Saturday, 15 January 2011

KOV's submission - Vauxhall Island Site/Kylun application

20 August 2010
Dear Mr Smith


We wish to submit the following observations on the above application and to urge that it be refused for the reasons stated below.

1. The KOV Forum was established in 2000/2001 by local representative groups and individuals, including residents’ and tenants’ associations, community organisations and local businesses, at the instigation of Lambeth Council to strengthen community involvement in Council programmes, policies and plans. The area represented by the Forum is the whole of Prince’s and Oval wards and a small corner of Bishops ward south of Lambeth Road.

2. During discussions at numerous Forum meetings it has been evident that there is widespread and general concern regarding the new high-rise developments that are proliferating at or close to Vauxhall Cross; also about the concentration and very high densities of these developments. We understand that this approach to the development of this area has been promoted and encouraged by the Government and the Mayor’s London Plan and the identification of Vauxhall/Nine Elms as an Opportunity Area. But we feel developments completed and currently proposed have been allowed to happen in too piecemeal a way, with highly damaging effects on the character and amenity of the area. Concern has always been that no plans have been put in place to ensure the development of a sustainable community.

3. Vauxhall Cross offered real opportunity to provide attractive new buildings and street patterns that would link the near hinterland (east of the railway viaduct) with the Thames. Those opportunities were lost completely with the approval of the St George Wharf development. Not only have the assurances given by the developers at the time, in the face of public concern, proved meaningless; the incremental planning permissions since then have made them even less relevant. Local residents argued that the scale and character of that development would in effect create a bulky and ugly ‘wall’ between the river and the Vauxhall Cross area and an oppressive and dominating environment. That is exactly what has happened.

4. The St George Wharf development is relevant to the above current application because the land plot concerned is the only small area of open space left near the transport interchange and major road network dominating the area between the riverside developments and the railway viaduct. Air quality is already very poor (see the statistics in the Mayor for London’s Vauxhall & Nine Elms Opportunity Area report). It will only deteriorate further.

5. Both British Rail and TFL state that transport links are at capacity and do not foresee any way to improve them. Permission for so many homes, especially with limited parking, on the island site will put more pressure on the transport system, further reducing the quality of life for residents and office workers alike.

6. Very tall buildings, approved and proposed, are generally more suited to office accommodation than to housing, yet the proportion of housing being provided is large. There is a mismatch between the type of residential accommodation that can be provided in very tall buildings and the housing needs of significant sections of the local population. High-rise flats do not provide suitable accommodation for families. In this case there is far too little amenity public space to prevent the area feeling overcrowded and oppressive, for daytime office workers as well as for local residents.

Specifically, there is a deficiency of open and green space in line with Lambeth’s own policy and taken with other developments such as Bondway, the building on the island site would reduce the effective space to half the recommended area of 1.6 hectares per thousand of the population.

The application statements refer to ‘a new landscaped public square’ – a totally fanciful description given the modest space available – and ‘cultural uses, improved public realm and community benefits’ – all big words for what we regard as token gestures.

7. There is also a deficiency of playspace. Development for families should include a MINIMUM of 10 square meters of DEDICATED children’s playspace per child, preferably indoors. This is the equivalent of a small children’s playground. Presumably there will be children in the development.

8. The applicants admit (in their Design and Access statement) that they ‘recognise that these provisions [of amenity space attached to the development] will not satisfy Lambeth Borough Council’s requirements for providing public amenity space. Kylun have entered into S106 discussions . . .’ It is our view, however, that no S106 payments for (as is being proposed) public amenity space improvements elsewhere will alter the fact that there would be inadequate public amenity space on and around the island site. The proposed development does not add any adequate open space. It would reduce existing open space.

To sum up, our main reasons for opposing this application are:
(i) It is clear from KOV Forum meetings that there is widespread public concern about the concentration and very high densities of high-rise developments at and near Vauxhall Cross.

(ii) Recent, planned and proposed new development in this area has largely resulted in a lost opportunity to upgrade an area that cried out for sensitive re-use of redundant and neglected industrial land and a riverfront with great potential.

(iii) The combination of excessive densities and over-development of land, with virtually no open ground space between buildings is creating a hostile environment.
(iv) There is a mismatch between need and supply of family housing.

(v) The planning application for the island site describes in misleading terms its proposals for an extremely small amount of ground-level public amenity space. In context that small area would be dominated by the two tower blocks, with no sense of the open space residents and office workers should reasonably expect when they approach or leave their building.

(vi) The development would put further pressure on transport links already at capacity.

(vii) The amount of amenity space proposed in relation to this development does not meet the Council’s planning requirement and is acknowledged by the applicant.
If the proposed development provides too little amenity space on a small land plot surrounded and enclosed by high and bulky buildings, the railway viaduct and a major road network and junction, it is surely per se an unacceptable development.

Yours sincerely
Maureen Johnston MBE
Chair of Kennington, Oval and Vauxhall Forum