Glassmill planning appeal - Day 1 Morning - Tuesday 17 March 2026, 9:00am

Glassmill planning appeal - Day 1 Morning
Tuesday, 17th March 2026 at 9:00am

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Disclaimer: This transcript was automatically generated, so it may contain errors. Please view the webcast to confirm whether the content is accurate.

Good morning. The time is now ten o 'clock and the inquiry is open. My name is Ms Joanna

Gilbert. I'm a Chartered Town Planner and Planning Inspector. I have been appointed

by the Secretary of State to hold this inquiry into an appeal made by Promontoria Battersea

Limited under section 78 of the Town and Country Planning Act 1990 against the decision of

the Council of the London Borough of Wandsworth to refuse planning permission for comprehensive

redevelopment of the site to include demolition of existing building, an erection of a part

10 storey, part 28 storey building plus ground floor and basement levels comprising residential

use class C3, office use class E, community use class F2 and a restaurant class E with

associated car parking, cycle parking, public realm, landscaping and other associated works

at the Glass Mill, 1 Battersea Bridge Road, Wandsworth London, SW 11 3 BZ.

Can I just cheque, particularly for those up in the balcony, can everybody hear me?

Thank you very much.

If at any time anybody cannot hear anyone, please do indicate to me and I'll try and

make arrangements so you can do so.

Just to be aware, we are being live streamed today and that's the intention for the rest of the inquiry as well.

So if you are speaking, please use the microphone as it's usually essential for live streaming to pick it up.

Can everybody please ensure that all electronic devices are switched to silent, please?

In terms of evacuation procedures, it's my understanding that the Council isn't planning a fire alarm, you'll be pleased to hear today.

So in the unlikely event of a fire, please take it seriously and follow the procedure I'm about to outline.

So the fire alarm evacuation procedure is activated by the fire alarm sounding continuously.

Please leave by the nearest accessible route, do not delay or take risks, do not use lifts or re -enter the building unless instructed to do so by a fire marshal.

And fire marshals usually are indicated by wearing high vis jackets, lucky people.

The assembly point is the rear car park behind the town hall extension that is known as Delta Zone, fronting Ram Street.

and the assembly point can be reached by exiting the council chamber and down the main staircase,

turning a sharp right to exit the town hall via the exit doors, walking towards the town

hall extension and turning left to the designated car park. But I'm sure there will be people

outside directing in the event of an evacuation. Anybody who does have difficulty with evacuating

the premises would be given assistance from the council chamber.

For those who are planning to be here tomorrow, my understanding is that fire alarm testing

takes place at approximately 9 .45 every Wednesday and doesn't require evacuation. But we may

have a short intermission just before we start tomorrow.

Okay, so in terms of toilets, my understanding is both ladies and gentlemen's toilets are

located on this floor and there are signs indicating the direction of travel.

In terms of appearances, I would like to take the names of those who wish to speak.

It will be helpful to me if you can provide a list of appearances and append these to

your closing submissions, please.

If I use the wrong title today and on subsequent days,

please do correct me.

I may have my moments and forget.

But for the appellant, first of all,

could I please ask the advocate to introduce himself

and his fellow advocate and witnesses.

Thank you.

Thank you very much, ma 'am.

And we've got a schedule of appearances as you've asked,

which I'll ask to be handed up to you now.

We will put it on our closing submissions

in addition to that.

there are copies. I don't know if there's enough for everyone but I'm going to read it out verbatim in any event.

Thank you.

Ma 'am, you'll see that I'm Russell Harris, I'm King's Counsel, I'm assisted by Miss Anjali Foster who sits to my left.

I propose, as you know, to call three witnesses and in this order, although in topic order,

Mr Peter Barbeloff, who is the scheme architect, Dr Chris Mealy, who will give evidence on

townscape and heritage, and Mr Jonathan Marjanson, who will give evidence on planning and planning

balance matters.

Thank you. Are any additional people expected for the roundtable discussions today and tomorrow?

Yes, they are not identified on here. I'll ensure that by the time we get there, or indeed

by the first adjournment if you prefer it, that I provide you with a schedule of those

who will be appearing both in the roundtable in relation to the Environment Agency and

also in the third party roundtable for tomorrow.

