APPENDIX 45
Memorandum received from Lambeth Council
INTRODUCTION
This submission is made in response to a request
from the Culture, Media and Sport Select Committee dated 23 January
and received by the Council on 28 January. The Select Committee
have asked for the following: information from Lambeth Council
regarding its involvement with the current plans to redevelop
the South Bank Centre (SBC) complex; Lambeth's response to the
SBC's concerns over the process followed by the Council in considering
their application; the responses to the proposals the Council
has received from the local community and how they have been involved
in the decision making process.
It should be noted that this submission has
been prepared at short notice for a deadline of Friday 1 February.
The Council would welcome the opportunity to give oral evidence
to the Select Committee as it believes that, on the basis of information
received to date, the Select Committee may have been misinformed
regarding the Council's handling of these matters. In addition,
we may wish to submit further written evidence after 4 February
on the return from annual leave of the Head of Planning who has
been very closely involved in these matters.
LAMBETH'S
INVOLVEMENT IN
THE THREE
PHASES OF
DEVELOPMENT
Lambeth Council is fully supportive of the South
Bank Centre's aspirations to enhance its status as a world class
centre for the arts. The Council recognises the benefits this
will bring to London as a whole and Lambeth in particular. The
successful redevelopment of the South Bank Centre will be a key
component in the regeneration of the South Bank and Waterloo.
However, it must be recognised that there are many other stakeholders
in the area including other substantial landowners, businesses
and community groups.
A number of other businesses in the area are
seeking to redevelop or consolidate their landholdings. In addition
to considering planning applications from the SBC, the Council
is currently considering applications to redevelop the Shell Centre
and to permanently retain the London Eye. The Council is also
having discussions with Frogmore Developments on their proposals
for the County Hall Island site and anticipate that proposals
to redevelop Elizabeth House on York Road and Waterloo Station
may come forward in the near to medium future.
The Council is keen to promote development in
the area but is mindful of the need to ensure that each new development
as it comes forward does not prejudice the proposals of others.
The Council is seeking to encourage an integrated approach to
the regeneration of the area, encouraging all the key stakeholders
to work together to ensure that the maximum benefit is achieved
from any new development.
The Council takes the view that it is vitally
important to look at the South Bank strategically. The implications
of every new planning application in the area must therefore be
carefully scrutinised to assess how it might affect the redevelopment
of other sites. In particular, issues of access, servicing and
pedestrian routes are of crucial importance. It is essential to
ensure that all new development is successfully integrated with
the public realm and the other development sites around it.
The Council's policies and proposals for the
South Bank and Waterloo are contained in the Lambeth Unitary Development
Plan (UDP), adopted in August 1998. The Council is currently consulting
on revised policies and proposals in its Draft Deposit UDP. The
adopted UDP designates the Hungerford car park and service road
to the south of the Hungerford railway viaduct as Metropolitan
Open Land (MOL). The UDP seeks to retain MOL in predominantly
open space use. Built development can only be considered where
it is associated with the open space and recreational use of the
land. Furthermore, the UDP designates the Hungerford car park
for an extension to Jubilee Gardens. The Council's new Draft Deposit
UDP largely maintains these designations with the exception that
the area needed by the SBC for its service road south of the Hungerford
car park is removed from both designations.
Therefore, whilst remaining supportive of the
SBC's aspirations, Lambeth Council, as planning authority for
the area, has to assess the SBC's planning applications on their
merits, taking account of Lambeth's own planning policies and
proposals, the results of public consultation and any other material
planning considerations.
Officers of the Council's Planning Service have
had discussions with the SBC regarding their masterplan proposals
on several occasions. At these meetings they have taken the approach
outlined above, being supportive of the general aims of the SBC
but also providing advice on what aspects of the SBC's proposals
were likely to prove problematic in planning terms. In particular,
officers expressed concerns regarding development on Jubilee Gardens,
pointing out its status as Metropolitan Open Land in Lambeth's
UDP expressing doubts that development below a raised gardens
could be successfully achieved without seriously compromising
the Council's aims of creating a world class metropolitan park.
