Do you have any comments on the revised Part 3 of the SPD?

Looks great, I especially like the stepped buildings that reduce the impact of height at street level.

Do you have any comments on the revised Part 3 of the SPD?

‘3.3 Whilst the demolition and redevelopment of heritage assets and buildings that make a positive contribution to the special interest of conservation areas is discouraged.’ ‘Discouraged’ in the above seems particularly weak, contrasting with the protection of the heritage elsewhere in the documents. ‘3.7 Redevelopment of sites should enable broader issues to be addressed from the outset, these include; climate change mitigation and adaptation, urban greening and biodiversity, creating inclusive environments which make a positive contribution to health and well-being and integration with the Healthy Streets Approach to promote active travel and low traffic neighbourhoods.’ ‘Should ‘ in the above is a weak word, it must be the case that where demolition is allowed then there is a solid requirement to fully meet climatic and environmental standards. Lambeth has declared a climate emergency so it should see this as non-negotiable when a site is cleared and so no longer compromised by existing structures. ‘3.11 With the need for continued growth in Lambeth and in recognition that London’s character is ever-evolving much of the new development coming forward is going to be taller than its current context. In some instances development may be substantially taller. Designers should: 1. Step massing down in sensitive locations where it would be desirable to respond positively to established context; especially heritage assets and in relation to neighbour amenity.’ The above first sentence says development can be taller or substantially taller and it is only in sensitive locations where it would be desirable to step massing down. This principle should apply to all taller buildings where it is in juxtaposition with local character. The use of the word desirable rather than must makes this sound optional and is weak. ‘3.31 In order to comply with London Plan Policy SI1, designers should consider air quality as part of their proposals and assess any impact there may be on local air quality. The impact is to be considered at all stages of the development, from demolition and construction through to operation.’ This is not a should but a must in view of the boroughs commitment to healthy streets. Why put this so weakly? 3.43 Designers should: 1. Meet the relevant space standards. 2. Achieve dual aspect layouts with practical room layouts 3. Anticipate the future needs of users by ensuring flexibility and adaptability are in the design, layout and construction. 4. Optimise daylight and sunlight (which might include roof lights and sun pipes on top floor units and using glazed doors borrowed light to bring light into halls and landings) both within flats and in common areas. 5. Avoid deep floor plans (to optimise daylight penetration and reduce daytime reliance on artificial light) 6. Optimise energy efficiency of space heat Surely these are not a should but a must, particularly space standards. It is unacceptable to design new build that is sub-standard. ‘Public Realm 3.64 Ensure the associated public realm is adequate for the volume of users and mix of uses but avoid stark contrasts between height and open space.’ There is no definition here of ‘adequate’ or a reference to another document to define it, so it is meaningless.

Do you have any comments on the revised Part 3 of the SPD?

With regards to paragraph 3.4 (Optimising Development Potential) please reword this section to reinforce, clarify and give weight to the final sentence. In certain cases over development is being sought to be justified by an emphasis by applicants that the balance of public benefits outweigh the public harms. Whilst I appreciate that all developments have some level of harms, I am concerned by the interpretation by planning applicants that SPD para 3.4 entails and encourages. There is a wide degree of subjectivity in interpreting what is the actual level of optimum density which is existing planning policies do not address, particularly the current London Plan. Optimum density when applied to those external to the site should not result in any material deterioration in quality of habitably and wellbeing.

Do you have any comments on the revised Part 3 of the SPD?

The approach seems to be that tall buildings are necessary even if this is detrimental to existing homes and residents. Tall buildings benefit few except developers because they can cram more units in and they are mostly private with a very few social units, as little as developers can get away with. They are not always appropriate to development sites so should not be automatically encouraged. Who decides on design excellence and is the future of "Lambeth's local distinctiveness" to look like every other area in every other city?

Do you have any comments on the revised Part 3 of the SPD?

I am concerned about Lambeth’s apparent enthusiasm for encouraging tall buildings in what seem to me and many other residents to be inappropriate settings. I wanted to take the opportunity to comment on this in the context of the design report as I have done in response to other documents. The section on tall buildings on p20 says that they can enable the efficient use of land when sensitively developed on appropriate sites. I would like the document to state that tall buildings may be inappropriate on sites where the prevailing height of existing buildings in the area is two or three storeys. At present, the main guidelines seem to be the optimisation of site potential in line with the London Plan (although you do refer to Policy Q26 which effectively rules out tall buildings in the suburban south of the borough). There is not much indication of what is meant by optimisation, or who decides whether a proposed development is the optimum (ie best) use of the land. Do residents have some say in this? I do note that in none of the examples pictured of good design are tall buildings set against two-storey suburban houses. They are all inner-city designs and older buildings next to them are four to six storeys. I propose that, from a design point of view, tall buildings over seven storeys in suburban settings I have described should be discouraged. Elsewhere in the report, you talk about the importance of Lambeth architecture being of a human scale. You also talk, in the context of tall buildings, of the importance of human scale at ground level and the avoidance of tall towers which “loom uncomfortably over low-rise neighbours or pedestrians”. I agree, but feel that these statements are in contradiction to Lambeth’s encouragement of a proposal for West Norwood involving a 22-storey block and two of around 10 storeys. When you do try to discuss what you mean by “optimisation”, you mention excessive pressure on public realm or infrastructure. But, again, it is not clear at what point the pressure becomes excessive. When a new school is required? Or when people cannot cram on to a commuter bus or train? Or simply when good views of the City from back windows are spoilt by a cluster of new sky-scrapers? Finally, I want to state that I find the discussion on the impact of a tall building in near, medium and distance views reveals a certain snobbery about the precious nature of our historic heritage compared to bog-standard townscapes. I agree with the statement in 3.55 that designers should “ take particular care to ensure that the building massing and form are successful in each context” (ie, from all views). But I do not think that we should concern ourselves purely with “sensitive receptors” by which I understand you to mean historic landmarks. The document says that receptors should include “the settings of heritage assets or places of townscape/landscape value”. Who decides whether a place has townscape value? I would prefer wording to indicate that tall buildings seem out of place in low-rise townscapes. And maybe existing residents and businesses should have a say on whether a townscape is of value? The document creates a hierarchy of importance attached to the setting of a new tall building, summed up in the tables at the end. Table 2 reveals an appalling design snobbery about “commonplace or unremarkable townscapes”, giving such places a low receptor value. The people who choose to live in such places would probably place a higher value on them as being human-scale, green and having a friendly and unthreatening feel. The views of residents should be credited with some value in this ranking which seems entirely decided by the values of design and planning professionals who are themselves swayed by fashionable notions of what constitutes attractive architecture and important assets. I do agree with 3.67, though, that tall building development should seek to blend into its context rather than stand out. One final point: there is quite a lot in the report, in the general approach section, on the whole life-cycle approach. I may be wrong, but surely tall buildings are much harder and messier to demolish when they reach the end of their life?