Thank you, that's very helpful. And just for the record, the document that's just been

handed to me with the names and qualifications of the witnesses is now

ID01. Thank you very much. Okay so we've heard who the appellant is bringing as

witnesses could the council please could the advocate introduce himself and the

council's witnesses. Thank you. Yes ma 'am good morning we too have a list of

that I can ask that be provided to you now, please.

Thank you very much.

Thank you, ma 'am.

I appear for the local planning authority

at this public inquiry.

My name is Douglas Edwards.

I'm a barrister in KC,

and I'm instructed by Mr. Moore's,

Duncan Moore's of Ashford's solicitors.

In terms of witnesses, ma 'am,

Giving formal evidence to the inquiry will be miss Joanna chambers who will deal with planning matters

Mr. Ben Ely and mom you have their position and their seven o 'clock set out in terms of the roundtable sessions at this stage

We expect that three

Or two officers and my instructing solicitor will participate the officers being mr. Granger

Who is the East Area team manager who sits behind me and mr. Tiddly Tiddly who is the head of transport strategy?

Thank you very much and that document of the witnesses and those assisting with

roundtable discussions is ID02. Thank you. Okay and turning to the Battersea

Society. So the Battersea Society is leading a consortium of civic societies

and my understanding is that that comprises the Battersea Society, the

Chelsea Society, the Chainwalk Trust, Friends of Battersea Park, Putney

Society and the Wandsworth Society.

And they are a rule six party in this inquiry.

As confirmed at the case management conference,

I will generally refer to you as the Battersea Society,

unless otherwise advised.

But could the advocate for the Battersea Society

please introduce himself and his witness?

Thank you.

Yes, I can, madam.

So I am William Walton, and I'm a member of the Royal Town

Planning Institute.

I will just be calling one witness which is Michael Jubb.

Or Dr Michael Jubb I should say.

Thank you.

Sorry, just on other points, we'll obviously circulate odd copies of his witness statement on Thursday morning.

We don't have those today to circulate but they will be circulated on Thursday.

and just on a minor point I'm not sure if our power switch is turned on here

because we don't have power for power up our computers and I wonder if somebody

from the council could maybe help us on that. I know it's a trivial thing but it's

okay thank you. Mr. Grainger would you be so kind or

Mr Tiddley to assist the Rule 6 party with access to power.

Okay, thank you.

And Mr Walton, will there be any additional people participating in roundtable discussion today and tomorrow for the Rule 6 party?

I didn't know when to make this clear.

I won't be available this afternoon because I have other commitments in my other workplace.

So if there is a roundtable discussion this afternoon, my understanding is that Dr. Jubb would be involved.

And, sorry, and Mr. Philip White, I do beg your pardon. That's W -H -Y -T -E.

Okay, thank you. And I understand that we'll have additional people from the Environment Agency here this afternoon as well for the roundtable discussion.

And I will do introductions for the roundtable later. Can I cheque, is there anybody else who would like to speak at the inquiry?

Okay, can I take your names please?

My name is Mark. I'm a local resident.

And I already have your name on my list from an email that was sent in to my case officer.

So can I understand that you're supporting the scheme, is that correct? And can I cheque

if you're happy to take questions on what you have to say.

Thank you.

Do you have any time restrictions today?

Okay, well hopefully we should be done by then.

So I will note your name down,

start off with Mr. Littlewood.

Thank you.

And the gentleman with his hand up.

Are you supporting or objecting Mr Hamadouche?

Thank you.

And are you willing to answer questions, take questions on what you say?

Thank you.

And the gentleman in the beige next Mr Hamadouche.

and you might see them playing a little bit at school.

Okay, thank you. And are you also willing to take questions?

Thank you very much, Mr Canning.

And the gentleman behind. Hello.

Our resident.

Sorry, could you give your name again?

Riddle. Our resident.

Yep. And are you supporting or objecting to the scheme?

Against.

Okay, thank you. And are you willing to take questions on what you say?

Yes, but let me just clarify, that means against the developer.

Yes, so my understanding is that you're objecting to the development proposal, which would mean in this instance that Mr Harris would be able to ask questions of you.

Sure.

Okay, if he chooses to do so.

