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ADDRESS - Lambeth … · ADDRESS: Archbishop’s Park, Lambeth Palace Road, London, SE1 7LF Application Number: 18/00793/FUL Case Officer: Rositsa Malinova Ward: Bishops Date Received:

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Page 1: ADDRESS - Lambeth … · ADDRESS: Archbishop’s Park, Lambeth Palace Road, London, SE1 7LF Application Number: 18/00793/FUL Case Officer: Rositsa Malinova Ward: Bishops Date Received:
Page 2: ADDRESS - Lambeth … · ADDRESS: Archbishop’s Park, Lambeth Palace Road, London, SE1 7LF Application Number: 18/00793/FUL Case Officer: Rositsa Malinova Ward: Bishops Date Received:

ADDRESS: Archbishop’s Park, Lambeth Palace Road, London, SE1 7LF

Application Number: 18/00793/FUL Case Officer: Rositsa Malinova

Ward: Bishops Date Received: 18 February 2018

Proposal: Erection of a Zip Line development for a temporary period between 8 May 2018 and 14 September 2018 (18.5 calendar weeks).

Drawing numbers:

Drawing 1; Drawing 2; Drawing 3; Drawing 4-Rev 0; Drawing 5-Rev.0; Drawing 6; Drawing 7; Drawing X; Drawing Y; Plan 1; West Elevation of Entire Zip Line end-to-end; Max mass of zip line; 5037/02; 3483/03 Rev. A; ACORN-BALLAST-BLOCK-V1.2V; ACORN-BALLAST-BLOCK-V1.1B; 17/0501-04D; 17/0501-05P; 17-0501-06P; 17/0501-07P; View point locations ABP L-1; ABP L-2A; ABP L-2B; ABP L-3A; ABP L-3B; ABP L-4; ABP L-5; ABP L 6; ABP L-7.

Documents:

Design & Access Statement, SLR, February 2018;

Planning Statement, SLR , February 2018;

Heritage Statement, SLR , February 2018;

Additional Specifications Document, SLR , 2018;

Ecological Impact Assessment, SLR , February 2018;

Event management Plan, SLR , December 2017;

Flood Risk Assessment, SLR , February 2018;

Noise Assessment, SLR , February 2018;

Arboricultural Impact Assessment, SLR , February 2018;

Transport and Crowd Management Plan, SLR , February 2018;

Archbishop’s Park Socio-Economic Effects Study, SLR, January 2018;

Noise Assessment, SLR, January 2018;

Photographs from the 2017 event.

RECOMMENDATION:

1. Resolve to grant planning permission, subject to conditions.

2. Agree to delegate authority to the Director of Planning, Transport and Development to finalise the recommended conditions as set out in this report including such refinements, amendments, additions and/or deletions as the Director of Planning and Development considers reasonably necessary.

Applicant: Mr Barry Shaverin The City Zip Company Limited 10 Finsbury Square London EC2A 1AJ

Agent: Mr Edward Bright SLR Consulting Limited 3rd Floor, Brew House Jacob Street Bristol BS2 0EQ

Page 3: ADDRESS - Lambeth … · ADDRESS: Archbishop’s Park, Lambeth Palace Road, London, SE1 7LF Application Number: 18/00793/FUL Case Officer: Rositsa Malinova Ward: Bishops Date Received:

SITE DESIGNATIONS

Relevant site designations:

Conservation Area - CA10 : Lambeth Palace Conservation Area

Environment Agency Flood Zone 3

Locally Listed Building - Entrance Gate To Archbishop’s Park Lambeth Road SE1 7LE

Locally Listed Building - Timber Shelter At South End Of Archbishop's Park

Neighbourhood Planning Areas - Southbank And Waterloo Neighbours Forum (SOWN)

Opportunity Area - London Plan Waterloo Opportunity Area

Sites of Borough Nature Conservation Imp - Lambeth Palace Gardens SNCI

Sites of Local Nature Conservation Imp' - Archbishop’s Park - SNCI

London Plan Thames Policy Area - Thames Policy Area

Tree Preservation Order - Tree Preservation Order 452 - Archbishop’s Park

Archaeological Priority Areas - Archaeological Priority Areas

Central Activities Zone - Central Activities Zone

Historic Parks & Gardens on Eng Her Reg - Historic Parks And Gardens (on English Heritage Register)

Protected Vistas - Primrose Hill Summit To The Palace Of Westminster - 4A.2

LAND USE DETAILS

Site area 2.25 Hectares (22,500 square metres)

Use Class Use Description

Existing D2 (Assembly and Leisure) Archbishop’s Park

Proposed Sui Generis Zip Line visitor attraction

EXECUTIVE SUMMARY

This application is for the erection of a ”zip line” visitor attraction in the Archbishop’s Park, which would operate for a temporary period between the 8th May 2018 and the 14th September 2018. The zip line structure would consist of a “launch tower”, which would connect to a “landing tower” via three zip line cables (plus six safety cables). The proposal would also include entrance and staff marquees and three open sided gazebos where visitors would prepare before going on the zip line. The attraction could accommodate up to 90 “flyers” per hour.

A similar scheme was approved on the application site by the Planning Applications Committee (PAC) on 24 July 2017 (LBL ref. 17/02067/FUL). It also featured two towers with three zip lines and operated from 18 July 2017 to 1 October 2017 between 10am and 7pm. The PAC resolved to grant planning permission subject to an informative requesting the applicant to engage with the Friends of Archbishop’s Park and the council to find ways of evaluating and monitoring the impact of the zip line on users of the park. In response the applicant has submitted a Socio-Economic Effects Study (January 2018), which addresses this matter.

Archbishop’s Park is a public park and contains a large children’s playground, football pitches, tennis courts and lawn areas. It is located within the Central Activity Zone, and the Lambeth Palace Conservation Area. Neighbouring uses include to the Lambeth Palace gardens, the Grade I Listed Lambeth Palace, Ronald McDonald House, the Grade II Listed St Mary’s Rectory, residential and light industrial buildings and a car park.

The proposed use of the park for this type of temporary visitor attraction is considered to be acceptable by officers because it would be consistent with local policies, which support visitor attractions located within the Central Activity Zone.

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The proposed launch and landing towers, together with the marquees and gazebos would occupy a total area of approximately 810 square metres (or 2.2%) of the lawn within the Archbishop’s Park. Officers consider that this would be acceptable because the loss of park space available to the public would be temporary, the proposed zip line would not harm the normal function and operation of the park, and there would be no long term harm to the grass, soil and trees.

The council’s conservation and design officers have advised that the proposed zip line would result in ‘less than substantial’ harm to the Lambeth Palace Conservation Area, because the proposed towers would detract from the leafy character of the park. There would be no harm to other heritage assets.

In accordance with the tests set out at paragraph 134 of the NPPF, officers have found that the public benefits of the scheme would outweigh the harm to the Lambeth Palace Conservation Area. The public benefits include:

Economic benefits, such as: increased spending in the vicinity of the Waterloo Area; direct and indirect employment opportunities; and bringing income into the park;

Social benefits, such as: support for charities and organisation to raise awareness and/or funding of different causes; raising awareness and use of the sport facilities at Archbishop’s Park; and

Environmental benefits, such as: enhancement of the park by generating income to be used for soil improvement, new planting beds and shrubs. This would increase nesting sites and provide necessary food sources for birds, invertebrates and insects.

Officers have been mindful of the proposed zip line’s impact on the amenity of adjoining residential properties and consider, subject to conditions, that the proposed development would not result in any unacceptable impacts including increase of noise, loss of daylight or sunlight, overlooking or loss of privacy. In addition the council’s transport officer has confirmed that the proposal would not result in any unacceptable transport impacts, given that it is expected that most users would arrive on foot or by public transport.

Officers consider that the proposal would be in general compliance with the Development Plan for the Borough. There are no material considerations of sufficient weight that would dictate that the application should be refused. Officers are therefore recommending approval of the scheme in accordance with the presumption in favour of sustainable development conferred upon Local Planning Authorities by the National Planning Policy Framework (NPPF), subject to the Conditions and Informatives detailed at Sections 10 and 11 of this report of this report.

Page 5: ADDRESS - Lambeth … · ADDRESS: Archbishop’s Park, Lambeth Palace Road, London, SE1 7LF Application Number: 18/00793/FUL Case Officer: Rositsa Malinova Ward: Bishops Date Received:

OFFICER’S REPORT

Reason for referral to PAC: The application is reported to the Planning Applications Committee in accordance with section 1(iii) of the Committee’s terms of reference due to the site having an area exceeding 1 hectare.

1 SITE AND SURROUNDINGS

1.1 The Site

1.1.1 The application site is located within the Archbishop’s Park, which is a 3.74 hectare public park containing tennis courts, a large children's playground, football pitches and lawn areas of approximately 2.42 hectares available to the wider community for recreation and leisure. The application site relates to approximately 2.25 hectares (shown in red in the image below) of the Archbishop’s Park.

Figure 1 – Site context, source: Google maps, 2018.

1.2 The Surrounds

1.2.1 Archbishop’s Park neighbours the Lambeth Palace, St Thomas’ Hospital, the Evelina London Children’s Hospital, residential sites and railway tracks. The park is bounded by Lambeth Palace Gardens and Lambeth Palace Road to the west, Lambeth Road to the south, and Carlisle Lane to the north-east.

1.2.2 The application site is located within the Lambeth Palace Conservation Area, in close proximity to a number of statutorily listed buildings, including the Grade I listed Lambeth Palace. It is a local space of heritage value located in an archaeological priority area.

