Representation made on behalf of Kennington Association
on 14 December 2009, objecting to the draft
Local Development Framework Core Strategy
as "unsound",
because it fails to deal comprehensively with Lambeth's neighbourhoods,
and because it omits reference to Kennington.
Who we are
The Kennington Association is a voluntary membership association of upwards of 430 members drawn from the wider Kennington area, in the north of the Borough of Lambeth, whose aim is to promote and maintain the Kennington area as a good place to live and work. The Kennington Association Planning Forum is a group of Association members with interest in and experience of planning and development issues, that develops planning policies and makes planning representations on behalf of the wider Association. The Association made representations about the previous draft Core Strategy in the consultation round that closed in May 2009, and the Forum meeting on 8 December 2009 authorised me as its Chair to make this representation on its behalf.
Why we make this representation
PPS12 states:
4.1 Every local planning authority should produce a core strategy which includes:
(1) an overall vision which sets out how the area and the places within it should develop; [our emphasis]
Lambeth Council, on its website recognises the variety of neighbourhoods and communities within its area:
“Lambeth by local area
Lambeth is made up of 21 wards. However there are many neighbourhoods and 'urban villages' in the borough, each with its own distinct character.
· Kennington and Oval
· South Bank
· Vauxhall
· Waterloo
Central Lambeth
· Herne Hill
South Lambeth
But in Section 5 of the Draft Core Strategy, the Council makes plain that it does not propose to deal comprehensively with the “people and neighbourhoods” of Lambeth, choosing instead to concentrate on areas of significant growth and change:
“The policies in this section are not intended to cover every part of the borough, focussing instead on areas of significant growth or change. Other parts of the borough not covered by the policies in this section are covered by the strategic policies in section 7.
This is reflected also in its response to May representations, that the Strategy should be made more comprehensive by including coverage of Kennington in this section:
“A separate neighbourhood section for Kennington is not considered necessary. The policies for places and neighbourhoods are not intended to cover every part of the borough but focus on areas of significant change or growth.” [Response to Rep 143 and similarly to Reps 120 and 150].
We say that this “Swiss Cheese” approach to place shaping, in a core strategy intended to have a 15 year time frame is an inadequate response to the challenge of PPS12.
· It privileges growth and change as opposed to conservation (cf the two headed approach to area action plans envisaged in PPS12:
“5.4 Area action plans should be used when there is a need to provide the planning framework for areas where significant change or conservation is needed. Area action plans should:
· deliver planned growth areas;
· stimulate regeneration;
· protect areas particularly sensitive to change;
· resolve conflicting objectives in areas subject to development pressures; or
· focus the delivery of area based regeneration initiatives.
[our emphasis])
· And it leaves “Black Holes” where a plan should be.
This is particularly evident when comparing the approach of Lambeth with that of Southwark, which identifies in its draft Core Strategy all the constituent neighbourhoods which cover its area, and succinctly addresses their character and needs. (Section 4, page 36 of the draft Southwark Core Strategy, attached) By contrast, the Lambeth approach covers perhaps half the area of the borough with its “Peoples and Neighbourhoods” plans, leaving large areas of the borough with no vision or strategy to address its “own distinct character”, save as part of borough wide policies. Kennington is the first black hole from the top! See Lambeth Core Strategy Annotated Key Diagram attached.
The rubric to PPS12 says:
Planning shapes the places where people live and work and the country we live in. It plays a key role in supporting the Government’s wider social, environmental and economic objectives and for sustainable communities.
Try shaping a black hole...
For these reasons we say that the People and Neighbourhoods section of the Strategy is unsound because
· Unjustified – there is ample evidence to sustain and illustrate a comprehensive approach which has not been used
· Ineffective – by omitting a comprehensive neighbourhood analysis Lambeth fails to provide a vision for perhaps half its area, and fails to provide a strategy in those areas for how the needs of development and conservation are to be reconciled
· Contrary to national policy, namely
o PPS12 para 2.1 first bullet
(Spatial planning is a process of place shaping and delivery. It aims to:
§ produce a vision for the future of places that responds to the local challenges and opportunities, and is based on evidence, a sense of local distinctiveness and community derived objectives, within the overall framework of national policy and regional strategies;)
o PPS12 para 4.1
( 4.1 Every local planning authority should produce a core strategy which includes:
(1) an overall vision which sets out how the area and the places within it should develop;
(2) strategic objectives for the area focussing on the key issues to be addressed;
(3) a delivery strategy for achieving these objectives. This should set out how much development is intended to happen where, when, and by what means it will be delivered. Locations for strategic development should be indicated on a key diagram; and
(4) clear arrangements for managing and monitoring the delivery of the strategy.)
o PPS12 para 4.2
(4.2 The vision should be informed by an analysis of the characteristics of the area and its constituent parts and the key issues and challenges facing them. The vision should be in general conformity with the RSS and it should closely relate to any Sustainable Community Strategy for the area )
[our emphasis]
What should be done instead?
Ideally, Lambeth Council should revisit Section 5 with a comprehensive analysis of its constituent communities and their needs, and review the area wide strategies in the rest of the document in the light of the new insights gained. We do not regard policy PN10 as an adequate stopgap until this is done, and with that in mind, for Kennington, we propose an additional policy PN11:
“Given the need to balance conservation and development needs in the wider Kennington area, the Council will develop an Area Action Plan for the area, in consultation with local community interests, that will
§ Analyse the demographics, tenure and employment patterns
§ Address the need to revitalise local shopping areas, cf existing UDP policy 68 for Kennington Cross
§ Address the need for a major improvement in sports and leisure facilities, as contemplated by the “Future Kennington” section of the Lambeth Council website
“Future Kennington – Our vision is to create a community hub at the former Lilian Baylis school site that is inter-generational and inclusive with activities based around sports, health, arts and culture, economic activity community activities, education, childcare and the environment from morning to night. “
§ Give guidance on how the balance should be struck between the needs of conservation, employment, skills improvement and development in the area, and on how there may be maintained a democratic share of amenities, eg
· pedestrian access along the river bank,
· views across the river from the interior of Kennington, not completely screened by riverside tall building development
· integration of affordable housing into adjacent development, rather than the creation of separate “affordable” communities, at the back, in the dark, without the views, with separate entrances”
As a contribution to such a plan, the Kennington Association intends to develop its own vision for the area, as contemplated by PPS12 para 6.2
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