statement on s106 obligations 56 Revised planning conditions 57 Reasons for conditions 58 Revised listed building consent/conservation area conditions 59 Revised draft s106 agreement 60 Draft s106 unilateral undertaking 61 Extract from Mayor s SPG on Land for Industry and Transport 62 Mr Webb s note on Dr Littlefair s table of ADF failures 63 Appellants plan identifying proposed yard areas 64 Copy of s106 obligations marked up with Council s comments 65 Closing statement by the Kennington Association 66 Knight Frank London Hotspots report Closing statement by Waterloo Community Development Group, Whitgift Tenants and Residents Association and Friends of Lambeth High Street 26

63 Appeal Decisions APP/N5660/A/12/ , APP/N5660/E/12/ , APP/N5660/E/12/ Recreation Ground 68 Closing statement by the Council 69 Closing statement by the Appellants 70 Core documents list dated 14 March 2013 DOCUMENTS SUBMITTED FOLLOWING THE INQUIRY 71 S106 Agreement dated 27 March S106 Unilateral Undertaking dated 27 March

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65 Fire Station Listing APPENDIX 3

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67 List Entry 1 of 5 24/04/ :42 List Entry Summary This building is listed under the Planning (Listed Buildings and Conservation Areas) Act 1990 as amended for its special architectural or historic interest. Name: LAMBETH FIRE STATION List Entry Number: Location LAMBETH FIRE STATION, 8, ALBERT EMBANKMENT The building may lie within the boundary of more than one authority. County: Greater London Authority District: Lambeth District Type: London Borough Parish: National Park: Not applicable to this List entry. Grade: II Date first listed: 02-Dec-2002 Date of most recent amendment: 29-Oct-2009 Legacy System Information The contents of this record have been generated from a legacy data system. Legacy System: LBS UID: Asset Groupings This List entry does not comprise part of an Asset Grouping. Asset Groupings are not part of the official record but are added later for information. List Entry Description Summary of Building Legacy Record - This information may be included in the List Entry Details.

68 List Entry 2 of 5 24/04/ :42 Reasons for Designation Legacy Record - This information may be included in the List Entry Details. History Legacy Record - This information may be included in the List Entry Details. Details 963/0/10123 ALBERT EMBANKMENT 02-DEC-02 8 Lambeth Fire Station (Formerly listed as: ALBERT EMBANKMENT 8 LONDON FIRE BRIGADE HEADQUARTERS) II Fire station (former Brigade Headquarters of the London Fire Brigade). Built 1937 by the London County Council to the design of EP Wheeler, Architect to the LCC, assisted by G Weald. Sculpture by Gilbert Bayes, Stanley Nicholas Babb and FP Morton. MATERIALS: Steel frame clad in brown-grey bricks in English bond; ground floor, central part of the first floor, cornice to top floor and top of central tower are faced in Portland stone. Granite courses to base. PLAN: Long rectangular 8-storey block aligned N-S along river frontage. The building comprised a ground floor fire station, with staff facilities (mess rooms, dormitories etc) at first floor, offices at second, administration at third, and living quarters on the fourth to eighth floors. The appliance room is placed centrally on the ground floor, with main entrance hall to the S plus a smaller entrance hall to the N. Two stairs to rear. Each floor is bisected by a long axial corridor. A single-storey rear wing, originally housing the LFB museum, and a bandstand to the south east, were demolished in the 1980s to make way for a large new extension. EXTERIOR: Moderne style, expressed through severe geometry, stepped-back upper storeys, flat roof and strong horizontal emphasis. Symmetrical façade of 9 storeys, with top two storeys stepped back, apart from central 5 bays of eighth storey which thus form a centrepiece to the façade. 25 bays, plus set-back blind end bays forming returns to side elevations. Original steel-framed casement windows with horizontal glazing; those to each end are narrower; those to central 5 bays at first floor and the central bay above are triple casements with margin lights. Ground floor has 7 central appliance bays with deep stepped-back splayed reveals and an upper transom with horizontal fluting (these details are repeated in the lower pedestrian entrances to either side). Appliance bays have folding wooden doors (some replicated) of coffered panels with metal grilles to the upper parts; transom lights also have decorative metal grilles. To each side of the appliance bays are 4 small square windows with metal grilles, arranged 2 to either side of a pedestrian entrance. Entrances have panelled double doors with metal grilles; above each of them is a stone relief of firemen in action by Nicholas Babb. Stone balcony to first floor, continuing around side elevations, bears name of building. Above first floor of central 5 bays is stone cornice with horizontal fluting, curved at the ends and in the centre around two elaborate metal lamp standards. From the first to the third floors are central stone reliefs by Gilbert Bayes with gold mosaic backgrounds. Flanking the first floor are two galleys, above the first floor are two mermen with water hoses, above the second floor Phoebus in his chariot with sun's rays behind, and on the third floor a griffin. Horizontal rustication to eighth-floor centrepiece, which has inset panel of wheat ears, and to ninth floor. Central set-back tower has side pavilions and elaborate stone cornice with square and dot pattern, iron railings and flagstaff above, and

69 List Entry 3 of 5 24/04/ :42 large carved LCC coat of arms crest in stone by FP Morton. Return elevations of 6 bays with narrower end windows. Here the top 3 storeys are set back apart from the 2 end bays to SE rear, which form a corner tower. The rear elevation has balconies on all floors, the three lowest floors are deeper with cast iron balustrading. The ends project and there is a built-in canted bay observation post to the second floor. The lower balconies were designed to be used as display platforms for up to 800 people to watch weekly public drill displays. The building diminishes in depth above 3rd storey level. 1980s rear extension is not of special interest. INTERIOR: Main (S) entrance hall has marble cladding and a geometrical frieze. Doors have elaborate geometrical patterned grilles. On the right-hand rear (E) side, set in an alcove, is a memorial by Gilbert Bayes presented to the LFB by Lloyds underwriters and dedicated 'to the memory of the officers and men of the London Fire Brigade who throughout the years lay down their lives whilst doing their duty'. The central marble relief depicts a contemporary fire-fighting scene, set within a bronze frame with opening panels to either side bearing the names of 62 men. The top bears the motto "FINIS CORONAT OPUS", surmounted by a statuary group with a steam fire engine drawn by galloping horses. Set in the walls to either side are bronze grilles depicting billhooks and historic fire-fighting equipment, below which are bas-relief panels of modern appliances. In front of the memorial is a circular floor mosaic depicting the Great Fire of London. On the left rear wall is an elaborate tablet commemorating the establishment of the London Fire Brigade in This has a marble relief by Gilbert Bayes dated 1938 depicting an C18 fire fighting scene, set in a bronze frame with relief figures to either side and the inscription 'OMNIUM RERUM PRINCIPIA PARVA SUNT' at the top. A circular early 1950s sgraffito floor panel on the right (W) side depicts the areas of the London Civil Defence Region Fire Services. Memorial tablet against central pier to LCC staff who died in the two World Wars, with gilded key pattern. The smaller N entrance hall has similar doors and frieze to main entrance; marble cladding is 1980s. Open-well moderne style stairs with bronze balustrades. First-floor mess room with beamed coffered ceiling and some original timber fittings. Second floor has rear conference room faced in polished wood veneer with a fluted frieze; the sliding partitions have gone. The upper residential floors have largely been stripped of domestic fittings, although many original doors survive and a few fireplaces. Other features include original wood-veneer post boxes, and doors to pole houses. The basement has a generator which is thought to date from WWII. Lambeth Fire Station and the former drill tower to the rear (qv) form a group. The former training school and workshops to the rear of the main building in Lambeth High Street are not of special interest. HISTORY: Albert Embankment marks the close of a long and remarkable programme of fire-station building which began in 1866 with the formation of the Metropolitan Fire Brigade, the first publiclyfunded authority charged with saving lives and protecting buildings from fire. Initially part of the Metropolitan Board of Works, the earliest fire stations were generally plain brick and few pre-1880 examples survive. In 1880s under the MFB architect Robert Pearsall, the fire station acquired a true architectural identity, most notably in the rich Gothic style typical of Victorian municipal buildings such as Bishopsgate. It was the building boom of the 1890s-1900s however that was to transform fire station architecture and give the Brigade some of its most characterful buildings. In 1889 the fire brigade came under the control of the newly-formed London County Council, and from 1896 new stations were designed by a group of architects led by Owen Fleming and Charles Canning Winmill, both formerly of the LCC Housing Department, who brought the highly-experimental methods which had evolved for designing new social housing to the Fire Brigade Division, as the department was called from 1899, and drew on a huge variety of influences to create unique and commanding stations, each built to a bespoke design and plan. This exciting period in fire station design continued to the outbreak of WWI, although there was some standardisation of design in the period. No new fire stations were built between , and only a few up to WWII, and when building resumed, a more functional, stripped-down idiom was employed. The new headquarters of the London Fire Brigade in Albert Embankment replaced the first HQ of 1876 in Southwark Bridge Road (listed Grade II). It was built on land occupied by the London Pottery of Doulton & Co, and opened on 21st June 1937 by King George VI and Queen Elizabeth. The complex comprised the administrative headquarters of London firefighting, residential quarters, a working fire station with a whole range of staff facilities, a drill parade ground, drill tower, and a training school and

70 List Entry 4 of 5 24/04/ :42 maintenance workshops at the rear, also combined with flats. The grandstand-like rear elevation with tiers of balconies accommodated large crowds of spectators to watch fire-fighting displays on the drill tower. There was also a river fire station with pontoon, still in use but rebuilt. It was from here that the capital's fire-fighting operations were run during WWII, when an underground control room was constructed to withstand a direct hit and a gas attack, with its own reserve electric light installation and forced ventilation. The building ceased to be the LFB headquarters in January 2008, but continues as Lambeth Fire Station. SOURCES: The Fireman, April 1935, pp The Builder, 12 March 1937 Architect and Building News, 19 February 1937 The Architects' Journal, 22 July 1937 The Times, 22 July 1937 The Illustrated London News, 24 July 1937 English Heritage Historian's Report, LAM/35 John B Nadel, London's Fire Stations, 2006, p 113 REASONS FOR DESIGNATION: Lambeth Fire Station is designated at Grade II for the following principal reasons: * Of special architectural interest as a well-composed and externally unaltered 1930s building which, while in the streamlined Moderne idiom, upholds the Arts and Crafts ideal of collaboration between architecture and sculpture; * A landmark building on the south bank of the River Thames; * Important sculptural reliefs, most notably by the distinguished C20 sculptor Gilbert Bayes; * Interior features of interest, including the main entrance hall and sculpture; * Of special historic interest as the headquarters of the London Fire Brigade, the most important fire brigade nationally and the third largest in the world. The building was the centre of London's fire-fighting operations in WWII. Selected Sources 1. Book Reference - Author: Nadal, J - Title: Londons Fire Stations - Date: Page References: Article Reference - Title: 12th March - Date: Journal Title: The Builder 3. Article Reference - Title: 19th February - Date: Journal Title: Architect and Building News 4. Article Reference - Title: 22nd July - Date: Journal Title: The Architects Journal 5. Article Reference - Title: April - Date: Journal Title: The Fireman - Page References: Map National Grid Reference: TQ The below map is for quick reference purposes only and may not be to scale. For a copy of the full scale map, please see the attached PDF pdf

71 List Entry 5 of 5 24/04/ :42 Crown Copyright and database right All rights reserved. Ordnance Survey Licence number British Crown and SeaZone Solutions Limited All rights reserved. Licence number This copy shows the entry on 24-Apr-2014 at 04:42:06.

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73 List Entry 1 of 3 24/04/ :44 List Entry Summary This building is listed under the Planning (Listed Buildings and Conservation Areas) Act 1990 as amended for its special architectural or historic interest. Name: DRILL TOWER TO THE EAST OF 8 ALBERT EMBANKMENT List Entry Number: Location DRILL TOWER TO THE EAST OF 8 ALBERT EMBANKMENT, ALBERT EMBANKMENT The building may lie within the boundary of more than one authority. County: Greater London Authority District: Lambeth District Type: London Borough Parish: National Park: Not applicable to this List entry. Grade: II Date first listed: 02-Dec-2002 Date of most recent amendment: Not applicable to this List entry. Legacy System Information The contents of this record have been generated from a legacy data system. Legacy System: LBS UID: Asset Groupings This List entry does not comprise part of an Asset Grouping. Asset Groupings are not part of the official record but are added later for information. List Entry Description Summary of Building Legacy Record - This information may be included in the List Entry Details.

74 List Entry 2 of 3 24/04/ :44 Reasons for Designation Listed 02 DEC 2002 History Legacy Record - This information may be included in the List Entry Details. Details 963/0/10129 ALBERT EMBANKMENT 02-DEC-02 Drill Tower to the East of 8 Albert Em bankment GV II Drill tower designed by LCC's architect E P Wheeler FRIBA, assisted by D Weald FRIBA as part of the London Fire Brigade Headquarters scheme. Square structure in brown brick in English bond 100 feet high. Nine storeys with two window openings to each floor. The top two floors of the front elevation are recessed with stone cornices. There is a stone band above the rusticated ground floor. There are two flat-arched windows to each floor, now with metal grilles, and the rear elevation has smaller openings to the lower five floors. This drill tower is set an angle to the main building on the edge of the former parade ground. The drill tower was used for training and the balconies at the back of the main Headquarters building were designed to be used as display platforms to enable over eight hundred people to watch weekly public drill displays. TQ Selected Sources Legacy Record - This information may be included in the List Entry Details. Map National Grid Reference: TQ The below map is for quick reference purposes only and may not be to scale. For a copy of the full scale map, please see the attached PDF pdf

75 List Entry 3 of 3 24/04/ :44 Crown Copyright and database right All rights reserved. Ordnance Survey Licence number British Crown and SeaZone Solutions Limited All rights reserved. Licence number This copy shows the entry on 24-Apr-2014 at 04:44:00.

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77 Viability Appraisal APPENDIX 4

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79 8 Albert Embankment: Central South Housing Market, Planning and Viability Comment Report prepared for: London Fire and Emergency Planning Authority January 2015

80 8 Albert Embankment, Lambeth Viability Report January 2015 Contents 1 Introduction Executive Summary Albert Embankment, Lambeth Planning Comment The Existing Site Planning History Background Planning Policy Framework Employment Floorspace Other Considerations Community Infrastructure Levy Revised Scheme Conclusion Central South Market Commentary Demographic Analysis Demographic Profile Analysis Map Looking Forward Albert Embankment Viability and Assumptions with KIBA Revised Scheme New KIBA Compliant Scheme (Interpreted by JLL) Residential End Sales Comparable schemes Affordable Housing Provision Car Parking Community Infrastructure Levy Appraisal Inputs Appraisal Conclusion Appendix I: KIBA Appraisal Appendix II: Non KIBA Appraisal COPYRIGHT JLL IP, INC All Rights Reserved 2

81 8 Albert Embankment, Lambeth Viability Report January Introduction The purpose of this report is to consider the implications of the Proposed Modifications to the draft Lambeth Local Plan and the effect these changes will have on the proposed development site, 8 Albert Embankment and land to the rear, London, which for the purpose of this report will be referred to as the subject site. The report provides the outline planning context to potential redevelopment at the subject site. This should be interpreted alongside the draft Lambeth Local Plan which was submitted to the Secretary of State in March A public hearing was held in July 2014 and subsequent modifications were proposed on 17 November 2014 as part the examination hearing process. In addition, the report provides local property market context, highlighting the backdrop for commercial and residential values achievable in the local market. Taken together, these two background sections have informed the assumptions that have been used to model the viability of proposed redevelopment at the subject site. In particular, this viability assessment considers the direct impact of the Proposed Modifications to the draft Lambeth Local Plan on redevelopment at the subject site. COPYRIGHT JLL IP, INC All Rights Reserved 3

82 8 Albert Embankment, Lambeth Viability Report January Executive Summary 8 Albert Embankment, Lambeth Planning Comment A planning application for the subject site was submitted consisting of 360 homes and 7,214m 2 of commercial space. The application was withdrawn in April 2010, prior to formal determination following an office recommendation for refusal. A second application ( Appeal Scheme ) was submitted in December 2010 for 265 units. Although the application was recommended for approval, it was refused by the Council Planning Committee in February An appeal was lodged and a Public Inquiry held in February and March Although the appeal was dismissed, the Inspector accepted the arguments for a number of wider benefits that would be secured by the proposal which included a significant amount of residential development within the Key Industrial Business Area (KIBA). Since the Appeal Decision, the draft Lambeth Local Plan has been submitted for examination. The effect of the Proposed Modifications removes the crucial flexibility from the previous draft policy wording which allowed some residential on the middle and rear sites if it can be demonstrated that this is necessary to achieve an acceptable scheme in all other respects. The ability to provide some residential on these sites is considered fundamental to the financial viability and therefore deliverability of this development. Central South Sub-market Commentary Although the London market has out-performed the rest of the UK in recent years, the underlying fundamentals that underpin the Capital s housing market have changed. High, unprecedented capital values have been achieved along the Southbank, although these values are around half the values being achieved on the northern bank of the Thames. A natural stabilization of price growth has occurred recently after a period of exuberant growth due to a strong spring selling market. Price growth has reduced, returning to more sustainable levels showing that the market is maturing rather than turning. This is also offering a greater realism for vendors on pricing. A strong sales rate has been achieved in the Central South sub-market over the last few years. This has been based on a limited number of large schemes, which has helped to manage the volume of stock for sale at any given time. The Central South sub-market has a healthy future development pipeline, with plans for over 20,000 homes that may come forward over the next decade. This pipeline could represent a sales and pricing risk in the local market as it would require a significant increase in absorption rates compared with current levels. Households within close proximity to the subject site fall into two main categories Rising Prosperity and Urban Adversity. These households consist of either young, affluent career climbers or households that are struggling with high levels of debt. COPYRIGHT JLL IP, INC All Rights Reserved 4

83 8 Albert Embankment, Lambeth Viability Report January 2015 As the subject site is positioned between two of the largest regeneration projects in the Capital, it is likely that the proportion of households within the Rising Prosperity category will continue to rise as the area becomes more appealing in the next few years. Consequently, it is also likely that the proportions of households within the Urban Adversity category will reduce. JLL forecasts a maturing of the Central London market away from the previous unsustainable high rates of price growth. However, new build price growth will remain positive over the medium-term with between 4% and 5.5% growth expected from JLL s latest forecasts HOUSE PRICE GROWTH (%) Central London UK RENTAL GROWTH (%) Central London UK Source: JLL 8 Albert Embankment Viability and Assumptions with KIBA A KIBA compliant scheme (based on Native Land s Revised Scheme areas) produces a land value of - 13,500,000 (Negative Thirteen Million Five Hundred Thousand Pounds). A non-kiba compliant scheme (based upon Native Land s Revised Scheme areas) produces a land value of 43,000,000 (Forty Three Million Pounds). The significant different of land values is owing to the low commercial value of the KIBA element, making the KIBA compliant scheme unviable. The low commercial value is driven by limited demand for workspace in the area, ample supply of space in the vicinity and the high volume of proposed KIBA space is likely to result in high void rates and diluted rents. COPYRIGHT JLL IP, INC All Rights Reserved 5