1.2.3 The site contains many mature trees and is subject to a Tree Preservation Order (number 452). The site is a Site of Importance for Nature Conservation (SINC).

2 PROPOSAL

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2.1 This application seeks full planning permission for the erection of a ‘zip line’ development for a temporary period between 8 May 2018 and 14 September 2018 (18.5 calendar weeks).

Figure 2 - Proposed site plan

2.2 The proposed temporary zip line visitor attraction is similar to the temporary zip line approved by the Planning Applications Committee (PAC) in 2017 under reference: 17/02067/FUL. The proposed zip line would cover an area of 810 square metres, and it would be 232m in length, crossing the park in an approximate north-south alignment between two tower structures. It would have a total of three zip cables (plus six safety cables), which would have a ride length of 225m. It would include the following:

Launch tower with a height of 35.32m and a landing tower with a height of 15.63m. The ‘launch tower’ is proposed to be located within the northern part of the park, between Lambeth Palace Road and the tennis courts. The ‘landing tower’ will be located at the south side of the park, in an area partially screened

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by mature trees. The route of the zip line would pass over the playground, football pitches and lawn (shown on the image above). The proposed towers would be constructed of steel frames covered in green screens for camouflage. The towers would have ballasts disguised by timber hoarding to the base and platforms at the top. The area occupied by the towers would be approximately 178 square metres.

Figure 3 - Proposed Landing and Launch Towers

A feature known as a powerfan would be installed into the landing tower, which was not part of the 2017 proposal. This would provide visitors taking the zip line ride with the opportunity to freefall to the ground, rather than taking the landing tower stairs.

Figure 4 - Powerfan

Reception and safety area which would consist of: o an entrance marquee containing reception and check-in area, safety

briefing area, lockers and visitor experience desk; o a staff marquee containing a storage area, ancillary office and staff rest

area; o Three open sided gazebos for preparing visitor for the zip line and safety

checks; and o Five portable toilets.

Lighting – the proposal would include lighting within both tower structures and within the marquees. The lighting would only be operated between 13 August 2018 and 9 September 2018, and between hours 7:30pm and 9pm.

Sound Barrier – the proposal would include lighting generator at the base of the launching tower, and a temporary sound barrier is proposed to mitigate any unacceptable increase of noise. The sound barrier would be in place between 13 August and 9 September 2018, which is the period when lighting is proposed.

2.3 The table below provides a comparison between the zip line event in 2017 and the proposed zip line in this application.

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Zip Line 2017 (Application)

Zip Line 2017 (Operation)

Proposed Zip Line 2018

Period 24th June – 3rd October 2017

24th June – 6th October 2017 (overrun on take down process)

8th May – 14th September 2018

Operation 7th July – 1st October 2017

18th July – 1st October 2017 (overrun on site set-up & waiting for planning committee)

22nd May – 9th September 2018

Days Open (not including site set-up and take down)

87 days 76 days 111 days

Construction duration

13 days 25 days (delay due to building regs sign off, safety checks and planning committee)

14 days

Take down duration

2 days 5 days 5 days

Hours of operation

Weekdays: 10:00 – 19:00

Weekends: 10:00 – 19:00

Weekdays: 10:00 – 19:00

Weekends: 10:00 – 19:00

Weekdays: 12:00 – 20:00

Weekdays (4th June – 15th July): 12:00 – 20:30

Weekends: 10:00 – 20:00

Staff on-site Weekdays: 09:00 – 19:30

Weekends: 09:00 – 19:30

Weekdays: 09:00 – 19:30

Weekends: 09:00 – 19:30

Weekdays: 11:00 – 21:00

Weekdays (4th June – 15th July): 11:00 – 21:30

Weekends: 09:00 – 21:00

Zip lines 3 zip lines (6 safety line)

2 zip lines (4 safety lines)

3 zip lines (6 safety lines)

Employees 50 staff members estimated

53 staff members employed during event

55 staff members estimated

Total visitors (customers / riders)

Theoretical maximum of 70,000 visitors anticipated (based on a maximum throughput of 90 riders per hour)

Approximately 32,350 (lower due to reduction to 2 no. lines and shorter operating period) – Theoretical maximum based on reduced operating was 41,040 (78.8% running capacity)

Estimated 40,00-58,000 – Theoretical maximum of 84,000 (higher than 2017 theoretical maximum due to longer operational period)

Page 9: ADDRESS - Lambeth … · ADDRESS: Archbishop’s Park, Lambeth Palace Road, London, SE1 7LF Application Number: 18/00793/FUL Case Officer: Rositsa Malinova Ward: Bishops Date Received:

Worst case scenario visitors per hour

90 flyers + 90 watchers = 180 visitors

Due to reduction in lines to 2: 60 flyers + 60 watchers = 120 visitors

90 flyers + 90 watchers = 180 visitors

Staff per hour (maximum during shift change)

15 staff members anticipated

17 staff members 21 staff members anticipated

Lighting No Yes – temporary lighting was installed during the autumn months with consent from the Parks Department

External temporary lighting proposed in accordance with existing park lighting to assist with walking routes

Music No No No

‘Powerfan’ No No ‘Powerfan’ is proposed

Cycle parking 5 No. Sheffield style hoops – 10 no. cycle parking spaces

5 No. Sheffield style hoops – 10 no. cycle parking spaces

5 No. Sheffield style hoops – 10 no. cycle parking spaces

2.4 In 2017 members of the PAC resolved to grant planning permission (LBL ref. 17/02067/FUL) for a similar scheme, subject to an informative requesting the applicant to engage with the Friends of Archbishop’s Park and the council to find ways of evaluating and monitoring the impact on users of the park. In response, the applicant has submitted a Socio-Economic Effects Study (January 2018), which covers the following topics: the increase in visitor and popularity of Archbishop’s Park; the potential amenity and transport impacts; the expenditure in the local supply chain as a result of the event; employment generation; and publicity. The Socio-Economic Effects Study will be referenced throughout the assessment contained in section 6 of this report.

3 RELEVANT PLANNING HISTORY

3.1 90/00581/PLANAP - Application Permitted - Decision date: 31.October.1990

Improvements to park including relocation of playground extension of park along frontage of Lambeth Palace Road, to enclose existing open space within new low wall and railings.

3.2 09/02443/RG3 - Application Permitted - Decision date: 24.December.2009

Improvements to existing park play area including the provision of seating, tables, play equipment and landscaping works.

3.3 15/02280/RG3 - Application Permitted - Decision date: 13.July.2015

Combined application for Full Planning permission and Outline application for refurbishment of sport facilities and associated buildings comprising:

1) Full planning permission for upgrade of sport facilities to include a 3G surface pitch area, a macadam surface mixed use games area, cricket nets and equipment storage area, all surrounded by sports pitch fencing. New floodlighting for the proposed pitches and new mixed use games area. Refurbishment of changing rooms building to include community space, changing rooms, public toilet facilities and sports management office. Associated soft and hard landscaping.

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2) Outline application (with all matters reserved) for demolition of the existing WC block and replacement with Use Class A3 cafe of up to 100m2 (Relevant area shown hatched on enclosed plan 13075-01-001).

3.4 17/02067/FUL - Application Permitted - Decision date: 24.July.2017

Erection of a temporary zip line development for a period of 14 calendar weeks and 4 days in total. (Planning Applications Committee date: 18.07.2017)

The above planning permission contains an informative requesting the applicant to engage with the Friends of Archbishop’s park and the Council to find ways of evaluating and monitoring the impact on users of the park. To address this the applicant provided a Socio-Economic Effects Study, prepared by SLR, dated January 2018.

4 CONSULATIONS

4.1 Adjoining owners/occupiers

4.1.1 Public consultation was undertaken in accordance with statutory and Council requirements. This included letters to neighbours, site notices and a press advert.

Number of neighbours consulted: 105 Number in support: 16 Number of objections: 10 Number neither supporting nor objecting: 0

4.1.2 The Council received 16 comments in support, which can be summarised as follows:

Comments Officer’s response

The zip line event in 2017 was a good attraction, fun activity and did not attract a bad crowd. It was well organised and it brought life to the park and some visitors enjoyed watching it.

Noted.

Residents did not notice the present of the zip line in 2017, and did not cause issues for neighbours.

Noted.

A local shop owner enjoyed the zip line and advised the zip line brought visitors to their shop and looks forward to a return.

Noted. The increase in spending in the area is a public benefit, which is discussed in section 6.5.14 of this report.

A local business expressed their support for the zip line and advised the applicant have been pro-active in communicating with the local community and approached local businesses to discussed opportunities and partnerships.

Noted. The partnership between the organisers of the zip line and local businesses is welcomed. The support for charities and other organisations is a public benefit, which is discussed in section 6.5.21 of this report.

The proposed attraction brings people to the park, and some of the families found the zip line a very welcome distraction from severely stressful times.

Noted.

4.1.3 The received 10 comments in objection, which can be summarised as follows:

Comments Officer’s response

Archbishop’s Park is not a suitable location for the proposed zip line.

The suitability of a temporary visitor attraction in the park is discussed in section 6.1 of this

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report. In summary, Archbishop’s Park is an open space located within the Central Activity Zone, and the proposal for a temporary attraction is acceptable in principle. Impacts on amenity and the park are discussed at sections 6.7 - 6.8 of this report. In summary officers conclude, subject to conditions, that the proposal would not have any unacceptable impacts on the park (including its usability and biodiversity) or the amenity of surrounding residential properties.

The proposed zip line and associated buildings are obstructive and out of character. The proposed development is too big and dominates the small green spaces on both ends of the park.