Similar concerns were expressed about development on the Hungerford
car park site.
Officers also expressed the view that as the
South Bank Centre is situated within the South Bank conservation
area it would be difficult to deal with an outline planning application.
In many ways the details of how the different component parts
of the redevelopment proposals were designed would be key to judging
their acceptability in planning terms.
At all times officers of the Council have stressed
the need to think strategically about the future of the wider
South Bank area and have encouraged the SBC to work closely with
other landowners in the area such as the Shell Centre and London
Eye. Officers of the Council considered that if information could
be shared amongst these landowners the Council would be in a better
position to assess any planning applications made and would not
have to refuse to deal with particular applications on the grounds
of prematurity.
PROCESS FOLLOWED
IN CONSIDERING
THE SBC'S
APPLICATIONS FOR
THE ROYAL
FESTIVAL HALL
The SBC submitted two sets of planning applications
to Lambeth. Firstly on 31 May 2000 planning, conservation area
and listed building applications were received for the "Liner
Building" project (reference numbers 01/00717/FUL, 01/00718/CON
and 01/00719/LB). Subsequently on 11 September 2000 planning and
listed building applications were received for the Foyers Project
(reference numbers 00/02263/FUL and 00/02595/LB). A timetable
illustrating the key stages in dealing with the SBC's planning
applications is set out as Annex 1 to this submission. Neither
application was submitted two years ago as we understand has been
stated by the SBC.
The SBC have stated that the Foyers Project
applications are simple, straightforward and non-controversial.
In fact both the Liner Building and Foyers Projects are very complex
involving external alterations and extensions to the Grade I Listed
Royal Festival Hall (RFH) together with changes to the way the
building is accessed and serviced. The applications have important
implications for the setting of the RFH and the quality of the
public realm around the building and both applications have raised
important issues of planning policy together with issues of strategic
importance for the future planning of the South Bank. Both projects
have elicited a large number of objections from the local community
(see section 3) and both projects have raised objections from
the 20th Century Society. In addition, the Liner Building has
raised concerns from the Greater London Authority (GLA). Neither
application could have been recommended to Lambeth's Planning
Applications Committee for approval in their original form and
both have undergone several revisions by the applicants, each
necessitating further rounds of public consultation.
A large number of objections have been received
to the Foyers Project. The proposals would alter the arrangements
for coach access to the RFH, would necessitate the relocation
of the disabled parking spaces and extend the retail areas of
the RFH below the riverside terrace. All matters objected to by
the local community. The local community have also objected that
the Foyers Project is inextricably linked to the Liner Building
and therefore raises all the policy and strategic planning issues
raised by that application. As originally submitted, the plans
for the Foyers Project application also showed the details of
the Liner Building. It was very difficult for officers and the
community to distinguish the applications from each other by simply
looking at the plans. Officers of the Council are therefore sympathetic
to arguments raised by the local community.
The length of time the applications have been
considered by Lambeth has been primarily due to the need to resolve
the important issues of policy and strategic planning of the South
Bank, together with a number of detailed issues, that required
amendments to the plans and the need for further rounds of public
consultation. For example the 5th floor of the Liner Building
as originally submitted would have had an unacceptable impact
on the Strategic View from Westminster Pier to St Paul's Cathedral.
Rather than refuse the application Lambeth entered into negotiations
with the SBC to resolve the issue.
The Liner Building proposals would consolidate
and extend the service road to the south of the Hungerford viaduct
on land designated as Metropolitan Open Land and as an extension
to Jubilee Gardens in Lambeth's UDP. This necessitated advertising
the Liner Building application as a departure from the UDP. Objections
raised by the local community rest primarily on this fundamental
policy objection to the scheme arguing that determination of both
applications would be premature in the absence of an agreed masterplan
for the redevelopment of the SBC as a whole and would prejudice
alternative masterplan proposals. The Waterloo Community Development
Group (WCDG) have objected that both proposals would prejudice
their alternative masterplan proposals that involve building underground
between the RFH and the river. They also object that the proposals
would prejudice the introduction of underground servicing to the
South Bank Centre.