84 8 Albert Embankment, Lambeth Viability Report January Albert Embankment, Lambeth Planning Comment 3.1 The Existing Site The site is located adjacent to the River Thames, south of Lambeth Bridge. The development site consists of three parcels of land. These are known as the Front, Middle and Rear sites. 3.2 Planning History Background The site has a significant and substantial planning history. A planning application, consisting of 360 homes and 7,214m 2 of commercial floorspace was submitted, but then withdrawn in April This was prior to formal determination following an officer recommendation for refusal. Later that year, a new scheme for 265 units was submitted for the redevelopment of the three sites ( Appeal Scheme ). The scheme was recommended for approval by officers, but members overturned the recommendation at planning committee and refused the proposals in February An appeal was subsequently submitted, and a Public Inquiry held in February and March The Inspector considered the following issues: a) Whether the scheme paid adequate regard to local employment and economic objectives; b) Whether the proposed level of provision of affordable housing was acceptable; c) The effect the proposal would have on the character, special interest and setting of listed buildings, the character and appearance of the Albert Embankment and Vauxhall Gardens Conservation Areas and of the surrounding locality; and d) The impact the proposal would have on the living conditions of nearby residential occupiers by reason of daylight and sunlight. COPYRIGHT JLL IP, INC All Rights Reserved 6

85 8 Albert Embankment, Lambeth Viability Report January 2015 The Inspector concluded that issue d) warranted dismissal of the appeal. However, the Inspector found in favour of the appellant on the other three matters. Notwithstanding the eventual dismissal of the appeal, the Inspector accepted the arguments for a number of the wider benefits that would be secured by the proposal which included a significant amount of residential development within the KIBA. These included: - An uplift in both the amount of floorspace and jobs within the KIBA; - The proposed mix of uses would be compatible with the existing uses in the area; - Not all commercial KIBA-compliant uses would be appropriate in this instance for this particular site; - Less jobs may be provided by a fully KIBA-compliant scheme; and - Only a residential scheme would deliver sufficient returns to make a scheme on the site viable. Since the Appeal Decision was issued a revised scheme ( Revised Scheme ) has been devised by the applicant. However, this Revised Scheme was not submitted to the Council. 3.3 Planning Policy Framework The Appeal Decision was issued in May 2013 and is a significant material consideration that carries considerable weight. The Appeal Decision reflected the existing planning policy framework at the time of the decision. Since the Appeal Decision, the draft Lambeth Local Plan has been submitted for examination. Both the Middle Site and Rear Site currently lie within the Southbank House and Newport Street Key Industrial Business Area (KIBA). The effect of the Proposed Modifications removes the crucial flexibility from the previous draft policy wording which allowed some residential on the Middle and Rear sites if it can be demonstrated that this is necessary to achieve an acceptable scheme in all other respects. The ability to provide some residential on these sites is considered fundamental to the financial viability and therefore the deliverability of development on the site. The addition of the word floorspace (rather than previous wording of replacement employment ) will further restrict the mix of uses that can be delivered on the Site. The previous version implied an emphasis on job creation. 3.4 Employment Floorspace Despite the existing KIBA designation, the Planning Inspectorate previously accepted that non KIBA uses within the KIBA could be justified on the basis of the wider economic benefits of the scheme. 3.5 Other Considerations i) Affordable Housing Lambeth s Core Strategy requires 50% affordable housing for schemes where public subsidy is available and 40% where no public subsidy is available. Policy H2 Delivering Affordable Housing of the Draft Local Plan also replicates this policy requirement. The proportion is also subject to housing priorities and, where relevant, viability evidence will be required to be independently assessed. Lambeth s Councillors consider the delivery of affordable housing to be the key priority for the borough. Below is an assessment of the affordable housing provision for schemes in the immediate area around the proposal site: COPYRIGHT JLL IP, INC All Rights Reserved 7

86 8 Albert Embankment, Lambeth Viability Report January 2015 Site Units Max Height (storeys) Prince Consort House (27-29 Albert Embankment) Eastbury House (30-34 Albert Embankment) Hampton House Percentage Affordable 1 Planning Permission % % % 2013 (20 Albert Embankment) Albert Embankment % Refused Parliament House (81 Black Prince Rd) % At Appeal 2009 Vauxhall Square % 2013 ii) Sunlight/Daylight The previous application was refused on the basis of an unacceptable impact on Whitgift House and 2 Whitgift Street. Whilst the Inspector noted that a reduction in light conditions could be justified, the extent of the impact on residential amenity was such as to warrant refusal. Changes to the massing in key areas of the building envelope would therefore be required in order to address this reason for refusal in the context of a future development proposal and the wider planning position, if planning permission for a comprehensive scheme on the site is to be secured. 3.6 Community Infrastructure Levy The Mayoral CIL is chargeable at a rate of 35 per m 2. The Lambeth CIL came into effect on 1 October For Zone A the Lambeth CIL charge for residential is 265 per m² and 125 per m² for offices. Therefore both the Mayoral CIL and the Lambeth CIL would be applicable for any future planning application. In respect of CIL charges, please note that if the existing buildings have been use for 6 months in the last 36 months then the relevant floorspace can be deducted as part of the net calculation. Furthermore, Social Housing Relief (SHR) can be claimed for the affordable housing elements that meet the specified criteria. 3.7 Revised Scheme Following the appeal decision, we understand that a revised scheme ( Revised Scheme ) was designed by the applicant. The Revised Scheme focussed on making changes to the Middle Site only and retaining the designs for the front and rear developments. The changes have been undertaken to remedy/reduce the sunlight / daylight impact that was the reason why the Appeal Scheme was dismissed. JLL was provided with the following schedule comparison of the Revised Scheme. 1 Based on Habitable Rooms, on site provision. 2 Year of Planning Permission issued, not the planning committee date. COPYRIGHT JLL IP, INC All Rights Reserved 8

87 8 Albert Embankment, Lambeth Viability Report January 2015 Net Internal Floor Areas (Square Feet) Appeal Scheme Revised Scheme Change Private Residential 202, ,470-3,791 Affordable Housing 16,823 16, Commercial 70,853 54,314-16,539 Retail 5,765 5,765 0 Storage 5,342 5,342 0 Total 301, ,780-20,264 The private residential element in the Revised Scheme comprises 246 units. The affordable element of the Revised Scheme comprises just 18 units (7.3%). 3.8 Conclusion It will be shown in the following viability comment that the Proposed Modifications would significantly impact on the financial viability of any future proposal and could render the site undeliverable. The Proposed Modification to the draft Local Plan will have a detrimental impact to the deliverability of the site. In summary the proposed changes to Policy Site 10 is likely to have the following negative impacts on the potential for bringing the Albert Embankment site forward for development: - Reduce the amount of residential on the site to such a point that it renders the site financially unviable and therefore undevelopable; - Limit the opportunity to bring the site forward for development within the plan period; - The development potential of the site cannot be optimised resulting in a development with fewer planning benefits; - The amount of affordable housing that could be provided on the site is likely to be severely compromised; The Proposed Modifications to Policy Site 10 are likely to significantly restrict the amount of residential floorspace that could be delivered in the KIBA parts of the site. As a result, development is likely to be commercially unviable and therefore undeliverable. COPYRIGHT JLL IP, INC All Rights Reserved 9

88 8 Albert Embankment, Lambeth Viability Report January Central South Market Commentary In contrast with the rest of the UK, the London housing market has performed well over the past few years but some of the fundamental characteristics that underpin this market have changed. Buoyed by international investment throughout the economic downturn, the recent awakening of domestic purchasers into the London market has ensured that demand is well supported. The strength of the recovery in Prime residential values post-downturn has had strong positive impacts for market activity along the south bank of the river Thames. The perception of this area has been radically altered by the vast stepchange in the quality of the built environment, both for commercial and residential premises. Neo Bankside set this precedence, and rightfully achieved values of circa 1,375 psf in an untested, and largely undeveloped, location. These values, although high for a new location, are around half the values being achieved along the northern bank of the river. Annual price growth in the year to Q was 8.7% - over double the growth seen in Prime Central London of 3.3%. Development price growth Central South 20 Source: JLL Sep 10 Dec 10 Mar 11 Jun 11 Sep 11 Dec 11 Mar 12 Jun 12 Sep 12 Dec 12 Mar 13 Jun 13 Sep 13 Dec 13 Mar 14 % change per year Jun 14 Sep 14 Central South Central London Prime Central London In truth, we have recently observed a slowing of this rate of growth in 2014 after a very strong spring selling market. This exuberance in the marketplace has been unsustainable, leading to a natural stabilization to occur. Demand currently remains well supported and broad-based, alongside a greater realism from vendors on pricing. There has been a high level of unit sales in the Central South sub-market, with an average quarterly sales rate of over 500 units. Sales activity is largely development-led as there are only a handful of active players who have been able to control the amount of units being launched to the market at any one time. For example, the first phase of the iconic Battersea Power Station development is behind the surge in number of units sold in Q As more developers have bought into the area and obtained planning as of late, the ability to control the amount of units being released to the market has reduced, increasing the risk of market saturation. COPYRIGHT JLL IP, INC All Rights Reserved 10

89 8 Albert Embankment, Lambeth Viability Report January 2015 Absorption rates Central South 2,500 Source: JLL, Molior No. of units launched in last year 2,000 1,500 1, Sep 12 Dec 12 Mar 13 Jun 13 Sep 13 Dec 13 Mar 14 Jun 14 Sep 14 There is a healthy development pipeline within the Central South sub-market however the components of this supply will be delivered over more than a decade, ensuring that a much smaller sub-set of properties will be offered to the market at any given time. However, the development pipeline may represent a sales and pricing risk for the local area over the medium term. Along the 3km stretch of Thames riverside between Chelsea Bridge and Lambeth Bridge, there will be over 20,000 homes, 3.2m sq ft of office space and 2.3m sq ft of retail space, giving an indication of the expected future density of this new location. Further north along the Albert Embankment, development in the Opportunity Area will add to this shift towards higher value uses as a complement to the Central London property market. Units in planning pipeline Central South No. of units in planning pipeline 16,000 14,000 12,000 10,000 8,000 6,000 4,000 2,000 Source: JLL, Molior 0 Sep 12 Dec 12 Mar 13 Jun 13 Sep 13 Dec 13 Mar 14 Jun 14 Sep 14 Application Permission Unbuilt in existing schemes 4.1 Demographic Analysis CACI Acorn analysis of households is a useful way to understand the demographics of an area. The definitions of the Acorn Groupings used are provided below. Households within a 1.5 mile radius of the subject site are largely split into two of the six categories Rising Prosperity and Urban Adversity. COPYRIGHT JLL IP, INC All Rights Reserved 11

90 8 Albert Embankment, Lambeth Viability Report January 2015 Households that fall into the Rising Prosperity category are generally younger, well-educated and mostly prosperous people living in our major towns and cities. Often these are highly educated younger professionals moving up the career ladder. Areas that have high proportions of households in this category usually have a high proportion of renters as many of these young professionals have yet to raise the capital for a deposit. At 46%, this sits below the proportion in Lambeth (55%), but above the proportion seen in Greater London (34%) and England & Wales (10%). Many of the most deprived areas of towns and cities across the UK fall into the category Urban Adversity. Household incomes are low, nearly always below the national average. The level of people having difficulties with debt or having been refused credit approaches double the national average. The proportion of households within close proximity of the subject site that sits in Urban Adversity is 46% - above the proportions seen in Lambeth (37%), Greater London (28%) and England & Wales (10%). The subject site is positioned between two of the largest regeneration projects in London Vauxhall Nine Elms Battersea (VNEB) and Elephant & Castle. This is putting upward pressure on other local areas around Oval, Camberwell and Kennington to be regenerated, which will potentially be assisted by the extension of the Bakerloo underground line to Camberwell depending upon the results of the ongoing consultation. As the regeneration continues over the next decade and the area becomes more appealing, it is likely that the proportion of households within the Rising Prosperity category continues to rise as the proportion of households within the Urban Adversity category diminishes. 1.5 miles Lambeth Greater London Eng & Wales Affluent Achievers 3% 2% 13% 22% Rising Prosperity 46% 55% 34% 10% Comfortable Communities 0% 2% 16% 27% Financially Stretched 4% 4% 9% 23% Urban Adversity 46% 37% 28% 18% Not Private Households 0% 0% 0% 0% Source: JLL, CACI COPYRIGHT JLL IP, INC All Rights Reserved 12

91 8 Albert Embankment, Lambeth Viability Report January Demographic Profile Analysis Map

92 Households by Acorn group Affluent Achievers Rising Prosperity Comfortable Communities Financially Stretched Urban Adversity Not Private Households Source: JLL, CACI These are some of the most financially successful people in the UK. They live in wealthy, high status rural, semi-rural and suburban areas of the country. Middle aged or older people, the baby-boomer generation, predominate with many empty nesters and wealthy retired. Some neighbourhoods contain large numbers of well-off families with school age children, particularly the more suburban locations. These are generally younger, well-educated and mostly prosperous people living in our major towns and cities. Most are singles or couples, some yet to start a family, others with younger children. Often these are highly educated younger professionals moving up the career ladder. Most live in converted or modern flats with a significant proportion of these being recently built executive city flats. This category contains much of middle-of-the-road Britain, whether in the suburbs, smaller towns or the countryside. All life stages are represented in this category. Many areas have mostly stable families and empty nesters, especially in suburban or semi-rural locations. There are also comfortably off pensioners, living in retirement areas around the coast or in the countryside and sometimes younger couples just starting out on their lives together. This category contains a mix of traditional areas of Britain. Housing is often terraced or semi-detached, a mix of lower value owner occupied housing and homes rented from the council or housing associations, including social housing developments specifically for the elderly. This category also includes student term-time areas. There tends to be fewer traditional married couples than usual and more single parents, single, separated and divorced people than average. This category contains the most deprived areas of large and small towns and cities across the UK. Household incomes are low, nearly always below the national average. The level of people having difficulties with debt or having been refused credit approaches double the national average. The numbers claiming Jobseeker s Allowance and other benefits is well above the national average. Levels of qualifications are low and those in work are likely to be employed in semi-skilled or unskilled occupations. These are postcodes where the bulk of residents are not living in private households which can be subdivided into three groups. Active communal population are people that may be in communal establishments yet still consumer to some degree. This includes defence establishments like military bases. It also includes hotels and other holiday accommodation. Inactive communal population are establishments like care homes, hospitals and other medical establishments. 4.3 Looking Forward At a fundamental level London residential demand remains well-supported. Over the medium-term, this will put upward pressure on prices across all sub-markets, with a particular strength expected in suburban locations. JLL forecasts a maturing of this market away from the previous unsustainable high rates of price growth. However, new build price growth will remain positive over the medium-term with between 4% and 5.5% expected from There are some risks to price growth in Prime and neo-prime locations, such as the VNEB and Southbank areas. Most commentators anticipate little or no growth in the short-term for these locations, with material risks to these markets from Government policies, both new and planned, for high value properties. JLL s latest forecasts HOUSE PRICE GROWTH (%) Central London UK RENTAL GROWTH (%) Central London UK Source: JLL

93 5 8 Albert Embankment Viability and Assumptions with KIBA For the purpose of our appraisal, we have relied upon floor areas based on the Revised Scheme, which followed the Appeal Scheme, to examine how the daylight issues would be addressed. The Revised Scheme provided a cut-back design to resolve the daylight issues. This Revised Scheme, for the purpose of this appraisal, is taken has the maximum massing of building that could be accommodated on the Site. (The Revised Scheme was not progressed or submitted to the Council.) 5.1 Revised Scheme Residential (Net Saleable Area) Element (Sq Ft) Block A Block B Block D Block E Block F Block G Total Sq Ft Total M Sq Private Residential 55,479 21,087 84,101 18,256 19, ,469 18,438 Affordable 7,847 9,042 16,889 1,569 Residential Total 55,479 21,087 84,101 18,256 27,394 9, ,358 20,007 Commercial (Net Internal Area) Accommodation Floors NIA Sq Ft NIA Sq M Workshop / Office G ,314 5,046 Space Retail Space G 5, Total Commercial 60,079 5,581 Additional Ancillary Storage 5, The Proposed Modifications require that Blocks D, E, F and G to be100% office/workshop uses (KIBA compliant uses). In order to comply with the KIBA requirements, we have run appraisals based on the Revised Scheme areas, but applying commercial inputs across the KIBA within the Middle Site and Rear Site. Our interpretation of a KIBA compliant scheme is detailed below: 5.2 New KIBA Compliant Scheme (Interpreted by JLL) We have interpreted these areas and adjusted the uses for the Front, Middle and Rear Sites to accord with the Proposed Modifications which would provide a KIBA use across the Middle and Rear Sites. We have retained the Revised Scheme s massing and areas the cut-back version of the Appeal Scheme. Residential (Blocks A + B) Element Block A (Sq Ft NSA) Block B (Sq Ft NSA) Total Areas (Sq Ft NSA) Total Areas (Sq M NSA) Private 44,383 16,870 61,253 5,690 Affordable* 11,096 4,217 15,313 1,423 Total Resi NSA 55,479 21,087 76,566 7,113

94 *For the purpose of this exercise, JLL have assumed a best case scenario of 20% on-site affordable housing provision. NB planning policy is 50%, but comparable schemes within the VNEB region are achieving closer to 30%. KIBA Area KIBA (Middle + Rear Site) Sq Ft NIA Net Saleable (Sq Ft)* KIBA offices/workshops area 54,314 48,883 (assumes 90% let) KIBA retail area 5,765 5,765 KIBA new area (formerly resi) 138, ,914 (assumes 90% let) Total KIBA 198, ,561 *The proposed KIBA space is targeted towards small and start-up businesses, requiring flexible space. We have had discussions with our commercial agency teams and have concluded that applying an occupancy rate of 90% would be a best case for this type of use. 5.3 Residential End Sales Block A = 1,700 per sq ft (blended) Block B = 1,100 per sq ft (blended) We have had close regard to comparable developments along Albert Embankment and in the surrounding area shown in the map below and table overleaf

95 Map Ref Scheme Name Developer Blended PSF* (recent sales/re-sales) 1 The Corniche St James 1,850 2 Merano St James 1,350 (Sales from Sept 2013) 3 Riverwalk House Heron 2,250 4 Parliament View Ho Bee N/A 5 One Nine Elms Wanda Group 1,600 6 Embassy Gardens Ballymore 1,250 7 Riverlight St James 1,300 8 Battersea Power Station P2 BPS Development 2,300 Company 9 Battersea Power Station P3 BPS Development 1,700 Company 10 Nine Elms Point Barratt London & Sainsburys 1,100 In arriving at our end-sales prices, we have taken into account the unique attractions and views from the proposed development. KIBA Space (Office / Industrial) We have explored rental values within the area and have established the following tones: Office Space = per sq ft Industrial Space = per sq ft 5.4 Comparable schemes In arriving at our conclusions, we have had close regard to the following comparables: Southbank House, Black Prince Road, SE1 7SJ Southbank House is located adjacent to the proposed KIBA site and is currently being run as a serviced office. The entire building was fully refurbished in 2006 and benefits from the following facilities: - Parking (car and bicycle) - Full data and intercom systems - Showers - Manned reception plus CCTV - On site café The levels of occupancy are unknown, but we have established through online commercial portals that the building extends to 64,000 sq ft. The currently asking prices for office suites range from c per sq ft (including all utilities and services). However, all these units are below 1,000 sq ft in size and for such small units, we would typically anticipate a rental premium beyond that of the local office market tone. We have not been able to ascertain individual transactions with net pricing and would note that the above are gross asking prices and we would consider that rent free or discount incentives would be likely.