This matter is discussed in section 6.5 of this report. In summary, although the proposed towers are tall, they have been camouflaged with green and timber materials to blend in with surrounding trees, and the structures would not unacceptably impact on the open feel of the park and the wider area. Most views of the towers and lines would be obscured by the trees in the park.

The proposal would result in an increase of noise. The scheme would disturb the quality of life of local residents. Residents living in York House were woken up from 7am by screaming people going down the zip line which continued to 8pm. The event also frequently went over its agreed hours of operation. This has impact on ill and venerable residents and increases leads to increased stress levels. The zip-line installation has a diesel-powered generator running next to the main marquee on the central lawn, producing noise, noxious fumes and potentially carcinogenic particulates all day long.

The submitted Noise Impact Assessment concluded that the proposal would not result in unacceptable impact to neighbouring properties subject to the installation of a sound barrier. Condition 12 is recommended to secure this sound barrier. In addition Condition 5 is recommended to restrict the hours of operation to ensure there is no noise in the morning or late in the evening.

Archbishop’s Park is a peaceful park and the zip line felt like an invasion when it appeared last year. The zip like has an impact to the quite peace and enjoyment of the park and its visitors. The proposal would result in unactable loss of green area available for public use, which is particularly important for the physical and mental well-being of the surrounding residents. Dog owners were not able to walk their dogs in the park in 2017, because the screaming frightens the dogs which are sensitive to such type of sounds.

The proposal would only occupy a total area of about 810sqm (or 2.2%) of the lawn area in the park and would not unacceptably impact the normal functions of the park, which is further discussed in section 6.2 of this report. Although it is accepted that some dogs may be distracted by people using the zip line, this is not considered to be a planning consideration that would warrant refusal of the application.

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Concerns were raised about the health and safety of the proposed attraction.

Health and safety is not a relevant planning consideration and is covered by other legislation. The Design Out Crime Officer has reviewed the proposal from a safety perspective and advised that there would be appropriate measures in place to mitigate potential safety incidents.

The bird life in the park is potentially threatened by the positioning of the high-level lines and hysterically-screaming 'riders'.

The council’s biodiversity officer has reviewed the proposal and was satisfied it would not impact on the existing species living within the park, including birds.

The footprint occupied by the installations has still not recovered from last year's operation, with the area still cordoned off to allow the grass to grow. However, there is still a large, dead yellow patch.

Officer’s visited the site on the 18th April 2018 and noted that the grass has recovered. Although there would be temporary damage to the lawn, officers consider that this is more than offset by the additional funds raised by the attraction and spent on improvements to soil and plants elsewhere in the park. Condition 13 is recommended to ensure that the grass is fully repaired. The applicant will be required to pay a £5000 deposit to the council’s event team, which will be withheld in the event of damage.

The organisations Zipworld's pose restrictions, including medical restrictions for the people that can use the zip line. This contradicts Lambeth’s history of inclusiveness. Source: https://www.zipworld.co.uk/medical-restrictions

Officers are of the view that medical restrictions would be sensible for the safety of riders and is not an inclusivity or planning issue.

There is no actual benefit from the zip line.

Were there any local people employed in the event last year?

Did any local people actually get free or reduced price tickets?

Has Lambeth Council actually properly verified any of the assurances and commitments made by the organisers last year?

There are public benefits that would arrive from the scheme, and these are discussed in detail in section 6.5. In particular:

The applicant advised that only 2 employees came from within Lambeth, and a number of employees came from the surrounding boroughs. This year the applicant has advised that 15% of the candidates are expected to live in Lambeth. This is further discussed in section 6.5.15

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The zip line provided free tickets to local organisation such as Echo, Evelina Children’s Hospital, Ronal Mc Donald House, Coin Street and others. Tickets were given on “ask and give” basis and the total number was not counted. However the applicant advised that the free tickets were in the region of 100 tickets.

The planning permission in 2017 was subject to an informative requesting the applicant to evaluate and monitor the event in 2017. In response the Socio-Economic Effects Study was submitted. This will also be requested for the proposed event.

The survey shows that six percent of visitors drove, at the proposed number this is over 8000 car journeys.

The estimate number of visitors is the worst case scenario and the absolute maximum the zip line can accommodate. The numbers are likely to be lower. The Transport Officer reviewed the application and advised that there would be no unacceptable transport impact, given that majority of the people would arrive via public transport or on foot. This is discussed in section 6.10.

The event will bring much needed funding to the council. It was a shame that last year’s event income would not have covered the offices time and would have caused a loss to the Council. Although fees are unpublished this year I am hoping that they bring real local benefit.

The Park Investment Levy (PIL) would be £12,700 and in addition to this the income for the council would be £45,539. The zip line event last year did not cause a loss to the council income that was reinvested in the park. This is further discussed in section 6.5.

The council should ask the developer

To cover the grass;

Not to use diesel generators;

To put a “company complain sign” at location on site to direct visitors how to contact the developer and the council;

The applicant proposes to cover the grass and this was secured via Condition 12;

The applicant proposes a sound barrier to surrounding the generator, which would mitigate any unacceptable noise impacts;

The applicant has advised that contact details for complaints and queries were provided on site and on the event website. This will be repeated this year and secured by Condition 17.

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The councils should have an officer present on site during construction to make sure trees are protected.

The council’s tree officer advised that the recommendations set out in the applicant’s Arboriculture Impact Assessment are appropriate, and advised provided their details to the applicant in case there are any problems with the implementation.

4.2 Public Consultation

4.2.1 The Council consulted with various amenity groups and residents associations. No comments were received in response.

4.3 Statutory and Other Consultees

4.3.1 Comments were received from a number of external and internal organisations. These are summarised in the material below:

4.3.2 Conservation and Design

The Conservation officer advised that the proposed zip line development would result in less than substantial harm to the Conservation Area. The Conservation Officer advised that the test set out within Paragraph 134 of the NPPF applies and that this harm should be balanced against the public benefits arriving from the scheme. This matter is further discussed at section 6.5 of this report.

4.3.3 Parks and Open Space

The Lambeth Parks and Open Space team raised no objections to the application. The team advised that they have been in close communication with The Council’s Events Team about the detailed site set up, management and breakdown programme, along with an acceptable reinstatement plan following departure from the site which will minimise any long term damage to it. The amount of public open space being taken by the application site is as minimal as possible and this should not impede general access to and use of the rest of the Park, especially sports and play facilities.

4.3.4 Arboricultural Officer

The council’s arboricultural officer raised no objections to the application, but did advise that the applicant should follow the tree protection recommendations within the submitted ‘’Arboricultural Impact Assessment’’, SLR, February 2018 to ensure the health of trees in the park. This is to be secured by Condition 13.

4.3.5 Transport and Highways

The Transport Officer raised no objections and his comments are included in sections 6.11 – 6.14 of this report.

4.3.6 Transport for London (TfL)

TfL advised that the proposal would not result in any unacceptable impact to the Transport for London Road Network (TLRN) and the Strategic Road Network (SRN). TfL did provide advice about the construction of the proposed development, which is included as Informative 7.

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4.3.7 Design Out Crime Officer

The Design Out Crime Officer (DOCO) raised no objections to the applications subject to the following:

Improved security and measures to negate any change of injury though aggressive vehicle attack, though the addition of approximately 40 tonnes of concrete to each tower and also “T Shield” steel fencing (with wooden panelling) surrounding the towers.

Potentially loose items (such as bags and action cameras) should be rigorously checked to ensure minimal risk of injury to anyone passing below the line; and

The use of a security guard to be present at all times the installation is not being used, and in particular after closing hours of the park to prevent urban explorers and the like.

The DOCO advised that, subject to the aforementioned point being adhered to, all possible measure would be put in place for this installation to go ahead safety. This is to be secured by Condition 15.

4.3.8 Natural England

Natural England provided no comments.

4.3.9 Environment Agency

The Environmental Agency raised no objection to the proposal, and provided advice with respect to flood risk and flood mitigation measures, which is included as Informative 5.

4.3.10 Veolia – waste management

Veolia raised no objections.

5 POLICIES

5.1.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise. The development plan in Lambeth is the London Plan 2015 (as amended by Minor Alterations to the London Plan (MALP) dated 14 March 2016), and the Lambeth Local Plan 2015.

5.1.2 The new Draft London Plan was published on 1 December 2017 for consultation and will eventually supersede the current 2016 consolidation London Plan once the final version is published (anticipated Autumn 2019). The Draft London Plan is a material consideration in planning decisions and is currently afforded very limited weight, although the weight to be given is a matter for the decision maker.

5.1.3 The current planning application has been considered against all relevant national, regional and local planning policies as well as any relevant guidance. Set out below are those policies most relevant to the application, however, consideration is made against the development plan as a whole.

5.2 The National Planning Policy Framework (2012)

5.2.1 The National Planning Policy Framework (NPPF) was published in 2012. This document sets out the Government’s planning policies for England including the presumption in favour of sustainable development and is a material consideration in the determination of all applications.

