CABINET

Date: Monday 13 December 2021

Time: 5.00 pm

Venue: Committee Members Town Hall / Others to dial in via MS Teams*

*In line with legislation and continuing Covid-19 precautions, committee members will attend the meeting

in person at Lambeth Town Hall, with members of the public and press, visiting members and officers

invited to attend virtually. Instructions overleaf.

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the Lambeth website. www.lambeth.gov.uk/moderngov

Members of the Committee

Leader of the Council, Councillor Claire Holland

Deputy Leader of the Council (Jobs, Skills and Community Safety), Councillor Jacqui Dyer

Deputy Leader of the Council (Planning, Investment and New Homes), Councillor Matthew Bennett

Cabinet Member for Sustainable Transport, Environment and Clean Air (job share), Councillor Mahamed

Hashi and Councillor Danny Adilypour*

Cabinet Member for Housing and Homelessness, Councillor Maria Kay

Cabinet Member for Finance and Performance, Councillor Andy Wilson

Cabinet Member for Children and Young People, Councillor Ed Davie

Cabinet Member for Health and Social Care (job share), Councillor Councillor Lucy Caldicott and Jim

Dickson*

Cabinet Member for Equalities and Culture, Councillor Sonia Winifred

Cabinet Member for Voluntary Sector and Leisure, Councillor Donatus Anyanwu

*non-voting

Further Information

If you require any further information or have any queries please contact:

Sarah Keeble, Telephone: 020 7296 4385; Email: skeeble@lambeth.gov.uk

Published on: Friday 3 December 2021

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AGENDA

Page

Nos.

1 Declarations of Pecuniary Interest

Under Cabinet Rule 1.5.2, where any Cabinet Member has a Disclosable Pecuniary Interest (as defined in the Members’ Code of Conduct (para. 4)) in any matter to be considered at a meeting of the Council, a committee, sub-committee or joint committee, they must withdraw from the meeting room during the whole of the consideration of that matter and must not participate in any vote on that matter unless a dispensation has been obtained from the Monitoring Officer.

2 Minutes of Previous Meeting

1 - 4

Cabinet is asked to confirm as a true record the Minutes of the previous meeting of Cabinet held on 22 November and to authorise the Leader to sign them.

3 Response to the Independent Inquiry into Child Sexual Abuse

(IICSA): Lambeth Council’s Action Plan

5 - 68

4 December Finance Planning and Medium Term Strategy Report

2021 to 2026

69 - 86

5 Responsible Procurement Policy 2021-2024

87 - 112

6 Regulation 18 draft Site Allocations Development Plan

Document

113 - 346

This page is intentionally left blank

CABINET MINUTES

Monday 22 November 2021 at 5.00 pm Committee Room (B6) - Lambeth Town Hall, Brixton, London, SW2 1RW

Present:

Cabinet Member: Portfolio:

Councillor Claire Holland Leader of the Council

Councillor Danial Adilypour

Cabinet Member for Sustainable Transport, Environment and Clean Air (job-share)

Councillor Donatus Anyanwu

Cabinet Member for Voluntary Sector and Leisure

Councillor Edward Davie Cabinet Member for Children and Young People

Councillor Jim Dickson Cabinet Member for Health and Social Care (job-share)

Councillor Dr. Mahamed Hashi *

Cabinet Member for Sustainable Transport, Environment and Clean Air (job-share)

Councillor Maria Kay Cabinet Member for Housing and Homelessness

Councillor Sonia Winifred Cabinet Member for Equalities and Culture

Apologies for absence Councillor Matthew Bennett, Councillor Lucy Caldicott, Councillor Jacqui Dyer and Councillor Andy Wilson

Also present: Bayo Dosunmu, Wayne Chandai and Sarah Keeble

Also present online: Councillor Mary Atkins

*non-voting

1 Declarations of Pecuniary Interest

There were none.

2 Minutes of Previous Meetings

The Minutes of the previous meetings of Cabinet held on 13 September and 4 October were agreed as a true record and signed by the Leader.

Page 1 Agenda Item 2

3 Air Quality Vision for Lambeth

The report was introduced by Councillor Adilypour, Cabinet Member for Sustainable Transport, Environment and Clean Air who highlighted that:

Air quality in Lambeth had improved significantly over recent years

The levels of air pollution throughout the Borough may be legal but not safe

The Air Quality Vision would set out a number of ambitious targets to shape the Borough

Work would be done to educate and inform residents and communities on how they may take action on air quality themselves.

Cabinet was addressed by Councillor Peter Elliott of the Green Group, who highlighted a number of questions surrounding:

The programme of rolling out air quality monitors

Whether the data collected by developers could be made public. In response to some of the questions and comments raised, Officers and the Cabinet Member advised the following:

Lightweight air quality monitors had been installed across the Borough

Next month it had been planned for an air quality monitoring station to be fitted which will ensure data was clarifiable

Services were being developed and expanded to ensure live data can be shared and published, increasing capability and ease of use by residents

Planning Permission had been applied to developers to ensure emissions are monitored

Discussions would be had going forward to see what could be done in terms of having data made public from developers

Cabinet made the following observations:

The report detailed a lot of data around the effects of poor air quality on children

There was a lot of community support on these issues, including residents using sustainable transport options such as walking and cycling

A number of schools had adopted air quality monitors which showed reduced levels of pollution around their cycle paths

It would be optimal for all schools to be able to monitor their air quality. In response to some of the comments raised, Officers and the Cabinet Member advised the following:

A number of interventions and workshops would be presented to schools offering opportunities to learn about climate change

Discussions were being had with different groups across the Council to obtain recommendations as to where air quality monitors would be best placed

Communities and areas that were particularly impacted would be prioritised (e.g. Schools and care homes)

It was important to recognise the positive impact policies have had on air quality e.g. Bus electrification and the Ultra Low Emission Zone.

Page 2

Following consideration, Cabinet resolved: 1. To approve and adopt the Air Quality Vision for Lambeth

4 Low Traffic Neighbourhoods Scrutiny Commission

The report was introduced by Councillor Adilypour, Cabinet Member for Sustainable Transport, Environment and Clean Air who highlighted that:

Lambeth was the first Borough to publish a Low Traffic Neighbourhood Strategy

Significant resources had been invested in monitoring and equalities analysis

The Action Plan contained a clear response from the Overview and Scrutiny Commission.

Cabinet was addressed by Councillor Mary Atkins, Chair of the LTN Scrutiny Commission, who raised a number of points including that:

The Scrutiny Commission gave its thanks for Cabinet’s approval of the report

One of the main focuses was around how a change could be made which would take residents with it

The importance of using evidence form trusted sources had been recognised, and that external monitoring was seen as reliable

It was important for residents to feel that the LTN report was a trusted document inclusive and available to all

It was also necessary for it to be accessible, with consideration given to language used, as to not exclude any party or community group.

Cabinet made the following observations:

The report was thorough, and Officers and Members had done a commendable job on the LTN and the Scrutiny Commission

Some communities were not able to access the online consultation response form; accessibility must be considered going forwards

All communities would need to be engaged with in future, so they do not feel left behind.

In response to some of the questions and comments raised, Officers and the Cabinet Member advised the following:

Lambeth recently hosted an event which covered digital inclusion, and further work was ongoing with a number of the Council’s partners

With Covid restrictions having eased, the Engagement team ran street stalls over the last consultation period to enable those unable to access online the chance to respond

EIA panel feedback had been heard and taken on board

The Council would continue to offer face-to-face ways of responding. Following consideration, Cabinet resolved: 1. To approve the Low Traffic Neighbourhoods Scrutiny Commission action plan response, attached at Appendix 1, subject to any comments from Members.

Page 3

The meeting ended at 5.51 pm

Councillor Claire Holland CHAIR, CABINET

Monday 13 December 2021 Date of Despatch: Friday 26 November 2021 Call-in Date: Friday 3 December 2021 Contact for Enquiries: Sarah Keeble Tel: 020 7296 4385 E-mail: skeeble@lambeth.gov.uk Web: www.lambeth.gov.uk

Page 4

CHILDREN’S SERVICES SCRUTINY SUB-COMMITTEE 07 DECEMBER 2021

CABINET 13 DECEMBER 2021

FULL COUNCIL 15 DECEMBER 2021

Report title: Response to the Independent Inquiry into Child Sexual Abuse (IICSA):

Lambeth Council IICSA Action Plan

Wards: All

Portfolio: Leader of the Council, Councillor Claire Holland

Report Authorised by: Andrew Travers, Chief Executive

Contact for enquiries: Merlin Joseph, Strategic Director for Children’s Services

mjoseph@lambeth.gov.uk

REPORT SUMMARY

The national Independent Inquiry into Child Sexual Abuse published its investigation report into Children

in the care of Lambeth Council on 27 July 2021. The investigation examined the scale and nature of

sexual abuse experienced by children in the former care of Lambeth Council over several decades

spanning the 1960s to the 1990s, and the extent of institutional failures to protect children in care from

sexual abuse and exploitation.

The Inquiry made three recommendations for Lambeth based on the Panel’s findings, the first being that

Lambeth should develop and publish a comprehensive action plan within six months which details the

actions that it will take in response to the issues raised throughout the Inquiry’s investigation report,

accompanied by timescales for completing identified actions as soon as possible.

This report requests the review and approval of the Lambeth Council IICSA Action Plan, in response to

the Inquiry’s recommendation.

FINANCE SUMMARY

The necessary resources to support delivery and programme manage the oversight, assurance and

monitoring of the Action Plan and to commission external services for peer review and research have

been assessed and allocated up to £500,000, with funding available from the budget originally set up to

manage the Council’s response to the Inquiry.

RECOMMENDATIONS

Children’s Services Scrutiny Sub-Committee

1. That the Children’s Services Scrutiny Sub-Committee review the draft Lambeth IICSA Action Plan,

made in response to the Inquiry’s Children in the Care of Lambeth Council investigation report

dated 27 July 2021 and provide challenge and feedback.

Page 5 Agenda Item 3

Cabinet

1. That Cabinet agree that the Lambeth IICSA Action Plan, made in response to the Inquiry’s Children

in the Care of Lambeth Council investigation report dated 27 July 2021, be formulated and prepared

in the form presented to Cabinet with this report.

Council

1. That Full Council resolve to take the decision itself as to whether to approve and adopt the IICSA

Action Plan made in the form presented to Full Council with this report.

2. That Full Council approve and adopt the IICSA Action Plan in the form presented to it with this

report.

Page 6

1. CONTEXT

1.1 In March 2015, the Home Secretary established the Independent Inquiry into Child Sexual Abuse

(‘IICSA’). In June 2015 the Inquiry identified Lambeth Council as one of three local authorities and

other organisations, including the Roman Catholic Church and the Anglican Church, for

investigation into the extent to which State and non-State institutions have failed in their duty of

care to protect children from sexual abuse and exploitation

1.2 The Inquiry investigated the circumstances of children in the care of Lambeth placed in its

children’s homes and foster care during several decades. Lambeth has accepted that it is clear

that the council of the past failed to keep children – with whose care it had been entrusted - safe

from abuse and neglect. The extent and scale of the abuse, which took place over many decades

remains deeply shocking. Lambeth has also accepted responsibility for creating conditions in

which adults were able to sexually abuse children in Lambeth’s care with apparent impunity.

1.3 In July 2015 the Shirley Oaks Survivors Association addressed the Council to highlight the

appalling treatment and the experiences of their many members as children placed in Lambeth

children’s homes. Without the courage victims and survivors have shown in coming forward to

share their experiences, the Council of today would not have been able to fully understand the

breadth, depth and long-standing nature of its failures to protect children in its care.

Public apologies

1.4 It is difficult to find adequate language to express a suitable apology to those affected. Since July

2015, successive Leaders of the Council have issued public apologies including the current Leader

of the Council Councillor Claire Holland on 27 July 2021 and at Full Council on 22 September

2021:

“On behalf of all elected Members and staff, Lambeth Council wishes to re-state our

sincere and heartfelt apology to all victims and survivors of abuse and neglect while in

Lambeth’s care. The council was responsible for their care and protection but failed, with

profound consequences. The council is deeply sorry for their experiences.

As the IICSA Report sets out, the council of the past failed to protect many of its most

vulnerable children. A disproportionate number of those children were from Black, Asian

and Multi-Ethnic backgrounds. The extent and scale of the horrendous abuse, which took

place over many decades, remains deeply shocking.

The council failed to acknowledge concerns when they arose, often failed to believe

children when they disclosed abuse and then failed to take effective action. That so many

children and adults were not believed compounded their experiences and caused further

pain and distress with lifelong impacts. The council takes responsibility for contributing to

conditions in which adults were able to abuse with apparent impunity.

The council has co-operated fully and transparently with IICSA, in order to understand what

happened to the children in our care and examine the institutional failings; and to reflect

and learn from the findings to ensure such events never happen again ”

1.5 The council’s corporate witness (Annie Hudson former Strategic Director of Children’s Services)

also set out Lambeth’s corporate apology in her witness statement dated 9 December 2019:

“On behalf of Lambeth Council, I apologise unreservedly to all those former children in the care of

the Council who were failed so badly by the Council. The Council was entrusted with the care of

the most vulnerable children in our society and those who experienced harm and abuse whilst in

Page 7

the care of the Council were failed by Lambeth. This has led to generations of survivors who have

spent many years living with the consequences of that harm and abuse and who experienced

great trauma and distress. It is not possible to undo the mistakes of the past but we must learn,

and have learned, from this. Lambeth Council acknowledges that it failed in its responsibility to

protect children in its care. It is clear that some Lambeth homes became places where there was

systematic failure by the Council to safeguard children in its care and who, as a result, were placed

in harm’s way and abused. I also wish to acknowledge the courage survivors have shown in

coming forward to share their experiences. I am profoundly sorry that some survivors were not

believed in the past. The Council has taken a number of steps in order to address this failure to

acknowledge the experiences of those in its care and to apologise to the survivors and victims of

abuse.”

1.6 At the start of her evidence to the hearing on 2 July 2020, Ms Hudson reiterated the council’s

corporate apology and went on to say:

“It's my absolute belief that children in care are entitled, as all children are, to a life where they can

grow up happy, in loving homes, free from any worry or fear of, or reality of, harm; where they can

pursue their dreams and ambitions. It is clear to me that a very, very great number of children

effectively had their childhoods stolen as a consequence of the abuse, the racist abuse, the

emotional abuse, the sexual abuse, the physical abuse and the general neglect of them and their

lives during a very long period of time. I am really, really sorry for what happened to those children.

I recognise that Lambeth's betrayal of them is very profound and was very prolonged, and the

failures are on many different levels. There was clearly an absolute failure to make sure that the

conditions in which they were growing up enabled them to be safe and feel safe from harm.

Instead, the council created and oversaw conditions in care where appalling and absolutely

shocking and horrendous abuse was perpetrated. So that, rather than living in safe homes, safe

environments, children were placed in toxic environments where they lived in constant fear, and

they could not have the ordinary life that every child needs -- the right to a good education, the

right to have contact with families, brothers and sisters.

Even when they did speak out, and when concerns were expressed, they were disbelieved, their

voices were silenced, there was distraction from what they were saying. Then we failed also to

give them the support and help that children and adults need to recover from the trauma of abuse,

and that, too, I think, was a very profound dereliction of our responsibilities to you, to the survivors.

Finally, and very importantly, people in power and authority were just not vigilant. They weren't

sufficiently vigilant about what was happening in children's homes, and they didn't take

responsibility for making sure that, even when concerns and issues were highlighted, there was

deep-seated change that was required.

I have been proud to be a social worker for 40 years, but I feel an enormous sense of shame about

what happened in Lambeth to so very, very many children, and the learning for me, and for

Lambeth, has been, and will be, hard, but I think it's really important that this inquiry provides the

opportunity for the truth of what happened to be told and for some measure of justice.”

1.7 Councillor Edward Davie, in his role as Lead Member for Children’s Services, apologised on behalf

of all current Members when he gave evidence to the hearing on 29 July 2020.

“As I am the only current elected Member to give evidence to this inquiry, I would like to add to

Lambeth Council's corporate witness Annie Hudson's apology on behalf of myself and all of my

elected member colleagues. The leader of the council, Councillor Hopkins, and his immediate

Page 8

predecessor, Councillor Peck, have both previously said how sorry they are to victims of the

council's failings, and I add my heartfelt apology to their words. But I, and we, recognise that words

alone are inadequate. Lambeth's motto is, "Judge us by our actions", and this inquiry has heard

from brave witnesses about terrible criminal actions by people in Lambeth Council's employment.

We have also heard about inaction as, time and time again, children tried to raise concerns an

recommendations from previous inquiries were not acted upon by this council. These failures

meant that many children were sexually, physically and emotionally abused, with devastating and

lifelong impacts, as we have heard from the brave testimony of the witnesses to this inquiry. Often

this abuse was compounded by antiblack racist abuse, which is a source of more shame for those

of us, including myself, who love Lambeth's multiculturalism, and our status as the Windrush

borough, where many black Caribbean people settled after World War II to help this country rebuild

its infrastructure.

We must never be complacent, and our children's services still require a lot more action to get

them where our children deserve them to be. You have my word, as statutory lead Member for

Children's Services, the Leader of the council and all Members of this council, that we will continue

to take further action, including any recommendations that this inquiry chooses to make, to

safeguard the children in our care and support victims of the failures of past administrations.”

Inquiry process and public hearings

1.8 The IICSA inquiry was an important opportunity to explore those past failings, and to ensure that

children in the care of the Council now and in the future do not experience abuse and neglect. It

also provides an opportunity to learn from the past and shape how institutions respond to and

support victims and survivors of abuse now and in the future. The council has been involved in a

number of historical inquiries and has been rightly criticised in the past for failing to act in response

to allegations of child abuse. The council has not undertaken its own independent inquiry or fact-

finding investigation given the remit of the Inquiry. The council decided against commissioning its

own investigation as independent scrutiny from a national Inquiry would give more confidence to

victims and survivors of abuse in the investigation, findings and recommendations.

1.9 The approach Lambeth has adopted throughout the inquiry’s investigation is one of transparency,

openness and accountability. The council has co-operated fully with the Inquiry and reviewed a

vast body of historical documentation so as to understand and identify the cause of the failures, in

particular of political and organisational leadership and governance which led to the widespread

failures to safeguard children in its former care. The council collated and disclosed over 300,000

pages of historical material to the Inquiry and submitted over 1,000 pages of corporate witness

statements setting out its own analysis and understanding of those historical failings to the Inquiry.

1.10 By the time of the five-week public hearing in June and July of 2020, there were 55

complainant/survivor Core Participants, 5 individual core participants such as former Councillors or

employees, and 5 institutional core participants (Lambeth Council, the Metropolitan Police Service,

Crown Prosecution Service, Independent Office for Police Conduct and the Department for

Education).

1.11 The hearing focused on children living in residential care and foster homes with the focus narrowed

through the use of case study homes and children selected by IICSA. The evidence presented

considered the experiences of victims and survivors and examined the scale and nature of the

abuse that took place under Lambeth’s care and sought to explore whether there were child

protection failures by the Council, the police and other public authorities. There was also

consideration of the extent to which particular vulnerabilities of any children who were subject to

Page 9

sexual abuse put them at risk and whether this may have shaped how public authorities responded

to these children and their disclosures.

1.12 Evidence was given by both victims and survivors of abuse, professionals involved at the time and

other professionals in considering current practice. Witnesses included former Leaders of the

Council, Chief Executives, Directors of Social Services and Chairs of the Social Services

Committee. A number of persons of interest and expert witnesses were also called.

1.13 A number of victims and survivors gave direct testimony at various stages throughout the hearing

as well as witness statements for other victims and survivors being read during the hearing. Many

of these survivors and victims had lived at Shirley Oaks and been resident at other children’s

homes (for example, South Vale and Angell Road) or had been fostered. Their testimonies were

all very powerful, poignant and very painful; they all, without any exception, brought into sharp and

vivid relief what it was like to be a child in care living in Lambeth’s children’s homes which were

open from the 1960s to 1990s.

1.14 IICSA is, explicitly and appropriately, very focussed on the experience of survivors and victims.

During their individual testimonies victims and survivors articulated powerfully and with enormous

courage what had happened to them; in so doing they communicated the myriad ways in which

their voices, needs and horrendous experiences of abuse and neglect were wholly and absolutely

ignored and denied. Their testimonies evidenced the shocking and often repeated ways in which

children were sexually abused by those in whom they should have been able to place their trust;

they also demonstrated how staff, managers, senior officers and elected members consistently and

perpetually refused to face the horrific but undoubted reality of children being sexually abused

when in the care of Lambeth. It was very clear that over many years there was institutional denial,

disbelief, and deflection from what was happening to children, including when there was

unambiguous evidence that children were being abused. There was stark evidence of the

disproportionate impact on Black children in care due to racism and that many Black children in

care and their families did not receive the quality of service and support that their needs

required. This was a failing on the part of the Council that would have compounded the multiple

disadvantages that they already faced, which would have had had a profoundly negative impact

upon these children

1.15 Importantly, many victims and survivors expressed very clear and valuable suggestions about how

practice could improve to ensure that children never again endure what they had experienced.

Whilst some of the events described by survivors took place decades ago, they highlight the

continued and absolute imperative of believing children and of positively creating different avenues

and mechanisms for enabling children to talk about what is happening to them. Victims and

survivors spoke of the way that the ‘stigma’ of being in care continuously invalidated their voices

and accounts of abuse. The eloquence of victims and survivors reinforced once again how very

important it is that children and young people participate and contribute to all the decisions

affecting them.

1.16 Survivors highlighted how crucial it is to create an environment in which children are, and feel,

empowered to speak openly about what is happening to them. It was understandably often very

difficult then, as now, for children looked after to be open about their experiences, particularly when

abuse and exploitation was involved. Survivors too rarely had positive relationships of trust with

professionals, thus making it even more difficult for them to disclose what was happening to them.

There were a few notable exceptions to this; for example, when an individual social worker

believed what children were saying. In the main, however, when concerns were expressed by

children, they were disregarded and disbelieved because the prevailing professional culture and

systems in Lambeth were not absolutely focused on listening to and believing children.

Page 10

1.17 The Inquiry Panel analysed the great volumes of evidence that they gathered and testimonies,

particularly from survivors and victims, core participants (including Lambeth Council) and from

other witnesses, including those who were previously employed by or elected members of

Lambeth Council during the period under investigation.

1.18 Within the evidence submitted to the Inquiry by the Council, which included the very lengthy

corporate statement and supplementary case study statements, the Council was clear and

unambiguous about a range of very significant failures based on its own analysis of the historical

materials.

1.19 The corporate statement also provided an analysis of Lambeth Council today, providing evidence

about the improvements that have been secured but also highlighting how the wider policy and

legislative framework has changed since the period examined by the Inquiry. The Council was

also clear in various statements about the work that the Council had done to address historical

failures and weaknesses, recognising that we can never be complacent and that there is much

further improvement work to undertake. Whilst reparations cannot right the wrongs of the past and

the experiences of victims and survivors, the Lambeth Children’s Homes Redress Scheme is a key

element of the Council’s response in addressing its profound historical failures to protect and

safeguard the welfare of children in its care. The Inquiry excluded the redress scheme from the

scope of its investigation in the Lambeth Council strand. In September 2019 the Inquiry published

its report in the Accountability and Reparations strand which considered the civil and criminal

reparations processes, and has indicated that it will return to the issue of redress schemes in its

final report due to be published in summer 2022.

Children in the Care of Lambeth Council Investigation Report

1.20 On 27 July 2021 the Inquiry published its detailed Investigation Report and made a number of

findings about the failures by the Council of the past and the causes which led to conditions

whereby appalling and absolutely shocking and horrendous abuse was perpetrated. Lambeth has

considered the Investigation Report and fully accepts its findings, which also reflected its own

submissions in its evidence to the Inquiry, on the appalling historic treatment of children in

Lambeth’s former care.

1.21 Alongside its findings and conclusions, the Inquiry made three recommendations for Lambeth

Council:

Recommendation 1: Response to this investigation report

Lambeth Council should develop and publish a comprehensive action plan which details

the actions that it will take in response to the issues raised throughout the Inquiry’s

investigation report. The action plan should be developed and published within six months of the

publication of this investigation report and should be accompanied by timescales for completing

identified actions as soon as possible.

Recommendation 2: Training for elected councillors

All Lambeth Council elected members should receive training on: (i) safeguarding and

(ii) corporate parenting. Newly elected members should receive training on these matters as soon

as possible following their election. Training should be mandatory and repeated on a regular basis.

The training content should be regularly reviewed and updated.

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Recommendation 3: Review of recruitment and vetting checks of current

foster carers and children’s home staff

Lambeth Council should review the application of recruitment and vetting procedures for all current

foster carers directly provided by Lambeth Council, to ensure that the procedures have been

followed correctly.

In addition, Lambeth Council should seek assurances from external agencies and other

local authorities, in which children in the care of Lambeth Council have been placed, that

recruitment and vetting procedures have been followed correctly for all foster carers and residential

children’s homes’ staff working with children.

1.22 The council has not waited for the recommendations and during 2020 identified a number of

learning points for the organisation through its engagement in the Inquiry process and

a corporate Action Plan to address these. The council has already taken steps to address vetting

and mandatory training for councillors on corporate parenting and safeguarding along with a

number of actions to assure the current systems and processes are effective. However, the

Council can never be complacent and recognises that there is further work to undertake.  The

Council is committed to continue to improve and its desire to ensure that learning from the Inquiry

translates into positive action which improves the quality of corporate parenting provided to

children in its care. 

1.23 The development, approval and publication of the Action Plan meets our responsibility and

determination to support the independent investigation and work of the Inquiry and our

commitment to the approach Lambeth has adopted throughout this process of transparency,

openness and accountability.

2. PROPOSAL AND REASONS

2.1 It is important to acknowledge Lambeth Council’s troubled past. It is equally important to recognise

how different the Council is today. There is, a very different political environment within Lambeth

today and a much more robust accountability framework within the Council. This provides

oversight and assurance to the Leader of the council, lead Members and senior managers with

statutory responsibilities, in terms of ensuring that issues in relation to risk management, child

protection and the council’s statutory duties are regularly reviewed and scrutinised. In addition, the

council today operates within a much more robust regulatory framework provided by Ofsted; this

currently includes yearly visits and the expectation of a full inspection every three years. Lambeth

has strengthened its commitment to transparency and to a culture of continuous learning. The

emphasis from leaders at Lambeth is that there has to be an honest recognition of situations when

there has been a failure to deliver the high standards of practice that are required with lessons

being learnt to secure and deliver necessary changes and improvements.

2.2 There can be confidence in Lambeth’s position today, with the appropriate caveat recognised by

the council that complacency is not something that can be countenanced. The council has

focused its resources on attempting to understand the failings of the past in order to incorporate

that understanding into its ongoing improvement journey and ensure the Lambeth IICSA Action

Plan delivers meaningful change and impact for our children and young people in care. To ensure

that this is achieved, all actions required as a result of the Inquiry report are developed and

collectively owned by the Council’s Senior Management Team and are fully monitored and

regularly reviewed by elected Members.

2.3 The IICSA Investigation Report requires us to evidence we are an authority that has changed and

to demonstrate how we will continue to change and ensure positive outcomes are fully embedded

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into our culture and ways of working to meet the needs of our children in care now and in the

future. The Lambeth Council IICSA Action Plan has been developed in such a way so as to

address those requirements.

2.4 The Action Plan has been formed of eight thematic groupings to ensure that we are able to give

sufficient focus both strategically and operationally to the issues raised in the Investigation Report.

In addition, structuring the Action Plan in this way has given us the space to comprehensively

address the specific findings of the report and demonstrate how we are continuing to make the

changes necessary to ensure children and young people in care are safeguarded.

2.5 Each theme sets a statement of high-level commitments, in response to the findings by IICSA,

such as listening to the voice of children and young people in care, leadership, political and

organisational culture and accountability. These commitments provide the overarching framework

under which specific actions can then deliver real and lasting change for children and young

people in care.

2.6 The eight themes and commitments in the Action Plan are:

Theme Lambeth commitment

1. Voice of the

Child

We will embed 'organisational listening' to give unrelenting focus to the

voice and experiences of children and young people in care.

We will amplify the mechanisms through which children’s voices can be

heard to create an environment where children feel empowered to share

their experiences.

Children and young people in care are actively involved in strategic level

decision making processes; they are involved in our Corporate Parenting

Board and Scrutiny meetings. They are also represented on our Lambeth

Safeguarding Children Partnership Board. We will continue to ensure their

representation and involvement

2. Political

Leadership and

Culture

We will maintain robust political leadership and accountability, founded on a

sound understanding of our corporate parenting responsibilities, and we will

provide appropriate oversight in line with the democratic processes of the

council.

As elected Members, we will ensure that the interests of children and young

people in care are paramount and that we create a culture of honesty,

openness and transparency.

3. Leadership

and

Accountability

We will maintain robust corporate and political leadership and

accountability, founded on a sound understanding of our corporate

parenting responsibilities.

We will embed a culture of constructive challenge within our leadership

teams.

We will maintain clear member oversight, scrutiny and challenge in line with

our democratic processes.

4. Organisational

Culture

We will continue to promote a culture of respect, listening, challenge and

learning across the council; ensuring our officers and members are

encouraged to be curious and not complacent.

We will make sure the voices of children and young people in care are

heard throughout the organisation at all levels and are at the heart of our

decision-making.

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Theme Lambeth commitment

5. Oversight and

Assurance

We will have effective corporate and political oversight and assurance that

strengthens safeguarding of our children in care and care leavers.

We will maintain and build on the mechanisms that enable clear line of sight

for senior leaders and councillors.

We will continue to ensure that our assurance bodies, including scrutiny

committees, function effectively and provide challenge.

6. Social Care

Practice and

Performance for

Children Looked

After

We will make sure our children and young people are placed in safe and

stable homes where they can thrive and achieve their potential.

Our children and young people in care benefit most from having a stable

and skilled social care workforce. Our Children’s Social Care Workforce

Development strategy will enable this and we will ensure our social care

staff have access to the resources and training to equip them to provide

effective, timely, and appropriate help to children and young people.

7. Corporate

Parenting and

Safeguarding

We will make sure we maintain and enhance effective governance

processes which both enable our leaders to discharge their corporate

parenting responsibilities in line with the Corporate Parenting Principles and

hold them to account.

We will foster increased council-wide awareness of our corporate parenting

role and how safeguarding is everyone’s business.

We will provide a robust training offer for staff and councillors with clarity on

how senior officers and political leaders should execute their responsibilities

as corporate parents.

8. HR Processes

and Management

of Allegations

We will maintain robust processes in place to manage allegations against

individuals working with children.

We will ensure all staff, and those employed by external and commissioned

providers, are recruited and vetted through Safer Recruitment procedures,

that have safeguarding at the heart of them.

We will ensure that staff, providers and partners are aware of Lambeth’s

Whistleblowing Policy and staff are able to raise concerns outside of their

line management and organisation where necessary.

2.7 The development of the Action Plan has been an iterative process, with much consideration given

to how best to integrate the voices of our children in care and care leavers at every step, as well as

the views and recommendations from victims and survivors from their testimonies and evidence to

the Inquiry.

2.8 The actions have been developed and defined by subject professionals, and practice and

operational leads. Delivery of the actions has been assessed against directorate business plans

and existing programmes to identify and assign operational leads who will be responsible for

delivery.

2.9 The Lambeth IICSA Action Plan has been drafted and presented to various forums for review and

challenge including the Lambeth Safer Children Partnership, Children’s Services CMB, Lambeth

Adult Safeguarding Board, Corporate Parenting Board (which includes our Children in Care

Council who are Board members) and the Equalities Impact Panel. The feedback from these

Boards has been incorporated into the actions.

2.10 A series of consultations with (older) young people in care was undertaken by the Participation

Team in Children’s Services in a separate exercise that sought their reflections and

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recommendations on the actions that the council needed to include in the Action Plan. This has

been incorporated into the actions.

2.11 In addition, a number of witnesses including all complainant and victim core participants, were

invited by IICSA to provide their views about any practical recommendations to prevent child

sexual abuse in the future and to improve the response to such allegations. Those

recommendation are set out in Annex 4 to the Investigation Report. Although Lambeth are not

required by IICSA to respond to the recommendations in Annex 4, we have considered and set out

the Council’s response to each recommendation.

2.12 The 62 actions within the Action Plan have been allocated to the operational Directors responsible

for their delivery. Delivery plans will be reviewed and monitored by dedicated programme

management, ensuring dependencies and risks are managed and mitigated. The quality and

progress of delivery of actions against intended outcomes will be regularly reported to, assured

and overseen by the senior leadership team as follows:

Quarterly report to IICSA Board chaired by the Chief Executive; and,

Six-weekly report to IICSA Oversight Board chaired by the Strategic Director for Children’s

Services.

2.13 Council oversight of the Action Plan and progress on delivery and outcomes will be in place

throughout the delivery period of the Action Plan, with the proposed reporting cycle as follows:

Annual report to Full Council, including Youth Council;

Bi-annual reports to Cabinet and Scrutiny Committee(s);

Annual report to Corporate Parenting Board, which includes representation from the Children

in Care Council; and,

Quarterly report to Children’s Services Cabinet Member Briefings.

2.14 In addition, the Action Plan incorporates external independent scrutiny and peer review by the

Local Government Association of organisational culture, focused on leadership and the council’s

working culture. The Lambeth Safeguarding Children Partnership (LSCP) will also act as critical

friend given their responsibility for overseeing safeguarding arrangements in the borough and will

scrutinise the impact of actions relating to the safeguarding of children and young people in care in

the Action Plan. It should also be noted that Ofsted are due to undertake a full inspection of

Children’s Services during 2022.

2.15 The Action Plan will demonstrate our commitment to tackling inequalities, and challenging

practices among our professionals as we all as our partners which can contribute to

disproportionate numbers of Black children and young people entering the care system. Our

review of social care practice will ensure processes are age and capacity appropriate, culturally

sensitive and our complaints process is accessible. There is also a specific action to commission

research into differential experiences of children and young people based on race and ethnicity.

This will enable a better understanding of the types of interventions, assumptions and language

used in relation to Black children, young people and their families to identify and address

un/wittingly discriminatory or racist practices within the system which may contribute to this

disproportionality and differential treatment

2.16 The Action Plan will also underpin our renewed pledge to children looked after and young people

leaving our care and help form solid foundations on which our UNICEF Child Friendly Lambeth

programme can build.

Page 15

Contract Management

2.17 None arising from this report.

3. FINANCE

3.1 Developing both the Action Plan and detailed delivery plan has been resource intensive. Interim

programme management resource has been provided by the Programme Performance service

within Finance and Investment, that has put in place the structure and definition required for the

delivery and governance of the Action Plan.

3.2 Dedicated full-time programme management resource will be put in place to support delivery and

programme manage the oversight, assurance and monitoring of the Action Plan, as well as

servicing the IICSA Board and IICSA Oversight Board and the associated reporting on the Action

Plan.

3.3 The necessary resources including commissioning external services for peer review and research

have been assessed and £500,000 allocated, with funding available from the budget originally set

up to manage the Council’s response to the inquiry.

4. LEGAL AND DEMOCRACY

4.1 Under sections 5, 24 and 25 of the Inquiries Act 2005 the Council as a core participant is obliged to

comply with a statutory inquiry (having a defined terms of reference). A statutory inquiry has the

power, under section 24(1) to include in its report “…anything else that the [inquiry] panel

considers to be relevant to the terms of reference (including any recommendations the panel sees

fit to make despite not being required to do so by the terms of reference).” The power to set any of

the time parameters for the Council to respond to IICSA’s recommendations is set by IICSA.

4.2 IICSA expects that where recommendations are made to the Council, the Council will act upon

these recommendations and publish the steps they will take in response. Unless otherwise agreed,

the Council must publish its response within six months of the recommendation being published, in

this instance by 24 January 2021. A failure to publicly respond to the recommendations of IICSA

will result in directions for a witness statement from the Council as to their failure to not publish a

response to the Inquiry’s recommendation.

4.3 Section 149 of the Equality Act 2010 (‘the public sector equality duty’) is also relevant to the

Council’s response to the Inquiry Report. The Inquiry report stated that “children from Black, Asian

and ethnically diverse backgrounds experienced overt racism”, and a disproportionate number of

our looked after children and care leavers are from Black, Asian and Multi-Ethnic backgrounds.

Further, the Equalities Impact Assessment (see section 7 of this report) shows that a significant

number of children and young people who are looked after have an additional health or

educational support need and many are therefore likely to be regarded as disabled for the

purposes of the Equality Act 2010.

4.4 Section 149 requires public authorities to have due regard to the need to:

(a) eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited

under that Act

(b) advance equality of opportunity between persons who share a relevant protected

characteristic (i.e. race, sex, disability, age, sexual orientation, religion or belief, pregnancy or

maternity, marriage or civil partnership and gender reassignment) and those who do not

share it; and

Page 16

(c) foster good relations between those who share a protected characteristic and those who do

not share it, which involves having due regard, in particular, to the need to-

(i) tackle prejudice; and

(ii) promote understanding.

4.5 Having due regard to the need to advance equality of opportunity between persons who share a

relevant protected characteristic and persons who do not share it involves having due regard, in

particular, to the need to:

(a) remove or minimise disadvantages suffered by persons who share a relevant protected

characteristic that are connected to that characteristic;

(b) take steps to meet the needs of persons who share a relevant protected characteristic that

are different from the needs of persons who do not share it, including, in particular, steps to

take account of disabled persons' disabilities; and,

(c) encourage persons who share a relevant protected characteristic to participate in public life

or in any other activity in which participation by such persons is disproportionately low.

4.6 The section 149 duty must be complied with before and at the time that a particular policy is under

consideration or decision is taken - that is, in the development of policy options, and in making a

final decision. A public body cannot satisfy the duty by justifying a decision after it has been taken.

4.7 Other relevant legal duties include the Council’s obligations to the welfare of children. These

include the duty under section 17 of the Children Act 1989 to safeguard and promote the welfare of

children within their area who are in need and under section 11 of the Children Act 2004 to make

arrangements for ensuring that its functions are discharged having regard to the need to safeguard

and promote the welfare of children.

4.8 Children’s Services Scrutiny Sub Committee – Due to the timing of meetings, comments from the

Children’s Services Scrutiny Sub Committee will be tabled at Cabinet for consideration

4.9 Cabinet - This proposed key decision was entered in the Forward Plan on 8 November and the

necessary 28 clear days’ notice has been given. The report will be published for five clear days

before the decision is considered by Cabinet. Should it be approved and following the publication

of the Cabinet minutes, a further period of five clear days, the call-in period, must then elapse

before the decision becomes effective. If the decision is called-in during this period, it cannot be

enacted until the call-in has been considered and resolved.

4.10 Council - Following the formulation and preparation of the IICSA Action Plan by Cabinet, it is within

Full Council’s remit to resolve that it (instead of Cabinet) should take a decision as to whether to

approve and adopt and approve the Plan. If full Council resolves to do so, it may then move on to

consider whether to approve and adopt the Plan.

5. CONSULTATION AND CO-PRODUCTION

5.1 The development of Lambeth’s IICSA Action Plan has centred on cross directorate working, with

contribution and oversight from senior officers within every directorate across the Council.

5.2 Internal consultation on the plan has been undertaken with Lambeth’s political leadership including

the Leader, Informal Cabinet, Lead Member for Children and Young People and Lead Member for

Finance and Performance. The plan has also been reviewed and challenge provided by Lambeth’s

senior leadership team and Chief Executive.

Page 17

5.3 Formal challenge and review of the Action Plan has been provided by: Corporate Parenting Board,

Lambeth Youth Council and Lambeth Safeguarding Children Partnership. This has also enabled

review of the Action Plan by some of our children looked after and care leavers in the Children in

Care Council, through their position as Board members.

5.4 In addition to review of the Action Plan through formalised governance avenues,

Lambeth’s Participation Officer facilitated an informal session for children and young people looked

after (following release of the Lambeth IICSA Report) to discuss the inquiry findings and explore

recommendations as to how past events can be prevented from happening again. These

recommendations have been encompassed within the Action Plan.

5.5 The Council has read and listened to the evidence and testimonies of survivors to the Inquiry.

There were 62 core participants who were victims and survivors who provided evidence to the

Inquiry. 11 survivors and victims also gave direct testimony during the hearings and the Inquiry

also read into the hearing 47 witness statements. Throughout the Inquiry, victims and survivors

were invited to provide their views and recommendations on preventing child sexual abuse in

the future and improving responses to allegations. These recommendations and views contained

with Annex 4 to the IICSA Report have been considered fully throughout the Action Plan

development and incorporated into the Action Plan where appropriate. We have also received

feedback from victims and survivors via the redress process – they have been clear in their wish to

know we will keep children safe and that the events of the past will not happen again

6. RISK MANAGEMENT

6.1 The main risks surrounding delivery of this Action Plan are:

Table 1 – Risk Register

No Risk Likelihood Impact Score Control Measures

1

Adverse impact on

experience of children

and young people in

care and care leavers

– particularly

disproportionate

impact on Black, Asian

and Multi-Ethnic

children and young

people - through not

delivering the actions

in the Plan

2 8 16

Rigorous governance arrangements

incorporating oversight from

Corporate Parenting Board, Children

in Care Council and Lambeth Youth

Council will continue to ensure that

our children and young people in

care and care leavers are at the

centre of Action Plan delivery. A

dependency management approach

will also be undertaken to align

Action Plan delivery with our

Equalities, Diversity and Inclusion

Strategy. Specific actions in the plan

have been developed that will enable

prioritisation of delivery to mitigate

the impact of this risk.

2

Identified actions don’t

deliver outcomes

which sufficiently

address Inquiry

recommendations and

2 4 8

Development of the Action Plan has

been a carefully considered, iterative

approach with input from across the

council and partners, with strong

reference to the Inquiry findings.

Quality management will be

Page 18

No Risk Likelihood Impact Score Control Measures

fail to deliver impactful

change

undertaken to ensure that actions are

delivered to high standard and

quality. Robust governance will allow

frequent review of the plan and

continual alignment to Inquiry

findings and conclusions.

3

Failure to sustain the

change delivered

through this Action

Plan

2 8 16

One of the key principles of the

Action Plan is to embed change in

our ways of working; each of the

actions has an operational Director

who will be responsible for ensuring

change is embedded in policies,

procedures, performance measures

and ways of working. Parallel to this

there is a commitment from the

political leadership to ensure that all

councillors engage and deliver on

their responsibilities and that there

will be robust assurance and

accountability through existing

mechanisms.

4

Insufficient

organisational capacity

to deliver the Action

Plan

2 4 8

Dedicated programme management

resource will be in place to steer

delivery of the Action Plan, with

support from Management Board and

elected Members to ensure ongoing

commitment. Operational Directors

will be responsible for embedding

actions within their annual business

plans to ensure they are properly

resourced and planned for alongside

service operations.

5

Insufficient political

and organisational

oversight of Action

Plan delivery

1 4 4

A comprehensive oversight,

accountability and governance

framework has been developed to

ensure clear line of sight against

action plan delivery both politically

and organisationally with dedicated

programme management resource to

steer this and service the requisite

reporting cycle

Key

Likelihood Very Likely = 4 Likely = 3 Unlikely = 2 Very Unlikely = 1

Impact Major = 8 Serious = 4 Significant = 2 Minor = 1

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7. EQUALITIES IMPACT ASSESSMENT

7.1 The Equalities Impact Assessment (EIA) was collated and analysed in October and November

2021 before receiving approval from the Director for Strategy and Communications on 16

November 2021.

7.2 Findings from the EIA centre primarily on Lambeth’s children looked after and care leavers;

showing a disproportionate number of our children looked after and care leavers are from Black,

Asian and Multi-Ethnic backgrounds, as well as significant number of children and young people

having an additional health or educational support need.

7.3 These findings intersect with those of the Inquiry, which made clear that children from Black, Asian

and Multi-Ethnic backgrounds were overrepresented in our children’s homes, faced additional

hardships, and were subject to overt racism. The Inquiry also noted that children with complex

needs and communication difficulties were under the care of staff who lacked the training and skills

to support them appropriately.

7.4 As a result of these findings, actions within the Action Plan have been designed to address the

inequalities faced by these groups and ensure that they receive support and care that is sensitive

to their needs and recognises the additional challenges they may face.

7.5 The EIA for Lambeth’s IICSA Action Plan was considered by the Corporate EIA Panel on 23

November 2021. Key feedback from the Chair centred on the need to build trust with our Black,

Asian and Multi-Ethnic children looked after and care leavers, recognising and showing sensitivity

to their mistrust of the Council as a result of our past failures. An agreed action was to reference

the duties of the Council in delivering its Sufficiency Strategy 2020 – 2023 within the Action Plan;

the strategy that provides the framework and approach Lambeth will take to meet the placement

needs of children and young people in care, prioritising keeping our children and young people

within the borough when this is possible. This has been reflected in Action 6.12 of the Plan.

8. COMMUNITY SAFETY

8.1 Not applicable

9. ORGANISATIONAL IMPLICATIONS

Environmental

9.1 Not applicable.

Health

9.2 Delivery of Lambeth’s IICSA Action Plan supports key priorities from the children and young people

prioritisation matrix within Lambeth’s Joint Strategic Needs Assessment, namely children in care

and care leavers, as well as our ongoing commitment to supporting children and young people in

Lambeth with special educational needs and disabilities (SEND).

Corporate Parenting

9.3 As corporate parents, staff and councillors are all responsible for providing the same standards of

care to our children looked after and our care leavers as would be good enough for our own

children. Lambeth’s IICSA Action Plan specifically relates to this group of children and young

people, with one of the eight overall themes focussed on corporate parenting and ensuring these

structures continue to be effective. Lambeth’s corporate parenting governance arrangements have

recently been reviewed and strengthened, with the inclusion of representatives from our Children in

Page 20

Care Council sitting as full board members, alongside the development of our annual corporate

parenting action plan and performance monitoring dashboard. Ensuring the Action Plan is fully

implemented will continue to underpin our responsibilities as corporate parents in making sure our

children looked after and care leavers are safeguarded, secure and have good stable homes to

enable them to thrive and reach their full potential.

Staffing and accommodation

9.4 Dedicated full-time programme management resource at 2 FTE will be put in place to support

delivery and programme manage the oversight, assurance and monitoring of the Action Plan, as

well as servicing the IICSA Board and IICSA Oversight Board and the associated reporting on the

Action Plan to elected Members.

Responsible Procurement

9.5 Not applicable.

10. TIMETABLE FOR IMPLEMENTATION

10.1 The table below details the stages and deadlines for implementing the recommendations:

Activity Proposed Date

Date published on Forward Plan 08.11.21

Children’s Service Scrutiny Sub Committee 07.12.21

Cabinet 13.12.21

Full Council 15.12.21

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AUDIT TRAIL

REPORT HISTORY

Original discussion with Cabinet Member Ongoing

Report deadline 29.11.21

Date final report sent 29.11.21

Part II Exempt from Disclosure/confidential

accompanying report? No

Key decision report Yes

Date first appeared on Forward Plan 08.11.21

Key decision reasons 3. Meets community impact test.

Background information

Children in the care of Lambeth Council Investigation

Report | IICSA Independent Inquiry into Child Sexual

Abuse

Sufficiency Strategy

Fostering Recruitment Strategy

Corporate Parenting Strategy 2021 - 2024

Appendices

Appendix 1 – Draft Lambeth Council IICSA Action

Plan 29.11.21

Appendix 2 – Equalities Impact Assessment dated

23.11.21

Name and Position/Title Lambeth Directorate Date Sent Date

Received

Comments in

paragraph:

Councillor Claire Holland Leader of the Council 26.11.21 26.11.21 Throughout

Councillor Edward Davie Cabinet Member for

Children’s Services 26.11.21 29.11.21 -

Andrew Travers Chief Executive 25.11.21 26.11.21 -

Merlin Joseph,

Strategic Director Children’s Services 24.11.21 25.11.21 -

Christina Thompson,

Finance and Property Finance and Investment 23.11.21 23.11.21 Section 3

Andrew Pavlou,

Legal Services Legal and Governance 23.11.21 24.11.21 4.1 - 4.5; 4.9

Wayne Chandai,

Democratic Services Legal and Governance 25.11.21 26.11.21 4.6 - 4.8

Page 22

Independent Inquiry into Child Sexual Abuse (IICSA) Lambeth Council IICSA Action Plan (DRAFT)

103008 (12.21)

Page 23

Contents Foreword by Leader of the Council 4

Foreword by Chief Executive 5

Introduction 7

Action Plan 14

Annex 4 to the IICSA Investigation Report 23

Glossary 31

About this document Title: Lambeth Council IICSA Action Plan (DRAFT)Purpose: Response to the IICSA Inquiry ReportApproved by: xxxxxxDate: 29 November 2021Version number: 0.1Status: Draft

Page 24

Forewords

Lambeth Council IICSA Action Plan (DRAFT) / page 3

Page 25

The publication of the Investigation Report in July 2021 by the Independent Inquiry into Child Sexual Abuse shone a light on one of the most painful and most profoundly shocking truths about Lambeth Council’s history. The council consistently failed some of the most vulnerable children and young people whose care was entrusted to us. We let them down.  At the report’s launch, I re-stated the sincere apology made by my two immediate predecessors as Leader. The council failed to listen and act, often not even believing children when they had the courage to report what was happening. The council failed to take effective action to stop abuse happening.  That failure has caused untold distress with lifelong impacts, which we know many survivors continue to

wrestle. The fact that such a highly disproportionate number of those affected came from our Black communities is a scar on our past that we must put right.

Since the publication of the report, the council has been working extremely hard to develop and implement an Action Plan which will ensure that our children and young people in care will never again face such heartless complacency and will instead be supported to live their lives positively and with ambition for the future. The Plan strongly incorporates the voice of the child throughout and benefits from careful and intensive oversight by elected Members, including myself.

We are absolutely determined to address the issues which the Independent Inquiry highlighted. Tough questions have been asked, no process is being left unreviewed and no child will be left behind. These are our collective and ongoing commitments to children and young people for whom we care. They are also our commitments to residents, carers, Lambeth Council staff and our partners across the borough. Each wants to see clear evidence that we

have changed, that the Lambeth of today is wholly different from the council of the past that so flagrantly put the needs of children aside.

In developing our Action Plan, I want to thank my fellow councillors for their engagement. Our staff have worked incredibly hard – and continue to do so – to implement meaningful change that will deliver results. Our wider partnership has carried out its role of critical friend which has helped shape our Plan for the better.

Finally, I want to pay tribute to each and every victim and survivor – and their families and support networks. It was their courage that forced these issues onto the agenda and ensured that the Inquiry into these appalling failures took place. As we move towards being recognised as a UNICEF Child Friendly Borough, the needs of children and young people in the future requires us to reflect on the past. Victims and survivors deserve our respect and our determination to succeed in our work. I believe this Plan will deliver on that promise.

Cllr. Claire Holland, Leader, Lambeth Council 

Foreword from the Leader of the Council

Lambeth Council IICSA Action Plan (DRAFT) / page 4

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Foreword from the Chief Executive

When it comes to be written, the history of Lambeth will have our response to the Independent Inquiry into Child Sexual Abuse (IICSA) at its heart. The Inquiry rightly requires that we evidence our assertions that Lambeth is very different today from that past which the Inquiry’s Report detailed so harrowingly, and we are absolutely determined to deliver on that.  Our Action Plan will achieve this requirement. Strong and robust professional leadership from the top – including from myself – but also our committed Strategic Director of Children’s Services, working with senior elected Members, Management Board colleagues and all of our councillors is a strong feature of this Plan. Every officer of this council has a role to

play in delivering it in full: this is not a ‘project in a silo’: it is the responsibility of everyone in the council to play their part in keeping our promises.

The Action Plan also sets out our strategic objectives relating to the specific recommendations from IICSA, such as on leadership and accountability, as well as updates on projects and programmes which ensure delivery against those. It ensures that elected Members’ priorities are actioned and can have confidence in how Lambeth works today to positively support children. So that there is clear alignment between this Action Plan and our broader work on children and young people in care, we have re-validated our existing safeguarding and corporate parenting strategies. Assisting with this important work, Lambeth also benefits from a well-established Children in Care Council called ‘Visions of Success’ (VoS), who are an absolutely pivotal steering group in helping us to make sure that our Action Plan and ways of working remain in the interest of all our children and young people in care and that it is implemented in a service user led way.

Our engagement with victims and survivors of abuse has been an important element as we strive to make sure what happened can never occur in Lambeth again. We are grateful to the brave victims and survivors for every detail they shared with the Council and IICSA which enables us to ensure that children and young people in care today and in the future are safeguarded.

Our Equalities, Diversity and Inclusion Board and Steering Group have reflected on the clear disproportionate impact on Black children in care in terms of the horrendous abuse the Inquiry Report evidenced. To address this, we have strong programmes and processes in place to support Black, Asian and Multi-Ethnic children and young people – but we are mindful of the consistent disproportionality of Black children in the care system.

The Action Plan includes detail on what we are doing to embed real and lasting change corporately through a new approach to organisational development, as well as making sure delivery is cascaded through individual business and directorate plans. We are doing this so that everyone who works here or

Lambeth Council IICSA Action Plan (DRAFT) / page 5

Page 27

Foreword from the Chief Executive

alongside us in partnership clearly understands our plans and priorities to safeguard and meet the needs of our children and young people in care. In effect, this Action Plan makes sure that what we say reflects what we actually do. Lambeth is currently devising our UNICEF ‘Child Friendly Lambeth’ programme that will work with all services across Lambeth to underpin our planning, commissioning, decision-making and evaluations with the rights of the child as a priority. We will be working with children and young people across Lambeth, including our children looked after and care leavers, to understand their priorities for the programme and ensure that they are at the heart of shaping our child friendly services for the future.

Resource has been carefully allocated to guarantee delivery of our Action Plan corporately with programme management support. Importantly, the Plan is not an articulation of a particular point in time. Like the work itself, it is evolving with

much already delivered: such as our recent review of out-of-borough placements for children looked after and strengthened governance arrangements for corporate parenting. These sit alongside key projects which are still very much underway, or which require further final endorsement. We are determined to deliver on a place where children and young people can feel safe, secure, cared for and able to grow and thrive and we will ensure that we work alongside our communities and partners, including our children and young people every step of the way to secure that promise.

Andrew Travers, Chief Executive, Lambeth Council

Lambeth Council IICSA Action Plan (DRAFT) / page 6

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Introduction

Lambeth Council IICSA Action Plan (DRAFT) / page 7

Page 29

4Voices and experiences of our children and young people in care are at the heart of decision making and influence policy and service development 

4Committed corporate parenting with shared councillor and staff responsibility for children looked after means the most vulnerable children are supported well, in line with the seven key Corporate Parenting Principles

4Equalities, Diversity and Inclusion is a key corporate priority which is meaningful and influences the way in which we meet the diverse needs of our children and young people in care

4Robust accountability framework within the council with oversight and assurance by elected Members and senior leaders.

4Robust process and procedures for safeguarding children, recruitment and vetting and management of allegations

4Resources to improve social work practice and children and young people’s lives

4Commitment to transparency and culture of continuous learning

4Working toward recognition as a UNICEF Child Friendly Community to ensure children, young people and their families are at the heart of our planning and delivery.

Lambeth Council today 

It is important to acknowledge Lambeth Council’s troubled past. It is equally important to recognise how different the Council is in 2021. Today Lambeth enables and facilitates a strong professional culture that actively promotes children and young people in care having a strong voice in all the decisions affecting them. Resource, clear political commitment and significant changes in leadership and approach have resulted in significant improvements. There is also a clear recognition that there is much more that needs to be done to ensure that services are consistently good or better and that, most importantly, children and young people in our care are supported to have safe and fulfilling lives.

Lambeth Council IICSA Action Plan (DRAFT) / page 8

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Recommendation 1: Response to this investigation reportLambeth Council should develop and publish a comprehensive action plan which details the actions that it will take in response to the issues raised throughout the Inquiry’s investigation report. The action plan should be developed and published within six months of the publication of this investigation report and should be accompanied by timescales for completing identified actions as soon as possible.

Recommendation 2: Training for elected councillorsAll Lambeth Council elected members should receive training on: (i) safeguarding and (ii) corporate parenting. Newly-elected members should receive training on these matters as soon as possible following their election. Training should be mandatory and repeated on a regular basis. The training content should be regularly reviewed and updated.

Recommendation 3: Review of recruitment and vetting checks of current foster carers and children’s home staffLambeth Council should review the application of recruitment and vetting procedures for all current foster carers directly provided by Lambeth Council, to ensure that the procedures have been followed correctly.

In addition, Lambeth Council should seek assurances from external agencies and other local authorities, in which children in the care of Lambeth Council have been placed, that recruitment and vetting procedures have been followed correctly for all foster carers and residential children’s homes’ staff working with children.

