Fight the proposal for 11 Storeys on Montford Place - Update

Fight the proposal for 11 Storeys on Montford Place - Update

Ref 20/01086/FUL

Heritage and Design Critique report

Thank you very much to those who have contributed towards the cost of the report. It is complete and was submitted to the Council on Tuesday morning, together with the comments below. Pending resolution of IT issues there, it should be available to download from the Lambeth website. 

The report makes it clear that this development would indeed result in instances of substantial harm to the heritage assets, which definitely helps our case.

Any more donations to the crowdfunder would be very welcome to close the gap a little between the £2,280 currently raised and the final cost which was £3,300. Link: https://www.gofundme.com/f/fight-the-proposal-for-11-storeys-on-montford-pl and I can send donors a copy of the report. 

Objections

There are over 70 objections registered on the Council’s website. There is still time to submit yours if you haven’t yet done so. The link is: https://planning.lambeth.gov.uk/online-applications/applicationDetails.do?activeTab=makeComment&keyVal=Q7PD4BBO08P00  or you can email Case Officer Cuma Ahmet: CAhmet@Lambeth.gov.uk. 

There is a list of objections on the GoFundMe page linked above - feel free to copy and paste if you don’t have time to write your own. 

Comments submitted to the Council on the heritage aspects of this proposal

We believe that the proposed development would result in an unacceptable amount of harm as identified in NPPF para 194 i.e. harm to, and loss of, the significance of designated heritage assets, resulting from development within their setting. 

• The applicant aspires to deliver 3,000 homes across a portfolio of 7 sites in London, i.e. they are building in bulk. However Montford Place is the smallest and most sensitive site in the portfolio. Building in bulk is not appropriate here and even with this very tall proposed scheme the site remains insignificant in terms of providing homes for Londoners. 
• The Independent Expert’s report identifies numerous instances of harm that would result from the proposed development. This harm includes instances of substantial harm. NPPF para 194 says that any harm to the significance of a designated heritage asset from development within its setting requires clear and convincing justification, which has not been provided; furthermore, the heritage assets include grade II and grade II* listed buildings, for which NPPF paras 194 (a) and (b) require exceptional and wholly exceptional justification, so the justification is all the more insufficient. 
• The site is within Kennington Conservation Area (CA), which has London-wide significance and is noted for its smart terraced housing. If permitted, this development would be roughly double the height of any other building in the entire CA. This would set an extremely unfortunate precedent which would conflict with the very reason for the designation of the CA and could result in erosion of its fundamental character as the Council will be less able to resist tall developments within it. 
• Contrary to paras 184 and 185 of the NPPF, the proposal fails to preserve or enhance the character or appearance of the CA, as the development would neither make a positive contribution nor leave it unharmed. 
• The circumstances, relevant policies, and legal framework are wholly different at this site when compared to the consented Oval Gas Works and Tesco Kennington sites (the "Berkeley” sites). Unlike the Berkeley sites, this site is surrounded on three sides by nationally listed buildings and one locally listed building, and is within the CA. The Berkeley sites are providing 1,300 housing units; this proposal would provide just 139. 
• It may be argued that the Berkeley developments harm the same heritage assets as the proposed development would. However, this is no justification to substantially increase the harm by allowing this present application to proceed. 
• The application documents confirm that the site has a value of £5.6 million if developed in line with existing policy.  Therefore there is no justification in viability terms to inflict the proposed harm. 
• We do not believe the proposed development would meet the statutory tests as set out in case law (South Lakeland DC, Bath Society, Barnwell Manor and Forge Field cases), as detailed in the Independent Expert’s report.  
• Therefore, and to quote from the Independent’s Expert’s report, we respectfully request that Lambeth Council reject this harmful scheme and encourage a much lower scale development that respects the quality and character of the Kennington Conservation Area, respects the scale of the existing surrounding buildings, and minimises the harm to the numerous heritage assets that surround this site.