It has been necessary for officers of the Council
to work long and hard with the SBC and Transport for London in
an attempt to resolve these strategic planning issues. The implications
of the SBC's proposals have been carefully explored and many alternative
arrangements for servicing have been tested. This has all taken
time but has been absolutely necessary for officers to be confident
in their recommendation that the SBC's proposals are acceptable
When first submitted on 11 September 2000 the
Foyers Project's application could not be accepted as valid by
the Council as insufficient information had been submitted. This
information was received from the SBC on 7 November 2000. Further
clarification on the extent of the application and how it related
to the Foyers Project was requested during November/December 2000.
The SBC have stated that the Council's debt
has led to a lack of investment in the Planning Service and poor
performance in deciding planning applications. The implication
is that the SBC's planning applications have been delayed by staff
shortages at Lambeth. It is the case that there was a delay in
considering the Foyers Project application when it was initially
submitted. This was the result of staff turnover within the Planning
Service. Two case officers left the Service shortly after the
case was allocated to them. It was then decided to deal with the
application in the Strategic Planning Group. However, the officer
responsible was engaged in a lengthy public inquiry and there
was a further period before detailed attention to the application
could be given. Once the case officer looked in detail at the
application it was realised that it involved additional development
and had wider implications than at first realised. A further round
of public consultation was therefore undertaken in July/August
2001 on a revised description of development. The main reason
for the time it has taken Lambeth to consider the application
however has not been staff shortages within the Planning Service
but the complexity of the application, the number of detailed
objections received from the local community and the need to resolve
the proposal's implications for the future strategic planning
of the South Bank.
Since 2000 Lambeth Council has been gradually
investing in its Planning Service in order to address previous
under-investment and to improve performance. In the past two years
an additional £400,000 has been invested in the service and
it is planned that a further £340,000 will be invested in
the service in 2002-03. This, together with improved procedures,
has begun to reverse the poor performance of the past. The proportion
of planning applications decided within eight weeks has risen
from 34 per cent in the year ending September 2000, when Lambeth's
performance was the lowest in London, to 54 per cent in the year
ending September 2001, putting Lambeth 23rd in London (ie above
the bottom quartile). The Council takes planning performance very
seriously and we would draw the Select Committee's attention to
Annex 2 The Performance Digestthis is considered monthly
at Lambeth's Policy Committee and includes planning performance
as a key performance indicator. The Select Committee will note
the recent in year improvements with current monthly performance
at 65 per cent. However, in common with many other planning authorities
in London, Lambeth suffers from problems of recruitment and retention
and is heavily dependent on the use of agency staff. This leads
to problems associated with high levels of staff turnover.
The Select Committee should also be aware that
the Council has put in place a full Best Value Review of the Planning
Service. This began in Autumn 2001 and is due to complete in Summer
2002. This provides a fundamental review of the whole service
and will recommend improvements together with an implementation
plan.
Due to the obvious connection between the Foyers
Project and Liner Building applications officers had originally
intended to present both to Lambeth's Planning Applications Committee
(PAC) on the same day in November 2001. Officers felt that this
would give Members of the Council the benefit of understanding
how both projects related to each other. However, negotiations
with the SBC were taking place to establish whether the servicing
arrangements submitted with the Liner Building could be amended
to reduce their impact on the Metropolitan Open Land to the south
of the Hungerford railway viaduct. Information was also needed
on the implications of the Liner Building on the potential for
achieving underground servicing of the SBC at some future date.
The SBC stressed the need for an early determination of the Foyers
Project for reasons of funding so it was agreed to present the
Foyers Project on its own to Committee on 27 November 2001.