IICSA Recommendations for Lambeth

Children in the care of Lambeth Council

Investigation ReportJuly 2021

20212020

Lambeth Council IICSA Action Plan (DRAFT) / page 9

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Lambeth’s IICSA Action Plan development

Through our engagement in the Inquiry process and following the public hearings in June and July 2020, we considered the lessons learned and developed and completed actions for ongoing improvement in services. Following publication of the Investigation Report in July 2021, which included recommendations from victims and survivors, we reflected on our position before formulating this Action Plan to safeguard against the failures of the past being repeated. This has allowed the council to continue to chart the clear course children and young people in Lambeth deserve.

We have engaged with care leavers and our Children in Care Council in considering what actions we could take, and what measures we could put in place to ensure children are always protected. We have also engaged with victims and survivors, including through an Independent facilitator, on the right way to integrate their voice into our work, and how we learn and reflect on the events of the past. 

We have worked with elected Members, partners, children and young people in care and other key stakeholders to seek views and contributions to the Action Plan to make certain that all areas have been reviewed and scrutinised. 

We explored how to develop actions that ensure changes are sustainable and outcomes embedded into our services, policies and processes. This plan will allow us to deliver meaningful and sustainable change that will safeguard our children and young people in care.

We have grouped these actions under the following eight themes together with our commitments:

1 Voice of the Child2 Political Leadership and Culture3 Leadership and Accountability4 Organisational Culture5 Oversight and Assurance6 Social Care Practice and Performance for Children Looked After7 Corporate Parenting and Safeguarding8 HR Processes and Management of Allegations

Lambeth Council IICSA Action Plan (DRAFT) / page 10

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Principles of Approach

4We will make sure that the voice of children and young people in care is embedded within each of our actions within this Plan – and crucially – that this is followed up meaningfully with children and young people themselves

4Use the victims and survivors’ recommendations about how to prevent such events happening again and to improve the response to such allegations; together with their testimonies and evidence to the Inquiry about how important it is that children and young people in care participate and contribute to all the decisions affecting them and inform our actions

4Know that while the events examined by the Inquiry were in the past, there is learning to take forward into the future and actions we can take today

4Learning does not stop; we will take time to reflect on these events and make sure that what we do to ensure they never happen again is reinforced by a culture of curiosity, accountability and challenge

4We will communicate our Plan and our progress as we deliver on the actions within it. We will do this in a timely and effective way with all of our stakeholders including children and young people in care

4We will make sure that our delivery plans are clear, enable effective review and scrutiny and are transparent. Equally, those changes set out in our Plan will be fully embedded into our ways of working.

Lambeth Council IICSA Action Plan (DRAFT) / page 11

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Views of our Children and Young People in Care Following the publication of the Inquiry’s report, we were concerned about the potential impact it could have on the children and young people in our care.

Taking this into consideration we wanted to ensure that our children and young people in care had a safe space where they could discuss any concerns they may have had following the Inquiry and to hear their recommendations on how we could prevent such things from happening again.  To ensure we did not simply do what we felt was needed, Lambeth’s Participation Officer met with young people in care to lead a discussion on the best way to go about it. 

They were surprised that we wanted to inform young people of what took place and stated there was no need to. They felt that by doing so, we would create further unneeded anxiety and heighten or create concerns which would not have ordinarily existed.

They felt that rather than telling children and young people what we were going to do, we just need to ensure that we do it, to prevent such failures from happening again.

Lambeth need to ensure they learn from what took place.

Lambeth need to ensure the same thing does not happen again.

Lambeth need to ensure that all children and young people know who to contact if they are ever concerned about an adult’s (more specifically a professional’s) interaction with them.

Lambeth need to focus on developing meaningful relationships between young people and staff.

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What our young people in care told us

Lambeth Council IICSA Action Plan (DRAFT) / page 12

“If you do not have a good relationship with your social worker you will not tell them anything.”

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Council Oversight and Governance

Lambeth Council IICSA Action Plan (DRAFT) / page 13

Oversight of our Action Plan by elected Members and senior leaders will ensure accountability, challenge and scrutiny.

Progress on delivery and outcomes will be reported via our existing democratic and governance processes throughout delivery of the Action Plan.

In addition to council oversight, there will be independent peer review by the Local Government Association and Lambeth Safeguarding Children Partnership.

Lambeth IICSA Board (quarterly)Chair: Chief Executive

IICSA Oversight Board (6-weekly)Chair: Strategic Director Children’s Services

Cabinet (bi-annually)Chair: Leader of the Council

Overview and Scrutiny / Children’s Services Scrutiny (bi-annually)Chair: Elected Member

4Corporate Parenting Board including the Children in Care Council (annually)4Children’s Services Cabinet Member Briefings (quarterly)

Council including the Youth Council (annually)Chair: Mayor of Lambeth

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IICSA Action Plan

Lambeth Council IICSA Action Plan (DRAFT) / page 14

Page 36

Ongoing

Ongoing

By January 2024

Ongoing

By March 2023

Annually

We will embed ‘organisational listening’ to give unrelenting focus to the voice and experiences of children and young people in care.

We will amplify the mechanisms through which children’s voices can be heard to create an environment where children feel empowered to share their experiences.

Children and young people in care are actively involved in strategic level decision making processes; they are involved in our Corporate Parenting Board and Scrutiny meetings. They are also represented on the Lambeth Safeguarding Children Partnership Board.  We will continue to ensure their representation and involvement.

1 Voice of the ChildACTIONS WHENCOMMITMENTS

1.1 We will continue to consult with our children and young people looked after to devise relevant approaches and strategies in how best to work with them, strengthening and forging meaningful and safe relationships between our children and young people looked after and professionals. We will embed continuous improvement in this area in our Children’s Services annual business plan.

1.2 Every child and young person in care under the age of 18 has an Independent Reviewing Officer (IRO). IROs are trained and qualified social workers who work in the local authority in an independent capacity. Lambeth’s IROs oversee and scrutinise the Care Plan of the child/ young person and ensure that everyone who is involved in that child/young person’s life fulfils his or her responsibilities. We will continue to ensure that we maximise the use of our IROs to support our children and young people and to add an extra layer of quality assurance in the way we work. 

1.3 We commission an Independent Visitor Scheme for our children and young people in care. The service is child-led, with the needs and views of our children and young people at the centre of all its work, this includes referrals, matching, visits, and endings. We will continue to ensure children and young people have access to externally trained professionals through this service for advice and support and to discuss their wishes and feelings, and will work with them to increase take-up of this service.

1.4 Lambeth commission an Independent Advocacy Service. We will continue to promote this service to ensure our children and young people have an independent professional who can also advocate on their behalf, help them to take part in decisions that affect their lives, make sure their rights are respected, and their views and wishes are heard and where possible acted upon.  

1.5 We will review our Independent Visitor and Advocacy services, seeking better practice and the best offer for our children, young people and children and young people in care and care leavers.

1.6 Lambeth Children’s Social Care has a complaints service where children, young people and other service users can make a formal complaint about the care and/or support provided to them. Children and young people can also receive support from an Advocate to help them in making a complaint. We will continue to: promote the complaints service and make it accessible and user friendly for our children and young people; monitor the handling of complaints, deliver what we have promised, learn from complaints, and use this learning to improve services for everyone who uses them; and to review and report annually to Corporate Committee.

Lambeth Council IICSA Action Plan (DRAFT) / page 15

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2.1 Ensure all councillors operate in line with the Nolan Principles of public office: Selflessness, Integrity, Objectivity, Accountability, Openness, Honesty and Leadership. 

2.2 Review and refresh the Member Code of Conduct ensuring ensuring clear directive about the distinction between oversight and scrutiny role of elected Members and operational decision-making by officers and reinforce on a regular basis.

2.3 Review elected Members’ involvement in our industrial relations and trade union processes and ensure these are appropriate and in line with the Member Code of Conduct and the respective roles of elected Members and officers. 

2.4 Ensure induction training for newly-elected councillors reinforces roles and responsibilities of elected Members and officers including Codes of Conduct and Member/Officer Protocols. 

2.5 Ensure that all newly-elected councillors complete mandatory corporate parenting, safeguarding and Equalities, Diversity and Inclusion (EDI) training as part of their induction and have refresher training each year for the duration of their term (Recommendation 2).

2.6 Review mandatory training requirements for elected Members and the process for monitoring completion, ensuring non-compliance is appropriately reported via formal mechanisms (including to Standards Committee and Cabinet) (Recommendation 2).

2.7 Continue to ensure annual refresh of Register of Interests by elected Members.

Ongoing

By April 2022

By December 2022

By April 2022

By April 2022

By April 2022

Annually

We will maintain robust political leadership and accountability, founded on a sound understanding of our corporate parenting responsibilities, and we will provide appropriate oversight in line with the democratic processes of the council.

As elected Members, we will ensure that the interests of children and young people in care are paramount and that we create a culture of honesty, openness and transparency.

2 Political Leadership and CultureACTIONS WHENCOMMITMENTS

Lambeth Council IICSA Action Plan (DRAFT) / page 16

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3.1 Oversight of our Action Plan by elected Members will ensure accountability, challenge and scrutiny: the Council, Youth Council, the Leader, Cabinet, Lead Member for Children’s Services, Scrutiny Committees, Corporate Parenting Board and Children in Care Council will scrutinise and help strengthen our Plan through our existing democratic and governance processes throughout delivery of the Action Plan.

3.2 Oversight and responsibility for delivery of our Action Plan by the Chief Executive, the statutory Director of Children’s Services and senior leadership team will ensure accountability, challenge and scrutiny.

3.3 Focus our new Organisational Development Strategy to instill the right cultures and processes and enable effective monitoring of performance against our objectives. 

3.4 Continue the development and implementation of our Equalities, Diversity and Inclusion Action Plan, to ensure that the council has a recognised culture and practices which empower staff to flag and challenge discriminatory practice so that they can be effective advocates within our communities and to those who use our services. 

3.5 Provide mechanisms for Black children and their families to share their lived experiences of the care system with senior leaders and elected Members to sensitise and reduce the distance between senior leaders and elected Members and the people they serve. 

Ongoing

Ongoing

By April 2022

Ongoing

Ongoing

We will maintain robust corporate and political leadership and accountability, founded on a sound understanding of our corporate parenting responsibilities.

We will embed a culture of constructive challenge within our leadership teams.

We will maintain clear Member oversight, scrutiny and challenge in line with our democratic processes.

3 Leadership and AccountabilityACTIONS WHENCOMMITMENTS

Lambeth Council IICSA Action Plan (DRAFT) / page 17

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4 Organisational CultureACTIONS WHENCOMMITMENTS

4.1 Design and hold an annual day of reflection, relevant to all staff and councillors, so that the learning from past events lives in the corporate memory of staff and councillors with a determination for it never to happen again.

4.2 Ensure our staff and councillors are appropriately informed and involved in our response to and actions resulting from the IICSA report through regular and repeated internal and external communications that also promote a culture of shared corporate safeguarding responsibility and ensure understanding of how best to act where concerns are identified.

4.3 Ensure a transparent, inclusive, accountable, user-centred and collaborative culture continues to develop through delivery of our Organisational Development Strategy, and is evidenced in a systematic and measurable way that we can monitor.

4.4 Ensure councillors and senior officers operate in an environment of supportive challenge to ensure issues and concerns can be voiced in line with the Nolan Principles of public office: Selflessness, Integrity, Objectivity, Accountability, Openness, Honesty and Leadership.

4.5 Reinforce roles and responsibilities of councillors and officers including Codes of Conduct and Member/Officer Protocols in induction training for new staff.

4.6 Ensure that our industrial relationship practices and working relationships with the trade unions operate effectively and fit with robust principles of transparency and accountability.

4.7 Work with Lambeth trade unions and their national organisations to ensure robust processes are in place that provide appropriate separation between trade unions, councillors and officers, always placing the safety of children above the interests of individual trade union members.  

4.8 We will adopt an integrated reporting dashboard to monitor performance on our organisational development objectives. This will provide a clear picture of the extent to which we have achieved:l a culture of listening to children, carers and staff l a culture of constructive and supportive challenge that is a welcome part of the way we work l a high level of confidence in the organisation in whistle-blowing as a necessary controll effective management of complaintsl a culture of honesty and support for staff and each otherl organisational clarity regarding the different roles of members and of officers, through inductions and ongoing training.

By July 2022

Ongoing

By March 2025

Ongoing

By May 2022

By March 2023

By March 2023

By September 2022

We will continue to promote a culture of respect, listening, challenge and learning across the council; ensuring our officers and councillors are encouraged to be curious and not complacent.

We will make sure the voices of children and young people in care are heard throughout the organisation at all levels and are at the heart of our decision-making.

Lambeth Council IICSA Action Plan (DRAFT) / page 18

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5 Oversight and AssuranceACTIONS WHENCOMMITMENTS

5.1 Review all existing performance reporting mechanisms to senior leaders charged with governance to ensure they are fit for purpose. Produce a quarterly report on all additional assurance processes to Management Board, Cabinet and the Corporate Committee.

5.2 Ensure information sharing processes and protocols for senior managers about individual children and allegations against professionals with Lead Member for Children’s Services are embedded within existing governance and processes.

5.3 Undertake review of systems and processes for commissioning to ensure good oversight of commissioned placements.

5.4 Ensure alignment of quality assurance processes for non-regulated placements for care leavers with processes for regulated placements for consistency.

5.5 Commission research and testing of the cultural competency of our social care practices to identify and address impacts of racism within the system. 

5.6 Commission the Local Government Association to undertake a peer review of organisational culture for the council, focused on our leadership and working culture.

5.7 Commission the Lambeth Safeguarding Children Partnership to undertake scrutiny of the impact of actions relating to the safeguarding of children and young people in care in this Action Plan.

 

By June 2022

Completed May 2021

Completed June 2021

Completed September 2021

By December 2023

By July 2023

By January 2024

We will have effective corporate and political oversight and assurance that strengthens safeguarding of our children in care and care leavers.

We will maintain and build on the mechanisms that enable clear line of sight for senior leaders and councillors. We will continue to ensure that our assurance bodies, including scrutiny committees, function effectively and provide challenge.

Lambeth Council IICSA Action Plan (DRAFT) / page 19

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6 Social Care Practice and Performance for Children Looked AfterACTIONS WHENCOMMITMENTS

We will make sure our children and young people are placed in safe and stable homes where they can thrive and achieve their potential.

Our children and young people in care benefit most from having a stable and skilled social care workforce. Our Children’s Social Care Workforce Development Strategy will enable this and we will ensure our social care staff have access to the resources and training to equip them to provide effective, timely, and appropriate help to children and young people.

Lambeth Council IICSA Action Plan (DRAFT) / page 20

6.1 Ensure that all children and young people know who to contact if they are ever concerned about an adult’s interaction with them and are confident to do so.

6.2 The Lambeth Safeguarding Children Partnership (LSCP) to commission an audit into harmful sexual behaviour.

6.3 Implement recommendations of the LSCP Harmful Sexual Behaviour Audit to ensure children and young people who report harmful sexual behaviour, are supported and responded to appropriately by partners such as health, education, police and others.

6.4 Ensure placements outside of the borough are reviewed to ensure that children and young people in care are receiving the same high level of care no matter where they are placed.

6.5 Deliver appropriate multi-agency training annually on core communication methods for children with complex needs and communication difficulties.

6.6 Deliver our Fostering Recruitment Strategy (2020 – 2023) that will enhance the support and training of foster carers in providing safe and stable homes.

6.7 Ensure guidance for social workers on how to respond to children who report sexual abuse includes requirement for harm reduction actions to be taken, and they are monitored within audits.

6.8 Ensure our Workforce Development Strategy for Children’s Social Care supports and integrates with our social workers’ personal development plans and continuing professional development, so they can achieve the best outcomes for our children and young people.

6.9 Expand our social care audit capacity and embed our new Quality Assurance Framework and audit cycle so that we have enhanced oversight of practice and the subsequent learnings.

6.10 Work with partners to identify and challenge practices which un/wittingly increase the risk and trauma of statutory interventions resulting in negative outcomes for our children and families.

6.11 Strengthen our document management system and processes to ensure our children’s records are maintained digitised and accessible.

6.12 Expand our in-house foster care service to reduce the demand on commissioned and out of borough placements through delivery of our Sufficiency Strategy (2020 – 2023).

Ongoing

Completed October 2021

By April 2023

Completed May 2021

Annually

By August 2023

By January 2022

By April 2022

By April 2022

Ongoing

By April 2023

By November 2023

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7 Corporate Parenting and SafeguardingACTIONS WHENCOMMITMENTS

7.1 Review effectiveness of our corporate parenting governance arrangements including our Children in Care Council to improve outcomes for our children looked after and care leavers and develop a clear governance and delivery structure.

7.2 Review the Constitution to strengthen corporate parenting responsibilities and reflect the Corporate Parenting Pledge all newly-elected councillors sign.

7.3 Deliver our Corporate Parenting Strategy (2021 – 2024) and listen to our children and young people to ensure our children looked after and care leavers have the right services and support in place to meet their identified needs and achieve good outcomes.

7.4 Update and implement a refreshed Corporate Safeguarding Policy for staff and councillors to ensure they understand that safeguarding is everyone’s responsibility.

7.5 Deliver refreshed corporate parenting and safeguarding training for all staff and embed refresher training in the corporate training offer for the duration of their employment.

7.6 Develop a corporate parenting handbook for councillors to support them in carrying out their duties as corporate parents, including those who are the thematic champions for early years, health and wellbeing, voice of the child, fostering and adoption, education employment and training, housing and care-experienced young people.

7.7 Develop a corporate parenting reporting dashboard to enable scrutiny of our performance against the Corporate Parenting Strategy.

Completed September 2021

By April 2022

By April 2024

By April 2022

By April 2022

Completed July 2021

CompletedJuly 2021

We will make sure we maintain and enhance effective governance processes which both enable our leaders to discharge their corporate parenting responsibilities in line with the Corporate Parenting Principles and hold them to account.

We will foster increased council-wide awareness of our corporate parenting role and how safeguarding is everyone’s business. We will provide a robust training offer for staff and councillors with clarity on how senior officers and political leaders should execute their responsibilities as corporate parents.

Lambeth Council IICSA Action Plan (DRAFT) / page 21

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8 HR Processes and Management of AllegationsACTIONS WHENCOMMITMENTS

8.1 Ensure the process for raising concerns about risk or harm to a child from a person who works with children – our Local Authority Designated Officer (LADO) process – is well-promoted and supportive of people who make an allegation.

8.2 Review and update our Recruitment and Vetting Policy to reflect our existing safer recruitment practices. 

8.3 Make sure our current staff working with children, our councillors and our foster carers have appropriate and up-to-date DBS (Disclosure and Barring Service) certificates, and implement an online DBS process that enables better monitoring of compliance in line with safer recruitment practice (Recommendation 3).

8.4 Review our Disciplinary Policy and key HR policies to ensure that we have robust processes when concerns are raised about risk of harm to a child.

8.5 Continue to ensure our commissioned services and placements have robust safer recruitment practices in place for staff working with children and young people.

8.6 Update our Whistleblowing Policy to include specific reference to safeguarding and promote awareness with our staff, partners and public.

8.7 Implement an annual refresh of the staff Declaration of Interests, that will be monitored and recorded on employment records.

8.8 Reinforce Staff Code of Conduct with staff on regular basis.

8.9 Improve staff exit interview completion rates and incorporate lessons learned from exit interviews into assurance reports to our leadership team.

8.10 Review requirements for DBS checks for elected Members to ensure alignment with regulations. Refresh policy and roll out new requirements following elections in May 2022.

Annually

Completed July 2021 

Completed October 2021

By April 2022

By April 2022

By January 2022

By April 2023

By April 2022

By April 2023

By May 2022

We will maintain robust processes in place to manage allegations against individuals working with children. We will ensure all staff, and those employed by external and commissioned providers, are recruited and vetted through safer recruitment procedures, that prioritise safeguarding. We will ensure that staff, providers and partners are aware of Lambeth’s Whistleblowing Policy and staff are able to raise concerns outside of their line management and organisation where necessary.

Lambeth Council IICSA Action Plan (DRAFT) / page 22

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Annex 4 to the IICSA Investigation Report

Recommendations proposed by Core Participants

Lambeth Council IICSA Action Plan (DRAFT) / page 23

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A number of witnesses, including all complainant and victim core participants, were invited by IICSA to provide their views about any practical recommendations to prevent child sexual abuse in the future and to improve the response to such allegations.

Although Lambeth is not required by IICSA to respond to the recommendations in Annex 4, the Council has considered and set out its response noting where existing legislation, guidance, practice or the Action Plan addresses each recommendation. Three of the recommendations require a change in legislation by government and IICSA has indicated it may revisit them in their final report due to published in summer 2022.

Lambeth Council IICSA Action Plan (DRAFT) / page 24

Annex 4 to the IICSA Investigation Report

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LAMBETH COUNCIL RESPONSEPROPOSED RECOMMENDATION BY WITNESS/ CORE PARTICIPANT

1. Mandatory reporting of child sexual abuse

There should be a statutory duty to report suspected and actual cases of child sexual abuse; a clear and unambiguous legal requirement to report abuse and reasonable suspicion of abuse, breach of which can give rise to criminal sanctions.

2. Mandatory training of elected councillors

Newly elected councillors should be given mandatory training on corporate parenting and safeguarding of children.

Councillors should also be trained in institutional racism and cultural differences.

3. Regulation of social care staff

Regulation of the children’s home workforce is urgently needed for social care workers. There should be an overarching local authority regulator or national safeguarding body that is able to compel action and impose financial sanctions on local authorities which are in breach of their statutory duties towards and causing harm to children.

Lambeth Council IICSA Action Plan (DRAFT) / page 25

This would require a change in legislation given at present, in England, there is no legal requirement on those working with children to report known or suspect child abuse or neglect. However, the statutory guidance Working Together to Safeguard Children (2018), states that “anyone who has concerns about a child’s welfare should make a referral to local authority children’s social care and should do so immediately if there is a concern that the child is suffering significant harm or is likely to do so.” While statutory guidance does not impose an absolute legal requirement to comply, it requires practitioners and organisations to take it into account and, if they depart from it, to have clear reasons for doing so. Some professional bodies also require their members to report any concerns about a child’s safety or well-being. A professional’s failure to adhere to such standards or codes of conduct may result in misconduct or fitness to practise proceedings against them.

IICSA have indicated they will return to this issue in their final report due to be published in summer 2022.

Training for councillors on corporate parenting and safeguarding is in place and will be mandatory. This recommendation has been incorporated into the Lambeth IICSA Action Plan, Equalities, Diversity and Inclusion (EDI) training will be mandatory (Action 2.5).

This recommendation is for IICSA/Government to consider as would require change in law.

Lambeth no longer directly provides residential care but instead commissions this, primarily from the independent sector. Ofsted’s role as the regulator of independent provision is clearly crucial in ensuring high quality provision and well trained and supported residential staff.

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LAMBETH COUNCIL RESPONSEPROPOSED RECOMMENDATION BY WITNESS/CORE PARTICIPANT

4. Training of social care staff

Social workers should have proper training and qualifications.

Foster carers should have better training regarding child care in general.

All social care staff and foster carers should be given training on how to deal with concerns about potential abuse, disclosures of abuse, how to identify the signs of child sexual abuse and what to do to address it.

Each child should have access to abuse prevention programmes and to social workers with expertise in child sexual abuse and substance abuse. 5. Vetting of social care staff and foster carers Stringent background checks should be carried out for all those people working with children, including social workers, foster carers and the individuals entering children’s homes as visitors.

Background checks should be regularly updated.

Lambeth Council IICSA Action Plan (DRAFT) / page 26

All social workers are trained and qualified; the professional governing body, Social Work England require them to demonstrate Continuous Professional Development (CPD) and to keep their training up to date. In Lambeth, we provide a comprehensive training programme to all social workers to meet continual professional development requirements.

Foster carers are required to undertake training and development as set out in the National Minimum Standards for Foster Care. There has been a focus on rolling out more trauma-based practice training to foster carers. Foster carers approved by Lambeth need to demonstrate ongoing personal development through an agreed Personal Development Plan (PDP). If carers do not adhere to ongoing development, supported by their signing of the Foster Carer Agreement, then their approval as a foster carer will be reviewed. Independent Fostering Agencies also need to adhere to the National Minimum Standards. All social workers are trained in child sexual abuse and there is guidance in the London Child Protection Procedures and Practice Guidance that they have to follow. As part of our annual training needs analysis and strategy, we provide our social workers the opportunity to enhance their learning and skills in this area. We also have a bespoke forum facilitated by a multi-disciplinary team at the South London and Maudsley NHS Trust to support to social workers and other professionals in assessment and intervention of children presenting with harmful sexual behaviour. All children in care have an allocated social worker who is trained in responding to child sexual abuse, and an Independent Reviewing Officer who sees them alone to promote safety.

All staff and foster carers who work directly with children are required to undergo stringent checks via the Disclosure and Barring Service which are updated regularly. In addition, councillors also undergo regular checks. Children’s homes are responsible for managing and monitoring visitors in line with their statutory duties and guidance.

All checks on staff, foster carers and councillors are updated every three years.

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Lambeth Council IICSA Action Plan (DRAFT) / page 27

6. Monitoring of children and placements

There should be intensive monitoring of children placed in care. Children’s homes and foster placements should be subject to regular visits by independent experts.

A child’s behaviour should be carefully observed. Systems should be put in place to record changes in behaviour and to examine whether behavioural issues, such as absconsion, are indicative of sexual or other abuse.

Lambeth Council does not manage any children’s homes. Residential placements are commissioned through independent providers. Social workers visit children in care within one week of the child being placed in the children’s homes and then regulations provide once every 6 weeks for the first year, however in Lambeth we do this on a 4-weekly basis. In addition, the Independent Reviewing Officer visits prior to a review within 20 days of a child coming into care, then at 3 months and then every 6 months. Under regulation 44 of the Children’s Homes Regulations 2015, ‘Independent Persons’ visit children’s homes at least once a month. They are able to interview in private (with their consent) children, their parents, relatives and staff working at the home. They must produce a report on whether children are effectively safeguarded and how the home is being run which is sent to Ofsted as well as the local authority where the home is located and the local authority from where the children are placed. In addition, children’s homes are regulated and subject to visits and annual inspections by Ofsted. Every foster carer has a supervising social worker. For short term foster carers, supervising social workers visit every 3 weeks, for long term foster carers this is every 6 weeks. In addition, they have the child looked after visits by the child’s allocated social worker and Independent Reviewing Officer just as the council undertakes when children are placed in children’s homes.

We have a designated Missing Person Coordinator who works in liaison with the Lambeth Child Sexual Exploitation Coordinator. Every time a child goes missing from a placement, they are offered a return home interview to find out where they went and any underlying reasons for running away. Any changes of behaviour are subject to ongoing assessments. We have enhanced the service by employing youth workers to carry out return to home interviews where the young person may be reluctant to talk to a social worker. The role of the CSE Coordinator, is to ensure sure that social workers are able to identify all children, including those who are looked after, who are at risk of child sexual exploitation. Monthly reports are provided to senior managers so that they are aware of concerns. There are also a number of other related processes and practices which are explicitly focussed on keeping children and young people in care safe.

LAMBETH COUNCIL RESPONSEPROPOSED RECOMMENDATION BY WITNESS/CORE PARTICIPANT

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There is statutory guidance for surveillance and monitoring in children’s homes. Surveillance and monitoring in residential childcare settings – GOV.UK (www.gov.uk)

Social workers are contactable during the daytime, or in their absence their team managers are contactable. We also have an out of hours social work service for any emergency requirements, that operates 365 days a year.

All social workers are trained in safeguarding policies and procedures. Practice evaluations and audits demonstrate that these are implemented in practice.

Guidance on how to investigate child sexual abuse is set out in London Child Protection Procedures and Practice Guidance which must be adhered to. https://www.londoncp.co.uk/

Under the Children Act 1989 duties, for all children we try and place them in family settings, but where this is not possible or appropriate, they may be placed in foster care or residential children’s homes. Children are involved in decision-making subject to their age and understanding. The children looked after reviewing process ensures decisions/action plans are completed. We have a variety of foster placements in different locations to meet a range of needs in line with our Sufficiency Strategy.

6. Monitoring of children and placements

Children’s homes should have CCTV in order to monitor and evidence any abuse that takes place in these homes.

Social workers should be contactable at any time so that the child may have support in an emergency.

7. Implementation of safeguarding policies

Policies and procedures should be in place to safeguard children. They must be actually implemented.

Policies should include training for staff regarding child sexual abuse, including an action plan regarding how to investigate allegations of such abuse.

8. Care planning

Children should not be kept for long periods in children’s homes.

Children should be involved in decisions about their lives and who will care for them. Specific action decisions about a child must be carried through. Foster placements should not be physically isolated.

Lambeth Council IICSA Action Plan (DRAFT) / page 28

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Lambeth actively monitors placement moves for children and reviews the data on this every month. In some instances, a child moves a placement for a positive reason, in other cases it is due to a placement breakdown. Managers oversee cases where there are placement breakdowns by looking at support needs of the placement to try and stabilise the placement and reduce further moves. Lambeth have a Workforce Board which is developing measures to retain a stable workforce and reduce staff turnover.

All children in care have an allocated social worker. They also have an Independent Reviewing Officer.

We have multiple mechanisms through which children and young people’s voices can be heard so that they can feel empowered to share their experiences. As part of our Action Plan, we are committed to amplifying their voices to ensure that ‘organisational listening’ is embedded in our working culture. Addressed in the Voice of the Child theme in Action Plan (Action 1.4), Lambeth commissions an Independent Advocacy service to provide this.

Children and young people in care have access to Independent Advocates. They also have access to their social worker and Independent Reviewing Officer. All children are advised how to make a complaint through a trusted adult in their support network. The Council has a statutory duty to promote contact between children in care and their families, which is reviewed on an ongoing basis to ensure it meets the needs of children.

8. Care planning

There should be a reduction of multiple moves between care and foster placements. Constant moves undermine stability and any trust a child can have in the people around them. This further reduces the possibility of a child feeling able to tell anyone about abuse. Similarly, there should be limited staff turnover, which is also disruptive.

9. Allocated social workers

Children in care should always have an allocated independent social worker. The social workers should work closely with the children they are assigned to so that the children can build trust and confide in them.

10. Voice of the child and responding to allegations of child sexual abuse

The approach to children placed in care should be child-centred. The child, his or her experience and their feelings about where they are should be at the centre of institutional work around children. The child’s feelings have value; their pain matters. Children in local authority care should have access to someone independent who can have independent meetings with the child. Children need someone who can act as an independent sounding board – like a nurse, or an advocate; someone the children can speak to.

There should be a support network around each child and more than one avenue by which a child can make a complaint. Keeping children connected to wider family members also reduces their vulnerability.

Lambeth Council IICSA Action Plan (DRAFT) / page 29

LAMBETH COUNCIL RESPONSEPROPOSED RECOMMENDATION BY WITNESS/CORE PARTICIPANT

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There is statutory guidance for multi-agency co-operation between the council, police and other agencies, when an allegation is made. The steps to be taken to safeguard children will include review of any ongoing contact with the alleged perpetrator pending investigation. If the allegation is against a member of staff, this is dealt with under our formal process to manage allegations under the Local Authority Designated Officer process. If the allegation is against an adult, then it will be investigated under London Child Protection Procedures and Practice Guidance.

If a child displays harmful sexual behaviour to another child, the social worker is required to follow the procedures set out in the London Child Protection Procedures and Practice Guidance. https://www.londoncp.co.uk/ch_harm_others.html?zoom_highlight=harmful+sexual

Procedures are in place to ensure children feel supported and safe to report abuse. Children are spoken to in a safe place on their own, and they will be supported to give evidence following the Achieving Best Evidence in Criminal Proceedings guidance, which sets out guidance on interviewing victims and witnesses, and guidance on using special measures for children with communication difficulties. We will also provide them with an advocate and therapeutic support.https://www.cps.gov.uk/sites/default/files/documents/legal_guidance/best_evidence_in_criminal_proceedings.pdf Under the Children Act 1989, the child’s welfare is paramount and must be safeguarded. There are clear procedures that all professionals must follow when abuse is reported. All professionals take allegations seriously and investigate them thoroughly in liaison with the Police. Under the Children Act 1989, it is a statutory requirement for the Council to have an established complaints process which along with child protection procedures requires timely and accurate record keeping.

10. Voice of the child and responding to allegations of child sexual abuse

lf a child reports any allegations of sexual abuse, immediate investigations should be carried out with coordination and cooperation between childcare authorities and the police. The alleged abuser must be stopped immediately from ongoing contact with children.

The child should be questioned in a safe environment away from their caregivers to ensure they feel able to share. A child should never be punished for disclosing abuse. Rather, he or she must feel they will be protected if they come forward to disclose sexual abuse.

Children should be listened to properly when abuse is alleged. Authorities are too quick to dismiss children when they speak out about their sexual abuse. Simple disbelief causes long-term psychological damage.

All complaints should be effectively documented by those to whom they are reported.

Lambeth Council IICSA Action Plan (DRAFT) / page 30

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The Achieving Best Evidence in Criminal Proceedings Guidance ensures this.

This recommendation is for the Police.

Children are offered counselling and support through the Children Looked After Mental Health Service (CLAMHS), a multi-disciplinary team that provides assessment, care and intervention for children and young people in care, up to the age of 18.

Children are offered support through our Children Looked After Mental Health Service.

Statutory responsibilities for children leaving care extend to up to 25 years of age. Advice and support that must be provided to care leavers is set out in the Children & Social Work Act 2017.

Lambeth has an established Complaints process and allegations which is a statutory requirement. The Complaints Team have a leaflet for children which was co-produced with children in care.

Team managers and social workers provide these leaflets to children and young people and provide links on the Council’s website to enable them to make a complaint. All children and young people in care wishing to make a complaint are also offered the support of an Independent Advocate. We have an annual report on Children’s Complaints that is reported to elected Members which enables us to learn lessons to improve accessibility, our communications about the complaints service, and to improve our services.

10. Voice of the child and responding to allegations of child sexual abuse

When police interview a child, someone should be present who has experienced abuse and can understand the child and ensure they are treated with respect. Protocols and guidelines are implemented to promote transparency within police investigations. Counselling and other support should be provided to a child who has made an allegation of abuse. The counselling provided ought to be by an organisation or agency that has specialist expertise in working with young people who have been affected by and experienced sexual abuse.

Support should also be provided to the victim or survivor after he or she has spoken to police or participated in a trial. After care support is vital. Care leavers should be provided with proper support to cover basic human necessities. At minimum, the authorities must ensure care leavers have somewhere to live and to cook.

There should be a transparent child-centred complaints procedure in place that is understood by children, staff, volunteers and families. The complaints policy must outline roles and responsibilities, approaches to dealing with different types of complaints and obligations to act and report. Complaints must be taken seriously, responded to promptly and thoroughly, and reporting, privacy and employment law obligations met. Children, staff, volunteers and families should know who to talk to if they are worried or are feeling unsafe. Information should be provided in accessible, age-appropriate and meaningful formats to children and families who use the service, mindful of their diverse characteristics, cultural backgrounds and abilities.

Lambeth Council IICSA Action Plan (DRAFT) / page 31

LAMBETH COUNCIL RESPONSEPROPOSED RECOMMENDATION BY WITNESS/CORE PARTICIPANT

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Lambeth has provided written legal submissions dated 26 August 2020 to the Inquiry on this issue. IICSA has stated it will revisit the issue in their final report due to be published in summer 2022 and would also require a change in law by government.

11. Revision of section 9 of the Children Act 1989

Section 9 of the Act restricts the powers of a court so that it may not make orders under section 8 of the Act in respect of children who are in care. Section 8 orders include contact orders, residence orders, prohibited steps orders and specific issue orders. Removing the statutory restriction set out in section 9 would reduce the discrimination between children in care and those not in care.

Lambeth Council IICSA Action Plan (DRAFT) / page 32

LAMBETH COUNCIL RESPONSEPROPOSED RECOMMENDATION BY WITNESS/CORE PARTICIPANT

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Glossary

Lambeth Council IICSA Action Plan (DRAFT) / page 33

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A – Z

Lambeth Council IICSA Action Plan (DRAFT) / page 34

C CabinetThe group of councillors, chosen by the Leader of the Council to lead on specific policy areas. A Cabinet member may also be referred to as a ‘Lead Member’.

Children in Care CouncilA group of children looked after and care leavers who share their own experiences of  being in care and advocate for other children looked after. They ensure children and young people are heard and included when decisions are being made. Lambeth’s Children in Care Council is called ‘Visions of Success (VoS).

Children looked afterA child is looked after if they are in the care of, or provided with accommodation by a local authority for more than 24 hours. Children looked after may also be described as being ‘in care’.

Code of ConductA document providing a clear set of standards with regards to conduct, attitude and behaviour.

Constructive challengeA culture of constructive challenge occurs when staff feel confident in expressing their views including talking truth to power in a way that leads to positive change and not to conflict.

Core Participant (IICSA) An individual or an institution that played, or may have played a direct or significant role in relation to the matters to which the Inquiry relates; has a significant interest in an important matter to which the Inquiry relates; or may be subject to explicit or significant criticism during the Inquiry proceedings or in a report prepared by the Inquiry.

Corporate Parenting When a child or young person becomes looked after, parental responsibility transfers to the local authority; this is referred to as corporate parenting.

Corporate Parenting BoardCorporate Parenting Board assists the Council in fulfilling its obligations and responsibilities towards children looked after and care leavers and ensures ongoing improvements for them, in consultation with our Children in Care Council.

Corporate Parenting PledgeLambeth’s set of promises that give ‘children looked after and young people the guarantee that we’ll provide consistent support to improve their life chances and quality of life’.

Corporate Parenting PrinciplesA set of seven nationally agreed principles that guide how we carry out our role as corporate parents, including taking into account the views, wishes and feelings of our children and young people and

promoting high aspirations for those children and young people.

Corporate safeguardingLambeth’s approach to safeguarding across all council services, ensuring all officers and elected members fulfil their duties and responsibilities to safeguard and promote the welfare of children, young people and adults at risk of abuse, neglect and exploitation.

Cultural competency Sensitivity to cross-cultural differences and the ability to adapt to other cultural environments, or awareness of cultural influences on a person’s thoughts and behaviours.

D Disclosure and Barring ServiceThe Disclosure and Barring Service (DBS) helps employers make safer recruitment decisions by processing and issuing DBS checks on spent and unspent convictions, cautions, reprimands and warnings that are held on the Police National Computer.

E Exit interviewAn interview held with an employee about to leave an organisation, usually in order to understand their reasons for leaving and discuss their experience of working for the organisation.

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Lambeth Council IICSA Action Plan (DRAFT) / page 35

F Fostering Recruitment StrategyLambeth’s approach to attracting and retaining foster carers to deliver high quality placements that meet our children’s needs.

H Harmful Sexual BehaviourHarmful sexual behaviour (HSB) is developmentally inappropriate sexual behaviour which is displayed by children and young people and which may be harmful or abusive. It can be displayed towards younger children, peers, older children or adults. It’s harmful to the children and young people who display it, as well as those it is directed towards.

I Independent Visitor & Advocacy ServicesVolunteers who are matched with a child or young person looked after, to provide friendship and support or to help children and young people looked after understand their rights and become more involved in important decisions about their lives.

InductionThe process a new member of staff goes through to be introduced to the company and their new role.

Integrated dashboardA data visualisation tool that tracks, analyses, and displays performance, metrics, and data points from a multiple range of data sources.

LLambeth Safeguarding Children Partnership (LSCP)The LSCP is a group of statutory and voluntary organisations working with and for children and young people in Lambeth with the goal of helping every child to realise their talents, achieve their full potential, have healthy lives and be safe.

M Management BoardLambeth’s most senior officers responsible for managing the organisation, led by the Chief Executive. 

Member (elected)A person who has been elected by the people in a particular area to represent them within the council. Members are often also referred to as ‘councillors’.

Member / Officer ProtocolsA framework for the interaction between elected Members and officers, in order to ensure that the Members and officers work together effectively and efficiently to conduct the business of the Council.

N Nolan Principles of Public Office The Nolan Principles are a set of seven principles outlining the ethical standards those working in the public sector are expected to adhere to. They are also sometimes called The Seven Principles of Public Life.

O Organisational Development StrategyA planned approach to improve organisational performance through aligning strategy, people and processes. The strategy provides a framework to address issues such as skills, culture and leadership.

P Peer ReviewA review of a process or service by organisations who have current or previous experience in that sector, to provide challenge, support and guidance on specific areas or issues.

Process reviewAn assessment of how a current process is being carried out and the identification of how this could be improved.

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Lambeth Council IICSA Action Plan (DRAFT) / page 36

Q Quality assuranceThe systematic and regular monitoring and evaluation of social care practice, with the aim of improving, to achieve better outcomes for children and families.

R Register of InterestsA record kept of any business or personal interest that may influence how an officer or elected member carries out their role, particularly in decision making and financial matters.

S Staff Code of ConductA document providing a clear set of standards for staff so that they know what is expected of them with regards to their conduct, attitude and behaviour during their employment with the Council.

Supportive challengeSupportive challenge describes the skill of providing challenge in a way that makes it easier for others to accept challenge and therefore respond receptively and constructively, so that the conversation can move forward to solutions.

U UNICEF Child Friendly LambethA UNICEF led initiative Lambeth is working on that helps communities make sure the voices, needs, priorities and rights of children are an integral part of public policies, programmes and decisions.

W Whistleblowing PolicyA framework to encourage staff to feel confident raising concerns about any aspect of the Council’s work, without fear of victimisation, subsequent discrimination or disadvantage.

Witness (IICSA)Someone who provides evidence to the Inquiry. For example, a witness may provide the Inquiry with a witness statement or documents. Witnesses may also be asked to attend to give oral evidence during a public hearing.

Workforce Development StrategyLambeth Children’s Services Workforce Development Strategy sets out the objectives and activities needed to support the social care workforce in achieving positive outcomes for our children and families.

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Proposal Title *

IICSA Action Plan

Author

Eibhlin McInerney

Lucy Sawyer

Please provide name of lead author and/or those within project team who may be required to contribute to this assessment

Who will sign off the assessment?

Paul Bates

Please indicate who will be involved in approving this assessment. This will need to be signed off by the Director

Q1a. What is changing?The council is developing and implementing an action plan in response to the July 2021

report regarding Lambeth, published by the Independent Inquiry into Child Sexual Abuse

﴾IICSA﴿. The action plan is one of the key recommendations made in the report, alongside

the suggestion that the action plan be published within six months of the report date.

The action plan encompasses a diverse set of actions and deliverables separated into

seven thematic groupings to ensure that the findings and recommendations from the

report are fully addressed. These include Voice of the Child and Organisational Culture.

Primarily the action plan will be delivering cross‐council assurance and service

improvement activities, along with significant culture change. The focus of these activities

is on reviewing, quality assuring and where necessary updating processes, practices and

procedures already in place. Actions will be undertaken by the organisation through

existing service operations and change programmes.

The key objective of the action plan is to ensure children's views and voices and their safety

is truly at the heart of our decision‐making at all levels of the organisation. The action plan

aims to achieve this by:

reflecting the learnings from our past failures to children in our care;

strengthening the current processes, policies, systems and procedures that safeguard

children in our care and care leavers;

strengthening our leadership and governance and,

transforming our organisational and political culture.

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What is the most significant or key change taking place? Can you indicate the type of change in your response ﴾e.g.policy/decision/strategy/ service/procedural/ geographic/procurement etc.﴿ so it is clear what is being equalitiesassessed? Why is this change happening? What do you aim to achieve? Can you clearly indicate what decision‐makersare being asked to take a decision on?

Read more

Here you will need to describe clearly and briefly what this change is about ﴾i.e. service change, policy review/update,decision﴿? Compared against what we do currently, what will be different? Can you explain what will happen if this isapproved and when will it be implemented? How will the EIA inform your business case, tender specification, forexample?

Q1b. Who will be involved in approving this decision?Cabinet, the Leader, Lead Member for Children's Services, Strategic DirectorChildren's Services, Chief Executive

Who else will be involved in signing‐off this decision?

Read more

Please detail any project sponsors, ﴾Head of Service, Directors cabinet member/s, legal, partners﴿ Note: Any reportsthat go to anyone needing to take decisions must refer to this equalities analysis so they can consider the effects ofthe proposals on different groups before and during decision‐making.

Q2a. What do we know about the people who will be impacted by thischange?Key stakeholder groups identified as being potentially impacted by theimplementation of the action plan:

Children looked after

We hold data including protected characteristics on all children looked after.The data held shows that a disproportionately high number of children inour care are from Black, Asian or Multi Ethnic backgrounds, whencompared to the Lambeth populace overall. In addition, significantnumbers of children in our care have a disability or additional health andeducational needs.

Of 376 Children Looked After in Lambeth ﴾July 2021﴿:

55% are male and 45% are female11% are Unaccompanied Asylum Seeking Children30% have a disability52% are Black, Black British, 24% mixed origin, 16% White, 4%Other/not stated, 3% Asian, Asian British87% are in good or outstanding schools27% have an Education, Health and Care Plan35% have a mental health assessment score showing cause for

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concern and triggering referral to Children Looked After Mental HealthService

Care leavers

We hold data including protected characteristics on young people whohave left the care of Lambeth. Similarly to data held on children lookedafter it reflects a high proportion of young people from Black, Asian orMulti Ethnic Backgrounds.

Of 370 Care Leavers in Lambeth ﴾July 2021﴿:

66% are male and 34% are female25% have a disability62% are Black, Black British, 14% mixed origin, 16% White, 7%Other/not stated, 6% Asian, Asian British74% 17‐18 yr olds, 63% 19‐21 yr olds, 70% 18‐25 yr olds inemployment education or training85% within 20 miles 83 remained with foster carer ﴾age 18﴿, 30 remained with foster carer﴾19‐20 yr olds﴿86% 17/18 in suitable accommodation80% 19‐21 in suitable accommodation

Councillors

EDI information held on councillors is limited to age and sex, with themajority of councillors being male.

All council staff

EDI information including protected characteristics is held on all councilstaff. This shows the majority of the workforce identifying as Black, Asianof Multi Ethnic and the majority of the workforce as female. There arerelatively low numbers of council staff with a disclosed disability or LGBTQ+identity.

59% of the workforce identify as being Black, Asian or Mutli Ethnic60% of the workforce identify as female9.6% of the workforce have disclosed having a disability8% of the workforce have disclosed that they identify as LGBTQ+

Commissioned services and contractors

We do not hold EDI data on our commissioned services or contractors.

What does your information tell you about the people who will affected by this change? Are protected groupsimpacted? What information do you hold on the protected characteristics of the people affected by the change? ﴾Age,disability, gender reassignment, pregnancy and maternity, race/ethnicity, religion or belief, gender, sexual orientation,health, socio‐economic, language﴿ Are there any gaps or missing information?

Read more

This is an opportunity for you to share what you understand about the people who will be affected by what is beingproposed whether now and/or potentially in the future. Do you know whether they are from protected groups? What

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does you service level profile data tell you about them? What if anything does your current and previousconsultations, surveys, complaints, contract monitoring data, equalities data monitoring ﴾including from partners andother service areas﴿ reveal about these people and their needs or issues that may be connected/relevant to thischange? Are there any gaps in your data? If yes, please note we are under a legal duty to be properly informed beforemaking a decision. If the relevant data is not available we are under a duty to obtain it and this will often mean someconsultation with appropriate groups is required. You will need to provide a reason or justification for why you havemissing data/information. You may have to address this by including plans to generate this information within youraction plan and responses to questions 3a, 3b and 4.

Q2b. How will they be impacted by the change?The action plan will be delivering service improvement, assurance, andconstructive culture change. We anticipate that this would lead to overallpositive or neutral impacts for all identified groups to varying degrees.

Children looked after and care leavers – positive impact

The overarching aims of the action plan underpin positive equalitiesimpacts for children looked after, in particular responding to the inquiryfindings that Black and ethnic minority children were overrepresented inLambeth’s children’s homes and faced additional hardships with some

subject to overt racism alongside discrimination.

We know that a high proportion of children looked after are Black, Asian orMulti Ethnic, which is disproportionately high to overall borough ethnicitymakeup. The plan makes sure we have mechanisms in place which aresensitive to and allow our children looked after to share their uniqueexperiences, impacted by their identity and intersectionality.

The plan also gives strong commitment to amplifying the voice of the childand working collaboratively to devise and monitor approaches andstrategies to safeguarding and building strong relationships.

We also expect positive impacts for our children and young people to befelt through commitments in the action plan to continue the developmentand implementation of our Equalities, Diversity and Inclusion Action Plan,and ensuring that Lambeth has a recognised culture and practices whichempowers staff to flag and challenge discriminatory practice and beeffective advocates within our communities and to those who use ourservices.

This drive toward an inclusive workforce will be crucial in delivering positiveequalities impacts for our children and young people, as consultation withchildren and young people looked after made clear that the ability to buildmeaningful relationships with social workers would enable them to feelconfident discussing experiences and increase the likelihood of making adisclosure.

Councillors – positive impact

Although we do not collect comprehensive equalities data for councillorsand so the impact of the plan on any one characteristic within this groupwould be difficult to gauge, we anticipate that the commitments within theaction plan to the ongoing development and implementation of Lambeth’sEDI action plan alongside fostering a culture of supportive challenge forcouncillors to operate within would underpin an overall positive equalities

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impact.

All council staff – positive impact

Findings from the IICSA report were clear that racism and sexism had beenissues for council staff during the periods investigated. Thusly actionswithin the plan which may impact council staff are primarily concerned withthe ongoing development of an inclusive and collaborative working culturewith transparent and supportive working practices. This is encompassed inseveral of the action plan themes, with specific actions including ongoingwork on the organisational development strategy, and EDI action plan, withnew dashboards in place to monitor progress against an honest andsupportive culture.

Not all equalities characteristics are routinely and consistently disclosed bycouncil staff, making impact in some areas difficult to assess. We anticipatehowever that the ongoing commitment to EDI and working culture withinthe action plan would lead to increased reporting in time.

Commissioned services and contractors ‐ neutral impact

Actions within the plan that involve our commissioned services andcontractors centre on continuing to improve services and outcomes for ourchildren and young people through review of current working practices andframeworks. We do not therefore anticipate there being any equalitiesimpacts affecting this group.

Would you assess the impact as positive, adverse, neutral? Do you have any uncertainty about the impact of yourproposal? Is there a likelihood that some people will more impacted than others? Can you describe the ways in whichthey will be affected? How might this change affect our ‘general duty’

Read more

Q3a. How do you plan to promote and deliver any positive impacts of theproposal?Our action plan programme will have a dedicated communicationsworkstream that will promote positive impacts of the action plan to keystakeholders, wider community and the public, with strong considerationfor the equality characteristics that have been identified.

Particular consideration will of course be given to communicating with ourchildren looked after and care leavers as the primary cohort affected by theaction plan. All actions affecting children looked after and care leavers areheld in one workstream led by Children’s Services, and we will ensurestrong collaborative working between workstreams to ensure all messagingand communication is accessible and appropriate.

Key actions within the plan which support measurement and tracking ofpositive outcomes include the development of an integrated performancedashboard to monitor progress against organisational developmentobjectives, alongside the commissioning of an independent peer review oforganisational culture within Lambeth.

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How might the principles of fairness, equality of opportunity and positiverelationships be further promoted as a consequence of this proposal? Howdo you propose to measure your positive outcomes and the benefits outlinedto find out if these have been achieved?

Read more

Is there a possibility that you will need to treat certain people differently, to enhance positive outcomes because of

greater need; disadvantage; experience of less favourable outcomes, etc.? What opportunities exist to support

Lambeth’s statutory duty to promote equalities? How does this contribute to your departmental service plan and/or

the council’s corporate priorities?

Q3b How do you plan to address and mitigate any negative impacts of theproposal?It is not anticipated there will be any negative equalities impacts as a resultof the action plan.

The action plan will be delivered using programme methodology that willundertake impact analyses as needed throughout delivery of the plan, withemphasis on the themes of Voice of the Child, Organisational Culture andSocial Work Practice.

The programme management will develop and sequence plans to optimisethe positive impacts identified and mitigate or reduce any negative impactshould it become apparent.

Dependency management will be undertaken with other related or crosscouncil programmes and projects using the Programme Performanceservice. By doing this we aim to reduce any potential negative impact ofthis action plan on others already in progress across the business. Asalthough we do not foresee any negative equalities impact from this actionplan in its own right, we must ensure it does not impede other workflowswhich may be delivering positive impacts in this area.

Risk management will be implemented in accordance with Lambeth's riskmanagement strategy.

The governance of the action plan has been set across four workstreams,each led at Strategic Director level, and with broad representation across alldirectorates. This will enable strong council wide oversight and earlyidentification of any negative impacts not identified previously.

What impact has this evidence had on what you are proposing? What can you do differently that might lessen theimpact on people within the timeframes i.e. development‐implementation? Who can help you to develop thesesolutions?

Read More

What actions can you take to reduce the impacts that you have identified? Are your actions SMART?

Specific, significant, stretching

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Measurable, meaningful, motivational

Agreed upon, attainable, achievable, acceptable, action‐oriented

Realistic, relevant, reasonable, rewarding, results‐oriented

Time‐based, time‐bound, timely, tangible, trackable

Who will be responsible for making sure these happen? How can you show you have taken these steps? Whatevidence can you provide? Please note developing mitigating actions is an essential part of the EIA process. Theseshould comprehensive and clearly align with the issues identified. If there are significant negative impacts withoutmitigation it is the responsibility of the decision maker/sponsor to challenge and request officers go back to thedrawing board.

Q4. How will you review/evaluate your proposal, mitigating actions and/orbenefits? Who will be responsible for this?The delivery and oversight of the action plan will have a strong multilayered governance structure, through both internal measures ﴾with ultimatereview at Cabinet﴿ and that commissioned externally, including through theLambeth Safeguarding Children Partnership via independent scrutiny ofsocial care practice within discreet reviews and evaluations, as well as acommissioned LGA Peer Review on organisational culture.

Outcome metrics and measures will be developed by the programmemanagers alongside business leads and owners of deliverables will beassigned so that there is accountability and resilience, and to mitigate driftand non‐delivery.

The deliverables in the action plan will be quality assured by workstreamleads who are all members of the executive management team, with aprogramme team in place to track deliverables, outputs and outcomes andprovide regular monitoring and reporting. Progress of the action plan willreport into the IICSA Board chaired by the Chief Executive.

We will use mature feedback mechanisms to measure benefits: surveys,social care audits, supervision, visits, peer reviews.

Who will you be accountable to for the above actions/outcome? How will those responsible know these actions haveworked? What performance indicators will you use to demonstrate this? Are there any other forms of evidence you canuse to support this assessment of their effectiveness?

Read more

Section to be completed by Sponsor/Director/Head of Service

Outcome of equality impact assessment

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Read more

No adverse impact, no change required ‐ No potential for discrimination or negative impact identifiedopportunities to promote equality addressed Low adverse impact, minor adjustment needed ‐ Adjustments needed to address negative impact all actionsdetailed within Q3a

Significant adverse impact, further action required ‐ The analysis has identified some potential for negativeimpact or some missed opportunities to promote equality which it may not be possible to mitigate fully. If you planto continue with proposals you will need to be satisfied that your officers have shown due regard and taken allnecessary steps ﴾as detailed within Q3a﴿ to remove and/or alleviate any negative impacts ﴾e.g. gatheringsupplementary data, consultation, specific action taken, etc.﴿ to better promote equality and have included thesewithin any implementation and/or service plans. It may be advisable to seek further advice including legal, wheresignificant impact has been found. Unlawful in/direct discrimination, stop and rethink ‐ Equality analysis shows actual or potential unlawfuldiscrimination. Do not proceed.

Comments from Sponsor/Director/Head of Service

Submit for approval

Pending

Executive Approval

Pending

Attachments

Close

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CABINET 15 DECEMBER 2021

Report title: Medium Term Financial Strategy 2021/22 to 2025/26

Wards: All

Portfolio: Cabinet Member for Finance and Performance: Councillor Andy Wilson

Report Authorised by: Fiona McDermott: Strategic Director for Finance and Investment

Contact for enquiries: Amaris Wong, Group Manager, Strategic Finance, 0207 926 7742,

awong1@lambeth.gov.uk

Report summary

Since we last reported on the Medium-Term Financial Strategy (MTFS), presented to Cabinet in July

2021, we have received the Chancellor of the Exchequer’s Budget and Spending Review which

outlined a continued tough financial outlook for London boroughs.

By London Council’s calculations London boroughs needed a £2bn increase over the spending

review period but they estimate that they will in fact receive around £1.1bn.

While the increase in local government’s core spending (CSP) is welcome, this increase will only

return local government to estimated funding on a par with 2010 levels, after over eleven years of

austerity and without accounting for increased demand in that time period. In real terms CSP has

been falling since 2010/11, down by 29% in 2020/21 and will be 19% below 2010/11 levels by

2024/25 – around £2.2bn less. This is 5% below the level of the England average and follows the

trend of London being at the bottom of the pile for government funding such as the Community

Renewal Fund and the Levelling Up Fund, with the distribution of the UK Prosperity Fund still to be

announced.

