Lambeth Core Strategy

Lambeth’s New Core Strategy

Note by the Kennington Association Planning Forum

1 February 2011

Background

1 The Lambeth Core Strategy was adopted on 19 January 2011 by Lambeth Council, following an Examination in Public before an independent Planning Inspector on four days in September 2010. The report of the Inspector found the strategy to be basically sound, and adoption now paves the way for further consultation on two daughter documents, which fill in more detail, within the framework set by the Strategy. These are the Development Management Document (DMD) and the Site Allocation Document (SAD). At present it is expected that these will be issued for consultation in parallel around April 2011, and be submitted later in the year for Examination in Public before a Planning Inspector at a combined hearing. As it took six months from submission to examination for the Core Strategy itself (March to September 2010) and a further four months from examination to adoption (September 2010 to January 2011), we shall be lucky if we see the completion of this process before the end of 2011.

Substance

2 The Inspector’s report reviewed the submitted Strategy under seven headings, which matched the key themes explored at the Examination. These were

·         Issue 1 –Does the overall strategy appropriately address the vision for the whole borough, across the entire plan period, in relation to other plans and strategies and is it consistent with national planning guidance? – essentially yes, says the Inspector; agreed that parts of the borough are not covered by specific policies, but “The fact that parts of the borough are not covered by PN policies or diagrams does not imply that they have been overlooked. On the contrary it reflects that they are more stable places where the scale of any development is such that it can be managed... through the CS strategic policies and through lower level DPDs and SPDs” (paras 10 to 17, especially para 11). This was one of Kennington’s key criticisms of the Strategy, and it remains to be seen how “stable” the environment will be as the Council prepares to sell off many of its key sites for development.

·         Issue 2 – Does the CS make appropriate provision for the supply of housing for the plan period and is its approach to house conversions and affordable housing justified? – supply OK, house conversion policy limitations (not allowed in stressed streets) not prejudicial to achieving targets, address issue of methodology for assessing viability of affordable housing at the DMD stage. (paras 18 to 30)  This was another of Kennington’s issues, and we want a post implementation review of methodology assumptions written into policy.

·         Issue 3 – Does the CS make sound provision for economic development, particularly in terms of the Key Industrial and Business Areas (KIBAs)? – Inspector finds strong demand and limited availability (para 33), but endorses Lambeth’s approach (de-designation of Bondway KIBA to facilitate VNEB OAPF, retention of Southbank House and Newport St KIBA). And note a subtlety: withdrawing KIBA designation reactivates, at least till adoption of site specific guidance in the SAD, an arguably more stringent residual provision (Policy 23 of the otherwise superseded 2007 UDP) protecting employment floor space everywhere outside KIBAs (paras 31 to 41)

·         Issue 4 –Is the CS approach to Metropolitan Open Land sound? – “bolder and more proactive” than the previous plans, says the Inspector of the Strategy’s willingness to de-designate part of the Hungerford Road car park before plans for a cultural facility on it are cut and dried, and she finds this sound.(paras 42 to 45) Our Waterloo colleagues thought this risky and the treatment a deal too summary.

·         Issue 5 – Does the CS provide a sound basis for the scale and location of tall buildings, having in mind the need to protect strategic views and heritage assets?- supporting work is fragmented, especially at Vauxhall, and there needs to be further urban design assessment, as the Strategy policy S9(d) contemplates. But the overall Strategy is sound, says the Inspector (paras 46 to 50). We beg to differ: in our view the failure to adopt the draft 2008 SPD for Vauxhall and finalise and endorse the BDP design study of 2009 gives the Planning Committee far too little to work with in opposing over dense “cluster” development at Vauxhall, in an area of open space deficiency.

·         Issue 6 –Does the CS provide a sound and effective strategy for meeting requirements for open space? – “setting a target for the provision of new open space would be unrealistic in an inner London borough where land prices are high and land is subject to many competing demands.” says the Inspector. Lambeth’s approach has yielded some new provision, but addressing improvements to the quantity, quality and access to open space should be part of the DMD (one of the rare changes to the Core Strategy coming out of the Examination) (paras 51 to 53)

·         Issue 7 – Does the CS provide a sound framework for infrastructure,

delivery and monitoring? – broadly yes, says the Inspector, with some minor tidying up language changes and a few new targets to monitor (paras 54 to 57).

Process

3 As we said at the wash up session with the Inspector, it was, in our view, an excessively legalistic process to get to the table (had you made an objection expressly impugning the “soundness” of the policy under discussion that day by the due date) and we had had to contemplate legal action at one stage before a broader view was taken of who could speak. You had to formulate any criticism or suggestions for improvement as an impeachment, as “unsound”, policies that had taken Lambeth planners years to bring to the table.  While it may have focused debate at the Examination, it introduced an unnecessarily adversarial tone into the debate between the Council planners and other parties. For whatever reason, there were only two community groups represented (ourselves and waterloo Community Development Group), but lots of developers. We think the process would have benefited by inviting other amenity groups to the table.

4 But once we were at the table, the formulation of questions by the Inspector, and the focused but reasonably informal style of discussion, made for a realistic probing of the issues, and although the whole process took barely four days, we left the proceedings with a sense that we had been given a fair crack of the whip, even if we differed over the conclusions reached. It is fair to note, however, that our Waterloo colleagues, who have a deal more experience at such affairs than we do, thought the discussion much more truncated than those they had taken part in at the equivalent Examination on the Southwark Core Strategy,  or on the draft replacement London Plan

Follow up

5 The Head of Planning at Lambeth, Les Brown, has offered us at KA a meeting to review any lessons we can learn from the process of consultation on, and examination and adoption of the Core Strategy. If other colleagues think it helpful, we might suggest a wider participation, to include interested amenity societies who might usefully have taken a larger part in the process.

David Boardman

Chair

Kennington Association Planning Forum

1 February 2011