I have a timeframe issue today.

Okay, what's your time limits today?

I should leave here at noon but I could be back probably around 2 .30.

Okay. Well if we try and hear from you, Mr Hamadouche and Mr Canning, would you be happy,

would you be content to wait until after Mr Riddle?

Thank you very much for your understanding.

So if Mr. Littlewood goes first, Mr. Riddle second,

then Mr. Hamadouche and Mr. Canning.

Okay, the gentleman up there in the gallery.

My name is Sir Chris Burns and I am a guest.

And would you be willing to take questions?

Thank you.

And do you have any time limitations today?

Thank you very much, sir.

The gentleman over there next to Mr White.

And are you supporting the scheme or objecting to it, sir?

And do you have any time limitations today?

And are you willing to take questions?

Okay, thank you.

Is there anybody else?

Okay, well if anybody does come in late and wishes to speak I will ask again at the point

where we hear from speakers anyway.

Sorry.

And would you be willing to take questions on what you have to say?

And do you have any time limitations today?

12. Okay. We'll see how we go. Time. Okay. Thank you.

So just to double cheque, is there anybody here from the press today? Yes. Could I just

Just ask your name and which organisation you're representing.

Yes, I'm Robert Gibbon. I'm the editor of the Chelsea Citizen.

Thank you.

I'm John Cookson.

I work there for my own job.

Thank you.

And are you planning to take photographs today?

Yes.

I have no objection to photographs being taken as long as they don't disturb the inquiry proceedings

but is there anybody who doesn't want to have their photograph taken? No, it appears you're in luck.

Okay thank you but please don't disturb proceedings as you as you go along. In terms of filming and

recording as I've already said the event is being live streamed can I just cheque whether anybody

else intends to film or record the event?

It's not a stranger question as it might sound, it does happen. Okay, thank you.

And just moving on with my opening, the Case Management Conference was held for

this case on the 26th of January this year and that took place with

representatives of the Appellant, the Council and the Royal Sixth Party and

and that was held to discuss the procedure for the inquiry. The merits of the appeal

were not discussed and my note of the conference should be made available on the Council's

website if it isn't already. In terms of notification letters, I have copies of the

Council's letters of notification. The first letter was dated 2 January 2026 and that notified

interested parties of the appeal. The second letter dated 24 February 2026 confirms the

date, time and location of the inquiry. I also have a list of those to whom the notification

was sent and a copy of the site notice and where it was put up. So thank you to both

the Appellant and the Council for undertaking that work.

Just in terms of representations, you will be aware there were quite a number of representations

made about this scheme and I have copies of those representations and that's in response

to the appeal notification and to the original planning application. I have read them. I

will take them into account in reaching my decision. Can I just double cheque that the

main parties have had sight of those representations?

Yes, thank you. Yes, thank you, ma 'am.

OK. Mr Walton, have the Rule 6 party had sight of the representations?

Sorry, I do beg your pardon, can you repeat the question?

Have the Rule 6 party had sight of the representations that were made at application and appeal stage?

Yes, yes we have. Thank you very much.

Yes, we have.

Okay, so in terms of plans, I've been provided with a paper set of plans today.

Thank you very much for making that possible.

And they are, existing drawings are CD 1 .28 on the website.

and I have proposed drawings as CD 1 .29.

And can I just double cheque with the council,

are these all the plans that were determined by the council?

Thank you.

And have there been any,

it would be great if the person whose phone keeps pinging

could turn the sound off.

Just in terms of plans, have there been any changes to plans since the council's decision?

No, ma 'am. The plans are set out in CDs 128, 129 and then the list is at 130.

Thank you very much.

Okay. Just in terms of documents and any late evidence, I'd just like to make the point

now and move on. Inquiry processes are time consuming and costly for all parties involved.

And as an inspector, it's my role to carry out inquiries effectively and efficiently

and deliver high quality appeal decisions. In order to allow me to complete the inquiry

in an efficient manner. I have previously asked for information on matters such as conditions

and statements of common ground to address particular points of disagreement up front.

Now in these instances I have had to chase the parties in respect of those documents

and I was particularly disappointed to receive an agreed statement of common ground on flood risk

at after 5pm on Friday. In fact I had to ask my case officer to log back on late

to ensure that I received them.