In addition, £3.7bn of the spending power attributed to local government represents central

government assumptions around local councils increasing their council tax (by 2%) and adult social

care precept (by 1%).

We cannot escape the fact that central government funding forms an ever-smaller share of funding

to Lambeth council, with local funding, council tax and business rates growth representing

increasing proportions. Since 2013/14 when business rates growth was introduced, we have seen

government funding reduce from 75.5% to 51.5% by the end of our MTFS planning period. There

continues to be no announcement of the scope or the timetable for the planned local government

finance reforms.

As rises in council tax become a more significant factor in providing additional resource to local

authorities, and the cost-of-living soars for our most financially exposed residents, we have

consulted on expanding the council tax support (CTS) scheme for those residents that find

increases in council tax increasingly unaffordable and struggle to make ends meet. This proposed

support will permanently reduce the bills of almost 7,000 vulnerable households eligible for CTS,

with most seeing their bills reduced to nil. Together with the Winter Support Package recently

announced by the council to cover food, energy bills and housing costs for vulnerable families,

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alongside holiday support for families in receipt of free school meals, this support is part of the

council’s increased efforts to protect Lambeth’s families from the cost-of-living crisis.

In addition, the adult social care reforms have not been fully explained by government and so the

financial effects are not fully understood, with most of the funding raised through Health and Social

Care levy going to the NHS. The council will need to remain financially resilient and sustainable

during what are very uncertain times.

But we must remain vigilant, as the new Omicron variant demonstrates, the covid-19 crisis is not

over and it will continue to have significant financial effect on the level of resources available, both

now and in the future, to the council and its partners. The already existing demand placed on our

services – particularly in social care and temporary accommodation – have been added to by the

pandemic and the continuing effect of the virus on our community and economy in the longer-term.

We will continue to take every opportunity to support vulnerable people in our communities, but we

must also be honest in our ability to do so in the face of gradually reducing grant funding, rising

inflation, and ever-increasing demand on our essential day to day services. Despite all these

pressures and uncertainties, we have maintained a balanced budget position without the need for

further cuts or new savings.

The current MTFS will continue to be developed to ensure that it underpins and supports the

delivery of the Borough Plan priorities and provide certainty to our most vulnerable residents who so

desperately rely upon our essential day to day services.

Finance summary

This whole report concerns the Council’s financial position.

Recommendations

1. To agree and approve the change to the funding deficit as set out in Table 2 and the

consequent amendment to the Council’s Medium Term Financial Strategy.

2. To note the progress on planned changes to the Council Tax Support scheme for 2022/23 as

summarised in paragraphs 2.21 to 2.24

3. To note the previously agreed savings summarised in table 3.

4. To note the continued uncertainty regarding elements of government funding, price and

demand pressures and the need to ensure that budgets set each year are sustainable during

the settlement period to 2025/26 and beyond.

5. To note the financial position of the Council’s budget in 2021/22 and the actions in place to

balance it over the period, including the use of reserves as required.

6. To note the 4-year Capital Investment Programme for the period 2021/22 to 2024/25 as set

out in paragraphs 2.43 to 2.46 and summarised in Appendix 1.

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1. CONTEXT

1.1 The main objectives of our MTFS are to:

Prioritise our resources in-line with the Council’s Borough Plan, and to ensure we

achieve our five goals.

Maintain a balanced budget position, and to always set a MTFS which maintains

and strengthens that position.

Provide a robust framework to assist the decision-making process within the

Council.

Manage the Council’s finances with a forward looking four year rolling strategy.

Deliver value for money to our taxpayers

Exercise probity, prudence and strong financial control.

Manage risk, which includes holding reserves and balances at an appropriate and

sustainable level.

Continually review budgets to ensure resources are targeted on our key priorities.

1.2 This report sets out the changes to Lambeth’s Medium Term Financial Strategy (MTFS) which

was approved at July 2021 Cabinet. In July we reported a funding gap of £11.7m for 2021/22

to 2025/26. In these subsequent months, we have worked to challenge and validate the

pressures identified. We have also received the Chancellor’s Budget and Spending Review

(SR) for 2022/23 to 2024/25 in October. This set out some of the parameters for local

government funding in the SR period. We have to wait for the Provisional Local Government

Finance Settlement for more details. This is likely to be made just before Christmas.

2. PROPOSAL AND REASONS

Medium Term Financial Strategy

National Outlook

2.1 In its October economic and fiscal outlook, The Office of Budget Responsibility (OBR) set out

their forecast up to 2026/27 taking into account measures announced up to and including the

October 2021 Budget and Spending Review. With these assumptions in place, the OBR

expects Gross National Product (GDP) to grow by 6.5% in 2021 (up from 4% in March 2021)

and to reach its pre-pandemic level towards the end of 2021. Unemployment is still expected

to peak in the fourth quarter of 2021 but to a lower level than previously projected.

2.2 The recovery of the economy and the continuing regulatory changes following Brexit and

increasing inflation have exacerbated supply side pressures experience around the world.

Combined with the rise in energy prices and labour shortages in particular sectors, the OBR

projects CPI inflation to reach 4.4% in 2022, with further developments suggesting a peak

closer to 5%, the highest rate seen in the UK for nearly 30 years.

Local Government Outlook

2.3 The outcome of the latest Spending Review (SR21) was announced with the Budget in

October 2021. SR21 covers a period of 3 years, from 2022/23 to 2024/25, the first multi-year

spending review since 2015 (for 2016/17 to 2019/20). Spending Reviews set departmental

totals for the period, but the financial implications for authorities will not be known until at least

the provisional Local Government Financial Settlement due in December.

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2.4 The business rates baseline reset is due to be implemented for 2023/24. The intention of

planned reforms is for greater retention of locally generated business rates. However, the

policy costings of SR21 and subsequent statements by the Minister to the Parliamentary

Housing, Communities and Local Government Select Committee would suggest that greater

retention rates by authorities is unlikely to be implemented during this SR period. Similarly,

there has been no updates on other large-scale reforms promised for local government such

as the Fair Funding Review.

Spending Review (SR21) Announcements

2.5 The headline increase in Local Government funding for 2022/23 to 2024/25 is around 3% per

year, and a cash increase of £8.5bn over the SR period. New grant funding of £4.8bn has

been announced with the remainder expected from increases in Council Tax. The referendum

limit for Council Tax is expected to remain at 2% per year over the next 3 years and the

application of the 1% increase on Social Care Precept, meaning a total council tax rise of 3%

per year for residents.

2.6 The business rates multiplier has been frozen for 2022/23, with the resulting shortfall in

income expected to be fully compensated by government. The conclusion of the review on

business rates was also announced, with a move to 3-yearly revaluations from the current

timeframe of 5 years and a new business improvement relief, allowing businesses to pay no

extra business rates for 12 months after making improvements. Local authorities are expected

to be fully compensated for these measures.

2.7 Recovery support for the Retail, Hospitality and Leisure sector has been extended with 50%

relief on business rates for 2022/23. This is also expected to be funded by government.

2.8 There was no further funding relating to Covid-19 announced for local government.

2.9 Other new measures also announced:

£4.7bn for core school budget, bringing per-pupil spending in England to 2010 levels

£650m for youth services

Continuing funding for Rough Sleeping Initiative and the Homelessness Prevention

Grant

£1.8bn to regenerate underused land for housing infrastructure and facilities

£850m for cultural and heritage infrastructure

Additional £200m for the Supporting Families Programme

£38m for cybersecurity

£35m to strengthen local delivery and transparency

Health and Social Care Levy

2.10 The Government announced the Health and Social Care levy in early September which will

increase the national insurance contribution rates (NICS) paid by employees and employers

by 1.25% beginning in April 2022. Receipts from 2022/23 will be directed to the NHS. From

2023/24, receipts will be divided between Local Government, NHS and the Department of

Health and Social Care, however, the split was not specified in the announcement.

2.11 Public sector employers are being compensated for the increase in the cost of NICS through

the funding formulae. Narrative within announcement suggests that inflationary pressures and

demographic pressures will need to be dealt with locally through Council Tax, social care

precept and long-term efficiencies.

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London Context

2.12 In the Greater London Assembly’s October publication on London’s Economy, there are

encouraging signs of recovery with 43% of firms saying that they were operating at full

capacity in the previous quarter, a two-year high and back in line with the pre-pandemic

average. However, responses were collected prior to the latest rise in energy prices and driver

shortage.

2.13 The furlough scheme came to an end on 30 September 2021. At the peak, over 905,000

people benefited from the scheme in London and provisional figures indicate over 231,100

people were still receiving support as the scheme ended. London’s unemployment rate was

highest in the UK at 5.8% during the second quarter of 2021, with around 284,000 Londoners

unemployed during that period. Of those, 7,100 were Lambeth residents; for comparison, there

were 6,700 and 6,400 in Southwark and Wandsworth, our nearest neighbours.

2.14 Recent research conducted by the Joseph Rowntree Foundation found that more than half of

low- income households in London was facing arrears with at least one bill. The removal of the

£20 per week uplift in universal credit payments at the end of September is beginning to affect

arrears collection rates. Whilst the pause on applications for evictions have ended, the council

is actively working with tenants to try and help them sustain their tenancies. The number of

evictions carried out had been decreasing year on year prior to the pandemic and we expect

this trend to continue.

Spending Power

2.15 Our spending power is the way in which Central Government measures the overall revenue

funding available for local authority services. The calculation of spending power consists of

items as set out in the Settlement Funding Assessment; this includes grants as well as Council

Tax.

Business Rates Income and Revenue Support Grant (RSG) – together these two

elements form the Settlement Funding Assessment (SFA). We expect the SFA to

remain broadly steady over the MTFS period. However, with the Business Rates

retention baseline reset due to take place in 2023/24, any increase in retained

business rates income is expected to be matched by a corresponding fall in RSG.

The SFA represent 43.5% of our 2021/22 net budget and is expected to fall to 41.6%

of the cash limit in 2025/26.

Council Tax income is 41% (£136.1m) of our 2021/22 core funding but forecast to be

46% (£158.8m) by 2025/26. It should be noted that within our MTFS we have

assumed increases of Council Tax at 1.99% in each year from 2022/23 to 2025/26.

This is subject to formal agreement in February 2022. The effect of the proposed

changes to the Council Tax Support scheme have been included in our calculation of

the council tax base. In addition, the adult social care precept has been included at

1% per annum based on the expectation from Government that demographic

changes and unit costs increases will be funded locally. This is a change to our

assumptions made in July when we included 2% in 2022/23 figures.

New Homes Bonus (NHB) has started to decrease over this period, in 2021/22 NHB

represents 1.4% of the cash limit (£4.5m). From 2020/21, no new legacy payments

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were paid. NHB is expected to be phased out completed by 2025/26 and not replaced

by alternative funding.

Improved Better Care Funding (iBCF) represents 4.4% of the cash limit (£14.5m) in

2021/22 and includes amounts previously allocated as Better Care Fund and Winter

Pressures grant. Our MTFS forecast is for this to remain the same in cash terms (with

inflation eroding its spending power) over the MTFS period reducing its share to 4.3%

of the net budget.

Social Care Grant and Lower Tier Services Grant represents 4.0% of the net budget

in 2021/22 and includes amounts previously allocated as Adult Social Care Support

Grant and Social Care Support Grant. This has been committed for the life of this

Parliament therefore we expect this to remain at the same level until at least 2025/26.

2.16 In recent times the increase in Council Tax has outpaced the increase in central government

funding which has increased the proportion of locally generated income. This trend continues

over the MTFS period with government funding and locally raised resources moving towards

parity. This is a significant change since the current system of Business Rates Retention was

introduced in 2013/14.

Chart 1 Spending Power – government funding vs locally raised 2013/14, 2021/22 and

2025/26

2.17 Whilst our spending power is forecast to increase at a steady pace from 2023/24 to 2025/26,

the increases have come from locally generated resources such as council tax and business

rates income over the guaranteed level of central government funding. within the borough.

Current government funding formulas do not take account of a number of demographic growth

and demand led pressures within the Financial Settlement. We, therefore, must manage and

fund these pressures from locally generated income sources. The demand led pressures

within Adult Social Care, Children Services and Temporary Accommodation continue to grow,

and we have built assumptions around these key areas within our Medium Term Financial

Strategy, however, as we have seen in recent years the demand led pressures continue to

grow beyond assumptions.

75.5%

55.1% 51.5%

24.5%

44.9% 48.5%

0

50

100

150

200

250

300

350

400

2013/14 2021/22 2025/26

£m

Locally raised resources(Council Tax andBusiness Rates growth)

Government Funding(SFA and grants)

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2.18 The most recent announcements relating to social care funding gives a clear indication that

any demographic and cost increases are expected to be funded by local authorities. In

additional, it is unclear how the operation of the social care cap and the ability for self-funders

to access local authority arranged care will affect the cost of services across the whole sector.

We await consultation on the revised charging mechanisms related to the Adult Social Care

Transformation.

London Business Rates Pool

2.19 In preparation for further localisation of business rates, all 32 London Boroughs, the City of

London Corporation and the Greater London Authority were part of a business rates pool

arrangement from 2016-17 to 2020-21. However due to the uncertainty to business rates

income brought on by the pandemic, the pool was discontinued for 2021/22.

2.20 The boroughs continued to monitor the position throughout 2021/22 and as a result have taken

the decision not to form a pool for 2022/23. However, all parties will continue to monitor the

situation and remain open to pooling when circumstances are more suitable.

Council Tax Support Scheme

2.21 The council’s Council Tax Support (CTS) scheme was developed to support residents who

needed help paying their Council Tax. The current Lambeth scheme protects and supports

around 24,000 households each year. However, the Council recognises the financial

challenges faced by Lambeth residents due to Covid-19 and the rises in Council Tax costs and

wishes to offer a more generous Council Tax Support scheme for 2022-23 to support residents

financially.

2.22 The council is legally required to consult prior to any changes to CTS. Consultation ran from

30 June 2021 until 30 September 2021. Five potential options were consulted upon:

Removing the 20% liability reduction

Removing the £5 minimum weekly payment

Removing mandatory minimum non-dependant deductions based on the

circumstances of the householder

Removing mandatory minimum non-dependant deductions based on the

circumstances of the non-dependant

Reducing the excess income taper to 20% from 25%

2.23 The cost of providing the additional support listed above is estimated at £3m and is already

included in the MTFS.

2.24 The consultation received 280 responses. Although not high, this is comparable to previous

CTS consultations and consultations in general. There was firm support from respondents for

all options.

Changes to the MTFS since July

2.25 We have adjusted our business rates assumption to include some transitional tapering

arrangement to compensate the loss of income due to business rate baseline resetting,

reducing the overall loss.

2.26 Looking again at service pressures and using the work done to identify savings, we are able to

reduce service pressures by £6.3m. At the same time, further pressures have been identified

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as we continue to look at wider changes brought on or accelerated by the pandemic:

increasing our forecast for inflation by £1m, funding the improvement of digital access and

ways of working and cybersecurity with £1.44m, including additional resources for measuring

performance of the children’s improvement programme with £0.2m, increasing learning and

development support for social care with £0.05m, removing undeliverable savings of £1.09m

and matching resources to increased volume of planning applications with £0.1m.

2.27 The effect of these changes has reduced the funding gap to £1.710m. We expect this to be

met through changes to fees and charges. A review is currently underway with proposals to be

included in the February budget report.

Table 2

Revised Funding Gap 2022/23

£m 2023/24

£m 2024/25

£m 2025/26

£m Total

£m

Position at Budget Report July 2021

Funding Gap 15.572 12.810 3.165 1.613 33.160

Savings Agreed (13.698) (4.975) (2.790) - (21.463)

Revised Funding Gap in July 2021 1.873 7.835 0.375 1.613 11.697

November 2021 Changes:

(Increase)/Decrease to Year on Year Cash Limit Change

(1.365) (4.474) (1.590) (0.152) (7.581)

New Pressures (0.508) (1.651) 1.215 (1.461) (2.405)

Revised Funding Gap - 1.710 - - 1.710

2.28 Although no new expenditure reduction has been required from services, the revised gap

takes into account previously agreed savings of £21.463m, summarised in the table 3 below.

The delivery of all agreed savings is essential for the financial resilience of the council.

Table 3

Type of Change

Previously Agreed Savings

2022/23 2023/24 2024/25 Total

£m £m £m £m

Income generation 3.241 3.870 0.964 8.075

Procurement (contract) 1.450 0.055 0 1.505

Service Change (Reduction in Provision) 0.770 0.275 0 1.045

Service Transformation (non-staffing) 3.674 1.980 1.826 7.480

Service Transformation (staffing) 4.029 0.500 0 4.529

Third Party Services 0.534 (1.705) 0 (1.171)

Total Savings 13.698 4.975 2.790 21.463

2.29 In addition, agreed savings of £13.7m are to be delivered in the current year 2021/22, of which

£1.4m were brought forward from 2020/21. It is forecast that £11.658m will be delivered in

year with £2.05m rolled forward to be delivered next year, bringing 2022/23 savings up to

£15.748m.

COVID-19 – Impact on council’s finances

2.30 Costs associated with the coronavirus pandemic continue to impact the council and

expenditure is forecast to be £35.5m in 2021/22 as of quarter 2, with the main areas of spend

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including, providing support to local businesses, reopening the economy safely and

expenditure with in Adult Social Care to facilitate hospital discharges and on infection control.

There are also forecast income losses of £2.4m due to lower fees and charges receipts for the

council. At this stage, it is expected that pandemic related pressures will be met by grant

funding for the 2021/22 financial year.

2.31 The longer-term cost pressures that have resulted from the pandemic are not receiving

additional grant funding.

Financial Management & Performance

2021/22 Revenue Q2 Forecast Position

Table 4 General Fund Forecast Outturn 2021/22

Full Year Budget

Forecast Forecast Variance

£m £m £m

Adults and Public Health 94.982 94.995 0.013

Children’s Services 75.579 80.435 4.856

No Recourse to Public Funds 2.734 2.347 (0.387)

Resident Services 70.293 73.373 3.080

Sustainable Growth and Opportunity 3.073 3.134 0.061

Finance & Investment 12.916 13.656 0.740

Strategy, Communications and Legal Services 7.746 7.988 0.242

Total 267.323 275.928 8.605

2.32 The position on the General Fund at the end of September is a forecast overspend of £8.605m

for 2021/22. The position for each directorate is summarised below, with greater detail

available in the quarterly Budget and Performance report presented to Cabinet.

2.33 Adults Social Care are forecasting to breakeven for 2021/22. However, this position is funded

by use of reserves and grants to alleviate staffing and third-party payments pressures, other

short-term projects and additional care costs incurred from the response to the pandemic. The

underlying overspend position in 2021/22 as of September is forecast at £3.8m, made up

mostly of third-party budget pressures in Learning Disability residential care and Mental Health

residential and nursing care. Funds carried forward from 2020/21 for staffing and provider

support will be used to offset additional expenditure in year and meet unachievable savings in

year. The overall position is approximately £2.8m more in expenditure than pre-pandemic

trends suggested. Work is progressing in revising long-term trends, but early information

shows that home care expenditure for older people has increased substantially and has only

been partly off-set by reductions in residential care expenditure as client numbers have

increased above pre-pandemic numbers. In addition, long-term cost increases in Learning

Disabilities appear to have accelerated over the last year.

2.34 Children’s Services are forecasting an overspend of £4.8m for the financial year. Within

Children Social Care there is a forecast overspend of £2.8m, which relates to supernumerary

unfunded posts. Within Education & Learning there is a projected overspend of £1.6m, most

of which relates to SEND management and home to school transport.

2.35 Resident Services are forecasting an overspend of £3.0m for the financial year. £1.7m of the

overspend relates to costs associated with Temporary Accommodation. The correlation can be

seen when reviewing the indicator measuring the number of households in temporary

Page 77

accommodation; towards the end of 2020-21 the numbers increased and exceeded the target,

and whilst the targets for 2021-22 have been reset to allow for this increase, the numbers

continue to grow, with a 10% increase compared to the same period last year. The most

recently published DLUHC figures for London reflecting occupations levels at the end of

December report Lambeth as having the sixth highest occupation levels in London with 2,767

households in occupation of temporary accommodation.

2.36 There is an underspend in Environment & Streetscene predominantly due to overachievement

of parking income. An overspend of £0.580m in Residents Experience & Digital is caused by

additional staffing costs in clearing Covid-19 backlogs in Registrars, a slow recovery in

Libraries income after Covid and staffing overspends within ICT. .

2.37 Sustainable Growth and Opportunity are forecasting a slight pressure of £0.062m due to a

shortfall in building control and planning income. There will be a significant level of expenditure

on supporting businesses within the Borough, however this is expected to be funded from

Central Government Grants and previously agreed NCIL funding.

2.38 Finance & Investment are forecasting an overspend of £0.7m this year, mainly due agency

staff costs within Human Resources and Organisation Development and Finance and

Property.

2.39 Strategy, Communications and Legal services are forecasting an overspend of £0.304m

within Legal Services in the financial year predominantly due to additional staff to support legal

work in the Children Services area.

2021/22 Housing Revenue Account Q2 Forecast Position

2.40 There are several factors that are driving the forecast of a £8.6m overspend. Within Housing

Services there are pressures within the responsive repairs service due to the necessity of

reducing outstanding repairs jobs ahead of the new suite of repairs contracts which

commenced in July 2021. There are also pressures against the voids budget due to a targeted

reduction in voids to bring them back into rental use. The HRA’s operations are continuing to

be adversely impacted by Covid-19 and this is reflected in £1m rent losses in HRA hostels.

There is a one-off £2m investment in system upgrades and transformation work to drive future

efficiencies and value for money procurements within the HRA.

2.41 The Council is forecasting a planned use of HRA reserves for the above whilst maintaining a

grip on the future balances and reserves via the HRA Business Plan.

Table 5 – HRA Forecast Outturn 2021/22

Full Year

Budget £m

Forecast £m

Variance £m

Housing Services 63.690 72.399 8.709

Strategic Programmes 15.541 18.062 2.521

Central HRA Budgets & Technical Adjustments (79.231) (81.823) (2.592)

TOTAL HRA 0 8.638 8.638

2021/22 Dedicated Schools Grant Q2 Forecast Position

Page 78

2.42 At quarter 2 the Dedicated Schools Grant (DSG) is projecting to be in a deficit of £2.6m at the

end of the financial year, to be recovered from future years DSG allocations. The main

pressure on the DSG is within the High Needs block associated with Special Education Needs

placements.

Table 6

Dedicated Schools Grant

(DSG)

DSG Reserve

brought forward

Deficit 2020/21

DSG

Allocation

2021/22

Forecast

DSG

spend

Projected

Deficit

2021/22

£m £m £m £m

Total DSG expenditure 2020/21 (0.473) (226.975) 229.187 2.685

2021/22 Capital Q2 Forecast Position

2.43 The approved capital budget for 2021/22 amounts to £286.7m. £34.4m has been spent by the

end of quarter 2 and £169m is forecast to be spent by the end of the year, with £117.8m

carried forward into the next financial year.

Table 7 CIP Forecast Outturn 2020/21

Directorate

21/22 Budget

£m

21/22 Actuals

£m

21/22 Forecast

£m

21/22 Carry

Forward £m

Adult Social Care 0.120 0 0 0.120

Children Services 1.079 0.011 0 1.079

Resident Services 88.481 7.510 68.781 19.700

Sustainable Growth & Opportunity 78.179 9.057 56.924 21.254

Finance and Investment 7.624 0 0 7.624

Housing Revenue Account (HRA) 67.945 7.510 43.207 24.738

Approved awaiting allocation 43.247 0 0 43.247

Total 286.675 34.449 168.912 117.762

2.44 A reprofiling of budgets was carried out following the Q2 forecast position with the 2021/22

budget revised to £269.8m (excluding the Redress scheme). Appendix 1 shows the analysis of

this working CIP for the 4 years 2021/22 to 2024/25 by themes together with how this is

expected to be financed.

Capital Investment Programme

2.45 A 5-year Capital Investment Programme (CIP) spending envelope was set by the Council in

March 2020 with Cabinet allocating headline totals to themes according to priority in July 2020.

The CIP is an amalgamation of both General Fund and Housing Revenue Account capital

schemes and is analysed to show how capital investment is spread across delivery themes. It

also shows where investment is supporting the entire organisation through enabling projects.

2.46 The pandemic resulted in severe delays in delivery in 2020/21 and a significant carry forward

of funds to the current year. There is continuing work to reprofile the programme within

existing resources as well as reviewing our planned investments and developments to ensure

they meet the needs of the borough in the future.

Page 79

2.47 The size of the capital programme is limited by available resources. Over recent years, the

role of developer contributions has increased as available capital receipts continue to reduce.

The other major source of funding is borrowing which has an impact on revenue budgets as

there are on-going costs to debt servicing and the need to repay the principal over time. A

review will begin shortly on the all available resources, including validating assumptions on

developer contributions following the pandemic-related delays to development.

2.48 After the reviews on the planned programme and projected available resources are complete,

there will be an opportunity to review the thematic allocations set by Cabinet to ensure they

continue to match the ambitions the council and to bring forward any proposed changes for

budget setting in February.

Reserves Strategy and Forecast

2.49 The Reserves Strategy sets out the Council’s current approach to ensuring that the level,

purpose and planned use of its reserves are appropriate in the current financial climate. Our

overall approach is to use the financial strength of our balance sheet to help the Council

through a period of high risk caused by real terms funding reductions and economic

stagnation.

2.50 In the short term, Covid-19 has created significant cost pressures as well as delaying the

delivery of a number of agreed savings, combined with the loss of income. Whilst some of

these pressures have been met by Government grant, we will look to use reserves and

balances to fill any remaining gap whilst continuing to lobby government to fully fund our

response to the pandemic and its long term affects.

2.51 Brexit is also adversely impacting on the economy. The potential impacts of an increase in

inflation and an economic slowdown have the potential to reduce local authority revenue from

business rates, parking income, events, new homes bonus and council tax. It is therefore key

that the council is prepared and ensures that reserves provide suitable financial resilience.

2.52 Table 7 below confirms our current reserve forecast position to this financial year-end, whilst

also forecasting up to 2026. The general fund balances continue to be forecast to be

maintained at 10% of the net general fund budget. Earmarked reserves are currently not

forecast to increase over the planning period; however this will be determined by future service

need.

2.53 Similar to many boroughs, despite the covid-related pressures last year, reserves have

increased in 2020/21. There are several reasons for this:

Compensation paid to councils for pandemic-related business rates reliefs paid in

2020/21 but repayable to the collection fund in 2021/22, required setting aside large

sums at year end.

More than half the Covid-19 funding in 2020/21 from central government was

received in the second half of year. With less time to budget for these, it was difficult

to allocate and spend the funding, therefore sums have been set aside as

contingency to deal with the on-going impact of the pandemic in 2021/22

The uncertainty of any central government funding for the on-going impact of the

pandemic on additional spending and income losses, means it is prudent to build

additional financial resilience whilst continuing to lobby government.

Table 9 2021/22 to 2025/26 Reserve Forecast

Page 80

Reserves Actual Forecast

2020/21 2021/22 2022/23 2023/24 2024/25 2025/26

£m £m £m £m £m £m

General Fund Balances 25.870 30.409 34.009 34.509 35.009 35.509

General Fund Reserves 151.068 109.370 86.870 86.124 85.755 85.755

Subtotal 176.938 139.779 120.879 120.633 120.764 121.264

CIL Reserve 12.212 12.327 11.327 11.827 10.827 11.577

GF Balances & Reserves 189.150 152.106 132.205 132.460 131.591 132.841

HRA Balances 10.971 2.603 2.603 2.603 2.603 2.603

HRA Reserves 17.944 17.944 17.944 17.944 17.944 17.944

HRA Balances & Reserves 28.915 20.547 20.547 20.547 20.547 20.547

Total Balances & Reserves 218.065 172.653 152.752 153.006 152.138 153.388

2.54 The impact on reserves due to the business rates relief compensation has had a significant

impact on all London boroughs’ reserves to varying degrees which has reduced the

comparability of 2020/21 positions therefore it has not been included in this report.

3. FINANCE

3.1 This report in its entirety is about the Council’s financial position and the implications for

service planning and delivery

4. LEGAL AND DEMOCRACY

4.1 The Council has a duty to maintain a balanced budget throughout the year and, accordingly,

members are required to regularly monitor the Council's financial position. In implementing the

Council’s financial strategy for 2021/22 and subsequent years, members will need to balance

the proposed level of expenditure in discretionary areas of service provision against that

required to ensure that the Council complies with its statutory duties.

4.2 Section 28 of the Local Government Act 2003 imposes a duty on the Council to monitor its

budgets throughout the financial year, using the same figures for reserves as were used in the

original budget calculations. The Council must take necessary appropriate action to deal with

any deterioration in the financial position revealed by the review.

4.3 The Housing Revenue Account is a ring-fenced account. Transfers to and from the account

are prescribed.

4.4 In reaching decisions on these matters, members are bound by the general principles of

administrative law. Lawful discretions must not be abused or fettered, and all relevant

considerations must be taken into account. No irrelevant considerations may be taken into

account, and any decision made must not be such that no reasonable authority, properly

directing itself, could have reached. Members must also balance the interests of service users

against those who contribute to the Council’s finances. Monies may not be expended

thriftlessly and the full resources available to the Council must be deployed to their best

advantage. Members must also act prudently and in a business-like manner at all times.

Page 81

4.5 In considering the advice of officers, and the weight to be attached to that advice, members

should have regard to the personal duties placed upon the Director of Finance (DoF) as Chief

Financial Officer. The Chief Financial Officer is required by Section 151 of the Local

Government Act 1972 and by the Accounts and Audit Regulations 2015 to ensure that the

Council’s budgeting, financial management, and accounting practices meet relevant statutory

and professional requirements. In the event that the Council’s overall financial position

worsens considerably during the remainder of 2021/22, the DoF will need to have regard to

the statutory obligations which are placed on her personally when deciding on any particular

actions to be recommended to Members to address her concerns.

4.6 This proposed key decision was entered in the Forward Plan on 17 May 2021 and the

necessary 28 clear days’ notice has been given. The report will be published for five clear

days before the decision is considered by Cabinet. Should it be approved, and following the

publication of the Cabinet minutes, a further period of five clear days, the call-in period, must

then elapse before the decision can be implemented. If the decision is called-in during this

period, it cannot be enacted until the call-in has been considered and resolved.

5. CONSULTATION AND CO-PRODUCTION

5.1 We are committed to working with our communities so that they can help themselves and be

more resilient to the changes in local services. Also, we are determined to talk to communities

about the tough choices we have to take as the money we receive from Central Government

continues to reduce.

5.2 The current funding gap is expected to be met through changes to fees and charges which will

carry out any required consultation before individual proposals are implemented.

6. RISK MANAGEMENT

6.1 None for the purposes of this report.

7. EQUALITIES IMPACT ASSESSMENT

7.1 This report is the beginning of the annual budget setting process and presents the key

headlines from the prior year and sets out the ongoing or new pressures and opportunities

together with indicative funding likely to be available for the next financial year.

7.2 The report sets of the key risks for the current year and next year and its impact on the

Medium Term Finance Strategy. The report sets out the indicative funding gap and a timetable

for preparing mitigations and proposals to be considered by Cabinet before formalising the

Budget for the following year.

7.3 No new savings have been proposed.

8. COMMUNITY SAFETY

8.1 None for the purposes of this report.

9. ORGANISATIONAL IMPLICATIONS

Environmental

Page 82

9.1 None for the purpose of this report, although the environmental impact of particular proposals

will be considered as part of the budget process.

Health

9.2 None for the purpose of this report.

Corporate Parenting

9.3 None for the purpose of this report.

Staffing and accommodation

9.4 None for the purpose of this report.

Responsible Procurement

9.5 None for the purpose of this report.

10. TIMETABLE FOR IMPLEMENTATION

10.1 The changes to the MTFS will inform the financial planning in preparation for the 2021-26

Medium Term Financial Strategy and the Budget for 2022/23.

Page 83

AUDIT TRAIL

Consultation

Name and Position/Title Lambeth Directorate Date Sent Date

Received

Comments in

paragraph:

Councillor Claire Holland

Leader

Leader of the Council 16/11/21 18/11/21

Councillor Andy Wilson

Cabinet Member

Cabinet Member for Finance

and Performance 16/11/21 18/11/21

Andrew Travers, Chief Executive

Chief Executive 16/11/21 17/11/21

Fiona McDermott,

Strategic Director

Finance and Investment 15/11/21 16/11/21

Christina Thompson,

Director

Finance and Investment/

Finance and Property 15/11/21 17/11/21 Throughout

Andrew Pavlou, Principal Lawyer

Governance

Legal and Governance

19/10/21 20/10/21

Sarah Keeble Democratic

Services Officer

Legal and Governance

Democratic Services 12/11/21 15/11/21

REPORT HISTORY

Original discussion with Cabinet Member 17.05.21

Report deadline 01.12.21

Date final report sent 01.12.21

Part II Exempt from Disclosure/confidential

accompanying report? No

Key decision report Yes

Date first appeared on forward plan 17.05.21

Key decision reasons Financial

Background information

Revenue & Capital Budget 2021/22 to 2024/25

July Financial Planning and Medium Term Strategy

Report

Appendices Appendix 1 - Capital Investment Programme

2021/22 to 2024/25

Page 84

Appendix 1 – Capital Investment Programme 2021/22 to 2024/25

Cabinet Portfolio Theme 2021/22 Budget

£m

2022/23 Budget

£m

2023-2025 Budget

£m

4 Year Total

£m

General Fund Capital Investment

Children and Young People

Children's Services 1.250 0.050 0.100 1.400

Schools 19.779 11.479 - 31.258

Equalities & Culture Archive 5.322 4.000 - 9.322

Brockwell Hall Restoration 3.311 2.250 - 5.561

Cemeteries 6.611 1.966 1.301 9.878

Libraries 1.812 0.244 0.392 2.448

Parks 3.819 1.657 2.500 7.975

Finance and Performance

Digital Transformation 7.722 4.000 7.500 19.222

Facilities Management 2.063 1.000 3.485 6.548

ICT Infrastructure 2.872 2.061 7.620 12.552

YNTH residual 0.683 - - 0.683

Health and Social Care Coburg Crescent 6.570 - - 6.570

Housing Adaptations 5.150 - - 5.150

Primary Care Contribution 2.000 - - 2.000

Housing and Homelessness

Housing Grounds Maintenance 0.733 - - 0.733

TA Procurement Strategy 2.437 1.000 2.000 5.437

Planning, Investment & New Homes

114-118 Lower Marsh 3.317 2.600 - 5.917

Estate Regeneration 15.872 11.149 7.005 34.026

Economic infrastructure investment, incl. affordable housing & workspace

11.469 8.964 12.540 32.973

Site Acquisition residual 0.183 1.705 - 1.888

Somerleyton Road 14.123 - - 14.123

Town Centre Development 0.821 - - 0.821

Sustainable Transport, Environment and Clean Air

Energy, flood prevention & climate change response infrastructure

15.441 4.788 8.181 28.410

Highways Improvement Programme 4.830 4.835 11.276 20.941

Parking 1.040 0.100 0.450 1.590

Public Protection 1.500 - - 1.500

Sustainable Transport/Public Realm 17.916 13.000 9.166 40.082

Waste and Recycling 9.112 3.863 - 12.975

Waterloo & South Bank Economic Recovery: public realm investment

3.089 2.400 4.800 10.289

Voluntary Sector and Leisure

Brixton Rec Refurbishment 4.062 0.670 2.157 6.889

Communities 0.930 - - 0.930

VCS Buildings 2.110 0.867 0.950 3.927

General contingencies (including overprogramming to be managed down over the life of the programme)

- - (0.996) (0.996)

General Fund Capital Investment Total 177.948 84.649 80.426 343.023

Page 85

Cabinet Portfolio Theme 2021/22 Budget

£m

2022/23 Budget

£m

2023-2025 Budget

£m

4 Year Total

£m

Other General Fund Capital Expenditure

Finance and Performance

Redress Scheme Capitalised Payments

31.896 - - 31.896

Planning, Investment & New Homes

RTB Buybacks 25.094 11.700 49.406 86.200

HRA Capital Investment

Housing and Homelessness

HRA Capital Programme 66.712 44.304 88.200 199.216

Total Capital Investment Programme 301.649 140.653 218.032 660.334

Indicative funding:

Grants 51.560 18.103 4.632 74.295

S106/CIL 32.224 26.901 67.052 126.177

RTB 1-4-1 Receipts 1.268 - - 1.268

Capital Receipts 17.166 6.097 7.700 30.964

Other Internal Resources 9.682 2.616 3.997 16.295

HRA Resources (MRR, s20 and HRA reserve) 37.751 37.751 75.585 151.087

Borrowing 151.997 49.186 59.065 260.248

Funding total 301.649 140.653 218.032 660.334

Page 86

CABINET 13 DECMBER 2021

Report title: Responsible Procurement Policy 2021-2024

Wards: All

Portfolio: Cabinet Member for Finance and Performance: Councillor Andy Wilson

Report Authorised by: Fiona McDermott: Strategic Director for Finance and Investment

Contact for enquiries: Sasa Glisic, Acting Head of Procurement, Finance and Investment,

0207 926 1352 sasaglisic@lambeth.gov.uk

REPORT SUMMARY

This paper presents an update to the Responsible Procurement Policy published in September 2019.

The Policy sets out the council’s approach to ensure that commissioning and procurement activity

supports the achievement of the ambitions set out in the Borough Plan and delivers tangible social,

economic and environmental benefits for Lambeth residents.

FINANCE SUMMARY

There are no direct financial implications arising from this report.

RECOMMENDATIONS

1. To approve and adopt the update to Responsible Procurement Policy which covers all

procurement and commercial activity including services, goods, works and concessions.

2. To delegate any minor revisions in response to the changing policy and/or regulatory framework

to the Head of Procurement in consultation with the Cabinet Member for Finance and

Performance

Page 87 Agenda Item 5

1. CONTEXT

1.1 In 2020/21 the council spent £552m through procurement activity. This was spent with 2,788

commercial suppliers including 513 based in Lambeth - representing 21% of total procurement

spend. 66% of suppliers were Small or Medium sized Enterprises (SMEs) and a further £38m was

spent with third sector organisations. In total, there are 300 contracts over £100,000 on the

Contract Register.

1.2 Responsible procurement is defined as “the process whereby organisations meet their needs for

goods, services and works in a way that achieves value for money on a whole life basis and

generates benefits not only to the organisation, but also to society, the economy and the

environment”. The Public Services (Social Value) Act 2012 provides the relevant legislative

framework and requires councils to consider these wider benefits when procuring and entering into

contracts. The Act applies to public services contracts and framework agreements to which the

Public Contracts Regulations 2015 apply and aims to provide a tool to assist commissioners to get

more value for money out of procurement

1.3 Lambeth has a strong history of promoting sustainable procurement and published the

Responsible Procurement Policy in 2019 to provide a clear framework, based on local ambitions

and priorities, to support the further embedding of the approach in all commissioning and

procurement activity. The Policy is designed therefore to ensure the Council effectively leverages

its third party spend to support delivery of local outcomes and priorities and as such acts as an

enabler of the Our Borough Plan.

1.4 The 2019 Responsible Procurement Policy identified six key policy areas that must be considered

as part of the procurement process. The areas (plus an additional focus on innovation) are set out

below:

Good quality jobs with fair pay and decent working conditions

Quality apprenticeships, targeted employment for Lambeth residents and Lambeth priority groups

Reduce emissions: Lambeth Council has a commitment to being zero carbon by 2030

Single use plastics

Positive health and wellbeing

Innovation

1.5 In the period September 2019 to March 2021, there were 81 contract award decisions presented at

the Procurement Board (seven of these were below £500k total contract value). The graph below

sets out the level of commitments achieved against each of the mandatory criteria set out

paragraph 1.4 above.

Page 88

Fig. 1

.

1.6 Social value has formed a mandatory part of the evaluation criteria in all procurements undertaken

since the policy was introduced and all tenders with commercial providers have resulted in

responsible procurement commitments across at least two of the mandatory criteria. Figure 1 sets

out the total number of tenders that have included social value commitments across the different

Policy priority areas. The securing of commitments to support the employment and skills of

Lambeth’s residents has been a particular area of success with a total of 143 commitments relating

to this objective achieved.

1.7 There has been a successful focus on London Living Wage (LLW) over the last few years. All

contracts that involve employment of staff (of which there have been 64 as set out in the chart

above) have complied with LLW and eligible organisations are also expected to sign up to the

Healthy Workplace Charter. A key factor in achieving this success has been the clarity of the

requirement and strong advocacy within the council.

2. PROPOSAL AND REASONS

2.1 This paper presents an update to the Responsible Procurement Policy building on the strengths of

the previous version and responding to changes in the policy and regulatory environment.

GREATER GOVERNMENT FOCUS ON RESPONSIBLE PROCUREMENT

2.2 In 2020 the Government updated the social value model for Central Government procurement

which has resulted in a number of changes introduced since the beginning of 2021. The social

value model which Government will assess contracts it is letting on now includes:

Supporting COVID-19 recovery, including helping local communities manage and recover from the impact of COVID

Tackling economic inequality, including creating new businesses, jobs and skills, as well as increasing supply chain resilience

Fighting climate change and reducing waste

Driving equal opportunity, including reducing the disability employment gap and tackling workforce inequality Improving health and wellbeing and community integration

29

64

19

31

28

20

19

15

0 10 20 30 40 50 60 70

Fair pay and decent working conditions

Living Wage

Targeted employment opportunities

Quality apprenticeships for Lambeth residents

Reduce emissions

Reduce consumption of raw materials and single use…

Maximise positive health and wellbeing

Innovation

number of award reportsResponsible Procurement identified in Procurement Board

approved ODDR/CMDDR between Sep-19 and Dec-20

Page 89

2.3 Whilst this further update does not apply to local government, it signifies a strengthening of

Government commitment to driving societal and environmental benefit through its third party

spend.

2.4 This is further supported by the proposed approach to UK public procurement as a result of EU

exit. Whilst the major implications of EU exit are not yet fully understood, the Transforming Public

Procurement Green Paper https://www.gov.uk/government/consultations/green-paper-

transforming-public-procurement sets out vision for public procurement. Consultation closed in

March 2021 and new legislation is likely to come into force during the 2022/23 Parliamentary

session.

2.5 The Green Paper proposes simplifying the current regime and reducing bureaucracy; stripping

back to the basics required under the Governmental Procurement Agreement and offering greater

flexibility to procuring bodies. It also suggests a shift in emphasis in procurement decision making

by moving away from contract award criteria based on Most Economically Advantageous Tender to

Most Advantageous Tender allowing for greater consideration of outcomes and added value.

2.6 The paper also suggests the introduction of new principles underpinning public procurement

including; public good, integrity and, fair treatment of suppliers in recognition of the opportunity to

influence markets through the way in which public procurement is conducted.

RESPONDING TO THE CHALLENGE OF THE PANDEMIC

2.7 In July 2020 the Council published ‘New Beginning’s: Building Lambeth’s Recovery’. This set out

the priorities for the borough’s recovery and established partnership and collaboration as central to

the council’s approach. The plan recognises that recovery will require the council to work

differently with its communities and to invest in community infrastructure and assets that enable

recovery to take place.

2.8 Responsible procurement and social value seek to provide positive impacts on the community

through procurement and commissioning and these may be directed to address inequalities and

local priorities. This is increasingly important given the experience of the COVID-19 pandemic and

the disproportionate impact it had, and continues to have, on many of Lambeth’s communities.

2.9 This Recovery plan will need to be underpinned by strong and effective commissioning,

procurement and contract management practice that leverages the resources of our contractors

and supply chains and enables services to not only deliver but also to innovate.

IMPACT BASED DECISION MAKING IN LAMBETH

2.10 The council has developed a Societal Impact Framework based on the Borough Plan and

responsible procurement principles, alongside national and international frameworks and indices

such as the UN development goals.

2.11 This framework will be used to aid understanding of the effects of decisions and thereby support

better decision making. This will be through real time identification of challenges and strengths in

different neighbourhoods and be a tool that enables decisions about investment to be made based

on a holistic understanding of the effects, both positive and negative, within local neighbourhoods.

The proposed update to the Responsible Procurement Policy will be a part of the societal impact

framework.

Page 90

THE ‘CHANGING LIVES’ SOCIAL VALUE PROGRAMME

2.12 ‘Changing Lives’ is the new social value programme launched by the Council in October 2021.

The approach has been spearheaded by the Resident Services department and aims to enhance

resident engagement using the council’s procurement supply chain in line with the Social Value

Act.

2.13 As a part of the programme a social value fund has been developed which encourages providers

to commit a percentage of the annual contract value to a community fund. Alongside these

financial contributions, providers may also contribute ‘in kind’ benefits such as offering work

experience placements to local school children, volunteering hours, offering local apprenticeships,

buying from local SMEs, promoting opportunities for disadvantaged groups, running events or

initiatives with local schools/community groups in the borough about reducing waste and tackling

climate change.

CONTRACT MANAGEMENT

2.14 Since the publication of the 2019 Responsible Procurement Policy, the council has invested in

developing internal contract management capability and capacity. Robust contract management is

essential to deliver contract outcomes; value for money, performance compliance and risk

management and to encourage continuous improvement. To ensure a consistent approach to the

way contracts are managed and to provide assurance and visibility to senior management, the

council has established a contract management model including guidance, training, tools,

templates, opportunities to share learning and best practice and a new contract management

system, eCMS, to hold data on all contracts.

2.15 A small centre of excellence was established in April 2020. The role of this team is to establish the

framework and tools necessary to ensure contract managers from across the council can

confidently do their job. The corporate team is responsible for strengthening internal capability and

capacity and providing support, tools, and guidance to managers responsible for contracts in order

to ensure consistency of approach across the organisation, facilitating the sharing of best practice,

shared learning, and peer support. The team continue to roll out the training as well as managing

the migration of existing contracts to the eCMS.

2.16 eCMS is now nearing the end of the implementation phase. This phase has focussed on migrating

all contracts on to the new system, ensuring contract managers and suppliers have access to the

system and are confident in using it, ensuring all KPIs, including responsible procurement, are set

up and, contract management processes are in place. The next phase will focus on developing a

community of practice around contract management to support continuous improvement and

developing reporting functionality to support impact-based decision making and enable even

greater transparency.

PROPOSED CHANGES

2.17 The Responsible Procurement Policy sets out a clear commitment to delivering greater value and

benefit to Lambeth’s communities. The Policy has been included in procurement guidance and

templates; the Council’s terms and conditions; the corporate template for all decisions and

governance tender documentation and, regular communication has been sent to staff.

2.18 The council has made good progress ensuring that responsible procurement is an inherent part of

commissioning and procurement activity, however there is more to do to ensure that we are able to

assess and understand the impact of the social value delivered and to work in partnership to

ensure the target groups identified benefit from the commitments secured. Responsible

procurement forms only one part of the Council’s approach to leveraging the resources within the

borough to achieve positive societal impact.

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2.19 The changes proposed to the Policy are designed to further strengthen the council’s approach and

ensure alignment with Lambeth policy and decision making as well as changes to the wider

regulatory environment. Key changes are detailed below:

Adoption of the societal impact framework criteria (in place of the previous six

responsible procurement priorities)

Introduction of 10% mandatory minimum social value evaluation criteria for all

procurements with a total contract value of £500k or more

Endorsement of the ‘Changing Lives’ social value programme including the community

benefit contribution

Greater emphasis on and commitment to shaping local supply markets and ensuring

procurement processes are inclusive

A focus on contract management and developing the capability to measure the impact

of responsible procurement

Commitment to reporting progress on an annual basis

3. FINANCE

There are no financial implications as a result of this report.

4. LEGAL AND DEMOCRACY

4.1 Under the Public Services (Social Value) Act 2012, the Council must consider before starting the

process of procurement of services how what is proposed to be procured might improve the

economic, social and environmental well-being of the relevant area, and how, in conducting the

process of procurement, it might act with a view to securing that improvement.

4.2 This social value duty is balanced by obligations to ensure fair and open competition as set out in

the Public Contracts Regulations 2015 which state, inter alia, that award criteria must be ‘linked to

the subject matter’ of the contract in question and must be contract-specific and not aimed at

assessing the business or corporate policies of the tenderer.

4.3 Contracting authorities are entitled to decide not to award a contract to the tenderer submitting the

most economically advantageous tender where they have established that the tender does not

comply with applicable obligations in the fields of environmental, social and labour law established

by retained laws in the UK-EU Trade and Cooperation Agreement, national law, or collective

agreements. The list of such obligations is prescribed and must be strictly construed. If the

tenderer is not in breach of any of those obligations the contracting authority is bound to select its

bid if it is the most economically advantageous tender.

4.4 As stated in paragraph 2.5 one of the proposals in the Transforming Public Procurement Green

Paper is that the most economically advantageous tender (MEAT) criterion is changed to the most

advantageous tender (MAT), which would allow more latitude to contracting authorities in

designing their procurements to secure social value outcomes. In the meantime contracting

authorities may pursue their social value duty under the MEAT criterion so long as the award

criteria are linked to the subject matter, as outlined in paragraph 4.2.

4.5 Government has issued a procurement policy note (05/21) requiring that contracting authorities

familiarise themselves with the contents of the National Procurement Policy Statement. The

Statement advises that contracting authorities should have regard to the following national

priorities in their procurement where it is relevant to the subject matter of the contract, and it is

proportionate to do so:

creating new businesses, new jobs and new skills

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tackling climate change and reducing waste, and

improving supplier diversity, innovation and resilience

4.6 The National Procurement Policy Statement affirms the requirement to comply with legal

obligations including those in the UK-EU Trade and Cooperation Agreement, and these

obligations include the binding commitment to fair and open competition which is assured by the

Public Contracts Regulations.

4.7 The procurement policy note also advises that contracting authorities should consider whether

they have the right policies and processes in place to manage the key stages of commercial

delivery identified in this statement where they are relevant to their procurement portfolio. They

should consider whether they have the right organisational capability and capacity with regard to

the procurement skills and resources required to deliver value for money.

4.8 This proposed key decision was entered in the Forward Plan on (X Date) and the necessary 28

clear days’ notice has been given. The report will be published for five clear days before the

decision is considered by Cabinet. Should it be approved and following the publication of the

Cabinet minutes, a further period of five clear days, the call-in period, must then elapse before the

decision becomes effective. If the decision is called-in during this period, it cannot be enacted until

the call-in has been considered and resolved

5. CONSULTATION AND CO-PRODUCTION

5.1 There has been wide consultation on the Responsible Procurement Policy to ensure it accurately

reflects the aspirations and priorities of Lambeth and is in line with commitments made in other

policies and plans.

5.2 Individual procurements must include consultation and coproduction as appropriate. This Policy is

designed to further strengthen the transparency regarding procurement activity and establishes

service user engagement and co-design as key to the Council’s approach.

6. RISK MANAGEMENT

6.1 The key risks associated with procurement are that the Council does not get value for money from

external spend or that it is challenged for non-compliance with its internal processes or with

legislation. Consistent processes, effective procurement planning, and focus of governance and

procurement professional time on high-value high-risk projects provides mitigation against these.

This policy and the underpinning framework provide clarity around council priorities for responsible

procurement, clearly linking requirements to Council outcomes, to ensure any benefits are

channelled appropriately.

6.2 Internal Audit continue to provide assurance to senior management and Members on procurement

controls and the assurances being obtained by management that the process is operating

effectively the requirements are being complied with. Internal Audit continue to include

procurement controls within the Continuous Auditing programme and reviews of procurement and

contract management arrangements in the annual Internal Audit Plan

7. EQUALITIES IMPACT ASSESSMENT

7.1 In developing the proposals for responsible procurement, the potential equality impacts and

prompts have been considered to ensure the Council is able to fulfil its Public Sector Equalities

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Duty. This has included review of the Equality and Human Rights Commission guide for public

authorities. A full EIA was completed for the new Responsible Procurement Policy and presented

to the EIA panel on 23 November 2021.

7.2 The impacts of the Policy on those with protected characteristics are anticipated to be positive as

particularly the skills and employment priorities are specifically targeted at priority groups identified

by the Lambeth Equality Commission. In addition, the priorities aimed at improving health may be of

greatest benefit to those disadvantaged by disability or a long-term health condition.

7.3 Equality and Diversity policies are embedded in the procurement processes and Equality Impact

Assessments are required for all procurements over £100,000. Local Small and Medium Sized

Enterprises and third sector organisations benefit from the higher tender threshold as they do not

need to go through a pre-qualification questionnaire or tender process on low value procurements.

In addition, lower value opportunities are advertised on Contracts Finder the Government website

with a link from the Council’s website

8. COMMUNITY SAFETY

8.1 The Policy is intended to support the Council in securing added value for local priorities as such

opportunities to support community safety may be considered, as appropriate, as part of the

procurement process).

9. ORGANISATIONAL IMPLICATIONS

.

Environmental

9.1 Environmental sustainability is a major consideration in all the council’s procurement activity. The

adoption of the societal impact framework outcomes ensures that the Policy aligns with the

Council’s commitment to environmental sustainability and tackling the causes of climate change.

Health

9.2 Health is one of the key areas for the Responsible Procurement Policy, specifically the health of

those who are employed through Lambeth contracts. There may also be indirect health benefits,

particularly for mental health through providing skills and employment opportunities targeted at

those with disabilities or long-term health conditions. In addition, the priority to reduce carbon

emissions would impact air quality and thus health. There is thus likely to be a positive health

impact from this Policy.

9.3 Health considerations are considered, as appropriate, for all tender opportunities. In particular, any

providers with more than 250 staff must sign-up to the London Healthy Workplace Charter.

Corporate Parenting

9.4 The Policy is intended to support the Council in securing added value for local priorities. Looked

after children and care leavers are considered as a potential target group when securing benefits,

particularly relating to employment and skills opportunities

Staffing and accommodation

9.5 Employment and skills opportunities targeted at priority groups and the wage rates and health of

contractor workforces are key responsible procurement priorities to be considered for each

procurement and thus the staffing impact of this Policy and report is likely to be positive.

9.6 There are no accommodation implications as a result of this Policy.

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Responsible Procurement

9.7 This report sets out the aims and objectives of the Responsible Procurement policy. All decision

reports supporting procurement activity must set out how the support the Responsible

Procurement priorities.

10. TIMETABLE FOR IMPLEMENTATION

10.1 A simple table to show stages and deadlines for implementing recommendations, or a list of

measurable aims and outcomes with the date by which they should be achieved. For Procurement

reports, please indicate how contracts would be monitored and managed using a detailed

timetable, as set out in the guidance (here).

10.2 The table below details the stages and deadlines for implementing the recommendations:

Activity Proposed Date

Date published on Forward Plan 31.08.2021

Cabinet 13.12.2021

End of Call-in Period (key decisions only) 24.12.2021

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AUDIT TRAIL

REPORT HISTORY

Original discussion with Cabinet Member Ongoing

Report deadline 01.12.2021

Date final report sent 01.12.2021

Part II Exempt from Disclosure/confidential

accompanying report? No

Key decision report Yes

Date first appeared on forward plan 31.08.21

Key decision reasons 3. Meets community impact test.

Background information

Future Lambeth: Our Borough Plan

Recommendations of Lambeth Equalities

Commission 2017

Lambeth Equalities Monitoring Policy 2017

Lambeth Council accreditation with London

Living Wage foundation and implementation of

the London Living Wage in the majority of its

contracts

Anti Slavery Charter

Name and Position/Title Lambeth Directorate Date Sent Date

Received

Comments in

paragraph:

Councillor Andrew Wilson

Cabinet Member for

Finance and

Performance

27.10.21 27.10.21 Throughout

Councillor Adrian Garden

Cabinet Member for

Resident Improvement

and Efficiency

27.10.21 27.10.21 Throughout

Fiona McDermott, Strategic

Director, Finance and

Investment

Finance and Investment 27.10.21 27.10.21 Throughout

Christina Thompson,

Director, Finance and

Property

Finance and Investment 27.10.21 27.10.21 Throughout

David Thomas, Contracts

Lawyer, Legal Services Legal and Governance 27.10.21 03.11.21 4

Wayne Chandai ,

Democratic Services Legal and Governance 27.10.21 05.11.21

Paul Keenleyside Climate

Change and Sustainability –

Technical Lead

Sustainable Growth and

Opportunity Directorate

27.10.21 27.10.21 Throughout

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Lambeth Investment and Opportunity Strategy

Central Government Sustainable Procurement

Tools

GLA Responsible Procurement Policy

Lambeth Air Quality Action Plan

Lambeth Waste Strategy

Lambeth Climate Change Action Plan

Lambeth Flooding Guide

Lambeth Local Flood Risk Management

Strategy

Lambeth Timber Policy

Lambeth Health and Wellbeing Strategy

Sustainability and public health: a guide to

good practice

Government Buying Standards for food and

catering services

Government Healthier and more sustainable

catering adult toolkit

LGA Healthier Food Procurement

London Healthy Workplace Charter

Lambeth Local Authority Declaration on sugar

reduction and healthier food

Appendices

Responsible Procurement Policy

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Updated Oct-21

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LAMBETH COUNCIL RESPONSIBLE PROCUREMENT POLICY 1. Introduction 1.1 Lambeth Council spends roughly £500million each year on the procurement of goods,

services and works. Our approach to this spend has a significant impact on council resources and the community. This presents a vital opportunity for the council to contribute significantly to economic, environmental and social gains, through well planned and executed procurement and commissioning. The Council aims to promote responsible procurement in the management and delivery of all its services in order to alleviate negative impacts on and increase positive experiences for Lambeth’s diverse communities.

