Examination of the Wandsworth Core Strategy: Inspector’s approval

>> Your chance to contribute: tell us what your think on Clapham Junction station redevelopment

Author: Cyril Richert

A government inspector has approved the central plank of the council’s new planning framework.

The Core Strategy (CS – which sets out the Council’s vision on the development of the borough for the next 15 years – more explanation here),  is the key document in the council’s Local Development Framework (LDF). It was  submitted to the Secretary months ago and subsequently examined by an independent Planning Inspector.

The planning inspectorate has now confirmed that the strategy is sound and can go ahead with a number of amendments.

Most of the changes were discussed at the public hearings in February 2010 following the topics:

  1. Design/townscape in general (scale and density of development)
  2. Tall buildings
  3. Major development areas and sites
  4. Sustainable buildings

[We reported on the hearing here: Public Hearing: Examination of the Wandsworth Core Strategy]

The inspector, Linda Wride, had raised issues around policies on tall buildings and affordable housing.

Her report accepts that the information provided by the council formed a suitable evidence base for the policies.

Her main conclusions are:

1.4 The changes I have specified in this report are made only where there is a clear need to amend the document in the light of the legal requirements and/or to make the document sound in accordance with PPS 12. Annexes A and B contain schedules of changes. I have used the Council’s suggested wording, unless stated otherwise.

1.7 My overall conclusion is that the London Borough of Wandsworth Core Strategy DPD is sound, provided it is changed in the ways specified in Annex A. The principal changes required are, in summary:

a) To amend Policies PL 5 (provision of new homes) and IS 5 (achieving a mix of housing), together with the supporting text, to require housing targets, including affordable housing targets and the tenure split between affordable rented and intermediate affordable housing, to be reviewed when the replacement London Plan is adopted.

b) To amend Policy IS 5 c (affordable housing) so that the definition accords with national guidance; to ensure the trigger for affordable housing provision is consistent with the London Plan; to specify the proportion of affordable housing required based on the findings of the Affordable Housing Economic Viability Assessment, and to clarify the circumstances in which a site specific economic viability assessment will be required; to signpost that other housing policies will be included in the Development Management Policies Document.

c) To amend Policy IS 5 g (gypsy and traveller accommodation) and the supporting text to refer to the estimated requirement for additional pitches in the plan period 2017/18 – 2021/22; clarify the role of the Site Specific Allocations Document in meeting future needs; indicate how demand for, and provision of, additional pitches will be monitored and reviewed.

d) To amend policies relating to the locations where tall buildings may be acceptable (Policies IS 3, PL 11, PL 12, PL 13, PL 14) to reflect the Council’s Stage 1 Urban Design Statement and to acknowledge the ongoing work in the Stage 2 Urban Design Statement and lower level DPDs.

e) To replace Policy IS 7 b (planning obligations) with a new section which refers to the Council’s intention to develop a Supplementary Planning Document on Planning Obligations and an associated Community Infrastructure Levy (CIL) charging schedules to support the provision of infrastructure projects.

f) To amend Policy PL 7 (waste management) and supporting text to confirm the Council’s role as waste planning authority; set out the DPDs which provide the spatial delivery tool to implement the Municipal Waste Management Strategy; refer to the movement of waste up the waste hierarchy; correct the estimate of land required to meet the London Plan waste apportionment figures; ensure this requirement is reviewed when the replacement London Plan is published.

g) To amend Policy PL 11 (Nine Elms and adjoining areas in north east Battersea) the supporting text so that targets for homes and jobs and the quantum/mix of development permissible in the Vauxhall Nine Elms Battersea Opportunity Area (VNEBOA) are reviewed when work on the VNEBOA Planning Framework is complete, and that the outcomes are fed into the Spatial Strategy for the Queenstown Road to Nine Elms area coming forward in the Site Specific Allocations Document DPD.

However, she suggests a list of changes to make the document sound and compliant. On tall buildings especially she wrote (from page  26):

Some of the locations identified include sensitive historic areas and buildings, whilst the height of development in the Vauxhall area impacts on a strategically important view of the Palace of Westminster World Heritage site from Hungerford Bridge. These considerations reinforced my concern about the apparent lack of evidence underpinning the Council’s tall buildings strategy. […]

[Through the extracts I make comments in dark red.]

Here she highlights that the lack of clarity of the current plans can lead to issues with important view protection such as the Palace of Westminster. Of course it is directly in view of the past critics with the plan to built a giant glass tower beside Battersea Power Station and the more recent projects (for New Covent Garden) including skyscrapers of 150-200 meters at less than 850 meters from the Houses of Parliament.