The Environment Agency's concerns are not new

and the delays involved in finalising this Statement of Common Ground

have not been helpful.

So if I ask for further documents to be provided during the inquiry,

I expect them to be provided by the date requested.

If this is not possible for good reason,

I expect the relevant party to advise me of this as soon as possible

and to keep me updated on progress.

and in this way we're all respectful of one another and of time constraints.

But I would like to have a positive inquiry where everybody gets to say what they feel they need to say.

I wish to draw a line under my disappointment with the late receipt of the Statement of Common Ground

and to move on with the inquiry positively.

Any comment on that?

Mr Harris?

No, nothing from us, ma 'am, save our apologies and no disrespect was intended as you'll hear this afternoon

There's a reason why it came to you so late, but I'll say nothing about that now

Thank you

Mr. Edwards?

Nothing further from me, ma 'am. I must say that your comments are noted.

Okay, Mr. Walton?

Nothing from us.

Thank you. And in terms of documents and evidence, all documents and evidence should already have been provided.

If you do intend to submit anything further, could you please tell me now and I will ask the appellant first of all

Nothing further from us. Thank you. Thank you for confirming that mr. Edwards

Nor from us mom. Thank you. Okay, mr. Walton

No, nothing for us. Okay

mr. Woodell

Okay, well that's

perfectly fine to provide to me in due course once you've given your statement.

But thank you very much for confirming that.

So moving on to changes in national and local planning policy.

Reference has already been made by the main parties to the draught National Planning Policy Framework

upon which consultation has recently been undertaken.

and consultation on that document ran from 16 December to 10 March.

My understanding is that the Government is currently analysing the feedback from that

consultation as is the norm and an updated National Planning Policy Framework will be

published in due course. I have heard mutterings of the summer but we shall wait and see.

So it's unlikely that that will happen prior to the inquiry closing but we'll keep an eye

on that and obviously as and when it needs to be discussed the draught National Planning

Policy Framework will be discussed as well as the existing National Planning Policy Framework.

I also understand that the Council has recently adopted the Wandsworth Local Plan Partial

Review and I did receive a notice from the Council, thank you very much for providing

that. So that is CD 5 .44 in the Core Documents Library.

Just to clarify, the Local Plan Partial Review effects, to my understanding, six policies,

which are LP 23, Affordable Housing, LP 24, Housing Mix, LP 28, Purpose Built Student

accommodation, LP 29, housing with shared facilities, LP 30, bill to rent, LP 31, specialist

housing for vulnerable or older people. Now the council considers that the adoption of

the Wandsworth local plan partial review would not result in a reassessment of the planning

balance, but it would be helpful if there is any difference between the parties on this

that it could be raised as a consideration at the relevant time during the inquiry.

Are there any comments on either national or local planning policy change?

Mr Harris.

Nothing.

We agree with what you've said.

Thank you.

Mr Edwards.

Nothing further from us, Madam Mayor.

Thank you.

Mr Walton.

Nothing.

Thank you.

OK.

Planning conditions and obligations.

I have received a schedule of suggested conditions which has been the subject of some work prior

the inquiry, so thank you for undertaking that work. It's always helpful to front -load

work on conditions, particularly when there's as many of them as there would be for this

case. I also have a proposed legal agreement and I normally allow time for receipt of signed

and completed copy of the legal agreement. Can I just cheque with the appellant at this

point how long they anticipate would be needed in terms of timing for signing?

14 days would be adequate, thank you.

Okay, and just to cheque, that would include the Easter break potentially, if we're going on 14 days from the end of the inquiry, would that still be okay?

Yes, I'll let you know if it's not, but those are my instructions.

Okay, thank you very much for confirming that Mr Harris. Anything on conditions or obligations at this point? No? No? Okay, thank you.

Proofs of evidence and statements of common ground.

I've received proofs of evidence from the main parties' witnesses,

including rebuttals from the council and the appellant.

Thank you for those.

I've read them all and I expect them to be largely taken as read.

For interested parties, all core documents,

including the proofs of evidence and the rebuttals,

are available on the council's website.

Main issues.