1.2 This policy sets out a clear approach to how we will use our procurement activities to

help deliver local priorities and support the well-being of communities over the next three years by embedding Responsible Procurement into our commissioning and procurement activity and realising it through effective contract management.

2. What is Responsible Procurement and Social Value? 2.1 Responsible Procurement refers to the approaches Public Bodies, such as councils,

take to maximise the additional benefits that can be created through procurement activity. It particularly relates to The Public Services (Social Value) Act 2012 which came into force on 31st January 2013.

2.2 This Policy extends the scope of Responsible Procurement considerations to cover all

the Councils’ commissioning and procurement activities. In addition to social value commitments, the Council also incorporates the value for money of the goods, services and works it procures, ethical sourcing and compliance with related legislation such as the Modern Slavery Act 2015 into what should be achieved under responsible procurement. This ensures we get the best value from the monies spent, not just in terms of pure financial benefit but through applying whole life costing models and delivering social, economic and environmental benefits for the benefit of our local communities.

2.3 Responsible Procurement in Lambeth sits as part of a wider Social Value framework.

Social Value is defined as “an approach to leverage Lambeth council’s position as a commissioning, contracting and business partner to advance equality in the borough through collaboration, innovation and targeted social, economic and environmental initiatives to benefit our residents and those that work on behalf of our residents, local enterprises and voluntary community sector.”

2.4 Responsible Procurement as such is a core element of Social Value, alongside

Partnerships and Philanthropy (referred to as the 3Ps).

3. Purpose 3.1 The purpose of this policy and the associated action plan is to:

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i. Ensure all procurement activity contributes to the Council’s overall vision and helps deliver our key priorities.

ii. Support our suppliers and contractors to understand local priorities in order to deliver improved outcomes for our residents.

iii. Provide a framework to support Officers to strengthen and enhance opportunities in delivering social benefit to our communities.

iv. Ensure compliance with relevant legislation, policies and procedures.

3.2 Responsible procurement is only achievable through best-in-class commissioning, procurement and contract management practice. Therefore, this Policy will also be used as a driver for improvement of our commissioning and procurement practice. The policy will therefore also deliver:

i. Improved contracts resulting in improved services, outcomes and facilities

for the whole borough. ii. Achievement of procurement efficiencies, allowing further investment in

services and the borough. iii. Fit for purpose procurement processes that are inclusive and enable the

voluntary, community and social enterprise sector and small businesses to participate.

iv. Improved commissioning practice placing impact-based decision making at the heart of our approach.

4. Scope 4.1 This policy supports the commitment to realising Responsible Procurement outcomes

against the themes set out in the Borough Plan. It is intended for all of those who are involved in, or affected by, the Council’s commissioning and procurement activities.

4.2 The policy covers all areas of commissioning and procurement within the Council and

will influence the way we procure goods, works and services. All procurement activity over £100,000 must comply with the requirements set out in this policy. For procurement below £100,000, Officers must consider the how this policy may be applied whilst having regard for the resources available to smaller providers which may bid for lower value procurement.

4.3 The requirements of this policy will also apply to major sub-contractors.

5. Understanding our societal impact 5.1 For the Council, Responsible Procurement means fostering socially, environmentally

and economically focused procurement to deliver improved quality of life and better value for money for the residents, businesses and visitors. Responsible procurement does not include the direct outcomes generated through services that the council commissions but rather the added value gained (at no cost to the council).

5.2 The Societal Impact Framework has been developed to support the Council to make

better decisions about the impact of its spending. It brings together the Borough Plan, responsible procurement framework, UN Sustainable Development Goals and other frameworks, and was developed through a series of staff workshops.

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Figure 1 Lambeth’s Societal Impact Framework, January 2021

5.3 The societal impact framework will also provide a systematic and comprehensive tool for Officers and potential providers to consider the responsible procurement opportunities as part of a tender exercise.

5.4 It is expected that all procurements will assess how a contract may impact and support

all eight of the themes. However, it is recognised that not all areas of the framework will be relevant to all contracts or services. Officers are encouraged to work with Policy leads across the Council to think strategically and creatively about all eight areas of the framework and the opportunity to support the outcomes from the Borough Plan, Equality Commission recommendations and Manifesto commitments.

5.6 The table below sets out intended outcomes from those areas of the framework that

may more readily be applied to all council contracts.

Education and learning

More young people have the skills they need to succeed in London’s growing economic sectors

Jobs, earnings and business

Increase the number of good jobs in the borough above the trend forecast.

More and better apprenticeships with local employers for young people.

More employment of local young people by local employers.

Increase the proportion of Lambeth residents paid London Living Wage or above.

Increase the opportunities available to those people needing support to access and sustain work, particularly Looked-after Children and people with mental health issues.

Encourage local employers to offer more volunteering, work experience, internships and shadowing opportunities for Lambeth residents from disadvantaged groups

Reduce inequalities in employment rates between different population groups

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Narrow the gap between the proportion of BAME residents, residents with mental health issues or disabilities in paid work on London Living Wage or above, and the general population.

Increase the quality and range of targeted employment opportunities for disabled residents, residents with mental health issues, and residents with complex needs

Environment and climate emergency

Reduce energy consumption and shift to renewable and low carbon forms of energy in line with the Council’s 2030 net zero target

Ensure that development is climate resilient, and where relevant, enables adaptation to future climate change

Work to reduce waste, and increase the percentage of waste that is sent to reuse, recycling or composting

Keep our parks and public spaces clean, well maintained and enjoyable for all, while conserving, enhancing and expanding wildlife habitat and biodiversity

Reduce vehicle milage across Lambeth, and shift to zero emission vehicles

Make it easier and safer to walk and cycle around the borough, so that residents shift to more sustainable forms of transport, more journeys in Lambeth are completed by bike and on foot, and car ownership is reduced.

Reduce air pollution in line with the Council’s air quality targets

Work to introduce a ban on all single use plastics used by the council and all major council suppliers

Health and wellbeing

Reduce the numbers of young people (16-19) whose status is unknown or who are not in education, employment and training, particularly looked after children, and children with SEN and/or disabilities.

Reduce food and fuel poverty and their associated impacts, particularly for children and young people, and older residents

Support more disabled, vulnerable and older adults to maintain their independence, stay healthy, active and engaged for longer, and remain in their homes. Should their health deteriorate, we will aim to treat and support them close to home. If hospital treatment is required, we will support them to go home more quickly.

Reduce inequalities in health and well-being between people with mental health issues, disability, lone parents and general population.

Reduce childhood obesity, with the greatest reduction for children living in poverty and from particular ethnic groups

Reduce the rate of avoidable deaths for the borough (in particular cancer and cardiovascular disease), with rates reducing most for the worst affected groups (low income groups and residents in specific parts of the borough)

Ensure that life expectancy is rising for all, and the gap between poorest and wealthiest is narrowing

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Community and participation

Our children, young people and students have access to the devices and networks they need to thrive and achieve world.

• Our older residents and residents with disabilities have the skills, confidence and support to live independently and well. • Our Black, Asian and Minority Ethnic communities have equitable access to the digital world and the skills needed for learning, play and work, helping to make Lambeth the home to the most diverse digital sector in the UK.

Our unemployed, homeless, refugee, asylum seeking and non-English speaking residents have access to the digital world to access further training and support, and participate in our communities and economy

Provide greater opportunities for the engagement of service users in the design, delivery and management of services

6. Tackling inequality and creating opportunities

6.1 Responsible procurement and social value seek to provide positive impacts on the community through procurement and commissioning and these may be directed to address inequalities and local priorities. This policy therefore is focussed on achieving our equalities priorities as outlined within the Borough Plan. This is increasingly important given the experience of the COVID-19 pandemic and the disproportionate impact it had, and continues to have, on specific parts of our community. Many of the negative impacts of the virus have exacerbated challenges of poverty and inequality already keenly felt by our communities and in particular our Black and Minority Ethnic communities, older and disabled residents. And on those communities, the impact has been and remains compounded by the multiple ways in which those individuals and communities have been hit harder than others.

6.2 In addition, the Lambeth Equality Commission made a number of recommendations in relation to procurement which have been incorporated within this policy. In particular, the Commission recommended that employment and skills opportunities be targeted at those groups affected by the greatest employment related disadvantage.

6.3 As part of the procurement process, the council will therefore require potential providers to consider how their proposed responsible procurement approach helps to support our target groups. At present, these priority groups include:

Looked After Children and care leavers,

young people (those under 25),

Special Education Needs and Disability SEND

disabled people,

black African, black Caribbean and Portuguese groups, and

residents aged 50 and over

7. Equality duty

7.1 The Council is committed to ensuring that equality is considered at each stage of the procurement process our policy and practices adhere to principles of fairness and inclusion. The Equality Act 2010, places a positive duty on public bodies to prevent discrimination in all aspects of service provision, including procurement and places obligations to:

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Prevent and eliminate unlawful discrimination,

Advance and promote equality of opportunity between people that share protected characteristics and those that do not.

Encourage and foster good relations between people that share protected characteristics and those that do not1.

In addition to the protected characteristic enshrined in the equality Act 2010 Lambeth Council commits to consider local protected characteristics, socio-economic status (education, income level health and language

7.2 When providing a public service, our suppliers are bound by the Equality Act and

potential suppliers are required to declare any contravention of labour law and provide their Equality Policy as part of the Standard Supplier Questionnaire process to evidence their commitment. In addition to the overall provisions for equality within procurement, it is a prerequisite that individual procurement projects over £100,000 are supported by equalities analysis primarily in the form of an Equalities Impact Assessment.

7.3 Lambeth is committed to encouraging contractors and other partners that work with

us to evidence good practice in terms of equality and diversity. We recognise that our procurement and commissioning functions can be effective in achieving equality and equality of opportunity in the following areas:

supplier recruitment and selection, for example encouraging small and medium sized enterprises; social enterprises and the voluntary and community sector from diverse or underrepresented backgrounds to participate and our weighting criteria;

staff working conditions, ensuring staff working for suppliers are treated fairly and paid appropriately;

service provision, ensuring contractors are able to meet the needs the of Lambeth’s diverse services users, residents and citizens; and

encouraging good practice in workforce equality and diversity – workforce composition, EDI strategies/ policies.

8. Implementing the Policy 8.1 Whilst commissioning, procurement and contract management can often be seen as

separate activities, they are in fact inter-related functions and are all critical to ensuring we are achieving social value through our supply base.

Commissioning 8.2 Commissioning is the process of ensuring that outcomes identified in the council’s

needs analysis, are delivered through the right service, and the right models of delivery (whether public, private or other sectors through voluntary service sector, or through social enterprises)

1 It is against the law to discriminate against someone because of a protected characteristic. The groups of individuals that share these characteristics: age, disability, gender reassignment, race, religion or belief, sex, sexual orientation, marriage and civil partnership and pregnancy and maternity are protected under the Equality Act 2010F

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8.3 Effective commissioning should consider how different service delivery models may support the achievement of improved service outcomes, efficiencies and/or cost assurance, management of risks and achievement of added value through social, economic and environmental benefits.

8.4 Commitments:

Every service redesign will consider societal impact and the opportunity to secure social value within the business case

We will assess the benefits of alternative service models and where we can improve services for residents and deliver better value for money by bringing more services back in house, we will.

Commissioning will focus on outcomes and effecting long-term change in the community

Social value and responsible procurement will be bespoke for each commissioning activity

Procurement 8.5 Procurement is the process of acquiring, goods, works and services. It involves

buying the services and issuing a contract to the provider in order to make this process legally binding. The process spans the end-to-end cycle from identification of needs, through to the end of a services contract or the end of the useful life of an asset. Tendering is an important part of the procurement stage and responsible procurement should be embedded in all tender documents.

8.6 Commitments

All tenders over £100,000 will be assessed for the potential societal impact and responsible procurement considerations will be included in the tender

All tenders over £500,000 will include a mandatory minimum social value weighting of 10% (as set out in the Contract Standing Orders)

We will promote the ‘Changing Lives’ social value fund (where appropriate) and encourage our providers to contribute either financial or in-kind benefits

Contract and supplier relationship management 8.7 Contract Management involves the day-to-day management of the contract -

understanding the requirements set out in the contract and ensuring the supplier performs in delivering them. Supplier Relationship Management (SRM) focuses on building a longer-term relationship with the supplier, forming common goals and seeking continuous improvement, innovation, and social and added value opportunities for the benefit of both parties throughout the life of the contract.

8.8 It is important once a contract has been let that it is effectively managed, especially

higher value or more complex contracts to ensure the outcomes detailed in the supplier’s tender submission are delivered, risks are identified and mitigated, and cost control is maintained. This will involve obtaining feedback from the client or users of the service, regular meetings with the supplier, gathering data and measuring the supplier’s performance against agreed key performance indicators and implementing improvement measures where necessary. SRM looks at longer term development of the relationship with the supplier, seeking mutual opportunities for cost and service improvements and innovation.

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8.9 Commitments:

Where responsible procurement is a requirement of the contract, we will require suppliers to report quantifiable social benefits against the themes of the societal impact framework

The corporate contract management framework will include guidance and tips to support contract managers in managing responsible procurement outcomes

The Council will publish an annual responsible procurement impact report bringing together activity from across our contract portfolio

Market shaping

8.10 Local businesses, and the VCSE sector and social purpose companies in particular, can play a powerful and essential role in delivering key services. Although social value can be generated from all public spending, we recognise and value the important role of local organisations in creating and securing social benefit within our community. Through this Policy we aim to increase supplier diversity.

8.11 We acknowledge the VCSE unique selling point and ability to achieve social value

goals as part of its day-to-day business. To this end, the sector can deliver wider social benefits beyond the scope of this framework, including:

Social capital generated through the use of volunteering

Roots in the community and ability to engage locally

Access to wider networks and partnerships to benefit wider priorities

Leverage funding from external sources

Provide unique opportunities for community-led design and co-production

Benefits the local economy by employing locally based staff

8.12 This policy aims to ensure that wherever possible local, VCSE and social purpose organisations are included as part of the supply chain. This provides the opportunity to improve value for money, enhance social value outcomes and, strengthen local market competitiveness.

8.13 Commitments:

We will proactively engage with local businesses and VCSE to ensure our commissioning and procurement approach is inclusive

We will ensure that the council’s processes provide the opportunity for VCSE and social purpose companies to articulate their inherent social value.

We will work with providers to ensure that employment and supply chain opportunities are advertised on Opportunity Lambeth

We will support local businesses and VCSE to develop the capacity and capability to compete

9. Responsibility for this Policy 9.1 The Council will work with suppliers, partners and other stakeholders to achieve the

set objectives set out in the Policy. Delivery of the commitments made in this policy and progress against the stated objectives will be monitored and reported on an annual basis as part of the responsible procurement impact report.

9.2 Lambeth’s Senior Leadership team have an important role to play in ensuring

Responsible Procurement is taken into account in the design and delivery of all

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services. Elected members must ensure that responsible procurement is considered in all Council decision making.

9.3 Lambeth procurement team are responsible for this policy and will work closely with

Commissioners (Service Managers, Project and Programme managers, etc.) to incorporate responsible procurement and support the Council’s commitments and outcomes as outlined below.

9.4 Practical guidance, templates and training will be provided on how responsible

procurement considerations can be incorporated throughout the Council’s commissioning and procurement processes at Business Case; Procurement Strategy; specification; tender evaluation and award and contract management.

10. Communicating, Monitoring and Reporting 10.1 This policy and related guidance will be available on the intranet and will be available publicly on the Council’s website. 10.2 The Council’s progress in achieving Responsible Procurement objectives will be

reported as part of the Council's annual responsible procurement impact report. The report will be used to demonstrate compliance with other legislation that places specific requirements on the Council with respect to all procurement activities, for example, the Equality Act 2010.

11. Reviewing

This policy will be reviewed annually and updated in line with the following;

changes in Lambeth's priorities

any new legislation, regulations and new government guidance and standards

departmental developments

the Council’s Procurement Strategy and

other Lambeth Policies and Drivers

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Lambeth Policies and other Drivers Appendix A

The following documents have been reviewed and informed development of this guide and will

assist and guide achievement of our aspirations towards responsible procurement.

Future Lambeth: Our Borough Plan

Recommendations of Lambeth Equalities Commission 2017

Lambeth Equalities Monitoring Policy 2017

Lambeth Council accreditation with London Living Wage foundation and implementation

of the London Living Wage in the majority of its contracts

Anti Slavery Charter

Lambeth Investment and Opportunity Strategy

Central Government Sustainable Procurement Tools

GLA Responsible Procurement Policy

Lambeth Air Quality Action Plan

Lambeth Waste Strategy

Lambeth Climate Change Action Plan

Lambeth Flooding Guide

Lambeth Local Flood Risk Management Strategy

Lambeth Timber Policy

Lambeth Health and Wellbeing Strategy

Sustainability and public health: a guide to good practice

Government Buying Standards for food and catering services

Government Healthier and more sustainable catering adult toolkit

LGA Healthier Food Procurement

London Healthy Workplace Charter

Lambeth Local Authority Declaration on sugar reduction and healthier food

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Lambeth Responsible Procurement Checklist Appendix B

Priority TOMS ref

Measure Unit

Jobs, Earnings & Businesses

Key impact areas: supporting financial inclusion, encouraging good employment, creating a thriving

local economy, advancing financial equality

1. Good quality jobs with fair pay and decent working conditions

Accreditation to Living Wage Foundation or commitment to pay real London Living Wage or Living Wage to contract and sub contract staff.

Contracts with total value over £100,000.

Required

Modern Slavery Statement (over £36m turnover)

Whistle-blowing policy for employees to blow the whistle on suspected modern slavery.

Required

Employees are free to join a trade union and not treated unfairly for belonging to one.

Required

2. Targeted employment opportunities for Lambeth residents from priority groups*

NT1 No. of local people (FTE) employed on contract for one year or the whole duration of the contract, whichever is shorter.

Number of people FTE

NT3 No. of employees (FTE) taken on who are from a Lambeth priority group

Number of people FTE

3. Increased supply chain opportunities for Lambeth businesses and VCSE

NT14 Total amount (£) spent with VCSEs within your supply chain

Required

NT18 Total amount (£) spent in LOCAL supply chain through the contract.

Required

Education & Learning

Key impact areas: supporting educational attainment, increasing lifelong learning and skills development, creating opportunities and aspirations and advancing equality in education. 4. Quality apprenticeships

for Lambeth residents: focus on priority groups*

NT10 No. of apprenticeships on the contract that have either been completed during the year by Lambeth residents from priority groups, or that will be supported by the organisation to completion in the following years - Level 2,3, or 4+ Standard recognised by the Institute for Apprenticeships and Technical Education

Number of completed apprenticeships (FTE apprentices)

Environment & Climate Emergency

Key impact areas: lowering carbon emissions, reducing production, consumption and waste,

supporting ecosystems, biodiversity and green space, ensuring air and water quality, providing

resilience and adaptive capacity

5. Reduce emissions: focus on cutting our carbon footprint and improving air quality

Silver Fleet Operator Recognition Scheme (FORS) accreditation or equivalent’ - required for all contracts with a significant transport element.

Accreditation number

Contractors required to report on CO2 emissions released in delivery of the Council’s contracts

Tonnes CO2e

Contractors required to report on steps taken to reduce CO2 emissions in delivery of the Council’s contracts, and emissions reductions

Tonnes of CO2e

Page 110

Page 13 of 14

and measures introduced to reduce CO2e

Percentage of a contractor’s fleet used for the contract that are zero emission vehicles

Percentage

6. Reduce consumption of materials, reuse materials, repair and recycle: focus to eliminate single use plastics.

Measures that the contractor uses to reduce waste and increase re-use, recycling and composting of materials

Tonnes of waste produced, and percentages of waste sent for reuse, recycling, composting and residual disposal

Detail of single use plastics eliminated.

Required for contracts with a food & drink element or goods, materials or equipment deliveries.

Text

Health & Wellbeing

Key impact areas: increasing access to nutritious food, supporting wellbeing, improving mental and physical health, encouraging physical activity, enabling access to support

7. Maximise positive health and wellbeing: focus on supporting a healthy workforce and healthier, affordable and more sustainable food and drinks offer

Adoption of London Healthy Workplace Charter or equivalent

Certificate number

Confirmation that Food & Drink will comply with the Government Buying Standard.

Required where there is a food or drink element within the contract such as catering, a café, canteen or vending machines.

Required

Community & Participation

Key impact areas: tackling the digital divide, improving digital literacy, enabling service user involvement in service design and management

8. Tackle digital exclusion by enhancing the digital skills of Lambeth residents and improving connectivity across the borough

Initiatives that support equitable access to the digital world and help Lambeth residents to develop the skills needed

Required

9. Encourage co-production of services to achieve improved outcomes

Service user engagement and feedback processes are in place and used to shape service delivery

Required

10. Investing in Lambeth’s local communities

NT28 Donations or in-kind contributions to local community projects

(Including the ‘Changing Lives’ social value fund)

£ or in-kind

NT27 No hours volunteering time provided to support local community projects

Required

Safety & Justice

Key impact areas: helping people to feel safe at home and in their local area, awareness of their human rights and how to access justice and freedom from abuse and slavery

11. Ensure all workers are free from abuse and slavery

Confirmation that provider complies with the Modern Slavery Act 2015

Required

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Page 14 of 14

Relationships & Family

Key impact areas: reducing loneliness and isolation and build strong networks and relationships. Improving the home environment and support early child health and development. Building parent/carer capacity.

12. Reducing social isolation Initiatives to be taken to support older, disabled and vulnerable people to build stronger community networks (e.g., befriending schemes, digital inclusion clubs)

Required

Housing & Infrastructure

Key impact areas: improving the suitability and availability of housing as well as improving accessibility and transportation

13. Developing local community infrastructure

Initiatives to support the development of local infrastructure

Required

Other Proposed Initiatives

Key impact areas: delivering improved service and reducing costs with a positive influence on

Lambeth communities.

14. Innovation NT36 Other measures (£) - please describe any additional initiatives that you would like to offer.

£

15. Corporate responsibility and governance

Statement of pro-social objectives such as the adoption of ethical procurement principles, the promotion of volunteerism among company employees and donating to charity.

Required

* At present, these priority groups include:

Looked After Children and Care leavers,

young people (under 25),

disabled people

Special Education Needs and Disability SEND

black African, black Caribbean and Portuguese groups,

residents aged 50 and over,

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1

Cabinet 13 December 2021

Report title: Draft Site Allocations Development Plan Document (Regulation 18)

Wards: All wards

Portfolio: Councillor Matthew Bennett: Deputy Leader (Cabinet Member for Planning, Investment and New

Homes)

Report Authorised by: Eleanor Purser and Sara Waller: Strategic Directors Sustainable Growth and

Opportunity

Contact for enquiries: Catherine Carpenter, Head of Policy and Place-shaping, Sustainable Growth and

Opportunity, 020 7926 1251, ccarpenter@lambeth.gov.uk

Report summary

The Site Allocations Development Plan Document (SADPD) will, if adopted, be part of the statutory

development plan for Lambeth, alongside the Lambeth Local Plan 2021, the London Plan 2021 and South

Bank and Waterloo Neighbourhood Plan 2019. It will support delivery of sustainable growth and opportunity

in the borough, and implementation of wider Council strategies including the Borough Plan, Economic

Resilience Strategy, Transport Strategy and emerging Climate Action Plan. The SADPD will add site-

specific policies to those already in the Lambeth Local Plan 2021: its principal objective is to unlock

investment on these sites through the mechanism of site-specific planning policy.

The Draft SADPD at Appendix 1 of this report includes emerging site allocation policies for fourteen sites,

distributed across the borough. These sites have potential to deliver new sustainable development that

includes housing, commercial uses and social infrastructure. The guiding approach in the draft policies is

design-led optimisation of development capacity, as required by London Plan policy. The draft policies

address key objectives for strategic place-making, as well as affordable housing and affordable workspace,

healthy routes and active travel, townscape, public realm, community safety and urban greening. Existing

development plan standards for housing quality, amenity space, parking, carbon reduction and employment

and skills will apply to these sites, and the ambition for exemplary approaches in meeting these standards

has been clearly signalled.

It is proposed to undertake public consultation on the Draft SADPD for six weeks in January and February

2022. The proposed approach to consultation and engagement is set out in Appendix 2.

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2

Finance summary

The projected revenue cost of producing the Site Allocations Development Plan Document to adoption is £231,000, of which £206,000 will be funded through existing revenue budgets and £25,000 by GLA Homebuilding Capacity Fund grant. Recommendations

1. To agree consultation in accordance with Regulation 18 of the Town and Country Planning (Local

Planning)(England) Regulations 2012 on the subject of a proposed site allocations development plan

document, including the Draft Site Allocations Development Plan Document at Appendix 1 of this report,

for six weeks between January and February 2022.

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3

1. Context

1.1 The Site Allocations Development Plan Document (SADPD) will, if adopted, be part of the statutory

development plan for Lambeth, alongside the Lambeth Local Plan 2021, the London Plan 2021 and

South Bank and Waterloo Neighbourhood Plan 2019. It will therefore be part of the suite of policy

documents that help deliver sustainable growth, investment and opportunity in Lambeth, along with

the revised CIL Charging Schedule and emerging supplementary planning documents. It will also

support implementation of wider Council strategies including the Borough Plan, Economic Resilience

Strategy, Transport Strategy and emerging Climate Action Plan.

1.2 The SADPD will add site-specific policies to those already in the Lambeth Local Plan 2021. The

principal objective of the SADPD is to unlock investment on these sites through the mechanism of site-

specific planning policy.

Statutory process

1.3 Preparation of the SADPD is the same as that for the recently adopted Lambeth Local Plan. This involves a number of stages required by the regulations governing plan preparation. In summary, these include:

Consultation on the subject of the Draft SADPD (Regulation 18 of the Town and Country Planning

(Local Planning) (England) Regulations 2012).

Consideration of representations received and revisions to the draft document.

Agreement by the Council of the version it intends to submit for examination (SADPD Proposed

Submission Version).

Publication of the proposed submission version of the SADPD, along with an open invitation to

submit representations (Regulations 19 and 20).

Submission of the proposed DPD and supporting documents to the Secretary of State, along with

any representations received at pre-submission publication (Regulation 22).

Independent examination by a planning inspector on behalf of the Secretary of State; this involves

an assessment against legal and procedural requirements and consideration of the ‘soundness’ of

the plan against four tests.

Assuming the Plan is found to be ‘sound’ by the inspector, adoption of the Plan by the Council.

1.4 The four tests of soundness are set out in the National Planning Policy Framework 2021. Plans are

‘sound’ if they are considered by the inspector to be:

a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s

objectively assessed needs; and is informed by agreements with other authorities, so that unmet

need from neighbouring areas is accommodated where it is practical to do so and is consistent

with achieving sustainable development;

b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based

on proportionate evidence;

c) Effective – deliverable over the plan period, and based on effective joint working on cross-

boundary strategic matters that have been dealt with rather than deferred, as evidenced by the

statement of common ground; and,

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4

d) Consistent with national policy – enabling the delivery of sustainable development in accordance

with the policies in the National Planning Policy Framework.

National Planning Policy Framework (NPPF)

1.5 The latest version of the NPPF was published by government in July 2021. The SADPD will need to

be consistent with the policies in the NPPF to succeed at examination under the tests of soundness.

General conformity with the London Plan

1.6 In addition to being consistent with national policy, a London borough development plan document must

be ‘in general conformity’ with the London Plan. This means the strategy and policy approach should

not contradict that established at regional level: borough development plan policies should be used

principally to reinforce and add local detail to the London-wide approach. The current version of the

London Plan was published in March 2021.

2. Proposal and Reasons

2.1 The Draft SADPD at Appendix 1 of this report includes emerging site allocation policies for fourteen

sites, distributed across the borough. All have potential to deliver housing alongside commercial uses,

apart from two that relate to hospital campuses. The location of the fourteen sites is shown on Map 1

at page 7 of the Draft SADPD. They include four sites in Waterloo, three in Brixton, one in Streatham,

two in West Norwood/Tulse Hill, one in Kennington and three in Loughborough Junction.

2.2 Of the fourteen sites, three have existing allocations in the Lambeth Local Plan 2021 (Royal Street

(Site 1), Gabriel’s/Princes Wharf (Site 9) and Norwood Road (Site 18)). These existing allocations will

be superseded on adoption of the SADPD. The other existing allocations within the Local Plan 2021

will be unaffected by the SADPD and will remain as they are. Appendix 4 of this report provides a

factual update on the latest position with the sites that are subject to existing adopted site allocations.

The numbering of the proposed allocations in the Draft SADPD is designed to work alongside the

numbering of the existing allocations in the Local Plan 2021. A table showing the proposed site

allocations and how these relate to existing allocations in the Lambeth Local Plan 2021 is provided at

Annex 1 of the Draft SADPD (at Appendix 1 of this report).

2.3 Cabinet is asked to agree ‘Regulation 18’ consultation on the subject of the Draft SADPD for six weeks

starting in January 2022. Further information about the proposed consultation approach is set out in

Section 5 below and in the consultation and engagement plan included at Appendix 2 of this report.

2.4 Sites are included in the Draft SADPD for one or more of the following reasons:

to set clear, site-specific parameters for the type and scale of development expected on a site,

including the associated public benefits it should deliver;

to address site-specific circumstances that may require a more tailored approach to that set out in

borough-wide policies;

to articulate the vision and potential that can be achieved through land assembly and/or a

comprehensive approach to developing adjacent sites, particularly where these are in different

ownerships;

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5

to encourage landowners to consider the potential for optimising the development capacity of their

land and help deliver key place-making objectives, where they might otherwise be uncertain about

what would be supported;

to signal some additional sites as appropriate for tall buildings, outside the locations already

identified in the Local Plan;

to enable key strategic infrastructure to come forward in a timely way.

2.5 It is not necessary, or recommended, to have a site-specific allocation for every potential development

site in the borough. Many larger sites can and do come forward successfully without such a policy,

with sustainable development achieved through application of the borough-wide and neighbourhood-

level policies in the development plan as a whole. There is also no need in Lambeth to allocate sites

to demonstrate the borough’s ability to meet its London Plan housing target, as this was achieved

through the recent examination of the revised Lambeth Local Plan. However, the new site allocation

policies will help to accelerate delivery of housing in the borough, which will contribute to maintaining

the necessary pipeline of new housing and thereby help ensure housing delivery targets continue to

be achieved. They will also enable the timely renewal and optimisation of social infrastructure and

commercial floorspace.

2.6 The guiding approach in developing the draft site allocation policies is design-led optimisation of

development capacity, as required by London Plan policy. This has involved policy-level analysis of

the optimum mass and height that can be achieved, having regard to all planning constraints relevant

to that site, including impacts on neighbouring uses, views, townscape and heritage assets. Key

spatial objectives have been factored in and identified, such as opportunities to contribute to strategic

place-making – for example the Central Activities Zone and potential for an SC1 life-

sciences/innovation district, South Bank creative and cultural quarter, town centres, or the growing

cluster of flexible workspace in West Norwood/Tulse Hill. Other objectives addressed include

improvement in movement and permeability, healthy routes and active travel, townscape, public

realm, community safety and urban greening.

2.7 Existing development plan standards for sustainable design and construction, zero carbon, climate

change adaptation, urban greening, employment and skills, housing quality, amenity space,

community safety, transport and parking will apply to these sites, and the ambition for exemplary

approaches in meeting these standards has been signalled in the Draft SADPD. Where possible,

additional site-specific guidance has been included on matters such as flood risk mitigation and air

quality. The aspiration for key public benefits is also signalled, such as employment and skills

contributions tailored to particular growth sectors.

Evidence

2.8 New policies need to be justified by evidence to meet the requirements of the statutory tests of

soundness for development plans. Supporting evidence that explains the approach to design-led

optimisation will therefore be made available alongside the Draft SADPD during the Regulation 18

consultation. The final evidence base documents supporting the SADPD Proposed Submission Version

will undergo examination alongside the DPD itself.

Sustainability appraisal

2.9 Emerging development plan documents must undergo a statutory process of sustainability appraisal.

This is a systematic process that aims to promote sustainable development by assessing the extent to

which the emerging plan, when judged against reasonable alternatives, will help to achieve relevant

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6

environmental, economic and social objectives. This includes consideration of impacts on equality and

health and well-being. The proposed policies in the Draft SADPD, alongside consideration of

reasonable alternatives, have been appraised against environmental, social (including health and

equalities) and economic objectives. The sustainability appraisal of the Draft SADPD will be published

for comment as part of the Regulation 18 consultation. The recommendations of the sustainability

appraisal and the results of consultation will together inform revisions to the SADPD prior to finalisation

of the Proposed Submission Version for pre-submission publication and submission. The final

sustainability appraisal will undergo examination alongside the SADPD itself.

Duty to cooperate

2.10 The Localism Act 2011 introduced the ‘duty to cooperate’, which places a legal duty on local planning

authorities and other public bodies to engage constructively, actively and on an ongoing basis to

maximise the effectiveness of development plan preparation in the context of cross-border strategic

planning issues. This duty is also reflected in the ‘positively prepared’ test of soundness .

2.11 The NPPF 2021 and associated planning practice guidance require local planning authorities to agree

a Statement of Common Ground with relevant bodies prior to submission of a development plan

document for examination.

2.12 Officers meet periodically with counterparts in neighbouring authorities and other statutory bodies to

discuss issues under the ‘duty to cooperate’. In relation to the Draft SADPD, this includes those sites

close to the borough boundary. Statements of Common Ground will be prepared in time for submission

of the SADPD.

Weight of the emerging policies in planning decision-making

2.13 Under paragraph 48 of the NPPF 2021, local planning authorities may give weight to relevant policies

in emerging plans according to: a) the stage of preparation of the emerging plan (the more advanced

its preparation, the greater the weight that may be given); b) the extent to which there are unresolved

objections to relevant policies (the less significant the unresolved objections, the greater the weight

that may be given); and c) the degree of consistency of the relevant policies in the emerging plan with

the NPPF (the closer the policies in the emerging plan to the policies in the NPPF, the greater the

weight that may be given). Ultimately the degree of weight to be attached to emerging policies will be

a matter for the individual decision-maker involved in determining a planning application.

3 Finance

3.1 Table 1 below sets out the projected revenue costs and timeframes for producing the SADPD to adoption. Table 1 – Projected cost by year

Year

Projected

Amount (£)

2021/22 81,000

2022/23 63,000

2023/24 87,000

Total 231,000

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7

3.2 This will be funded through £206,000 of existing revenue budgets and £25,000 by GLA Homebuilding

Capacity Fund grant.

3.3 The projected costs cover the use of consultants, public consultation, examination and document production.

3.4 Officer time spent on the preparation of the SADPD will be funded through existing revenue staffing budgets.

4 Legal and Democracy

4.1 The legislative framework that governs the process of preparing a development plan document is

contained in the Planning and Compulsory Purchase Act 2004 and the Town and Country Planning

(Local Planning) (England) Regulations 2012. Section 2 of the report sets out the steps that it is

proposed to take by reference to the requirements of those regulations.

4.2 Regulation 8 of the 2012 Regulations sets down what a development plan document needs to contain.

A development plan document is required to contain a reasoned justification of the policies that it

contains. It may introduce policies that are intended to supersede particular policies in an adopted

development plan, as long it is made clear which policies in the adopted plan are being superseded.

To the extent that policies in the adopted development plan are not being superseded, the policies in

the new development plan document need to be consistent with the adopted development plan.

4.3 Regulation 18 of the 2012 Regulations sets out the requirements for consultation at the start of the

formal plan-making process. The local planning authority needs to make a range of people and

bodies aware of the subject of development plan document that it proposes to prepare, and invite

them to make representations about what such a development plan document should contain. The

people and bodies to be consulted under Regulation 18 are as follows:

‘Specific consultation bodies’ likely to have an interest in the subject of the proposed development

plan document. The bodies are specified in the 2012 Regulations and includes organisations such

as Historic England and the Environment Agency, infrastructure undertakers and neighbourhood

forums;

‘General consultation bodies’ that the local planning authority considers it appropriate to consult.

These are also defined in the 2012 Regulations and essentially comprise local voluntary bodies,

and bodies operating in the authority’s area which represent the interests of different racial, ethnic

or national groups and different religious groups, the interests of disabled persons and the interests

of persons carrying on business; and

‘Such residents and other persons carrying on business in the area that the local planning authority

considers it appropriate to invite representations from.’

4.4 It is proposed in this case to provide people whose views are sought with a draft development plan

document as part of the Regulation 18 consultation process. Section 5 of the report sets out the

proposals for consultation in more detail.

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4.5 This proposed key decision was entered in the Forward Plan on 24 November 2020 and the

necessary 28 clear days’ notice has been given. The report will be published for five clear days before

the decision is considered by Cabinet. Should it be approved and following the publication of the

Cabinet minutes, a further period of five clear days, the call-in period, must then elapse before the

decision becomes effective. If the decision is called-in during this period, it cannot be enacted until the

call-in has been considered and resolved.

5 Consultation and co-production

5.1 The full consultation process for preparation of the SADPD is set out in paragraph 1.3 above. Cabinet

is being asked in this report to agree to undertake the first stage in this process, known as Regulation

18 consultation. If agreed, Regulation 18 consultation will start in January 2022 and last six weeks. This

will take the form of consultation on a full draft of the SADPD, which will be published on-line and made

available in hard copy in libraries.

5.2 The consultation will be promoted widely through a database of those who have asked to be kept

informed of planning policy consultations. This database also includes the ‘specific’ and ‘general’

consultation bodies required in the Town and Country Planning (Local Planning) (England) Regulations

2012). Specific and general consultation bodies are listed in Appendix 1 of the Lambeth Statement of

Community Involvement 2020, along with further information about the people, groups and

organisations included on the consultation database.

5.3 The consultation will be further promoted via wider email distribution lists, council publications, e-

bulletins and social media. Meetings will be held with key stakeholder groups in different parts of the

borough during the six week consultation period. Consultees will be asked to comment using an on-

line form or by email or letter. This is consistent with the approach set out in the Council’s Statement of

Community Involvement 2020. A more detailed consultation and engagement plan is included at

Appendix 2 of this report.

5.4 The Mayor of London will be consulted on the Draft SADPD and it is anticipated his response will give

an indication of whether he considers it to be in general conformity with the London Plan. The Mayor

will be asked to express a final view on general conformity at Regulation 19 pre-submission publication

stage (as required by Regulation 21 of the Town and Country Planning (Local Plans) (England)

Regulations 2012).

5.5 The results of the consultation will be assessed and reported in a consultation report. The responses

received will inform the content of the SADPD Proposed Submission Version, which will be reported to

Cabinet and Council for agreement prior to Regulation 19 publication and submission.

6 Risk management

6.1 The procedures for seeking to prepare a development plan document are governed by legislation,

supplemented by guidance issued by central government relating to particular stages in the process.

Issues that may arise from the consultation (for example questions about the extent of conformity with

national and London-wide policy) will be addressed in the process of plan preparation as outlined in

paragraph 2.1 above, by ensuring the plan-making regulations are correctly followed, by engagement

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9

with relevant bodies under the duty to cooperate and by addressing the requirements of the statutory

tests of soundness.

7 Equalities impact assessment

7.1 Assessment of the equalities impacts of the emerging site allocation policies is being undertaken on an

ongoing basis as part of the process of statutory sustainability appraisal (see paragraph 2.9 above).

The final outcome of the sustainability appraisal process, including assessment of equalities impacts,

will be reported to Cabinet and Council at the end of the plan preparation process.

7.2 An Equalities Impact Assessment (EIA) has been undertaken of the policies in the Draft SADPD, and

on the proposed approach to consultation and engagement, to inform the decision that is being taken

now. This is included at Appendix 3. This EIA draws on the findings of the sustainability appraisal

described in paragraph 2.9 above. The EIA concludes that, overall, the proposed policies in the Draft

SADPD have potential to have a positive effect on some protected characteristics such as those within

more disadvantaged socio-economic groups, some disabled people and some younger and older

people. It also notes that the proposed policies include measures to help mitigate potential harmful

impacts. In relation to the proposed approach to consultation and engagement, it concludes that, within

the resources available, measures have been identified to promote the consultation and engage pro-

actively with those with protected characteristics.

7.3 The Equalities Impact Assessment Panel has considered the EIA and made recommendations about

one of the proposed draft site allocation policies (SA21), which resulted in an update to the wording of

the Draft SADPD (Appendix 1 of this report) and to the EIA (Appendix 3a of this report). The EIA Panel

feedback form is included at Appendix 3b of this report. The EIA Panel will have a further opportunity

to consider the Draft SADPD after the Regulation 18 consultation, at the next stage in the plan

preparation process.

8 Community safety

8.1 Planning and the built environment have a considerable impact on community safety. The Draft SADPD

considers the context for community safety for each site and includes site-specific provisions where

relevant to improve conditions through the design of development proposals. This is in addition to

borough-wide policy Q3 in the Lambeth Local Plan, which will also apply to each site and specifically

addresses safety, crime prevention and counter terrorism; and to emerging supplementary planning

guidance on urban design. The social impacts of this approach have been assessed as part of the

sustainability appraisal process outlined in paragraph 2.9 above.

9. Organisational implications

Corporate Parenting

9.1 Not applicable.

Staffing and accommodation

9.2 Not applicable.

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Responsible Procurement

9.3 Not applicable

Good Quality Jobs with Fair Pay and Decent Working Conditions

9.4 Not applicable.

Quality Apprenticeships, targeted Employment for Lambeth residents and Lambeth Priority

Group

9.5 Where relevant, the policies in the Draft SADPD signal opportunities to tailor site-specific employment

and skills plans to specific growth sectors appropriate to particular sites. This will supplement Lambeth

Local Plan 2021 policy ED15, which secures employment and training opportunities from new

development for Lambeth residents and will apply to all the sites included in the Draft SADPD. This

approach will contribute to implementing the Council’s Economic Resilience Strategy. The social

impacts of this approach have been assessed as part of the sustainability appraisal process outlined in

paragraph 2.9 above.

Reduce Emissions: Lambeth Council has a commitment to being Zero Carbon by 2030

9.6 The London Plan 2021 and Lambeth Local Plan 2021 include numerous policies that address climate

change mitigation and adaptation through the planning process. This includes policies on transport,

waste management, flood risk and sustainable urban drainage, open space, trees and green

infrastructure, nature conservation and biodiversity, local food growing, carbon dioxide emissions

reduction, energy efficiency and sustainable design and construction. All these borough-wide policies

will apply to the sites included in the Draft SADPD.

9.7 In addition, the site allocation policies in the Draft SADPD include site-specific provisions for developers

to take into account in their proposals. The draft policies also clearly signal the expectation of an

exemplary approach to meeting the policy requirement to achieve net zero carbon. The Draft SADPD

therefore provides an additional mechanism to help the Council achieve its objective of net zero carbon

and climate change adaptation across the borough.

9.8 The environmental effects of the Draft SADPD have been assessed as part of the sustainability appraisal

process outlined in paragraph 2.9 above.

Single Use Plastics 9.9 Not applicable.

Positive Health and Wellbeing 9.10 The policies in the Draft SADPD are intended to achieve significant improvements in the health and

well-being of those living and/or working on or near, or passing through, the sites in question, through

setting out the optimum approach to design of new buildings and associated public realm and through

promotion of active travel and urban greening. All the existing borough-wide standards for new

development in the Local Plan and London Plan and associated planning guidance will also apply to the

sites in question. The health and well-being impacts of the Draft SADPD have been assessed as part

of the sustainability appraisal process outlined in paragraph 2.9 above.

Other Offers (Innovation) 9.11 Not applicable.

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11

10. Timetable for implementation

10.1 The indicative timetable for the remaining steps in the preparation of the SADPD is set out in the table

below and reflects the timetable in the Council’s Local Development Scheme October 2021.

10.2 If Cabinet agree to the recommendation of this report, consultation on the Draft SADPD will start after

the end of the call-in period for the Cabinet decision, assuming no call-in takes place. The anticipated

start date for the consultation is 10 January 2022, ending after six weeks on 21 February 2022.

Stage Date

Consultation (Regulation 18) – six weeks January-February 2022

Pre-submission publication of the SADPD Proposed

Submission Version (Regulations 19 and 20)

Winter 2022/23

Submission (start of examination) (Regulation 22) Spring 2023

Examination hearing Summer 2023

Adoption Winter 2023/24

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12

Audit trail

Consultation

Name/Position

Lambeth cluster/division or

partner Date Sent

Date

Received

Comments in

para:

Cllr Matthew Bennett Deputy Leader (Planning, Investment

and New Homes) 11.11.2021 22.11.2021

Para 2.2 and

Appendix 4

Eleanor Purser and

Sara Waller

Strategic Directors Sustainable

Growth and Opportunity 02.11.2021 04.11.2021

Para 1.1 and

report

summary

Rob Bristow Director Planning, Transport and

Sustainability 27.10.2021 02.11.2021 Throughout

Susan Boucher Legal Services 05.11.2021 12.11.2021 Section 4

Sarah Keeble Democratic Services 05.11.2021 11.11.2021 Section 4

Paul Badiani Corporate Resources 05.11.2021 11.11.2021 Section 3

Report history

Original discussion with Cabinet Member 18 October 2021

Report deadline 1 December 2021

Date final report sent

Report no. N/A

Part II Exempt from Disclosure/confidential

accompanying report? N/A

Key decision report Yes

Date first appeared on forward plan 24 November 2020

Key decision reasons 3. Community Impact

Background information

Lambeth Local Plan 2021

London Plan 2021

National Planning Policy Framework

National Planning Practice Guidance Town and Country Planning (Local Planning)

(England) Regulations 2012

Lambeth Statement of Community Involvement

2020

Lambeth Local Development Scheme October

2021

Appendices

Appendix 1 – Draft Site Allocations

Development Plan Document

Appendix 2 – Consultation and engagement

plan

Appendix 3a – Equalities Impact Assessment

Appendix 3b – Equalities Impact Assessment

Panel feedback form

Appendix 4 – Position on sites subject to

existing adopted site allocations in the Lambeth

Local Plan 2021

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Lambeth Site Allocations Development Plan DocumentRegulation 18 Consultation Draft

January 2022

Page 127

II Draft Lambeth Site Allocations Development Plan Document

ContentsSection 1: Introduction 1

Map 1: Proposed Site Allocations 7

Section 2: Proposed Waterloo and South Bank Site Allocations 8

Proposed Site 1: Royal Street SE1 10Proposed Site 2: St Thomas’ Hospital SE1 23Proposed Site 8: 110 Stamford Street SE1 36Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1 45

Section 3: Proposed Brixton Site Allocations 58

Proposed Site 17: 330–336 Brixton Road SW9 60Proposed Site 20: Tesco, 13 Acre Lane SW2 70Proposed Site 21: 51–65 Effra Road SW2 79

Section 4: Proposed Streatham Site Allocation 92

Proposed Site 3: 35–37 and Car Park Leigham Court Road SW16 94

Section 5: Proposed West Norwood / Tulse Hill Site Allocations 104

Proposed Site 18: 286–362 Norwood Road SE27 106Proposed Site 19: Knolly’s Yard SW16 118

Section 6: Proposed Kennington / Oval Site Allocation 128

Proposed Site 7: 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11 130

Section 7: Proposed Loughborough Junction Site Allocations 140

Proposed Site 22: 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24 142Proposed Site 23: Land at corner of Coldharbour Lane and Herne Hill Road SE24 153Proposed Site 24: King’s College Hospital, Denmark Hill SE5 163

Annex 1: Relationship with site allocations in Lambeth Local Plan 2021 176

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Section 1: Introduction

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The Site Allocations Development Plan Document

1.1 Once adopted, the Site Allocations Development Plan Document (SADPD) will be part of the statutory development plan for Lambeth, alongside the Lambeth Local Plan 2021, the London Plan 2021 and South Bank and Waterloo Neighbourhood Plan 2019. It will therefore be part of the suite of planning policy documents that help deliver sustainable growth and investment in Lambeth. It will support implementation of wider Council strategies including the Borough Plan, Economic Resilience Strategy, Transport Strategy and emerging Climate Action Plan.

1.2 The principal objective of the SADPD is to unlock investment through the mechanism of site-specific planning policy.

1.3 This Draft of the SADPD adds site-specific policies to those already in the Lambeth Local Plan 2021. The SADPD should be read, and policies will be applied, alongside and in conjunction with the rest of the development plan for Lambeth, namely the London Plan, Local Plan and made neighbourhood plans.

1.4 The Draft SADPD includes policies for fourteen sites, distributed across the borough as shown on Map 1. Of these sites, three have existing allocations in the Lambeth Local Plan 2021: Royal Street (Site 1); Gabriel’s/Princes Wharf (Site 9) and Norwood Road (Site 18). These existing allocations will be superseded on adoption of the SADPD. The other existing allocations within the Local Plan 2021 are unaffected by the SADPD and will remain as they are in the Local Plan.

1.5 The numbering of the proposed allocations in the Draft SADPD is designed to work alongside the numbering of the existing allocations in the Local Plan 2021. See Annex 1 for a full list of the site allocations in both the Local Plan 2021 and the Draft SADPD.

Process

1.6 Preparation of the SADPD is the same as that for the recently adopted Lambeth Local Plan 2021. This involves a number of stages required by the regulations governing plan preparation. In summary, these include:

• Consultation on the subject of the DPD (Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).

• Consideration of representations received and revisions to the draft document.

• Agreement by the Council of the version it intends to submit for examination (SADPD Proposed Submission Version).

• Publication of the proposed submission version of the SADPD, along with an open invitation to submit representations (Regulations 19 and 20).

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• Submission of the proposed DPD and supporting documents to the Secretary of State, along with any representations received at pre-submission publication (Regulation 22).

• Independent examination by a planning inspector on behalf of the Secretary of State; this involves an assessment against legal and procedural requirements and consideration of the ‘soundness’ of the plan against four tests.

• Assuming the Plan is found to be ‘sound’ by the inspector, adoption of the Plan by the Council.

National Planning Policy Framework

1.7 Government sets out national planning policy in the form of the National Planning Policy Framework (NPPF). The latest version of the NPPF was published by government in July 2021. Local development plan documents must be consistent with national policy. The NPPF is also a material consideration in the determination of planning applications.

1.8 The proposed submission version of the SADPD will be examined by an independent planning inspector whose role is to assess whether the plan has been prepared in accordance with legal and procedural requirements, and whether it is sound. A ‘sound’ plan must be:

a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;

b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the NPPF.

The London Plan

1.9 The London Plan is the spatial development strategy for London, produced by the Greater London Authority on behalf of the Mayor of London. London borough development plan documents must be in general conformity with the London Plan. All references to the London Plan in this Draft SADPD relate to the London Plan 2021.

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Duty to Co-operate

1.10 The Localism Act 2011 and the tests of soundness in the NPPF require public bodies, including local planning authorities, to co-operate on planning issues that cross administrative boundaries, particularly those that relate to strategic priorities such as housing, retail and commercial development, infrastructure, climate change and conservation and enhancement of the natural and historic environment.

1.11 Lambeth has borders with the Cities of London and Westminster, and the London boroughs of Southwark, Bromley, Croydon, Merton and Wandsworth. Each of these authorities has its own local plan at various stages of preparation or review. Lambeth engages periodically with these boroughs, and with other public bodies such as the Environment Agency and Historic England, to help achieve a full assessment of cross border issues and strategic alignment of objectives and policies. In addition, they will be formally consulted at each stage of preparation of the SADPD. Statements of Common Ground will be agreed to support the examination of the SADPD.

Rationale for allocation of sites

1.12 Sites are included in this Draft SADPD for one or more of the following reasons:

• to set clear, site-specific parameters for the type and scale of development expected on a site, including the associated public benefits it should deliver;

• to address site-specific circumstances that may require a more tailored approach to that set out in borough-wide policies;

• to articulate the vision and potential that can be achieved through land assembly and/or a comprehensive approach to developing adjacent sites, particularly where these are in different ownerships;

• to encourage landowners to consider the potential for optimising the development capacity of their land and help deliver key place-making objectives;

• to signal some additional sites as appropriate for tall buildings, outside the locations already identified in the Local Plan; and

• to enable key strategic infrastructure to come forward in a timely way.

1.13 It is not necessary to have a site-specific allocation for every potential development site in Lambeth. Many larger sites can and do come forward successfully without such a policy, with sustainable development achieved through application of the borough-wide and neighbourhood-level policies in the development plan as a whole.

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1.14 There is also no need in Lambeth to allocate sites to demonstrate the borough’s ability to meet its London Plan housing target, as this was achieved through the recent examination of the revised Lambeth Local Plan. However, the new site allocation policies will help to accelerate delivery of housing in the borough, maintain the necessary pipeline of new housing and thereby ensure housing delivery targets continue to be achieved. They will also enable the timely renewal and optimisation of social infrastructure and commercial floorspace.

Approach

1.15 The guiding approach in developing the draft site allocation policies is design-led optimisation of development capacity, as required by London Plan Policy D2.

1.16 This has involved analysis of the optimum mass and height that can be achieved on each site, having regard to site-specific planning constraints including impacts on neighbouring uses, views, townscape and heritage assets. An evidence base has been prepared to support the Draft SADPD and explain how design-led optimisation of development capacity has been approached on each of the sites. References to building heights should be read in the context of the definitions in Local Plan Policy Q26. Building heights are expressed in metres rather than storeys because floor to ceiling heights vary according to the use of a building. As a very approximate rule of thumb, a typical residential floor to ceiling height is in the order of 3 metres and a commercial one is between 3.5 and 4 metres.

1.17 Key spatial planning objectives have been factored in and identified for each of the sites. This includes for example: strategic place-making and contribution to implementation of the relevant policy for Places and Neighbourhoods; inclusion, accessibility and permeability in the public realm; healthy routes and active travel; community safety; townscape and design quality, including contribution to local distinctiveness; and urban greening.

1.18 Existing development plan standards and requirements for matters such as sustainable design and construction, urban greening, zero carbon, climatre change adaptation, housing quality, amenity space, child-friendly design, parking & transport and employment & skills will apply to these sites, but the policies in this Draft SADPD signal a clear expectation for exemplary approaches in meeting these standards. In many cases direct cross references are included within the draft site allocation policies, however relevant borough-wide policies and standards will apply even if they are not specifically referenced. Mayoral Supplementary Planning Guidance and Lambeth Supplementary Planning Documents will also apply in full to all of the sites included in this Draft SADPD. Where necessary and justified, the Council will use conditions and/or planning obligations to limit uses consented within

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Class E to achieve the objectives of the site allocations and other development plan policies.

1.19 The Council is in the process of developing a Climate Action Plan for the borough. The next version of this Draft SADPD will include appropriate reference to the Lambeth Climate Action Plan once it has been prepared, in order to contribute to its delivery.

Format of the site allocations

1.20 The site allocations in this Draft SADPD are presented in the following format:

• Contextual information, including area and site-specific maps showing relevant policy designations, constraints and opportunities.

• A brief statement of the vision for the site, highlighting the opportunity presented by its redevelopment and its potential to contribute to strategic place-making.

• The site allocation policy, setting out the requirements and expectations for the site.

Sustainability Appraisal

1.21 Emerging development plan documents must undergo a statutory sustainability appraisal. This is a systematic process that aims to promote sustainable development by assessing the extent to which the emerging plan, when judged against reasonable alternatives, will help to achieve relevant environmental, economic and social objectives. This includes consideration of impacts on equality and health and well-being. The sustainability appraisal of the Draft SADPD has been published for comment alongside the draft plan. The sustainability appraisal of the proposed submission version of the SADPD will undergo examination alongside the SADPD itself.

Strategic and local policies

1.22 The NPPF requires local development documents to identify which policies are ‘strategic’ and which are ‘local’, to assist groups preparing neighbourhood development plans. All the policies in this Draft SADPD are strategic because they contribute to achieving London Plan and Local Plan strategic objectives across the borough.

Monitoring

1.23 Following adoption of the SADPD, progress with implementation of the site allocations will be reported in the Council’s annual Authority Monitoring Report.

