Annex 3
REPRESENTATIONS RECEIVED TO DATE IN RESPONSE TO THE
FOYERS PROJECT AND LINER BUILDING APPLICATIONS—FOYERS PROJECT
(Ref: 00/02263/FUL)
English Heritage raises no objections to this
proposal or the accompanying listed building application subject
to conditions and a schedule of details to be conditioned for
approval.
The Twentieth Century Society raises a number
of objections to this proposal stating: "We agree to some
of the principles . . . such as the clearance of retail areas
from the main first floor foyer level . . . the restoration of
the original three banks of entrance doors at ground level facing
the Hayward together with the internal spaces beyond, the re-opening
of certain terraces at higher levels . . . It is also our view
that the building does need sprucing up—partly due to its
persistent 24-hour over-use—and we welcome in principle
the prospect of money being spent on such an important building
"in our period". The applicant has clarified that the
RFH is not open 24 hours a day but from 10am-11pm.
The Society goes on to identify aspects of the
proposal that it is deeply opposed to, including:
(i) The airport departure lounge philosophy
of squeezing in more retail space wherever possible and that this
should not be the way to finance important cultural and civic
buildings;
(ii) If it is so important to have administrative
space within the building, then the proposed "supermarket"
space on the ground floor should be used thus avoiding the need
to build the damaging liner building;
(iii) Opposed to the loss of the 1960s staircase
linking level one and two and the proposed flooring over the well;
(iv) Against the proposed in-filling and
relocation of the central bar on level two;
(v) The proposed set of stairs linking the
riverside to level two of the building are not adequate and lack
sculptural qualities. They would compare rather poorly with the
many inspired examples found in the building;
(vi) The light fittings between level two
and three are an integral part of the design and therefore should
be retained and maintained regularly to ensure their longevity;
(vii) The proposed RFH frontage would not
offer a suitable replacement as it would essentially be composed
of two uninspired staircases and a row of shops;
(viii) The Society had always presumed that
the refurbishment would be mainly conservation work, and is appalled
to see such a large amount of new interventions, at the detriment
of conservation.
Railtrack identifies a number of comments/conditions
to be observed to safeguard the adjacent railway.
The Theatres' Trust has stated that since the
building is not designated as a theatre it falls outside its remit.
The Waterloo Community Development Group (WCDG)
have made the following objections:
— Application forms part of a wider
proposal including the development of a liner building and service
road on MOL;
— Should be referred to the Mayor;
— The two applications are inextricably
linked and both are shown on the plans;
— The proposal can not be implemented
without the liner building consent;
— Premature to an agreed strategic
plan for the area;
— Should be considered in the context
of an agreed Masterplan;
— Would prejudice the development of
the land between the RFH and the river;
— This will inevitably lead to the
liner building proposal and to development on MOL;
— Would preclude the introduction of
underground servicing;
— An alternative Masterplan exists
promoted by the WCDG that shows that all the arts uses included
in the SBC Masterplan can be accommodated on the SBC site without
development on MOL;
— This application would prevent implementation
of this alternative Masterplan;
— Oppose further extension to the RFH
under the terrace; and
— Large extent of glazing on river
frontage only appropriate for a High Street retail.
Thirteen letters of objection have been received
from local people quoting the reference numbers for both the Foyers
Project application and the Liner Building application. These
comments do not raise any issues in addition to those summarised
above.
Liner Building application (ref: 01/00717/FUL)
CABE welcome the amendments made to this scheme.
CITY OF WESTMINSTER does not wish to comment
on the proposal.
CORPORATION OF LONDON initially raised objections
to the proposal on the grounds that it clipped the Westminster
Pier to St Paul's viewing corridor. Following the removal of an
originally proposed fifth floor these objections were withdrawn.
LONDON AND MIDDLESEX ARCHAEOLOGICAL SOCIETY,
acting on behalf of the CBA raised no objection subject to seeing
the proposals for the Hall itself "as these are the raison
d'etre for the new building". Having now studied the Hall
proposals, they are enthusiastically supportive of the overall
scheme subject to details.
