24/02771/FUL

The proposed development would materially harm the future vitality and viability of the Clapham Park Hill Key Industrial and Business Area, which amongst other things aims to protect land in Class E g uses usually associated with industrial areas such as builders' yards, haulage, employment-training, bus garages and telecommunications. The residential intensification of the site and loss of any additional industrial floorspace and/or land would essentially end any prospects of industrial intensification of this site and future viability, which still remains a feasible option at this time. The Clapham Park Hill KIBA continues to be viable prospect to help provide and Lambeth's strategic supply of business, industrial, and storage functions and therefore very limited weight is given to the residential development that has occurred within the KIBA. The proposals are thereby contrary to the stated aims and objectives of Policy ED3 of the Lambeth Local Plan (2021) and Policies E4, E6 and E7 of the London Plan (2021).

Insufficient and inadequate viability information has been submitted and therefore the proposed development has failed to demonstrate that the quantum proposed is the maximum reasonable provision of on-site affordable housing the development can deliver. This is contrary to Policies D4 and H2 of the Lambeth Local Plan (2021), H4 and H5 of the London Plan (2021), Lambeth's Development Viability SPD (2018), the Mayor's Affordable Housing and Viability SPG (2017) and Lambeth's SHMA (2017).

The proposed development does not provide a policy compliant range of dwelling sizes and types for both the market and affordable housing element of the proposal and does not provide a preferred tenure split of affordable units. The Council would require a better range of types and sizes of units in accordance with adopted policies, particularly in terms of the affordable housing element. The proposal would therefore fail to meet current and future housing needs that are necessary for creating mixed and balanced communities, which is contrary to Policy H4 of the Lambeth Local Plan (2021) and Policy H6 of the London Plan (2021) and Lambeth's SHMA (2017).

The proposed five-storey building (Block C), by reason of its height, scale and massing would fail to remain subordinate in its backland context, would fail to provide a positive response to the prevailing local character, and would represent an over-intensification and over-development on the site. The proposal is contrary to Policies Q5, Q6, Q7, and Q14 of the Lambeth Local Plan (2021).

The proposed five-storey building (Block C), by reason of its siting, scale and massing would result in an overbearing and unneighbourly form of development that would result in undue loss of residential amenity for the occupiers of neighbouring property, namely the residential units of no. 146 Clapham Park Road (known as St. Pauls Court) in terms of loss of privacy and outlook. Furthermore, the proposal would be overly dominant and fail to maintain the visual amenity of the area. The proposal would be contrary Policies Q2, Q5 and Q7 of the Lambeth Local Plan (2021).

The proposed development would provide substandard residential accommodation which would be to the detriment of the amenities of future residents. This is due to, the lack of adequate communal amenity space to serve the proposed units and the loss of existing communal amenity space to serve the units within 3 Park Hill: lack of private amenity space for some of the units (Block E) and compromised privacy and poor outlook (bedrooms) for some of the units within the proposed five-storey building (Block C). The proposal is therefore considered to be contrary to Policies H5, Q2 and Q14 of the Lambeth Local Plan (2021), D6 of the London Plan and the London Plan Housing SPG (2016).

The proposed development falls within an area of open space deficiency, where all major developments should seek to alleviate these deficiencies. The proposed development would not provide an appropriate provision of on-site and would therefore fail to alleviate open space deficiencies within the area. The proposal would be contrary to EN1 of the Lambeth Local Plan (2021) and the Lambeth Open Spaces Strategy (2013).

In the absence of a Unilateral Undertaking or other legal agreement securing appropriate mitigation by restricting future occupiers of the development from obtaining parking permits within the Controlled Parking Zone and providing car and cycle club membership along with a contribution towards Healthy Routes, the proposed development would likely exacerbate existing parking stress and congestion on the surrounding highway network. The application is therefore contrary to Policies D4, T1, T2, T3, T4 and T6 of the Lambeth Local Plan (2021).

Insufficient and inadequate highways information has been submitted to allow officers to make a full assessment of the proposed development. This includes the need for an updated Transport Assessment and further information regarding pedestrian access, pedestrian visibility, emergency service access, revised TRICS generation, Trip generation for commercial vehicles, parking surveys, cycle parking, disabled parking, electric charging points, refuse storage, delivery and servicing, revised swept path for refuse vehicles, drag distances and a draft Construction Management Plan. As such, the proposals are thereby unacceptable and prejudicial to highways safety and the safe and free flow of traffic, including the needs of pedestrians and cyclists. The proposals are thereby contrary to policies T1, T2, T3, T4, T6 and T7 of the Lambeth Local Plan (2021) and T1, T2, T3, T4, T5, T6, T7 and D12 of the London Plan (2021).

In the absence of an adequate energy strategy to illustrate how the scheme would meet the requirements of the energy and sustainability targets as set out in the London Plan; and in absence of a S106 agreement to provide a carbon offset contribution (if required), it has not demonstrated that the proposal minimise carbon dioxide emissions or meet the zero-carbon target for major residential developments. Therefore, the proposed development is contrary to Policies EN4 and D4 of the Lambeth Local Plan (2021) and Policy SI 2 of London Plan (2021).

In the absence of a S106 agreement to secure an Employment and Skills Plan for the construction phase of the development, and also to secure a payment towards an employment and skills training, the proposals would fail to provide the opportunities for local residents to benefit from new development in the Borough, and would fail to comply with Policies D4 and ED15 of the Lambeth Local Plan (2021), and the Employment and Skills SPD (2018).

The proposed erection of Block D and subsequent loss of garden land serving the existing flatted units at no. 3 Park Hill by virtue of its bulk, siting and design would fail to retain subordinance in terms of height and scale and would give rise to an unacceptable loss of amenities to neighbouring occupiers and thereby represent an incongruous and cramped form of development. The principle for loss of such garden land development is therefore contrary to the objectives outlined within policy Q14 of the LLP (2021).