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5.3 The London Plan (MALP, 2016)

Policy 2.18: Green infrastructure: the multi-functional network of green and

open spaces

Policy 4.1: Developing London’s economy

Policy 4.6: Support for and enhancement of arts, culture, sport and

entertainment

Policy 5.3: Sustainable design and construction

Policy 5.12: Flood risk management

Policy 6.3: Assessing effects of development on transport capacity

Policy 6.8: Coaches

Policy 6.9: Cycling

Policy 6.10: Walking

Policy 6.11: Smoothing traffic flow and tackling congestion

Policy 6.13: Parking

Policy 7.3: Designing out crime

Policy 7.4: Local character

Policy 7.5: Public realm

Policy 7.8: Heritage assets and archaeology

Policy 7.13: Safety, security and resilience to emergency

Policy 7.15:Reducing and managing noise, improving and enhancing the acoustic environment and promoting appropriate soundscapes

Policy 7.18: Protecting open space and addressing deficiency

Policy 7.19: Biodiversity and access to nature

Policy 7.21: Trees and woodlands

5.4 The Lambeth Local Plan 2015

5.4.1 The key relevant policies from the Lambeth Local Plan 2015 are:

Policy D2: Presumption in favour of sustainable development

Policy D3: Infrastructure

Policy ED11: Visitor attractions, leisure, arts and culture uses

Policy T1: Sustainable Travel

Policy T2: Walking

Policy T3: Cycling

Policy T4: Public transport infrastructure

Policy T6: Assessing impacts of development on transport capacity

Policy T7: Parking

Policy T8: Servicing

Policy EN1: Open space and biodiversity

Policy EN5: Flood Risk

Policy EN7: Sustainable waste management

Policy Q1: Inclusive environments

Policy Q2: Amenity

Policy Q3: Community safety

Policy Q6: Urban design: public realm

Policy Q9: Landscaping

Policy Q10: Trees

Policy Q12: Refuse/recycling storage

Policy Q13: Cycle storage

Policy Q19: Westminster World Heritage Site

Policy Q20: Statutory listed buildings

Policy Q22: Conservation areas

Policy Q23: Undesignated heritage assets

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Policy PN1: Waterloo

5.4.2 The following Lambeth Supplementary Planning Documents (SPD) and Guidance Documents are also considered relevant:

Lambeth Refuse and Recycling Storage Design Guide (2013)

Lambeth Waste and Recycling Storage and Collection Requirements – Technical Specification for Architects and Developers (2013)

6 ASSESSMENT

The main planning issues arising from this application are:

Land Use

Acceptability of the proposed zip line on site– Section 6.1

Open Space, Design and Conservation

Open Space and Biodiversity – Section 6.2

Trees and Landscaping – Section 6.3

Conservation, Heritage and Design: Legislation and Policy – Section 6.4

Conservation, Heritage and Design: Assessment – Section 6.5

Amenity impacts

Outlook, Daylight, Sunlight and Overshadowing, and Privacy Section 6.6

Noise – Section 6.7

Light spill – Section 6.8

Accessibility and Transport

Access and Public Transport Accessibility – Section 6.9

Trip Generation – Section 6.10

Car Parking – Section 6.11

Cycle Parking – Section 6.12

Construction – Section 6.13

Waste Management – Section 6.14

Other

Community safety– Section 6.15

Flood Risk – Section 6.16

6.1 Acceptability of the proposed zip line on the site

6.1.1 The application site is located within the Central Activity Zone, where visitor attractions are supported by policy ED11(a) of the Lambeth Local Plan 2015. The proposed zip line development would be for a temporary period of 18.5 calendar weeks and it would be located within an open space. It is therefore acceptable in principle subject to compliance with other policies. Officers note that a similar zip line development was approved in Archbishop’s Park by the PAC under ref. 17/02067/FUL.

6.2 Open Space and Biodiversity

6.2.1 Archbishop’s Park is a public open space, and is designated as a Site of Importance for

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Nature Conservation (SINC); however, it is not Metropolitan Open Land or a Registered Park. Therefore the application is required to be assessed against policy EN1 (Open space and diversity) of the Lambeth Local Plan 2015, but is not required to be assessed against the green belt tests set out in paragraphs 79-92 of the NPPF or policy Q21 (Registered Parks and gardens) of the Lambeth Local Plan (2015).

6.2.2 Policy EN1 states that the council will meet requirements for open space by:

(a) Protecting and maintaining open spaces and their function. Development which would involve the loss of existing public or private open space will not be supported unless at least one of the following tests is met:…

(iii) It is for the provision of facilities directly related to the use of open space including ecology centres, indoor sports facilities, changing rooms, toilets or cafes as long as these are appropriate in scale and form to the size and character of the open space and acceptable in terms of impact on openness and do not harm the function and operation of the open space.

(b) Preventing development which would result in loss, reduction in area or significant harm to the nature conservation or biodiversity value of an open space including any designated or proposed Local Nature Reserves (LNR) or Sites of Importance for Nature Conservation (SINC) unless adequate mitigation or compensatory measures are included appropriate to the nature conservation value of the assets involved.

6.2.3 The proposed zip line would be a “facility directly related to the use of open space” as required by policy EN1 (a) of the Lambeth Local Plan 2015. It would allow ‘riders’ to ascend into the treetops and enjoy views of the trees, park and wider area from the launching platform on the launching tower. Riders would then enjoy a ride through the treetops to the landing tower at the other end of the park. The zip line would offers visitors an alternative way to enjoy the park.

6.2.4 The proposed zip line would not have an unacceptable impact on the park’s functions and it would result in a limited and temporary loss of open space. The proposed development would cover a total area of 810 square metres, this area would be cordoned off for the duration of the event and would result in a temporary loss of an area of public open space. This loss would equate to 2.2% of the total area of Archbishop’s Park (810sqm of 3.74 hectares), or 3.4% of the park’s lawn (810sqm of 2.42 hectares).

6.2.5 The council’s parks and open space officer raised no objections to the zip line and advised that the amount of public open space being taken by the proposed development is as minimal as possible. It would not impede general access to and use of the rest of the park, especially the sports and play facilities. This has been confirmed by the submitted Socio-Economic Effects Study (January 2018) which states that ‘’the majority of interviewed the park users felt that the zip line has no effect on the frequency of their visit to the Park (77%) and 83% of the park users stated that the zip line had made ‘no difference’ to the length of time they spend in the park.’’

6.2.6 The study did show that approximately 12% of the interviewed local residents felt that the presence of the zip line had deterred them from visiting the park. It is therefore officers’ opinion that the proposed development would not unacceptably impact on the normal park functions.

6.2.7 The council’s biodiversity officer advised that the applicant has committed to implementing a series of mitigations and protective measures that would minimise or avoid any harm or damage to trees, landscape features or wildlife habitats. This includes the following:

the lighting, operating hours and access management strategy is acceptable and

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minimises impacts upon night flying species like bats. Officers recommend Condition 6 to ensure that the proposed lighting would only be used after dusk from 13 August 2018 to 9 September 2018 (between 19:30 to 21:00).

The siting of the towers and other associated equipment is away from sensitive habitats and locations where protected species are using trees or buildings.

6.2.8 The planning statement advises that the applicant has agreed with the council’s parks and open space team to undertake any remedial repair necessary following the removal of the structures from site, which would include re-seeding, laying tuft and/or minor repair to park infrastructure. Officers recommend Condition 14 to ensure that the lawn is made good following the take down of the development.

6.2.9 Given the above, officers are satisfied that the proposed development would not have any unacceptable impacts on the park and would not result in any loss of biodiversity. The proposed development would be in compliance with policy EN1 of the Lambeth Local Plan 2015.

6.3 Trees and Landscaping

6.3.1 Policy Q10 of the Lambeth Local Plan 2015 states that proposals for new development will be required to take particular account of existing trees on site and on adjoining land. It further states that development will not be permitted that would result in the loss of trees of significant amenity, historic or ecological/habitat conservation value, or give rise to a threat, immediate or long term, to the continued wellbeing of such trees

6.3.2 The proposed zip line would not impact the surrounding trees. It would not be necessary to remove any trees, and the proposal does not necessitate any pruning. The Council’s Tree Officer raised no objections to the proposal, but did advise that the applicant should follow the recommendation set out in the submitted ‘Arboricultural Impact Assessment, SLR, February 2018, which include: appropriate ground protection; low branches assessment prior to installation on site; temporary protecting fencing to the surrounding trees; the zip line cables to be located above the crowns of the trees T17, T18, T20, T22, T24 and T25 (as identified on drawing TPP 4 and TCP 3); and . Therefore subject to compliance with this document, the proposal would comply with policy Q10 of the Local Plan (2015).

6.4 Design, Heritage and Conservation: Legislation and Policy

6.4.1 This section of the report sets out the legislative and national policy context for the officer assessment of the impact of the development proposal on the historic environment and its heritage assets.

Legislative framework

6.4.2 The following legal commentary is provided:

6.4.3 Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 (“PLBCAA”) provides that in considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.

6.4.4 Section 72(1) PLBCAA provides that in the exercise, with respect to any buildings or other land in a conservation area, of any functions under or by virtue of (amongst others) the Planning Acts, special attention shall be paid to the desirability of preserving or enhancing the character or appearance of the conservation area.

6.4.5 The South Lakeland District Council v Secretary of State for the Environment case and the

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Barnwell Manor case (East Northamptonshire DC v SSCLG) establish that “preserving” in both s.66 and s.72 means “doing no harm’.

National Policy

6.4.6 Paragraph 17 of the National Planning Policy Framework (NPPF, 2012) sets out 12 “core planning principles” that should underpin both plan-making and decision-taking. Those principles include the following: “Planning should always seek to secure high quality design” and should “conserve heritage assets in a manner appropriate to their significance so that they can be enjoyed for their contribution to the quality of life of this and future generations”.

The NPPF defines a “heritage asset” as:

“A building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest”.

6.4.7 The definition includes both designated heritage assets (of which, Listed Buildings and Conservation Areas are relevant here) and assets identified by the local planning authority (including local listing).

“Significance” is defined within the NPPF as being:

“The value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic. Significance derives from a heritage asset’s physical presence, but also from its setting”.