ENGLISH HERITAGE has been closely involved with
the emerging proposals for the regeneration of the South Bank
in general and the refurbishment of RFH in particular. English
Heritage consider that an extension building, such as that now
proposed, has always been regarded as an integral part of those
proposals. English Heritage accepts that a building in this location
may have some impact upon the setting of the RFH and upon views
of it from Jubilee Gardens and Westminster Bridge. However, it
does not consider that the proposed development would damage these
important views. It is considered that the proposed building is
architecturally reticent and subservient in bulk and massing terms,
and that the RFH will continue to be the dominant building. In
terms of the issue of servicing the RFH building from Hungerford
car park, servicing of RFH has always been from the south of the
building and it is difficult to see how else it could be achieved
without causing serious damage either to important internal spaces
or to the setting of the listed building. For these reasons, English
Heritage does not wish to raise any objection to the granting
of planning permission.
EH ARCHAEOLOGY requests that a building assessment
of the water tower building be submitted prior to determination
of the application in order to form a decision on appropriate
mitigation measures.
GREATER LONDON ASSEMBLY supports the approval
of planning permission stating:
" . . . the type and form of the development
and its incremental nature are not ideal as they potentially frustrate
certain elements of emerging strategic aspirations for the wider
area. However, there are a number of factors and benefits, which
to some extent outweigh the wider concerns. The Mayor therefore
supports the approval of planning permission, but requests that
Lambeth Council takes account of the wider aspirations for the
South Bank area and the detailed issues raised in their report
relating to servicing and design matters."
On the issue of servicing, the report acknowledges
that the continued servicing use and widening of the existing
service road on MOL/proposed public open space would impact on
aspirations for extending Jubilee Gardens over the car park and
up to the viaduct. It goes on to state that there are a number
of other factors that need to be considered, including the practicalities
of retaining service access over the Hungerford car park and the
benefits to the public realm on the north side of the viaduct
resulting from the scheme. There is serious concern however, regarding
the size of the service and waiting area. TfL does not feel that
the service access and waiting area is adequate to cope with the
volume of traffic proposed. If the service and waiting area is
full, vehicles will have to wait on Belvedere Road causing potential
obstruction and delays to the riverside bus service due to start
2002. The report concludes that it is therefore possible that
a larger area is required to accommodate waiting vehicles requiring
a larger take of MOL. The applicant is therefore requested to
explore this matter further and ensure that there will be no overspill
of servicing vehicles onto Belvedere Road. One suggested possibility
is the development of a servicing strategy, which avoids peak
hour rushes, perhaps through the provision of night servicing.
The GLA has some concern regarding the architectural
treatment of the southern elevation of the building (facing Hungerford
car park) where the building extends approximately seven metres
above the parapet of the viaduct. The report states: "the
appearance of the liner building from this side is shed like and
potentially could be mistaken for a building associated with the
operation of the railway." The report goes on to say highlight
the visibility of the rooftop from the upper gallery areas within
the RFH and from wider views of the site and suggests "design
opportunities could include providing an extensive green roof
and a vegetated elevation to the railway". Concern is also
expressed about the use of glass and steel panel facades and whether
these contemporary finishes will assist the liner building assuming
the identity of an annex to the RFH.
P&O DEVELOPMENTS support the proposals as
a much-needed enhancement and improvement to the facilities available
in the area.
QUEEN'S WALK PARK SOCIETY are completely opposed
to the planning application, stating:
"The very idea of developing just part
of the total area that awaits redevelopment seems to us completely
bizarre. The arches in question should play an appropriate role
when Jubilee Gardens are finally planned."
"This approach to piecemeal redevelopment
of parts of the South Bank applies to the construction of all
individual buildings. It makes no sense to deal with the total
area by redeveloping isolated bits without it being a part of
the overall (agreed) plan."
ROYAL FESTIVAL HALL/SOUTH BANK ACCESS GROUP
(representing a broad range of different disabilities: physical,
sensory and cognitive) supports these proposals, stating:
"It is the opinion of our group members
that a back-up non-mechanised means of access is essential for,
particularly, wheelchair users in the case of lift breakdown."
"In order to provide ramped access from
the Terrace down to Queen's Walk level, the removal of the present
slip road and access for get-ins to the RFH is essential. If the
slip road remains, the provision of a ramp is impossible. The
repositioning of the servicing route from the present slip road
to Hungerford Bridge car park would have the added advantage of
providing a new public space and ground level pedestrian access
to the west side of RFH. It also removes what is now, potentially
a hazardous approach to the river, with the conflict of pedestrians
and traffic in a dark narrow road and provides instead, a route
that is out of sight and is exclusively for the use of traffic."