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Map 1: Proposed Site Allocations

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Section 2: Proposed Waterloo and South Bank Site Allocations

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Proposed Waterloo and South Bank Site Allocations

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Proposed Site 1: Royal Street SE1

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Context Proposed Site 1: Royal Street SE1

Site address and postcode Royal Street SE1

Ward Current: Bishop’s

Proposed: Waterloo & South Bank

Site area 7.2 ha

Land ownership Guy’s and St Thomas’ Foundation (GSTF)

The railway arches are leased by GSTF and a car hire firm

Existing land uses North of Royal Street

• Canterbury House – residential (77 self-contained market units) and offices (336 sqm GEA)

• Stangate House – residential (52 self-contained market units)

• Becket House – offices (18,885 sqm GEA)

Railway Arches

• Commercial car park and car hire

South of Royal Street

• Temporary ‘meanwhile’ uses, including:

– Community City Farm

– ‘Old Paradise Yard’ small business start-up space

• Carlisle Lane car park (used by St Thomas’ hospital)

Local Plan Place and Neighbourhood policy

PN1: Waterloo and South Bank

London Plan and Local Plan designations

The site lies within:

• London Plan Central Activities Zone: within the CAZ health cluster; the railway arches only fall within the Waterloo CAZ retail cluster

• Waterloo Opportunity Area

• Thames Policy Area

Neighbourhood Development Plan

South Bank and Waterloo Neighbourhood Plan 2017-2032

Community Infrastructure Levy charging zones

• Lambeth CIL Zone A

• MCIL2 Band 2

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Context Proposed Site 1: Royal Street SE1

Heritage assets Partly within:

• Approaches and wider setting of the Westminster World Heritage Site

• Lambeth Palace Conservation Area

Within the site:

• ‘South of the River’ sculpture (Grade II)

• The former School on Carlisle Lane and former Institute at no. 10 Royal Street are positive contributors to the Lambeth Palace Conservation Area

Near the site

• Westminster World Heritage Site

• Albert Embankment Conservation Area

• Lambeth Palace Gardens (registered landscape)

• Archbishop’s Park (local list space)

• County Hall (Grade II*)

• County Hall South Block (local list)

• South Wing at St Thomas’ Hospital (Grade II)

• Lower Marsh Conservation Area

Views Strategic views:

• Strategic view 4A.2 – Primrose Hill

• Strategic view 17A – Hungerford Bridge Upstream

• Strategic view 18A – Westminster Bridge

• Strategic view 19A – Lambeth Bridge

• Strategic view 20A – River Prospect Victoria Embankment to The County Hall

• Strategic view 23A – Serpentine Bridge

• Strategic View 27B – N side Parliament Square to Palace of Westminster (protected silhouette)

Local views (Policy Q25):

• (c) (i) Brockwell Park to the city

• (c) (ii) Norwood Park to City

• (d) (viii) Lambeth Palace Terrace to Victoria Tower

• (d) (ix) Lambeth Palace Gardens

• (d) (x) Kennington Lane / Courtenay Street to Elizabeth Tower

• (d) (xi) St Thomas’ Hospital Garden to Palace of Westminster

• (d) (xv) Victoria Tower Gardens/Members Terrace, Houses of Parliament to Lambeth Palace

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Context Proposed Site 1: Royal Street SE1

Transport and access • PTAL 6b (whole site)

• South Lambeth Road is part of the TfL Road Network (TRLN)

• Kennington Road / Westminster Bridge Road (east of the Royal Street site) – London Distributor Roads

• Royal Street is an existing Healthy Route (HR), connecting to Hercules Road Quietway / HR, and adjacent to Upper Marsh (proposed HR)

• Lambeth Palace Road is a Partnership Healthy Route

• Walking distance to Waterloo Station, Waterloo East Station and Lambeth North Underground Station.

• Close to several bus routes along Lambeth Palace Road

• Close to timed closure of Lower Marsh

• Royal Street one-way with contraflow for cycles, with a two-way section between Upper Marsh and Lambeth Palace Road approximately 1 minute walk from Cycle Hire Docking station (Archbishop’s Park)

• Within the Waterloo Controlled Parking Zone

Nearby projects:

• Low Line pedestrian and cycle link along railway arches past Urbanest student accommodation, linking to Waterloo and onto Southwark

• Spine Route project on Belvedere Road / Upper Ground

• Guy’s and St Thomas’ Hospital Trust has a significant off-site freight consolidation strategy to reduce servicing trips to the hospital.

• TfL’s Lambeth Bridge Scheme proposes to replace the roundabout with a four-way junction with segregated cycle lanes and increased pedestrian space.

• Southbound bus lane on Lambeth Palace Road to be lengthened and northbound cycle lane to be removed as part of this scheme

• Planned cycle route connecting St Thomas’ and Guy’s hospital sites via Upper Marsh / Lower Marsh (along HR network)

Air Quality Focus Area No

Energy Located in a Heat Network Priority Area

Flood risk Wholly within the EA’s Flood Zone 3 and 2100 Thames Tidal Breach Scenario, although the site of Canterbury House is outside the 2005 Thames Tidal Breach Scenario.

From the EA’s surface water mapping, isolated ponding of low risk (0.1 per cent AEP) surface water is present across the site. It is likely these are generated from surface water originating from the site.

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Context Proposed Site 1: Royal Street SE1

Access to open space and nature conservation

Archbishop’s Park is to the immediate south of the site and Millennium Green (also a Local SINC) is about 450m to the north-east.

The site is within an area of open space deficiency for regional parks, and part of site is also within an area of open space deficiency for district parks.

The site is within an area that is deficient in access to nature.

Trees Tree Preservation Order no. 452 lies to the immediate south of the site, within Archbishop’s Park. The trees protected include 12 London Plane (Acer plantanus) and two Lime (Tilia Spp). There is also a significant London Plane tree standing on the lawn of Canterbury House, within the site.

Community safety Recorded crimes in Bishop’s ward May 2020 – April 2021: 4,304.

Top three categories:

• Anti-social behaviour: 30.3 per cent

• Violence and sexual offences: 17.3 per cent

• Other theft: 11.0 per cent

Recorded crimes in Bishop’s ward June 2018 – April 2021: 15,092.

Top three categories:

• Anti-social behaviour: 20.8 per cent

• Other theft: 19.8 per cent

• Violence and sexual offences: 16.6 per cent

Bishop’s ward has one of the highest crime rates in the borough due to the high level of footfall along the South Bank area and around London Waterloo Station. It has also had one of the highest rates of serious youth violence (SYV) in Lambeth since 2018 and had the highest rates of all wards in 2020.

Description of current site character

Carlisle Lane runs north south along and below the railway viaduct into Waterloo Station and connects to Westminster Bridge Road at the north. It provides the access into the car park and into the former Christ Church School site, which is a low-rise, single storey stock brick building that makes a positive contribution to Lambeth Palace Conservation Area. At the school vehicular entrance a small pocket park sits on the corner of Carlisle Lane and Royal Street. It is hard paved with a number of trees.

No. 10 Royal Street is an Edwardian former institute on the corner of Lambeth Palace Road that also makes a positive contribution to Lambeth Conservation Area.

Stangate House and Canterbury House are two 1950s residential blocks. Becket House on Lambeth Palace Road is a 1970s office with front lawn.

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Context Proposed Site 1: Royal Street SE1

Neighbour context The Urbanest student accommodation at 199 Westminster Bridge Road lies to the north of the site (approximately 60m in height).

Carlisle Lane and railway viaducts carrying lines into London Waterloo run along the eastern boundary of the site.

To the south is Archbishop’s Park and a significant line of mature trees along its perimeter.

To the west is Lambeth Palace Road and the St Thomas’ Hospital campus, and beyond that the River Thames.

Relevant planning history Canterbury House13/04991/FUL – Change of Use from D1 (Community) to B1 (Office) at the vacant ground floor unit. Granted 18/12/2013. Completed 01/11/2014.

Land to the south of Royal Street20/01748/FUL – Retention of Community City Farm and retention of sheltered teaching and storage spaces, polytunnel, raised planters and pens (for a temporary period of three years). Granted 30/07/2020.

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Vision: Proposed Site 1: Royal Street SE1

This key site provides a significant opportunity to contribute to the growth of the Waterloo SC1 cluster, linked to local hospitals and universities and supporting population health and well-being, life-sciences (including MedTech) and complementary sectors such as artificial intelligence; the growing cluster of low carbon industries in this part of Lambeth; and the evolution of the South Bank and Waterloo creative cluster. Public benefits will include new affordable housing, plus affordable workspace and employment and training opportunities for local people within those growing sectors.

High quality development of exemplary design will express a clear vision and strong ambition for environmental sustainability and health and well-being in the built environment, including public realm and connections to the wider neighbourhood. This will address the currently discordant and incomplete urban realm in this part of the Waterloo Opportunity Area, creating a new place of distinct character, which: preserves or enhances the setting and Outstanding Universal Value of the Westminster World Heritage Site; is exemplary in achieving net zero carbon; achieves excellent levels of urban greening; improves the entrance to Archbishop’s Park; provides routes through that integrate positively with pedestrian and cycle routes and networks, including Healthy Routes, Greenways and the Low Line; and significantly enhances the environmental quality and pedestrian experience along perimeter roads, particularly Lambeth Palace Road.

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Site Allocation Policy Proposed Site 1: Royal Street SE1

Land uses Development should include no fewer than 129 self-contained residential units, to replace the existing quantum of homes on the site.

In addition, the site has potential to accommodate:

• office floorspace, including approximately 30 per cent that is lab-enabled to contribute to the growth of the SC1 cluster linked to hospitals and universities

• flexible spaces at ground floor level to activate frontages, providing a range of unit sizes and types

• cultural uses to contribute to the evolution of the South Bank and Waterloo cultural cluster

Given the majority of the site falls outside the Waterloo CAZ retail cluster, this site should not primarily be a retail destination. Applications should demonstrate there would be no harmful impact on the role and special character of the Lower Marsh/the Cut/Leake Street Special Policy Area as a centre for local needs and specialist independent retail.

Affordable housing and affordable workspace

The affordable housing threshold is 35 per cent.

At least 10 per cent of the net uplift in office floorspace must be provided as affordable workspace at a 50 per cent reduction from market values for a period of 15 years, or a level of on-site provision of equivalent value (see Local Plan Policy ED2). This should include on site: a proportion of the lab-enabled space (wet and dry); research and development business incubator space to support small business growth including life-science spinout or start-up activity; cultural uses; a skills and education hub linked to the life-sciences sector. This cannot include general Class E space or other community uses.

The affordable workspace provision on site should take account of the latest life-science industry requirements, demand and evidence of market failure in the supply of space for that sector. This should also take particular account of affordable workspace and incubator space provision on the St Thomas’ hospital campus.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

The Employment and Skills Plan should reflect the particular opportunity on this site to secure jobs and training opportunities for Lambeth residents within the health and life sciences, low carbon, creative, digital and artificial intelligence sectors.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

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Site Allocation Policy Proposed Site 1: Royal Street SE1

Heritage assets Development should have regard to the significance (including setting) of heritage assets. In particular:

• Preserve or enhance the Outstanding Universal Value, authenticity and integrity of the Westminster World Heritage Site; and preserve or enhance the setting of the Albert Embankment Conservation Area and the South Bank Conservation Area by:

– Having a height and massing which is not distracting or visually discordant in the cityscape

– Ensuring the architectural forms are calm and recessive

– Using a palette of materials which closely mimics the appearance of Portland stone in views from across the river.

• Preserve or enhance the character or appearance of the Lambeth Palace Conservation Area by:

– Retaining former School, Carlisle Lane

– Retaining former Institute at no. 10 Royal Street

– Delivering a high-quality building on the car park site which responds positively to the character of the conservation area in terms of height, appearance and materials.

• Preserve or enhance the setting of the Lower Marsh Conservation Area by:

– Ensuring building heights are not unduly dominant

– Ensuring an interesting roofline in views south along Lower Marsh

• Preserve the significance (setting) of Lambeth Palace garden.

• Preserve the significance (setting) of Archbishop’s Park.

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Site Allocation Policy Proposed Site 1: Royal Street SE1

Building heights and views; townscape

The site is appropriate for tall buildings in the locations shown in Local Plan Annex 10. Development should integrate the buildings into its context sensitively by:

In locations appropriate for a tall building:

• Achieving a general building height of 60m AOD on the site of Becket House (Annex 10 location W7).

• Achieving a general building height of 50m AOD on the sites of Stangate House and Canterbury House (Annex 10 location W8).

Away from these tall building locations:

• There should be a fall in building heights towards the southern edge of the site adjacent to Archbishop’s Park to preserve or enhance the character and appearance of the Lambeth Palace Conservation Area, and the openness of Archbishop’s Park.

Development should also address the following principles:

• Provide activation and animation at ground floor, including to the facades onto the perimeter streets

• Ensure the route from the north-east gate of the park northwards along Carlisle Lane remains an attractive, safe and overlooked one for pedestrians including:

– Urban greening

– Pocket parks / informal seating

– Generous footways

• Improve the public approach and visibility of the north-east entrance to Archbishop’s Park (from Carlisle Lane).

• Maintain the historic route of Upper Marsh

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

Development should be serviced off-street and servicing impacts should be minimised through freight consolidation, and by considering sharing of servicing requirements with nearby sites.

Shared surfaces will be considered where appropriate but protected pedestrian areas should be provided where vehicles are expected to be large and / or manoeuvring.

Development should contribute towards implementation of the Healthy Route Network in the vicinity of the site.

Generous areas of public realm should be incorporated, with widened footways on Royal Street. Permeability for cyclists and pedestrians through the site should be maintained and where possible enhanced, linking into and improving existing and future cycle routes, Healthy Routes, Greenways and the Low Line.

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Site Allocation Policy Proposed Site 1: Royal Street SE1

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

Streets and routes through the development site must have good natural surveillance, be legible and have a good degree of activation at ground level.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution. Particular regard should be paid to the relationship with the Urbanest building on Westminster Bridge Road.

Flood risk mitigation Development must comply with Local Plan Policy EN5.

A site-specific Flood Risk Assessment (FRA) will be required as part of a planning application and flood risk should be verified by site-specific breach inundation flood levels, to determine more accurate flood depths at precise locations.

Ground floor levels and below will be restricted to Less Vulnerable use types only and will require multiple access and egress points, in addition to a sufficient Evacuation Plan.

More vulnerable uses will not be allowed below breach. Self-contained residential development and/or sleeping accommodation will not be permitted at basement levels in areas identified as at risk of flooding.

Sustainable Drainage Systems (SuDS) will be required as per the requirements of Local Plan Policy EN6. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs, and blue/green infrastructure in open spaces are ideal for this location to achieve this and should be considered.

The isolated ponding of low-risk surface water should be acknowledged and assessed within the site-specific FRA and should be resolved by a sustainable surface water management system such as SuDS that also provides multiple environmental benefits.

The approximate greenfield runoff rate is QBar=12.8l/s.

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Site Allocation Policy Proposed Site 1: Royal Street SE1

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

Waste management The River Thames should be prioritised for transportation of construction materials and waste during construction of the development, and for site waste once operational.

Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d). The entrance to Archbishop’s Park should be improved.

If development will result in increased useage of nearby open spaces, developer contributions will be sought to their ongoing maintenance and management.

Urban greening and trees The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

The relationship with Archbishop’s Park should be improved through the urban greening strategy for the site. The design should take account of the above and below ground constraints posed by the adjacent mature trees of value in Archbishop’s Park (namely tree protection area and tree canopy constraints) and the positive integration of these trees thereafter including space for future growth. Opportunities for new tree planting should be optimised. The biodiversity value of the site should be significantly improved to help address the existing deficiency in access to nature conservation in this location.

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Proposed Site 2: St Thomas’ Hospital SE1

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Context Proposed Site 2: St Thomas’ Hospital SE1

Site address and postcode St Thomas’ Hospital SE1

Ward Current: Bishop’s

Proposed: Waterloo & South Bank

Site area 2.35 ha

Land ownership The whole site is owned by Guy’s and St Thomas’ NHS Foundation Trust (GSTT)

Existing land uses Hospital

Florence Nightingale Museum (within Gassiot House)

Local Plan Place and Neighbourhood policy

PN1: Waterloo and South Bank

London Plan and Local Plan designations

The whole sites falls within:

• The London Plan CAZ

• The Waterloo Opportunity Area

• Thames Policy Area

• Approaches to the Westminster World Heritage Site

Part of the site falls within:

• Immediate setting of the Westminster World Heritage Site

Neighbourhood Development Plan

South Bank and Waterloo Neighbourhood Plan 2017-2032

Community Infrastructure Levy charging zones

• Lambeth CIL Zone A

• MCIL2 Band 2

Heritage assets Within the site:

• Albert Embankment CA

• Westminster World Heritage Site – setting and approaches (Policy Q19)

Nearby:

• Westminster World Heritage Site

• Edward VI statue – Grade I

• Robert Clayton statue – Grade I

• County Hall – Grade II*

• St Thomas’ Hospital Victorian Buildings – Grade II

• Torsion fountain – Grade II

• Lambeth Palace Gardens (registered landscape)

• Lambeth Palace Conservation Area

• South Bank Conservation Area

• County Hall South block (local heritage list)

• Archbishop’s Park (local heritage list)

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25 Draft Lambeth SADPD | Section 2: Proposed Waterloo and South Bank Site Allocations

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Context Proposed Site 2: St Thomas’ Hospital SE1

Views Strategic views:

• Strategic view 4A.2 – Primrose Hill

• Strategic view 17A – Hungerford Bridge Upstream

• Strategic view 18A – Westminster Bridge

• Strategic view 19A – Lambeth Bridge

• Strategic view 20A – River Prospect Victoria Embankment to The County Hall

• Strategic view 23A – Serpentine Bridge

• Strategic View 27B – N side Parliament Square to Palace of Westminster (protected silhouette)

Local views (Policy Q25):

• (c) (i) Brockwell Park to the city

• (c) (ii) Norwood Park to City

• (d) (viii) Lambeth Palace Terrace to Victoria Tower

• (d) (ix) Lambeth Palace Gardens

• (d) (x) Kennington Lane / Courtenay Street to Elizabeth Tower

• (d) (xi) St Thomas’ Hospital Garden to Palace of Westminster

• (d) (xv) Victoria Tower Gardens/Members Terrace, HoP to Lambeth Palace

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Context Proposed Site 2: St Thomas’ Hospital SE1

Transport and access • PTAL 6b

• Walking distance to Waterloo Station, Waterloo East Station and Lambeth North Underground Station.

• Close to several bus routes.

• Site is surrounded by existing and proposed Healthy Routes:

– Lambeth Palace Road and Westminster Bridge Road – Partnership Healthy Routes

– Royal Street is an existing Healthy Route, connecting to Hercules Road Quietway / HR,

– Upper Marsh and Belvedere Road proposed HRs

• Close to timed closure of Lower Marsh.

• Royal Street one-way with contraflow for cycles, with a two-way section between Upper Marsh and LPR.

• Cycle Hire Docking station in Archbishop’s Park

• South Lambeth Road (which lies immediately to the east of St Thomas’ Hospital) – TLRN

• Kennington Road / Westminster Bridge Road (further to the east of Royal Street) – London Distributor Road

• The site is in an existing CPZ (Waterloo)

Nearby projects:

• Spine Route Project on Belvedere Road / Upper Ground

• ‘Low Line’ pedestrian and cycle link along railway arches past Urbanest student accommodation, linking to Waterloo and onto Southwark

• GSTT has a significant off-site freight consolidation strategy to reduce servicing trips to the hospital

• TfL’s Lambeth Bridge Scheme proposes to replace roundabout with a four-way junction with segregated cycle lanes and increased pedestrian space. Southbound bus lane on LPR to be lengthened and northbound cycle lane to be removed

• Planned cycle route connecting St Thomas’ and Guy’s hospital sites via Upper Marsh / Lower Marsh (along HR network)

Air Quality Focus Area No

Energy Site is located in a Heat Network Priority Area.

Flood risk The site is wholly within the EA’s Flood Zone 3 and both 2005 and 2100 Thames Tidal Breach Scenario.

The surface water flood risk is low.

Access to open space and nature conservation

Archbishop’s Park is adjacent to the site and Millennium Green (also a SINC) is about 600m to the north-east.

The Albert Embankment path adjoins the site along the River Thames frontage.

The site is within an area of open space deficiency for regional parks and the south and south-eastern part of the site is also within an area of open space deficiency for district parks.

Part of the site is within an area that is deficient in access to nature.

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Context Proposed Site 2: St Thomas’ Hospital SE1

Trees No Tree Preservation Orders on site.

14 trees protected under Tree Preservation Order no. 452 are east of the site on the northern boundary of Archbishop’s Park.

Community safety Recorded crimes in Bishop’s ward May 2020 – April 2021: 4,304.

Top three categories:

• Anti-social behaviour: 30.3 per cent

• Violence and sexual offences: 17.3 per cent

• Other theft: 11.0 per cent

Recorded crimes in Bishop’s ward June 2018 – April 2021: 15,092.

Top three categories:

• Anti-social behaviour: 20.8 per cent

• Other theft: 19.8 per cent

• Violence and sexual offences: 16.6 per cent

Bishop’s ward has one of the highest crime rates in the borough due to the high level of footfall along the South Bank area and around London Waterloo Station. It has also had one of the highest rates of serious youth violence (SYV) in Lambeth since 2018 and had the highest rates of all wards in 2020.

Description of current site character

A large central London hospital campus comprising Victorian listed buildings and late 20th Century tall buildings (circa 60m in height), along with other 20th Century buildings closer to Lambeth Palace Road and Westminster Bridge Road. The allocation covers the latter only (Gassiot House, Lambeth Wing and Accident and Emergency department).

Located on the River Thames opposite the Westminster World Heritage Site and highly visible within a range of important strategic views. There are important open spaces and groupings of mature trees of value.

Neighbour context To the west of the site is the Thames Walk and River Thames. Lambeth Palace Road forms the eastern boundary, with the Royal Street allocation standing directly opposite. To the north is Westminster Bridge Road and County Hall. To the south is Evelina Children’s Hospital within the wider St Thomas’ campus.

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Context Proposed Site 2: St Thomas’ Hospital SE1

Relevant planning history Gassiot House11/03370/FUL – Refurbishment of existing accommodation spaces, upgrading and alterations to selected entrances, a proposed new glazed courtyard pavilion within an existing external courtyard and associated plant within a new plant enclosure on the existing roof level. Granted 24/01/2012.

12/00923/FUL – Relocation of the existing St Thomas’ Hospital Data Centre to the Ground floor undercroft area which is being vacated by the existing Cycle Store and Waste Store. Existing Cycle Store and General Waste Stores relocated to an adjacent area in the undercroft. Granted 01/06/2012.

19/01532/FUL – Erection of 135 sqm single storey pain management outpatients building (Use Class C2) and internal access connection to Gassiot House. Granted 01/07/2019.

North Wing09/00188/FUL – Erection of a single storey ground floor extension to the existing ancillary retail and restaurant uses within the North Wing. Granted 18/03/2009.

20/01004/FUL – Installation of wellbeing garden on West side of North wing. Granted 21/07/2021.

East and Lambeth Wings13/01999/FUL – Extension and reconfiguration of St Thomas’ A & E department including internal rearrangement and erection of a ground floor glazed entrance and first floor staff facilities. Granted 11/09/2013.

Evelina Children’s Hospital00/01685/FUL – Demolition of Riddell House and ancillary outbuildings and construction of nine-storey building to be used as a children’s hospital. Granted 19/07/2001.

Adjacent to the Evelina Children’s Hospital19/01397/FUL – Redevelopment to provide six storey hospital building (C2 use). Granted 12/12/2019.

21/01869/FUL – Demolition of existing St Thomas’ House and Dunhill Fitness Centre and development of a 12 storey building (G+11) plus two storey basement with five storey link extension to the Evelina London Children’s Hospital to provide additional children’s medical services (Class C2), hard and soft landscaping, access and associated works. Resolution to grant by Planning Applications Committee on 05/10/2021.

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Context Proposed Site 2: St Thomas’ Hospital SE1

Prideaux Building20/00884/FUL – Demolition of existing building and redevelopment of the site to provide a part three, part four storey mixed-use development comprising research and development and educational uses and associated enabling landscape and public realm works. Demolition of the external access link between the Grade II listed South Wing of St Thomas Hospital (Block 8) and the main entrance to the Prideaux Building development site, creation of new public walkway link and associated façade works to the south elevation of the South Wing (Block 8), demolition of security hut and substation adjoining Block 9 of St Thomas Hospital and associated facade works, demolition of part of boundary wall to Lambeth Palace Road and associated repair work. Granted 13/04/2021.

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Vision: Proposed Site 2: St Thomas’ Hospital SE1

The optimisation of development on this site provides an opportunity to deliver enhanced clinical care facilities and to contribute to the growing SC1 Life sciences and MedTech health cluster in this part of the Waterloo Opportunity Area. There is also a significant opportunity to improve the townscape character and pedestrian experience along Lambeth Palace Road, in conjunction with the development of the Royal Street site. Both developments offer the potential to enhance the Albert Embankment Conservation Area and should preserve or enhance the setting and Outstanding Universal Value of the Westminster World Heritage Site.

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Site Allocation Policy Proposed Site 2: St Thomas’ Hospital SE1

Land uses Hospital and ancillary uses. Re-provision of the Florence Nightingale Museum on site or at an appropriate alternative location.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Heritage assets • Development should preserve or enhance the Outstanding Universal Value, authenticity and integrity of the Westminster World Heritage Site; and preserve or enhance the setting of the Albert Embankment Conservation Area, the South Bank Conservation Area and County Hall.

Building heights and views; townscape

• The site is not within a location identified as appropriate for tall buildings.

• The detailed massing of proposed new blocks should respond positively to their context, ensuring parapet heights, form and appearance relate coherently to the character of Lambeth Palace Road and Westminster Bridge Road. The latter is particularly important given heritage sensitivity in terms of the setting of and approaches to the Westminster World Heritage Site.

• Where it would be visible in sensitive views from outside the Campus, all rooftop plant should not exceed the height of the building envelopes and be effectively screened from view.

Development should also address the following principles:

• The footprint of Gassiot House may be extended / cantilever an additional 10m westward so long as it maintains the principal pedestrian route into the hospital campus within a generous colonnade or cantilever.

• The footprint of Lambeth Wing and A&E may be extended eastward towards Lambeth Palace Road so long as it does not come any closer than 10m to the back edge of pavement.

• The existing palette of external materials of the post-war buildings should be closely matched in order to maintain a unified Campus character and to respond positively to the local distinctiveness of this heritage sensitive part of central London.

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Site Allocation Policy Proposed Site 2: St Thomas’ Hospital SE1

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

Development will be expected to contribute towards implementation of the Healthy Route Network in the vicinity of the site.

Development should be serviced off-street and servicing impacts should be minimised through freight consolidation, and by considering sharing of servicing requirements with nearby sites.

The existing network of routes through the site should not be compromised by redevelopment.

Shared surfaces will be considered where appropriate but protected pedestrian areas should be provided where vehicles are expected to be large and / or manoeuvring.

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

Neighbour relationships Development should not cause unacceptable impacts on existing neighbours, including overlooking, loss of daylight, overshadowing and noise pollution.

Particular regard should be paid to sensitive residential neighbours at County Hall South Block and the Urbanest building on Westminster Bridge Road.

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Site Allocation Policy Proposed Site 2: St Thomas’ Hospital SE1

Flood risk mitigation Development must comply with Local Plan Policy EN5.

A site-specific Flood Risk Assessment will be required as part of a planning application and flood risk should be verified by site-specific breach inundation flood levels, to determine more accurate flood depths at precise locations.

Ground floor levels and below will be restricted to Less Vulnerable use types only and will require multiple access and egress points, in addition to a sufficient Evacuation Plan.

There is a possibility the site could discharge its surface water directly to the River Thames. In this scenario, the sustainable drainage system should prioritise water quality management above reducing the rate of runoff e.g. an intensive green roof would be more practical than a blue roof.

Should it not be feasible to discharge the site’s surface water into the River Thames, the development will be required to discharge any controlled runoff at the greenfield runoff rate.

Outfalls with diameters greater than 300mm will need to have a second line of defence (e.g. in-line check valve) to prevent inundation of the development if the drainage system was to become tidally locked or the main flap valve was to fail.

All developments adjacent to a tidal flood defence must ensure the current and future statutory crest levels are maintained as outlined in the Thames Estuary 2100 plan and the condition of tidal wall defences provide a sufficient level of defence in accordance with the design life of the building (e.g. generally 100 years for residential and 50-60 years for commercial), and that a 16 metres setback safeguarded for inspections, maintenance, future defence raising and potential replacement without increasing flood risk or encroaching on the river channel.

The approximate greenfield runoff rate: QBar=12.5l/s.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

Waste management The River Thames should be prioritised for transportation of construction materials and waste during construction of the development, and for site waste once operational.

Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d).

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Site Allocation Policy Proposed Site 2: St Thomas’ Hospital SE1

Urban greening and trees The two significant groups of trees within the site should be retained.

Additional urban greening and enhancement of existing urban greening should be optimised especially along its street frontages.

The Urban Greening Factor (UGF) target score is 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

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Proposed Site 8: 110 Stamford Street SE1

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Context Proposed Site 8: 110 Stamford Street SE1

Site address and postcode 110 Stamford Street SE1

Ward Current: Bishop’s

Proposed: Waterloo & South Bank

Site area 0.114 ha

Land ownership Private ownership (social enterprise)

Existing land uses Vacant since 1985

Local Plan Place and Neighbourhood policy

PN1: Waterloo and South Bank

London Plan and Local Plan designations

• Waterloo Opportunity Area

• Central Activities Zone

Neighbourhood Development Plan

South Bank and Waterloo Neighbourhood Plan 2017-2032

Community Infrastructure Levy charging zones

• Lambeth CIL Zone A

• MCIL2 Band 2

Heritage assets None on the site

Nearby:

• 85 to 123 Stamford Street (Grade II)

• Waterloo Conservation Area. (The Waterloo Conservation Area Appraisal (2009) proposed to include Cornwall House to the west of the site in the CA.)

Views No strategic views.

• Local views (Policy Q25):

• (c) (i) (c) Views N and NNE to the City from Brockwell Park

• (c) (ii) View NNE from Norwood Park

Transport and access • PTAL 6b.

• Walking distance to Waterloo Station, Waterloo East Station and Blackfriars Station.

• Close to several bus routes

• London Eye Pier approximately 800m away: River Bus route RB1 (London Eye Pier – Woolwich Arsenal Pier)

• Upper Ground and Cornwall Road form part of the Healthy Route network

• Several cycle hire docking stations within walking distance

• Within the Waterloo Controlled Parking Zone

Nearby projects:

• Spine Route project on Belvedere Road / Upper Ground

Air Quality Focus Area Yes - Waterloo

Energy Located in a Heat Network Priority Area.

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Context Proposed Site 8: 110 Stamford Street SE1

Flood risk Wholly within the EA’s Flood Zone 3 and both 2005 and 2100 Thames Tidal Breach Scenario.

The extent of surface water flooding within the site is from a topographic anomaly in the model that shows the remnants of a lower ground floor level and a vacant site. The risk of flooding to the site is likely low if a building with a formal drainage system is positioned on this site.

Access to open space and nature conservation

St John’s Church Gardens is about 150m to the south of the site. Bernie Spain Gardens is 200m and Hatfields Green is within 300m to the east.

The site is within an area of open space deficiency for district, metropolitan and regional parks.

The site is within an area that is deficient in access to nature.

Trees No Tree Preservation Orders on or adjacent to the site.

Community safety Recorded crimes in Bishop’s ward May 2020 – April 2021: 4,304.

Top three categories:

• Anti-social behaviour: 30.3 per cent

• Violence and sexual offences: 17.3 per cent

• Other theft: 11.0 per cent

Recorded crimes in Bishop’s ward June 2018 – April 2021: 15,092.

Top three categories:

• Anti-social behaviour: 20.8 per cent

• Other theft: 19.8 per cent

• Violence and sexual offences: 16.6 per cent

Bishop’s ward has one of the highest crime rates in the borough; it has had one of the highest rates of serious youth violence (SYV) in Lambeth since 2018 and the highest rates of all wards in 2020.

Description of current site character

The site had been vacant since the demolition of the previous building in 1985 and redevelopment of the rest of the street block by Coin Street Community Builders for housing and the Coin Street Neighbourhood Centre immediately adjacent.

Neighbour context The site is the last remaining part of a perimeter block development fronting Stamford Street, Cornwall Road, Upper Ground and Duchy Street. The building immediately adjacent to the Site at 108 Stamford Street was developed in the 2000s as the Coin Street Neighbourhood Centre and is four storeys in height with a fifth storey set back from the Stamford Street frontage. The building is award-winning, noted for its sensitive, contemporary response to context.

Immediately opposite the Site on Stamford Street is a Grade II listed Georgian terrace, which is four storeys. To the west, fronting Stamford Street and Cornwall Road, is the Franklin Wilkins Building - a six-storey Edwardian academic building occupied by King’s College London.

To the north are terraced homes that form part of the Coin Street Community and include a communal garden.

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Context Proposed Site 8: 110 Stamford Street SE1

Relevant planning history 108 Stamford Street (Coin Street Neighbourhood Centre Development)03/01794/FUL (Land Corner Of Coin Street And Stamford Street) – Erection of a part-four/part-two/part-single storey building with basement, comprising retail/restaurant use on part-ground and part-basement floor, community-care/meeting room and offices on part-ground floor, plant on part-basement, nursery with outdoor play area to rear and offices at first and second floor level, offices with terrace to second floor and learning and enterprise support centre and conference facilities/and plant to third floor, roof terrace and plant to fourth floor, associated landscaping and pick up/drop off lay-by to Stamford Street, installation of stainless steel planting wires on south east elevation of Iroko Housing adjacent to Coin Street. Granted 03/05/2006 (Implemented as Coin Street Neighbourhood Centre Development).

09/00749/FUL – Use of Basement level to provide health facilities, waiting rooms, kitchen and meeting facilities/or the retention of retail/restaurant use (A1/A3) (as approved 3 May 2006 - reference 03/01794/FUL). Granted on 17/08/2009.

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Vision: Proposed Site 8: 110 Stamford Street SE1

The site provides an opportunity to contribute to the Waterloo Opportunity Area through mixed use development, including new housing and affordable housing. Ground floor uses have potential to complement the existing services provided by the adjacent Neighbourhood Centre.

Development will address the current eyesore condition by completing the urban block. The design should complement the award-winning design of the Coin Street Neighbourhood Centre. There is an opportunity to create new public realm on the Stamford Street frontage with potential for activation on the corner with Cornwall Road.

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Site Allocation Policy Proposed Site 8: 110 Stamford Street SE1

Land uses The site has potential to accommodate:

• community/office floorspace at ground floor, providing an active frontage to Stamford Street

• approximately 30 to 40 self-contained residential units

Affordable housing and affordable workspace

The affordable housing threshold is 50 per cent for public sector land and 35 per cent for private sector land.

If office space is proposed, Local Plan Policy ED2 on affordable workspace will apply.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Heritage assets None on the site

Nearby:

• 85 to 123 Stamford Street (Grade II)

• Waterloo Conservation Area (the CA appraisal 2009 proposed to include Cornwall House to the west of the site in the CA)

Building heights and views; townscape

The site is not appropriate for a tall building. Development should mediate between prevailing heights in the immediate context.

Development should address the following principles:

• continue the building line of no. 108 Stamford Street

• abut closely to the flank of no. 108 to avoid gaps in the frontage

• respond positively to the award-winning façade of no. 108 and local historic context in terms of façade design, materiality and colour

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

The ramp to the underground car park is to be retained. Suitable pedestrian and vehicular inter-visibility splays must be provided.

Development will be expected to contribute to the implementation of the Spine Route and Healthy Route along Upper Ground.

Servicing should be from the existing loading bay on Stamford Street to protect users of Quietway 1 on Cornwall Road. Potential for freight consolidation and sharing of servicing requirements with nearby sites should be explored.

The site presents the opportunity to create a new, high quality public space on Stamford Street with potential for a kiosk on the corner with Cornwall Road.

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Site Allocation Policy Proposed Site 8: 110 Stamford Street SE1

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution. Particular regard should be paid to the relationship with sensitive residential neighbours on Stamford Street and Cornwall Road.

Flood risk mitigation Development must comply with Local Plan Policy EN5.

A site-specific Flood Risk Assessment will be required as part of a planning application and flood risk should be verified by site-specific breach inundation flood levels, to determine more accurate flood depths at precise locations. The FRA will also need to confirm that the flood risk identified in modelling is likely due to an anomaly in the topography due to the presence of an exposed below ground level; and demonstrate that the site is safe.

Ground floor levels and below will be restricted to Less Vulnerable use types only and will require multiple access and egress points, in addition to a sufficient Evacuation Plan.

More vulnerable uses will not be allowed below breach. Self-contained residential development and/or sleeping accommodation will not be permitted at basement levels in areas identified as at risk of flooding.

Sustainable Urban Drainage Systems will be required as per the requirements of Local Plan Policy EN6. The development should reduce the rate of surface water runoff on this site to the greenfield equivalent. The use of blue or green roofs are ideal for this location to achieve this.

The approximate greenfield runoff rate is QBAR = 0.67l/s.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

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Site Allocation Policy Proposed Site 8: 110 Stamford Street SE1

Waste management Where possible the River Thames should be prioritised for transportation of construction materials and waste during construction of the development, and for site waste once operational.

Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d).

Urban greening and trees The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

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Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

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Context Proposed Site 9: Gabriel’s Wharf and Princes Wharf, SE1

Site address and postcode Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

Ward Current: Bishop’s

Proposed: Waterloo & South Bank

Site area 0.53 ha

Land ownership Social enterprise (Coin Street Community Builders)

Princes Wharf leased to ITV (expires 2029)

Small section of Council-owned land on western edge also leased to ITV (expires 2029)

Existing land uses Gabriel’s Wharf: Shops, food and drink and cultural uses (approximately 906 sqm GIA)

Princes Wharf: Former TV studio used in association with the former ITV studios adjacent at 72 Upper Ground (3,189 sqm GIA)

Local Plan Place and Neighbourhood policy

PN1: Waterloo and South Bank

London Plan and Local Plan designations

The site falls within:

• Waterloo Opportunity Area

• Central Activities Zone

• South Bank and Bankside Strategic Cultural Area

• Thames Policy Area

Neighbourhood Development Plan

South Bank and Waterloo Neighbourhood Plan 2017-2032

Community Infrastructure Levy charging zones

• Lambeth CIL Zone A

• MCIL2 Band 2

Heritage assets Site falls within:

• South Bank Conservation Area (no. 58 Upper Ground on Princes Wharf is a positive contributor)

• Westminster World Heritage Site approaches

Near the site:

• Westminster World Heritage Site

• Old Barge House Alley Conservation Area (LB Southwark)

• Somerset House (Grade I) (City of Westminster)

• National Theatre (Grade II*)

• IBM Building, Upper Ground (Grade II)

Views Strategic views:

• Protected vista 8: Westminster Pier to St Paul’s Cathedral

Local views (Policy Q25):

• (c) (i) Views N and NNE from Brockwell Park to the City

• (c) (ii) View NNE from Norwood Park to the City

• (c) (iii) View N from Gipsy Hill to the City

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Context Proposed Site 9: Gabriel’s Wharf and Princes Wharf, SE1

Transport and access • PTAL 6b - walking distance to Waterloo, Waterloo East and Blackfriars Stations; bus stops on Stamford Street (approximately 200m south), Upper Ground (approximately 280m west) and Waterloo Bridge (approximately 450m west); London Eye Pier approximately 800m south-west with access to River Bus route RB1 (London Eye Pier – Woolwich Arsenal Pier)

• Upper Ground, a two-way single carriageway road: a Borough Road; part of the Healthy Route Network; part of National Cycle Route 4 between London and Fishguard.

• Many cycle-hire docking stations within walking distance of the site

• Within a Controlled Parking Zone (Waterloo)

Nearby projects:

• Spine Route Project - to improve conditions for cyclists and pedestrians along Upper Ground

Air Quality Focus Area Located in the borough-wide Air Quality Management Area..

Energy Located in a Heat Network Priority Area.

Flood risk The site is wholly within the EA’s Flood Zone 3 and both 2005 and 2100 Thames Tidal Breach Scenario.

Surface water management issues are deemed not significant.

Access to open space and nature conservation

Bernie Spain Gardens adjoins the site to the east. Hadfields Green open space is about 300m to the south of the site. The Queen’s Walk adjoins the site along the River Thames frontage.

The site is within an area of open space deficiency for district, metropolitan and regional parks.

The site is within an area that is deficient in access to nature.

Trees There are no Tree Preservation Orders on or near the site.

Trees lining the western side of Bernie Spain Gardens have canopies that over-sail Gabriel’s Wharf. These trees are of high amenity value.

Street trees on Upper Ground over-sail the southern site boundary of Gabriel’s Wharf.

Community safety Recorded crimes in Bishop’s ward May 2020 – April 2021: 4,304.

Top three categories:

• Anti-social behaviour: 30.3 per cent

• Violence and sexual offences: 17.3 per cent

• Other theft: 11.0 per cent

Recorded crimes in Bishop’s ward June 2018 – April 2021: 15,092.

Top three categories:

• Anti-social behaviour: 20.8 per cent

• Other theft: 19.8 per cent

• Violence and sexual offences: 16.6 per cent

Bishop’s ward has one of the highest crime rates in the borough. It has had one of the highest rates of serious youth violence (SYV) in Lambeth since 2018 and had the highest rates of all wards in 2020.

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Context Proposed Site 9: Gabriel’s Wharf and Princes Wharf, SE1

Description of current site character

Gabriel’s Wharf – a collection of small, and some independent, businesses (shops, food and beverage) in low-rise purpose-built structures around a central space accessed from north and south; the uses contribute to the vibrancy of the South Bank. None of these buildings has architectural or historic interest.

Princes Wharf – Early 20th Century warehousing accessed solely from Upper Ground, part of which was formerly used as a TV studio in association with the adjacent former ITV site. The only structure of architectural or historic value is the Neo-Tudor frontage building at no. 58 Upper Ground, which makes a positive contribution to the character and appearance of the South Bank Conservation Area.

Neighbour context The former ITV site is to the west, comprising a 1970s studio and office complex. Bernie Spain Gardens open space, with its mature trees, adjoins to the east. Residential terraces on Upper Ground adjoin to the south. The north of the site fronts Queen’s Walk.

Relevant planning history Princes Wharf, 58 Upper Ground99/01787/FUL – Erection of first floor extension for ancillary use as television studio storage unit and associated alterations. Granted 02/11/1999

99/02019/FUL – Conversion of building for use as a studio with ancillary space and extension of roof. Granted 07/03/2000

17/04152/FUL – Demolition of existing temporary structures (external staircases, portable building, bridge links and other structures) and making good to the fabric of the retained building. Granted 26/04/2018.

Adjacent to the site – 72 Upper Ground21/02668/EIAFUL – Demolition of all existing buildings and structures for a mixed-use redevelopment comprising offices, cultural spaces and retail uses with associated public realm and landscaping, servicing areas, parking and mechanical plant. Decision pending.

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Vision: Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

The site has significant potential for a mix of uses that will contribute positively to the Waterloo Opportunity Area and this part of the South Bank and Bankside Strategic Cultural Area, including cultural uses, offices, housing with affordable housing, and shops and restaurants fronting a new piazza. Such a scheme would enhance the character and appearance of the South Bank Conservation Area.

By following the building line of Duchy Street there is a specific opportunity to create a new area of activated public realm between the site and the line of trees that marks the boundary with Bernie Spain Gardens. Sensitive redevelopment designed to complement proposals for the neighbouring former ITV site at 72 Upper Ground can also improve the public realm at Queen’s Walk, providing better activation to the river frontage; help increase the permeability of the area; and contribute positively to the townscape along this part of the South Bank.

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Site Allocation Policy Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

Land uses The site provides an opportunity for mixed-use redevelopment. This should include active frontage and cultural uses on the ground floor, plus housing. This could also include offices and/or workspace.

Uses at ground floor level on the northern, western and eastern perimeter of the site should include a range of small and medium-sized units suitable for independent businesses and cultural uses, designed to activate new areas of public realm.

Affordable housing and affordable workspace

The affordable housing threshold is 50 per cent for public sector land and 35 per cent for private sector land.

If office space is proposed, Local Plan Policy ED2 on affordable workspace will apply.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Heritage assets Development should cause no harm to the significance (including setting) of heritage assets, in particular:

• the Westminster World Heritage Site – Queen’s Walk should be widened to improve the approaches to it

• the South Bank Conservation Area, particularly in relation to views from River Thames / Queen’s Walk, Bernie Spain Gardens and Upper Ground; and no. 58 Upper Ground as a positive contributor

• the Old Barge House Alley Conservation Area (LB Southwark)

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Site Allocation Policy Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

Building heights and views; townscape

The site is not appropriate for a tall building. Taller elements of up to 44 metres are possible south of the LVMF view cone.

Development should:

• Mediate building heights to ensure the scheme is well integrated with its larger scale neighbours to the west and yet is responsive to the lower-rise character of its context to the south and east.

• Respect the Strategic Linear view 8 from Westminster Pier to St Paul’s Cathedral.

• Avoid appearing in the setting of Somerset House as viewed from its courtyard entrance.

• Continue the building line on Upper Ground established by no. 58 Upper Ground in order to integrate the historic building into the development.

• Set back the building line on Queen’s Walk to give more space to the public realm and allow for entry and egress from the development. This will improve the public realm approaches to the Westminster World Heritage Site.

• Continue the building line set by Duchy Street frontages to the eastern boundary with Bernie Spain Gardens.

• Ensure there are active ground floor uses around as much of the site perimeter as possible.

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

Potential should be explored for freight consolidation and shared servicing with adjoining and nearby sites. Servicing must be off-street and accessed from Upper Ground.

Development will be expected to contribute to projects to improve conditions for cyclists and pedestrians and reduce through-traffic in the vicinity of the site.

New vibrant and attractive pedestrian routes should be created to the eastern and western boundaries of the site, giving access between Queen’s Walk and Upper Ground. This should be prioritised over creating a new route through the site.

The western route should be designed to respond positively to the proposed redevelopment at 72 Upper Ground, including straightening the current irregularity in the party wall building line on the western side of Princes Wharf.

On the eastern side, development should improve the relationship with Bernie Spain Gardens by straightening the path along its western edge and creating good natural surveillance through active ground floor frontages and upper floor fenestration.

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Site Allocation Policy Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution. Particular regard should be paid to the relationship with sensitive residential neighbours on Upper Ground.

Development should ensure that the amenity value of Bernie Spain Gardens is not diminished by undue overshadowing or enclosure.

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Site Allocation Policy Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

Flood risk mitigation Development must comply with Local Plan Policy EN5.

A site-specific Flood Risk Assessment will be required as part of a planning application and flood risk should be verified by site-specific breach inundation flood levels, to determine more accurate flood depths at precise locations.

Ground floor levels and below will be restricted to Less Vulnerable use types only and will require multiple access and egress points, in addition to an Evacuation Plan.

More vulnerable uses will not be allowed below breach.

There is a possibility the site could discharge its surface water directly to the River Thames. In this scenario, the sustainable drainage system should prioritise water quality management above reducing the rate of runoff e.g. an intensive green roof would be more practical than a blue roof.

If surface water is discharged into the Thames via an outfall with a diameter greater than 300mm the drainage system will need to include a second line of defence to prevent inundation if the system is tidally locked or should the main flap valve fail.

Should it not be feasible to discharge the site’s surface water into the River Thames, the development will be required to discharge any controlled runoff at the greenfield runoff rate.

The approximate greenfield runoff rate is QBar=2.8l/s.

All developments adjacent to a tidal flood defence, must ensure the current and future statutory crest levels are maintained as outlined in the Thames Estuary 2100 plan and the condition of tidal wall defences provide a sufficient level of defence in accordance with the design life of the building (e.g. generally 100 years for residential and 50-60 years for commercial), and that a 16 metres setback safeguarded for inspections, maintenance, future defence raising and potential replacement without increasing flood risk or encroaching on the river channel.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

Waste management The River Thames should be prioritised for transportation of construction materials and waste during construction of the development, and for site waste once operational. Where possible, construction should be coordinated with nearby sites.

Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

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Site Allocation Policy Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

Access to open space and nature conservation

Development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d).

If development will result in increased useage of nearby open spaces, developer contributions will be sought to their ongoing maintenance and management.

Urban greening and trees The building line to the eastern edge of the site should not harm the root protection zones or canopies of trees in Bernie Spain Gardens. Allowance should be made for the construction phase and also future growth of the trees.

The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

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Section 3: Proposed Brixton Site Allocations

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Proposed Brixton Site Allocations

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Proposed Site 17: 330–336 Brixton Road SW9

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Context Proposed Site 17: 330–336 Brixton Road SW9

Site address and postcode 330–336 Brixton Road SW9

Ward Current: Ferndale

Proposed: Brixton North

Site area 0.52 ha

Land ownership 332-334 Brixton Road is owned by South London and Maudsley NHS Foundation Trust. The rest of the site is in mixed private ownership.

Existing land uses 330 Brixton Road – petrol station and premises – 552 sqm GIA

Land to the rear of 330-334 Brixton Road – 1,289 sqm GIA of light industrial workshop space (non-designated industrial land).

332-334 Brixton Road – 563 sqm GIA of medical services with ancillary office floorspace

336 Brixton Road – 3,553 sqm GIA of office and associated ancillary floorspace

Local Plan Place and Neighbourhood policy

PN3: Brixton

London Plan and Local Plan designations

Within the Brixton Creative Enterprise Zone. Not within a town centre.

Neighbourhood Development Plan

None

Community Infrastructure Levy charging zones

• Lambeth CIL Zone C

• MCIL2 Band 2

Heritage assets Site partly within:

• Brixton Road Conservation Area

• Archaeological Priority Area no. 4 – Line of Roman Road linking London and Lewes

Adjacent:

• 340 Brixton Road (Grade II)

Views No strategic views.

Local views (Policy Q25):

• (c) (i) (c) View N and NNE from Brockwell Park to the City

Transport and access • PTAL 2

• Brixton Road is part of the TfL Road Network (TLRN) and a TfL Red Route

• Brixton Road is part of the ‘Partnership’ Heathy Routes

• Within the Brixton Liveable Neighbourhood area ‘Opportunities to Improve’.

Air Quality Focus Area No

Energy Located in a Heat Network Priority Area

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Context Proposed Site 17: 330–336 Brixton Road SW9

Flood risk The site is in Flood Zone 1. EA and Lambeth modelling suggests flood flows are confined to the highway for the high (3.3 per cent AEP) and medium (1.0 per cent AEP) risk events, with flood depths between 0.15 and 0.30m. The low-risk event shows the flooding from the highway to extend past the eastern site boundary.

Access to open space and nature conservation

There is a local open space directly opposite the site on the other side of Brixton Road.

The site is within an area of open space deficiency for district and regional parks.

The site is within an area that is deficient in access to nature.

Trees No Tree Preservation Orders on or adjacent to the site.

Community safety Recorded crimes in Ferndale ward August 2020 – July 2021: 2,691.

Top three categories:

• Anti-social behaviour: 38.3 per cent

• Violence and sexual offences: 16.6 per cent

• Other theft: 7.5 per cent

Recorded crimes in Ferndale ward September 2018 – July 2021: 8,202.

Top three categories:

• Anti-social behaviour: 30.3 per cent

• Violence and sexual offences: 18 per cent

• Other theft: 10.6 per cent

Ferndale ward has had one of the highest rates of serious youth violence (SYV) in Lambeth since 2018 and was the sixth highest ward out of 21 in 2020.

Description of current site character

No. 330 Brixton Road is a modern petrol filling station with forecourt canopy, totem sign and retail unit. It harms the appearance of the conservation area.

Nos. 332 – 334 Brixton Road are an inaccurate rebuild of a pair of early Victorian houses. Their scale and general appearance make them a low basic positive contributor to the conservation area, but the façade detailing is inauthentic (especially the discordant central door / window on the party wall between the two units).

No. 336’s striking frontage office block is a post-war landmark. It was erected as a computer centre for Coutts Bank and is considered to be a non-designated heritage asset. It is a positive contributor to the conservation area. The warehouses premises behind the frontage buildings are not considered to have any architectural or historic interest and where they stand within the conservation area they are considered to make a negative contribution.

Neighbour context The site is surrounded by 3 to 4 storey housing dating from a variety of periods.

Relevant planning history None

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Vision: Proposed Site 17: 330–336 Brixton Road SW9

Redevelopment of this site offers potential to provide improved accommodation for existing users, including offices for the WeAre336 hub of voluntary and community sector organisations, plus NHS clinical facilities and associated ancillary space. Retention of light industrial workspace on the site will make a significant contribution to the Brixton Creative Enterprise Zone. There is additional potential to create new housing and affordable housing.

New development can positively contribute to place-shaping in the area by enhancing the townscape and visual attractiveness of the site, improving the environment for pedestrians through the reduction in vehicle cross-overs, and introducing soft landscaping to the Brixton Road frontage to improve visual amenity, air quality and sustainable urban drainage. Winans Walk has potential to be reinstated as a residential street through the creation of a defensible street boundary and dedicated footways at the rear of the site. Some of the key features of the Brixton Road Conservation Area can also be reinstated, including the historic building line, street boundary treatments and soft-landscaped front gardens.

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Site Allocation Policy Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

Land uses The site provides an opportunity for comprehensive mixed-use redevelopment, which is likely to help optimise overall development capacity and achieve the best place-shaping outcome. However, given multiple land ownerships, the site may come forward in phases, in which case each phase should contribute to and help deliver the overall vision for the site as a whole. Proposals for any part of the site should not compromise or restrict delivery of the overall vision.

Redevelopment should include replacement office and community floorspace of equivalent or better functionality, new light industrial workspace appropriate to the Brixton Creative Enterprise Zone and new housing, including affordable housing.

The site as a whole has potential to accommodate:

• Reprovision of the existing quantum of office floorspace.

• Reprovision of the existing community use to equivalent or better functionality, unless the existing clinical facility is re-provided elsewhere as part of an agreed strategy for provision of that service

• At least 1,289 sqm GIA light industrial workspace (to achieve no net loss of existing industrial floorspace capacity).

• Approximately 70 to 75 self-contained residential units, with the quantum depending on the relative proportions of other uses on the site.

Affordable housing The affordable housing threshold will range from 35 per cent to 50 per cent as the site is in a mix of private and public ownership.

If the site comes forward for comprehensive development, the affordable housing threshold across the whole site will be 38 per cent.

In a phased approach, the affordable housing threshold for each phase of development will be calculated pro rata according to the proportion of private and public sector land involved in that phase, following the approach in the GLA Practice Note ‘Threshold Approach to Affordable Housing on Public Land’ (July 2018) or any subsequent updated guidance.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Given the requirement to provide workspace on this site within the Brixton Creative Zone, there is a particular opportunity to provide jobs and skills training for local people in the creative industries.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

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Site Allocation Policy Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

Heritage assets Development should preserve or enhance the significance (including setting) of heritage assets including:

• Brixton Road Conservation Area

• 340 Brixton Road (Grade II)

Opportunities include:

• removal of the discordant petrol station including its canopy and signage

• removal of vehicle hard standing to the street frontage

• reinstating the original building line parallel to Brixton Road

• reinstating boundary treatments to Brixton Road

• better integration of no. 336 into the townscape

• authentic remodelling of the frontage of 332-334 Brixton Road; redevelopment of 332-334 will be considered if the proposed replacement causes no harm to the character or appearance of the conservation area

Building heights and views; townscape

The site is not appropriate for a tall building. Heights should step down from no. 336 south to north on the Brixton Road frontage. There is potential for slightly greater height at the rear of the site to Winans Walk.

Development should address the following principles:

• Retain the frontage building at no. 336 Brixton Road as a positive contributor to the conservation area

• Use high quality building materials which preserve or enhance the character and appearance of the conservation area

• Re-instate the historic building line to Brixton Road

• Remove the car-dominated front forecourts and replace with front gardens and landscaping

• Restore Winans Walk as a residential street by introducing a pavement and defensible street boundary

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

Servicing should be accommodated off-street, potentially using Winan’s Walk as per the existing arrangement.

Development should facilitate the reduction of off-street parking fronting Brixton Road, the reduction of vehicle crossovers and associated improvements to the public realm for pedestrian safety.

It may be possible to create a pedestrian access to the development site from Winans Walk.

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Site Allocation Policy Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution. Particular regard should be paid to the relationship with sensitive residential neighbours on George Mews, Winans Walk and at Bedwell House.

Flood risk mitigation Development must comply with Local Plan Policy EN5.

Mitigation measures to reduce the risk of surface water flooding from the surface water flow route along Brixton Road are highly recommended and will be required should residential development be considered at areas prone to flooding (i.e. the southeast corner). The standard of protection required will be for the medium risk (i.e. 1 per cent AEP) event with the impacts of climate change which must be considered.

It is expected that finish flood levels and/or threshold levels are at a minimum of 300mm above the 1 per cent AEP flood.