6.4.8 Paragraph 129 of the NPPF requires local planning authorities to identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting its setting), taking account of the available evidence and any necessary expertise. That assessment should then be taken into account when considering the impact of the proposal on the heritage asset, to avoid or minimise conflict between the heritage asset’s conservation and any aspect of the proposal.

6.4.9 Paragraphs 131 and 132 of the NPPF provide as follows:

131. In determining planning applications, local planning authorities should take account of:

the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation;

the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and

the desirability of new development making a positive contribution to local character and distinctiveness.

132. When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.

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6.4.10 Paragraph 133 of the NPPF deals with substantial harm to or total loss of significance of significance of a designated heritage asset.

6.4.11 Paragraph 134 of the NPPF provides that where a development proposal will lead to less than substantial harm to the significance of the designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.

6.4.12 Paragraphs 137 and 138 of the NPPF are as follows:

137 Local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites and within the setting of heritage assets to enhance or better reveal their significance. Proposals that preserve those elements of the setting that make a positive contribution to or better reveal the significance of the asset should be treated favourably.

138 Not all elements of a World Heritage Site or Conservation Area will necessarily contribute to its significance. Loss of a building (or other element) which makes a positive contribution to the significance of the Conservation Area or World Heritage Site should be treated either as substantial harm under paragraph 133 or less than substantial harm under paragraph 134, as appropriate, taking into account the relative significance of the element affected and its contribution to the significance of the Conservation Area or World Heritage Site as a whole.

6.4.13 Officers have also had regard to the Planning Practice Guidance in respect of conserving and enhancing the historic environment.

Regional Policy

6.4.14 Part B of London Plan (2015, as amended 2016) Policy 7.4 relating to Local Character states that:

Buildings, streets and open spaces should provide a high quality design response that:

a. has regard to the pattern and grain of the existing spaces and streets in orientation, scale, proportion and mass

b. contributes to a positive relationship between the urban structure and natural landscape features, including the underlying landform and topography of an area

c. is human in scale, ensuring buildings create a positive relationship with street level activity and people feel comfortable with their surroundings

d. allows existing buildings and structures that make a positive contribution to the character of a place to influence the future character of the area

e. is informed by the surrounding historic environment.

6.4.15 Parts A to C of London Plan Policy 7.5 relating to Public Realm states that:

A London’s public spaces should be secure, accessible, inclusive, connected, easy to understand and maintain, relate to local context, and incorporate the highest quality design, landscaping, planting, street furniture and surfaces.

Planning decisions

B Development should make the public realm comprehensible at a human scale, using gateways, focal points and landmarks as appropriate to help people find their way.

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Landscape treatment, street furniture and infrastructure should be of the highest quality, have a clear purpose, maintain uncluttered spaces and should contribute to the easy movement of people through the space. Opportunities for the integration of high quality public art should be considered, and opportunities for greening (such as through planting of trees and other soft landscaping wherever possible) should be maximised. Treatment of the public realm should be informed by the heritage values of the place, where appropriate.

C Development should incorporate local social infrastructure such as public toilets, drinking water fountains and seating, where appropriate. Development should also reinforce the connection between public spaces and existing local features such as the Blue Ribbon Network and parks and others that may be of heritage

6.4.16 Part A of London Plan Policy 7.8 relating to Heritage Assets and Archaeology states that:

London’s heritage assets and historic environment, including listed buildings, registered historic parks and gardens and other natural and historic landscapes, conservation areas, World Heritage Sites, registered battlefields, scheduled monuments, archaeological remains and memorials should be identified, so that the desirability of sustaining and enhancing their significance and of utilising their positive role in place shaping can be taken into account.

6.4.17 Part B of London Plan Policy 7.10 relating to World Heritage Sites states that:

Development should not cause adverse impacts on World Heritage Sites or their settings (including any buffer zone). In particular, it should not compromise a viewer’s ability to appreciate its Outstanding Universal Value, integrity, authenticity or significance. In considering planning applications, appropriate weight should be given to implementing the provisions of the World Heritage Site Management Plans.

Local Policy

6.4.18 The application site is situated within the Lambeth Palace Conservation Area. Policy Q22 of the Council's Local Plan 2015 seeks to promote high quality design that makes appropriate reference to the character and appearance of conservation areas and contributes positively to its surroundings.

6.4.19 Policy Q19 states that development affecting the setting of the Westminster World Heritage Site will be required to demonstrate that it:

(i). preserves or enhances the Outstanding Universal Value, authenticity and integrity of the World Heritage Site (as set out in the official statement of Outstanding Universal Value) and its setting;

(ii). preserves or enhances the environmental quality of the approaches/vantage points; and

(iii). provides the opportunity to better understand, reveal and appreciate the Outstanding Universal Value, authenticity and integrity of the site

6.4.20 Policy Q20 seeks to ensure that development affecting statutory listed buildings will be supported where they would (i) conserve and not harm the significance/special interest; (ii) not harm the significance/setting (including views to and from); and (iii) not diminish its ability to remain viable in use in the long term.

6.4.21 Policy Q22 states that development proposals affecting conservation areas will be permitted where they preserve or enhance the character and appearance of the conservation area by (i) respecting and reinforcing the established, positive characteristics of the area in terms of the building line, siting, design, height, forms, materials joinery, window detailing etc (ii) protecting the setting (including views in and out of the area).

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6.4.22 Policy Q23 of the Local Plan relating to Undesignated Heritage Assets.

Part C states that:

The council will:

(i). resist the destruction of assets on the local heritage list and expect applicants to retain, preserve, protect, safeguard and where desirable enhance them when developing proposals that affect them;

(ii). require proper investigation and recording of archaeological remains and publication and archiving of results to advance understanding.

Approach required

6.4.23 Turning to consider the application of the legislative and policy requirements set out above, the first step is for the decision-maker to consider each of the designated heritage assets (referred to hereafter simply as “heritage assets”) which would be affected by the proposed development in turn and assess whether the proposed development would result in any harm to the heritage asset.

6.4.24 The decision of the Court of Appeal in Barnwell Manor confirms that the assessment of the degree of harm to the heritage asset is a matter for the planning judgement of the decision-maker.

6.4.25 However, where the decision-maker concludes that there would be some harm to the heritage asset, in deciding whether that harm would be outweighed by the advantages of the proposed development (in the course of undertaking the analysis required by s.38(6) PCPA 2004) the decision-maker is not free to give the harm such weight as the decision-maker thinks appropriate. Rather, Barnwell Manor establishes that a finding of harm to a heritage asset is a consideration to which the decision maker must give considerable importance and weight in carrying out the balancing exercise.

6.4.26 There is therefore a “strong presumption” against granting planning permission for development which would harm a heritage asset. In the Forge Field case the High Court explained that the presumption is a statutory one. It is not irrebuttable. It can be outweighed by material considerations powerful enough to do so. But a local planning authority can only properly strike the balance between harm to a heritage asset on the one hand and planning benefits on the other if it is conscious of the statutory presumption in favour of preservation and if it demonstrably applies that presumption to the proposal it is considering.

6.4.27 The case-law also establishes that even where the harm identified is less than substantial (i.e. falls within paragraph 134 of the NPPF), that harm must still be given considerable importance and weight. Where more than one heritage asset would be harmed by the proposed development, the decision-maker also needs to ensure that when the balancing exercise in undertaken, the cumulative effect of those several harms to individual assets is properly considered.

6.4.28 What follows below is an officer assessment of the extent of harm which would result from the proposed development to the scoped heritage assets. This includes as assessment of Conservation Areas, Listed Buildings and World Heritage Site. Both an individual assessment against each heritage asset as well as a cumulative assessment is provided. This is then followed by an assessment of the heritage benefits of the proposals.

6.4.29 In reaching their assessment, officers have undertaken their own assessment, have taken into account the Lambeth Design and Conservation Officer’s comments. In addition, Officers have also taken into account the judgements reached in the Applicant’s Planning Statement (Section 5.2 Heritage Appraisal).

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6.5 Design, heritage and conservation: Assessment

6.5.1 This section of the report contains the assessment the proposed development’s impact to the surrounding heritage assets:

Figure 5 - Heritage Assets, source Historic England.

The Lambeth Palace Conservation area

6.5.2 The proposed zip line would be located in the Archbishop’s Park which is within the Lambeth Palace Conservation Area.

6.5.3 The council’s conservation officer has advised that the proposed staff and reception units would be lightweight, small scale, garden structures and would have a neutral impact on the character of the public park. These structures would be fully screened both in views surrounding the park and in important views taken from Westminster Bridge, Victoria gardens and Lambeth Bridge on the other side of the river.

6.5.4 The proposed launch tower will be about 36 m tall with an 11 m wide base, while the landing tower would be about 16 m tall with a 7 meter wide base. The conservation officer advised that both structures would feature concrete ballasts disguised by timber hoardings to the base and platforms at the top. Both towers would impact the leafy character of the park, identified in the Lambeth Palace conservation area statement as being important elements in the conservation area. The conservation officer advised that the impact of the towers would equate to ‘less than substantial harm’ to the appearance of the conservation area.

Westminster World Heritage Site

6.5.5 The council’s conservation officers did not identify any harm to the setting of the Westminster World Site, given that views from the southern end of the park towards the Westminster World Heritage Site are not affected by the towers due to the views already being obscured by trees in full leaf with extensive canopy coverage.

