Document B Grounds of Appeal 1. This appeal is against the London Borough of Lambeth to refuse planning permission for the redevelopment of 81 Black Prince Road for the erection of a 23 storey building comprising 1770 sqm of commercial floorspace and 101 residential units (application reference: 08/04454/FUL). n For each of the reasons for refusal set out in the Council’s decision letter, the grounds of appeal are as follows: Reasons for Refusal 1 and 2 The proposal, by reason of its height, bulk, scale and form would fail 10 preserve the setting and character of the Grade Il Southbank House and the London Fire Brigade Headquarters. As such, the proposal is contrary to Policies 33, 40, 41 and 45 of the Lambeth Unitary Development Plan (2007) The proposal, by reason of its height, bulk, scale and form, would fail 10 preserve or enhance the character or appearance of the Albert Embankment Conservation Area. As such, the proposal is contrary to Policies 33, 40, 41, 47 and 58 of the Lambeth Unitary Development Plan (2007). 3. The impact of the proposed building on the setting of the listed buildings and conservation areas was considered by the Townscape and Visual Impact Assessment, undertaken by Professor Robert Tavernor in support of the planning application. It is considered that the proposed development would not be harmful to the Grade II listed South Bank House and London Fire Brigade Headquarters and would relate well to the local conservation areas. Therefore, it is considered that the proposals comply with both Policies 45 and 47 of the Lambeth UDP, which relate to the preservation of the setting and character of listed buildings and conservation areas.4. Policy 33 of the adopted Lambeth UDP outlines the criteria for assessing the suitability of application sites for high density development and states that major development should relate to adjacent townscape taking into consideration scale and character. Given the regeneration aims for the Albert Embankment and the recent consents granted for other tall buildings in the area, it is considered that the proposed 23 storey building relates well to character of the Albert Embankment and complies with Policy 33 with respect to townscape, The development is of high quality, the layout, bulk, massing and detailed design of the proposed building is appropriate to its location and the proposed development will make a positive contribution to the street scene. 5. Policy 58 of the UDP relates directly to the Albert Embankment and notes that this is a key stretch of Lambeth’s Thames frontage and is the focus for several major development proposals. The policy seeks to encourage development which helps to overcome the ‘barrier effect’ which has been created by a monotonous wall of post-war office buildings built to a poor standard. The proposed building has been designed as a sculpted pinnacle which adds positively to the background setting of Albert Embankment and therefore complies with Policy 58. 6. The UDP places great emphasis on the capacity of tall buildings to act as a catalyst for regeneration in the area and the proposed building would seek to fulfil these aims. Policy 40 of the UDP relates to tall buildings and sets out a number of criteria which proposed buildings need to meet, including their impact on conservation areas and listed buildings. The development has been designed to the highest architectural quality and will enhance the skyline through its elegant profile and use of materials. Further justification for the height of the building is set out within the Design and Access Statement, submitted in support of the application. Therefore, it is considered that the proposed building would meet the criteria set out in Policy 40. Additionally, it is considered that the proposed development would not harm the setting and character of the adjacent conservation area and listed buildings by virtue of its height, bulk, scale and formReason for Refusal 3 The proposal, by reason of its height, roofline, form, scale, shape, and silhouette would have an adverse impact on the setting of the Palace of Westminster and Westminster Abbey World Heritage Site. In particular, the development would undermine the important setting of St Stephen's Tower by introducing an incongruous feature amongst the established skyline as viewed down Whitehall from Trafalgar Square. As such, the proposal is contrary to Policy 40, 41 and 58 of the Lambeth Unitary Development Plan (201 The planning application was supported by a Townscape and Visual Impact Assessment, which concluded that the proposed development would not have any harmful effect on the Westminster World Heritage Site, nor would it harm the setting or visibility of the World Heritage Site, either in the protected statutory views or other important views which were selected. The proposed building is not considered to be incongruous and has a negligible impact on the skyline as viewed down Whitehall from Trafalgar Square. As such, the proposals are. said to be compliant with Policies 40, 41 and 58 of the UDP. Reason for Refusal 4 The proposal, by virtue of the failure to incorporate communal amenity space and children’s play space of sufficient quality and quantity, would fail to provide a satisfactory residential environment for future occupiers, particularly with regard to families and children, contrary to Policies 33(d) and 50(j) of the Lambeth Unitary Development Plan (2007), the Council's Supplementary Planning Document “Guidance and Standards for Housing Development and House Conversions”, together with Policy 3D.13 of the London Plan and the Mayor of London's associated Supplementary Planning Guidance “Providing for Children and Young People’s Play and Informal Recreation. ” . Reason 4 for refusal is unreasonable. The treatment of the open space is of a sufficient high quality. The applicant submitted amended plans, which included the provision of 130 sqm of door stop child playspace for children under 5 years