The Site Allocations Development Plan Document
1.1 Once adopted, the Site Allocations Development Plan Document (SADPD) will be part of the statutory development plan for Lambeth, alongside the Lambeth Local Plan 2021, the London Plan 2021 and South Bank and Waterloo Neighbourhood Plan 2019. It will therefore be part of the suite of planning policy documents that help deliver sustainable growth and investment in Lambeth. It will support implementation of wider Council strategies including the Borough Plan, Economic Resilience Strategy, Transport Strategy and emerging Climate Action Plan.
1.2 The principal objective of the SADPD is to unlock investment through the mechanism of site-specific planning policy.
1.3 This Draft of the SADPD adds site-specific policies to those already in the Lambeth Local Plan 2021. The SADPD should be read, and policies will be applied, alongside and in conjunction with the rest of the development plan for Lambeth, namely the London Plan, Local Plan and made neighbourhood plans.
1.4 The Draft SADPD includes policies for fourteen sites, distributed across the borough as shown on Map 1. Of these sites, three have existing allocations in the Lambeth Local Plan 2021: Royal Street (Site 1); Gabriel’s/Princes Wharf (Site 9) and Norwood Road (Site 18). These existing allocations will be superseded on adoption of the SADPD. The other existing allocations within the Local Plan 2021 are unaffected by the SADPD and will remain as they are in the Local Plan.
1.5 The numbering of the proposed allocations in the Draft SADPD is designed to work alongside the numbering of the existing allocations in the Local Plan 2021. See Annex 1 for a full list of the site allocations in both the Local Plan 2021 and the Draft SADPD.
1.6 Preparation of the SADPD is the same as that for the recently adopted Lambeth Local Plan 2021. This involves a number of stages required by the regulations governing plan preparation. In summary, these include:
• Consultation on the subject of the DPD (Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012).
• Consideration of representations received and revisions to the draft document.
• Agreement by the Council of the version it intends to submit for examination (SADPD Proposed Submission Version).
• Publication of the proposed submission version of the SADPD, along with an open invitation to submit representations (Regulations 19 and 20).
• Submission of the proposed DPD and supporting documents to the Secretary of State, along with any representations received at pre-submission publication (Regulation 22).
• Independent examination by a planning inspector on behalf of the Secretary of State; this involves an assessment against legal and procedural requirements and consideration of the ‘soundness’ of the plan against four tests.
• Assuming the Plan is found to be ‘sound’ by the inspector, adoption of the Plan by the Council.
National Planning Policy Framework
1.7 Government sets out national planning policy in the form of the National Planning Policy Framework (NPPF). The latest version of the NPPF was published by government in July 2021. Local development plan documents must be consistent with national policy. The NPPF is also a material consideration in the determination of planning applications.
1.8 The proposed submission version of the SADPD will be examined by an independent planning inspector whose role is to assess whether the plan has been prepared in accordance with legal and procedural requirements, and whether it is sound. A ‘sound’ plan must be:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the NPPF.
The London Plan
1.9 The London Plan is the spatial development strategy for London, produced by the Greater London Authority on behalf of the Mayor of London. London borough development plan documents must be in general conformity with the London Plan. All references to the London Plan in this Draft SADPD relate to the London Plan 2021.
Duty to Co-operate
1.10 The Localism Act 2011 and the tests of soundness in the NPPF require public bodies, including local planning authorities, to co-operate on planning issues that cross administrative boundaries, particularly those that relate to strategic priorities such as housing, retail and commercial development, infrastructure, climate change and conservation and enhancement of the natural and historic environment.
1.11 Lambeth has borders with the Cities of London and Westminster, and the London boroughs of Southwark, Bromley, Croydon, Merton and Wandsworth. Each of these authorities has its own local plan at various stages of preparation or review. Lambeth engages periodically with these boroughs, and with other public bodies such as the Environment Agency and Historic England, to help achieve a full assessment of cross border issues and strategic alignment of objectives and policies. In addition, they will be formally consulted at each stage of preparation of the SADPD. Statements of Common Ground will be agreed to support the examination of the SADPD.