Lambeth Palace - Grade I Listed Building

6.5.6 The council’s conservation officers did not identify any harm to the setting of the Lambeth Palace, given that the proposed towers are not perceived in views of Lambeth Palace and Lambeth Palace Road. Furthermore views from the southern end of the park towards

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Lambeth Palace are not affected by the towers because the views are already obscured by trees in full leaf with extensive canopy coverage.

St. Mary’s Rectory - Grade II Listed Building

6.5.7 The council’s conservation officers did not identify any harm to the setting of St. Mary’s Rectory.

Impact on heritage assets: summary

6.5.8 In summary, there would be no harm to the Westminster World Heritage Site and the surrounding listed buildings. However there would be ‘less than substantial’ harm to the Lambeth Palace Conservation Area.

Public benefits that flow from the proposed development

6.5.9 The publication of the National Planning Policy Guidance (NPPG) provides a definition of a ‘public benefit’ and it explains that “public benefits may follow from many developments and could be anything that delivers economic, social or environmental progress as described in the National Planning Policy Framework. Public benefits should flow from the proposed development. They should be of a nature of scale to be of benefit to the public at large and should not just be a private benefit. However, benefits do not always have to be visible or accessible to the public in order to be genuine public benefits. Public benefits may include heritage benefits”.

6.5.10 Officers need to consider the public benefits that would flow from the proposed development and which deliver economic, social or environmental progress. The components of sustainable development are defined as follows:

an economic role – contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;

a social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural wellbeing; and

an environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.

6.5.11 The rest of this section considers the public benefits that would flow from the proposed development:

Economic

6.5.12 The proposal would have the following public benefits:

1) Increase in spending in the Waterloo area

6.5.13 The additional pedestrian footfall to the site will bring people to the Waterloo area, many of whom are likely to support local business particularly food and drink venues before or after their zip line experience. This was confirmed within the submitted Socio-Economic Effects Study (January 2018), which shows that in the 2017 event on average the zip line customers spend approximately £30.70 within the local area, above any expenditure on

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the zip line.

6.5.14 The 2017 zip line event generated approximately £228,000 Gross Value Added (GVA) for local businesses; GVA is a standard measure of economic output that measures the value of goods and services produced in an area. The proposed zip line is likely to attract more visitors than the 2017 zip line, because it would operate for a longer period of time and would also have extended evening hours, and therefore exceed these figures.

2) Employment opportunities

6.5.15 The proposed development would create direct employment opportunities. The proposed event would employ an estimated 55 team members for the event. The applicant advised that they are making best efforts to employ these members of staff locally and they expect that 15% of the staff members would be Lambeth residents (which is at least 8 persons). In comparison, the 2017 year zip line event employed only 2 local residents and a total of 53 members of staff, which is 11.0 full time equivalent staff. The submitted Socio-Economic Effects Study (January 2018) shows that the overall total full time equivalent (FTE) jobs estimated to have been supported by the operation of the attraction is 29.4 jobs (disaggregated as follows: direct jobs: 11.0 FTE; indirect jobs in supply chain 6.9 FTE; jobs linked to off-site spending: 6.4 FTE; and jobs supported via income effects: 5.1 FTE).

6.5.16 The proposed development would result in the employment of a new “trader pitch” in the Archbishop’s Park which would be managed by the Lambeth Parks Team (who would charge rent for the pitch). The council’s events officer advised that the trader is likely to be a local Lambeth trader. The decision to open a new trader pitch was influenced by a customer’s survey reported in the submitted Socio-Economic Effects Study (January 2018), which showed that approximately 25% of the customers said that a food and drink outlet would have improved the experience. The council’s events officer advised that in response to this, a trader pitch to offer refreshments will be provided in the park for the public and attendees.

3) Bringing income into the park

6.5.17 The proposal will generate income for the Archbishop’s Park and the council, a proportion of which would be spend for the maintaining and improvement of the park. The council’s events officer advised that in the 2017 the Park Investment Levy (PIL) paid by the zip line operator was used to carry out extensive planning, pathways repair and soil improvements. The PIL amount was £7,830 for the year 2017/2018 because of the zip line event (which is the entire amount paid by the zip line operator), and in comparison the PIL in 2016/2017 for Archbishop’s Park was £0. This year the PIL would be £12,700.

6.5.18 In addition to the PIL, the proposed development would also generate income to the Council through the form of booking fees and events permit, which would be £45,539 (not including the PIL) and in addition a ground damage deposit of £5,000 will be held from the organisers to pay for any repairs (if any repairs exceed this amount the applicant will pay the additional fees). In comparison last year the council’s income was £34,000.

6.5.19 The proposal would bring awareness of the sports facilities on offer at Archbishop’s Park which may result in future bookings of these facilities bringing further income to the park.

Social

1) Support for charities and awareness of different causes

6.5.20 The applicant would support charities and organisation to raise awareness of different causes and would provide free tickets for charities. This was initiated in the 2017 year event

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when the applicant donated a number of free tickets to charities and community groups including the Waterloo Community Theatre, Coin Street Community Builders, the Evelina Children’s ward, Ronald McDonald House and others. The applicant advised that the tickets were given on a “ask and give” basis whereby named groups could ring up and tickets were provided. The applicant provided an estimate of 100 tickets but advised that this is not restricted in any terms and it entirely depends on the needs and requests made. In 2017, the zip line event was also used by different charities who went on the zip line to raise awareness and/or funding of their causes and used social media for publicity. This means that people went on the zip line in support of a cause. The charities that did this included Muscular Dystrophy UK, the Pituitary Foundation and Diversity Role Model. The applicant advised that they are looking to expand the fundraising opportunities for charities in 2018, and would provide packages specifically tailored to the charitable and fundraising sector.

2) Awareness and use of the sport facilities at Archbishop’s Park

6.5.21 The publicity for Archbishop’s Park generated from the proposed event would result in social benefits. The level of publicity was shown in the Socio-Economic Effects Study, which showed that 2017 year event the zip line attracted publicity both domestically and internationally, in total the project generated 125 pieces of coverage estimating 2.41 million views, with a further 3.25 million reading online, 20.2 million watching on television, and 3.08 million listening on the radio. Furthermore the customers’ survey showed that approximately 98% of the zip line customers were not local residents of Lambeth, and 72% of the customers advised that they would not have visited Archbishop’s Park had it not been for the presence of the zip line.

6.5.22 The event would bring people into the park who may not have previously used or known about it previously. This would raise awareness of the facilities on offer at this park including the multi-use games area (MUGA) and tennis courts. The use of the sports facilities at the park would also encourage physical exercise, which in turn has a direct positive physical and psychological impact on those taking part.

Environmental

6.5.23 The zip line development would result in improvements to the park. This was demonstrated in the 2017 event, as the Park Investment Levy (PIL) paid by the zip line operator directly contributed to the enhancement of the Archbishop’s Park. The Council’s Events Officer advised that this has enabled new planting, soil improvements and pathway repairs. This resulted in enhancement to the biodiversity of the site, which this included:

Soil improvement, which is organic matter added to the soil to improve its biomass, soil structure and condition. This adds nitrogen and other essential minerals to the soil to help the important root development and plant growth.

Two new planting beds: a summer bed, designed to add additional colourful summer planting; and a more lasting planting bed, which has more muted perennial grasses that are able to thrive in shady areas.

Additional shrubs planted to the the long boarder, which is a parallel to Lambeth Palace. Some of these shrubs will be dramatic in colour to provide extended spring flowering and autumn colour and berries, increase nesting sites and provide necessary food sources for birds, invertebrates and insects.

Over 3000 spring bulbs including a wide variety of Narcissi and Tulips have been planted around the park and in many of the large containers.

Harm to a heritage assent versus public benefits

6.5.24 Officers consider that having accorded considerable importance and weight to the ‘less than substantial’ harm to the Lambeth Palace Conservation Area such harm will be

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outweighed by the public benefits of the proposal. As such, the proposal would pass the test specified at paragraph 134 of the National Planning Policy Framework.

6.6 Outlook, Daylight, Sunlight and Overshadowing and Privacy

6.6.1 Policy Q2 of the Lambeth Local Plan (2015) states that development will be supported if: (i) visual amenity from adjoining sites and from the public realm is not unacceptably compromised; (ii) acceptable standards of privacy are provided without a diminution of the design quality; (iii) adequate outlooks are provided avoiding wherever possible any undue sense of enclosure or unacceptable levels of overlooking (or perceived overlooking); (iv) it would not have an unacceptable impact on levels of daylight and sunlight on the host building and adjoining property; and (vi) adequate outdoor amenity space is provided free from excessive overshadowing.

6.6.2 The proposed development would be located at a sufficient distance from neighbouring residential properties (a minimum of approximately 35m from the closest residential site) to ensure that there would be no unacceptable impacts in terms of loss of light, outlook, and disturbance.

6.6.3 With regards to visual amenity, officers have identified a less than substantial harm to the character and appearance of the surrounding conservation area, and this is further discussed in sections 6.4 and 6.5 of this report.

6.7 Noise

6.7.1 Policy Q2 of the Lambeth Local Plan 2015 states that development will be supported if (v) the adverse impact of noise is reduced to an acceptable level through the use of attenuation, distance, screening, or internal layout/orientation.

6.7.2 The proposal does not include music, or amplified sound. It is noted that no complaints about noise were received during the 2017 event.

6.7.3 The proposal this year would have shorter operation hours during the day, and it would operate from 12pm until 8pm on weekdays and from 11am to 8:30pm on weekends and holidays. The proposal would start later and would have extended evening hours later compared to the event in 2017, which operated between 10am and 7-7:30pm. The applicant advised that this change is because it was found that the morning period was more popular among park users for recreation, and the evening period was popular among the zip line customers. Officers consider the hours of operation to be appropriate, and note that this would ensure quiet mornings. The hours of operation would be secured via Condition 5.