96 106A Tinworth Street, SE11 5EQ The unit comprises a newly refurbished railway archway located in close proximity to the subject site. The use is designated as Industrial (B1, B2 and B8). The unit comprises 2,000 sq ft and achieved a rent of 30,000 per annum, or 15 per sq ft in November Dolland St, SE11 5LN The unit comprises a refurbished office space close to Vauxhall. The unit comprises 14,670 sq ft and let for 249,997 per annum, or per sq ft in January Westminster Tower, 3 Albert Embankment, SE1 7SP Westminster Tower is an office block located in close proximity to the proposed site. The 2 nd floor (part 2,107 sq ft) was let to an Estate Agent (MyLondonHome) for per sq ft. The transaction occurred in Dec-12, but had been on the market since 2010 asking per sq ft. Whilst the transaction took place two years ago, it represents how up-take can be affected if the rent is pitched too high. The KIBA is close to 200,000 sq ft Net Internal Area which is a significant volume of workshop/office space for the local market to absorb, especially given the proposed SME occupiers which typically let smaller floor spaces. In the context of the rental tones and comparable evidence detailed above, we would assume that a rent of 15 per sq ft would be achievable, to operate the space at circa 90% occupancy. We have provided a sensitivity appraisal which demonstrates how the potential KIBA rent affects the land value. In terms of the investment yield, it has been difficult to establish serviced offices / workshop comparable evidence within the vicinity. Typically serviced office space requires higher levels of management / internal costs plus a high investment risk due to shorter term lease agreements and therefore uncertainty on the income. Therefore, a higher yield is required by investors in comparison with a single let office. We have excluded the office investments which offered a development angle. A large proportion of office space within Vauxhall / Nine Elms / Albert Embankment has been purchased by residential developers seeking to capitalise on permitted development rights or full conversion / re-development opportunities, subsequent this has created artificially low yields for office space in the area. We have assumed that the proposed KIBA space would not be granted consent for conversion and therefore would not attract the developer/short-term investor market. Focussing on the serviced space investment market alone, we have had close regard to the following transactions:

97 Salamanca Square, 9 Albert Embankment, SE1 7SP Long Leasehold 8,253 sq ft First floor office space with 4 x parking spaces (let until 2021, current rent passing is 20 per sq ft) 100% let 6.45% NIY in Jul-14 Blue Sky House, Kennington Road, SE11 4PT Freehold 17,977 sq ft Mixed Use Building (Office with ground floor retail) 100% let 8.38% NIY in Jun Southwark Bridge Road, SE1 9EU Freehold 97,000 sq ft office building 100% let 7% NIY in May-13 Hercules House, 6 Hercules Road, SE1 7DU Long Leasehold 15,230 sq ft Gym space let to Pure Gym for 20 years (RPI linked) 100% let 7.78% NIY in Aug-13 The majority of evidence available comprises single-let office investments which are deemed to be more secure investments / higher certainty on income compared with serviced office or workshop space, which tend to have shorter lease lengths, lower overall occupancy levels and higher associated management costs. Therefore, we consider that an All Risk Yield of 8% would be a reasonable assumption, combined with a 24 month letting period to achieve an occupancy rate of 90%. 5.5 Affordable Housing Provision We have applied a best-case scenario of 20% affordable housing provision. 5.6 Car Parking The revised scheme proposed for 60 x private parking spaces. However, the proposed KIBA scheme has a significantly reduced the residential space. JLL have reviewed the Core Strategy Policy S4 which requires developments to comply with maximum car parking standards in the London Plan, as below:

98 The Public Transport Accessibility Levels (PTAL) for the front site is excellent and good for the Middle and Rear Sites. We have considered that significantly less than 1 space per unit would be amenable to Lambeth. The proposed KIBA scheme would accommodate circa 71 apartments on the Front Site, therefore we have allocated 36 private car parking spaces within our appraisal ( 75,000 per space). 5.7 Community Infrastructure Levy For the purpose of this exercise, we have assumed a best-case scenario that the sites will pass the occupational test. This is subject to proving to the council that the buildings have been occupied for six out of the past 36 months. Should this prove not to be the case, this will have a negative impact upon the site s value. We are aware that Lambeth s CIL rate of 265 per sq m (Residential) and 125 per sq m (Office), plus Mayoral CIL at 35 per sq m.

99 5.8 Appraisal Inputs Input Assumptions Residual Land Value Targeted **Based on the Special Assumption that Planning consent is in place for the proposed KIBA scheme. ** Profit on Cost 20% Finance Costs 6.50% Site Acquisition Costs Stamp Duty 4.00% Agency Fee 1% Legal Fee 0.50% Revenue Residential (20% Affordable) Tenure Type Sales PSF Costs Private PSF (Blended across A + B) 1, % Marketing Costs 2.0% Agency Fee 0.25% Legal Fee Affordable PSF % Legal Fee Commercial Use Rent PSF All Risk Yield Incentive Costs Workshop/office 8% 24 month letting period to achieve 90% occupancy Retail 8.00% 24 month letting period to achieve 100% occupancy CIL/Statutory Construction Payments Base cost 94,000,000 / M2 / Ft2 Residential (Private) PSF 350 CIL commercial /M2 Nil Nil Residential (Affordable) PSF 250 CIL Resi /M2 Nil Nil Workshop / KIBA 150 Contingency 7.5% Professional Fees 10.00% Timescales Stage Months Phasing Purchase 1 Pre-construction 3 Site set-up / assembly of equipment. Construction 30 As per previous timescales. Sale 9 Resi 1 KIBA 5.8% Purchasers 10% Letting Fee 5% Letting Legal Fee 1% Disposal 0.25% Legal Fee 5.8% Purchasers 10% Letting Fee 5% Letting Legal Fee 1% Disposal 0.25% Legal Fee Residential sales: Cash flow assumes 50% pre-sold / reserved during construction with completions of these units occuring one month post construction, followed by a further 8 months of sales. KIBA / Commercial: Forecasted to sell on completion with the 24 months letting period PV'd into the price. A best case scenario.

100 5.9 Appraisal Conclusion Owing to the proportion of commercial space vs residential on the KIBA scheme, the appraisal produces a land value of; - 13,500,000 (Negative Thirteen Million Five Hundred Thousand Pounds) The negative land value is being driven from the KIBA use. The commercial inputs create a Gross Development Value of 31,892,540 / 29,132,411 after disposals costs (agency and legal fees) and purchaser s costs. This reflects a capital value of 146 per sq ft across the Net Internal Area. The build cost rate is higher than this capital value and therefore the project becomes unviable. We have provided a sensitivity analysis below to demonstrate if the KIBA rent was higher or lower than the 15 per sq ft which we have estimated: KIBA Rent ( PSF) Residual Land Price 10-20,680, ,500, ,315, ,000 Our rental sensitivity analysis above concludes that if the entire KIBA space was let for 25 per sq ft (which is above most of the nearby office rents), the land value remains severely impacted due to the KIBA use. In addition to the KIBA scenario, we have carried out an appraisal based on the Revised Scheme proposal, which has a higher proportion of residential space; KIBA Compliant Scheme Private Residential (NSA Sq Ft) Non-KIBA Compliant Scheme Private Residential (NSA Sq Ft) 61, ,469 We have applied the same base inputs, with a varying rate of residential sales values depending upon each respective block. This appraisal results in a land value of; 43,000,000 (Forty Three Million Pounds)

101 6 Appendix I: KIBA Appraisal Licensed Copy Development Appraisal 8 Albert Embankment Agency Appraisal KIBA scheme (Assuming Detailed PP in place) 20% Affordable (Best case scenario) CIL to be confirmed - Subject to vacancy test Report Date: 09 January 2015

102 TIMESCALE & ASSUMPTIONS 8 Albert Embankment LICENSED COPY Timescale (Duration in months) Project commences Jan 2015 Phase 1 Stage Name Duration Start Date End Date Anchored To Aligned Offset Phase Start Jan 2015 Purchase 1 Jan 2015 Jan 2015 Phase Start Start 0 Pre-Construction 3 Feb 2015 Apr 2015 Purchase End 0 Construction 30 May 2015 Oct 2017 Pre-Construction End 0 Sale 24 Nov 2017 Oct 2019 Income Flow End 0 Phase End Oct 2019 Phase Length 58 Project Length 58 (Includes Exit Period) Assumptions Expenditure Professional Fees are based on Construction Purchaser's Costs are based on Gross Capitalisation Purchaser's Costs Deducted from Sale (Not added to Cost) Sales Fees are based on Net Capitalisation Sales Fees Added to Cost (Not deducted from Sale) Receipts Show tenant's true income stream Offset income against development costs Rent payment cycle Apply rent payment cycle to all tenants Renewal Void and Rent Free apply to first renewal only On Off Quarterly (Adv) On Off Initial Yield Valuation Method Off Default Capitalisation Yield % Apply Default Capitalisation to All Tenants Off Default stage for Sale Date Off Align end of income stream to Sale Date Off Apply align end of income stream to all tenants On When the Capital Value is modified in the cash flow Recalculate the Yield Valuation Tables are Annually in Arrears Rent Free method Defer start of Tenant's Rent Finance Financing Method Interest Compounding Period Interest Charging Period Nominal rates of interest used Calculate interest on Payments/Receipts in final period Include interest and Finance Fees in IRR Calculations Automatic Inter-account transfers Manual Finance Rate for Profit Erosion Calculation Site Payments Other Payments Negative Land Receipts Basic (Interest Sets) Quarterly Monthly Off Off Off Off In Arrears In Arrears In Arrears In Advance Initial IRR Guess Rate 8.00% Minimum IRR -100% Maximum IRR 99999% Manual Discount Rate Off IRR Tolerance Letting and Rent Review Fees are calculated on Development Yield and Rent Cover are calculated on Include Tenants with no Capital Value Net of Deductions Rent at Sale Date(s) On File: T:\30 Warwick Street\Residential Agency\A - Z Property Directory\Albert Embankment, 8\ Appraisal.wcf ARGUS Developer Version: Date: 09/01/2015

103 TIMESCALE & ASSUMPTIONS 8 Albert Embankment LICENSED COPY Assumptions Include Turnover Rent Net of Non-Recoverable costs Net of Ground Rent deductions Net of Rent Additions/Costs Off On On On Value Added Tax Global VAT Rate 0.00% Global Recovery Rate 0.00% Recovery Cycle every 2 months 1st Recovery Month 2 (Feb 2015) VAT Calculations in Cash Flow On GST Margin Calculations in Cash Flow Off Residual Land Cost Mode Multi-Phasing Target Type Residualised Land Value Separate Land Residual for each phase Profit on Cost Phase Number Target Value Locked Treat Neg Land Value as Revenue Phase % No No Distribution Construction Payments are paid on Sales Receipts are paid on Sales Deposits are paid on S-Curve Single curve Monthly curve Interest Sets Interest Set 1 Inflation and Growth Growth Sets Debit Rate Credit Rate Months Start Date 6.500% 0.000% Perpetuity Jan 2015 Growth Set 1 Inflation/Growth for this set is calculated in arrears This set is not stepped Inflation Sets Rate Months Start Date 0.000% Perpetuity Jan 2015 Inflation Set 1 Inflation/Growth for this set is calculated in arrears This set is not stepped Rate Months Start Date 0.000% Perpetuity Jan 2015 File: T:\30 Warwick Street\Residential Agency\A - Z Property Directory\Albert Embankment, 8\ Appraisal.wcf ARGUS Developer Version: Date: 09/01/2015

104 APPRAISAL SUMMARY 8 Albert Embankment LICENSED COPY Summary Appraisal for Phase 1 REVENUE Sales Valuation Units Unit Amount Gross Sales Car Parking 36 units at 75,000 2,700,000 ft² Rate ft² Gross Sales Block A + B - Private Resi 61,253 1, ,962,102 Block A + B - Affordable Resi 15, ,215,730 Totals 76,566 97,177,832 99,877,832 Rental Area Summary Units Unit Amount Gross MRV Ground Rents - Private Resi 57 units at ,500 ft² Rate ft² Gross MRV KIBA Site (Assumes 90% Occupancy 179, ,693,415 Investment Valuation KIBA Site (Assumes 90% Occupancy Market Rent 2,693, % PV 0yrs % ,374,358 Ground Rents - Private Resi Current Rent 28, % ,182 31,892,540 GROSS DEVELOPMENT VALUE 131,770,372 Purchaser's Costs 5.80% (1,849,767) NET DEVELOPMENT VALUE 129,920,604 Income from Tenants 54,625 NET REALISATION 129,975,229 OUTLAY ACQUISITION COSTS Residualised Price (13,455,151) (13,455,151) CONSTRUCTION COSTS Construction Units Unit Amount Cost Total Construction 1 unit at 94,000,000 94,000,000 94,000,000 Contingency 7.50% 7,050,000 PROFESSIONAL FEES Total Fees 10.00% 9,400,000 MARKETING & LETTING Marketing 2.00% 1,879,242 Letting Agent Fee 10.00% 2,850 Letting Legal Fee 5.00% 1,425 7,050,000 9,400,000 1,883,517 DISPOSAL FEES Resi Sales Agent Fee 2.00% 1,879,242 Commercial Sales Agent Fee 1.00% 313,744 Resi Sales Legal Fee 0.25% 242,945 Commercial Sales Legal Fee 0.25% 78,436 2,514,366 FINANCE Debit Rate 6.500% Credit Rate 0.000% (Nominal) Total Finance Cost 6,919,962 TOTAL COSTS 108,312,694 PROFIT 21,662,535 File: T:\30 Warwick Street\Residential Agency\A - Z Property Directory\Albert Embankment, 8\ Appraisal.wcf ARGUS Developer Version: Date: 09/01/2015

105 APPRAISAL SUMMARY 8 Albert Embankment Performance Measures Profit on Cost% 20.00% Profit on GDV% 16.44% Profit on NDV% 16.67% Development Yield% (on Rent) 2.51% Equivalent Yield% (Nominal) 7.96% Equivalent Yield% (True) 8.37% Gross Initial Yield% 8.53% Net Initial Yield% 8.53% LICENSED COPY Rent Cover Profit Erosion (finance rate 6.500%) 25.51% 7 yrs 12 mths 2 yrs 10 mths File: T:\30 Warwick Street\Residential Agency\A - Z Property Directory\Albert Embankment, 8\ Appraisal.wcf ARGUS Developer Version: Date: 09/01/2015

106 SENSITIVITY ANALYSIS 8 Albert Embankment Table of Residual Land Price Sensitivity Analysis for Phase 1 LICENSED COPY Sales Total Value Constr. Tot Cost % % 0.000% % % 84,565,892 89,263,997 93,962,102 98,660, ,358, % ( 9,482,745) ( 6,242,575) ( 3,024,475) 145,996 3,077,037 84,600,000-6,561,702-7,036,955-7,534,267-8,071,201-8,694, % ( 14,735,832) ( 11,467,665) ( 8,217,104) ( 4,986,709) ( 1,783,058) 89,300,000-6,292,302-6,739,541-7,204,395-7,689,431-8,201, % ( 20,020,195) ( 16,730,177) ( 13,455,151) ( 10,196,930) ( 6,957,224) 94,000,000-6,054,164-6,479,561-6,919,962-7,377,127-7,852, % ( 25,328,603) ( 22,020,338) ( 18,724,512) ( 15,443,898) ( 12,179,727) 98,700,000-5,840,077-6,247,219-6,666,822-7,101,623-7,552, % ( 30,656,532) ( 27,333,499) ( 24,020,487) ( 20,722,270) ( 17,438,242) 103,400,000-5,645,515-6,037,893-6,440,273-6,857,498-7,288,883 Sensitivity Analysis : Assumptions for Calculation Sales Total Value Heading Phase Original Value Block A + B - Private Resi 1 93,962,102 These fields varied in Steps of % of the original value Construction Total Cost Heading Phase Original Value Total Construction 1 94,000,000 These fields varied in Steps of % of the original value File: T:\30 Warwick Street\Residential Agency\A - Z Property Directory\Albert Embankment, 8\ Appraisal.wcf ARGUS Developer Version: Date: 09/01/2015

107 7 Appendix II: Non KIBA Appraisal Licensed Copy Development Appraisal 8 Albert Embankment Agency Appraisal - Revised Scheme Not Subject to KIBA 20% Affordable (Special Assumption that detailed planning consent is in place) CIL Charge to be added - dependent upon vacancy test Report Date: 09 January 2015