Support is also expressed for:
— The use of the building primarily
as office space for RFH/SBC staff thereby allowing the RFH offices
to return to their original public use;
— The buffer effect of the Extension
Building in terms of reducing noise pollution from trains;
— The proposed glass frontage retail
and restaurant units, overlooking the River, which will provide
additional safety for people using the ramp, providing light and
the security of activity within the commercial units.
RAILTRACK states that this scheme depends on
agreement with Railtrack for the long term lease of Railtrack
land adjacent to and under part of the railway viaduct between
Charing Cross and Waterloo East. Railtrack is currently undertaking
discussions with various parties in connection with the proposed
lease, including the applicant's agent. A number of Conditions
are suggested.
THE TWENTIETH CENTURY SOCIETY commented as follows
on the proposals as originally submitted:
"The Committee had reservations about the
height of the building and its proximity to Festival Hall. They
considered that it was unacceptable that a large part of the building
would be visible above the bridge (notably the pavilion), and
that the proposed building would be far too visible at night,
if lit from within. Further to this, the committee felt that the
proposed building was too close to the Hall and would partly block
its eastern elevation. As the hall had been designed as a building
of light, it should receive light from all sides."
"The Committee also had concerns that the
proposals failed to deal satisfactorily with the issue of access
to the footbridge planned for Hungerford Bridge. It was felt that
further careful thought should be given to the way in which the
bridge's spiral access ramps might intersect with the proposed
building." On the amended plans, the Society holds its earlier
views and objects to the proposal.
ASSOCIATION OF WATERLOO GROUPS have stated that
they are concerned about this application being considered "ahead
of strategic planning in the area".
MANOR OF KENT RESIDENTS' ASSOCIATION objects
to the proposal on the same grounds given by the WCDG.
THE PEARMAN STREET RESIDENTS' ASSOCIATION object
strongly to this proposal on the grounds that it would impact
upon designated MOL land. Also, the new building itself would
be built on an existing adequate access road thereby necessitating
the need for a new access road. Objects to the provision of a
turning head on the Queens Walk Riverside Walkway as it would
result in an unacceptable loss of public amenity. Lambeth should
not concede the principle of development on the Hungerford Car
Park.
WATERLOO COMMUNITY DEVELOPMENT GROUP has put
forward its own alternative proposal for the site (as Friends
of Jubilee Gardens). It has raised the following objections:
— It would be premature for the LPA
to approve this application until such time as the South Bank
Masterplan has been completed.
— It is considered that this proposal
is a departure from Policies W18, RL21, RL20, AT4, W33, W32, T40
and W29 of the adopted UDP and should have been advertised on
that basis.
— The use of the site by large servicing
lorries would amount to intensification of the current use as
a car park and therefore a material change of use, requiring planning
permission. Such a change of use would clearly undermine Lambeth's
objective to extend Jubilee Gardens across Hungerford car park,
contrary to Policy W18 and Proposal P1 of the UDP. It is an entirely
insufficient argument for an applicant to seek to build upon their
service road and thereby insist that they should be allowed to
develop a new service road on proposed new public open space.
— The applicant's proposal to place
742m2 of retail development at the western end of the railway
viaduct would entirely block the current coach and disabled access
route to the western entrance of RFH. As a result the applicant
proposes that an area which is part of Jubilee Gardens as identified
in the UDP and outside the boundary identified on the site plan
for this application is used for the parking and turning of six
coaches. The applicant is therefore seeking a change of use of
part of Jubilee Gardens from public open space to coach parking
contrary to Policies RL21 and RL20.
— The proposal to create a turning
head on the Queen's Walk by extending vehicular access from the
service road running between RFH and QEH/HG is contrary to UDP
Policy W33. The proposal to maintain and enlarge that service
road for taxis is contrary to proposals in the Masterplan and
elsewhere to create a major public open space here. The proposal
to allow a "dropping off" point running from Belvedere
Road towards RFH will encroach upon and compromise the objective
identified in the Masterplan of providing a major public open
space at Festival Square.