Sustainable Urban Drainage Systems will be required as per the requirements of Local Plan Policy EN6. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs, and blue/green infrastructure in open spaces are ideal for this location to achieve this and should be considered.

The approximate greenfield runoff rate is QBar=2.81 l/s.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

Waste management Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

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Site Allocation Policy Proposed Site 9: Gabriel’s Wharf and Princes Wharf, Upper Ground SE1

Access to open space and nature conservation

Development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d).

Urban greening and trees Soft landscaping should be incorporated on the Brixton Road frontage that will enhance the visual attractiveness of the site and provide a SuDS function.

The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

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Proposed Site 20: Tesco, 13 Acre Lane SW2

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Context Proposed Site 20: Tesco, 13 Acre Lane SW2

Site address and postcode Tesco Store, 13 Acre Lane SW2

Ward Current: Brixton Hill

Proposed: Brixton Acre Lane

Site area 1.3 ha

Land ownership Private

Existing land uses Tesco supermarket (approximately 2,500 sqm net sales area) and car park (229 spaces)

Local Plan Place and Neighbourhood policy

PN3: Brixton

London Plan and Local Plan designations

• Brixton major town centre (outside primary shopping area)

• Brixton Creative Enterprise Zone

Neighbourhood Development Plan

None

Community Infrastructure Levy charging zones

• Lambeth CIL Zone C

• MCIL2 Band 2

Heritage assets There are no heritage assets on the site.

Nearby:

• Trinity Gardens Conservation Area

• Brixton Conservation Area

• Lambeth Town Hall, Brixton Hill / Acre Lane (Grade II)

• Trinity Homes Almshouses, 1-26 Acre Lane (Grade II)

• 46 Acre Lane (Grade II)

• Cedars House, 48-50 Acre Lane, (Grade II)

• 52 Acre Lane (Grade II)

• 55-57 Acre Lane (Grade II)

• Ivor House, Acre Lane (local list)

Views No strategic views.

Local views (Policy Q25):

• (c) (i) Views NNW from Brockwell Park to (a) Lambeth Town Hall’s Tower, and (b) St Matthew’s Church tower.

• (c) (ii) Views from Norwood Park to the City

Transport and access • PTAL 6a – walking distance to Brixton tube and over-land stations and numerous bus stops

• Acre Lane – London Distributor Road

• Within Brixton Liveable Neighbourhood

• Within Brixton Hill Low Traffic Neighbourhood

• Nearest cycle hire docking station on Saltoun Road off Effra Road (42 bikes)

Air Quality Focus Area No

Energy Located in a Heat Network Priority Area

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Context Proposed Site 20: Tesco, 13 Acre Lane SW2

Flood risk Within flood risk zone 1. No known surface water management issues.

Access to open space and nature conservation

Part of the site is within an area that is deficient in access to nature.

Trees There are three trees on site protected under Tree Preservation Order no. 180. These are:

• Tree 1 – Sycamore Acer pseudoplatanus on boundary with 22 Baytree Road SW2 5RP

• Tree 2 – Ash Fraxinus excelsior on boundary with 4 Porden Road SW2 5RT. This tree is no longer present.

• Tree 3 – Sycamore Acer pseudoplatanus within Tesco car park c15m from the boundary with Acre Lane.

There are existing mature street trees along the Acre Lane boundary of the site.

Community safety Recorded crimes in Brixton Hill ward August 2020 – July 2021: 2,267.

Top three categories:

• Anti-social behaviour: 35.5 per cent

• Violence and sexual offences: 21.9 per cent

• Burglary: 7.1 per cent

Recorded crimes in Brixton Hill ward September 2018 – July 2021: 6,657.

Top three categories:

• Anti-social behaviour: 29.7 per cent

• Violence and sexual offences: 22.6 per cent

• Vehicle crime: 7.3 per cent

Brixton Hill has one of the highest rates of serious youth violence in Lambeth.

Description of current site character

The site accommodates a single storey supermarket with surface level car parking.

Neighbour context To the north, across Acre Lane, is the Trinity Gardens Conservation Area and several Grade II listed buildings.

The site to the west, 41–45 Acre Lane, is being redeveloped for housing. To the east along Acre Lane lie Ivor House and Lambeth Town Hall, within the Brixton Conservation Area.

Behind the site along Baytree Road and Porden Road are two storey residential terraces. The south-east corner of the site tapers to a point between Arlington Lodge and Somerset Place, five storey blocks of flats.

Relevant planning history None

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Vision: Proposed Site 20: Tesco, 13 Acre Lane SW2

The site presents an opportunity to reprovide a supermarket for the town centre in addition to new homes, including affordable housing. This will help to address the current poor appearance of the site through high quality design, which responds well to its sensitive context adjoining conservation areas. Other benefits include a widened footway and increased activity on and around Acre Lane, that will improve community safety; and significant potential for enhanced urban greening and biodiversity.

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Site Allocation Policy Proposed Site 20: Tesco, 13 Acre Lane SW2

Land uses • Replacement supermarket with residential. The site has potential to accommodate approximately 120 to 170 self-contained residential units.

Affordable housing The affordable housing threshold is 35 per cent.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Heritage assets • Development should cause no harm to the significance (including setting) of heritage assets, in particular to the setting of Lambeth Town Hall in views from Coldharbour Lane, which is identified as significant in the Brixton Conservation Area Statement.

Building heights and views; townscape

The site is not appropriate for a tall building development.

Development should address the following principles:

• reinstate a building line to Acre Lane

• introduce animation and pedestrian entrances to Acre Lane

• use materials and massing which responds positively to local distinctiveness

• ground floor residential units should all be provided with adequate defensible space, especially those fronting Acre Lane

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

A replacement supermarket of equivalent net sales area to the existing store is expected to need an appropriate level of parking to operate effectively. Car parking provision should secure a meaningful reduction from the existing quantum in order to achieve key Local Plan and Transport Strategy objectives around active travel, carbon reduction and air quality improvement. Non-car access and pedestrian accessibility to the store should be positively promoted through scheme design.

Visibility for pedestrians and cyclists should be optimised and pedestrian access into and through the site should be improved. This should include a widened footway along Acre Lane with enhanced urban greening.

Servicing of the replacement supermarket should be accessed from Baytree Road rather than from Acre Lane.

Vehicular cross-overs at Acre Lane should be minimised, to maximise pedestrian flow to and from the town centre.

New streets should be legible, safe, and tree-lined, with adequate defensible space to ground floor residential uses.

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Site Allocation Policy Proposed Site 20: Tesco, 13 Acre Lane SW2

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution. Particular regard should be paid to the relationship with sensitive residential neighbours on Baytree Road, Porden Road and Arlington Lodge.

There may be benefits to future occupiers in reducing the height of the boundary wall shared with Arlington Lodge.

Flood risk mitigation Development must comply with Local Plan Policy EN5.

Site-specific Flood Risk Assessment (FRA) and Drainage Strategy that demonstrates conformity with national and local standards and policies for sustainable surface water management will be required to support any planning application.

Sustainable Urban Drainage Systems will be required as per the requirements of Local Plan Policy EN6. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs, and blue/green infrastructure in open spaces are ideal for this location to achieve this and should be considered.

The approximate greenfield runoff rate is QBar=6.75l/s.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

Waste management Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d).

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Site Allocation Policy Proposed Site 20: Tesco, 13 Acre Lane SW2

Urban greening and trees The existing trees of value are protected under Local Plan Policy Q10. Development should be situated to avoid harm to them or to existing street trees during construction. Additional urban greening should be provided in association with a widened footway along Acre Lane.

The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

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Proposed Site 21: 51–65 Effra Road SW2

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Context Proposed Site 21: 51–65 Effra Road SW2

Site address and postcode 51–65 Effra Road SW2

Ward Current: Coldharbour

Proposed: Brixton Rush Common

Site area 1.85 ha

Land ownership The site is in mixed public and private ownership.

Lambeth Council owns Fitch Court, 59 Effra Road with land adjoining, and 61 and 63 Effra Road.

Existing land uses Brixton Unitarian Church – approximately 400 sqm GIA of community floorspace

Mosaic Centre – approximately 700 sqm GIA of community floorspace

Effra Road retail park – 3,456 sqm GIA of retail floorspace across two large sheds.

Fitch Court – 35 self-contained residential units (affordable sheltered housing, to be re-provided as part of the nearby Somerleyton Road development)

63 Effra Road (b and c) – 2 self-contained residential units (market housing owned and let by the Church)

Masey Mews – private road providing access to the separate housing development at the rear of the Church.

Local Plan Place and Neighbourhood policy

PN3: Brixton

London Plan and Local Plan designations

The site falls within:

• Brixton Creative Enterprise Zone

• The site is not within a town centre

Neighbourhood Development Plan

None

Community Infrastructure Levy charging zones

• Lambeth CIL Zone C

• MCIL2 Band 2

Heritage assets Within the site:

• Art Deco lamp-post (local list)

Whilst considered to be a competent piece of post-war design, the Brixton Unitarian Church is not of sufficient quality to warrant treatment as a non-designated heritage asset.

Close to the site:

• Brixton Conservation Area to the north

• 43 and 45 Effra Road (Grade II)

• Lambeth Town Hall (Grade II)

• St Matthew’s Church (Grade II*)

• 47 and façade of 49 Effra Road (local list)

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Context Proposed Site 21: 51–65 Effra Road SW2

Views No strategic views.

Local views (Policy Q25):

• (c) (i) View NNW from Brockwell Park to (a) Lambeth Town Hall tower

• (c) (i) View NNW from Brockwell Park to (b) St Matthew’s Church tower

• (c) (i) View NNW from Brockwell Park (c) N and NNE to the City

Transport and access • PTAL – 6a

• Effra Road is a London Distributor Road

• Southern edge of Brixton Liveable Neighbourhood

• Site in Railton Low Traffic Neighbourhood

• Nearest cycle hire docking station on Saltoun Road off Effra Road (42 bikes)

• Pedestrian environment: relatively narrow footways walking towards Brixton

Air Quality Focus Area Yes - Brixton/Streatham

Energy Located in a Heat Network Priority Area

Flood risk The site is located in Flood Zone 1.

The EA’s model and Lambeth’s ICM model show a high risk (3.3 per cent AEP) of flooding to the site from surface water, with depths between 0.30 and 0.60m during a 1 per cent Annual Exceedance Percentage event.

The source of this water is likely to be from flows within the highway generated by the large upper catchment. This water then flows through the site entrance from Effra Road. According to the current models the flood water reaches existing residential properties along Dalberg Road.

Access to open space and nature conservation

Rush Common adjoins the site and runs along both sides of Effra Road. St Matthew’s Church Gardens is within 200m of the site and Brockwell Park is within 500m of the site.

The site is within an area of open space deficiency for regional parks.

Trees No Tree Preservation Orders (TPO) located on or adjacent to the site.

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Context Proposed Site 21: 51–65 Effra Road SW2

Community safety Recorded crimes in Coldharbour ward August 2020 – July 2021: 4,005.

Top three categories:

• Anti-social behaviour: 35 per cent

• Violence and sexual offences: 20.3 per cent

• Drugs: 6.9 per cent

Recorded crimes in Coldharbour ward September 2018 – July 2021: 11,368.

Top three categories:

• Anti-social behaviour: 28.2 per cent

• Violence and sexual offences: 22 per cent

• Other theft: 8.2 per cent

Coldharbour Ward had one of the highest rates of serious youth violence offences and the highest rate of firearm offences among Lambeth wards between 2018 – 2020.

Description of current site character

At the north of the site are two large retail sheds with extensive forecourt parking. To the south of this is an inward-looking development of sheltered housing (Fitch Court) which is two storeys in height and dates from the 1980s/1990s. At the southern end of the site, south of Masey Mews, is the post-war Brixton Unitarian Church complex and adjoining it to the south is the single-storey Mosaic Clubhouse which is a purpose-built 1970s community facility, providing support to those living with a mental health condition in the borough of Lambeth. The Rush Common designation runs along the front part of each of these individual plots fronting Effra Road, providing a welcome sense of openness and greenery.

Neighbour context Terraced housing to the east (Dalberg Road) and flats to the south (Bailey Mews and Masey Mews). To the west, across Effra Road, a medium-rise residential housing estate (St Matthew’s Estate) set in Rush Common landscape. The Eurolink Business Centre, a designated Key Industrial and Business Area, is immediately to the north of the site.

Relevant planning history None

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Vision: Proposed Site 21: 51–65 Effra Road SW2

Together, the parcels of land within this site present an opportunity to bring forward high-quality, mixed-use development that can contribute replacement community facilities and place of worship, new workspace and jobs within the Brixton Creative Enterprise Zone, and new housing and affordable housing within an existing residential neighbourhood, all within walking and cycling distance of Brixton town centre. New development will provide improvements to the quality of the Rush Common open space, with new green space and trees to improve amenity and air quality and assist with sustainable urban drainage in an area at risk of surface water flooding. New buildings will reinstate the historic building line along Effra Road, respect local views and preserve or enhance the setting of the Brixton Conservation Area and other nearby heritage assets. It will provide a strong sense of place, with a unified architectural character that reflects and enhances the local distinctiveness of this part of Brixton.

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Site Allocation Policy Proposed Site 21: 51–65 Effra Road SW2

Land uses The site provides an opportunity for comprehensive mixed-use redevelopment, which is likely to achieve optimum development capacity and the best place-shaping outcome. However, given multiple land ownerships and the need to ensure effective transitional arrangements for current uses, the site may come forward in phases, in which case each phase should contribute to and help deliver the overall vision for the site as a whole. Proposals for any part of the site should not compromise or restrict delivery of the overall vision.

Redevelopment should include replacement space for the existing community uses of equivalent or better functionality and equivalent affordability to the occupiers; new light industrial workspace appropriate to the Brixton Creative Enterprise Zone; and new housing, including affordable housing. Planning applications must consider and address the transitional arrangements required to ensure on-going and effective provision of services by and for the current occupiers of the community facilities on the site.

The site as a whole has potential to accommodate:

• Replacement community space of equivalent or better functionality to that already on the site and equivalent affordability to the occupiers

• Approximately 200 to 240 self-contained residential units (gross)

• An element of flexible, light industrial workspace at the northern end of the site

Affordable housing The affordable housing threshold will range from 35 per cent to 50 per cent as the site is in a mix of private and public ownership.

If the site comes forward for comprehensive development, the affordable housing threshold across the whole site will be 39 per cent.

In a phased approach, the affordable housing threshold for each phase of development will be calculated pro rata according to the proportion of private and public sector land involved in that phase, following the approach in the GLA Practice Note ‘Threshold Approach to Affordable Housing on Public Land’ (July 2018) or any subsequent updated guidance.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Given potential to create new workspace on this site within the Brixton Creative Zone, there is a particular opportunity to provide jobs and skills training for local people in the creative industries.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

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Site Allocation Policy Proposed Site 21: 51–65 Effra Road SW2

Heritage assets The locally listed lamp column should be repaired and brought back into working order. Should relocation be necessary the lamp should be placed in a publicly accessible area within the site.

Development should preserve or enhance the significance (including settings) of nearby heritage assets.

Building heights and views; townscape

The site is not identified as appropriate for tall building development (defined in this part of the borough as exceeding 45m in height). Given the local views constraints, heights should range from approximately 13m in the east to approximately 26-29m to the west and be stepped and arranged to avoid unacceptable impacts on neighbour amenity.

Development should also observe the following principles:

• Reinstate the historic building line to Effra Road.

• Ground floor residential units should, where possible, have their own front doors to the street rather than be accessed through communal cores, to maximise activity and surveillance.

• The architectural approach should demonstrate responsiveness to the site / local context, its history and the character. Locally distinctive stock brick should be the primary building material.

• Provide a coherent sense of place, with a strong unified architectural character.

• The community use and place of worship provides an opportunity for architectural interest and delight.

• Maintain the openness of Rush Common, enhance the existing landscaping.

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Site Allocation Policy Proposed Site 21: 51–65 Effra Road SW2

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

The layout of the site should minimise the number of vehicular crossing points over Rush Common and use where possible the existing retail park entrance/egress, and an upgraded Masey Mews. There is the potential to narrow the existing site entrance and move it slightly to south.

Rush Common land should be used to provide an enhanced walking route that is fully publicly accessible and landscaped accordingly. Where vehicles must cross pavements along Effra Road, a pedestrian priority design will be expected.

Vehicular traffic should not dominate the public realm within the site. This could include measures to slow cars through incorporation of a meandering route between landscaping features. Development access roads should not be gated and should provide well-overlooked conventional tree-lined streets.

Servicing for light industrial uses should comprise a single off-street servicing point that avoids service vehicles going through the site.

The street layout should be supported by all street-facing properties (including to Effra Road) having a positive relationship to the street with defensible space, natural surveillance and clear entrances. Rear gardens and communal amenity space should not be publicly accessible.

Landscaping should incorporate children and young people-friendly features such as play-on-the-way parallel playable routes.

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Rush Common land should not be relied upon to meet external amenity space standards for new housing.

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Site Allocation Policy Proposed Site 21: 51–65 Effra Road SW2

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution.

Particular regard should be paid to the relationship with sensitive residential neighbours on Dalberg Road, Masey Mews, and Bailey Mews. New terraced housing to the rear of site should provide a better relationship with the gardens on Dalberg Road than the existing site layout.

Flood risk mitigation Development must comply with Local Plan Policy EN5.

Part of the site is subject to considerable surface water flooding. A site-specific Flood Risk Assessment (FRA) will be required for any new development and must address the surface water flooding risk. To mitigate the risk of flooding the FRA should include and consider in order of preference:

• Analyse, assess, and understand the flood risk in detail to establish extents and depths of flooding across the development site, with an acceptable level of confidence.

• Avoid the most vulnerable use types in locations at risk of flooding (e.g. Omit development in location identified as at risk of flooding).

• Substitute land use types in accordance with the Environment Agency’s Vulnerability Classification, through locating the most vulnerable use types to areas least likely to flood (e.g. locate residential properties above ground floor levels in at risk locations).

• Mitigate the risk of flooding through a Flood Alleviation Scheme that manages the source(s) of flooding, but ensuring the risk of flooding elsewhere is not increased. Examples of measures include land and threshold raising, flood control measures, and surface water management measures. (Note: Surface water flood level reaches 16.685m AOD (0.384m deep).

In addition to the above, Sustainable Drainage Systems (SuDS) will be required as per the requirements of Local Plan Policy EN6. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs, and blue/green infrastructure in open spaces are ideal for this location to achieve this and should be considered.

The approximate greenfield runoff rate is QBar=10.02 l/s.

Planning obligations may be sought towards a Flood Alleviation Scheme in the form of SuDS in the vicinity that will help to reduce the surface water flood risk to the site and neighbouring properties (located the other side of Effra Road within Council-owned land). This scheme may reduce the risk for the site sufficiently to allow residential properties to be located at ground floor.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

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Site Allocation Policy Proposed Site 21: 51–65 Effra Road SW2

Waste management Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Rush Common open space should be retained and enhanced, including the removal of hardstanding and reinstatement of soft landscaping.

In addition, development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d).

Urban greening and trees New development should optimise opportunities for street tree planting and new green infrastructure along Effra Road.

Trees of value on Rush Common should not be negatively impacted or altered by the development.

The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

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Section 4: Proposed Streatham Site Allocation

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Proposed Streatham Site Allocation

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Proposed Site 3: 35–37 and Car Park Leigham Court Road SW16

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Context Proposed Site 3: 35–37 and Car Park Leigham Court Road SW16

Site address and postcode 35–37 and Car Park Leigham Court Road SW16

Ward Current: Streatham Wells

Proposed: Streatham Hill East

Site area 0.22 ha

Land ownership Lambeth Council

Existing land uses Car park

Public toilets (disused) 35–37 Leigham Court Road

Local Plan Place and Neighbourhood policy

PN4: Streatham

London Plan and Local Plan designations

Nos 35–37 Leigham Court Road are within Streatham major town centre but not in a primary shopping area. The car park at the rear of the site is not within the town centre.

Neighbourhood Development Plan

None

Community Infrastructure Levy charging zones

• Lambeth CIL Zone D

• MCIL2 Band 2

Heritage assets There are no heritage assets within the site.

Near the site:

• Streatham High Road/Streatham Hill Conservation Area adjoins to the north, west, and south-west.

• Leigham Court Road (North) Conservation Area adjoins to the south. Nos. 39 and 43 Leigham Court Road immediately adjoining the site and are positive contributors to this conservation area. No. 45 and the synagogue make a neutral contribution to the conservation area; their main merits are their sympathetic height. No. 49 Leigham Court Road is locally listed and a positive contributor to this conservation area.

Views None

Transport and access • PTAL 6a

• Leigham Court Road is a ‘Local Distributor Road’

• Streatham Hill is a Healthy Routes ‘Partnership route’

• Site is close to Streatham Hill station

• Located in Streatham Hill Low Traffic Neighbourhood

• Good bus links with a number of bus stops close by on Streatham High Road

• Not currently within a Controlled Parking Zone

• Some Red Route 30 minute parking/loading along Leigham Court Road

Air Quality Focus Area Yes - Brixton/Streatham

Energy Located in a Heat Network Priority Area.

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Context Proposed Site 3: 35–37 and Car Park Leigham Court Road SW16

Flood risk The site is within flood risk zone 1.

There are no known surface water management issues at this site.

Access to open space and nature conservation

Hillside Gardens Park and Tooting Bec Common (LB Wandsworth) are about 900m from the site. Valley Road Playing Fields are about 1km from the site.

The site is within an area of open space deficiency for local, small and pocket parks, as well as regional parks.

Borough Site of Importance for Nature Conservation (SINC) 14 – Railway Lineside Streatham Hill abuts the site.

Trees No Tree Preservation Orders located on or adjacent to the site. Mature trees within the Leigham Court Road (N) Conservation Area adjoin the site.

Community safety Recorded crimes in Streatham Wells ward August 2020 – July 2021: 1,651.

Top three categories:

• Anti-social behaviour: 41.6 per cent

• Violence and sexual offences: 20.7 per cent

• Other theft: 8.7 per cent

Recorded crimes in Streatham Wells ward September 2018 – July 2021: 4,469.

Top three categories:

• Anti-social behaviour: 41.2 per cent

• Violence and sexual offences: 19.4 per cent

• Vehicle crime: 10 per cent

Streatham Wells Ward had the 4th lowest rate of Serious Youth Violence among Lambeth wards in 2020, down from 5th in 2019 and 9th in 2018.

Description of current site character

The site is a Council-owned public car park to the rear with disused public toilets fronting Leigham Court Road. The rear of the site abuts the railway line, including designated borough SINC 14 - Railway Lineside Streatham Hill which contains numerous mature trees.

Neighbour context The retail properties on the north side of Leigham Court Road between the site and Streatham High Road are generally single storey although 29-33 Leigham Court Road is two-storey. Across the road and towards Streatham High Road the inter-war buildings are five and six storeys in height and fall within the Streatham Town Centre boundary; they generally have retail at ground floor and there is a GP surgery. The footpaths on both sides of the road towards Streatham High Road are wide and generous for pedestrians.

Residential buildings to the south of the site are generally Victorian and three to four storeys in height.

There is a nursing home at no. 45 with a synagogue behind it (which bounds the site) and a disused bowling green behind Nos. 47 and 49.

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Context Proposed Site 3: 35–37 and Car Park Leigham Court Road SW16

Relevant planning history None on site

Adjacent to site – Dorchester Parade21/01583/FUL – Demolition of existing building and erection of a four-storey building with roof top insert, comprising two commercial units (Use Class E) on the ground floor with eleven flats (Use Class C3), together with the provision of private and communal amenity space, plus refuse, recycling and cycle storage facilities. Decision pending.

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Vision: Proposed Site 3: 35–37 and Car Park Leigham Court Road SW16

The site provides an opportunity for sustainable mixed-used development that includes ground floor active frontages onto Leigham Court Road, with commercial space or residential above, and new housing with affordable housing to the rear of the site. As well as contributing new commercial space to the town centre, new development can contribute positively to the character of the nearby conservation areas and help to improve the public realm along Leigham Court Road, creating an attractive gateway to the town centre from the south. There is a particular opportunity for urban greening in association with the nearby nature conservation site along the railway embankment. Potential for comprehensive redevelopment with adjacent sites is strongly encouraged.

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Site Allocation Policy Proposed Site 3: 35–37 and Car Park Leigham Court Road SW16

Land uses The site provides an opportunity for mixed-use development and is suitable for new housing with active ground floor town centre uses within the town centre boundary fronting onto Leigham Court Road.

The site has potential to accommodate:

• approximately 30 to 35 self-contained residential units

• ground floor commercial floorspace within Class E within the town centre boundary

Applicants are strongly encouraged to explore potential for comprehensive redevelopment with adjacent sites

Affordable housing The affordable housing threshold is 50 per cent as the site is in public sector ownership.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Heritage assets Development should preserve or enhance the significance (including setting) of all heritage assets.

Redevelopment of the site’s frontage should respond positively to the character of the adjoining Streatham High Road / Streatham Hill Conservation Area.

Care is required to preserve or enhance the setting of the Leigham Court Road (N) Conservation area, in particular the backdrops of nos. 39 & 43 Leigham Court Road. No building behind the street frontage block should loom up from behind these buildings when viewed from the opposite side of the street within this Conservation Area.

Building heights and views; townscape

The site is not appropriate for a tall building. Redevelopment should respond to the height of existing buildings across the road to reinforce the character of the town centre.

Development should also address the following principles:

• not compromise the future development potential of the single storey retail parade (nos. 29, 31, 33 and 33a Leigham Court Road) or other adjacent sites, and should explore potential to bring sites forward together where possible

• respond positively to the adjacent SINC by maximising the opportunity for urban greening on the site and to enhance residential amenity areas

• high quality design to reflect that seen throughout the surrounding conservation areas

• use of brick is strongly encouraged to reinforce local distinctiveness and heritage settings

• provide a clear public front and a secure, resident-only rear to the site

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101 Draft Lambeth SADPD | Section 4: Proposed Streatham Site Allocation

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Site Allocation Policy Proposed Site 3: 35–37 and Car Park Leigham Court Road SW16

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

The access route into the site should be publicly accessible and un-gated with a sense of security achieved through good levels of natural surveillance over all publicly accessible areas.

Vehicles accessing the site from Leigham Court Road will need to enter and exit in forward gear.

Off-street servicing and turning within the site must be provided.

The spacious footway and public realm to Leigham Court Road should be enhanced.

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution.

Particular regard should be paid to the relationship with sensitive residential neighbours on Leigham Court Road.

Flood risk mitigation Development must comply with Local Plan Policy EN5.

PSite-specific Flood Risk Assessment (FRA) and Drainage Strategy that demonstrates conformity with national and local standards and policies for sustainable surface water management will be required to support any planning application.

Sustainable Urban Drainage Systems will be required as per the requirements of Local Plan Policy EN6. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs, and blue/green infrastructure in open spaces is ideal to achieve this at this location and should be considered.

The approximate greenfield runoff rate: QBar=1.56l/s.

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Site Allocation Policy Proposed Site 3: 35–37 and Car Park Leigham Court Road SW16

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

Waste management Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency by meeting the requirements of Local Plan Policy EN1(d).

Urban greening and trees New development should be sensitive to adjacent trees on the boundary perimeter.

The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance. Urban greening should be provided across the site but specifically focused along the north-eastern boundary to provide biodiversity benefits and improve the cohesiveness to the SINC 14.

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104 Draft Lambeth SADPD | Section 5: Proposed West Norwood / Tulse Hill Site Allocations

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Section 5: Proposed West Norwood / Tulse Hill Site Allocations

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Proposed West Norwood / Tulse Hill Site Allocations

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Proposed Site 18: 286–362 Norwood Road SE27

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Context Proposed Site 18: 286–362 Norwood Road SE27

Site address and postcode 286–362 Norwood Road SE27

Ward Current: Knight’s Hill

Proposed: Knight’s Hill

Site area 1.9 ha

Land ownership Lambeth Council, Metropolitan Thames Valley Housing and mixed private ownership

Existing land uses • 80 residential units

– Snowe House (12 affordable units)

– Thanet House (12 units, 9 affordable)

– 8-12 Lansdowne Hill (12 affordable units)

– Residential above Knowles of Norwood (19 units)

– Residential above shops between 328-362 Norwood Road (24 units)

– 2 Lansdowne Hill (1 unit)

• 4,152 sqm GIA – retail floorspace (consisting of one large unit of 1,867sqm and 15 smaller units)

• 57 sqm GIA – office floorspace

• 2,605 sqm GIA – industrial floorspace

• 440 sqm GIA – church

• 233 sqm GIA – petrol station

• 318 sqm GIA – pub

• 263 sqm GIA – art studio

• 398 sqm GIA – fast food takeaways and restaurants (6 small units)

Local Plan Place and Neighbourhood policy

PN7: West Norwood / Tulse Hill

London Plan and Local Plan designations

The whole site falls within the West Norwood district centre. The frontage on Norwood Road lies within the primary shopping area and the rear of the site is outside the primary shopping area.

Neighbourhood Development Plan

Within neighbourhood area of Norwood Planning Assembly

Community Infrastructure Levy charging zones

• Lambeth CIL Zone D

• MCIL2 Band 2

Heritage assets No heritage assets within the site.

Near the site:

• St Luke’s Church, Knight’s Hill (Grade II*)

• 445 Norwood Road (Grade II)

• Lancaster Avenue Conservation Area

• West Norwood Conservation Area

• West Norwood Cemetery (registered landscape)

• 364-366 Norwood Road (local list)

• Archaeological Priority Area 14 – Levehurst Medieval Manor House

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Context Proposed Site 18: 286–362 Norwood Road SE27

Views No strategic views.

Local views (Policy Q25):

• (c) (iv) View N from Knight’s Hill (across LB Southwark) to the City Knight’s Hill looking north

• (d) (ii) View N along Knight’s Hill to St Luke’s Church Tower

• (d) (iii) View S along Norwood Road to St Luke’s Church Tower

• (d) (iv) View N from Chapel Road along Weaver Walk to St Luke’s Church Tower

Transport and access • PTAL 5 Very Good

• Norwood Road to the north of the site is part of the Healthy Route network

• Norwood Road is a London Distributor Road, York Hill is a Local Distributor, Lansdowne Hill is a Borough Road

Air Quality Focus Area No

Energy The Heat Network Priority Area is adjacent to the site on the eastern boundary.

Flood risk The site is in Flood Zone 1. The EA model only shows shallow (0.00-0.15m) surface water extent within the site, however this is moving away from the roof car park via the ramped surface towards Norwood Road.

Access to open space and nature conservation

St Luke’s Church Gardens and West Norwood Cemetery are to the south of the site.

The site is within an area of open space deficiency for district and regional parks; the northern part of site only is within an area of open space deficiency for local, small and pocket parks.

Trees No Tree Preservation Orders on or adjacent to the site. There is a group of trees at the York Hill end of site.

Community safety Recorded crimes in Knight’s Hill ward August 2020 – July 2021: 1,716.

Top three categories:

• Anti-social behaviour: 31.3 per cent

• Violence and sexual offences: 24.4 per cent

• Vehicle crime: 8.7 per cent

Recorded crimes in Knight’s Hill ward September 2018 – July 2021: 4,841.

Top three categories:

Anti-social behaviour: 29.9 per cent

Violence and sexual offences: 23.2 per cent

Vehicle crime: 10.1 per cent

Knight’s Hill Ward has had average rates of serious youth violence since 2018 and had the 11th highest rate out of 21 Lambeth wards in 2020.

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Context Proposed Site 18: 286–362 Norwood Road SE27

Description of current site character

A series of unrelated plots and dead-end routes comprising a large area between York Hill and Lansdowne Hill. The Norwood Road frontage, within the primary shopping area of West Norwood town centre, is lined with Victorian and 20th Century commercial premises, including a large retail shed. Within the site are pockets of existing housing, commercial garages, warehousing, a car park. Current buildings do not optimise the potential of the site given its town centre location, or provide a strong active frontage on the high street.

The sites at the foot of York Hill and ground levels step significantly on the western boundary with the York Hill Estate. For this reason, heights are given in both metres from ground level and in metres Above Ordnance Datum (AOD) height. The latter combines the building height and the height above sea level of the site itself.

Neighbour context To the east of the site are shops on Norwood Road with residential above. They are three to four storeys in height. To the south of the site is Lansdowne Church, built in 1907, and some modern flats/maisonettes which are two storeys. To the west of the site, and partially to its north, is the York Hill Estate, which is characterised by five storey blocks of walk-up Council flats. To the north of the site, across York Hill, are three storey terraces.

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110 Draft Lambeth SADPD | Section 5: Proposed West Norwood / Tulse Hill Site Allocations

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Context Proposed Site 18: 286–362 Norwood Road SE27

Relevant planning history 6 Lansdowne Hill19/02840/FUL – Demolition of the existing buildings and erection of a part 6 and part 7 storey building to provide 51 residential flats (Use Class C3) with amenity space at 5th floor level, and erection of a separate 4 storey office building (Use Class B1(a)), together with provision of cycle stores, car parking spaces, refuse/recycling stores, landscaping and new pedestrian links. Granted 13/03/2020.

294-298 Norwood Road19/00398/FUL – Erection of a part two, part three and part four storey building to provide 4 art studios (Use Class B1c) and 1 residential unit (1x 1-bed) (Use Class C3) at the ground floor and 8 residential units above (2x 1-bed and 6x 2-bed) (Use Class C3) together with provision of refuse and cycle storage and landscaping plus installation of solar panels. Refused 18/10/2019 – the proposal was considered to prejudice the future regeneration of the wider Norwood Town Centre Opportunity Area and did not comply with Local Plan policies on affordable housing, transport and design. Appeal dismissed 28/09/2021.

20/03478/FUL – Erection of part three, part two and part one storey building with nine residential units (use C3) located at first, second and third level and four art studios (B1c) located at ground floor level together with the provision of communal and private amenity space, cycle storage and refuse storage. Awaiting decision.

Rear of 300-302 Norwood Road18/05496/OUT – Application for outline planning permission (Access, Layout and Scale) to provide 28 dwellings (Use Class C3), community space (Use Class D1) and office space (Use Class B1), together with refuse and cycle storage, access, circulation and parking, amenity space and other ancillary works. Refused 22/03/2019 - insufficient marketing evidence to justify the loss of the D1 community floor space, unacceptable site layout, unsafe access and failure to comply with Local Plan policies on dwelling size mix, affordable housing and sustainability. Appeal dismissed 10/07/2020.

20/01394/FUL – Change of use from Sui generis (Use Class B1/B2) to storage and distribution (Use Class B8). Granted 16/09/2020.

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Vision: Proposed Site 18: 286–362 Norwood Road SE27

This key town centre site provides significant opportunity for sustainable, mixed-use redevelopment to include new housing and affordable housing, flexible workspace, and shops and food and drink uses that contribute to the renewal of the shopping frontage on Norwood Road, helping to contribute to the ‘fifteen-minute neighbourhood’ this area provides for local people.

The public realm around and within the site can be improved by increasing pedestrian and cycle permeability, through urban greening and by providing a new built frontage on Norwood Road that creates a more generous footway. A new town centre public space will provide an appropriate setting for new buildings and an appropriate space for informal town centre activity, allowing people to spend time in and move through the area. Development of high architectural quality and detailing will enhance the overall appearance of the town centre.

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Site Allocation Policy Proposed Site 18: 286–362 Norwood Road SE27

Land uses The site has potential for comprehensive, mixed-use development, but given the multiple land ownerships it is likely to come forward in phases. Each phase of development should contribute to and help deliver the overall vision for the site as a whole. Proposals for any part of the site should not compromise or restrict delivery of the overall vision.

The site as a whole has potential to accommodate approximately:

• 390 to 470 self-contained residential units (gross)

• 5,000 sqm to 7,000 sqm GIA of commercial/community floorspace.

A mix of unit sizes and types should be provided along Norwood Road. Uses will be restricted through conditions to ensure at least 50 per cent of units are in shop use within the primary shopping area, alongside other town centre and community uses that diversify and activate the high street.

Space provided behind the Norwood Road frontage can be fully flexible within Class E and could include some space within Classes F1 or F2 if the uses are appropriate to the town centre location. There is a particular opportunity to provide flexible workspace for creative businesses, to enhance the growing cluster in West Norwood and Tulse Hill.

Affordable housing The affordable housing threshold will range from 35 per cent to 50 per cent as the site is in a mix of private and public ownership.

The affordable housing threshold for each phase of development will be calculated pro rata according to the proportion of private and public sector land involved in that phase, following the approach in the GLA Practice Note ‘Threshold Approach to Affordable Housing on Public Land’ (July 2018) or any subsequent updated guidance.

If redevelopment proposals involve existing affordable housing, the requirements for reprovision set out in London Plan Policy H8 will apply.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Heritage assets Development should preserve or enhance the significance (including setting) of all heritage assets. Particular regard should be paid to:

• St Luke’s Church, Knight’s Hill (Grade II*)

• West Norwood Conservation Area

• West Norwood Cemetery (registered landscape)

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Site Allocation Policy Proposed Site 18: 286–362 Norwood Road SE27

Building heights and views; townscape

The central part of the site is appropriate for a tall building of a general building height of 36m (81m AOD), adjacent to a new public space. Other buildings slightly exceeding the threshold definition of tall buildings in this part of the borough (25m) may be acceptable in the central part of the site.

The rest of the site is suitable for buildings of around 15m (57m AOD) to 21m (69m AOD), to create a coherent roofscape rising from the perimeter street frontages to a single highest point within the site.

Development should also address the following principles:

• no harm to views affecting heritage assets

• provide a clearly defined parapet line to Norwood Road to respect context and create a balanced townscape with the Victorian frontage opposite

• activate ground floor uses along Norwood Road, as well as at public spaces and key routes through the site

• provide a varied roofscape for visual interest in townscape views

• use brick as the principal building material to reinforce local distinctiveness

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

Development should provide a network of new and reconfigured existing streets to increase permeability through the site. This should include:

• a reduced number of vehicular access points and no servicing from Norwood Road

• servicing accommodated on site, with all vehicles able to enter and exit in forward gear; potential to reduce servicing vehicle movements through freight consolidation should be fully explored

• a new service road to link York Hill to Lansdowne Hill, designed safely to accommodate pedestrians and cyclists

• improvements to east-west pedestrian and cyclist connections between the York Hill Estate and Norwood Road, including from Chatsworth Way

• a potential secondary east-west access for disabled parking and residential servicing, in addition to pedestrians and cyclists

• control of routes within the site to prevent ‘rat-running’ by vehicles seeking to avoid signals on Norwood Road

• new and reconfigured roads should be tree-lined and include separate roadway and footways

At the southern end of Norwood Road, the building line should be set back to provide enhanced public realm with highway improvements to walking and cycling as part of the Healthy Route Network.

High quality public realm should be provided within the site to serve the whole community. A new public space should provide a focal point for the town centre, preferably adjoining the largest buildings.

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Site Allocation Policy Proposed Site 18: 286–362 Norwood Road SE27

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

Development must ensure that residential streets are legible, they benefit from good natural surveillance and include prominent entrances with defensible space to the street.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution.

Particular regard should be paid to the relationship with sensitive residential neighbours on Lansdowne Hill, Norwood Road, York Hill and the York Hill Estate.

Flood risk mitigation Development must comply with Local Plan Policy EN5.

Site-specific Flood Risk Assessment (FRA) and Drainage Strategy that demonstrates conformity with national and local standards and policies for sustainable surface water management will be required to support any planning application.

Sustainable Urban Drainage Systems will be required as per the requirements on the NPPF. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs, and blue/green infrastructure in open spaces are ideal for this location to achieve this and should be considered.

The approximate greenfield runoff rate is QBar=7.27l/s.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

Waste management Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency by meeting the requirements of Local Plan Policy EN1(d).

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Site Allocation Policy Proposed Site 18: 286–362 Norwood Road SE27

Urban greening and trees High value trees should be retained and new streets should be tree-lined. Where possible, there should be improved tree planting on Norwood Road.

The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance. Significant levels of greening should be provided throughout new areas of public realm, including the new public space.

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Proposed Site 19: Knolly’s Yard SW16

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Context Proposed Site 19: Knolly’s Yard SW16

Site address and postcode Knolly’s Yard SW16

Ward Current: Knight’s Hill

Proposed: Knight’s Hill

Site area 1.45 ha

Land ownership Public sector (Network Rail)

Existing land uses 884 sqm GIA of industrial floorspace plus approximately 9,000 sqm of associated yard space

Local Plan Place and Neighbourhood policy

PN7: West Norwood / Tulse Hill

London Plan and Local Plan designations

Key Industrial and Business Area with potential for industrial intensification and co-location.

Not in a town centre.

SINC 10 surrounds and falls partly within the site.

Neighbourhood Development Plan

Located in the Norwood Planning Assembly neighbourhood planning area.

Community Infrastructure Levy charging zones

• Lambeth CIL Zone D

• MCIL2 Band 2

Heritage assets No heritage assets within the site.

Near the site:

• Holy Trinity Church, Trinity Rise (Grade II)

• 242-244 Norwood Road (Grade II)

• West Norwood Cemetery (registered landscape)

• Brockwell Park (registered landscape)

• West Norwood Conservation Area

• Lancaster Avenue Conservation Area

• Leigham Court Estate Conservation Area

• Brockwell Park Conservation Area

• 270 Norwood Road (local list)

• Hitherfield Primary School (local list)

Views No strategic views.

Local views (Policy Q25):

• (c ) Landmark Silhouette Views iii) - View N from Chapel Road along Weaver Walk of St Luke’s Church tower

Transport and access • PTAL is a mix of 6a, 5 and 3 across the site.

• Bus stop on York Hill at 200m. West Norwood station 900m walking distance; Tulse Hill 950m walking distance.

• Currently one single-track, low-level vehicular and pedestrian access to the site via Cameron Place, off Knolly’s Road.

• York Hill, Knolly’s Road and Leigham Vale are local distributor roads. Knolly’s Road is street lit and subject to a speed limit of 20mph with regular speed bumps. Knolly’s Road and York Hill both have wide pedestrian footways.

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Context Proposed Site 19: Knolly’s Yard SW16

Air Quality Focus Area No

Energy The Heat Network Priority Area is adjacent to the site on the eastern boundary.

Flood risk The site is in Flood Zone 1. EA and Lambeth Council modelling shows the site has medium (1 per cent AEP) and low (0.1 per cent AEP) risks of surface water flooding.

Access to open space and nature conservation

Part of the site is within an area of open space deficiency for district parks and the whole site is within an area of open space deficiency for local, small, pocket parks and regional parks.

Hillside Gardens Park, Unigate Wood and Valley Road Playing Fields are within 1.5km. West Norwood Cemetery is approximately 800m from the site.

Borough Site of Importance for Nature Conservation (SINC) 10 – Railway Lineside Leigham Vale and Tulse Hill Junctions surrounds the site on all three sides and falls partly within the site.

Trees Tree Preservation Order (TPO) Boundaries (nos. 211, 213, 214, 217) are on the perimeter of the site within the site boundary, except at the northern tip and the north-western boundary of the site. TPO Boundaries (nos. 212, 215, 216, 218 b) adjoin the outer perimeter of the site; and TPO no. 205: Horse Chestnut (Aesulus hippocastanum) is located outside 177 Knollys Road on the corner of Knollys Road and Cameron Place.

All TPO Boundaries (excluding no. 211) are either wholly or mostly within SINC 10.

Community safety Recorded crimes in Knight’s Hill ward August 2020 – July 2021: 1,716.

Top three categories:

• Anti-social behaviour: 31.3 per cent

• Violence and sexual offences: 24.4 per cent

• Vehicle crime: 8.7 per cent

Recorded crimes in Knight’s Hill ward September 2018 – July 2021: 4,841.

Top three categories:

• Anti-social behaviour: 29.9 per cent

• Violence and sexual offences: 23.2 per cent

• Vehicle crime: 10.1 per cent

Knight’s Hill Ward has had average rates of serious youth violence (SYV) since 2018 and had the 11th highest rate out of 21 Lambeth wards in 2020.

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121 Draft Lambeth SADPD | Section 5: Proposed West Norwood / Tulse Hill Site Allocations

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Context Proposed Site 19: Knolly’s Yard SW16

Description of current site character

The site is characterised by single storey industrial sheds and ancillary yard spaces, mostly used by a range of businesses working in the construction sector such as scaffolders. It is surrounded on all sides by three railway lines, each of which has a railway embankment that falls within a Site of Importance for Nature Conservation. The immediate impression within the site is therefore of green infrastructure shielding the appearance of the railway lines. There are significant level changes surrounding and across the site. The site is currently impermeable and severs the local area, so residents to the south and west have to walk around the site to get to the town centre and stations. The site presents exceptional development challenges arising from its very constrained access.

Neighbour context The surrounding area is generally characterised by two storey pre-war residential terraces with some modern infill development. Some of these are located in close proximity to the other side of the railway lines that surround the site.

Relevant planning history None

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Vision: Proposed Site 19: Knolly’s Yard SW16

The site presents a significant opportunity for local regeneration to provide new, high quality light industrial space appropriate for businesses in key Lambeth growth sectors such as the creative, digital and low carbon industries. This will add to the existing and growing clusters in these sectors elsewhere in West Norwood and provide for a significant uplift in local jobs and employment opportunities. In addition, the site can accommodate new housing and affordable housing close to existing residential neighbourhoods and near to West Norwood/Tulse Hill town centre. Improved pedestrian and cycle access to the town centre and new and inclusive areas of public realm will be essential to successful place-making and improved connectivity, shortening journey times to the station for existing residents and promoting sustainable transport. Extensive urban greening and improvements to biodiversity value will enhance the existing network of green infrastructure in this part of the borough, and could contribute to opportunities for urban food growing.

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Site Allocation Policy Proposed Site 19: Knolly’s Yard SW16

Land uses This site is a Key Industrial and Business Area with potential for industrial intensification and co-location with other uses, particularly residential.

Industrial intensification can be achieved through provision of high quality light industrial workspace, which in this part of the borough is particularly suited to businesses in the creative and digital and/or low carbon clean technology sectors. Space should be designed to be flexible to accommodate a range of types and size of business. At least 1,500 sqm GIA of light industrial floorspace should be provided, based on a robust demonstration that this meets identified needs and is designed accordingly.

In addition, the site has potential to accommodate approximately 400 to 430 self-contained residential units.

The site is not appropriate for main town centre uses.

Affordable housing The affordable housing threshold is 50 per cent as the site is in public sector ownership.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Given the requirement for provision of high quality light industrial workspace, there is a particular opportunity to provide jobs and training for local people within the creative and digital industries and/or low carbon sector.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Heritage assets Development should not harm the significance (including setting) of all heritage assets. In relation to proposed tall buildings, particular regard should be paid to:

• West Norwood Cemetery (registered landscape)

• Brockwell Park (registered landscape)

• West Norwood Conservation Area

• Holy Trinity Church, Trinity Rise (Grade II listed)

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Site Allocation Policy Proposed Site 19: Knolly’s Yard SW16

Building heights and views; townscape

Given the hilly topography and elevated nature of the site building heights are given in both metres from ground level and in metres Above Ordnance Datum (AOD) height. The latter combines the building height and the height above sea level of the site itself.

The settings of heritage assets, townscape considerations, and residential amenity constraints restrict development height in parts of the site.

The site is appropriate for tall buildings of the following general building heights:

• Western corner – general building height 68m (115m AOD)

• South-western side – general building height of 31m (78m AOD) rising to 40m (87m AOD) in the southern corner

• Northern side – general building height 34m (81m AOD)

Outside of these locations, heights should be below the tall building threshold (25m).

On the eastern side of the site, building heights should be lowest given the proximity to Harpenden Road.

Development should not cause unacceptable harm to local townscape character.

Development should also address the following principles:

• Given the scale and visibility of development, buildings should be of high-quality design with a material palette that harmonises and integrates well with the context. Taller buildings should have a pale recessive material palette.

• Dedicated external amenity space for residents should be clearly separated from areas of public realm.

• In addition to the required residential amenity space, publicly accessible areas should be designed be inclusive and to optimise their use and amenity value for people of all ages, including residents, workers and those passing through the site to access West Norwood/Tulse Hill town centre. Soft landscaping and trees are integral to achieving this.

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

The existing access from Cameron Place should be retained and the public realm improved. There is an opportunity for this to be used for pedestrian and cycle access only.

A new vehicular and pedestrian overbridge should be provided from the eastern end of Knolly’s Road to serve as the primary vehicular access into the site. Servicing should take place via this overbridge.

A new, safe and fully accessible footbridge for pedestrians, cyclists and those with mobility issues is necessary to connect the site to Leigham Vale. This is expected to result in a reduction in walking distances to Tulse Hill station by approximately half, thereby providing significant benefits to the wider area and promoting sustainable transport.

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126 Draft Lambeth SADPD | Section 5: Proposed West Norwood / Tulse Hill Site Allocations

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Site Allocation Policy Proposed Site 19: Knolly’s Yard SW16

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Residential amenity spaces should be for the sole use of occupiers and not double counted as public space.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution.

Particular regard should be paid to the relationship with sensitive residential neighbours on Leigham Vale, Harpenden Road, Cameron Place and Knolly’s Road.

Flood risk mitigation Development must comply with Local Plan Policy EN5.

A site-specific flood risk assessment will be required for any new development. The risk of flooding from surface water has been identified within the western corner of the site. Any new development may require a sequential approach to arranging the site layout and its use types, such as residential properties (should they be proposed) located outside the areas at risk or at above ground floor. The Flood Risk Assessment must acknowledge the surface water flood risk to the site and address it within the site proposal, as will developing the site layout and uses.

Sustainable Urban Drainage Systems will be required as per the requirements of Local Plan Policy EN6. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs, and blue/green infrastructure in open spaces are ideal for this location to achieve this and should be considered. Particular consideration should be given to water attenuation at the western edge of the site.

The approximate greenfield runoff rate is QBar=11.40l/s.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

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127 Draft Lambeth SADPD | Section 5: Proposed West Norwood / Tulse Hill Site Allocations

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Site Allocation Policy Proposed Site 19: Knolly’s Yard SW16

Waste management Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency by meeting the requirements of Local Plan Policy EN1(d).

Provision of a new footbridge to Leigham Vale will significantly improve access to Hillside Gardens Park.

Any harm to the nature conservation value of the SINC should be mitigated in accordance with Local Plan Policy EN1(b) and London Plan Policy G6 C.

Urban greening and trees The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

Proposed development should take account of existing trees on and surrounding the site in accordance with Local Plan Policy Q10 and London Plan Policy G7 C. Their value should be enhanced through complementary tree and shrub planting to maximise the green infrastructure network.

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128 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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Section 6: Proposed Kennington / Oval Site Allocation

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129 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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Proposed Kennington / Oval Site Allocation

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130 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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Proposed Site 7: 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11

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131 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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Context Proposed Site 7: 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11

Site address and postcode 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11

Ward Current: Prince’s

Proposed: Kennington

Site area 0.67 ha

Land ownership Guy’s and St Thomas’ NHS Foundation Trust own Wooden Spoon House. The rest of the site is in mixed private ownership.

Existing land uses 6–12 Kennington Lane (1,206 sqm GIA floorspace plus separate yard in use as a builders’ merchant) – non designated industrial land.

Christ the Redeemer Building (650 sqm GIA) – four storey building that stands within the yard fronting Kennington Lane (vacant but previously operating as a community use – language school).

Wooden Spoon House (approximately 2,800 sqm GIA) – medical services with ancillary office space and facilities.

Local Plan Place and Neighbourhood policy

PN8: Kennington / Oval

London Plan and Local Plan designations

None. Not within a town centre.

Neighbourhood Development Plan

Located in the Kennington, Oval and Vauxhall neighbourhood area

Community Infrastructure Levy charging zones

• Lambeth CIL Zone B

• MCIL2 Band 2

Heritage assets The north-western corner of the site is in the Renfrew Road Conservation Area.

Adjacent to the site on Renfrew Road:

• Former fire station (Grade II)

• Former Lambeth Magistrates’ Court (Grade II)

• Telephone Kiosk outside Magistrates’ Court (Grade II)

Near the site:

• Water tower to former Lambeth Workhouse (Grade II)

• Administrative block to former Lambeth Workhouse (Cinema Museum) (Grade II)

Adjacent to the site are the following locally listed buildings:

• Gate piers to former Lambeth Hospital site

• North lodge to Lambeth Hospital Site

• South lodge to Lambeth Hospital Site

• Reception buildings to Lambeth Hospital Site (north and south)

• 42 Renfrew Road – former Court Tavern PH

The Cottingham Close Council Estate to the South has been identified by the Council as being worthy of consideration as a potential post-war conservation area.

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132 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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Context Proposed Site 7: 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11

Views Strategic view:

• Townscape View 27(b) – Parliament Square to Palace of Westminster

Local views (Policy Q25):

• (c) (i) views N and NNE from Brockwell park to the City

• (c) (ii) view NNE from Norwood Park to the City

• (c) (iii) view N from Gipsy Hill to the City

• (d) (i) view SE and SSE from Westminster Bridge Road to the Lincoln Tower

• (d) (xiii) (a) view E from Victoria Tower Gardens and (b)

• SE from Members’ Terrace of Houses of Parliament to Lambeth Palace

• (d) (xiv) view ESE from Millbank to 8 Albert Embankment

Transport and access • PTAL 6a

• Elephant and Castle Rail and Tube and Kennington Tube approximate 10 minute walk

• Various buses on A3 and Kennington Lane.

• On the TfL Road Network (TLRN)

• A3 in close proximity, a Healthy Route and Cycle Superhighway 7

• Cycle hire docking stations at Cotton Gardens Estate and Hampton Street

• Located in a Controlled Parking Zone

Air Quality Focus Area No

Energy Located in a Heat Network Priority Area

Flood risk Wholly within the EA’s Flood Zone 3 and the Thames Tidal Breach Model shows the northern portion of the site to be at risk during a 2100 scenario only.

Small ponding has been identified in the modelling during a low-risk surface water event but is considered to be very low risk.

Access to open space and nature conservation

St Mary’s Park (LB Southwark) is within 200m of the site.

Within an area of open space deficiency for local/small/pocket, district, metropolitan and regional parks.

Within an area deficient in access to nature.

Trees No Tree Preservation Orders on or adjacent to the site.

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133 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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Context Proposed Site 7: 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11

Community safety Recorded crimes in Prince’s ward August 2020 – July 2021: 1,988.

Top three categories:

• Anti-social behaviour: 34.9 per cent

• Violence and sexual offences: 21.3 per cent

• Other theft: 7.8 per cent

Recorded crimes in Prince’s ward September 2018 – July 2021: 6,253.

Top three categories:

• Anti-social behaviour: 30.8 per cent

• Violence and sexual offences: 21.1 per cent

• Vehicle crime: 9.7 per cent

Prince’s ward has had one of the lowest rates of serious youth violence (SYV) in Lambeth since 2018.

Description of current site character

The builders’ merchant requires concrete paving for operations. This gives the site a hard, urban character with no urban greening. Also in the site boundary is the Christ the Redeemer building, a 1960s/1970s brick building of 4 storeys that is vacant.

Wooden Spoon House lies at the rear of the site, accessed from Dugard Way. The character of the building contrasts with the rest of the site as it appears more modern and has been tiled in blue and white.

The current uses on site do not provide any natural surveillance of the street and there is virtually no activation.

Neighbour context The flanks of no. 2 Kennington Lane, nos. 1-9 Hollyoak Road adjoin the eastern boundary of the site.

To the north stand Limelight House and Goddard House, which are four and five storey residential blocks fronting Dugard Way.

Part of the Jamyang Buddhist Centre, the former firestation on Renfrew Road (now residential) and the flank of number 34 Kennington Lane adjoin to the west.

19th Century terraced properties in residential use occupy numbers 5-13 Kennington Lane directly opposite the site. Fontenoy House, which stands within the Cottingham Close Estate, is a five storey LCC walk-up block.

Relevant planning history Timber Yard R/O 6-24 Kennington Lane 99/00028/FUL – Erection of storage/warehouse and sales buildings, together with associated external works, including the installation of new boundary wall and railings (revised proposal). Granted 14/04/1999.

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Vision: Proposed Site 7: 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11

The site has potential for a mix of uses to include replacement light industrial capacity and community facilities, along with new housing and affordable housing. Whilst close to the Elephant and Castle Opportunity Area, the site is not in a town centre.

Comprehensive development presents an opportunity to enhance the townscape and street-scene on a main road frontage close to the boundary with the neighbouring borough of Southwark. High quality design will enhance local character and heritage through appropriate materials and building form. The density of new development can be optimised in a way appropriate to this immediate context.

There are also opportunities to improve Kennington Lane for pedestrians and cyclists, by widening the pavement and for a signalised crossing to be provided on the Kennington Lane frontage.

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135 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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136 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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Site Allocation Policy Proposed Site 7: 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11

Land uses The site provides a signficant opportunity for comprehensive mixed-use redevelopment, which is likely to achieve optimum development capacity and the best place-shaping outcome. However, given the two separate land ownerships, the site may come forward in two phases, in which case each phase should contribute to and help deliver the overall vision for the site as a whole. Proposals for any part of the site should not compromise or restrict delivery of the overall vision or the ability of the other site to optimise its development capacity.