108 TIMESCALE & ASSUMPTIONS 8 Albert Embankment LICENSED COPY Timescale (Duration in months) Project commences Jan 2015 Phase 1 Stage Name Duration Start Date End Date Anchored To Aligned Offset Phase Start Jan 2015 Purchase 1 Jan 2015 Jan 2015 Phase Start Start 0 Pre-Construction 3 Feb 2015 Apr 2015 Purchase End 0 Construction 30 May 2015 Oct 2017 Pre-Construction End 0 Sale 24 Nov 2017 Oct 2019 Income Flow End 0 Phase End Oct 2019 Phase Length 58 Project Length 58 (Includes Exit Period) Assumptions Expenditure Professional Fees are based on Construction Purchaser's Costs are based on Gross Capitalisation Purchaser's Costs Deducted from Sale (Not added to Cost) Sales Fees are based on Net Capitalisation Sales Fees Added to Cost (Not deducted from Sale) Receipts Show tenant's true income stream Offset income against development costs Rent payment cycle Apply rent payment cycle to all tenants Renewal Void and Rent Free apply to first renewal only On Off Quarterly (Adv) On Off Initial Yield Valuation Method Off Default Capitalisation Yield % Apply Default Capitalisation to All Tenants Off Default stage for Sale Date Off Align end of income stream to Sale Date Off Apply align end of income stream to all tenants On When the Capital Value is modified in the cash flow Recalculate the Yield Valuation Tables are Annually in Arrears Rent Free method Defer start of Tenant's Rent Finance Financing Method Interest Compounding Period Interest Charging Period Nominal rates of interest used Calculate interest on Payments/Receipts in final period Include interest and Finance Fees in IRR Calculations Automatic Inter-account transfers Manual Finance Rate for Profit Erosion Calculation Site Payments Other Payments Negative Land Receipts Basic (Interest Sets) Quarterly Monthly Off Off Off Off In Arrears In Arrears In Arrears In Advance Initial IRR Guess Rate 8.00% Minimum IRR -100% Maximum IRR 99999% Manual Discount Rate Off IRR Tolerance Letting and Rent Review Fees are calculated on Development Yield and Rent Cover are calculated on Include Tenants with no Capital Value Net of Deductions Rent at Sale Date(s) On File: T:\30 Warwick Street\Residential Agency\A - Z Property Directory\Albert Embankment, 8\ Appraisal - Proposed Resi Majority.wcf ARGUS Developer Version: Date: 09/01/2015

109 TIMESCALE & ASSUMPTIONS 8 Albert Embankment LICENSED COPY Assumptions Include Turnover Rent Net of Non-Recoverable costs Net of Ground Rent deductions Net of Rent Additions/Costs Off On On On Value Added Tax Global VAT Rate 0.00% Global Recovery Rate 0.00% Recovery Cycle every 2 months 1st Recovery Month 2 (Feb 2015) VAT Calculations in Cash Flow On GST Margin Calculations in Cash Flow Off Residual Land Cost Mode Multi-Phasing Target Type Residualised Land Value Separate Land Residual for each phase Profit on Cost Phase Number Target Value Locked Treat Neg Land Value as Revenue Phase % No No Distribution Construction Payments are paid on Sales Receipts are paid on Sales Deposits are paid on S-Curve Single curve Monthly curve Interest Sets Interest Set 1 Inflation and Growth Growth Sets Debit Rate Credit Rate Months Start Date 6.500% 0.000% Perpetuity Jan 2015 Growth Set 1 Inflation/Growth for this set is calculated in arrears This set is not stepped Inflation Sets Rate Months Start Date 0.000% Perpetuity Jan 2015 Inflation Set 1 Inflation/Growth for this set is calculated in arrears This set is not stepped Rate Months Start Date 0.000% Perpetuity Jan 2015 File: T:\30 Warwick Street\Residential Agency\A - Z Property Directory\Albert Embankment, 8\ Appraisal - Proposed Resi Majority.wcf ARGUS Developer Version: Date: 09/01/2015

110 APPRAISAL SUMMARY 8 Albert Embankment LICENSED COPY Summary Appraisal for Phase 1 REVENUE Sales Valuation Units Unit Amount Gross Sales Car Parking 66 units at 75,000 4,950,000 ft² Rate ft² Gross Sales E - G Affordable 43, ,045,120 A - Resi 55,479 1, ,314,300 B - Resi 21,087 1, ,195,700 D - Resi 84, ,998,475 E (S) - Resi 11, ,167,500 Totals 215, ,721, ,671,095 Rental Area Summary Units Unit Amount Gross MRV Ground Rents - Private Resi 1 unit at 106, ,000 ft² Rate ft² Gross MRV Workshops 48, ,660 Retail 5, ,475 Totals 54,648 1,064,135 Investment Valuation Workshops Market Rent 977, % PV 0yrs % ,388,314 Ground Rents - Private Resi Current Rent 106, % ,927,273 Retail Market Rent 86, % (0yrs 6mths Rent Free) PV 0yrs % ,040,133 14,355,719 GROSS DEVELOPMENT VALUE 238,026,814 Purchaser's Costs 5.80% (720,850) NET DEVELOPMENT VALUE 237,305,964 Income from Tenants 203,167 NET REALISATION 237,509,131 OUTLAY ACQUISITION COSTS Residualised Price 43,056,396 Stamp Duty 4.00% 1,722,256 Agent Fee 1.00% 430,564 Legal Fee 0.50% 215,282 45,424,498 CONSTRUCTION COSTS Construction Units Unit Amount Cost Total Construction 1 unit at 105,000, ,000, ,000,000 Contingency 7.50% 7,875,000 PROFESSIONAL FEES Total Fees 10.00% 10,500,000 MARKETING & LETTING Marketing 2.00% 4,193,520 Letting Agent Fee 10.00% 8,648 Letting Legal Fee 5.00% 4,324 DISPOSAL FEES Resi Sales Agent Fee 2.00% 4,292,519 Commercial Sales Agent Fee 1.00% 124,284 Resi Sales Legal Fee 0.25% 559,178 7,875,000 10,500,000 4,206,491 File: T:\30 Warwick Street\Residential Agency\A - Z Property Directory\Albert Embankment, 8\ Appraisal - Proposed Resi Majority.wcf ARGUS Developer Version: Date: 09/01/2015

111 APPRAISAL SUMMARY 8 Albert Embankment Commercial Sales Legal Fee 0.25% 31,071 5,007,053 FINANCE Debit Rate 6.500% Credit Rate 0.000% (Nominal) Total Finance Cost 19,911,209 TOTAL COSTS 197,924,251 LICENSED COPY PROFIT 39,584,880 Performance Measures Profit on Cost% 20.00% Profit on GDV% 16.63% Profit on NDV% 16.68% Development Yield% (on Rent) 0.59% Equivalent Yield% (Nominal) 7.68% Equivalent Yield% (True) 8.07% Gross Initial Yield% 8.15% Net Initial Yield% 8.15% Rent Cover Profit Erosion (finance rate 6.500%) 16.58% 33 yrs 10 mths 2 yrs 10 mths File: T:\30 Warwick Street\Residential Agency\A - Z Property Directory\Albert Embankment, 8\ Appraisal - Proposed Resi Majority.wcf ARGUS Developer Version: Date: 09/01/2015

112 SENSITIVITY ANALYSIS 8 Albert Embankment Table of Residual Land Price Sensitivity Analysis for Phase 1 LICENSED COPY Sales Total Value Constr. Tot Cost % % 0.000% % % % 40,254,575 46,931,894 53,609,287 60,286,631 66,963,971-18,221,390-19,668,400-21,115,429-22,562,445-24,009, % 34,978,152 41,655,486 48,332,806 55,010,197 61,687,541-17,619,285-19,066,300-20,513,310-21,960,339-23,407, % 29,701,718 36,379,061 43,056,396 49,733,718 56,411,107-17,017,179-18,464,195-19,911,209-21,358,220-22,805, % 24,425,254 31,102,628 37,779,970 44,457,306 51,134,630-16,415,064-17,862,088-19,309,105-20,756,119-22,203, % 19,148,840 25,826,160 32,503,537 39,180,880 45,858,216-15,812,962-17,259,973-18,706,998-20,154,014-21,601,029 Sensitivity Analysis : Assumptions for Calculation Sales Total Value Heading Phase Original Value Car Parking 1 4,950,000 A - Resi 1 94,314,300 B - Resi 1 23,195,700 D - Resi 1 81,998,475 E (S) - Resi 1 10,167,500 These fields varied in Steps of % of the original value Construction Total Cost Heading Phase Original Value Total Construction 1 105,000,000 These fields varied in Steps of % of the original value File: T:\30 Warwick Street\Residential Agency\A - Z Property Directory\Albert Embankment, 8\ Appraisal - Proposed Resi Majority.wcf ARGUS Developer Version: Date: 09/01/2015

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114 8 JLL 30 Warwick Street London W1B 5NH COPYRIGHT JLL IP, INC This publication is the sole property of JLL IP, Inc. and must not be copied, reproduced or transmitted in any form or by any means, either in whole or in part, without the prior written consent of JLL IP, Inc. The information contained in this publication has been obtained from sources generally regarded to be reliable. However, no representation is made, or warranty given, in respect of the accuracy of this information. We would like to be informed of any inaccuracies so that we may correct them. JLL does not accept any liability in negligence or otherwise for any loss or damage suffered by any party resulting from reliance on this publication.

115 APPENDIX 5 Economic Case & Employment Assessment

116

117 8 Albert Embankment and Adjoining Sites Economic Case and Employment Assessment January 2015 Prepared by Dr Gary Cox MPIA

118 8 Albert Embankment Economic and Employment Assessment January 2015 CONTENTS MAIN REPORT... 3 Executive Summary The Economic Case for Mixed Use Development Purpose of this report KIBA designation for 8 Albert Embankment KIBA outcomes for 8 Albert Embankment The Lambeth economy is experience long run restructuring Southbank House and Newport Street KIBA as a special case TECHNICAL ANNEX KIBA locations Lambeth s economic base Mixed use case studies

119 8 Albert Embankment Economic and Employment Assessment January 2015 Main Report Executive Summary The Economic Case for Mixed Use Development The front of the site includes the Grade II listed former London Fire Brigade Headquarters and served that purpose since its construction in 1937 until 2008 (when the London Fire Brigade relocated the majority of its functions from the Site to modern offices in Southwark). The middle site of 8 Albert Embankment is occupied by vacant offices and a workshop. They currently do not provide any employment. The rear site comprises an area of vacant hard standing. These sites are part of the Southbank House and Newport Street Key Industrial Business Area (KIBA) designation as set out by Lambeth Unitary Development Plan ( UDP ) 2007, Lambeth Core Strategy 2011, and also the emerging Local Plan. This report supports the case for mixed use redevelopment of this KIBA site, in particular a combination of housing and commercial accommodation. This type of redevelopment would optimise employment generation across the site and provide wider regeneration and community benefits. The key findings of this report are: 1. The planning outcomes from the KIBA designation have not been delivered 1.1. According to Lambeth Council s own biennial survey of KIBAs, Southbank House and Newport Street KIBA overall had a percentage vacancy rate of 36 per cent of available premises in 2012, up from 16 per cent in Only three KIBAs had vacancy rates over 20 per cent in This demonstrates lack of effective demand for this type of accommodation. It also reflects the poor location for workspaces, which require superior access by vehicle and public transport Most of the subject site has been vacant since Southbank House (not part of the subject site) provides basic quality fully serviced office space B1(a) in a building dating from the 1800s. Southbank House is currently underutilised and has a high business turnover. Recent vacancy rates have been around 80 to 85 per cent and Workspace, the operators of Southbank House, indicate that there are significant limitations on occupancy levels and rents. Workspace, who are highly experienced operators in this sector, consider this a poor location for this type of accommodation largely due to the distance from public transport. Any adjacent expansion of this type of accommodation only is unlikely to be successful in attracting additional businesses to this KIBA Previous research conducted in 2010 has indicated that less than 10 per cent of workers in this KIBA area are local, compared to up to 72 per cent 3

120 8 Albert Embankment Economic and Employment Assessment January 2015 for some other KIBA sites the designation of this particular location is not protecting local employment The borough has a relatively high unemployment rate (7.6 per cent). However, a very low proportion of jobseekers, only one per cent, are seeking process, plant and machine operative occupations that are traditionally associated with the manufacturing or industrial sectors. In addition, in terms of those currently in employment, less than one per cent are classified as being process, plant or machine operatives. These figures underline the declining industrial and manufacturing base in the borough. It is significant that in the Workspace managed properties in Southbank House there are no manufacturing users. All tenants comprise offices for small to medium sized businesses The KIBA designation for this site does not assist in delivering the council s B2 and B8 priority employment sectors. Furthermore in terms of the over- arching borough employment policies, this designation does not deliver on employment generation to tackle worklessness. An approach that supports project viability and leads to a mix of employment uses suited to the location will yield higher employment than a theoretical approach that is likely to sterilise the site. B1(a) uses are likely to be part of this mix Both the geographic location of this KIBA and its historical designation are clear anomalies. Fundamentally, this particular site is not achieving any of the planning outcomes which is to support local economic development, Lambeth s contribution to the central and wider London economy and a range of local business and job opportunities, by giving priority to a diverse range of economically beneficial uses in appropriate locations (Policy S3 - Lambeth Core Strategy 2011) One of the key justifications for KIBA designations is that they represent the borough s stock of locally significant industrial sites as presented in London Plan 2011 (Policy 4.4). The focus of the London Plan policy is on the local provision of a range of specifically industrial uses, including waste management, transport facilities, logistics, workspaces for SMEs The London Plan Policy 4.4 implicitly excludes B1(a) offices. Furthermore London Plan Policy 4.4 exhorts an approach that locally significant industrial sites must be designated on the basis of robust evidence demonstrating their particular importance for local industrial type functions. The support for specificity is provided in the London Office Policy Review 2012, which states that such a policy could be more explicit about the kinds of activities, rather than simply the type of land use, that it is seeking to protect or release. Both the current Core Strategy KIBA policy and the proposed preferred uses policy for Site 10 do not do this. Both policies are highly generic and non- specific and ultimately lack any reference to the uniqueness of the Site s location. 4

121 8 Albert Embankment Economic and Employment Assessment January The Lambeth economy is experiencing long run restructuring 2.1. Industrial and manufacturing employment in the London Borough of Lambeth has decreased since falling from 3.4 per cent of total borough employment in 2001 to 2.0 per cent in 2008 and now stands at 0.9 per cent. This has been despite of the KIBA designations The evidence suggests that this decline is structural that is, not reflective of the business cycle. Most of the private sector employment in the borough is now within the retail, business services and the hospitality/leisure sector. The council s own Local Economic Assessment (Lambeth First 2011) confirms this view Recent employment forecasts for Lambeth Borough to 2026 project that manufacturing employment will reduce by between a third and two thirds under any scenario. Manufacturing is forecast to decline by 500 jobs in the base scenario and by an identical number in the high growth scenario. For the low growth scenario, the decline in manufacturing is far more pronounced at a reduction of 800 jobs. This analysis would appear to confirm the structural decline in the manufacturing sector in Lambeth Standard B1(a) office uses may not be the most appropriate use in this location. The vacancy analysis indicates firstly the large quantum of vacant business B1(a) floorspace applicable in This is reflected also in KIBAs. This alone would question the policy of specific safeguarding of KIBA uses for office employment over the other B class uses envisaged as the target of the locally significant industrial site policy in the London Plan As a central London borough Lambeth is in a prime position to capture future growth. However, employment has grown faster in other areas of the South Bank with more mixed uses, instead of employment designations Devising planning policies to address a sector in structural decline is not likely to be successful in generating economic growth where other employment uses would clearly be more appropriate or viable. 3. Southbank House and Newport Street is a special case amongst the borough s KIBAs 3.1. The subject site is located within the London Plan s Central Activities Zone and is within the Vauxhall Nine Elms Opportunity Area, which presents a major opportunity to achieve the higher order objectives of the council s policies relating to sustainable growth and job creation The key land use strategy in the Vauxhall Nine Elms Opportunity Area Planning Framework for Albert Embankment is for high density mixed use housing- led intensification. This is characterised as housing led 5

122 8 Albert Embankment Economic and Employment Assessment January 2015 development with a mix of commercial and community uses to support existing and emerging communities Recent schemes in the environs of the subject site have been mixed use developments containing residential, retail, hotel and office components. Though many of these planning applications have necessitated appeals, they are broadly consistent with the strategic direction of development envisaged in the OAPF The 2013 Atkins assessment of the Southbank House and Newport Street KIBA highlighted the poor vehicle access to the KIBA site. This would make it unsuitable for some of the designated KIBA uses, particularly for waste management, industrial or warehousing The subject site is close to residential properties which makes it unsuitable, for reasons of amenity, for B2, B8, waste and other bad neighbour uses. In terms of potential future uses on 8 Albert Embankment and Adjoining Sites, the provision of lower value B1 uses on the Southbank House and Newport Street KIBA would significantly under develop the site. This issue is further examined in the 8 Albert Embankment: Central South Housing Market, Planning and Viability Comment (Jones Lang LaSalle 2015) The most recent appeal (APP/N5660/A/12/ ) ( Appeal Scheme ) relating to the subject site provides useful guidance on what may be acceptable for an alternative development on the site, particularly relating to employment uses and scheme viability. It also highlights the linkage between the viability of employment uses and delivering regeneration objectives For the purposes of this assessment report, an analysis of employment generation was carried out on two schemes: (i) the Appeal Scheme and (ii) an illustrative KIBA Compliant Scheme. Overall the Appeal Scheme would yield 1,308 additional jobs (or 884 direct jobs). The KIBA compliant scheme only yields 362 jobs. A scheme with the mixed use configuration as applied in the Appeal Scheme would yield an employment outcome between double and three times that of a KIBA compliant scheme A mixed use scheme on the lines envisaged in the OAPF would have significant additional regeneration benefits. Retaining the KIBA in this location constrains future development in that it cannot reflect the mixed use character of the wider locality The current KIBA designation on Southbank House and Newport Street is a major obstacle, not only to the redevelopment of the site, but also to the wider regeneration of the local area and the borough. 6

123 8 Albert Embankment Economic and Employment Assessment January Purpose of this report 1.1 This report has been prepared as a technical assessment to support the representation in relation to 8 Albert Embankment and Adjoining Sites ( the Site ) regarding the proposed modifications to the emerging Lambeth Local Plan. 1.2 The Proposed Submission Draft Local Plan dated November 2013 includes a site allocation policy that relates to Site 10. The site comprises: 8 Albert Embankment - ( Front Site ) Land bounded by Whitgift Street, Lambeth High Street, the railway embankment and Southbank House - ( Middle Site ) Land on the corner of Black Prince Road and Newport Street - ( Rear Site ). 1.3 The Submission Draft Local Plan would maintain the Middle Site and Rear Site as a Key Industrial Business Area (KIBA). 1.4 The purpose of this technical report is to assess the employment and wider economic implications of the retention of this KIBA designation. The report is in two parts: (i) the overall employment and economic assessment of the Site, and (ii) a technical annex which includes an overview of the Lambeth economy. 2.0 KIBA designation for 8 Albert Embankment 2.1 The London Borough of Lambeth introduced KIBA designations into its local planning framework, then the Lambeth Unitary Development Plan ( UDP ) This planning policy followed a borough wide investigation into demand and supply of employment and employment lands, the Lambeth Employment Demand Study (GVA Grimley June 2001). The report recommended that a limited number of the best employment generating sites in the borough be given enhanced protection through designation as KIBAs. 2.2 These were historical designations intended in part to stem the loss of manufacturing employment in the borough by providing jobs for local residents. These designations were historical in that they identified existing sites in use for industrial purposes, rather than allocating new sites based on contemporary industry requirements or planning criteria. 2.3 The Lambeth UDP was adopted by the council in August Policy 22 related to safeguarding KIBAs and the text of this policy is shown in Figure 1. The planning rationale for the policy was stated as: To address the continuing and steady loss of employment sites and floorspace in the borough, which are under intense pressure for development for other uses. 7