Rationale for allocation of sites
1.12 Sites are included in this Draft SADPD for one or more of the following reasons:
• to set clear, site-specific parameters for the type and scale of development expected on a site, including the associated public benefits it should deliver;
• to address site-specific circumstances that may require a more tailored approach to that set out in borough-wide policies;
• to articulate the vision and potential that can be achieved through land assembly and/or a comprehensive approach to developing adjacent sites, particularly where these are in different ownerships;
• to encourage landowners to consider the potential for optimising the development capacity of their land and help deliver key placemaking objectives;
• to signal some additional sites as appropriate for tall buildings, outside the locations already identified in the Local Plan; and
• to enable key strategic infrastructure to come forward in a timely way.
1.13 It is not necessary to have a site-specific allocation for every potential development site in Lambeth. Many larger sites can and do come forward successfully without such a policy, with sustainable development achieved through application of the borough-wide and neighbourhood-level policies in the development plan as a whole.
1.14 There is also no need in Lambeth to allocate sites to demonstrate the borough’s ability to meet its London Plan housing target, as this was achieved through the recent examination of the revised Lambeth Local Plan. However, the new site allocation policies will help to accelerate delivery of housing in the borough, maintain the necessary pipeline of new housing and thereby ensure housing delivery targets continue to be achieved. They will also enable the timely renewal and optimisation of social infrastructure and commercial floorspace.
1.15 The guiding approach in developing the draft site allocation policies is design-led optimisation of development capacity, as required by London Plan Policy D3.
1.16 This has involved analysis of the optimum mass and height that can be achieved on each site, having regard to site-specific planning constraints including impacts on neighbouring uses, views, townscape and heritage assets. An evidence base has been prepared to support the Draft SADPD and explain how design-led optimisation of development capacity has been approached on each of the sites. References to building heights should be read in the context of the definitions in Local Plan Policy Q26. Building heights are expressed in metres rather than storeys because floor to ceiling heights vary according to the use of a building. As a very approximate rule of thumb, a typical residential floor to ceiling height is in the order of 3 metres and a commercial one is between 3.5 and 4 metres.
1.17 Key spatial planning objectives have been factored in and identified for each of the sites. This includes for example: strategic place-making and contribution to implementation of the relevant policy for Places and Neighbourhoods; inclusion, accessibility and permeability in the public realm; healthy routes and active travel; community safety; townscape and design quality, including contribution to local distinctiveness; and urban greening.
1.18 Existing development plan standards and requirements for matters such as sustainable design and construction, urban greening, zero carbon, climate change adaptation, housing quality, amenity space, child-friendly design, parking & transport and employment & skills will apply to these sites, but the policies in this Draft SADPD signal a clear expectation for exemplary approaches in meeting these standards. In many cases direct cross references are included within the draft site allocation policies, however relevant borough-wide policies and standards will apply even if they are not specifically referenced. Mayoral Supplementary Planning Guidance and Lambeth Supplementary Planning Documents will also apply in full to all of the sites included in this Draft SADPD. Where necessary and justified, the Council will use conditions and/or planning obligations to limit uses consented within Class E to achieve the objectives of the site allocations and other development plan policies.
1.19 The Council is in the process of developing a Climate Action Plan for the borough. The next version of this Draft SADPD will include appropriate reference to the Lambeth Climate Action Plan once it has been prepared, in order to contribute to its delivery.
Format of the site allocations
1.20 The site allocations in this Draft SADPD are presented in the following format:
• Contextual information, including area and site-specific maps showing relevant policy designations, constraints and opportunities.
• A brief statement of the vision for the site, highlighting the opportunity presented by its redevelopment and its potential to contribute to strategic place-making.
• The site allocation policy, setting out the requirements and expectations for the site.
1.21 Emerging development plan documents must undergo a statutory sustainability appraisal. This is a systematic process that aims to promote sustainable development by assessing the extent to which the emerging plan, when judged against reasonable alternatives, will help to achieve relevant environmental, economic and social objectives. This includes consideration of impacts on equality and health and well-being. The sustainability appraisal of the Draft SADPD has been published for comment alongside the draft plan. The sustainability appraisal of the proposed submission version of the SADPD will undergo examination alongside the SADPD itself.
Strategic and local policies
1.22 The NPPF requires local development documents to identify which policies are ‘strategic’ and which are ‘local’, to assist groups preparing neighbourhood development plans. All the policies in this Draft SADPD are strategic because they contribute to achieving London Plan and Local Plan strategic objectives across the borough.
1.23 Following adoption of the SADPD, progress with implementation of the site allocations will be reported in the Council’s annual Authority Monitoring Report