If the NHS facility at Wooden Spoon House is re-provided elsewhere as part of an agreed strategy for the relevant service, that community use would not need to be re-provided on this site and there is potential for other uses including residential to come forward (see Local Plan Policy S1(b)(iii)).

In that scenario, the site overall has potential to accommodate:

• At least 2,200 sqm GIA of light industrial floorspace to achieve no net loss of industrial capacity (based on 65 per cent of the area of the existing builders’ yard).

• Approximately 135 to 145 self-contained residential units. Proposals for non-self-contained housing will be considered against relevant London Plan and Local Plan policies.

• A replacement community use of equivalent or better functionality to the existing space within the Christ the Redeemer building.

Main town centre uses are not appropriate in this out of centre location.

Affordable housing The affordable housing threshold on 6–12 Kennington Lane is 35 per cent if there is no net loss of industrial capacity, or 50 per cent if there is, in accordance with London Plan policy. The affordable housing threshold on 5 Dugard Way is 50 per cent as it is in public sector ownership.

If the site comes forward for comprehensive development, and assuming no net loss of industrial capacity, the affordable housing threshold across the whole site would be 42 per cent, which is a blended threshold calculated pro-rata according to the proportions of the overall site area in private and public ownership, following the approach in the GLA Practice Note ‘Threshold Approach to Affordable Housing on Public Land’ (July 2018) or any subsequent updated guidance. If there is a net loss of industrial capacity, the affordable housing threshold across the whole site would be 50 per cent.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

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137 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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Site Allocation Policy Proposed Site 7: 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Heritage assets Development should not harm the significance (including setting) of heritage assets, in particular the former listed fire station on Renfrew Road.

Building heights and views; townscape

If developed comprehensively, part of the site is appropriate for a tall building of a general building height of 50m, in the location shown. The remainder of the site is appropriate for low-rise and mid-rise development, stepping up in height from the lowest around the perimeter of the site where neighbour constraints are most sensitive.

If the site is developed in two phases, the first phase should not limit optimisation of the second. Developed alone, neither 6–12 Kennington Lane nor 5 Dugard Way is likely to be able to accommodate a tall building as a result of each separate site’s smaller developable area and because a comprehensive approach will allow for greater capacity to accommodate the appropriate mix of uses, servicing and the necessary setting for a tall building.

Development should also address the following principles:

• Has a massing and form that integrate well with the established low-rise, largely residential neighbourhood and townscape context

• Built form and materials should be respectful of the adjacent heritage assets and local distinctiveness

• Include ground floor façade activation on Kennington Lane

• Not re-provide panel advertisements

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

No new public pedestrian routes or spaces should be provided between Kennington Lane and Dugard Way to maintain Renfew Road as the primary local pedestrian north-south as this will reinforce community safety by avoiding pedestrian dispersal, especially at night.

No vehicular access or servicing should be provided from Dugard Way, although residential access is required. Servicing on Kennington Lane is unacceptable.

Development should widen the footpath along the Kennington Lane frontage to improve pedestrian movement, accessibility and safety. This is particularly important with any tall building proposal to ensure adequate circulation space around the tallest part and to avoid an inappropriate canyon effect on Kennington Lane.

Depending on the location of any vehicular access points, an existing signalised pedestrian crossing may need to be relocated.

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138 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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Site Allocation Policy Proposed Site 7: 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

Good natural surveillance to both Kennington Lane and Dugard Way must be provided.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution. Particular regard should be paid to the relationship with sensitive residential neighbours on Newington Butts, Kennington Lane, Dugard Way and Renfrew Road.

Flood risk mitigation Development must comply with Local Plan Policy EN5.

A site-specific Flood Risk Assessment will be required as part of a planning application and flood risk should be verified by site-specific breach inundation flood levels, to determine more accurate flood depths at precise locations.

Ground floor levels and below in areas located as at risk during a 2100 Thames Tidal Breach Scenario will be restricted to Less Vulnerable use only and will require multiple access and egress points, in addition to an Evacuation Plan submitted as part of a site-specific Flood Risk Assessment.

More vulnerable uses will not be allowed below breach. Self-contained residential development and/or sleeping accommodation will not be permitted at basement levels in areas identified as at risk of flooding.

Sustainable Urban Drainage Systems will be required as per the requirements of Local Plan Policy EN6. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs are ideal for this location to achieve this and should be considered.

The approximate greenfield runoff rate is QBar=3.61l/s.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

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139 Draft Lambeth SADPD | Section 6: Proposed Kennington / Oval Site Allocation

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Site Allocation Policy Proposed Site 7: 6–12 Kennington Lane and Wooden Spoon House, 5 Dugard Way SE11

Waste management Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d).

Urban greening and trees Opportunities for increased tree planting must be maximised.

The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

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140 Draft Lambeth SADPD | Section 7: Proposed Loughborough Junction Site Allocations

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Section 7: Proposed Loughborough Junction Site Allocations

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141 Draft Lambeth SADPD | Section 7: Proposed Loughborough Junction Site Allocations

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Proposed Loughborough Junction Site Allocations

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142 Draft Lambeth SADPD | Section 7: Proposed Loughborough Junction Site Allocations

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Proposed Site 22: 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24

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143 Draft Lambeth SADPD | Section 7: Proposed Loughborough Junction Site Allocations

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Context Proposed Site 22: 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24

Site address and postcode 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24

Ward Current: Herne Hill

Proposed: Herne Hill & Loughborough Junction

Site area 0.2 ha

Land ownership Private

Existing land uses 960 sqm GIA light industrial floorspace

32 sqm GIA retail floorspace

Local Plan Place and Neighbourhood policy

PN10: Loughborough Junction

London Plan and Local Plan designations

Within the Brixton Creative Enterprise Zone

Not in a town centre

Neighbourhood Development Plan

None

Community Infrastructure Levy charging zones

• Lambeth CIL Zone C

• MCIL2 Band 2

Heritage assets No heritage assets on the site or immediately adjoining it.

Nearby:

• Loughborough Park Conservation Area

• Ruskin Park, (Grade II listed Registered Landscape)

• Green Man ‘Skills Zone’, 225 Coldharbour Lane (local list)

• Business Centre, 245 Coldharbour Lane (local list)

Views No strategic views.

Local views (Policy Q25):

• (c) (i) (c) Views N and NNE from Brockwell Park to the City

• (c) (ii) View NNE from Norwood Park to the City

Transport and access • PTAL rating 3 (bordering areas of PTAL 4 or 5)

• Loughborough Junction Station approximately 200m to the north on Coldharbour Lane

• Brixton underground station approximately 1.1km away

• Several bus routes running along Coldharbour Lane, one down Hinton Road.

• CPZ in place

• Coldharbour Lane, Herne Hill Road and Hinton Roads are London Distributor Roads

• Coldharbour Lane is a Healthy Route

Air Quality Focus Area No

Energy Located in a Heat Network Priority Area

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144 Draft Lambeth SADPD | Section 7: Proposed Loughborough Junction Site Allocations

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Context Proposed Site 22: 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24

Flood risk Located in Flood Zone 1.

Within the site boundary there appears to be a low risk of flooding from surface water. However deep surface water flows and ponding are present within the highway (Hinton Road) during a high (3.3 per cent AEP), medium (1.0 per cent AEP) and low (0.1 per cent AEP) event. The ponding is likely due to the underpass creating a low point along the highway that allows water to collect.

Access to open space and nature conservation

Wyck Gardens is about 200m from the site to the north-east, Loughborough Park open space is within 500m to the south-west, Milkwood Community Park is about 400m to the south and Ruskin Park is within 400m of the site to the east.

The site is within an area of open space deficiency for district and regional parks, and the eastern part of site is within an area of open space deficiency for metropolitan parks.

Trees No Tree Preservation Orders on or adjacent to the site.

Community safety Recorded crimes in Herne Hill ward August 2020 – July 2021: 2,296.

Top three categories:

• Anti-social behaviour: 32.9 per cent

• Violence and sexual offences: 20.6 per cent

• Other theft: 7.7 per cent

Recorded crimes in Herne Hill ward September 2018 – July 2021: 6,361.

Top three categories:

• Anti-social behaviour: 27.4 per cent

• Violence and sexual offences: 21.5 per cent

• Vehicle crime: 9.2 per cent

Herne Hill Ward has had one of the lowest rates of serious youth violence (SYV) since 2018 and had the lowest rate of all Lambeth wards in 2020. Coldharbour Ward to the immediate west of the site had one of the highest rates of SYV offences, and the highest number of firearm offences over the last three years.

Description of current site character

The site is predominately in industrial use and is split into two parts. The western part is accessed via Wellfit Street / Hinton Road and includes a scrap metal yard, a skip yard and a retail unit. The eastern part of the site is accessed via Hardess Street / Herne Hill Road and contains four small light industrial units, two of which are currently vacant. The buildings are low-medium rise and of no architectural merit.

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Context Proposed Site 22: 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24

Neighbour context The site is bounded to the north by a railway viaduct carrying elevated railway lines with occupied railway arches beneath. Hinton Road bounds to the west, to north (beyond the railway bridge) there are residential units and the former Green Man pub on the corner with Coldharbour Lane), and to the south on Hinton Road are terraced houses. Herne Hill Road bounds to the east of the site with former car garage / services building, an NHS GP surgery and residential units. The south of the site is bounded by three-storey residential properties which front Wanless Road, as well as a single -storey community hall, which is currently in use as a church.

The railway arches, owned and managed by The Arch Company, lie outside of the site boundary and are currently occupied by a range of uses including a cinema, boxing gym, artist studios and a car repair garage.

North, immediately beyond the railway viaduct, is the Higgs Yard, which has extant planning permission for mixed use redevelopment.

Further north still is the Loughborough Junction Local Centre and proposed Site Allocation 23 – Land at the corner of Coldharbour Lane and Herne Hill Road SE24.

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146 Draft Lambeth SADPD | Section 7: Proposed Loughborough Junction Site Allocations

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Context Proposed Site 22: 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24

Relevant planning history 1, 3–11 Wellfit Street, 7–9 Hinton Road and Units 1–4 Hardess Street19/04280/FUL – Demolition of existing retail and industrial buildings and erection of a car free, part 3, part 20, part 29-storey mixed-use podium building comprising 2,073 sqm of employment floorspace (Use Class B1 a) and c)) with ancillary sandwich bar/café (Use Classes A1/A3) and site care-takers accommodation, an industrial yard of 55 sqm and 170 dwellings with associated disabled car parking, cycle and bin stores, and hard and soft landscaping. Refused 21/07/2021.

1 Wellfit Street 11/01192/FUL – Erection of a single storey building to provide general industrial (Use Class B2). Granted 06/10/2011.

3–11 Wellfit Street 90/00027/PLANAP – In outline, redevelopment by the erection of a 3 storey Class B1 building comprising 7,144 sq. feet floorspace including loading bay and car parking accommodation, together with the creation of a new vehicular access. Granted 22/12/1989.

Unit 4, Hardess Street 16/00373/LDCE – Application for a certificate of lawfulness (existing) with respect to mixed use of Unit 4 for pizza preparation, cooking and delivery to customers (Use Class A5) and as a central catering kitchen for the storage, preparation and distribution of its products to other hot food takeaway units (Use Class B2). Granted 21/01/2016.

15/06650/LDCE – Application for a certificate of lawfulness (existing) with respect to use of Unit 4 as a hot food takeaway (Use Class A5). Refused 18/01/2016.

Adjoining site – Higgs Industrial Estate – north of railway line18/05425/FUL – Clearance of site and mixed-use redevelopment to provide a building ranging in height from 2 to 16 storeys with 134 residential units and 4,150 sqm of commercial/employment floorspace (including a minimum of 414 sqm of light industrial use) along with disabled parking, serving, cycle parking, public realm and amenity space. Granted 20/12/2020.

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Vision: Proposed Site 22: 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24

Redevelopment of this site presents an opportunity to provide new, purpose-built light industrial accommodation in an accessible location close to Loughborough Junction local centre and transport links and within the Brixton Creative Enterprise Zone. This will offer ‘maker-space’ for small and growing businesses, particularly in the creative and digital industries, in a location where many businesses of this type already exist. There is potential for this to be provided as part of a sustainable, mixed-use development with new housing, including affordable housing, to complement that on the adjacent Higgs site and contribute to Loughborough Junction as a residential neighbourhood.

A well-designed, locally distinctive scheme will enhance townscape and improve pedestrian access and the public realm around and through the site, with potential to connect to Loughborough Junction’s other characteristic yards and railway viaducts.

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Site Allocation Policy Proposed Site 22: 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24

Land uses The site has potential to accommodate:

• At least 1,400 sqm GIA light industrial workspace (based on no net loss of industrial capacity calculated at 65 per cent of the area of the current industrial use)

• Approximately 70-90 self-contained residential units.

Light industrial units should be designed flexibly to provide a range of unit sizes, with adequate servicing and access provision (such as goods lifts if above ground floor level).

Main town centre uses are not appropriate in this out of centre location.

Affordable housing The affordable housing threshold is 35 per cent if there is no net loss of industrial floorspace capacity, or 50 per cent if there is a net loss in this capacity, in accordance with London Plan policy.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Given the site’s location within the Brixton Creative Enterprise Zone, there is a particular opportunity to provide jobs and training opportunities for local people within the creative and digital sectors.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Heritage assets Development should preserve or enhance the significance (including setting) of all heritage assets with particular regard to the Loughborough Park Conservation Area.

Building heights and views; townscape

The site is appropriate for a tall building of a general building height of 47m, to provide a step-down from the approved scheme at Higgs Yard.

Lower buildings elsewhere on the site should respond to their immediate context, particularly adjacent to the rear gardens on Wanless Road.

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Site Allocation Policy Proposed Site 22: 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

A pedestrian and vehicular service route through the site should be provided linking Hinton Road to Herne Hill Road. This must be safe, legible and overlooked. Shared surface environments are strongly discouraged given the mix of residential and light industrial uses required.

Where possible the access arrangements to arches 257–261 Hardess Street should be improved. The existing forecourts serving arches 253-256 should be retained.

Existing business activity on Hardess generates significant vehicular activity and informal parking on the road. Consideration should be given to how the road will accommodate these vehicle movements, as well as the increased pedestrian / cycle and other servicing vehicle activity that would be generated by the development of this site.

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

Residential entrances should be placed in locations which are clearly visible from Hinton Road or Herne Hill Road and benefit from clear sightlines and good natural surveillance.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution. Particular regard should be paid to the relationship with sensitive residential neighbours on Wanless Road.

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Site Allocation Policy Proposed Site 22: 1 & 3–11 Wellfit Street, 7–9 Hinton Road & Units 1–4 Hardess Street SE24

Flood risk mitigation Development must comply with Local Plan Policy EN5.

Residential properties at ground level may need to be located outside the area at risk of surface water flooding or raised to limit ingress of water (e.g. raise finish flood levels or property thresholds to 300mm above flood depth elevation or situate residential properties above ground floor). A site-specific Flood Risk Assessment will be required and will need to acknowledge and address this risk of flooding, and demonstrate properties at ground floor level have a sufficient level of protection (i.e. 1 per cent AEP).

Sustainable Urban Drainage Systems will be required as per the requirements on the NPPF. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs are ideal for this location to achieve this and should be considered.

The approximate greenfield runoff rate is QBar=5.55l/s.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

Waste management Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d).

Urban greening and trees The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

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Proposed Site 23: Land at corner of Coldharbour Lane and Herne Hill Road SE24

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Context Proposed Site 23: Land at corner of Coldharbour Lane and Herne Hill Road SE24

Site address and postcode Land at corner of Coldharbour Lane and Herne Hill Road SE24

Ward Current: Herne Hill

Proposed: Herne Hill & Loughborough Junction

Site area 0.1 ha

Land ownership Site is in private ownership

Existing land uses Community use – place of worship (1,058 sqm GIA)

Local Plan Place and Neighbourhood policy

PN10: Loughborough Junction

London Plan and Local Plan designations

Within the wider Brixton Creative Enterprise Zone

The majority of the site is within Loughborough Junction local town centre. The rear of the site along Junction Yard is outside the local centre.

Neighbourhood Development Plan

None

Community Infrastructure Levy charging zones

• Lambeth CIL Zone C

• MCIL2 Band 2

Heritage assets No heritage assets within the site.

Near the site:

• Loughborough park CA

• Ruskin Park (registered landscape

• 225 Coldharbour Lane (local list

• 45 Coldharbour lane (local list)

Views No strategic views.

Local views (Policy Q25):

• (c) (i) (c) Views N and NNE from Brockwell Park to the City

• (c) (ii) View NNE from Norwood Park to the City

Transport and access • PTAL rating 4

• London Distributor Road - Coldharbour Lane

• Local Distributor Road - Herne Hill Road, Hinton Road

• Coldharbour Lane is a Healthy Route

• Loughborough Junction rail station is across the road from the site. The nearest London Underground station is Brixton, approximately 1.1km away.

Air Quality Focus Area No

Energy Located in a Heat Network Priority Area

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Context Proposed Site 23: Land at corner of Coldharbour Lane and Herne Hill Road SE24

Flood risk Located in Flood Zone 1.

Within the site boundary there appears to be a low risk of flooding from surface water. However, relatively deep ponding of surface water is present within the highway (Coldharbour Lane) during a high (3.3 per cent AEP), medium (1.0 per cent AEP) and low (0.1 per cent AEP) event. This ponding finished abruptly against the current building outline, which suggests there could be a high risk of surface water flooding.

Access to open space and nature conservation

Wyck Gardens is within 150m of the site to the north-west, Loughborough Park open space within 450m to the south-west and Ruskin Park is approximately 500m to the south-east.

The site is within an area of open space deficiency for district and regional parks.

Trees No Tree Preservation Orders on or adjacent to the site.

Community safety Recorded crimes in Herne Hill ward August 2020 – July 2021: 2,296.

Top three categories:

• Anti-social behaviour: 32.9 per cent

• Violence and sexual offences: 20.6 per cent

• Other theft: 7.7 per cent

Recorded crimes in Herne Hill ward September 2018 – July 2021: 6,361.

Top three categories:

• Anti-social behaviour: 27.4 per cent

• Violence and sexual offences: 21.5 per cent

• Vehicle crime: 9.2 per cent

Herne Hill Ward has had one of the lowest rates of serious youth violence (SYV) since 2018 and the lowest rate of all Lambeth wards in 2020. However, Coldharbour Ward to the immediate west of the site had one of the highest rates of SYV offences and the highest rate of firearm offences between 2018 – 2020.

Description of current site character

This corner site comprises a building 2-3 storeys in height that accommodates Sureways International Ministries – a place of worship. The post-war premises are of no architectural or townscape interest. The public footway around the site is inadequately narrow.

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Context Proposed Site 23: Land at corner of Coldharbour Lane and Herne Hill Road SE24

Neighbour context The site is within Loughborough Junction Local Centre and the buildings making up this centre are generally three to four storeys in height.

The site is surrounded by/in close proximity to three mainline railway lines interspersed by distinctive ‘yards’ that are mainly industrial in character. This includes Junction Yard to the rear of the site and nearby Higgs and Hardess Yards.

Within the wider Loughborough Junction area there are six Key Industrial Business Areas, providing an important source of the borough’s light industrial and creative employment space. Parts of Loughborough Junction are identified in the London Plan as Strategic Areas for Regeneration.

Immediately south of the site is the site formerly known as the Higgs Industrial Estate, or Higgs Yard, which has an extant planning permission for mixed use redevelopment to provide a building ranging in height from 2 to 16 storeys with 134 residential units and 4,150 sqm GIA of commercial/employment floorspace.

To the east of the site are industrial uses based in the arches of the railway viaduct.

Further south down Herne Hill Road, are two storey buildings, one of which is a medical centre. Beyond Wanless Road the area becomes residential in nature.

Relevant planning history Unit 1 Higgs Industrial Estate 2-12 Herne Hill Road01/02667/FUL – Change of use from warehouse general industrial (B2) to place of worship (D1). Refused 19/03/2002 – lack of adequate marketing evidence to support the loss of an employment-generating use. Appeal allowed 22/12/2002.

14/04835/FUL – Refurbishment of and extensions to existing two storey Sureway Church building to create a block up to five storeys in height, providing additional class D1 with ancillary B1 floorspace and five residential flats (use class C3). Refused 19/12/2014 – insufficient information has been submitted to demonstrate that the proposal would not have an unacceptable impact on pedestrian safety contrary to Saved UDP Policy 9.

Adjoining site – Higgs Industrial Estate18/05425/FUL – Clearance of site and mixed-use redevelopment to provide a building ranging in height from 2 to 16 storeys with 134 residential units and 4,150 sqm of commercial/employment floorspace (including a minimum of 414 sqm of light industrial use) along with disabled parking, serving, cycle parking, public realm and amenity space. Granted 20/12/2020.

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Vision: Proposed Site 23: Land at corner of Coldharbour Lane and Herne Hill Road SE24

The site can contribute to the implementation of Local Plan Policy PN10 for Loughborough Junction by delivering a sustainable, mixed-use development in this well-connected town centre location. This has potential to provide improved accommodation for the existing place of worship, or alternative town centre uses, presenting active frontages at ground floor within the town centre along Coldharbour Lane and Herne Hill Road. There is also potential for new housing, including affordable housing, on upper floors. The part of the site along Junction Yard, outside of the town centre and opposite the railway viaduct, is well suited to new light industrial workspace at ground floor level, adding to the stock and mix of space available to small businesses within the Brixton Creative Enterprise Zone.

This prominent corner site, in a town centre and with a high level of public transport accessibility, presents an opportunity for moderately increased density if accompanied by improved public realm and a wider footway; and if well designed to integrate well with, and complement the scale of, the approved redevelopment on Higgs Yard immediately to the south.

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Site Allocation Policy Proposed Site 23: Land at corner of Coldharbour Lane and Herne Hill Road SE24

Land uses The existing community use and/or alternative town centre uses must be replaced with equivalent or better functionality, to include active frontages at ground floor level.

The site has potential to accommodate:

• Replacement community use of equivalent or better functionality, providing an active frontage at ground floor level.

• Alternatively, flexible town centre uses within Class E, that provide active frontages at ground floor level.

• Approximately 25-30 new homes on upper floors, with potential for more depending on the mix and quantum of other community or town centre uses provided. The site is not suitable for residential units at ground floor.

• Light industrial uses along Junction Yard adjacent to the railway arches (outside the town centre boundary). Town centre uses are not appropriate in this part of the site as it is outside the town centre. Residential units are unlikely to be appropriate in this part of the site given the proximity of the railway viaduct.

Affordable housing The affordable housing threshold is 35 per cent.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure and assessment of anticipated impacts on existing social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Given the site’s location within the Brixton Creative Enterprise Zone and potential to provide some new light industrial space, there may be an opportunity to provide jobs and training for Lambeth residents within the creative and digital industries.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Building heights and views; townscape

The site is not appropriate for a tall building.

As a prominent corner site in a town centre, height around 30m is appropriate to make a positive contribution to place-making and townscape. This must be accompanied by improved public realm in the form of wider pavements; and should be designed to integrate well with, and complement the scale of, the approved redevelopment on Higgs Yard immediately to the south.

The building line to Herne Hill Road should align with the approved scheme at Higgs Yard.

The residential entrance should be on Herne Hill Road.

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Site Allocation Policy Proposed Site 23: Land at corner of Coldharbour Lane and Herne Hill Road SE24

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

Vehicular servicing should be from the existing rear access. There is potential for freight consolidation with other surrounding sites, including Higgs Yard.

Development should provide a new route along the railway viaduct to connect through to Higgs Yard and to facilitate the animation of the railway arches.

The building footprint should be set back from the back of pavement to allow for a widened along Coldharbour Lane.

Planning obligations may be sought to mitigate any impacts of development on local public realm and transport infrastructure, such as the Healthy Route Network on Coldharbour Lane, local cycling infrastructure and Loughborough Junction station.

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

Configuration of internal land uses should enable passive surveillance/overlooking onto Herne Hill Road and of the new pedestrian route to Higgs Yard where possible.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships The scheme should be designed to cause no unacceptable impacts on existing neighbours adjacent to the site, including overlooking, loss of daylight, overshadowing and noise pollution.

Particular regard should be paid to the relationship with adjoining railway viaduct.

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Site Allocation Policy Proposed Site 23: Land at corner of Coldharbour Lane and Herne Hill Road SE24

Flood risk mitigation Development must comply with Local Plan Policy EN5.

A site-specific Flood Risk Assessment will be required and will need to acknowledge and address the risk of surface water flooding, and demonstrate properties at ground floor level have a sufficient level of protection (i.e. 1 per cent AEP).

Sustainable Urban Drainage Systems will be required as per the requirements of Local Plan Policy EN6. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs are ideal for this location to achieve this and should be considered.

The approximate greenfield runoff rate is QBar=2.71l/s.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

Waste management Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d).

Urban greening and trees The Urban Greening Factor (UGF) target score is 0.4 for predominately residential schemes and 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

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Proposed Site 24: King’s College Hospital, Denmark Hill SE5

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Context Proposed Site 24: King’s College Hospital, Denmark Hill SE5

Site address and postcode King’s College Hospital, Denmark Hill SE5

Ward Current: Herne Hill

Proposed: Herne Hill & Loughborough Junction

Site area 7.5 ha

Land ownership King’s College Hospital NHS Foundation Trust and King’s College London

Existing land uses Hospital and associated ancillary uses

King’s Business Park (129 - 131 Coldharbour Lane) – business units used by the hospital for administration and storage

Safeguarded waste site used for transfer of clinical waste

Local Plan Place and Neighbourhood policy

PN10: Loughborough Junction

London Plan and Local Plan designations

King’s Business Park within the Coldharbour Lane Estate and Bengeworth Road Depot Key Industrial and Business Area (KIBA)

Neighbourhood Development Plan

None

Community Infrastructure Levy charging zones

• Lambeth CIL Zone C

• MCIL2 Band 2

Heritage assets Within the site:

• Hambledon Block, Bessemer Road (local list)

• Statute of Robert Bentley Todd, Bessemer Rd (local list)

• Railings and gate piers to Denmark Hill (local list)

• Guthrie Block, Denmark Hill (local list)

• Gate piers and railings to Venetian Road (non-designated heritage asset)

Nearby:

• Ruskin Park (registered landscape)

• Camberwell Grove CA (Southwark)

• Camberwell Green CA (Southwark)

• 93 Denmark Hill (Grade II) (Southwark)

• 95 Denmark Hill (Grade II) (Southwark)

• 97 Denmark Hill (Grade II) (Southwark)

• 99 Denmark Hill (Grade II) (Southwark)

• 103 Denmark Hill (Grade II) (Southwark)

• Maudsley Hospital admin block (Grade II) (Southwark)

• Railings to Maudsley Hospital (Grade II) (Southwark)

• 111 Denmark Hill (Grade II) (Southwark)

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Context Proposed Site 24: King’s College Hospital, Denmark Hill SE5

Views Strategic views:

• London Plan View 4 – London Panorama – Primrose Hill

Local views (Policy Q25):

• (c) (i) (c) views N and NE from Brockwell Park to the city

• (c) (ii) (c) views NNE form Norwood Park to the city

Transport and access • PTAL 6b

• Denmark Hill overground station and several bus routes in close proximity

• Denmark Hill and Coldharbour Lane - London Distributor Roads

• Coldharbour Lane - planned Healthy Route proposed to continue onto Daneville Road (LB Southwark)

• Quietway is Q8 runs north-south to the east of the hospital connecting to Burgess Park

• Within CPZ Herne Hill , adjoins CPZ Camberwell ‘A’

Air Quality Focus Area No

Energy Located in a Heat Network Priority Area

Flood risk Located in Flood Zone 1.

The EA model and Lambeth ICM model show surface water ponding across the site during the medium (1.0 per cent AEP) and low (0.1 per cent AEP) events. This is likely from runoff generated by the site as opposed to a flow route originating from elsewhere. This is considered low risk.

Access to open space and nature conservation

Ruskin Park lies immediately south of the site across the railway tracks.

Due to the barrier created by the railway line, part of the site is within an area of open space deficiency for local, small and pocket parks and the whole site is within an area of open space deficiency for district, metropolitan and regional parks.

Trees No Tree Preservation Orders on or adjacent to the site.

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Context Proposed Site 24: King’s College Hospital, Denmark Hill SE5

Community safety Recorded crimes in Herne Hill ward August 2020 – July 2021: 2,296.

Top three categories:

• Anti-social behaviour: 32.9 per cent

• Violence and sexual offences: 20.6 per cent

• Other theft: 7.7 per cent

Recorded crimes in Herne Hill ward September 2018 – July 2021: 6,361.

Top three categories:

• Anti-social behaviour: 27.4 per cent

• Violence and sexual offences: 21.5 per cent

• Vehicle crime: 9.2 per cent

Herne Hill Ward has had one of the lowest rates of serious youth violence (SYV) since 2018 and the lowest rate of all Lambeth wards in 2020. Coldharbour Ward to the immediate west of the site had one of the highest rates of SYV offences and the highest rate of firearm offences between 2018 – 2020.

Description of current site character

The buildings largely date from the 20th Century, ranging from earlier buildings of traditional architectural character to post-war blocks to more recent buildings. There is no unified campus style and the general appearance is that of piecemeal development of varying quality. The Ruskin Wing lies at the south-east corner of the site, is the tallest building on the campus (c55m) and includes a roof-top helicopter pad.

Neighbour context To the north are two storey residential properties along Venetian Road, Bavent Road and Caldecot Road.

Immediately to the east is Denmark Hill and the principal campus of the South London and Maudsley Hospital.

Rail lines run along the southern boundary (Brixton to Denmark Hill). Further south is Ruskin Park.

To the west lies the Coldharbour Lane Estate and Bengeworth Road Depot KIBA, part of which is within the hospital estate.

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Context Proposed Site 24: King’s College Hospital, Denmark Hill SE5

Relevant planning history Ruskin Wing13/03008/FUL – Erection of a helipad on top of the existing 10 storey Ruskin Wing building in the South-East corner of the hospital site, including the supporting structure, associated office space, access ramp, new lift core and first floor bridge link. Granted on 06/12/2013.

Critical Care Centre12/03858/FUL – The construction of a three-storey building on top of the existing two storey operating theatre block to provide a critical care unit, including additional plant, re-cladding of all existing external facades and the re-provision of a clinical waste store. Granted 13/05/2014.

Cheyne Wing08/04821/FUL – Redevelopment of a site to provide 3 storeys of accommodation in an extension adjoining existing hospital buildings for university research. Granted 11/03/2009.

08/04822/FUL – Partial removal of existing hospital wing in the south-west corner of the site and the erection of a four storey building to be used as a Haematology Centre. Granted 27/02/2009.

Denmark Wing13/06091/FUL – Extension of the Ultrasound Department at Second Floor Level, Denmark Wing, north-east corner. Including the removal of existing pitched roof currently over the X-Ray department and replacement with a new lightweight structure. Granted 05/03/2014.

Golden Jubilee Wing14/00993/FUL – Erection of a new four storey building located in the courtyard between Hambleden building and Golden Jubilee wing, to provide new MRI suite and associated clinical and ancillary areas on the first floor and supporting clinical offices on the ground and second floors. New facility to also provide direct links and access into existing Hospital Street at ground, first, and second floor level. Mechanical and electrical plant to be located at roof level. The building will be raised off the ground to maintain delivery routes through the courtyard and into Hambleden building. Granted 09/05/2014.

King’s Business Park07/02080/FUL – Unit 5 – Change of use of the warehouse (Use Class B8) to office and training facilities (Mixed Use Class B1/D1) including the internal installation of a mezzanine floor, alterations to the front and rear elevations to include installation of new windows and doors and three parking spaces at unit 5. Granted 09/08/2007.

09/00727/FUL – Unit 2 – Alterations to the front and rear elevation including the installation of new windows and doors to enable continued use for mixed B Class use. Granted 01/06/2009.

09/04167/FUL – Unit 3 – Change of use to Class B1 and external works to the front and rear elevation involving the installation of new windows and doors and the removal of the existing roller shutter and replacement roofing material. Granted 12/02/2010.

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Context Proposed Site 24: King’s College Hospital, Denmark Hill SE5

11/01917/FUL – Unit 6 – External works to the east, west and south elevations of Unit 6 King’s Business Park (formerly Coldharbour Lane Industrial Estate) associated with the continued use of the premises for Class B purposes. Proposed works include the installation of new windows and doors, new entrance canopy, the removal of the existing roller shutter, replacement roofing material, installation of a disabled ramp and handrail and the laying out of two disabled parking spaces. Granted 13/10/2011.

12/02892/FUL – Unit 4 – Change of Use to Office (Class B1) together with external alterations comprising of new doors, windows and the installation of a condenser units on the ground floor. Granted 24/09/2012.

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Vision: Proposed Site 24: King’s College Hospital, Denmark Hill SE5

The gradual reconfiguration of the hospital estate, including King’s Business Park, will enable the hospital trust to optimise clinical and associated ancillary activity at its main campus and contribute to delivery of the King’s Health Partners MedTech cluster. This presents an opportunity to introduce a more coherent approach to building massing and materials to improve the general character of the hospital campus and give it a stronger identity, particularly on the eastern and southern sides of the campus, where there are heritage sensitivities.

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Site Allocation Policy Proposed Site 24: King’s College Hospital, Denmark Hill SE5

Land uses Hospital and ancillary uses, medical services.

Change of use from business and storage use to hospital and associated uses within King’s Business Park (KIBA) will be supported to enable reconfiguration and optimisation of the hospital estate for clinical service provision and associated research and development activity.

Social infrastructure The requirements of Local Plan Policy S2 in relation to new social infrastructure should be addressed.

Employment and skills Development should maximise local employment opportunities and help address skills deficits in the local population. This is to be achieved through meeting the requirements of Local Plan Policy ED15, including agreement of an Employment and Skills Plan.

Digital connectivity Provision for digital connectivity infrastructure is required in accordance with Local Plan Policy T9 and London Plan Policy SI6.

Heritage assets Development should not harm the significance (including setting) of heritage assets. In particular:

• Ruskin Park (Grade II registered landscape)

• Camberwell Grove CA (Southwark)

• 93 Denmark Hill (Grade II) (Southwark)

• 95 Denmark Hill (Grade II) (Southwark)

• 97 Denmark Hill (Grade II) (Southwark)

• 99 Denmark Hill (Grade II) (Southwark)

• 103 Denmark Hill (Grade II) (Southwark)

• Maudsley Hospital admin block (Grade II) (Southwark)

• Railings to Maudsley Hospital (Grade II) (Southwark)

• 111 Denmark Hill (Grade II) (Southwark)

• Hambledon Block, Bessemer Road (local list)

• Statute of Robert Bentley Todd, Bessemer Road (local list)

• Railings and gate piers to Denmark Hill (local list)

• Guthrie Block, Denmark Hill (local list)

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173 Draft Lambeth SADPD | Section 7: Proposed Loughborough Junction Site Allocations

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Site Allocation Policy Proposed Site 24: King’s College Hospital, Denmark Hill SE5

Building heights and views; townscape

The site is not appropriate for tall building development (defined as 45m and above).

Given the view constraints and proximity to heritage assets and neighbouring residential properties, development heights should range from approximately 17m in the west adjacent to Northlands Street, approximately 9m in the north fronting Venetian Road and rising to approximately 40m AOD along its eastern and southern boundaries.

I. Development along Denmark Hill should present a unified height of approximately 40m – presenting a lower shoulder height of approximately 9m to Denmark Hill to step down towards the historic development across the road it in LB Southwark.

II. Development facing onto Grade II registered Ruskin Park should comprise several blocks with clear gaps between blocks.

Development should observe the following principles:

• Irrespective of the architectural styles used, development within the campus should adopt a unified architectural palette to the hospital estate of stock brick and pale Portland Stone-like materials to reinforce a distinct ‘campus’ character. The use of a Portland stone – like material is considered most appropriate for larger buildings to lessen their perceived bulk. Brick is considered most appropriate on the northern and western boundaries where development adjoins traditional terraced housing.

• To Denmark Hill frontage retain / reinstate a soft-landscaped belt along the retained railing frontage and establish a continuous building line set back 12m back from that railing line.

• The campus boundary to Ruskin Park is particularly sensitive. Elevations to the park should (i) share a unified palette (ii) be recessive in character, (ii) optimise outlook for patients and (consider urban greening / living walls) in order to enhance the relationship with the Park.

• Public entrances should be located in highly visible locations to aid legibility.

Transport, movement and public realm

Local Plan and London Plan parking standards will apply. All other Local Plan transport policies, plus Local Plan Policy Q1 on inclusive environments and Policy Q6 on urban design in the public realm should be addressed.

Where possible development should utilise the existing road network into and within the site.

Development should be serviced off-street and servicing impacts should be minimised through freight consolidation, and by considering sharing of servicing requirements with nearby sites.

Generous areas of public realm should be incorporated, with widened footways where appropriate. Permeability for cyclists and pedestrians through the site should be provided for, linking into the Healthy Route Network.

Shared surfaces will be considered where appropriate but protected pedestrian areas should be provided where vehicles are expected to be large and / or manoeuvring.

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174 Draft Lambeth SADPD | Section 7: Proposed Loughborough Junction Site Allocations

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Site Allocation Policy Proposed Site 24: King’s College Hospital, Denmark Hill SE5

Community safety The building design must consider the need for any enhanced protective security measures that could increase community safety and prevent crime in light of Policy Q3 Safety, Crime Prevention and Counter Terrorism. The applicant must consider the perceived threat and vulnerability of a development based on its location and whether the site includes any crowded places or Publicly Accessible Locations (PALs). The applicant must liaise with Metropolitan Police Service (MPS) Counter Terrorism Security Advisers (CTSAs) early in the planning process to determine whether enhanced security measures are required. Design principles set out in Secured by Design should also be addressed early in the design process in discussion with MPS Crime Prevention Design Advisers.

On-site residential amenity Residential accommodation should meet all relevant internal and external amenity standards and requirements as set out in London Plan and Local Plan policy and guidance.

Neighbour relationships Where possible, the scheme should improve the relationship with existing neighbours. The scheme should be designed to minimise impacts on the existing and future neighbours adjacent to the site in particular Northlands Street and Venetian Road, including overlooking, loss of daylight, overshadowing and noise pollution.

Flood risk mitigation Development must comply with Local Plan Policy EN5.

Site-specific Flood Risk Assessment (FRA) and Drainage Strategy that demonstrates conformity with national and local standards and policies for sustainable surface water management will be required to support any planning application.

The low-risk surface water ponding should be acknowledged and assessed within the site-specific FRA and should be resolved by a sustainable surface water management system such as Sustainable Drainage Systems (SuDS) that also provides multiple environmental benefits.

SuDS will be required as per the requirements of Local Plan Policy EN6. The discharge rate should be restricted as close as reasonably practicable to the greenfield rate. The use of blue or green roofs, and blue/green infrastructure in open spaces are ideal for this location to achieve this and should be considered.

The approximate greenfield runoff rate is QBar=25l/s.

Energy and sustainability Development should be exemplary in meeting the net zero carbon requirements of London Plan Policy SI2 as well as Local Plan Policy EN3 and Policy EN4. Every effort should be made to maximise the contribution towards achieving net zero emissions on site rather than through off-setting. London Plan policy and guidance on Whole Life-Cycle Carbon Assessments should be followed.

Waste management The existing safeguarded clinical waste transfer facility may be relocated on-site with potential for an increase in capacity of waste management operations.

Waste management and refuse and recycling storage are required to comply with Local Plan Policy EN7 and Policy Q12. Refuse and recycling storage and servicing must be accommodated on site.

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175 Draft Lambeth SADPD | Section 7: Proposed Loughborough Junction Site Allocations

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Site Allocation Policy Proposed Site 24: King’s College Hospital, Denmark Hill SE5

Air quality Air quality should be addressed in accordance with London Plan Policy SI1 and Lambeth’s Air Quality Action Plan.

Access to open space and nature conservation

Development should address existing open space deficiency and access to nature deficiency by meeting the requirements of Local Plan Policy EN1(d).

Urban greening and trees The Urban Greening Factor (UGF) target score is 0.3 for predominately commercial schemes as set out in London Plan policy and guidance.

Urban greening should be provided across the site but specifically focused along the southern boundary of the site to provide biodiversity benefits and improve the cohesiveness with Ruskin Park.

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Draft Lambeth SADPD | Annex 1

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176

Annex 1: Relationship with site allocations in Lambeth Local Plan 2021

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Draft Lambeth SADPD | Annex 1

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177

Annex 1: Relationship with site allocations in Lambeth Local Plan 2021

Site allocations in this document are shown in bold.

Place and Neighbourhood policy in Lambeth Local Plan 2021

Site number in Lambeth Local Plan 2021

Site number in SADPD

Site Status

PN1 – Waterloo and South Bank

Site 1 Site 1 Royal Street New allocation – will supersede existing

PN1 n/a Site 2 St Thomas’ Hospital New allocationPN1 Site 5 n/a Elizabeth House Existing allocation –

no changePN1 Site 6 n/a Shell Centre Existing allocation –

no changePN1 n/a Site 8 Stamford Street New allocationPN1 Site 9 Site 9 Gabriel’s / Princes

WharvesNew allocation – will supersede existing

PN2 – Vauxhall Site 10 n/a 8 Albert Embankment Existing allocation – no change

PN2 Site 11 n/a Keybridge House Existing allocation – no change

PN2 Site 12 n/a Wandsworth Road / Parry Street / Bondway

Existing allocation – no change

PN2 Site 13 n/a Vauxhall Island Site Existing allocation – no change

PN3 – Brixton Site 4 n/a New Park Road Existing allocation – no change

PN3 Site 14 n/a Somerleyton Road Existing allocation – no change

PN3 Site 15 n/a Pope’s Road Existing allocation – no change

PN3 Site 16 n/a Brixton Central Existing allocation – no change

PN3 n/a Site 17 330–336 Brixton Road

New allocation

PN3 n/a Site 20 Tesco Acre Lane New allocationPN3 n/a Site 21 Effra Road New allocationPN4 – Streatham n/a Site 3 Leigham Court Road New allocationPN7 – West Norwood / Tulse Hill

Site 18 Site 18 286–362 Norwood Road

New allocation – will supersede existing

PN7 n/a Site 19 Knolly’s Yard New allocationPN8 – Kennington / Oval

n/a Site 7 Kennington Lane New allocation

PN10 – Loughborough Junction

n/a Site 22 Hardess Yard New allocation

PN10 n/a Site 23 Coldharbour Lane New allocationPN10 n/a Site 24 King’s College

HospitalNew allocation

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Draft Lambeth SADPD | Annex 1

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178

Existing site allocations in the Lambeth Local Plan will remain in force unless and until they are superseded by new site allocations once the SADPD is adopted. Where an existing site allocation remains unchanged it keeps its existing number in this SADPD.

Some former site allocations (Sites 2, 3, 7, 8 and 17) have been deleted and no longer appear in the current version of the Lambeth Local Plan adopted in September 2021. These numbers have been re-used in this SADPD for new site allocations on different sites. For the avoidance of doubt, if a number has been re-used it does not indicate that a former site allocation has been reinstated.

London Borough of Lambeth

PO Box 734

Winchester

SO23 5DG

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1

Appendix 2 Lambeth Site Allocations DPD - Consultation and Engagement Plan

Introduction This consultation and engagement plan sets out the methods that will be used to publicise

and consult on the Draft Site Allocations Development Plan Document (Draft SADPD).

This consultation is an opportunity for stakeholders to comment on the emerging draft site

allocation policies and associated evidence and sustainability appraisal, in accordance with

the Town and Country Planning (Local Planning)(England) Regulations 2012 and Lambeth’s

Statement of Community Involvement 2020.

Stakeholders The key stakeholders for the consultation are:

• Those who live, work and carry out business in Lambeth

• Tenants and leaseholders

• Residents’ associations

• Community and voluntary groups

• Elected politicians

• Neighbourhood planning groups (existing and emerging)

• Business Improvement Districts (BIDs) and business networks

• Developers and landowners (and their representatives)

• Registered providers of affordable housing

• Infrastructure providers (such as transport, health service)

• Statutory consultees such as the Mayor of London, other London boroughs, Historic

England, Environment Agency, Natural England

Consultation methods

Primary method

The primary method for seeking stakeholders’ views at Regulation 18 consultation will be

Commonplace, a digital consultation platform used by the Council. This is designed to be

easy to access on smartphones and tablets.

The Commonplace platform for the Draft SADPD will present an overview of the sites in map

form, allowing stakeholders to select the site(s) they are interested in rather than reading

through lengthy documents. Details of each site will be provided individually, including an

aerial photograph and its boundary. Stakeholders will be able to read the vision for the site

along with maps showing the context and proposed approach, plus the draft policy wording.

There will be links to relevant sections of the supporting evidence and to the sustainability

appraisal for that site.

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There will be a concise explanation of the background to the Draft SADPD and the process

that will be followed. It will set out what people are being asked to comment on in this

round of consultation, how the results of the consultation will be considered and reported

and the next steps in the process for preparing the Draft SADPD.

The introductory material for the consultation will be written as far as possible in plain

English, avoiding technical jargon wherever possible. However, it should be noted that it is

necessary in the draft policies and supporting evidence to use some technical language (in

relation to flood risk levels or categorisation of heritage assets, for example) in order to

convey the correct meaning in a statutory planning context.

Consultation questions will invite responses on the content of the Draft SADPD and on the

proposed approach to each site. If someone does not wish to respond using Commonplace,

they can send their comments in writing by email or by post. All responses received will be

considered equally, irrespective of the medium used.

A link to the Commonplace site will also be provided via a consultation page on the Council’s website

Supplementary methods The following supplementary methods will be used to gather the views and comments of

stakeholders:

Supplementary method

A briefing for ward councillors (for current wards within which proposed sites are located) before the start of the consultation, providing them with the information they need to help people understand what the consultation is about and support them in responding.

Meetings during the consultation with designated neighbourhood planning forums, local groups/partnerships and Business Improvement Districts covering the areas in which the proposed sites are located. This is likely to be organised for groups of sites in different parts of the borough (e.g. Waterloo, Brixton, Loughborough Junction, West Norwood)

A presentation to the Lambeth Housing Partnership

A presentation to the Lambeth Staying Healthy Partnership Board

A presentation to the Lambeth Safer Spaces working group

A workshop with representatives of disability groups in the borough

A workshop with young people

Meetings before or during consultation with the GLA, relevant neighbouring boroughs and Historic England

Meetings before or during consultation with key land-owners affected by the proposed site allocations

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Publicity and dissemination

A range of methods will be used to raise awareness about the consultation and encourage

people to respond, with the objective of raising awareness among the full range of

stakeholders, including those who are characterised as groups with whom the council has

struggled to engage (see section on equalities below).

In addition to more traditional publicity methods, ward councillors, community groups and

networks will be encouraged to raise awareness about the consultation through word of

mouth and ‘cascading’ amongst their constituents and members.

The following publicity and dissemination methods will be used:

• An email to all those on the Council’s planning policy consultation database (some 2,050 contacts which includes the statutory, specific and general consultation bodies required by the Regulations). This will include contacts for landowners and their representatives, for the proposed sites.

• The Council’s social media channels including Facebook and Twitter

• Promotion through Love Lambeth and Lambeth Talk

• Press release

• A request to neighbourhood planning groups, Business Improvement Districts and other local community forums to disseminate to their members.

• Promotion through existing bulletins and networks (such as Lambeth Forum Network, public health networks, cycling and walking networks, , Lambeth 500, Lambeth Housing Partnership, BIDs, creative and digital industries advisory groups, Healthy Streets Forum, LGBT+ networks, disability networks, Climate Change and Biodiversity newsletters the youth and play e-bulletin, the Lambeth Schools Partnership newsletter, Lambeth Youth Council, Integrate’s email bulletin to community and voluntary groups, an email to those who have signed up to be notified about current consultations, and the Community Round Up email).

• Use of internal communications channels to inform and engage staff

The Commonplace digital engagement platform allows real-time analysis of respondents by

demographic characteristics (subject to this information being provided by respondents).

We will review the demographic information at key points in the consultation and look to

increase take up by under-represented groups.

Equalities To assess potential equalities impacts of the consultation approach, the key stakeholder

groups for the consultation have been assessed against three levels of engagement; ‘active’;

‘aware and potentially active’; and ‘groups with whom the council has struggled to engage’. The

assessment is set out in the stakeholder mapping table below. This mapping exercise has

helped to identify the consultation and publicity methods listed in the right-hand column of

the table.

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Site Allocation DPD consultation - stakeholder mapping Audience characteristic

Audience attributes Stakeholder Consultation/publicity method

Active • Likely to be identified consultees (general, specific or other)

• Established interest in planning and regeneration issues

• Likely to be members of community organisations

• Have a sense of belonging to their neighbourhood

• Follow and/or are aware of various council initiatives

• Politicians

• Neighbourhood planning groups

• Interest groups e.g. Lambeth 500

• Developers and landowners

• Registered providers of affordable housing

• Infrastructure and service providers

• Statutory consultees

• Notification by email and through bulletins/networks

• Briefing for ward councillors

• Individual meetings with neighbourhood planning groups and BIDs

• Presentation to Lambeth Housing Partnership

• Meetings with statutory consultees and service providers

Aware and potentially active

• Likely to read newsletters, council website, tweets etc

• Easy to inform but not so easy to involve – maybe don’t have the time or we don’t provide the right opportunity

• Might engage if we are in the right place or offer the right forum

• Limited knowledge of planning and regeneration issues

• Might rally around a single issue

• Tenants’ and Residents’ Associations

• Community and voluntary groups

• Special interest groups or networks

• Businesses and business networks

• Notification by email and through bulletins/networks

• Promotion in council publications

• Promotion by ward councillors

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Audience characteristic

Audience attributes Stakeholder Consultation/publicity method

Groups with whom the council has struggled to engage

• Don’t really read the literature that the council sends

• Think that what the council says doesn’t really affect them

• Limited knowledge of planning and regeneration issues

• May not speak English as a first language

• May not feel they have much of a stake in their local community (e.g. young people, just moved into the area)

• Residents not involved in groups or networks

• Those in more disadvantaged socio-economic groups

• Some older people

• Some young people

• Some disabled people

• Some black and minority ethnic groups

• Promotion by ward councillors

• Use of social media channels

• Publicity through the Youth Council and bulletins targeting young people

• Meeting with groups representing people with disabilities and young people

• All consultation material to include detail of support available in libraries

An Equalities Impact Assessment (EIA) of this consultation and engagement plan has been

carried out alongside the EIA of the Draft SADPD itself.

Those responding through Commonplace will be asked to complete optional questions

about their demographic characteristics. This will enable analysis of the consultation

findings by stakeholder group and protected characteristic, where relevant.

Reporting and feedback

Analysis of the results will inform the revisions to the Draft SADPD, which will then be the

subject of a second round of consultation (known as ‘Regulation 19’ pre-submission

publication) prior to submission for examination. The results of the first round of

consultation will be presented in a consultation report, which will be made available to

inform a decision about whether to proceed with pre-submission publication. It will be

published on-line. The material presented in the second round of consultation will include

a summary setting out what people said during round one and how this was used to inform

the content of round two (alongside other factors such as evidence and

national/regional/local policy requirements).

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EQUALITY ANALYSIS PROFORMA

Author: Vanessa Rodgers

Extension:

Directorate Neighbourhoods and Growth

Department/Division Growth, Planning and Employment / Planning, Transport and Development

Draft Site Allocations Development Plan Document

Q1.What is changing?

What is the most significant or key change taking place? Can you indicate the type of change in your response (e.g.

policy/decision/strategy/ service/procedural/ geographic/procurement etc.) so it is clear what is being equalities assessed?

Why is this change happening? What do you aim to achieve? Can you clearly indicate what decision-makers are being asked

to take a decision on?

The Site Allocations Development Plan Document (SADPD) will be part of the statutory development

plan for Lambeth, alongside the Lambeth Local Plan 2021, the London Plan 2021 and South Bank and

Waterloo Neighbourhood Plan 2019. It will therefore be part of the suite of policy documents that

help deliver sustainable growth and investment in Lambeth, along with the revised CIL Charging

Schedule and emerging supplementary planning documents. It will support implementation of

wider Council strategies including the Borough Plan, Economic Resilience Strategy, Transport

Strategy and emerging Climate Action Plan.

The SADPD will add site-specific policies to those already in the Lambeth Local Plan 2021. The

principal objective of the SADPD is to unlock investment on these sites through the mechanism of

site-specific planning policy.

The Draft SADPD at Appendix 1 of this report includes emerging site allocation policies for fourteen

sites, distributed across the borough. All have potential to deliver housing alongside commercial

uses, apart from two that relate to hospital campuses. Of these fourteen sites, three have existing

allocations in the Lambeth Local Plan 2021 (Royal Street (Site 1), Gabriel’s/Princes Wharf (Site 9) and

Norwood Road (Site 18)). These existing allocations will be superseded on adoption of the SADPD.

The other existing allocations within the Local Plan 2021 will be unaffected by the SADPD and will

remain as they are. The numbering of the proposed allocations in the Draft SADPD is designed to

work alongside the numbering of the existing allocations in the Local Plan 2021.

Sites are included in the Draft SADPD for one or more of the following reasons:

• to set clear, site-specific parameters for the type and scale of development expected on a

site, including the associated public benefits it should deliver;

• to address site-specific circumstances that may require a more tailored approach to that

set out in borough-wide policies;

• to articulate the vision and potential that can be achieved through land assembly and/or

a comprehensive approach to developing adjacent sites, particularly where these are in

different ownerships;

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• to persuade landowners to consider the potential for optimising the development

capacity of their land and help deliver key place-making objectives, where they might

otherwise be uncertain about what would be supported;

• to signal some additional sites as appropriate for tall buildings, outside the locations

already identified in the Local Plan;

• to enable key strategic infrastructure to come forward in a timely way.

It is not necessary, or recommended, to have a site-specific allocation for every potential

development site in the borough. Many larger sites can and do come forward successfully without

such a policy, with sustainable development achieved through application of the borough-wide and

neighbourhood-level policies in the development plan as a whole. There is also no need in Lambeth

to allocate sites to demonstrate the borough’s ability to meet its London Plan housing target, as this

was achieved through the recent examination of the revised Lambeth Local Plan. However, the new

site allocation policies will help to accelerate delivery of housing in the borough, maintain the

necessary pipeline of new housing and thereby ensure housing delivery targets continue to be

achieved. They will also enable the timely renewal and optimisation of social infrastructure and

commercial floorspace.

The guiding approach in developing the draft site allocation policies is design-led optimisation of

development capacity, as required by London Plan policy. This has involved analysis of the optimum

mass and height that can be achieved, having regard to all planning constraints relevant to that site,

including impacts on neighbouring uses, views, townscape and heritage assets. Key spatial

objectives have been factored in and identified, such as opportunities to contribute to strategic

place-making – for example the Central Activities Zone and potential for an SC1 life-

sciences/innovation district, South Bank creative and cultural quarter, town centres, or the growing

cluster of flexible workspace in West Norwood/Tulse Hill. Other objectives addressed include

improvement in movement and permeability, healthy routes and active travel, townscape, public

realm, community safety and urban greening. Consideration of viability has informed indicative

development quantums and the expectations around delivery of affordable housing and affordable

workspace (where relevant).

Existing development plan standards for housing quality, amenity space, parking, urban greening

and zero carbon will apply to these sites, but the ambition for exemplary approaches in meeting

these standards has been signalled in the Draft SADPD. Where possible, additional site-specific

guidance has been included on matters such as flood risk mitigation and air quality. The aspiration

for key public benefits is also signalled, such as employment and skills contributions tailored to

particular growth sectors.

Q1.b Who will be involved in approving this decision?

Cabinet Q2.What do we know about the people who will be impacted by this change?

What does your information tell you about the people who will affected by this change? Are protected groups impacted? What information do you hold on the protected characteristics of the people affected by the change? (Age, disability, gender reassignment, pregnancy and maternity, race/ethnicity, religion or belief, gender, sexual orientation, health, socio-economic, language) Are there any gaps or missing information?

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The proposed site allocations affect the following wards: Bishop’s, Prince’s, Herne Hill, Ferndale,

Brixton Hill, Coldharbour, Streatham Wells, Knight’s Hill and Streatham Wells. Wards such as

Ferndale, Coldharbour, Prince’s and Bishop’s are also some of the most deprived parts of Lambeth,

which is one of the most deprived areas of the country according to the IMD therefore efforts will

need to capture groups from a variety of backgrounds and those with protected characteristics in

these areas in particular.

Demographic data on these wards can be found in the State of the Ward report. Key stakeholders for the Draft SA DPD are:

• Those who live, work and carry out business in Lambeth, particularly those on or

surrounding the 14 proposed sites

• Tenants and leaseholders of the proposed 14 sites and surrounding areas. Three of these

sites have existing residents: Royal Street (Site 1), Norwood Road (Site 18) and Effra Road

(Site 21).