124 8 Albert Embankment Economic and Employment Assessment January 2015 That if current trends continue, Lambeth would lose many of its employment sites, particularly in the manufacturing sector, with the result that parts of the borough would become purely residential. There are growth sectors in the economy that have particular floorspace requirements which are not being met, and lack of suitable local premises could mean that some local businesses would be forced to re- locate. Figure 1 Lambeth Unitary Development Plan 2007 Policy 22 Key Industrial and Business Areas (in part) Key Industrial and Business Areas (KIBAs) are safeguarded for B Class Uses (business, industrial, warehousing) and other uses falling outside a use class and commonly found in industrial areas (e.g. artists studios/rehearsal areas and galleries; haulage; employment training; bus garages and telecommunications). Development in these areas - which protects and improves land in employment use and increases employment levels, will be encouraged, as will measures to improve access to employment, - such as the creation of small business incubator units. Parts of KIBAs have MDOs (as shown on the Proposals Map); that are listed as Mixed Use Employment Areas and described under area headings in section B of the Plan. Here some residential and other non- employment uses are acceptable on appropriate parts of the site. The overall development, however, should be predominantly employment- based, incorporating the maximum feasible amount of employment development - either at least 50% of the site area or 50% of the replacement floorspace should be B1/B2/B8, including the work element of any work- live scheme, unless otherwise specified in the MDO. A lower proportion will be considered for schemes predominantly of affordable housing. The scheme should include improved access for the employment uses, separate, as far as possible, from the residential access. 2.4 Though the policy intent for KIBAs in the UDP emanates from industrial uses, office development B1(a) is also within the permissible uses. Furthermore, Policy 21 (Location and Loss of Offices) permits smaller scale office development in KIBAs where they are appropriate to the character and the function of the area. The Middle and Rear Sites are classified as Major Development Opportunity Site 4 on the UDP proposals map. As detailed in Figure 1, this permits some residential and other non- employment uses but with employment uses remaining predominant on the site. 2.5 The KIBA designation is included in Lambeth s Local Development Framework Core Strategy adopted in 2011 ( Core Strategy ). Policy S3 (see Figure 2) replaced the KIBA policy in the UDP but with reduced flexibility. The Core Strategy references the UDP for the policy justification for the designation of KIBAs. In the section of the Core Strategy outlining the approach to the overall spatial strategy, 11 key principles are enunciated. As regards KIBAs, a change of approach from the UDP is highlighted in that the Core Strategy will strengthen the existing policy approach to Key Industrial and Business Areas (KIBAs), removing the mixed use employment area designation in these locations (Core Strategy 2011, para. 3.9). The list of designated KIBAs is retained from the UDP. 8

125 8 Albert Embankment Economic and Employment Assessment January 2015 Figure 2 Lambeth Core Strategy 2011 Policy S3 Economic Development paras (a)- (c) The Council will support local economic development, Lambeth s contribution to the central and wider London economy and a range of local business and job opportunities, by giving priority to a diverse range of economically beneficial uses in appropriate locations. The Council will achieve this by: (a) Safeguarding Key Industrial and Business Areas (KIBAs) for business, industrial, storage and waste management uses, including green industries, and other compatible commercial uses, excluding large scale retail. (b) Maintaining a stock of other sites and premises (not in KIBAs) in commercial use across the borough subject to the suitability of the site and location. (c) Allowing exceptions to the protection of employment land both within and outside of KIBAs to provide sites for schools where these are required to meet local need and no alternative site is available. 2.6 The Core Strategy further policy justification for the KIBA designations is by reference to the London Plan It states that KIBAs represent the borough s strategic reservoirs of land for business use and are Lambeth s Locally Significant Industrial Sites as defined in the London Plan (UDP 2007, para.4.15). In the London Plan 2011, Policy 4.4 relates to managing industrial land and premises. Inter alia, Policy 4.4 states that boroughs in preparing their LDFs should demonstrate how the borough stock of industrial land and premises will be planned and managed in local circumstances in line with this strategic policy (Policy 4.4 B). The types of use envisaged in this policy range form waste management, transport facilities, logistics, wholesale markets, as well as workspaces for SMEs and for new emerging industrial sectors (such as renewable energy generation). 2.7 Further detail on London Plan industrial classifications is provided in the Land for Industry and Transport Supplementary Planning Guidance (Mayor of London 2012). In this SPG, the expressions industry and related uses and industrial land are broken down into nine categories (para 2.1). These are: (i) Light industry (ii) General industry (iii) Logistics, warehousing and storage (iv) Waste management and recycling (v) Utilities including energy and water management (vi) Land for public transport functions (vii) Wholesale markets (viii) Some creative industries (ix) Other industrial related uses not in categories (i) to (viii) above. 2.8 Broadly, these uses would be defined in the General Use Classes Order as B1(b) and (c), B2 and B8, though some specific uses might be sui generis. Further, the SPG highlights Locally Significant Industrial Sites as sites warranting protection because of their particular importance for local industrial type functions (para.4.9). Designation by boroughs must be justified by robust demand assessments following criteria set out in paragraphs 4.14 to 4.16 of the SPG. The criteria relate to economic, land 9

126 8 Albert Embankment Economic and Employment Assessment January 2015 use and demand factors. Among the criteria are whether the site supports local or strategically important clusters of employment or industrial activity (para.4.14(iii)) and offers potential for the provision of industrial units for creative, knowledge- based, high technology and Small and Medium Sized Enterprises (SMEs) serving local residential and commercial areas (para.4.14(viii)). There are no criteria that imply any provision for B1(a) offices uses, whether primary or ancillary to a main use. 2.9 The discussion in the London Plan relating to Policy 4.4 (para.4.18) refers to the increasing need for less high value activities to support an increasingly service- based economy. It characterises these uses as services for the services sector, for instance sufficient space to accommodate demand for workspace suitable for SMEs and for new and emerging industries. As strong case is presented in the London Office Policy Review 2012 (Ramidus and RTP 2012) for such locations to favour what it calls hybrid office/industrial activity (p.148). It points to the focus of office policy being grade- A and institutional properties. A more hybrid range of uses is warranted in these locations. The policy direction is that: Industrial spatial policy could therefore be more explicit about the kinds of activities, rather than simply the type of land use, that it is seeking to protect or release (para , p.149). The currently proposed generic policy for Site 10 as well as the overall KIBA policy appears to be the antithesis of this approach Office accommodation is not envisaged under Policy 4.4. The policies in the London Plan that relate to office development are Policy 4.2 (Offices) and Policy 4.3 (Mixed Use Development and Offices). The narrative relating to Policy 4.4 does anticipate redevelopment of surplus industrial land (including that within the borough locally significant industrial sites). Such redevelopment should address strategic and local objectives particularly for housing, and for social infrastructure such as education, emergency services and community activities (The London Plan 2011, para 4.23) Thus, the Core Strategy KIBA policy retains the broad uses from the original policy in the UDP encompassing business, industrial, storage and waste management uses. This is despite the linkage with the London Plan s classification of locally significant industrial sites, which would appear to exclude development that is predominantly offices. The mixed use designation from MDO sites is entirely removed On 28 March 2014, the Council submitted the Lambeth Local Plan Proposed Submission (November 2013) for examination by an independent planning inspector. In part, the plan s spatial vision states (2013, p.32): By 2030 Lambeth will be a key part of, and contributor to, central London s thriving economy and the benefits of this will be shared throughout the borough. It will be home to centres of innovation, a 10

127 8 Albert Embankment Economic and Employment Assessment January 2015 skilled workforce and a growing number of businesses and jobs providing opportunities for local people The plan has two strategic objectives relating to economic prosperity. These are shown in Figure 3. The objectives relate to both supporting key growth sectors and protection of land for commercial use within neighbourhoods. Both are very broad. The guiding spatial policy approach simply states that the new plan will maintain the existing policy approach to Key Industrial and Business Areas (KIBAs), but with some revisions to boundaries (para. 3.8, p.31). The main policy, as shown in Figure 4, is a restatement of that in the Core Strategy The categories of uses permitted, being business, industrial and storage, are explicitly defined to include all uses in the B use class (B1, B2 and B8). Figure 3 Strategic Objectives in Lambeth Emerging Core Strategy 2013 Strategic Objectives - Lambeth Local Plan Proposed Submission November 2013 B Achieving economic prosperity and opportunity for all 2 Support the growth of key economic sectors and innovation through the development of new shops, offices and visitor accommodation, by maintaining a varied supply of business premises and through plans for town centre regeneration. 3 Increase the number and variety of job opportunities for local people by protecting land for commercial use within neighbourhoods and seeking contributions to employment and skills support programmes. Figure 4 KIBA Policy in Lambeth Emerging Core Strategy 2013 Policy ED1 Key Industrial and Business Areas (KIBAs) Development in KIBAs will be permitted only for business, industrial, storage and waste management uses, including green industries and other compatible industrial and commercial uses (excluding large scale retail) ancillary to, or providing for, the needs of the KIBA There are a number of other observations relating to the KIBA policy. Other compatible industrial and commercial uses ancillary to the KIBA are defined as non- B class uses usually associated with industrial areas such as builders yards, haulage, employment- training, bus garages and telecommunications (para. 6.8). For the Southbank House and Newport Street KIBA, it is stated that the KIBA policy takes priority over other policies in the plan (para.6.10) In the section of the emerging Lambeth Local Plan relating to Vauxhall, 8 Albert Embankment and the land to the rear is designated as Site 10. In the original submission for examination this contained a preferred use policy. Following the examination into the Submission Draft Local Plan, Lambeth Council published modifications ( Proposed Modifications in November 2014 to the Submission Draft Local Plan). This significantly amends the originally proposed preferred use policy relating to Site 10. The modified text is shown in Figure 5. The initial more flexible preferred use policy has been rendered inoperable and internally conflicted with 11

128 8 Albert Embankment Economic and Employment Assessment January 2015 the amended text the amount of employment floorspace should be maximised. This would appear to determine that only employment floorspace should occur on the Middle and Rear Sites. Figure 5 Emerging Lambeth Local Plan policy relating to Site 10 Proposed modification relating to Site 10 preferred use Retention/provision of an operational fire station. Mix of uses including residential and employment but respecting the KIBA designation of part of the site. Exceptionally, configuration of the site to include some residential within the KIBA boundary may be considered, if it can be demonstrated that this is necessary to achieve an acceptable scheme in all other respects. The amount of replacement employment floorspace should be maximised and should include space for small and medium enterprises. 3.0 KIBA outcomes for 8 Albert Embankment 3.1 The question arises as to whether the designation of UDP site MDO4 (as now proposed as Site 10 in the emerging Lambeth Local Plan) as a KIBA has been successful. That it has achieved the objective of retaining employment on the site and business, industrial, warehousing employment, particularly in the manufacturing sector. Three issues will be examined here: (i) effective demand for KIBA floorspace, (ii) the proportion of KIBA employment being held by local residents, and (iii) the match between local jobseekers and KIBA employment. Effective demand for KIBA floorspace 3.2 According to the Economic Development Topic Paper (London Borough of Lambeth November 2013), on the whole, the council s KIBAs are operating effectively and viably as employment locations, and in particular the future employment land supply demand balance shows that there is sound justification for the continued protection of KIBAs and smaller sites. This finding is based on the Lambeth Employment Land Review Update (Atkins 2013). However, when evaluating the KIBA objectives relating to the Southbank House and Newport Street KIBA, the opposite conclusion is drawn. Fundamentally, the subject site within the KIBA does not generate any jobs. 3.3 According to the Survey of Key Industrial Business Areas August 2012 (London Borough of Lambeth 2012), Southbank House and Newport Street KIBA overall had a percentage vacancy rate of 36 per cent of available properties in 2012, up from 16 per cent in Only three KIBAs had vacancy rates over 20 per cent in According to the same survey of KIBAs, there were 1,124 premises total of which 111 were then vacant, 95 of these were B Class premises. Sites with the highest level of specifically B class vacancy were Freemans (88 per cent), Waterworks Road (49 per cent), and Southbank House and Newport Street (33 per cent). 12

129 8 Albert Embankment Economic and Employment Assessment January The Lambeth Employment Land Review Update (Atkins 2013) provides much more detailed commentary on each KIBA than the survey report. It confirmed that most of the subject site has been vacant since 2008, causing some problems with trespassing. However, to the south of the subject site and fronting onto Black Prince Road is Southbank House. This provides basic quality fully serviced office space B1(a) in a building dating from the 1800s. This provides accommodation for a range of business sizes. Though Southbank House was stated to be well- occupied at the time of the Atkins review more recent investigations reveal that it experiences a high turnover rate. Recent vacancy rates have been around 80 to 85 per cent. Businesses typically stay from six months to two years. It is significant that in Southbank House there are no manufacturing users. All tenants comprise offices for small to medium sized businesses. Workspace, the operators of Southbank House, indicate that there are significant limitations on occupancy levels and rents. The accommodation is considered by many potential users to be too far from the Vauxhall tube station as well as having poor vehicle access. Consequently, any adjacent expansion of this type of accommodation only is unlikely to be successful in attracting additional businesses to this KIBA. 3.5 The Atkins report does not recommend a change to the KIBA designation for Southbank House and Newport Street. But this is contrary to the report s own evaluation findings as it concluded the following (p.66): Given the recent planning application and long period of vacancy, it is evident that redevelopment opportunity for these sites may only come forward through a mixed use development scheme, which would be contrary to the KIBA policy. 3.6 This KIBA does not perform well in terms of meeting the objectives of the Core Strategy Policy S3 in terms of either addressing the loss of employment or assisting the specific floorspace needs of the growth sectors of the economy. Profile of vacant B class floorspace 3.7 The Lambeth Employment Land Review Update (Atkins 2013) provides a survey of B class floorspace across the borough. This was extracted from the Estates Gazette Interactive (EGI) database and the Valuation Office Agency (VOA). VOA data was valid for 2010 and EGI data was current as at the end of This provides some indicative information on the profile of B class floorspace in the borough. 3.8 The VOA data identifies 84 per cent of the B Class employment floorspace is outside of KIBAs, as shown in Figure 6. The total amount of KIBA floorspace is estimated at 186,551 square metres. This is around 48 per cent less than estimates of total B class floorspace in the Survey of KIBAs (London Borough of Lambeth 2012), which estimates a total supply of 387,995 square metres. This is due to the fact that the VOA data only 13

130 8 Albert Embankment Economic and Employment Assessment January 2015 includes rateable floorspace whereas the KIBA survey includes all floorspace. On these figures, the KIBAs have just over 35 per cent of floorspace categorised as B1(a) uses. Figure 6 Stock of Floorspace by Use Class (Atkins 2013, p. 39) District B1(a) (sq.m) B1(c) (sq.m) B2 (sq.m) B8 (sq.m) Total Other Employment (non- KIBA) 757, ,290 19,058 80, ,727 KIBA 65,598 63,746 4,395 52, ,551 KIBA proportions 35.2% 34.2% 2.4% 28.3% 100.0% Total 822, ,036 23, ,003 1,144,278 Source: Valuation Office Agency The study analysed the EGI availability data to give an indication of the current availability of B class to new occupiers. Figure 7 identifies the amount of vacant floorspace in the borough including all vacant floorspace that is in the EGI database. It should be noted that there may be other floorspace currently available as the database may not be comprehensive. The EGI data identifies that Lambeth has over 213,440 sq.m of B class use employment floorspace that is being actively marketed. this is approximately 15 per cent of all floorspace in the borough. Around 95 per cent of this is office space B1(a), 3 per cent is mixed industrial (B1b/B1c/B2/B8) and 2 per cent is general industrial B2. The Atkins study revealed that, as at 2012, the South Bank, Waterloo and Vauxhall had the largest quantity of vacant B class floorspace at some 136,340 sq.m, which is 64 per cent of the total B class floorspace. The actively marketed floorspace was entirely office B1(a), covering 20 sites. Figure 7 Vacant Floorspace by Use Class (Atkins 2013, p. 43) Business B1(a) (sq.m) (%) Mixed Industrial (B1/B2/B8) (sq.m) (%) General Industrial (B2) (sq.m) (%) Row Total (sq.m) Non- KIBA 199, , , , KIBA 4, , ,712 4 KIBA proportions 54.3% % - 0.0% - 100% - Total 203, , , , Source: Estates Gazette Interactive The evidence base for the Core Strategy 2011 listed the London Office Policy Review May 2007 (GLA 2007) as the main source for trends in the demand and supply of London office space. The study included indicative figures for demand at borough level until The London Office Floorspace Projections 2014 (Peter Brett 2014) is the most recent in a series of independent reviews of office market trends commissioned by the GLA. This derives a 25 year office space demand forecast based on office employment projections. The projection for Lambeth is for 149,000 (%) 14

131 8 Albert Embankment Economic and Employment Assessment January 2015 additional office floorspace between , based on an employment density of 10.8 square metres per worker. This would equate to an average gross figure of 5,960 square metres additional floorspace per year The vacancy analysis would indicate firstly the large quantum of vacant business B1(a) floorspace applicable in This is reflected also in KIBAs. This alone would question the policy of specific safeguarding of KIBA uses for office employment over the other B class uses envisaged as the target of the locally significant industrial site policy in the London Plan The match between KIBA employment and current jobseekers 3.12 In a detailed analysis conducted for a report submitted in support of planning application (10/04473/FUL) - 8 Albert Embankment and Adjoining Sites Economic Case & Employment Assessment (Hunt Dobson Stringer 2010), it is detailed that only 9.8 per cent of jobs in this KIBA were held by Lambeth residents. This was by far the lowest proportion of any of Lambeth s KIBA sites. The other KIBA locations range from 15.7 per cent to 72.1 per cent of jobs in each area going to local residents, with the average being around 23 per cent. This data is indicative only as it relates to the 2001 Census A key priority for Lambeth is to tackle the problem of worklessness. Lambeth s Community Plan sets out how the Council will prioritise resources and commission services in order to become a cooperative council. The first goal of the plan is to secure more jobs and sustainable growth. In the foreword to the plan, the Leader of the Council states: Unlocking the benefit of our regeneration schemes across the borough is vital to increasing the opportunities we can create for Lambeth s residents. In Vauxhall Nine Elms we have the largest regeneration scheme in Europe; we need to make sure this development really benefits our residents The borough has a relatively high rate of unemployment at 7.6 per cent (ONS June 2014), but industrial land uses are unlikely to solve this problem. Thus, B1(c), B2 and B8 uses in this location would not primarily address the employment objectives of the KIBA designation. A very low proportion of jobseekers, only one per cent (ONS Survey 2010), are seeking process, plant and machine operative occupations that are traditionally associated with the manufacturing or industrial sectors. In addition, in terms of those currently in employment, less than one per cent (ONS Survey 2010) are classified as being process, plant or machine operatives. Retention of a KIBA designation in a location better suited to other employment uses would clearly limit the site s potential to generate jobs. The only major employment generating use is likely to be B1(a). This is more of a limitation on achieving the council s worklessness agenda 15

