Writing to the Secretary of State: guidance from our advocates

Write in your own words why the Secretary of State should refuse the planning application for 8 Albert Embankment with emphasise on…

  • Lambeth Council’s support for the scheme is the result of significant errors:

The application was seriously mishandled by the authority, including failing to present the final (26.11.19) BRE report into sun & daylight to councillors in the Planning Applications Committee in December 2019, which misled the committee as to the severity of the impact.  This includes ‘major adverse’ impacts on neighbouring properties and in total 424 windows on every side of this proposed development fail the BRE benchmark.

With respect to the Westminster World Heritage (WWH) site the position of Historic England was misrepresented in the report to Planning Applications Committee in December 2019 and Lambeth’s heritage officer admitted this in the public inquiry in December 2020.

Historic England had objected to the impact on WWH site as well as specifically proposing the tall buildings were reduced, yet they were ignored.

Lambeth Palace was described as Grade II listed (Committee Report P189 at 8.2.69), so demeaning it’s significant, it is of course Grade I listed and holds an important relationship with the Westminster World Heritage site across the river.

  • Lambeth ignored the increased protection for heritage assets granted by the Secretary of State on this site

Increased protection for the heritage assets included in the Lambeth Local Plan 2015 were ignored and these included a specific design requirement for ‘no tall building development’ (P163 Site 10).  The Lambeth Local Plan 2015 went through public consultation and a public inquiry before being agreed by the planning inspectorate on behalf of the Secretary of State.

  • The London Mayor Sadiq Khan fails to follow planning policy, his own and Lambeths

The London Fire Brigade is directly controlled by the London Mayor Sadiq Khan and yet it made a ‘departure‘ planning application at 8 Albert Embankment on a site that had previously been refused at planning inquiry and importantly where the Local Plan (2015) had been amended to provide an agreed way forward.

The London Mayor’s ‘departure‘ from planning policy has been driven by achieving a land value, rather than creating his ‘good growth’ policy and results in multiple harms to the local community and to London’s heritage including the Westminster World Heritage site.

The Mayor has claimed that the creation of a Fire Brigade Museum is a benefit significant enough to justify circumventing policy, but he himself closed down the previous museum in the Victorian Fire Brigade HQ in Southwark, sold it and took the profit …..now he is asking local people to live in the shadows to pay for this reprovision.

  • The proposals are significantly ‘out of character’ with the area and are not ‘beautiful’
  • five of the proposed buildings are towers being more than 30 meters tall and two of them are skyscrapers at or near 90m.
  • the tallest towers actually step up not down from towers to the south and do not relate to the local character planning character area.
  • the materials do not reflect the brick of the grade 2 listed and art deco Fire Brigade Headquarters or the grade 2 listed Victorian South Bank House, formerly the Royal Doulton HQ.
  • the buildings density fails to reflect that of an area of heritage and one that neighbours the important Grade 1 listed Lambeth Palace.

All five towers sit inside a conservation area (8 Albert Embankment) and abuts another (Lambeth Palace).

This sets an unacceptable precedent of building towers in conservation areas, rather than the development taking it’s typology from the heritage. 

A 26 storey skyscraper sits opposite a two storey residential home at the end of Whitgift Street and does not relate in shape or form to adjacent buildings as required by the sites design principles in the Lambeth Local Plan (2015).

Even in the VNEB opportunity area planning policy this is a character zone recognised for its ‘heritage sensitivities’ and being of a ‘more local character’.

This is a dense dark development with very little greening, it fails the London Mayor’s new ‘Urban Greening Factor’ very significantly and as a result of the hyper density, much of the new public realm will be in shade much of the day. The ‘Central Garden’ doesn’t even meet the minimum BRE guidance of two hours sunlight per day.

The development will cast shade onto Old Paradise Gardens affecting the community work of the Garden Museum and also it’s Lambeth Green plan for the area which relies on maintaining sunlight in the park for both food and medicinal gardening.