Royal Street • 77 self-contained market units in Canterbury House

• 52 self-contained market units in Stangate House

Norwood Road • 80 residential units o Snowe House (12 affordable units) o Thanet House (12 units, 9 affordable) o 8-12 Lansdowne Hill (12 affordable units) o Residential above Knowles of Norwood (19 units) o Residential above shops between 328-362 Norwood

Road (24 units) o 2 Lansdowne Hill (1 unit)

Effra Road • 35 self-contained residential units (affordable sheltered

housing) at Fitch Court – to be re-provided as part of

nearby Somerleyton Road development

• 2 self-contained residential units (market owned and let

by the Church)

• Residents’ associations affected by redevelopment of any of the proposed 14 sites

• Community and voluntary groups affected by redevelopment of any of the proposed 14

sites, for example members of the congregation at Sureway Church and Brixton Unitarian

Church (Proposed Sites 23 and 21), We are 336 (Proposed Site 17), groups using Mosaic

Centre (Proposed Site 21)

Brixton Road Site 17 WeAre336 own, occupy and lease this building. They are a

registered charity that supports disabled people and their

organisations by providing an accessible disability hub at the

building at 336 Brixton Road. People can access advice and

support from the wide range of disability organisations based

here. This provision is being enhanced by the development of

a One-Stop Information Shop which is the first project of

Lambeth Centre for Independent Living currently being

established by organisations with the support of WeAre336.

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Effra Road Site 21 Brixton Unitarian Church owns and occupies 400sqm at this

site. It is a liberal Christian multi-faith church welcoming of

those of all faiths and none.

Mosaic Clubhouse also occupies 700sqm space at this site

(leased from the Council). It supports people who are living

with a mental health condition in Lambeth. The Clubhouse

offers it members and visitors a wide range of opportunities,

access to education and employment, crisis support and

information and signposting to other local organisations.

Corner Coldharbour Lane

and Herne Hill Site 23

Sureways International Ministries occupies 1058sqm as place of worship. Sunday service is attended by approximately 250 people. It is noted that there are no planning conditions limiting the times of operation, or the capacity of the church. It is a Christian church that welcomes all backgrounds.

• Landowners of proposed 14 sites and landowners surrounding the proposed sites – we do

not currently know much about their protected characteristics (if any).

• Neighbourhood planning groups (existing) - There are neighbourhood planning forums for

South Bank and Waterloo; Norwood Planning Assembly; and Kennington, Oval and Vauxhall.

Who they represent was considered at the time they were designated as forums. A forum

must have a minimum of 21 members drawn from different places in the area and different

sections of the community. More information about these designated Forums in Lambeth

can be found on the council’s neighbourhood planning webpages.

• Businesses on proposed 14 sites – we do not currently know much about their protected

characteristics (if any).

Q2b. How will they be impacted by the change? Would you assess the impact as positive, adverse, neutral? Do you have any uncertainty about the impact of your proposal?

Is there a likelihood that some people will more impacted than others? Can you describe the ways in which they will be

affected? How might this change affect our ‘general duty’

Information on existing landuses/ownerships are provided in the draft site allocation policies. It is

important to note that where sites are in existing lawful community use (eg church use, community

hall) then the starting point in adopted Local Plan policy is for these landuses to be re-provided as

part of any proposed redevelopment of the site. Where community and voluntary groups use office

space, proposed site allocation policies seek to re-provide the office floorspace. Where sites have

existing housing on site, at least the same quantum of housing units, including affordable housing of

equivalent tenure, will need to be re-provided on site (in accordance with local plan policy H3).

Where sites have existing market housing only (eg Proposed Site 1), redevelopment of the site will

require at least 35% of the replacement housing to be affordable housing for the fast track route.

Detailed analysis of potential equalities impacts of the proposed site allocation policies has been

undertaken as part of the statutory Sustainability Appraisal for the Draft SADPD (explained further

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below). This Equalities Analysis Proforma summarises the findings of this initial analysis with regards

to sustainability objective 5 – Equalities.

The Council is required to prepare a Sustainability Appraisal (SustA) for all development plan

documents (section 39 Planning and Compulsory Purchase Act 2004). A SustA has been prepared on

the Draft Site Allocations DPD. A SustA is a systematic and iterative process undertaken during the

preparation phases of a plan or strategy. The process tests the overall plan, including each emerging

policy against the sustainability objectives that have been agreed for this purpose. The purpose of

the SustA is to inform the decision-making process, by highlighting the potential implications of

pursuing a particular strategy or policy response.

Accordingly, the Draft SA DPD is likely to be further refined after the initial round of public

consultation in response to the SustA process of maximising benefits and/or minimising adverse

effects as well as in response to any forthcoming consultation comments.

It is important to note that once adopted the SA DPD will form part of the development plan for

Lambeth alongside the London Plan 2021, Lambeth Local Plan 2021 and any made neighbourhood

plans (ie currently South Bank and Waterloo Neighbourhood Plan). All three of these development

plans have undergone sustainability appraisal / integrated impact assessment and all three plans

have been found sound through their respective independent examinations. The London Plan had a

supporting Integrated Impact Assessment (IIA) comprising Strategic Environment Assessment,

Sustainability Appraisal, EqIA, Health Impact Assessment and Community Safety Impact Assessment.

A Supplementary Equalities Impact Assessment Information was also prepared. The Local Plan 2021

was subject to Sustainability Appraisal including equalities impact assessment. The Inspector for the

Draft Revised Lambeth Local Plan found the SustA to be ‘wide ranging and thorough’ (para 40 of the

Inspectors Report). All London Plan and Local Plan policies will apply to the proposed site allocations

and as demonstrated above all those policies within those plans have been subject to equalities

impact assessment.

The SustA on the Draft SA DPD assesses, among other things, how protected equality groups are

likely to be impacted by the policies contained in the Draft Plan. The Draft SA DPD has been assessed

against 19 sustainability objectives (the same objectives as the Local Plan was appraised against).

While there is a specific objective on equality and diversity (SustA Objective 5), a number of other

objectives seek to improve outcomes for various protected equality groups. For example, there are

SustA objectives on health and well-being, access and services, addressing crime and fear of crime,

housing, liveability and social cohesion, transport, education and skills, local economy and tackling

worklessness – all of which apply to, and seek to benefit, different protected equality groups.

SA Objective 5 states: To ensure equitable outcomes for all communities, particularly those most

liable to experience discrimination, poverty, and social exclusion. To achieve this objective, plan

policies should promote a culture of equity, fairness and respect for people and the environment;

improve environmental conditions for Lambeth’s deprived areas and deprived communities; reduce

poverty and social exclusion; remove or minimise disadvantage suffered by persons who experience

disadvantage or discrimination; promote social cohesion within and between population groups;

enable social integration between minority groups and wider society; address housing, cultural,

Page 317

social and employment needs of those with protected characteristics; and promote adequate

accessibility, in particular for older and disabled people.

The table below sets out a summary of the Sustainability Appraisal outcomes on the potential effects

on protected equality groups for the proposed 14 site allocations.

Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

Royal Street

SE1

• No fewer than 129 self-

contained residential units

• Office floor-space including 30%

that is lab-enabled, contributing

to the SCI innovation/life-

sciences district

• Affordable workspace, including

skills and education hub and

business incubator space

• Ground floor cultural uses,

community space and business

units for shops and food and

drink outlets

Positive effects on equality groups:

• Current residential units on site provides no affordable

housing. Requiring replacement of at least existing quantum

of self-contained units will result in 35% affordable housing

delivered on site, 70% of which will be low-cost social rent

and 30% intermediate housing. This will help address unmet

need in Lambeth and Waterloo in particular for affordable

housing.

• Provision of affordable workspace – 10 per cent of the net

uplift in office floorspace must be provided as affordable

workspace at a 50 per cent reduction from market values for

a period of 15 years. This will have a positive effect on those

in Lambeth wishing to start and grow small businesses.

• Employment and Skills Plan to secure jobs and training

opportunities for Lambeth residents within the health and life

sciences, low carbon, creative, digital and artificial intelligence

sectors

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Public realm improvements including widened footways on

Royal Street; protected pedestrian areas where vehicles are

expected to be larger and/or manoeuvring – will result in

improved accessibility for those with mobility difficulties,

including some people with disabilities, older people and

families with very young children

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• Located in an area with exceptional public transport

accessibility, including step-free access to trains and tube at

Waterloo Station

• Improved opportunities for active travel, through better

pedestrian and cycle routes and cycle infrastructure and car

free development – this will have significant health and well-

being impacts particularly for people with long-term health

conditions, older people younger people, and well as

improving air quality and helping to mitigate climate change

• Close proximity to a variety shops, services and facilities and employment areas

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

• Promotes social cohesion within and between population

groups

• Enables social integration between minority groups and wider

society

• Extensive new green infrastructure will improve health and

well-being for those living, working and visiting in the area

• New housing will have significantly higher energy

performance than existing, which will reduce carbon

emissions and fuel bills. This will be a particular benefit to

those on lower incomes occupying the new affordable

housing.

• Net zero carbon across the whole development will have

wider societal impacts on climate change mitigation, which

will help address the unequal impacts of climate change on

lower income groups, many of whom have protected

characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality

benefits to protected groups for example through mitigating

flood damage to homes and businesses.

Potential uncertain effects on equality groups:

• Potential impact on nearby small and independent businesses

in Lower Marsh

Recommendation (already incorporated into Draft SADPD):

• Site allocation policy should require contribution to

maintenance of existing open spaces as development of the

site will result in significant increased usage of existing parks

and open spaces.

• Whilst Local Plan policy S2 will apply, SA policy could specify

community uses are to be designed in such a way to facilitate

shared/flexible use of space to appeal to a wider range of

people (eg young, older, maternity/paternity, disabled,

health groups), and accommodate facilities that could be

used for longer hours and weekdays as well as weekends

St Thomas’

Hospital SE1

• Hospital and ancillary uses

• Re-provision of Florence

Nightingale Museum on-site or

at an appropriate alternative

location

Positive effects on equality groups:

• Enhanced clinical care facilities

• Contribute to growing SC1 LifeSciences and MedTech health

cluster

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Protected pedestrian areas where vehicles are expected to be

larger and/or manoeuvring will result in improved

accessibility for those with mobility difficulties, including

some people with disabilities, older people and families with

very young children

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• Located in an area with exceptional public transport

accessibility, including step-free access to trains and tube at

Waterloo Station.

• Car free development will have significant health and well-

being impacts particularly for people with long-term health

conditions, older people younger people, and well as

improving air quality and helping to mitigate climate change

Stamford

Street SE1

• Flexible community/office

floorspace at ground floor

• Approximately 30-40 self-

contained residential units

Positive effects on equality groups:

• Additional residential units of which at least the required

threshold will be affordable housing, 70% of which will be

low-cost social rent and 30% intermediate housing This will

help address unmet need in Lambeth and Waterloo in

particular for affordable housing.

• Potential for additional community space that could

complement adjoining Coin Street Neighbourhood Centre

• Potential for new office floorspace of which 10% must be

provided as affordable workspace at a 50 per cent reduction

from market values for a period of 15 years. This will have a

positive effect on those in Lambeth wishing to start and grow

small businesses.

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Located in an area with exceptional public transport

accessibility, including step-free access to trains and tube at

Waterloo Station.

• Improved opportunities for active travel, through better

pedestrian and cycle routes and cycle infrastructure – this will

have significant health and well-being impacts particularly for

people with long-term health conditions, older people

younger people, and well as improving air quality and helping

to mitigate climate change

• Public realm improvements including new, high quality public

space on Samford Street with potential for a kiosk on the

corner with Cornwall Road – will result in improved

accessibility for those with mobility difficulties, including

some people with disabilities, older people and families with

very young children

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

• Car free development in air quality focus area will have

significant health and well-being impacts particularly for

people with long-term health conditions, older people

younger people, and well as improving air quality and helping

to mitigate climate change

• Close proximity to a variety shops, services and facilities and employment areas

• Promotes social cohesion within and between population

groups

• Enables social integration between minority groups and wider

society

• Extensive new green infrastructure will improve health and

well-being for those living, working and visiting in the area

• New housing will have significantly higher energy

performance than existing, which will reduce carbon

emissions and fuel bills. This will be a particular benefit to

those on lower incomes occupying the new affordable

housing.

• Net zero carbon across the whole development will have

wider societal impacts on climate change mitigation, which

will help address the unequal impacts of climate change on

lower income groups, many of who have protected

characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality

benefits to protected groups for example through mitigating

flood damage to homes and businesses.

Recommendation:

• Site allocation policy should require contribution to

maintenance of existing open spaces if development of the

site will result in significant increased usage of existing parks

and open spaces.

Gabriel’s

Wharf and

Princes

Wharf SE1

• Mixed-use redevelopment

• Active frontage and cultural uses

ground floor including range of

small and medium sized units for

independent businesses and

cultural uses

• Housing

• Potential for offices and/or

workspace

Positive effects on equality groups:

• Provision of new additional housing on site which if C3 units

will include at least the threshold level of affordable housing

of which 70% will be low-cost social rent and 30%

intermediate housing. If the housing is not conventional self-

contained housing but another form of housing such as

Shared Living, then an affordable housing contribution will

still be required, to be spent elsewhere in Lambeth. This will

help address unmet need in Lambeth and on-site provision

would help address need in Waterloo in particular for

affordable housing.

• Site allocation policy makes clear there is particular

opportunity on this site to provide job and training

opportunities for local people in the creative and cultural

industries and hospitality sector.

• Provision of small and medium sized unit for independent

businesses and culture uses could potentially be of benefit to

some protected groups who wish to set and grow businesses

in the borough

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• New vibrant and attractive pedestrian routes to be created on

eastern and western boundaries

• Located in an area with exceptional public transport

accessibility, including step-free access to trains and tube at

Waterloo Station

• Improved opportunities for active travel, through better

pedestrian and cycle routes and cycle infrastructure and car

free development – this will have significant health and well-

being impacts particularly for people with long-term health

conditions, older people younger people, and well as

improving air quality and helping to mitigate climate change

• Close proximity to a variety shops, services and facilities and employment areas

• Promotes social cohesion within and between population

groups

• Enables social integration between minority groups and wider

society

• Extensive new green infrastructure will improve health and

well-being for those living, working and visiting in the area

• New housing will have significantly higher energy

performance than existing, which will reduce carbon

emissions and fuel bills. This will be a particular benefit to

those on lower incomes occupying the new affordable

housing.

• Net zero carbon across the whole development will have

wider societal impacts on climate change mitigation, which

will help address the unequal impacts of climate change on

lower income groups, many of whom have protected

characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality

benefits to protected groups for example through mitigating

flood damage to homes and businesses.

Recommendation:

• Site allocation policy should require contribution to

maintenance of nearby existing open spaces as development

of the site will result in significant increased usage of existing

parks and open spaces.

• The local planning authority may wish to consider stipulating

provision of self-contained residential units at this site.

330-336

Brixton

Road SW9

• Mixed use development

• Reprovision of the existing quantum of office floorspace.

• Reprovision of the existing community use to equivalent or better functionality, unless the

Positive effects on equalities

• Provision of new additional self-contained residential housing

to the site. The affordable housing threshold will range from

35% to 50% as the site is in a mix of public and private

ownership. Of the affordable housing offer 70% will be low-

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

existing clinical facility is re-provided elsewhere as part of an agreed strategy for provision of that service

• At least 1,289sqm light industrial workspace (to achieve no net loss of existing industrial floorspace capacity).

• Approximately 70 to 75 self-

contained residential units, with

the quantum depending on the

relative proportions of other

uses on the site.

cost social rent and 30% intermediate housing. This will help

address unmet need in Lambeth in particular for affordable

housing.

• Site allocation policy encourages the particular opportunity to

provide jobs and skills training for local people in the creative

industries.

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Provision light industrial workspace and therefore

employment and business opportunity for local people –

particularly in the creative industries, within the Brixton

Creative Enterprise Zone

• Reprovision of community use on site (unless the existing

clinical facility is re-provided elsewhere). The existing clinical

facility provides mental health services and substance misuse

services for people who are addicted to drugs and alcohol.

332-334 Brixton Road is owned by South London and

Maudsley NHS Foundation Trust.

• Reprovision of existing quantum of office floorspace provides

opportunity for improved accommodation for existing users

WeAre336 (a registered charity that supports disabled people

and their organisation by providing an accessible disability

hub). This has potential to significantly improve the

accessibility of the building, and indeed of all buildings on the

site

• Improved opportunities for active travel, through better

pedestrian infrastructure and car free development – this will

have significant health and well-being impacts particularly for

people with long-term health conditions, older people

younger people, and well as improving air quality and helping

to mitigate climate change

• Public realm improvements for pedestrian safety – will result

in improved accessibility for those with mobility difficulties,

including some people with disabilities, older people and

families with very young children

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• Close proximity to a variety shops, services and facilities in Brixton town centre

• Promotes social cohesion within and between population

groups

• Enables social integration between minority groups and wider

society

• Extensive new green infrastructure will improve health and

well-being for those living, working and visiting in the area

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

• New housing will have significantly higher energy

performance than existing, which will reduce carbon

emissions and fuel bills. This will be a particular benefit to

those on lower incomes occupying the new affordable

housing.

• Net zero carbon across the whole development will have

wider societal impacts on climate change mitigation, which

will help address the unequal impacts of climate change on

lower income groups, many of whom have protected

characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality

benefits to protected groups for example through mitigating

flood damage to homes and businesses.

Potential uncertain effects on equality groups:

• Risk the redevelopment is not undertaken in a

comprehensive way, or that piecemeal development does

not address the wider vision for the site, therefore the full

benefits of the site allocation are not achieved.

Tesco Acre

Lane SW2

• Replacement supermarket with

self-contained residential units

Positive effects on equalities:

• Provision of new additional self-contained residential housing

to the site. The affordable housing threshold will be 35% of

which 70% will be low-cost social rent and 30% intermediate

housing. This will help address unmet need in Lambeth in

particular for affordable housing.

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Located in an area with exceptional public transport

accessibility, including step-free access to the tube at Brixton

Underground Station.

• Close proximity to a variety shops, services and facilities in Brixton town centre

• Significantly improved pedestrian environment, including wider footway along Acre Lane and urban greening; and improved cycle infrastructure. This will increase opportunities for active travel, which will have health and well-being benefits for groups with protected characteristics, as well as helping to improve accessibility for those with mobilities difficulties (such as older people, people with disabilities, families with very young children).

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• promotes social cohesion within and between population

groups

• enables social integration between minority groups and wider

society

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

• Extensive new green infrastructure will improve health and

well-being for those living, working and visiting in the area

• New housing will have significantly higher energy

performance than existing, which will reduce carbon

emissions and fuel bills. This will be a particular benefit to

those on lower incomes occupying the new affordable

housing.

• Net zero carbon across the whole development will have

wider societal impacts on climate change mitigation, which

will help address the unequal impacts of climate change on

lower income groups, many of whom have protected

characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality

benefits to protected groups for example through mitigating

flood damage to homes and businesses.

Potential uncertain effects on equality groups:

• Risk that the reprovided store does not fully optimise the

potential to improve pedestrian accessibility and active travel.

51-65 Effra

Road

• Comprehensive mixed-use

redevelopment

• Replacement community space

of equivalent or better

functionality to that already on

site

• New light industrial workspace

appropriate to Brixton Creative

Enterprise Zone

• Approximately 200 to 240 self-

contained residential units

Positive effects on equalities:

• Provision of essentially new additional self-contained

residential housing to the site. The affordable housing

threshold will range from 35% to 50% as the site is in a mix of

public and private ownership. Of the affordable housing offer

70% will be low-cost social rent and 30% intermediate

housing. This will help address unmet need in Lambeth in

particular for affordable housing.

• Community uses are to be re-provided so the church and

daycentre currently on-site will have opportunity to remain

on the site

• Site allocation policy encourages the particular opportunity to

provide jobs and skills training for local people in the creative

industries

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Provision light industrial workspace and therefore

employment and business opportunity for local people

• Located in an area with exceptional public transport

accessibility, including step-free access to the tube at Brixton

Underground Station.

• Public realm improvements including using Rush Common

land to provide an enhanced walking route that is fully

publicly accessible and making clear a pedestrian priority

design will be expected where vehicles cross pavements along

Effra Road will result in improved accessibility for those with

mobility difficulties, including some people with disabilities,

older people and families with very young children

• Consideration of community safety early in the design process

of the development will have positive effects on several

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• Car free development in air quality focus area will have

significant health and well-being impacts particularly for

people with long-term health conditions, older people

younger people, and well as improving air quality and helping

to mitigate climate change

• Close proximity to a variety shops, services and facilities in Brixton town centre

• promotes social cohesion within and between population

groups

• enables social integration between minority groups and wider

society

• Extensive new green infrastructure will improve health and

well-being for those living, working and visiting in the area

• New housing will have significantly higher energy

performance than existing, which will reduce carbon

emissions and fuel bills. This will be a particular benefit to

those on lower incomes occupying the new affordable

housing.

• Net zero carbon across the whole development will have

wider societal impacts on climate change mitigation, which

will help address the unequal impacts of climate change on

lower income groups, many of whom have protected

characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality

benefits to protected groups for example through mitigating

flood damage to homes and businesses.

Potential uncertain effects on equality groups:

• Risk the redevelopment is not undertaken in a comprehensive

way, or that piecemeal development does not address the

wider vision for the site, therefore the full benefits of the site

allocation are not achieved

Recommendation (already incorporated into Draft SADPD):

• Whilst Local Plan policy S2 will apply, SA policy could specify

community uses are to be designed in such a way to facilitate

shared/flexible use of space to appeal to a wider range of

people (eg young, older, maternity/paternity, disabled,

health groups), and accommodate facilities that could be

used for longer hours and weekdays as well as weekends

• The EIA Panel recommended that officers add wording to the

draft allocation policy for this site to ensure affordability and

transitional arrangements for the M clubhouse are

appropriately considered. Officers agreed to do this, and

relevant wording has been added to the draft allocation

policy.

Leigham

Court Road

Car Park

SW16

• Mixed-use development

• Approximately 30 – 35 self-

contained residential units

Positive effects on equality groups:

• Provision of new additional self-contained residential housing

to the site. The affordable housing threshold will be 50% as

the site is in public ownership. Of the affordable housing

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

• Active frontage ground floor

commercial floorspace within

Class E

offer 70% will be low-cost social rent and 30% intermediate

housing. This will help address unmet need in Lambeth in

particular for affordable housing.

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• Located in an area with exceptional public transport

accessibility, including step-free access to Streatham Hill Rail

Station

• Close proximity to a variety shops, services and facilities in

Streatham town centre

• New, high quality space for small businesses

• Accessible business space that will improve accessibility to

shops and small businesses within this part of Streatham town

centre.

• Extensive new green infrastructure will improve health and well-being for those living, working and visiting in the area

• New housing will have significantly higher energy performance, which will reduce carbon emissions and fuel bills. This will be a particular benefit to those on lower incomes occupying the new affordable housing.

• Net zero carbon across the whole development will have wider societal impacts on climate change mitigation, which will help address the unequal impacts of climate change on lower income groups, many of whom have protected characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality benefits to protected groups for example through mitigating flood damage to homes and businesses.

• Car free development and loss of carpark in air quality focus area will have significant health and well-being impacts particularly for people with long-term health conditions, older people younger people, and well as improving air quality and helping to mitigate climate change

Site 18 286-

362

Norwood

Road SE27

• Comprehensive mixed-use

redevelopment

• Approximately 390 – 470 self-

contained residential units

(gross)

• Approximately 5,000 to

7,000sqm of

commercial/community

floorspace, including new

workspace

Positive effects on equality groups:

• Provision of additional self-contained residential housing to

the site (approx. 310 – 390 net additional units). The

affordable housing threshold will range from 35% to 50% as

the site is in a mix of public and private ownership. Of the

affordable housing offer 70% will be low-cost social rent and

30% intermediate housing. This will help address unmet need

in Lambeth in particular for affordable housing.

• Reprovision of existing affordable housing on site will be

required.

• Community uses are to be re-provided so the church currently

on-site will have opportunity to remain on the site

• New, high quality space for small businesses

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

• Accessible business space that will improve accessibility to shops and small businesses within this part of Streatham town centre.

• Site allocation policy encourages particular opportunity to

provide jobs and training opportunities for local people within

the creative and digital industries or other town centre

sectors such as retail, hospitality and leisure.

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Improved permeability (vehicular, pedestrian, cycle) through

the site and public realm improvements will result in

improved accessibility for those with mobility difficulties,

including some people with disabilities, older people and

families with very young children

• Improved opportunities for active travel, through better

pedestrian and cycle routes and cycle infrastructure and car

free development and public realm improvements – this will

have significant health and well-being impacts, and well as

improving air quality and helping to mitigate climate change

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• Located in an area with very good public transport

accessibility including step-free access at West Norwood Rail

Station

• Close proximity to a range of shops, services and facilities in

West Norwood town centre

• Extensive new green infrastructure will improve health and

well-being for those living, working and visiting in the area

• New housing will have significantly higher energy

performance than existing, which will reduce carbon

emissions and fuel bills. This will be a particular benefit to

those on lower incomes occupying the new affordable

housing.

• Net zero carbon across the whole development will have

wider societal impacts on climate change mitigation, which

will help address the unequal impacts of climate change on

lower income groups, many of whom have protected

characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality

benefits to protected groups for example through mitigating

flood damage to homes and businesses.

Potential uncertain effects on equality groups:

• Risk the redevelopment is not undertaken in a

comprehensive way, or that piecemeal development does

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

not address the wider vision for the site, therefore the full

benefits of the site allocation are not achieved

Recommendation (already incorporated into Draft SADPD):

Whilst Local Plan policy S2 will apply, SA policy could specify

community uses are to be designed in such a way to facilitate

shared/flexible use of space to appeal to a wider range of people

(eg young, older, maternity/paternity, disabled, health groups),

and accommodate facilities that could be used for longer hours

and weekdays as well as weekends

Knolly’s

Yard SW16

• Industrial intensification through

provision of at least 1500sqm

high quality light industrial

workspace – particularly creative

and digital and/or low carbon

sectors

• Approximately 400 – 430 self-

contained residential units

Positive effects on equality groups:

• Retaining the site for industrial uses provides local people

employment opportunities / land for business development

• Provision of additional self-contained residential housing to

the site. The affordable housing threshold will be 50% as the

site is in public ownership. Of the affordable housing offer

70% will be low-cost social rent and 30% intermediate

housing. This will help address unmet need in Lambeth in

particular for affordable housing.

• Site allocation policy encourages particular opportunity to

provide jobs and training for local people within the creative

and digital industries or/or low carbon sector.

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Close proximity to variety of shops, services and facilities at

West Norwood/Tulse Hill town centre – with significant

potential for improved connectively to the town centre for

those using the site and those in neighbouring streets who

will be able to use the new route.

• Public transport accessibility is mixed across the site – West

Norwood Rail Station has step-free access and is about 900m

walking distance away – as above, there is potential for this

distance to be significantly reduced

• Improved opportunities for active travel, through better

pedestrian and cycle routes and cycle infrastructure, including

fully accessible footbridge that connects to Leigham Vale –

this will have significant health and well-being impacts, result

in improved accessibility to services, public transport, jobs

and shops as well as improving air quality and helping to

mitigate climate change

• Public realm improvements on Cameron Place and fully

accessible footbridge that connects to Leigham Vale – will

result in improved accessibility for those with mobility

difficulties, including some people with disabilities, older

people and families with very young children

• Car free development will have significant health and well-

being impacts particularly for people with long-term health

conditions, older people younger people, and well as

improving air quality and helping to mitigate climate change

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• Extensive new green infrastructure will improve health and

well-being for those living, working and visiting in the area

• New housing will have significantly higher energy

performance than existing, which will reduce carbon

emissions and fuel bills. This will be a particular benefit to

those on lower incomes occupying the new affordable

housing.

• Net zero carbon across the whole development will have

wider societal impacts on climate change mitigation, which

will help address the unequal impacts of climate change on

lower income groups, many of whom have protected

characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality

benefits to protected groups for example through mitigating

flood damage to homes and businesses.

Uncertain effects on equality groups:

• Significant new infrastructure to improve vehicular and

pedestrian access to the site is required – any new pedestrian

access (footbridge) will need to enable step-free access for

those with mobility issues

Recommendation (already incorporated into Draft SADPD):

• The site allocation should specifically state that the fully

accessible footbridge should be fully accessible for

pedestrians, cyclists and those with mobility issues.

6 – 12

Kennington

Lane and

Wooden

Spoon

House SE11

• Comprehensive mixed-use

redevelopment

• At least 2200sqm light industrial

floorspace

• Approximately 135 – 145 self-

contained residential units

• Replacement community use of

equivalent or better

functionality to existing space

Positive effects on equality groups:

• Provision of additional self-contained residential housing to the site. The affordable housing threshold is 35% on 6-12 Kennington Lane, which is in private ownership, and 50% on 5 Dugard Way, which is in public sector ownership (or 42% across the whole site). This will help address unmet need in Lambeth in particular for affordable housing.

• Community uses are to be re-provided

• Provision light industrial workspace and therefore

employment and business opportunity for local people

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Located in an area with exceptional public transport

accessibility, including step-free access to the tube at

Elephant and Castle Underground Station but only

southbound on the northern line.

• Close proximity to a variety shops, services and facilities in

neighbouring Elephant and Castle town centre

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

• Widening footpath along the Kennington Lane frontage to

improve pedestrian movement, accessibility and safety – this

will result in improved accessibility for those with mobility

difficulties, including some people with disabilities, older

people and families with very young children

• Car free development will have significant health and well-

being impacts particularly for people with long-term health

conditions, older people younger people, and well as

improving air quality and helping to mitigate climate change

• Maintaining Renfew Road as the primary local pedestrian

north-south route. This will reinforce community safety by

avoiding pedestrian dispersal, especially at night. This has

potential to benefit many protected groups including women,

younger and older persons, LGBTQ+, faith and race groups.

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• Promotes social cohesion within and between population

groups

• Enables social integration between minority groups and wider

society

• Extensive new green infrastructure will improve health and well-being for those living, working and visiting in the area

• New housing will have significantly higher energy performance than existing, which will reduce carbon emissions and fuel bills. This will be a particular benefit to those on lower incomes occupying the new affordable housing.

• Net zero carbon across the whole development will have wider societal impacts on climate change mitigation, which will help address the unequal impacts of climate change on lower income groups, many of whom have protected characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality benefits to protected groups for example through mitigating flood damage to homes and businesses.

Potential uncertain effects on equality groups:

• Risk the redevelopment is not undertaken in a

comprehensive way, or that piecemeal development does

not address the wider vision for the site, therefore the full

benefits of the site allocation are not achieved

Recommendation (already incorporated into Draft SADPD):

Whilst Local Plan policy S2 will apply, SA policy could specify

community uses are to be designed in such a way to facilitate

shared/flexible use of space to appeal to a wider range of people

(eg young, older, maternity/paternity, disabled, health groups),

and accommodate facilities that could be used for longer hours

and weekdays as well as weekends

1&3 Wellfit

Street, 7-9

Hinton

Road, Units

• Approximately 70-90 self-

contained residential units

• At least 1400sqm light industrial

workspace

Positive effects on equality groups:

• Provision of new additional self-contained residential housing

to the site. The affordable housing threshold is 35% if there is

no net loss of industrial floorspace capacity, but 50% if there

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

1-4 Hardess

Street SE24

is a net loss in this capacity. This will help address unmet need

in Lambeth in particular for affordable housing.

• Reprovision of light industrial workspace and therefore

employment and business opportunity for local people,

particularly in the creative sectors within the Brixton Creative

Enterprise Zone

• Site allocation policy encourages the particular opportunity to provide jobs and skills training opportunities for local people in the creative and digital sectors

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Located in an area with generally good public transport

accessibility

• Close proximity to a variety shops, services and facilities in

Loughborough Junction local centre and Brixton town centre a

short distance away as well as near to King’s College Hospital

– improved pedestrian movement through the area which will

have positive benefits for those with mobility difficulties,

including some people with disabilities, older people and

families with very young children

• Improved opportunities for active travel, through better

pedestrian and cycle routes and cycle infrastructure and car

free development – this will have significant health and well-

being impacts particularly for people with long-term health

conditions, older people younger people, and well as

improving air quality and helping to mitigate climate change

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• promotes social cohesion within and between population

groups

• enables social integration between minority groups and wider

society

• Extensive new green infrastructure will improve health and well-being for those living, working and visiting in the area

• New housing will have significantly higher energy performance than existing, which will reduce carbon emissions and fuel bills. This will be a particular benefit to those on lower incomes occupying the new affordable housing.

• Net zero carbon across the whole development will have wider societal impacts on climate change mitigation, which will help address the unequal impacts of climate change on lower income groups, many of whom have protected characteristics around race, age and disability for example.

• Flood risk mitigation on the site will provide indirect equality benefits to protected groups for example through mitigating flood damage to homes and businesses.

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

Land at

corner of

Coldharbour

Lane and

Herne Hill

Road SE24

• Replacement community use of

equivalent or better

functionality

• Alternatively flexible town

centres uses with Class with

ground floor active frontage

• Approximately 25 – 30 self-

contained residential units

• Light industrial uses along

Junction Yard

• Provision of new additional self-contained residential housing

to the site. The affordable housing threshold is 35%.

• Reprovision of community use so the existing church can

remain on site

• Reprovision of light industrial workspace and therefore

employment and business opportunity for local people,

particularly in the creative sectors within the Brixton Creative

Enterprise Zone

• Site allocation policy encourages the particular opportunity to

provide jobs and skills training opportunities for local people

in the creative and digital sectors

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Located in an area with generally good public transport accessibility

• Close proximity to a variety shops, services and facilities in

Loughborough Junction local centre and Brixton town centre

a short distance away as well as near to King’s College

Hospital

• Promotes social cohesion within and between population

groups

• Enables social integration between minority groups and wider

society

• Public realm improvements including widened footway on

Coldharbour Lane – will result in improved accessibility for

those with mobility difficulties, including some people with

disabilities, older people and families with very young children

• Car free development will have significant health and well-

being impacts particularly for people with long-term health

conditions, older people younger people, and well as

improving air quality and helping to mitigate climate change

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

• Extensive new green infrastructure will improve health and

well-being for those living, working and visiting in the area

• New housing will have significantly higher energy

performance than existing, which will reduce carbon

emissions and fuel bills. This will be a particular benefit to

those on lower incomes occupying the new affordable

housing.

• Net zero carbon across the whole development will have

wider societal impacts on climate change mitigation, which

will help address the unequal impacts of climate change on

lower income groups, many of whom have protected

characteristics around race, age and disability for example.

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Site Proposed land uses Sustainability Appraisal – Equalities Objective (5) analysis

• Flood risk mitigation on the site will provide indirect equality

benefits to protected groups for example through mitigating

flood damage to homes and businesses.

Recommendation:

Whilst Local Plan policy S2 will apply, SA policy could specify

community uses are to be designed in such a way to facilitate

shared/flexible use of space to appeal to a wider range of people

(eg young, older, maternity/paternity, disabled, health groups),

and accommodate facilities that could be used for longer hours

and weekdays as well as weekends

King’s

College

Hospital

• Reconfiguration and

optimisation of hospital estate

for clinical service provision and

associated research and

development activity

Positive effects on equality groups:

• Expanded health services and associated research and

development activity for the health sector

• Promoting employment and training opportunities for local

people will generate local employment opportunities and

reduce the need to travel. Focusing activities mainly on those

most marginalised from the workforce, including those that

lack the skills required by employers, will help to reduce

deprivation and inequalities and improve social inclusion.

• Public realm improvements including widened footways and;

protected pedestrian areas where vehicles are expected to be

larger and/or manoeuvring – will result in improved

accessibility for those with mobility difficulties, including

some people with disabilities, older people and families with

very young children

• Improved opportunities for active travel, through better

pedestrian and cycle routes and cycle infrastructure and car

free development – this will have significant health and well-

being impacts particularly for people with long-term health

conditions, older people younger people, and well as

improving air quality and helping to mitigate climate change

• Consideration of community safety early in the design process

of the development will have positive effects on several

protected equality groups, for example, older people, younger

people, those of certain faiths, LGBTQ+, race groups,

disabilities.

Overall, it is considered the Draft SA DPD will likely result in generally positive impacts on different

protected groups in Lambeth. Many of the positive impacts relate to housing, including affordable

housing, affordable workspace, employment and skills, reprovision of community facilities and

access to a variety of services and facilities, improved public realm, improved community safety,

improved opportunities for active travel, urban greening, flood risk mitigation, climate change

mitigation and adaptation, and improvement to air quality.

Recommendations arising from the EqIA that have now been incorporated into the Draft SA DPD

include:

1. where community uses are proposed, that it is stipulated that such spaces are designed to

be flexible to enable a range of groups to use the premises at various times of the day and

week; and

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2. contributions to maintenance of nearby open spaces for larger sites in Waterloo given likely

significant increase in useage

3. Knollys Yard site allocation policy should specify that the fully accessible footbridge should

be fully accessible for pedestrians, cyclists and those with mobility issues.

4. In response to a recommendation from the EIA Panel the wording of the draft policy for

SA21 has been updated to ensure appropriate consideration of affordability and transitional

arrangement for the Mosaic Clubhouse.

The EqIA has identified some potential uncertain effects on equality groups. For sites that are in

multiple land ownership there is a risk the redevelopment is not undertaken in a comprehensive

way, or that piecemeal development does not address the wider vision for the site, and therefore

the full benefits of the site allocation are not achieved. This may affect sites 332-336 Brixton Road,

51-65 Effra Road, 6-12 Kennington Lane, 286-362 Norwood Road. Other uncertainties identified are

site specific:

• Tesco Acre Lane - Risk that the reprovided store does not fully optimise the potential to improve

pedestrian accessibility and active travel.

• Royal street - Potential impact of the development on nearby small and independent businesses

in Lower Marsh

The provision of safe and secure walking and cycling routes should have positive impacts on those

who are more likely to suffer harassment in the streets, such as LGBTQ+ and BAME groups and also

those with mental health issues. However, the whole journey experience needs to be accessible,

from leaving the house to arriving at the desired destination. All journeys, particularly those made by

public transport, involve an element of walking. People with disabilities, and powered mobility

scooters and wheelchairs users all use (or should be able to use) footpaths as part of their journeys

in a safe and inclusive manner. It is noted that the IDP identifies funding gaps for some transport

projects, for example Healthy Route Network, Low Traffic Neighbourhoods, Loughborough Junction

Public Realm which suggests it is uncertain when such projects can be delivered. Until they are,

adverse impacts for some protected groups will continue.

It is noted that some proposed Site Allocations are close to public transport (rail and/or tube

stations) that do not have step-free access. The site allocation is not going to worsen the problem of

lack of step-free access, but the indirect consequence is that those using the site will experience that

lack of step-free access. Mitigation to address this is that all the new development proposed under

the Draft SA DPD (as well as from other developments) will bring with it Community Infrastructure

Levy (CIL) payments that can contribute towards providing step-free access in accordance with the

approach identified in the Infrastructure Delivery Plan.

Q3a. How do you plan to promote and deliver any positive impacts of the proposal? How might the principles of fairness, equality of opportunity and positive relationships be further promoted as a consequence of this proposal? How do you propose to measure your positive outcomes and the benefits outlined to find out if these have been achieved?

Page 335

Provided Cabinet agrees, the Draft SA DPD will be promoted in the first instance through Regulation

18 public consultation for a period of six weeks starting January 2022.

The full Consultation and Engagement Plan (C&E Plan) for the Draft SA DPD is attached. The primary

method for seeking stakeholders’ views will be Commonplace, a digital consultation platform used

by the Council. This is designed to be easy to access on smartphones and tablets and has successfully

been used in a number of recent Council consultations. The consultation material will be written as

far as possible in plain English, avoiding technical jargon wherever possible. The C&E Plan sets out

the consultation methods to be used including how it is proposed to engage with those groups with

community engagement challenges, for example those more disadvantaged socio-economic groups,

some older people, some younger people, some disabled people and some people for whom English

is not their first language. For these groups the C&E Plan sets out the measures to get a range of

people to respond within the resources available. For groups with community engagement

challenges the Plan proposes to use social media channels, have publicity through the Young

Lambeth Coop and Youth Council, word of mouth from ward councillors, meeting with groups

representing people with disabilities and availability of support offered in libraries. There will also

be meetings with community groups in different parts of the borough.

A feature of Commonplace is the ability to send out targeted reminders to specific groups during the

consultation, based on analysis of the demographic characteristics of those who have responded so

far. This will help encourage and further alert more people of different protected equality groups to

respond to the consultation.

Following the first round of consultation, comments will be considered by officers and the Draft SA

DPD will be amended accordingly where appropriate for pre-submission publication of the SA DPPD

Proposed Submission Version (an opportunity to comment on legal compliance, soundness and

compliance with the duty to co-operate). Submission (start of examination) is expected in Spring

2023 with the examination hearing Sumer 2023 and adoption of the SA DPD in Winter 2023/24.

Delivery of the SA DPD (once adopted) will be through the planning application decision-making

process and through publishing data on what is actually being delivered though statutory duty

monitoring reports. The Lambeth Local Plan 2021 includes a series of monitoring indicators covering

the range of policy topics that are also applicable to the SA DPD, such as overall housing delivery,

affordable housing, affordable workspace, office floorspace, industrial land, open space and green

infrastructure, transport and air quality. These monitoring indicators help determine how policies

are working in practice and how successful they are, and this information will be used to consider

whether policies may need to change in any future review. All planning policy monitoring data is

published on-line. Data on housing and employment also inputs into corporate KPIs.

Q3b. How do you plan to address and mitigate any negative impacts of the proposal? What impact has this evidence had on what you are proposing? What can you do differently that might lessen the impact on people within the timeframes i.e. development-implementation? Who can help you to develop these solutions?

The purpose of the SustA work on the Draft SA DPD is to appraise site allocation policies against the

sustainability framework and where appropriate make recommendations to either improve positive

impacts or avoid/mitigate negative impacts in implementing the SA DPD. Recommendations made

through the SustA process are considered by officers preparing the Draft SA DPD and may result in

Page 336

the Draft SA DPD being amended accordingly. Importantly, policies within the London Plan 2021 and

the Lambeth Local Plan 2021 will apply to the site allocations within the Draft SA DPD. Both these

planning documents have been subject to their own sustainability appraisal and equalities impact

assessment and were each found to be thorough and sound during their respective independent

examinations.

The Equality Act 2010 places a duty on officers and the council to have due regard to the impact our

policies and decisions have on people with ‘protected characteristics’: sex, race, disability, sexual

orientation, age, religion or belief, gender reassignment, pregnancy, and maternity, and to ensure no

negative equalities impacts from planning decisions. Accordingly, the Equality Duty supports good

decision-making to ensure policies and services are appropriate and accessible to all and meet

different people’s needs and that equality considerations in all stages of policy making process has

been made. It is considered that at this stage of the plan-making process preparation of the Draft SA

DPD is meeting this duty.

Development plan policies are designed to ensure negative impacts are mitigated, either by

amending the design of developments and/or through planning obligations. Planning obligations

assist in mitigating the impact of unacceptable development to make it acceptable in planning

terms. Planning obligations may only constitute a reason for granting planning permission if they

meet the tests that they are necessary to make the development acceptable in planning terms,

directly related to the development, and fairly and reasonably related in scale and kind. These tests

are set out as statutory tests in the Community Infrastructure Levy Regulations 2010 and as policy

tests in the National Planning Policy Framework. Lambeth Local Plan Policy D4 sets out that planning

obligations will be sought to secure affordable housing and to ensure that development proposals

provide or fund local improvements to mitigate the impact of development and/or additional

facilities and requirements made necessary by the development. This may include:

i. provision of infrastructure, such as transport, education, health,

libraries, sport and leisure, waste, energy, emergency services and

cultural and community provision

ii. local public realm improvements including streetscape, local public

open space, play facilities and community safety

iii. mitigation of impacts on and/or enhancement of heritage assets

iv. mitigation of noise impacts

v. highways and traffic works

vi. public transport improvements

vii. local walking and cycling improvements

viii. car clubs, parking restrictions, and travel plans

ix. hotel and visitor management measures

x. access to employment opportunities created by the development by

securing employment premises and learning and skills initiatives

xi. access for local businesses to supply chain opportunities created by

the development

xii. small and flexible office space, affordable workspace and affordable

retail units

Page 337

xiii. maintenance and management arrangements

xiv. town centre management

xv. public access to on-site facilities

xvi. low carbon and renewable energy, including carbon offset

xvii. sustainable drainage systems and flood risk mitigation

xviii. connection to, and support of, quality broadband and other

telecommunication and information technology support networks

xix. green infrastructure

xx. local food production and growing; and

xxi. other sustainability measures, including mitigation of impacts on and/or

enhancement of biodiversity and wildlife habitats.

Community Infrastructure Levy (CIL) contributions are also collected from new development to

contribute towards the cost of delivering the infrastructure required to support growth and

development in the borough.

Q4. How will you review/evaluate your proposal, mitigating actions and/or benefits? Who will be

responsible for this?

Who will you be accountable to for the above actions/outcome? How will those responsible know these actions have worked? What

performance indicators will you use to demonstrate this? Are there any other forms of evidence you can use to support this assessment of

their effectiveness?

The council is required to review its Local Plan and once adopted, SA DPD, every five years. This

provides an opportunity to look again at the implementation of new or revised policies and assess

their effectiveness. There are monitoring indicators in the Plan that help determine how policies

are working in practice and how successful they are, and this information will be used to consider

whether policies may need to change during the next review.

The council is also required to produce an annual monitoring report. These brings together data in

other annual monitoring reports that are prepared including housing development pipeline report

(includes completions and affordable housing), student accommodation assessment, hotel and

visitor accommodation and commercial development pipeline report. Data is published on-line and

reported internally to the lead Cabinet Member. Data on housing and employment also inputs into

corporate KPIs. Following adoption of the SADPD, progress with implementation of the site

allocations will be reported in the Council’s annual Authority Monitoring Report.

The team responsible for section 106 agreements (planning obligations) and CIL reports annually on

the collection and spend of financial contributions received.

The Local Plan monitoring indicators measure performance on matters that are directly and

specifically influenced by decision-making on planning applications. Given the anticipated positive

impact of Local Plan and Draft SA DPD policies on some protected characteristics groups, it is

expected that positive performance against Local Plan indicators will therefore also have an indirect

positive effect on more general statistics about protected characteristics groups collected/reported

by other council service areas. When reviews of the Local Plan and SA DPD take place, this wider

Page 338

information about protected characteristics groups will be considered in addition to more narrow

performance against the specific Local Plan indicators.

In addition to monitoring data, subsequent reviews of Local Plan and SA DPD policy will be informed

by other forms of evidence and any changes to the national and/or regional planning policy context.

The Planning Strategy and Policy team within Planning, Transport and Development

(Neighbourhoods and Growth) is responsible for reviewing/evaluating the Local Plan and collating

monitoring data.

Section to be completed by Sponsor/Director/Head of Service

Outcome of equality impact assessment

No adverse impact, no change required X

Low adverse impact, minor adjustment required

Significant adverse impact, further action required

Unlawful in/direct discrimination, stop and rethink

Comments from Sponsor/Director/Head of Service

Sponsor/Director/Head of Service Rob Bristow, Assistant Director Planning, Investment and Growth

Overall, the proposed policies in the Draft SA DPD are expected to have a positive impact on groups with

protected characteristics, particularly those within more disadvantaged socio-economic groups, some BAME

people, some disabled people and some younger and older people. On the whole, it is considered the draft

site allocation policies embody a recognition that place-shaping is best addressed through a neighbourhood

approach. Where development has potential for harmful impacts, Local Plan policies include measures and

mechanisms to mitigate these impacts.

The C&E Plan sets out the consultation methods to be used including how it is proposed to engage with those

groups with community engagement challenges, for example those more disadvantaged socio-economic

groups, some older people, some younger people, some disabled people and some people for whom English is

not their first language. For these groups the C&E Plan sets out the measures to get a range of people to

respond within the resources available.

The Council’s Equalities Impact Assessment Panel will have another opportunity to consider the draft SA DPD

after Regulation 18 consultation, at the next stage of plan preparation.

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Corporate EIA Panel Feedback Form, revised October 2020 1

LONDON BOROUGH OF LAMBETH CORPORATE EQUALITY IMPACT ASSESSMENT PANEL

FEEDBACK FORM

DOCUMENT TITLE: Regulation 18 Draft Site Allocations Development Plan Document

PANEL DATE: 23.11.2021

FEEDBACK ISSUE DATE:

24.11.2021

Enabling evidence-based inclusive decision making

The primary objective of an Equality Impact Assessment is to determine the potential impact of a policy, service or function on different equalities groups. The EIA must consider any influence the policy could potentially have on individual equality strands and socio-economic status. It should examine and clearly identify:

• The aim/purpose of the policy

• Relevant strategic objectives, local plans and population needs

• Equality legal requirements

• Improvement actions

• The policy outcomes

• How progress will be measured

• Relevant data, research and consultation

• Potential differential impact (adverse/positive) on equality groups

• Measures to mitigate adverse impact

• Monitoring arrangements

• Publication arrangements Promoting positive impact and mitigating negative impact The EIA process should not be regarded as an end in itself, findings emerging from the process and the outcomes are what is most important. If the assessment shows a potential for adverse impact or unlawful discrimination, this must be addressed.

Recommendations made by the Panel aim to ensure compliance with the equalities duties and demonstrate the Council’s commitment to tackling inequalities and social exclusion.

Page 341

Corporate EIA Panel Feedback Form, revised October 2020 2

Equality Impact Assessment Presenting Officers:

Regulation 18 Draft Site Allocations Development Plan Document Catherine Carpenter Vanessa Rodgers

Recommendations Department Response to Recommendations (Please insert your response to each recommendation here.)

Thinking about the example that was given will there be provision on other site? When routines are changed for vulnerable groups it can really impact them? Why weren’t bigger sites considered?

The site used as an illustrative example of the EIA approach does includes the retail sheds mentioned (Curry’s and Halfords), in addition to the community uses discussed.

There was no mention of different religious groups. Why have these not been mentioned?

Officers work very closely with the Council’s communications team, partners and VCS groups to access all networks in Lambeth; this will help ensure a full range of religious groups will be notified of the consultation.

On the map there appeared to be the Eurolink Business Centre. The Centre is a very big hub for BAME business, so what is the approach for that site?

The Eurolink Business Centre is not included within the draft site allocation policy for the example discussed, but it is adjacent to it. Development of the draft allocation site provides an opportunity for additional business space within the Brixton Creative Enterprise Zone. These are draft policies for sites, not specific development proposals or planning applications. Should these policies be adopted there will be subsequent planning applications that would undergo bespoke consultation in the normal way.

We need to be developing homes for young people and training?

This policy sets out how development can contribute to the area and secure public benefits, including for local employment and skills training. Delivery of these benefits is the specialism of the Council’s Economic Inclusion team. Increasing the delivery of housing overall is a key objective of the Draft SADPD. This will include new

Page 342

Corporate EIA Panel Feedback Form, revised October 2020 3

NOTE: Please sign and return the response to equalities@lambeth.gov.uk within 1 week of the feedback issue date. A copy of this completed form should be attached to your cabinet report.

--------------------------------------- ----------------------------------------- Director Presenting officer Rob Bristow Catherine Carpenter

Date: 29 November 2021 Date: 24 November 2021

affordable housing. This will contribute to mitigating the need for affordable housing among young people in Lambeth.

Mosaic Clubhouse is a safe space so any disturbance could be detrimental. Is something in the policy that any replacement is equal or better?

The policy specifically requires on site reprovision of community space of equivalent or better functionality. Officers agreed to add wording to the draft policy prior to Cabinet, to include reference to ensuring appropriate transitional arrangements for the existing community uses on the site.

We also need to think about we engage with the community so they understand what this is, what we can and cannot do and that we are doing everything we can to look after their interests as they are a valuable part of our community

Yes, the consultation and engagement plan provided sets out the range of measures proposed to engage and communicate with residents and businesses about the draft site allocation policies.

Affordability is an issue as there has been problems in the past. So community group have ceased and had to move due to developments. what is there to protect against that?

Officers agreed to add wording to the draft policy prior to Cabinet, to include reference to ensuring the affordability of the re-provided community space on the site discussed.

In the report it mentions potential for tall buildings, what does this mean? Are we consulting with friends of groups?

There are a small number of sites in the Draft SADPD that are identified as locations appropriate for tall buildings, in addition to the locations already identified in the adopted Local Plan 2021. General building heights are identified for the sites in question, having regard to individual site context. ‘Friends of’ groups will be notified of the consultation, as they are for other planning policy consultations.

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Appendix 4 – Site allocations in Local Plan 2021 – current position

Local Plan 2021 site allocation Summary of preferred uses in Local Plan 2021 allocation Current position

Site 1 – Land north and south of and including

10 Royal Street, SE1 (Founders Place)

Health use for the expansion of St Thomas’ Hospital to

provide clinical and ancillary hospital uses; replacement of

existing housing.

Allocation subject to review through the Draft SADPD

Site 4 – New Park Road SW2 Education use with potential for enabling residential

development.

No planning application submitted to date

Site 5 – Elizabeth House, York Road SE1 Office-led development with a mix of central London

activities including ground-floor active-frontage uses and

residential, with a new city square onto York Road.

Planning consent granted 18/02/2021 for office and retail

scheme (19/01477/EIAFUL)

Site 6 – Shell Centre, York Road SE1 Mixed-use employment-led development: office,

residential, active ground-floor frontage uses to include

retail, cultural, sport, leisure, community facilities including

the replacement of the police facility.

12/04708/FUL permission (as amended by

19/03437/NMC) for a mixed-use scheme including

commercial space and 880 residential units. 776 units

completed and 104 units under construction.

Site 9 – ITV Centre and Gabriel’s Wharf,

Upper Ground SE1

Mixed-use including offices, residential and active-frontage

uses at ground-floor level.

Allocation subject to review through the Draft SADPD

Site 10 – 8 Albert Embankment and land to

the near bounded by Lambeth High Street,

Whitgift Street, the railway viaduct and

Southbank House SE11

Retention/provision of an operational fire station. Mix of

uses including residential and employment.

Resolution to grant permission for a mixed-use scheme

(19/01304/FUL). Dismissed through Secretary of State

call-in following public inquiry in December 2020.

Site 11 – Keybridge House, 80 South Lambeth

Road, 10-22 Wyvill Road (even) and 143-161

Wandsworth Road (odd) SW8 1RG

Mixed-use development with active frontages at ground-

floor levels, employment with residential on the upper

levels and potential location for a new primary school.

Coming forward as five plots with a mix of uses:

• 143 - 161 Wandsworth Road: 239 residential units

completed

• Keybridge House: 473 units completed and 125 units

under construction

• 10 Wyvil Road: no planning consent to date

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Local Plan 2021 site allocation Summary of preferred uses in Local Plan 2021 allocation Current position

• 12-20 Wyvill Road: extant consent includes 278

residential units

• 22 Wyvil Road: extant consent includes 30 residential

units

Site 12 – Land bounded by Wandsworth Road

to the west, Parry Street to the north,

Bondway and the railway viaduct to the east

SW8 (Vauxhall Square)

Town-centre-led mixed-use development with

employment, community uses and residential on the upper

floors. A new urban square with a linear park connecting

through the site and the reprovision of a hostel.

15/05619/VOC permission for a mixed-use scheme

including 578 residential units. Under construction.

Site 13: Plot bounded by 7-93 Wandsworth

Road, Parry Street, Bondway including the

bus station SW8 (Vauxhall Island Site)

Town-centre-led mixed-use development centred on

Bondway and the existing bus station.

Permission 17/05807/EIAFUL for mixed-use scheme

including 257 residential units.

Site 14 – Somerleyton Road SW9 Mixed-use development of residential, employment,

cultural and community facilities, social enterprise and

business start up spaces, and provision of open space.

15/05282/RG3 & 15/07308/FUL permissions include 308

residential units in total. Both permissions are under

construction.

Site 15 – Popes Road SW9 Mixed-use development - retail, commercial, community,

leisure, residential.

Regeneration-led project expected to result in a planning

application submission.

Site 16 – Brixton Central (between the

viaducts) SW9

Mixed-use development including retail, new workspace,

food and drink, community, educational, leisure and

recreation uses, possible market extension and associated

uses.

Resolution to grant permission 03/11/2020

(20/01347/FUL) for office, retail, assembly and leisure

scheme.

Site 18 – 286-362 Norwood Road SE27 Retail-led mixed-use development to include housing, new

public space and improved connections through the area,

smaller retail units fronting Norwood Road and car parking.

Allocation subject to review through the Draft SADPD

6 Lansdowne Hill: extant consent for 51 residential units

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