132 8 Albert Embankment Economic and Employment Assessment January 2015 given that a different mix of uses would present a better match between jobseekers and available jobs. Conclusions relating to KIBA outcomes 3.15 According to the Economic Development Topic Paper (London Borough of Lambeth November 2013), KIBAs have been a vital element of the council s planning strategy for many years. They are considered to form the borough s strategic reserve of employment land and business use as well as being Lambeth s locally significant industrial sites as defined in the London Plan Though the borough has more successful KIBAs in terms of the achievement of the stated policy objectives, the Southbank House and Newport Street KIBA cannot be judged to be in this category. The KIBA designation for this site has not assist in delivering the council s B2 and B8 priority employment sectors. The inclusion of B1(a) office uses within the designation in the UDP has not led to viable office uses emerging. Furthermore in terms of the over- arching borough employment policies, this designation does not deliver on employment generation to tackle worklessness. The KIBA designations are not primarily related to the provision of B1(a) office accommodation and the linkage with the London Plan Policy 4.4 shows that the underlying policy intent is for B1(b), B1(c), B2 and B The Lambeth economy is experience long run restructuring 4.1 Section 3 of the Technical Annex presents an overview of the Lambeth economy. This analysis is consistent with the picture presented in Lambeth First s Local Economic Assessment 2011 Report (Lambeth First 2011). This document forms part of the evidence base for the Lambeth Core Strategy. Local Economic Assessments are a key part of the evidence base used to make strategic and delivery decisions in a local authority. Some of the Lambeth First key findings about the structure of the local economy are shown in Figure 8. 16

133 8 Albert Embankment Economic and Employment Assessment January 2015 Figure 8 Lambeth First s Local Economic Assessment (2011) Key findings on the structure of the Lambeth economy The key sectors in terms of numbers of businesses for Lambeth are: the broad general business activities group that includes finance and IT; retail, hotels and restaurants. Compared to the central London boroughs, Lambeth has a higher proportion of public, education, health and social sectors and lower proportions of the broad general business activities group. This is reflected in the number of jobs in the borough but the proportion in the public, education and health sector is higher still, especially in the health and social care sub- sector. Lambeth s main business clusters are: business information, management services and support; architecture, engineering and technical services (predominantly engineering and technical services); and hospitality and events. There are other smaller clusters that offer future opportunities for expansion. Businesses in Lambeth employ over 126,000 workers; this is 7,300 more than in 2002 a rise of 6.1%. This rise is about the same as the London average but lags behind the central London borough jobs growth of 7.2%. In line with comparable locations, the borough s business structure has changed with lower proportions of jobs in manufacturing, construction and transport sectors and higher proportions in the broad public sector category and a slight rise in other services. The proportion of finance, IT and other business activities has fluctuated but not risen as in other boroughs, however due to overall jobs growth there are over 7,000 more jobs in that sector in Lambeth. 4.2 Overall, industrial and manufacturing employment in Lambeth has decreased since 2001 (Annual Business Inquiry, ONS 2001, 2008; Business Register and Employment Survey, ONS 2013), falling from 3.4 per cent of total borough employment in 2001 to 2.0 per cent in 2008 and now stands at 0.9 per cent. This has been in despite of the KIBA designations. The evidence reveals a steady and inexorable decline over the period This would suggest that this decline is structural that is, not reflective of the business cycle. Most of the private sector employment in the borough is now within the retail, business services and the hospitality/leisure sector (Business Register and Employment Survey, ONS 2013; Atkins 2013). 4.3 As the employment forecasting conducted for the Lambeth Employment Land Review Update (Atkins 2013) revealed, the borough s growth sectors are predominantly business services, communications, construction, hospitality and health. The sectors in decline are public administration (minus 1,200 jobs), utilities (minus 600 jobs) and education (minus 200 jobs). Manufacturing is forecast to decline by 500 jobs in the base scenario and by an identical number in the high growth scenario. For the low growth scenario, which overall sees an increase of a total of 2,900 jobs to 2026, the decline in manufacturing is far more pronounced at a reduction of 800 jobs. This would represent a 61.5 per cent reduction in the 2013 employment figure for manufacturing. This analysis would appear to confirm the structural decline in the manufacturing sector in Lambeth. 17

134 8 Albert Embankment Economic and Employment Assessment January The decline in manufacturing is most evident in the Lambeth Employment Land Review Update (2013) - in the low growth forecast, manufacturing is projected to reduce by between a third and two thirds under any scenario. The key growth sectors in the borough are in the knowledge economy (including creative and cultural industries and business and financial services), the hospitality, leisure, travel and tourism sector. Though some of these uses are KIBA compatible, some are clearly in other uses classes, such as A2, A3, C1 and D2. The KIBA compatible uses are evidently not matched to the growth sectors of the local Lambeth economy. 4.5 Modern manufacturing has become less employment intensive. In order to remain competitive, these industries have had to increase productivity and efficiency with higher added value, robotics and automation, resulting in fewer jobs. Modern manufacturing and industrial uses will therefore not provide the growth in employment to provide jobs locally in Lambeth. 4.6 The fundamental conclusion is that devising planning policies to address a sector in structural decline is not likely to be successful in generating economic growth where other employment uses would clearly be more appropriate or viable. B1(a) uses are permissible in the KIBA, though there are questions around the demand for offices in this specific location. The Jones Lang LaSalle Planning and Viability Comment (2015, 5.4) states: A large proportion of office space within Vauxhall/Nine Elms/Albert Embankment has been purchased by residential developers seeking to capitalise on permitted development rights or full conversion/re- development opportunities, subsequently this has created artificially low yields for office space in the area. 5.0 Southbank House and Newport Street KIBA as a special case 5.1 The preceding sections make the case that the Southbank House and Newport Street designation is an anomaly in terms of the council s KIBA policy. This KIBA stands out in terms of its low performance relating to vacancy rates, the long period of under- occupancy, and its extremely low proportion of local employment. This situation is reinforced in the context of the structural decline in manufacturing in the Lambeth local economy. 5.2 This final section presents the case of the opportunity that this site presents in terms of achieving the higher order objectives of the council s policies relating to sustainable growth and job creation. Location of the KIBA and surrounding uses 5.3 The subject site is situated in the London Plan s Central Activities Zone (CAZ) and in the Vauxhall Nine Elms Battersea Opportunity Area ( OA ). The CAZ covers London s geographic, economic and administrative core. It brings together the largest concentration of London s financial and 18

135 8 Albert Embankment Economic and Employment Assessment January 2015 globally oriented business services. Almost a third of all London jobs are based here. Together with Canary Wharf, the CAZ has historically experienced the highest rate of growth in London. 5.4 Opportunity areas are designated in the London Plan. They are the capital s major reservoirs of brownfield land with significant capacity to accommodate new housing, commercial and other development linked to existing or potential improvements to public transport accessibility. Over the next 10 to 15 years, the OA will deliver high density mixed use development comprising 16,000 new homes and between 20,000 and 25,000 new jobs. 5.5 The CAZ and OA present unique opportunities. As the Vauxhall Nine Elms Battersea Opportunity Area Planning Framework (2012) ( OAPF ) states (p.26): At 195 hectares the OA is the largest remaining development opportunity within the CAZ and is vitally important in terms of strengthening London s CAZ and World City status, providing development capacity for a range of high value uses including the financial and business sector, institutions, communications, retail, tourism, culture and entertainment. 5.6 The key land use strategy in OAPF for Albert Embankment is for high density mixed use housing- led intensification (4.2, p.32). This is characterised as housing led development with a mix of commercial and community uses to support existing and emerging communities. The OAPF does state that Lambeth s employment retention policies will continue to apply here (p.33). 5.7 As shown in Figure 9, recent schemes in the environs of the Site have been mixed use developments containing residential, retail, hotel and office components. Though many of these planning applications have necessitated appeals, they are broadly consistent with the strategic direction of development envisaged in the OAPF housing led mixed use intensification. 5.8 The Atkins (2013) assessment of the Southbank House and Newport Street KIBA highlighted the poor vehicle access to the KIBA site. The report observed that the road network covering the actual KIBA site comprises small local roads (Newport Street and Old Paradise Street), which are unsuitable for HGV access (p.64). This would suggest that some of the uses the current KIBA designation intends for this site are inappropriate given the access conditions. 5.9 The most notable mismatch of use and the attributes of the subject site relates to waste management. The Lambeth Local Plan Waste Evidence Base November 2013 states (p.3): Lambeth does not propose to allocate specific sites for future waste management use. Instead, Lambeth s Key Industrial Business Areas 19

136 8 Albert Embankment Economic and Employment Assessment January 2015 (KIBAs) are identified as the most appropriate areas for additional waste management facilities and these cover over 47 hectares. Lambeth Local Plan Proposed Submission policies support the location of waste management uses in all KIBAs as well as on- site waste management facilities for major developments This policy position is reiterated in the Economic Development Topic Paper 2 (London Borough of Lambeth 2013). This states that KIBAs represent the primary area of search for additional land for waste management use to meet the London Plan apportionment target. Given both the access constraints and the primarily residential nature of surrounding land uses, this be an inappropriate use for 8 Albert Embankment. Given the active community concerns around new developments in this locality, this would likely to engender community opposition if such a waste management proposal came forward. Figure 9 Recent schemes in Albert Embankment List of recent schemes and planning applications in the environs of Albert Embankment 1. No.81 Black Prince Road Erection of a 23 storey building (including basement) to contain 1,770m² (GEA) of commercial floorspace (flexible use B1 or A2) together with 101 flats on the upper floors. Completed. 2. Salamanca Tower, Salamanca Place 17 storey tower to provide 43 one and two bedroom residential units together with commercial uses on the ground, first and second floors. Completed. 3. Riverbank Park Plaza (No.10 Albert Embankment) Erection of a 15 storey (including basement) apart- hotel together with restaurant and residential penthouse. Completed. 4. Queensborough House Albert Embankment Extension of existing hotel building to provide 98 additional rooms over 5 new floors, recladding existing facade, creation of new open spaces at roof level. Permitted Hampton House, 20 Albert Embankment Erection of a part 15, part 16-24, part storey building to provide 253 residential units, cafe/restaurant uses (A3), office (B1) and ancillary residential facilities and landscaped public piazza. Permitted Not commenced. 6. Prince Consort House Albert Embankment Erection of a part 9, part 23, part 27 storey residential led mixed use development comprising a ground floor cafe/retail unit (Use Classes A1,A2 and A3), office space (Use Class B1) and 47 residential units (Use Class C3). Permitted Eastbury House Albert Embankment Erection of a part 14, part 21, part 28 storey building to provide a mixed use scheme incorporating: ground floor cafe/retail unit (A1/A3) and public piazza, office accommodation (B1) and 48 residential units. Permitted Not commenced. 20

137 8 Albert Embankment Economic and Employment Assessment January Albert Embankment Redevelopment of the site involving the demolition of existing petrol station and erection of a 23 storey building (including basement) to contain 2,073sqm of commercial floor space at ground, first and second floor levels (flexible use comprising retail [Class A1], café, restaurant [Class A3], wine bar [Class A4], offices [Class B1], gym [Class D2]), together with 164 self- contained flats (20 studios, 46 x 1 bed, 90 x 2 bed, 8 x 3 bed units) on upper floors, along with basement parking, plant, and associated landscaping works. Application refused. Mixed use viability of 8 Albert Embankment and Adjoining Sites 5.11 In terms of potential future uses on the Site, the provision of only B2, B8 and lower value B1 uses on the Southbank House and Newport Street KIBA would significantly under develop the site. As indicated in the Jones Lang LaSalle Planning and Viability Comment (2015), demand for higher value office accommodation may not be able to be realised for this site. The JLL viability assessment indicates a negative residual land value of 13.5 million for a KIBA compliant scheme, compared to a positive residual land value of 43.0 million for Native Land s revised scheme. The development of the subject site creates an opportunity to meet the objectives of the CAZ and the OA and to deliver purpose built space to meet the identified need for start- up commercial space and create a suitable environment for new and growing enterprises A mixed- use development here would improve the overall connection to the surrounding area. In addition, a range of commercial uses with mixed tenure residential would create a more dynamic environment, creating active street frontages and support restaurants and shops needed to foster this type of vibrant urban realm. The Southbank House building on the adjacent site to the south contains fully serviced office and studio suites managed by the Workspace Group. This provides accommodation for a range of business sizes. Recent observations indicate that this accommodation is underutilised and continues to have vacancies Instead of offering more of the same, the new commercial space within the proposed development would need to be complementary to Southbank House. This could be larger move on space for businesses that have outgrown serviced office accommodation. This would enable a chain effect freeing up smaller units for new firm creation and incubation. It would allow successful firms to expand and create jobs without moving from the area. This would seem to be more in keeping with the aspirations of the KIBA policy to enable and retain employment in the area The type of space in the proposed development should be flexible and create a different offer than Southbank House. The space could be converted into medium or smaller units depending on the needs of the occupier. This would allow the commercial element of this development to respond to changing market demands and trends reducing the risk of 21

138 8 Albert Embankment Economic and Employment Assessment January 2015 vacant ground floor units. This type of space is good for targeting small and medium size enterprises, start- ups and creative industries Southbank House and Newport Street KIBA has a number of characteristics that set it apart from the other KIBA sites. It is situated in the far north of the borough and provides a major opportunity to tap into Lambeth s growth sectors and to capitalise on its central London location. Unlike other KIBAs this site is in the Vauxhall Nine Elms Battersea Opportunity Area and the majority of the site is also in the CAZ The KIBA allocation is severely limiting this site s potential and constraining its capacity to provide employment for Lambeth residents. It is not likely to deliver industrial uses, nor major A- grade headquarter type offices. However, given its central London location and its designation within the Opportunity Area, it has the potential to deliver just the sort of mixed and attractive environment, suitable for a range of new and growing business. The next section examines in some detail the site s potential as an employment generator. The Planning Inspector s findings on the most recent Appeal 5.17 The most recent planning application for 8 Albert Embankment and Adjoining Sites was refused by the London Borough of Lambeth Planning Applications Committee (03/02/12). The subsequent Appeal (APP/N5660/A/12/ ) though dismissed on the grounds of impact of daylight and sunlight provides useful guidance on what may be acceptable for an alternative development on the Site, particularly relating to a broad mix of uses The Appeal Decision makes reference to Policy S3 of the Lambeth Core Strategy 2011 noting that this commits the Council to support local economic development, Lambeth s contribution to the central and wider London economy and a range of local business and job opportunities, by giving priority to a diverse range of economically beneficial uses in appropriate locations. Among means to achieve this is (a) Safeguarding Key Industrial and Business Areas (KIBAs) for business, industrial, storage and waste management uses, including green industries, and other compatible commercial uses, excluding large scale retail. ( 30) 5.19 The Appeal Decision s key finding was: on balance the departure from the KIBA objective of policy S3 is justified by the common ground position on viability and optimum provision of employment floorspace, the employment and wider economic benefits of the proposal, and the contribution it would make towards regeneration and vitality in the local area (also dealt with further below) by way of an intensive mixed use development with active street frontages. ( 36) 22

139 8 Albert Embankment Economic and Employment Assessment January 2015 Employment generation the Appeal Scheme and the Compliant Scheme 5.20 For the purposes of this economic and employment assessment report, an analysis of employment generation is useful. Two schemes are compared: (i) the above Appeal Scheme and (ii) a hypothetical KIBA Compliant Refurbishment Scheme The Appeal Scheme development relates to the entire site (with retention of the Grade II listed building) and would provide a total of: 265 residential units 2,721 square metres for the fire station 8,554 square metres of commercial floorspace (use Class B1) 696 square metres of retail floorspace (use Class A) 92 car parking spaces The KIBA Compliant Refurbishment Scheme would comprise the fire station and a simple refurbishment of the Middle Site and would provide a total of: Retention of the existing fire station (no change) 2,460 square metres of commercial floorspace (use Class B1) 4,180 square metres of warehousing floorspace (use Class B8) Standard job density ratios are applied to the scheme to calculate how much employment can be expected to be generated. These are obtained from the Employment Densities Guide 2 nd Edition (Homes and Communities Agency 2010). In addition to on- site employment, indirect employment is considered to be created as a result of new commercial floorspace. The Westminster Office Report Impact of the Recession (Drivers Jonas 2009) cited the English Partnerships evidence review of B1 office multiplier effects. This suggested a local area employment indirect multiplier of 1.29 (29 supporting jobs in the local area for every 100 office jobs). This multiplier is used in this analysis. The GLA have conducted a review of multipliers for housing development (Measuring Jobs From the Housing Programme, GLA 2012). For new gross housing output in London the suggested indirect job multiplier is 1.6 (that is 1.6 jobs per home built as a supply chain effect) Figure 10 shows the results of this analysis. Overall the Appeal Scheme would yield 1308 additional jobs. Even without consideration of the indirect jobs from the residential component, this would be a total of 884 additional jobs. The KIBA compliant scheme only yields 362 jobs. The key finding is that permitting the highest and best use (all other planning considerations being taken into account), a scheme with the mixed use configuration as applied in the Appeal Scheme would yield an employment outcome between double and three times that of a KIBA compliant scheme. 23

140 8 Albert Embankment Economic and Employment Assessment January 2015 Figure 10 Modelled employment generation on two schemes Appeal Scheme Direct employment Fire station - reprovision Commercial (B1) Retail Car parking Indirect / induced employment Residential Commercial Total employment: Total employment without residential jobs: Employment Yield Compliant Scheme Direct employment Fire station current Commercial (B1) Warehousing (B8) Car parking Indirect / induced employment Residential Commercial Total employment: A housing led mixed use scheme on the lines envisaged in the OAPF would have additional economic benefits for the surrounding area. The residents and employees will support other uses in the surrounding area. This begins the reinstatement of Lambeth High Street, which has lost its original function, reanimating this area and boosting the local economy. Household spending from the 265 new households in the Appeal Scheme could contribute up to 1.5 million per year to the economy, far more than an employment- only scheme. 1 Conclusion 5.26 The Site is located in the Central Activities Zone, an Opportunity Area and in an area of high density, residential- led mixed use developments. If a scheme did not maximise the opportunity presented by the Site it would not meet the objectives of the London Plan, in particular the Vauxhall Nine Elms Battersea Opportunity Area, which is to accommodate large scale development to provide substantial numbers of new employment and housing. On a local scale the enhancements to the local neighbourhood envisaged in the Vauxhall SPD are dependent on 1 Average weekly expenditure on food, clothing and footwear, household goods. From ONS 2014, Family Spending