— The argument that the arts centre
requires ground level servicing routes and parking is entirely
unconvincing. Both the previous Farrell and Rogers' schemes for
the SBC demonstrated that there is ample room under the areas
around the RFH in which servicing roads and parking areas could
be accommodated.
— The use of the arches on the south
side as plant, refuge, storage etc would deter pedestrians from
approaching the arts centre from the public open space. The proposal
would result in a lost opportunity to provide uses for the arches
that complement the use of Jubilee Gardens and HCP as public open
space. The impact of the proposed service road, parking and use
of the viaduct arches upon the amenity of future public open space
would be severe.
— When viewed from the public open
space, the proposed extension building would appear as a second
wall of development above the viaduct and would exacerbate the
sense of impenetrability between the arts centre and the public
open space, and the sense of enclosure within the space. It would
impede views of RFH from Jubilee Gardens and from St Thomas' through
Belvedere Road, and from the Embankment around Westminster Pier,
contrary to Policy W29.
— Whilst the removal of administrative
offices from RFH is admirable since it allows for more arts uses
within the building, it cannot justify the provision of a strip
of office and retail development along the viaduct. The administrative
needs could be catered for elsewhere, either within the SBC's
estate or in the under-occupied Shell Centre, or in other long-vacant
offices in the area. No evidence has been provided that alternative
sites are unavailable or inappropriate. This proposal would provide
38 per cent (526m2) more office space than that currently enjoyed.
No explanation or justification of this expansion is provided.
— The need for ground level routes
and access across the South Bank has been a consistent theme of
the local community for many years. Despite this widely supported
principle, the applicant proposes to exacerbate the fundamental
problem by further restricting ground level access, blocking off
ground level movement between Belvedere Road and the River. As
a result, the disability access provided by the proposal is unconvincing,
in particular the absence of a ramping or methods of vertical
movement from the Belvedere Road to the terrace, other than steps
down to Festival Square.
— The microclimate will worsen as a
result of the corridor created between the new build and RFH,
contrary to Policy AT4.
The COUNTY HALL OWNERS' AND RESIDENTS' ASSOCIATION
(CHORA) endorses the objections to this proposal made by the WCDG.
They also consider that the application is a departure to UDP
policies W18; RL21; RL20; AT4; W33; W32; T40 and W29.
STAMFORD, AQUINAS AND CLIMSLAND HOUSE RESIDENT'S
ASSOCIATION objects to the proposal on the grounds that it would
compromise the ability of the council to create a comprehensive
plan to redevelop the South Bank and also because of its impact
on MOL land. The proposal would create a dead area beneath Hungerford
Bridge and the height of the extension building would be intrusive
from the River Thames.
WHITEHOUSE RESIDENTS' ASSOCIATION has indicated
that it objects to the proposal on the same grounds given by the
WCDG.
The executors of the late FELIKS TOPOLSKI'S
ESTATE are concerned that the proposals pose a threat to the artist's
studio, housed in arch 158, which has an historic relationship
with, and has been a major cultural feature of the South Bank
Arts Centre since 1953.
GUY'S AND ST THOMAS' HOSPITAL is generally supportive
of this application. It requests that:
the Disability Discrimination Act 1995 is met
in all relevant areas;
— Any impact on York Road and the route
from Waterloo Station to St Thomas' Hospital, particularly during
the construction stage is not made worse during or after the development
process.
— In a second letter the Trust has
expressed concern about this proposal on the grounds that a number
of their patients have indicated that it involved development
on Jubilee Gardens.
LOCAL RESIDENTS—A total of 37 letters
have been received from 34 local residents. Residents have objected
principally on the grounds of prematurity and impact on MOL land,
identifying the MOL status of Hungerford car park and the desire
to extend Jubilee Gardens over the car park. Other objections
have been raised in terms of the height and design of the extension
building, loss of views, compromising the integrity of the listed
building, access restrictions to the RFH at ground level and restriction
of the movement and flow of pedestrians, and increases in traffic
along Belvedere Road resulting from the development.
Kate Hoey MP has objected to these proposals
on the grounds that the applications are being put forward in
advance of consideration of the whole scheme. She is concerned
that the granting of planning permission would seriously jeopardise
alternative proposals, particularly the alternative proposal put
forward by the Friends of Jubilee Gardens.
1 February 2002
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