6.7.4 The submitted Noise Impact Assessment has been undertaken to assess the likely operation noise and noise from people. The report advises that a temporary acoustic barrier should be erected between the generator and the properties on Carlisle Lane. The report concludes that, provided an element of mitigation is imposed, the noise associated with the zip line would not result in any significant adverse effects at the nearest noise sensitive uses (including residential and the nearby hospital). Condition 11 is recommended to ensure that the acoustic barrier is provided.

6.7.5 Officers considered that the measures detailed in the Event Management Plan, along with the adequate separation distances to the nearest noise sensitive uses and the hours of operation would ensure that amenity is safeguarded.

6.7.6 Subject to conditions 3, 4, 5 and 11, the impact of noise would be reduced to an acceptable level consistent with policy Q2 (v) of the Lambeth Local Plan 2015.

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6.8 Light Spill

6.8.1 The proposal would include external lighting, which would only be utilised post dusk between 13 August and 9 September (approximately 19:30 to 21:00). The lights would direct people walking to and from the zip line along footpaths. They would be orientated downwards for the illumination of the grounds and would not direct light into nearby residential properties.

6.8.2 Officers consider that the proposed lighting would not result in unacceptable impact, noting the existing floodlights of the football pitches which are located at a higher level and the surrounding mature trees which would screen the lighting and would mitigate the impact to neighbouring residential properties. Condition 6 is recommended to secure the hours of operation of the proposed lighting.

6.9 Access / Public Transport Accessibility

6.9.1 Policy T1 (a) of the Lambeth Local Plan 2015 states that the council will promote a sustainable pattern of development in the borough, minimising the need to travel and reducing dependence on the private car. Furthermore part (c) states that development that generates a significant number of trips will be required to be located in an area with an appropriate level of public transport accessibility.

6.9.2 The application site has excellent public transport accessibility level (PTAL score of 6b), with the Waterloo Mainline and Underground station nearby along with multiple bus routes at the Lambeth Palace Road and Lambeth Road entrances. There are also London Cycle Hire docking stations at both the northern and southern park entrances. The application site has access to a range of different sustainable transport modes.

6.9.3 Visitors and staff are likely to use public transport or walk to arrive the proposed zip line. This is supported by the Socio-Economic Effects Study, which showed that 92% of the zip line visitors in 2017 used public transport and only 6% came by car and 2% by taxi. The study also showed that the customers were satisfied with the public transport accessibility, and none felt that transport links to the park needed to be improved.

6.10 Trip Generation

6.10.1 Policy T6 of the Lambeth Local Plan 2015 states that planning applications will be supported where they do not have unacceptable transport impacts, including cumulative impacts on highways safety, traffic flows, congestion of the road network, on-street parking, footway space desire lines and pedestrian flows, and all other transport modes, including public transport and cycling.

6.10.2 The proposed zip line event would result in an acceptable trip generation. The maximum amount of visitors is calculated at 180 visitors per hour (90 flyers and 90 spectators), which is the worst case scenario and the actual numbers are expected to be lower. The application was reviewed by the council’s transport officer who noted that the Transport and Crowd Management Plan indicates a capacity of 90 riders/hour and that visitors would be encouraged to pre-book tickets and 90% pre-booked last year. This arrangement would reduce potential for large queues of pedestrian building up. The transport officer noted that the survey of visitors last year (the same event in 2018) indicated most visitors arrived by public transport and other sustainable transport modes.

6.11 Car Parking

6.11.1 Policy T7 of the Lambeth Local Plan 2015 supports car free development, particularly in areas where alternative modes of transport are available and where public accessibility is high.

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6.11.2 The proposal does not include any car parking. This is considered acceptable for the following reasons:

The site has excellent access to public transport as detailed at Section 6.11 of this report above

The site is within a Controlled Parking Zone (CPZ), therefore customers could not park in spaces designated for residents

The council’s transport officer advised that in 2017 only a small proportion of the visitors arrived using a car (6% by car and 2% by taxi)

There were no complaints about congestion or parking stress were received during the event in 2017.

6.12 Cycle Parking

6.12.1 Policy T3 states that Lambeth would require the provision of appropriate secure and covered cycle parking facilities in accordance with the minimum standards set out in the London Plan and will expect these standards to be exceeded. Policy Q13 sets the requirements of the cycle storage design.

6.12.2 The applicant would provide 5 temporary bike racks, which can accommodate 10 cycle parking spaces. The council’s transport officer has advised that the proposed cycle stands would be located close to the Landing tower on the south side of Archbishop’s Park, and would be acceptable in number and design.

6.13 Construction

6.13.1 The council’s transport officer noted that the construction management plan includes vehicular swept paths and suitable routes that were also used in the 2017 year event. It is also noted that the current proposal would have a shorter period for construction: 14 days compared to the previous year which was 25 days.

6.14 Waste Management

6.14.1 Policy Q12 sets the Council’s requirements of the refuse/recycling storage. Policy Q12 sets the council’s requirements for refuse/recycling storage.

6.14.2 There are existing waste and recycling bin within the Archbishop’s Pak and are currently used by visitors to the park. In addition the applicant proposes to undertake a litter picking in and around the towers every day. In 2017 waste management was sub-contracted to the council’s parks department and this will be done again this year. The applicant advised that the parks team do not collect waste at weekends and this was undertaken by the zip line organisations to ensure the park was kept tidy. The collected waste was stored in the park deport on Carlisle Lane. This approach would be repeated this year. It is also noted that ‘‘Veolia‘’, the council’s waste management company, raised no objections to the proposal

6.15 Community Safety

6.15.1 Policy Q3 of the Lambeth Local Plan 2015 states that the council will expect development to utilise good design to design out opportunistic crime, antisocial behaviour and fear of crime in a site-specific manner, based on an understanding of the locality and likely crime and safety issues it presents. This requirement is contained within Section 17 (2) of The Crime and Disorder Act 1998 which imposes an obligation on the Local Planning Authority to consider crime and disorder reduction in the assessment of planning applications.

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6.15.2 The DOCO advised that all possible measures would be put in place to mitigate potential accidents, including fencing to prevent potential aggressive vehicle attack; use of 24 hours security guard and checks of any loose items such as bags and action cameras before a ‘’fly’’. Officers recommend these to be secured by Condition 15. The proposals would incorporate safety and security measures compliant with policy Q3 of the Local Plan 2015.

6.16 Flood Risk

6.16.1 Policy EN5 (a) of the Lambeth Local Plan 2015 states that the council will seek to minimise the impact of flooding in the borough and part (b) states that All development in Flood Zones 2, 3a and 3b defend in the Lambeth Strategic Flood Risk Assessment (SFRA);, or identified as at risk of flooding from other sources, should contribute positively to actively reducing food risk through avoidance, reduction, management and mitigation.

6.16.2 The site is located in Flood Zone 3, which is defined as having high probability of river and/or sea flooding, and it is located within area that benefits from River Thames tidal flood defences. The Environment Agency advised that the proposed development would likely be classified as ‘water compatible’ and raised no objections. Officers are therefore satisfied the proposal would not result in unacceptable impact on flood risk in line with policy EN5 of the Lambeth Local Plan 2015.

6.16.3 The Environment Agency advised that the owners and operators of the proposed development should be registered with the Environmental Agency’s Floodline Warnings Direct service, as referred to within the submitted Flood Risk Assessment. This will be included as an informative.

7 CONCLUSION

7.1 This application is for the erection of a “zip line” facility for a temporary period between 8 May 2018 and 14 September 2018.

7.2 The use of the site is appropriate as a visitor attraction for the following reasons:

It would be located within the Central Activity Zone where visitor attractions are supported (policy ED11 of the Lambeth Local Plan 2015);

It would be a “facility directly related to the use of open space” (policy EN1 (a) of the Lambeth Local Plan 2015) offering visitors an alternative way to enjoy the park; and

It would not have an unacceptable impact on the park’s functions and any impact would only be for temporary period (policy EN1 (a) of the Lambeth Local Plan 2015).

7.3 The proposed development would result in ‘less than substantial harm’ to the character of

the Lambeth Palace Conservation Area, however officers consider that having accorded considerable importance and weight to such harm the public benefits flowing from the scheme would outweigh the harm to the heritage asset. The public benefits include (i) economic benefits: increase spending within the surrounding area of the application site, new employment opportunities and generation of income for the Archbishop’s Park; (ii) social benefits: support for charities and organisation to raise awareness and funding and raising awareness of the use of the park and the available sports facilities; and (iii) indirect environmental benefits such as improvements to the park leading to the enhancement of the biodiversity.

7.4 The proposed development would not result in any unacceptable amenity impacts. There would be no unacceptable loss of light to or overshadowing of the neighbouring properties, and the proposed structures would not result in any unacceptable impact on visual amenity, privacy or (subject to conditions) increase of noise.

7.5 The council’s transport team has confirmed that the proposed development would not have

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an unacceptable impact on the local highway network or parking stress levels in surrounding streets.

7.6 The approval of the proposed development would be subject to conditions and informatives as set out in sections 10 and 11 of this report. The conditions are necessary to make the application acceptable in planning terms.

7.7 For these reasons and those set out throughout this report, and subject to the conditions and informatives detailed below, officers consider that the Development would be in general compliance with the Development Plan for the Borough, and that there are no material considerations of sufficient weight that would dictate that the application should be refused.