I acknowledge that the Stage 2 Urban Design Study is in draft at present, and is intended to provide the evidence base for lower level DPDs covering site allocations and development management, rather than the CS. However, in general terms, it provides the type and level of analysis I would expect to see as evidence supporting a CS policy identifying areas where tall buildings may be appropriate. […]

See our article on Site Specific Allocation Document.

I consider that a requirement for tall buildings to respect the historic environment should be woven into the qualifications embodied in Policy IS 3 d, alongside the recognition that tall buildings have potential benefits in terms of regeneration, townscape and the public realm. This will convey more clearly the Council’s balanced approach to assessing proposals for tall buildings in the areas identified.[…]

The Stage 1 Urban Design Study states that selecting a limited number of areas where tall buildings may bring an acceptable balance of positive change, will send a clear message that tall buildings are not considered appropriate across the great majority of the borough. In my view, this needs to be spelt out in the supporting text and policy itself, rather than assuming that readers will recognise the implicit message in the policy. […]

That is what we wrote in June 2009, saying: “we will continue to work for the Council’s policy on tall buildings to be clarified so that developers don’t keep spending great amounts of time and money on proposals which prove so unpopular as soon as local people get to hear about them“. Some applications were submitted because developers assumed encouragements from the Council’s documents; their plans were later proven deeply unpopular.

I see no need to refer to “areas well served by public transport”. In my view, unless this reference is deleted, false hopes may be raised that tall buildings are likely to be considered appropriate on sites with a good PTAL rating but located outside the areas identified. In this context, I think it would be helpful to name the “defined focal points of activity” in the policy, rather than expect the reader to search place-based policies in order to establish their whereabouts. […]

Similar as above, and she will later ask for Clapham Junction Station to be removed from areas suitable for tall buildings as suggesting during previous amendments. We wrote in a previous article that PTAL and tall buildings are two different concepts, which is exactly what the inspector is saying with other words.

Circular 07/2009 advises that it may be appropriate to protect the setting of World Heritage sites by protecting specific views and viewpoints. In the light of this advice (which was published after the CS was submitted for examination) I consider that Policy IS 3 ought to indicate how the Council will assess proposals for tall buildings on sites within the protected view of the World Heritage site, even though the site itself is outside the borough. […]

During the Public Hearing, we raised doubts, in view of past experience, of the way the Council might (not) follow its own policies. The inspector is asking here for the Council to explain the measures taken to enforce its own policy.

The Stage 2 Urban Design Study highlights that constructing tall buildings in the Falcon Lane area of Clapham Junction could have a potentially harmful impact on the residential enclave of Mossbury Road. I therefore agree with the Council’s suggested change (IC16) to delete the reference to tall buildings in Policy 13 e, on the basis that proposals for tall buildings would only be acceptable near the railway and would therefore considered in the context of Policy 13 b (Clapham Junction Station site redevelopment). […]

In the more recent consultation on Site Specific Allocation Document, we wrote: “Amendments specific to 4.1 Area Spatial Strategy for ASDA, LIDL and Boots sites, Falcon Lane, Clapham Junction SW11: Applications for buildings of more than 20 6 storeys are unlikely to be considered acceptable […]“. It was also reinforced previously by the change already discussed to remove Clapham Junction Station from areas suitable for tall buildings.

In view of the tall building amendments,  I copy below the changes [Delete paragraph and replace with the following renumbering subsequent paragraphs as necessary]:

IC15 73 PL 13 b A comprehensive retail and residential led mixed-use redevelopment of the station approach shopping centre and the adjoining land bounded by St John’s Hill and Falcon Road could will enable substantial improvements to take place to the station and access to it, which are a priority for planning gain objectives. Public realm improvements will also need to be provided. The provision of new retail floorspace will help integrate the area better into the town centre and strengthen its retail function. New residential accommodation will help meet housing targets in a highly accessible location. Development at Clapham Junction and other sites in and around the town centre should aim to meet targets of at least 500 homes in the medium term rising to 1,500 with the development of all identified sites by 2023, with up to 30,000 sq ms of employment space. Other appropriate uses in this highly accessible location include offices, hotel, cultural, leisure and entertainment. A high quality street frontage can be created around the existing station entrance in St John’s Hill, building upon the established urban grain of the town centre. Taller buildings could not only help deliver significant regeneration benefits but also give a visual focus to the town centre, subject to qualifications set out in Policy IS 3 and the criteria based policy on tall buildings to be included in the Development Management Policies Document.