141 8 Albert Embankment Economic and Employment Assessment January 2015 achieving a viable redevelopment on 8 Albert Embankment and Adjoining Sites Returning to the Appeal Decision (APP/N5660/A/12/ ) discussed above. The Inspector in the appeal referenced the 2010 Examination of the Lambeth Core Strategy ( 31): The 2010 Examination into the Core Strategy considered as part of an economic development issue the argument that confining KIBAs to employment use would mean that future development in this KIBA cannot reflect the mixed use character of the wider locality, and restrict redevelopment of sites within the KIBA in conjunction with the listed Fire Station building. The Inspector noted that removal of the KIBA designation would clearly overcome this obstacle and allow future development to reflect that in the surrounding area. However, she found there to be no compelling evidence to demonstrate that retaining this KIBA makes the Core Strategy unsound This is an important finding and recognises the fact that the current KIBA designation on Southbank House and Newport Street is a major obstacle, not only to the redevelopment of the site, but to the wider regeneration of the local area and the borough. 25

142 8 Albert Embankment Economic and Employment Assessment January 2015 Technical Annex 1. KIBA locations The following is a list of KIBA locations in the London Borough of Lambeth. This is derived from the KIBA Survey 2012 and the Lambeth Employment Land Review Update Final Report (Atkins, January 2013). These studies identified 27 KIBA locations as well as two clusters. Figure 11 List of KIBA designations in the London Borough of Lambeth (Atkins 2013) Site Postcode Area Bon Marche SW9 Stockwell Brighton House SW9 Stockwell Camberwell Trading Estate SE5 Camberwell Clapham North Ind. Estate SW4 Clapham Clapham Park Hill SW4 Clapham Coldharbour Lane Ind. Estate and Bengeworth SE5/SW9 Camberwell Durham Street/Oval Way SE11 Kennington Ellerslie Industrial Estate SW2 Brixton Eurolink Business Centre SW2 Brixton Freemans SW9 Stockwell Hamilton Road SE27 West Norwood Kennington Business Park SE11 Kennington Lion Yard SW4 Clapham Loughborough Road SW9 Stockwell Milkwood Road Estates SE24 Herne Hill Montford Place SE11 Kennington Norwood Commercial Area SE19 Norwood Park Hall Road Trading Estate SE21 Dulwich Shakespeare Road Business Centre SE24 Herne Hill Shakespeare Road Depot SE24 Herne Hill Somers Place SW2 Brixton South Bank House and Newport Street SE11 Kennington Stannary Street SE11 Kennington Timber Mill Way SW4 Clapham Wandsworth Road SW8 South Lambeth Waterworks Road SW2 Brixton Zennor Road Estate & Adjoining Sites SW12 Clapham South Cluster: Abbeville Mews SW12 Clapham Cluster: Hackford Walk SE11 Kennington 26

143 8 Albert Embankment Economic and Employment Assessment January Lambeth s economic base The London Borough of Lambeth s current and future economic base is presented below. The first part outlines labour demand that is employment based within the borough. This reveals the pattern of industry sector employment. This analysis is support by a review of business structure and the number of local business units operating in the borough. To complete this demand side analysis, a summary of recent employment forecasts is provided. Finally, there an analysis of labour supply is provided. This is based on the current resident population of the London Borough of Lambeth. This comprises an analysis of the economically active and inactive population of the borough, as well as occupational classifications and qualification levels. This economic base analysis provides the background and context for the more specific analysis of the current KIBA designation for 8 Albert Embankment. 2.1 Labour demand Labour demand includes jobs and vacancies available within a given area. Data is obtained from the Business Register and Employment Survey (BRES). The Office of National Statistics conducts this on an annual basis. The BRES replaced two existing surveys, the Business Register Survey and the Annual Business Inquiry. The BRES has two purposes, collecting data to update local business unit information and producing annual employment statistics. This dataset provides an annual snapshot of labour demand. Jobs density is a useful high level indicator of employment in an area. The indicator measures the numbers of jobs per resident aged For example, a job density of 1.0 would mean that there is one job for every resident aged The total number of jobs is a workplace- based measure and comprises employee jobs, self- employed, government- supported trainees and HM Forces. The number of residents aged figures used to calculate jobs densities are based on the relevant mid- year population estimates. Figure 12 shows the job density for the London Borough of Lambeth and for London as a whole. At 0.66, Lambeth has less than one job per resident. However, the borough does rank as the thirteenth highest in London, with the ninth ranking and above having more jobs than residents. Lewisham is the lowest at The density figure for Lambeth has fluctuated over the past 10 years, being 0.73 in 2000 and 0.71 in The 2012 figure is clearly still affected by the previous recession. Figure 12 Jobs density (ONS 2012) LB Lambeth (number) LB Lambeth London Jobs density 152, Source: ONS jobs density Notes: The density figures represent the ratio of total jobs to population aged Total jobs measure includes employees, self-employed, government-supported trainees and HM Forces. 27

144 8 Albert Embankment Economic and Employment Assessment January 2015 Figure 13 shows the number of jobs held by employees. Employee jobs excludes self- employed, government- supported trainees and HM Forces, so this count will be smaller than the total jobs figure shown in the jobs density table. The information comes from the Business Register and Employment Survey (BRES), which is an employer survey conducted in December of each year. The BRES records a job at the location of an employee's workplace (rather than at the location of the business's main office). Figure 13 Employee jobs by industry (ONS 2013) LB Lambeth (employee jobs) LB Lambeth (%) London (%) Total employee jobs 139, Full-time 99, Part-time 40, Employee jobs by industry Primary industry (agriculture and mining) Energy and water 1, Manufacturing 1, Construction 3, Services 133, Wholesale and retail, including motor trades 11, Transport and storage 5, Accommodation and food services 12, Information and communication 11, Financial and other business services 37, Public admin, education and health 46, Other Services 8, Source: ONS business register and employment survey The table reveals the structure of employment by industry classification. Thus, the broad split between the tertiary sector (services) and primary and secondary industry taken together is similar for the London Borough of Lambeth and London as a whole. The manufacturing sector in Lambeth is small at 0.9 per cent even by the low London standard of 2.3 per cent. Manufacturing for the UK as a whole is around 8.5 per cent. Some other features to point out are the larger public administration sector and smaller finance sector (though still significant) compared to London as a whole. In addition, the wholesale and retail sector is lower in Lambeth than the London figure. Previous data for Lambeth (based on the slightly different Annual Business Inquiry) showed a decrease in manufacturing employment from 3.4 per cent in 2001 to 2.0 per cent in This continued decline would appear to indicate a structural change in the Lambeth economy. It is noteworthy that the construction sector seems to have stabilised from 3.6 per cent in 2001 to 2.4 per cent in It is now 2.2 per cent. On the whole, private sector employment in Lambeth is now focused on wholesale/retail trade, transport, hospitality, IT and finance. 28

145 8 Albert Embankment Economic and Employment Assessment January 2015 Figure 14 shows the pattern of commuting into and out of the London Borough of Lambeth. This is based on the Census 2011 journey to work data and represents a snapshot of commuting at the time of the census. This reveals that more people leave the borough on a daily basis than enter it for work. The net effect is that 28,926 more people leave the borough for work than enter it for work. For neighbouring Southwark, 36,211 more people enter the borough each day for work than leave it. Figure 14 Labour market dynamics and commuting (ONS 2011) Commuter in- flows and out- flows for the London Borough of Lambeth. Source: ONS Census Business structure The data on business structure and local business units complements the previous analysis of labour demand. The data contained in the tables are compiled from the Inter- Departmental Business Register (IDBR) recording the position of units as at March of the reference year. The IDBR contains information on VAT traders and PAYE employers in a statistical register, which provides the basis for the Office for National Statistics to conduct surveys of businesses. Figure 15 shows the number of local business units operating in the borough. A business unit is an individual site a registered company or business enterprises operates from (such as a factory, office or shop). It is the best measure to use as it provides a true representation of businesses operating in the borough. The table reveals that over 90 per cent of businesses in Lambeth are in the service sector. Consistent with the labour market analysis above, only a small proportion (2 per cent) are in the manufacturing, energy and water sector. Of note also is the fact that over half of Lambeth s local business units are in the finance and business services sector (51.5 per cent). This is significantly higher that the corresponding figure for London as a whole. 29

146 8 Albert Embankment Economic and Employment Assessment January 2015 Figure 15 Local business units by broad industry group (ONS 2014) Employee jobs by industry LB Lambeth (local business units) LB Lambeth (%) London (%) Primary industry (agriculture and mining) Manufacturing, energy and water Construction Services 15, Wholesale and retail, including motor trades Transport storage Accommodation and food services Information and communication Financial and other business services Public admin, education and health Other Services Total 16, Source: ONS Inter-Departmental Business Register Figure 16 shows the number of local business units based on the number of employees in order to provide the standard categories of business size. The pattern of size of local business units in Lambeth broadly mirrors that of London as a whole. Small and micro businesses predominate. A crude comparison of the number of business units in manufacturing with the number of employees in the sector would indicate that most of these business units would likely be micro or small undertakings. Figure 16 Local business units by number of employees (ONS 2014) Local unit size by number of employees LB Lambeth (number) LB Lambeth (%) London (%) Micro (0 to 9) 15, Small (10 to 49) Medium (50 to 249) Large (250+) Total 16, Source: ONS Inter Departmental Business Register Note: Percentage is as a proportion of total local units. 30

147 8 Albert Embankment Economic and Employment Assessment January Forecast of increased employment demand (Atkins 2013) In August 2012, Atkins and Regeneris were commissioned to undertake the Lambeth Employment Land Review Update on behalf London Borough of Lambeth in order to analyse the future demand for employment land in the borough to The review provides the evidence base and associated policy recommendations to assist in the development of policies in the council s planning policies and land allocations. The review undertook an employment forecasting exercise. Under the base scenario, the number of full time equivalent jobs in Lambeth is projected to increase from 128,400 in 2011 to 148,400 in This would represent a strong increase of around 19,000 jobs, at a growth rate of 15 per cent, which is a similar growth rate to that projected across London as a whole. This equates to an average increase of around 3,800 jobs per year. Note that lower and higher scenarios were also modelled. The sectoral pattern of employment change is shown in Figure 17. Under the baseline scenario, employment is projected to increase in business services (10,100 jobs), communications (3,400 jobs), construction (2,100 jobs), other services (2,100 jobs), hospitality (1,200 jobs), and health (1,100 jobs), with smaller increases in transport and retail. The sectors in decline are public administration (1,200 jobs), utilities (600 jobs) and education (200 jobs). Manufacturing is forecast to decline by 500 jobs in the base scenario and by an identical number in the high growth scenario. For the low growth scenario, which overall sees an increase of 2,900 jobs to 2026, the decline in manufacturing is far more pronounced at a reduction of 800 jobs. This would represent a 61.5 per cent reduction in the 2013 employment figure for manufacturing. This analysis would appear to confirm the structural decline in the manufacturing sector in Lambeth. 31

148 8 Albert Embankment Economic and Employment Assessment January 2015 Figure 17 Employment forecasts ( ) Baseline growth scenario for the London Borough of Lambeth Source: Regeneris Consulting based on Oxford Economics Economic Forecasts, 2012, cited in Atkins 2013, p

149 8 Albert Embankment Economic and Employment Assessment January Labour supply Labour supply consists of people who are employed, as well as those people defined as unemployed or economically inactive, who can be considered to be potential labour supply. Consequently, the information in this section relates to the characteristics of people living in the London Borough of Lambeth. The resident population is thus the starting point of a labour supply analysis. Most labour supply data comes from the ONS Annual Population Survey. The APS is the largest regular household survey in the United Kingdom. It includes data from the Labour Force Survey, plus what are termed sample boosts in England, Wales and Scotland. The survey includes data from a sample of around 256,000 people aged 16 and over. The ONS mid- year population estimate for the London Borough of Lambeth for 2013 was 314,200. The key base statistic for labour supply is the resident population aged 16-64, which was 233,800 or 74.4 per cent of the total population. This proportion is higher than for London as a whole, which was 68.4 per cent in Figure 18 shows the main indicators of the Lambeth labour market. For the year to June 2014, there were 185,100 economically active persons in the borough. This refers to people who are either in employment or unemployed and seeking work. This represented 84.3 per cent of the resident population aged This was a higher proportion than for London as a whole. Again a higher proportion than London were in employment (78.7 per cent). This figure includes people on government- supported training and employment programmes. The unemployment indicator is derived using a statistical model developed by the ONS to estimate unemployment estimates from small samples. The model- based estimate improves on the Annual Population Survey estimate by borrowing strength from the JSA claimant count to produce an estimate that is more precise. The unemployment rate is expressed as a percentage of the economically active population. For the London Borough of Lambeth this was 7.6 per cent, which was close to the modelled London average. (Note however, that the Labour Force Survey derived indicator for the London Region was 6.3 per cent.) Figure 18 also provides an estimate of the economically inactive. These are classified as people who are neither in employment nor unemployed. They may want work but critically have neither not sought work in the last four weeks nor have been available to start work. The economically inactive include full time students, the long term sick, retired people and those looking after the family home. Proportionally, there were less economically inactive people in Lambeth (15.7 per cent) than in London as a whole (22.7 per cent). There were 11,900 students resident in Lambeth, which represents a high proportion than in London as a whole. 33

150 8 Albert Embankment Economic and Employment Assessment January 2015 Figure 18 Employment and unemployment (July June 2014) All people (16-64) LB Lambeth (number) LB Lambeth (%) London (%) Economically active 185, In employment: 172, Employees 139, Self-employed 30, Unemployed (model-based) 14, Economically inactive 34, Students 11, Long term sick 8, Looking after family/home 6, Source: ONS annual population survey Note: Numbers are for those aged 16 and over; percentage is as a proportion of those aged Figure 19 shows a breakdown of claimants for Jobseeker s Allowance (JSA) as at October These claimant count figures are always significantly less that the internationally agreed International Labour Organisation unemployment rate (based on the criteria of without a job, want a job, have actively sought work in the last four weeks and are available to start work in the next two weeks ). For Lambeth the claimant count was 7,107 or 3.0 per cent of the population. The JSA data provides an accurate profile of unemployed jobseekers. For all age groups, the duration split was 1.5 per cent seeking work for less than six month and 1.1 per cent for over 12 months. The claimant count for the 18 to 24 year age cohort was 4.1 per cent but with 3.0 per cent seeking work for less than six months. The claimant count for the 50 to 64 age cohort was higher at 4.4 per cent. Figure 19 Jobseeker s Allowance claimants (October 2014) All people (16-64) LB Lambeth (number) LB Lambeth (%) London (%) All people Males Females All ages duration Up to 6 months Over 6 and up to 12 months Over 12 months Aged 18 to 24 duration Up to 6 months Over 6 and up to 12 months Over 12 months Aged 25 to 49 duration Up to 6 months Over 6 and up to 12 months Over 12 months

151 8 Albert Embankment Economic and Employment Assessment January 2015 Aged 50 to 64 duration Up to 6 months Over 6 and up to 12 months Over 12 months The Jobseeker s Allowance (JSA) is payable to people under pensionable age who are available for, and actively seeking, work of at least 40 hours a week Source: ONS claimant count with rates and proportions Note: Percentage is a proportion of claimant count + workforce jobs total. JSA claimant count data provides information about the type of industries and occupational groups that people who are receiving unemployment benefit are seeking employment in. An extract was derived for the previous study by Hunt Dobson Stringer (2010). This revealed that within the London Borough of Lambeth, 58 per cent of jobseekers were looking for work in sales, administration and service sector employment. Only 1 per cent were seeking process, plant and machine operative occupations. This data is shown in Figure 20. Figure 20 Sought occupation of jobseekers (August 2010) JSA claimants sought occupation LB Lambeth (%) Administrative and secretarial 13.0 Personal service 6.0 Sales and customer service 25.0 Elementary administration and service 14.0 Source: Claimant count data 2010, cited in Hunt Dobson Stringer Figure 21 shows employment of residents of Lambeth by standard occupational grouping. The most significant finding here is that Lambeth has by far a higher proportion of employed people in higher order professional and managerial positions than in London as a whole, 70.1 per cent compared with 54.7 per cent in SOC2010 major group 1-3. There are far less skilled trades people in Lambeth (3.4 per cent) than in London as a whole (7.7 per cent). The same disparity is revealed for elementary occupations (4.8 per cent and 8.6 per cent respectively). The numbers of process, plant and machine operatives are too low in Lambeth to derive reliable estimates. This labour supply pattern for manufacturing occupations is consistent with the labour demand analysis, which indicates a structural and long term diminishing of manufacturing in the borough. Figure 21 Employment by occupation (July June 2014) All people (16-64) Standard Occupational Classification LB Lambeth (number) LB Lambeth (%) London (%) SOC2010 major group , Managers, directors and senior officials 20, Professional occupations 56, Associate professional & technical 43, SOC2010 major group ,

152 8 Albert Embankment Economic and Employment Assessment January Administrative & secretarial 13, Skilled trades occupations 5, SOC2010 major group , Caring, leisure and other service occupations 10, Sales and customer service occupations 10, SOC2010 major group , Process plant & machine operatives # # Elementary occupations 8, Total: 171, Source: ONS annual population survey Note: # sample size too small for a reliable estimate. Figure 22 shows the levels of qualifications obtained by Lambeth residents. This again reveals a higher skill based population than London as a whole. Lambeth has both more people qualified to NVQ4 and above and less people with no qualifications compared with London as a whole. For the NVQ4 category, the difference is very marked, with 62.8 per cent for Lambeth compared with 49.1 per cent for London as a whole. Figure 22 Qualifications (January December 2013) All people (16-64) Qualification level LB Lambeth (number) LB Lambeth (%) London (%) NVQ4 and above 134, NVQ3 and above 159, NVQ2 and above 172, NVQ1 and above 183, Other qualifications 17, No qualifications 13, Source: ONS annual population survey 3. Mixed use case studies For completeness, the case studies presented in the previous Hunter Dobson Stringer have been reproduced here. Note that this information was compiled in To demonstrate the attractive and long- term viability of mixed use development, this section gives examples of some developments elsewhere along the Thames riverside where employment uses successfully co- exist with residential uses, to the mutual benefit of both. 3.1 Vanilla and Sesame Court This is a ten year old development by Fairview Homes, set back from the river on Curlew Street in the London borough of Southwark. It has ground floor offices with up to seven storeys of residential above. Current businesses working from 36