Unfortunately, due to an administrative delay,
the officer's report missed the 27 November agenda. The report
was subsequently submitted to the Committee on 11 December resulting
in a delay of two weeks. Any assertion by the SBC that the Council
lost the papers and that a huge amount of time was lost as a result
is not correct.
On 11 December 2001 Members of Lambeth's Planning
Applications Committee deferred consideration of the Royal Festival
Hall Foyers Project applications for a site visit. The Members
of the Committee also resolved that they be given a presentation
on site of the Liner Building applications at the same time. Officers
had hoped to present the Liner Building applications to Committee
on 26 February 2002.
The Foyers Project applications were subsequently
placed on the committee agenda for 15 January 2002. The site visit
took place on Saturday 12 January 2002 at 10.30am and was attended
by Members of the Committee, council officers representatives
of the South Bank Centre (SBC), the scheme architects (Allies
and Morrison) and around 20-30 members of the public including
representatives from local community groups.
During the site visit the Members of the Committee
decided that they wanted to consider both sets of applications
together at a special meeting to be held in the Waterloo area
as soon as possible after 26 February. The main reasons the Members
made this decision were as follows:
The two sets of applications are
complex and there were many issues of detail to consider;
The two sets of applications are
closely linked (although officers advised that it would be possible
to decide the Foyers Project applications independently of the
Liner Building);
Both sets of applications include
alterations to the Grade I listed RFH, have important implications
for its setting and the function of the public spaces around it
and affect the way it would be accessed and serviced;
The Liner Building proposals would
consolidate and extend the service road on the south side of the
Hungerford railway viaduct. This road is on land designated as
Metropolitan Open Land (MOL) and proposed for an extension of
Jubilee Gardens in Lambeth's UDP;
Objections have been received that
the proposals should not be considered in the absence of an agreed
masterplan for the South Bank, that they would prejudice an alternative
masterplan drawn up by the local community, that they would prevent
the introduction of underground servicing to the South Bank and
that they would inevitably lead to further development on MOL;
The applications therefore raise
a number of important planning policy issues and issues of strategic
importance for the future of the South Bank;
A special meeting in the Waterloo
area would allow for the maximum participation by the local community
in the decision making process.
Officers are currently making arrangements to
hold the special Planning Applications Committee meeting in Waterloo
on 5 March 2002. The exact time of the meeting and the venue are
yet to be decided.
In conclusion Lambeth hopes that the Select
Committee will recognise the positive attitude the Council has
adopted to the SBC's aspirations but will recognise that, as local
planning authority, it has a duty to assess the SBC's planning
applications on their merits. The Council admits responsibility
for some of the delay in processing the SBC's applications but
it is quite wrong for the SBC to say that Lambeth has taken over
two years to deal with a simple, straightforward, non-controversial
application. Problems associated with the recruitment and retention
of staff within Lambeth's Planning Service have had some effect
on the progress of the SBC's planning applications but the nature
and complexity of the applications and the need to resolve issues
of strategic planning importance for the area have been the main
causes of delay. As outlined above both the Foyers Project and
Liner Building applications have proved to be complex and controversial
and officers of Lambeth's Planning Service have worked hard in
an attempt to resolve the planning issues the applications have
raised. The Council hopes that a full and fair consideration of
the proposals will be given at the special Planning Applications
Committee on 5 March.
RESPONSES FROM
THE LOCAL
COMMUNITY AND
HOW THEY
HAVE BEEN
INVOLVED IN
THE DECISION
MAKING PROCESS
As the local planning authority Lambeth has
consulted the local community on the SBC's applications. Nearby
residents in the Whitehouse apartments (the converted Shell downstream
building), nearby commercial businesses and local residents and
amenity groups have been consulted by letter. All those who made
representations on the schemes were invited to attend the Planning
Applications Committee meetings. The level of concern expressed
by the local community was one of the main reasons that Members
of the Committee decided to hold a special meeting in the Waterloo
area on 5 March to consider the RFH applications.
A summary of the representations received in
response to both the Foyers Project and Liner Building applications
is given in Annex 3.
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