Here with a small word change (could/will), the inspector suggests clearly that substantial changes such as for Clapham Junction Area (think about the drastic plan of twin towers proposed by Metro Shopping Fund last year) is not inevitable but only possible. In addition it links taller building to the guidance defined in the other policies.

IC16 73 PL 13 e The area around Falcon Lane should be restructured to secure an extension to the town centre in a compact and sustainable form consistent with the distinctiveness of Clapham Junction. This should take the form of a mixeduse development with good quality streets. Additional new housing can be provided in higher density mixed use redevelopment of low density retail facilities on the north side of the town centre on or close to Lavender Hill, to include enhanced retail provision where appropriate. Taller buildings in this location could be justified due to the proximity of Clapham Junction station and its accessibility to high frequency public transport. New public space should be provided within any redevelopment.

It is now clearly stated that Clapham Junction Station has been removed from areas suitable for tall buildings. In addition it highlights the necessity to include public space within any development, which should avoid any extended coverage of concrete and high rise.

IC19 89 IS 3 c Throughout the borough, with the exception of the major development sites within the VNEB [Vauxhall-Nine Elms-Battersea] Opportunity Area, t The scale and density of development should make the most effective use of land and buildings without harming the character of the surrounding area, paying regard to the site’s accessibility and existing and proposed infrastructure and the London Plan density matrix, without harming the character of the surrounding area.

The words “without harming the character of the surrounding area” should be read as avoiding the recent applications such as the Ram Brewery or the twin towers of CJ station where developments were definitely changing the character of the surrounding area.

IC20 89 4.132 :
Tall buildings are those which are substantially taller than the prevailing height of neighbouring buildings and/or which significantly change the skyline. The height at which buildings will be considered ‘tall’ on individual sites, together with detailed criteria for assessing the design and impact of tall buildings and consideration of the appropriateness of tall buildings on individual sites will be set out in the Development Management Policies Document (DMPD) and Site Specific Allocations Document (SSAD). […] it is important that they are sited in appropriate locations, respect local context and the historic environment, are acceptable in terms of design and impact on their surroundings and do not harm existing important views and skylines.

Here let me just quote the joint statement on tall buildings that we submitted in September 2009 along with the Wandsworth Society, the Putney Society and the Battersea Society: ““Tall” buildings, those significantly taller than their neighbourhood must be considered in their urban context […] “Tall” buildings must stand up to scrutiny in terms of need, appropriate location, architectural quality in their own right and their contribution to urban design.” Even sharp criticisms should have difficulties to ignore the similarities between our views and the Inspector suggestions.

IC21 89 IS 3 d Replace IS 3 d with the following:
Tall buildings, that is those which are substantially taller than the prevailing height of neighbouring buildings and/or which significantly change the skyline, may be appropriate in the borough’s town centres, Nine Elms near Vauxhall or at Putney Wharf, Wandsworth Riverside Quarter, Wandle Delta, Ransomes Dock, and Battersea Power Station focal points of activity (as illustrated on Map 15) . Some locations within these areas will be sensitive to, or inappropriate for, tall buildings. Applications for tall buildings will need to justify themselves in terms of the benefits they may bring for regeneration, townscape and public realm and be of high architectural quality, respect local context and the historic environment. Tall buildings are likely to be inappropriate in other areas. Detailed criteria for the assessment of tall buildings, consideration of the appropriateness of tall buildings on individual sites, and the height at which buildings will be considered ‘tall’ on individual sites will be contained in the Development Management Policies Document and Site Specific Allocations Document.

IC22 89 IS 3 Insert new policy IS 3 e as follows:
Views of the Westminster World Heritage Site will be protected in accordance with the London Plan and the London View Management Framework.

A press review issued by Wandsworth Council said: “She confirmed that while guidance on tall buildings published by CABE and English Heritage is relevant there are other ways of providing appropriate supporting information“. If the Council means that instead of putting all criteria in the Core Strategy brief, it could be detailed in a Site Specific Allocation document they are right. However, as English Heritage view was that “the current definition of “tall building” included in Policy IS3 is not sufficiently clear. It is our experience that the phrase “significantly exceed” requires further definition in order to provide sufficient clarity as to what it means. In order to help overcome this, English Heritage has sought to amend this by replacing it with the phrase “are substantially taller than their neighbours and/or which significantly change the skyline.” [EH arguments can be read HERE] this is EXACTLY what the Inspector is asking to add in IC20 89 4.132.

The core strategy itself is expected to be adopted by the council at its meeting on October 20, 2010.

The council will now prepare detailed planning policies to support the core strategy including a document setting out specific uses for key sites and another clarifying the criteria by which the council will consider applications. Public consultation on this stage begins in October.

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