153 8 Albert Embankment Economic and Employment Assessment January 2015 the building include back2normal (medical services), Gutenberg Networks (marketing production), Paper Hat (print management), Orange Information Systems (IT services). It is part of a very successful mixed use cluster around Shad Thames, including offices, shops, restaurants, and homes. 3.2 Oxo Tower Wharf This building was originally built as part of a power station to later be converted into a cold store. It was redeveloped into an award winning mixed use building by the Coin Street Community Builders in the 1990s. The development includes a range of retail design studios, specialist shops, galleries, restaurants, cafés, bars and 78 residential units. This development has been very successful and received a number of awards including the Royal Fine Art Commission/BSkyB s Building of the Year Award for Urban Regeneration in 1997, RIBA Award for Architecture in 1997 and the Civic Trust Award in 1998 amongst others. 3.3 Imperial Wharf Imperial Wharf is a mixed use riverside development in the London Borough of Kensington and Chelsea. This development includes over 800 residential units, 350,000 square feet of commercial space including offices, restaurants, bars and a hotel. Similar recent proposals for 8 Albert Embankment, the office accommodation is located under the residential units as well as above the retail space. While this development experienced problems with vacancy rates during early phases, this was due to concern over the levels of construction that was on- going throughout the development. This development was of a larger scale than that proposed at 8 Albert Embankment and therefore had a number of construction phases. This development is now accepted as a successful example of mixed use development and has received a number of awards including Best Mixed Use Development, Building for Life Silver Standard 2009 and the What House Awards

154 8 Albert Embankment Economic and Employment Assessment January

155 Statement by LFEPA APPENDIX 6

156

157 Statement regarding Lambeth Fire Station Site 12 January 2015

158 London Fire Brigade Statement regarding Lambeth Fire Station Site Introduction Lambeth fire station is one of 102 land fire stations which are strategically maintained to provide the fire and rescue service in London. They deliver a response to emergency incidents by getting fire engines and other resources to incident locations as quickly as possible, and by delivering proactive community safety work. The Brigade has targets for the speed of attendance which include getting a first fire engine to an emergency within an average six minutes and the second fire engine, when needed, within an average of eight minutes to all types of emergency London wide. Lambeth fire station is of key strategic importance to the London Fire Brigade (LFB) due to its position not only within Lambeth but also with it being so close to the Houses of Parliament and other key government buildings. The LFB s Fifth London Safety Plan (LSP5) was agreed in September 2013 following extensive consultation. Changes to fire stations and fire engines included in LSP5 were implemented in January 2014 which involved, amongst other things, the closure of nearby Westminster and Southwark fire stations; Lambeth fire station now covers a larger area and is the only fire station within the Government Security Zone (GSZ) which is the area of central London containing most of the major government and public buildings. During the planning process for LSP5 Lambeth fire station was one of 28 fire stations across London which were protected from potential closure due to factors such as age, significant recent or planned investment, their functionality and flexibility. In 2014, there were nearly 2,000 emergency incidents in Lambeth s enlarged station area. Incidents in the Lambeth station area received a first appliance in 4m:53s on average in 2014, and 5m24s on average for a second appliance (where needed). Lambeth fire station is in a prominent location which provides for effective operational deployment with excellent access to residential areas both the north and south of the river, as well as important sites like Guys and St Thomas Hospital, Palace of Westminster and Whitehall and Waterloo station. The profile of the area covered by (or close by to) Lambeth fire station will change with the significant developments now underway or planned in the Vauxhall and Nine Elms area; these will increase significantly the level of high rise residential and commercial buildings within this area. The location of Lambeth fire station also presents a positive and reliable public image and a strong civic presence for the LFB within this part of central London. Lambeth fire station currently hosts the Brigade s Rapid Response Team (RRT) which would respond to chemical, biological, radiological, or nuclear (CBRN) incidents. The RRT s capability is 12 January 2015 Page 1

159 very suitably located within the GSZ, and also provides a key emergency response resource located centrally in the Capital for all other key risk sites. A fire station needs to be provided in this area and re-provided as part of any redevelopment of this site. History of Lambeth Fire Station The LFB Headquarters (HQ) on the Albert Embankment was opened on the 21 July 1937 by King George VI. The building, designed by the London County Council (LCC) architects, E. P. Wheeler, FRIBA and assistant architect, G. Weald FRIBA, was built to replace the old headquarters building in Southwark. The large site is in two sections on either side of Lambeth High Street. Historically the ground floor of the eight storey building on the Albert Embankment provided operational facilities with the first floor designed for living quarters and recreation rooms for on-duty fire crews together with a London-wide control room. Many of the upper floors were designed as flats for fire officers and their families, but were previously used as administrative offices for the LFB The drill tower at the rear of the Albert Embankment building - was the first in the LFB to be provided with an internal staircase and a dry rising main. At the rear of the Albert Embankment building, across Lambeth High Street, is the former workshop block which accommodated garages and repair shops, stores, various workshops and a training school complete with kitchens and more living quarters. In 1939, in view of the impending war, an underground control room was built, which was responsible for mobilising appliances across London. On 29 December 1940, the control room mobilised some 2,200 appliances which dealt with 1,500 fires during a series of bombing raids which threatened to destroy the City of London. A new control room opened on the basement site in This was replaced by anew Command and Mobilising Control (CMC) centre in DATE at the south end of the Albert Embankment building. HQ was the social venue for a dozen Christmas pantomimes which began in the early 1950s. Staged originally in the Rear Block Workshops, the early performances were simply intended to entertain HQ personnel and their families. However they became so popular that they were forced to move to a 300-seat theatre next to the old Southwark HQ. The final curtain call was in Christmas The original site also included a Museum which was demolished to facilitate construction of the CMC. The Brigade Band used the former Lambeth Ragged School (a free school for poor 12 January 2015 Page 2

160 vagrant children where they were taught and given food) on the far side of the railway arches as a practice room and band library. This building is now the Beaconsfield Art Gallery. The Memorial Hall In the main, (South), entrance stand three impressive memorials. The first, on the left rear wall, presented to the Brigade by the association of insurance underwriters, is an elaborate tablet commemorating the establishment of the Metropolitan, (later London), Fire Brigade in The second memorial presented by the underwriters of Lloyds, commemorates those firemen and firefighters who have died in the execution of their duty. This memorial has a carved centre panel depicting a firefighting scene showing firemen with breathing apparatus, hose and wheeled escape. The panel is flanked by rolls of honour of firefighters of the Brigade, dating back to 1840, who have died on duty. Two grilles at right angles to the panel show an old fire helmet, firehooks and other historical items. The bronze plaque at the foot of the memorial reads: To the memory of the officers and men of the London Fire Brigade who throughout the years lay down their lives whilst doing their duty. A mosaic on the floor in front shows boats on the Thames with St Paul s Cathedral in the background with people escaping by the river steps from the great Fire of The surround bears the inscription: London s burning, London s burning, Fire, Fire. In 1956 a third memorial, commemorating the men and women of the London fire services who lost their lives during the Second World War, was unveiled and dedicated. Standing opposite the second memorial which consists of a brass replica of St Paul s attached to stonework etched and coloured to represent smoke and flame. Blue drapes separate the memorial from the wooden panels engraved with the names of those who perished. Beneath is a map in terrazzo on the floor showing the London Civil Defence Region and the constituent authorities, whose brigades combined to provide the fire defence of London. The memorials are considered to be key areas of significance of the listed building and to the Brigade s heritance. The conservation area, within which the fire station is located, was designated in 2001 and the main fire station building itself was Grade II Listed in The Existing Lambeth Fire Station The LFB has an Asset Management Plan (AMP) which establishes the brigade s priorities for investment in its estate to deliver improvements in attendance times, property improvement and to release the latent financial value of existing fire station sites. This is all part of the LFB s 12 January 2015 Page 3

161 corporate aim of managing risk by using resources flexibly, efficiently and effectively, continuously improving the way we use public money.one of our key objectives in the LFB s AMP is To maintain our properties and preserve their value in accordance with the lifing policy that where possible, no station shall be over sixty years old. This objective is designed to provide fire station facilities fit for the 21st century including community facilities and it reinforces our commitment to providing the best possible service to Londoners. It also helps to ensure that the LFB s fire stations continue to respond to the changing risks facing London such as terrorist threat, climate change, increased risk of flooding and population growth. To meet these risks there has been a significant increase in the number and size of some of our specialist response vehicles and the way we manage the availability of these vehicles and skills continues to impact on the accommodation needs on fire stations now and in the future. The Lambeth fire station and LFB HQ are nearly 80 years old. The fire station requires significant modernisation to allow its firefighters to efficiently and safely cope with the current identified (and future) risks within Lambeth and surrounding boroughs and to provide the required accommodation for new and larger specialist fire service vehicles. The existing Lambeth fire station has five usable appliance bays and supporting operational functions on the ground floor with amenity, administration and training facilities on the first and second floors. The upper floors above the fire station were built as residential quarters which in later years were converted to office accommodation for the former HQ of the LFB. These floors have been vacant since February 2008 when the LFB moved to a new HQ at 169 Union St in Southwark. This move was prompted by the fact that the existing accommodation was out-dated, not suitable for modern day office usage and technology, nor is it energy efficient. This part of the building remains in a poor state of repair according to condition surveys that we have undertaken. In addition, LFB has insufficient funding to maintain its upkeep. The obsolete workshop building on the middle site is also vacant and in a poor state of repair. It has suffered from a history of squatting since it became vacant in 2008 resulting in significant legal, repair and clean up costs. The LFB now employs at substantial cost full time residential security guards on these premises to minimise further squatting and prevent harm to the amenity of neighbouring properties. The need for improved facilities The LFB HQ on Albert Embankment was spread across three sites at number 8 and also numbers 20 to 21. The latter buildings were leased and the LFB was required to vacate them in As part of planning for this, the LFB concluded in 2004 that the premises at number 8 were no longer fit for purpose as the HQ for the LFB because there was limited opportunity to deliver 12 January 2015 Page 4

162 open plan space and 21st century technology. Whilst moving from this historical purpose built site represented significant upheaval, it did provide an opportunity to consolidate in a single premises and incorporate one of our largest sites within a Corporate Property Project (CPP). The CPP is aimed at releasing the latent value in a site to re-provide a fire station and reinvest any uplift in the rest of the LFB estate. In this instance the proceeds from the sale were targeted in part to fund the relocation into our new consolidated HQ building at Union Street at a cost of 20m. Given Lambeth fire station s key position, it needs to remain open but it can only do so if it is substantially improved. Our Standard Station Design Brief sets out size of spaces, building services requirements together with the equipment and fittings to be installed to deliver a consistent standard of accommodation at our fire stations and to be able to adapt to changing working practices and vehicle capacity. The primary deficiencies at Lambeth fire station against this Brief include the following: Insufficient area to accommodate our New Dimension/London Resilience vehicles and equipment under cover, which are deployed to respond to highly specialised search and rescue incidents related to flooding and CBRN threats in the Government Security Zone. Insufficient covered area to wash down the appliances and carry out training. The watch room, fire gear and breathing apparatus rooms all need extra space to function properly. The gym on the first floor would be better sited at ground floor level to facilitate a wider range of physical training. The general layout of the fire station building is inefficient (over three floors) and no clear definition exists between the operational areas and the supporting facilities. Accommodation does not meet the diverse workforce and flexible arrangement for the future e.g. provide for women s accommodation and varying numbers of men and women for each duty period over four watches. The existing building does not provide the required community engagement facilities to support the community services and provide a welcoming community interface. The very old training facilities do not facilitate effective on-site training in a diverse area. In addition the drill tower has limited training capacity due to its age and condition so training tends to be carried out on other more modern sites. The building services are at the end of their normal operational life and are not energy efficient. The external building fabric is in poor condition and is costly to upkeep and repair particularly due to its listed status. A new fire station is required. Specifically a scheme would need to address the deficiencies outlined above and permit the key criteria of the LFB approved Standard Station Design Brief to be accommodated as follows: 12 January 2015 Page 5

163 Four fire engines in the existing bays with New Dimension/London Resilience vehicles in the covered area. A covered wash down area. More flexible space to meet a diverse workforce and changing working practices of a 21st century fire service. Modern and energy efficient facilities for staff and community engagement. New amenities, resting and changing facilities to provide an appropriate level of dignity to all firefighters. Ground floor gym and operational facilities. New building services, redecoration internally and externally. 21 car parking spaces including two disabled car parking spaces. A new prominent entrance to the fire station with pedestrian access to community facilities and the memorials which are considered to be key areas of significance of the listed building. External and/or internal training facilities to meet a diverse range of training requirements. This could include the refurbishment of the existing listed drill tower to facilitate full usage or a new drill tower constructed within the training area. Ensure that the memorials in the south entrance to the listed building maintain a synergy with the fire station now that the HQ function has moved. Savings in facilities management (maintenance and energy costs) will be achieved. With major station improvements in the past, the LFB had the flexibility to temporarily redeploy appliances and crews to neighbouring stations whilst building works were carried out, but the overall reduction of spare capacity at stations elsewhere and station closures under the Fifth London Safety Plan has made this option impractical. Therefore, business continuity is a key factor in the design of the new fire station for Lambeth. It is essential for the station to remain fully open and operational at all times during any redevelopment of the site. There is also potential for the LFB museum to be relocated to this site as part of the fire station or within the overall redevelopment of the site. Challenges facing the LFB estate Adapting the assets of the LFB to fulfil these modern roles and responsibilities is a major task, often made more problematic given that a third of the fire stations are listed, locally listed or located within a conservation area. Funding to address this challenge is tightly constrained. The LFB s capital funding revenue support through fire formula grant ceased in 2010 and capital grant funding that replaced it will cease in 2015/16. Possible future capital funding is uncertain as central Government have not announced their intentions for future grant funding for the fire 12 January 2015 Page 6

164 service. The Authority must therefore assume no further capital funding will be received from central Government, which means the only alternatives available to fund its future asset programme would be through borrowing and/or capital receipts generated from the sale of its assets. Given the Authority has made in excess of 100m in revenue savings since 2008 with further savings of 14m required in 2016/17, this will severely limit its ability to finance borrowing to fund property projects from revenue within its capital programme, especially given the additional demand on it in replacing the operational vehicle fleet. Given the level of works backlog identified in its approved Asset Management Plan (2011) of 141.0m the Authority s only alternative to borrowing is the use of any capital receipts it can generate. In the present financial climate increasing borrowing with the associated debt costs can only be entertained where capital spend would result in immediate net revenue savings, which is very difficult, if not impossible, to achieve when updating a property portfolio with the property and operational constraints that the Authority faces. Having regard to key operational requirements (to optimise response times for the arrival of the first and second fire engines to incidents, site access and tenure), alternative site searches have been undertaken. No suitable sites have been identified to date. The LFB recognises that staying in the same location would serve to reinforce our historical and functional connection with the site since the 1930s as well as our proximity to the memorials. The procurement process for the sale of Albert Embankment has been lengthy. LFEPA has already had to deal with substantial delays in terms of the receipt for the sale proceeds principally due to the very protracted period associated with the planning process. The original plan to fund the HQ relocation from Albert Embankment was based upon an assumption that the additional borrowing required for this would be offset by a corresponding reduction in borrowing in later years as a result of the capital receipt. This has also been significantly delayed. This has meant that the property projects in the Capital Programme have had to be restricted in every year since 2010/11 to ensure that LFB stays within affordable borrowing limits. This has resulted in delays to the projects to refurbish or replace West Norwood, East Ham, Brixton, Plumstead fire stations and contributed to the closures of Knightsbridge, Woolwich and Clerkenwell fire stations all of which require significant investment if replacement fire stations were required. Completing the sale of Albert Embankment will generate a receipt which will allow us to make further essential investment in our estate without increasing our borrowing and associated revenue costs. This is essential given the grant reductions mentioned above. 12 January 2015 Page 7

165 Concluding Statement In preparing our operational strategies, LFB are mindful of how London will change over the coming years. The Mayor s spatial development strategy, the London Plan, identifies Waterloo and Vauxhall Nine Elms Battersea as development opportunities. The Lambeth fire station will provide flexibility in considering what impact these opportunities may have on the LFB's services. This is likely to mean increased focus on prevention and protection requiring facilities to engage with the local community. The existing station is ideally located for this purpose and the new fire station will provide a welcoming and accessible facility for the community and a complementary presence for the memorials in the listed front building. LFB must be able to respond to fires and other types of incidents which will still occur at the same time as we are dealing with one or more major incidents e.g. terrorism, flooding and CBRN hazards. If any of these events do happen, the public will expect us to be there as soon as possible to help and save lives and reduce the damage that they are causing. The proposed new fire station for Lambeth will enable us to be prepared for these eventualities from a modern facility and one that is strategically located to achieve fast response times to these emergency incidents. The LFB s capital programme over the past years to support strategic and operational objectives has been constantly under pressure through capital and stretched resources. It has not proved possible to provide sufficient investment to enable the required refurbishment and redevelopment of stations to be met. The redevelopment of Albert Embankment is seen by the LFB as a key opportunity to provide a refurbished fire station (self funded through the private residential component of the development) and to fund other new or refurbished fire stations in the Borough of Lambeth (e.g. Brixton) and elsewhere in central London. It will also bring about essential property improvement for the LFB which cannot be funded through other means. The LFB have already completed the new Millwall fire station on this basis where it was entirely funded by the private sector providing a new fire station on an alternative site with the capital receipt reinvested in other parts of the estate, including our new Harold Hill fire station constructed in Lambeth fire station is strategically important to the LFB due to its position not only within Lambeth but also close to the heart of government and the key Government Security Zone. However it is in poor condition and no longer meets our operational requirements. It can therefore only continue to stay open if it is substantially improved. The proposed development will allow us to continue to provide a fire station at this strategically important location as well as regenerating a site that has been largely vacant now for 4 years. 12 January 2015 Page 8

166 Local residents will benefit from a new state of the art fire station on their doorstep as well as improvements to this landmark building which will retain its originally intended use. The successful completion of a development on this site will also provide essential funds to invest in other areas of the LFB estate including the Brixton fire station. The LFB remains committed to delivering a high design quality, operationally efficient fire station cognisant of the listed building to ensure progressive improvement in the provision of fire prevention and fire and rescue services within Lambeth. This cannot be delivered without a more flexible approach to planning considerations for this site. The LFB respectfully request a reconsideration of the Local Plan. Dominic Ellis, Assistant Commissioner Technical and Service Support. 12 January January 2015 Page 9