8 EQUALITY DUTY AND HUMAN RIGHTS

8.1 In line with the Public Sector Equality Duty, the Council must have due regard to the need to eliminate discrimination and advance equality of opportunity, as set out in section 149 of the Equality Act 2010. In making this recommendation, regard has been given to the Public Sector Equality Duty and the relevant protected characteristics (age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation).

8.2 In line with the Human Rights Act 1998, it is unlawful for a public authority to act in a way which is incompatible with a Convention right, as per the European Convention on Human Rights. The human rights impact have been considered, with particular reference to Article 1 of the First Protocol (Protection of property), Article 8 (Right to respect for private and family life) and Article 14 (Prohibition of discrimination) of the Convention.

8.3 The Human Rights Act 1998 does not impair the right of the state to make decisions and enforce laws as deemed necessary in the public interest. The recommendation is considered appropriate in upholding the Council's adopted and emerging policies and is not outweighed by any engaged rights.

9 RECOMMENDATION

9.1 Resolve to grant conditional planning permission.

9.2 Agree to delegate authority to the Director of Planning, Transport and Development to finalise the recommended conditions as set out in this report including such refinements, amendments, additions and/or deletions as the Director of Planning and Development considers reasonably necessary.

.

10 CONDITIONS

1) Time Limit

The development to which this decision relates shall be dismantled and removed from the site by no later than 3rd October 2017 and Archbishop’s Park reinstated to the satisfaction of the Local Planning Authority

Reason: The nature and duration of the temporary uses and structures are acceptable, but the use of Archbishop’s Park on a continuous and permanent basis, would cause unacceptable harm to the character and appearance of the conservation area (Policies EN1, Q2 and Q22 of the London Borough of Lambeth Local Plan (2015)).

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2) In accordance with approved plans

The development hereby permitted shall be carried out in accordance with the approved plans listed in this decision notice.

Reason: For the avoidance of doubt and in the interests of proper planning.

3) Hours of use (1)

The use of the site for set up by staff shall not begin before 9:00 Hours on any day of the week. Reason: To protect the amenities of adjoining occupiers and the surrounding area. (Policies Q2, ED11 and PN1 of the London Borough of Lambeth Local Plan (2015)).

4) Hours of use (2)

The use of the site for shut down by staff shall not occur after 21:30 Hours on any day of the week. Reason: To protect the amenities of adjoining occupiers and the surrounding area. (Policies Q2, ED11 and PN1 of the London Borough of Lambeth Local Plan (2015)).

5) Hours of use (3)

The use of the zip line for customers shall not begin before 10:00 Hours and shall cease to operate at or before 20.30 Hours on any day of the week.

Reason: To protect the amenities of adjoining occupiers and the surrounding area (Policies Q2, ED11 and PN1 of the London Borough of Lambeth Local Plan (2015)).

6) Lighting

The external lighting hereby permitted shall only be operated from 13 August 2018 to 9 September 2018 within the following hours: 19:30 hours to 21:00 hours.

Reason: To protect the amenities of the surrounding area and mitigate potential impact on

flying species at night (policy EN1, and Q2 of the Lambeth Local Plan 2015)

7) Enter and exit in forward direction only

No vehicles shall enter or leave the events sites other than in a forward direction. Reason: To minimise danger, obstruction and inconvenience to users of the highway (policies T1, T6 and T8 of the London Borough of Lambeth Local Plan (2015)).

8) Vehicular access

The vehicular access to the site shall be provided and used in accordance with the Event Access Arrangements document. Reason: To minimise danger, obstruction and inconvenience to users of the highway (policies T1, T6 and T8 of the London Borough of Lambeth Local Plan (2015)).

9) Waste Management Strategy

Prior to the occupation of the development hereby permitted, a Waste Management Strategy shall be submitted to and approved in writing by the local planning authority. The development hereby permitted shall be built in accordance with the approved details and shall thereafter be retained solely for its designated use. The use hereby permitted shall thereafter be operated in accordance with the approved Waste Management Strategy. The

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Waste Management Plan should comply with the guide for architects and developers on waste and recycling storage and collection requirements (2013). Reason: To ensure suitable provision for the occupiers of the development, to encourage the sustainable management of waste and to safeguard the visual amenities of the area (policies Q2 and Q12 of the London Borough of Lambeth Local Plan (2015)).

10) Area to be kept clean

The areas surrounding the launch tower, landing tower and associated marquees and gazeboos shall be kept clean at all times and shall be left clean after customer closing hours.

Reason: To protect the visual amenities of park users and the area in general. (Policies Q2, and Q5 of the Lambeth Local Plan (2015)).

11) Noise from any mechanical equipment

Noise from any mechanical equipment, as measured in accordance with BS4142: 2014, shall not exceed the background noise level L90B(A) 15 minutes, when measured outside the window of the nearest noise sensitive or residential premises.

Reason: To protect the amenities of adjoining occupiers and the surrounding area (policy Q2 of the London Borough of Lambeth Local Plan (2015)).

12) Acoustic barrier

Prior to the use hereby permitted, a temporary acoustic barrier shall be erected between the lighting generator and Carlisle Lane, as recommended within the Noise Assessment, prepared by the SLR, February 2018. The acoustic barrier shall only be in place between 13 August 2018 and 9 September 2018.

Reason: To protect the amenities of adjoining occupiers and the surrounding area (policy Q2 of the London Borough of Lambeth Local Plan (2015)).

13) Tree and ground protection

The development hereby permitted shall be carried out in accordance with the approved Arboricultural Impact Assessment, prepared by SLR, dated February 2018. The damage mitigation measures should be implemented, including but not limited to the following:

ground protection under the anchor points of the towers;

temporary protecting fencing to the surrounding trees;

Low branches assessment prior to installation on site; and

The zip lines shall be located above and shall not encroach with the crowns of trees T17, T18, T20, T22, T24 and T25 (as identified on drawing TPP 4 and TCP 3);

Reason: To protect the trees on site (policy T10 of the Lambeth Local Plan 2015).

14) Lawn repair

Following the removal of the structures from site, the lawn shall be made good which should include re-seeding, laying tuft and/or minor repair to park infrastructure.

Reason: To mitigate the potential impact from the development on the lawn areas (policy EN1 of the Lambeth Local Plan 2015).

15) Secured by design

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The development hereby permitted shall be carried out in accordance with the following security measures:

Improved security and measures to negate any change of injury though aggressive vehicle attack, though the addition of approximately 40 tonnes of concrete to each end and also T Shield steel fencing (with wooden panelling) surrounding the towers.

Potentially loose items (such as ‘’bum bags’ and action cameras) should be rigorously checked to ensure minimal risk of injury to anyone passing below the line; and

The use of a security guard to be present at all times the installation is not being used, and in particular after closing hours of the park to prevent urban explorers and the like.

Reason: In the interest of community safety (policy T10 of the Lambeth Local Plan 2015).

16) Non-road mobile machinery (NRMM)

No non-road mobile machinery (NRMM) shall be used on the site unless it is compliant with the NRMM Low Emission Zone requirements (or any superseding requirements) and until it has been registered for use on the site on the NRMM register (or any superseding register). Reason: To ensure that air quality is not adversely affected by the development in line with London Plan policy 7.14 and the Mayor’s SPG: The Control of Dust and Emissions during Construction and Demolition.

17) Details for complaints

A “complaints sign” shall be displayed on site at both the launch tower and the landing tower. The signs shall provide information how customers and park uses can contact the zip line organisers and the council if they want to raise a complaint.

Reason: To ensure that amenity and other potential impacts are monitored and recorded (Policies Q2 and ED11 of the Lambeth Local Plan 2015).

11 INFORMATIVES

1) This decision letter does not convey an approval or consent which may be required under any enactment, by-law, order or regulation, other than Section 57 of the Town and Country Planning Act 1990.

2) Your attention is drawn to the provisions of the Building Regulations, and related legislation which must be complied with to the satisfaction of the Council's Building Control Officer.

3) Your attention is drawn to the provisions of The Party Wall Act 1996 in relation to the rights of adjoining owners regarding party walls etc. These rights are a matter for civil enforcement and you may wish to consult a surveyor or architect.

4) Your attention is drawn to the need to comply with the requirements of the Control of Pollution Act 1974 concerning construction site noise and in this respect you are advised to contact the Council's Environmental Health Division.

5) You are advised that the owners and operators of the proposed development shall register with the Environment Agency’s Floodline Warnings Direct service.

6) You are advised of the necessity to consult the Principal Highways Engineer of the

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Highways team on [email protected] in order to obtain necessary prior approval for undertaking any works within the Public Highway including Scaffold, Temporary/Permanent Crossovers, Oversailing/Undersailing of the Highway, Drainage/Sewer Connections and Repairs on the Highways, Hoarding, Excavations, Temporary Full/Part Road Closures, Craneage Licenses etc. You are advised to contact the Highways team at the earliest possible opportunity.

7) You are advised to use construction contractors who are registered on the Fleet Operator Recognition Scheme *(FORS). You are also advised that:

All vehicles associated with the construction must only park/ stop at permitted locations and within the time periods permitted by existing on-street restrictions

No skips or construction materials shall be kept on the footway or carriageway on the Transport for London Road Network (TLRN) at any time. Should the applicant wish to install scaffolding or a hoarding on the footway whilst undertaking this work, separate licences may be required with TfL, please see, https://www.tfl.gov.uk/info-for/urban-planning-and-construction/highway-licences

8) For information on the NRMM Low Emission Zone requirements and to register NRMM, please visit http://nrmm.london/

9) The applicant is advised to engage with the Friends of Archbishop's Park and the Council to find ways of evaluating and monitoring the impact on users of the park.