Monday, 4 May 2009

Our draft response to Lambeth Council's consultation on the Local Development Framework Draft Core Strategy

Draft response to consultation on LDF Draft Core Strategy from the Kennington, Oval and Vauxhall (KOV) Forum

The following is the draft response of Kennington Oval & Vauxhall Forum to Lambeth Council’s consultation on the Local Development Framework Draft Core Strategy. Please tell us what you think on E: – the final version has to be submitted by 18 May.

The KOV supports the six key themes of the Core Strategy. We also support Item 17 Page 100, “support the regeneration and renewal of the London Plan Opportunity Areas at Waterloo and Vauxhall/Nine Elms/Battersea to reflect their role in central London, working in close partnership with all key stakeholders” with the caveat that our purpose is to ensure that there is no inappropriate development, that sufficient high quality and sustainable infrastructure is in place before any residential accommodation is occupied and that tall buildings should not put other accommodation into shade. In addition, applications for sites need to be scrutinised to ensure that impact is either positive or strictly limited.

KOV also supports the recognition of heritage, historic assets, community identity, the contribution of local artists to this local economy. We also support Lambeth support for Business Improvement Districts and would welcome one for KOV area. How does this link in with the Core Strategy?

The draft raises questions of accuracy, interpretation and intention. There are statements in the daft which appear inaccurate or on which further explanation is required to be clear as to what is meant so that an informed and constructive comment can be made. We would like to be assured that questions from consultees will receive responses so that sensible, well informed comments may be made.

We have asked some questions in this response for clarification.

As an example of where we need clarity, the geographical boundary of an area may be relatively clear (for instance separate consultation was undertaken on the Vauxhall area), however, those reading the Draft in isolation, would have no indication as to what the boundaries are. Is the boundary for Oval as referred to in the draft the ward boundary of that name? Kennington Lane is mentioned but does this extend as far as the Beefeater site?


Policy PN2 First paragraph last sentence states

“Overall, development can provide at least 3,500 new homes and 8,000 new jobs in the Vauxhall area by 2026 and appropriate community and public transport infrastructure improvements will be sought.”

This policy statement needs strengthening. The commitment to improved community and public transport infrastructure should be in place before any development takes place.

Whilst KOV approves of the intention to create a permeable pedestrian and cycling environment, including creating public spaces, seeking the removal of the one way traffic system, car free developments, etc, etc, we remain concerned that, once again, the strategy is not sufficiently robust and does not constitute a delivery strategy for achieving these objectives as required by the DCLG. A piecemeal approach is unlikely to produce the desired changes and could result in more homes and more jobs without the infrastructure to support them and an even more hostile traffic dominated environment.

A clearer, coordinated, more radical and ultimately, more effective strategy is essential.

(a) ... with a mix of uses including Central London Activities – What are Central London Activities?

(b) ...that access to a high quality riverside walk is maintained

(c) Seeking the removal of the one-way traffic system should dominate this paragraph – needs reinforcing. Every consultation has highlighted this as the number one desired improvement in Vauxhall.

(d) Respecting strategic views – this needs strengthening so that views from Kennington Road, Lane towards the river should also be respected in relation to tall buildings.

(e) KOV do not support tall building anywhere but of all the Vauxhall quarters identified, the Vauxhall Heart might be considered the least inappropriate.


We do not support tall buildings and believe that any reference to them in any area should emphasise the need to ensure they do not cast other accommodation or open space or retail areas into the shade.

Para 8.10 – The Vauxhall area contains some good areas of active frontages. We believe this should be limited areas of active frontages.

Para 8.11 – Whitgift Park, Pedlers Park are little more than Greens.

Para 8.12 However, public transport capacity is currently limited. It is at capacity!


In the Draft Core Strategy, the character of the Oval area is too heavily focussed on the cricket ground. This places too much importance on the ground in comparison with the other features of the area which give it character and which represent the area, its community and their aspirations.

The wording in PN7(a) particularly needs clarification. It refers to Harleyford Street in the following terms:-

“... improving the relationship of the stadium with the adjoining area particularly the quality of the linkages with the centre along Harleyford Street, by improving the attractiveness of the public realm, the creation of appropriate public spaces, interesting features and promoting active frontage uses along the route. “

Please identify what is meant by the “centre” in the above statement.

This route has a street frontage to the north consisting of the boundary wall of Blades House and Lockwood House and on the other side of the road junction with Kennington Oval, there is the boundary wall of the Oval cricket ground itself.

The best opportunity for the creation of appropriate an public space was lost when the Planning Applications Committee agreed to the Surrey County Cricket Club (SCCC)’s planning application for the area in front of the SCCC pavilion. In the event that the application is approved by the Secretary of State, the area will become private space enclosed by turnstiles. There is otherwise little opportunity for creation of appropriate public spaces along that side of Harleyford Street/Kennington Oval. On the other side of the road is the underground station, a private block of flats and the Oval House Theatre. LBL will be aware how dangerous the bend in the road is at that particular point and, therefore, how inappropriate that location might be for public open space.

Where is the opportunity for LBL to promote active frontage uses along the route . Are you considering the redevelopment of the Oval House Theatre. For many reasons it is unlikely that major or minor retailers will wish to locate themselves at this point on a very busy main road with no parking and with Tesco and Sainsburys in relatively close proximity.

Paragraph 8.57 states

“The major issues for the area are how to derive more benefit economically and for the community from the use and events at the Oval stadium, which included many conferences and a proposed hotel We question how?

Before it is possible to comment constructively on this statement, it is important to know exactly what it is intended to mean.

In our view the local, the residential community has derived few benefits from activities at the Oval over the years. Please refer to the submissions made by the local community (United Friends of Oval, UfO) to the Planning Applications Committee in early 2008 and to the submissions made by UfO to the Planning Inspector at the end of 2008. The evidence contained in these submissions demonstrates clearly that the events held at SCCC not only do not benefit the community, but give rise to disturbance and detriment to the community. It would be most desirable to derive more benefit economically and for the community from the presence of SCCC in our midst. One-off conferences and one or two day cricket match per week in summer will be staffed by an agency and there will be few , if any, opportunities for employment of local people.

Apart from the possibility of a few local jobs it has been impossible to identify the benefits to be derived from the proposed hotel development. Indeed there will be a detrimental effect on those residing locally from the continuous noise and disturbance from deliveries to the hotel plus staff arriving and departing. Could your draft Core Strategy please clarify what exactly benefits means in this specific context. Please check with the local community that we acknowledge what is identified is a benefit to the community),then set out clearly in what way real, tangible benefits are to be delivered.


Section 3, Key Stages & next steps: At each stage the Core Strategy is revisited to ensure that comments received have been addressed.”

How will those who have commented be informed that comments have been addressed?

That's it for now. Please let us know if you have points to add.