So moving on to the main issues in this appeal, I set these out in the note that I issued

following the case management conference, but I shall provide them here for everybody's

information.

And main issue A is the effect of the proposal on the character and appearance of the area.

Main issue B is the effect of the proposal on the significance of heritage assets.

Main issue C is whether the proposal would make appropriate provision for infrastructure.

And main issue D is the overall planning balance having regard to the development plan and any proposed benefits

Can I just cheque with the parties whether there's any comments or change of position in terms of those main issues?

It's the no change in position. We agree. Thank you. Mr. Edwards. We also agree mom

But those are the main issues for the inquiry. Thank you. Mr. Walton. We concur. Yep. Thank you very much

Okay, so in terms of procedural matters, I shall follow the procedure in the 2000 inquiry

procedure rules. The inquiry is scheduled to last for eight days. I have issued a programme

prior to the inquiry which is available on the core documents library as CD2 .07. Thank

you for putting that up. Has everybody seen it? Okay, are there any comments from the

parties at this stage about the programme? Mr Harris?

Nothing from us. Nothing from us, Mum.

Mr Walton? Only to the extent that my availability on

this Tuesday afternoon and next Tuesday afternoon is, well, I will not be available, so there

are two afternoons that I won't be available, so I have to give my opening this morning

in case that things run on or run over, I'd prefer to do that today. If there are any

other reasons why I have to be absent and also I would notify but I've

indicated to my colleagues that I expect to be here for all but those two

occasions. Okay thank you and just before we move into talking about how the

inquiry will go, the appellant was kind enough yesterday to send some details on

some forthcoming TfL tube strikes and it's my understanding that they're

expected to start and affect all lines but to potentially differing extents.

Tuesday at midday to Wednesday at midday and then Thursday at midday to Friday at

midday and this is not this week this is next week. So I asked the case officer to

send an email round to the main parties to double cheque what the situation was

in terms of how much would those strikes potentially affect the ability of the main parties to

attend the inquiry here in this building next week.

With the, well, there's various worst case scenarios, it depends what you think a worst

case is.

But Mr Harris, can I understand the appellant's position in terms of the ability to get here and attend the inquiry next week?

We feel we can get here and attend, but of course we're not the only people at the inquiry and it's important that everybody can get here and attend.

From previous experience involving inquiries during a similar rail strike, London almost ground to a halt with all line bikes taken, all taxis taken,

and there were difficulties including with the inspector getting to inquiries.

If the worst comes to the worst, and, ma 'am, I think we should wait and see because it's

a moving feast, if the worst comes to the worst and it looks as if it's going to be

intolerably difficult for some people to come, we are not adverse to your suggestion of a

virtual second week of the inquiry, but we think it should be a last resort.

Thank you. Understood. Mr Edwards.

Well, my position is very much the same as the appellant's. As far as the council's attendees

at the inquiry, we think we can all get here next week because we're not dependent on the

underground. But as Mr Harris indicates, we're not the only people in the room and if others

find it difficult then we're not averse to the inquiry proceeding on a virtual basis.

Okay. Mr Walton.

Yeah, we take the same view. Representing local people is probably an opportunity for

them to do some walking so we if it comes to that but we have no problems

with either an actual or a virtual inquiry.

Okay so my view is that we leave things as is at the moment we monitor the

situation and we can revisit it later this week but in terms of the council it

would be helpful if the council could confirm that they would be able to run online and

that an update would be placed on the website for the inquiry to indicate that.

Thank you. I've already made provisional inquiries in that respect and I'm assured that the council

can make arrangements for the inquiry to continue virtually, probably using a Teams platform

and for live streaming to continue if the inquiry does proceed through that moment.

Okay, thank you. As far as I'm concerned, I would have no problem getting here and I

would have no problem travelling to and from the inquiry every day. Whether I could get

home might be another matter but that's an adventure for the future but I've

heard what everybody's saying we'll revisit it later in the week and go from

there okay thank you. Sorry mum can I suggest that we we do that on Friday

morning at the earliest so that there is perhaps then sufficient notice for

everybody to make sure that there aren't any people who turn up to an inquiry

that isn't happening on the following Tuesday. Absolutely, okay, thank you and if

anything changes in the meantime I'm sure you can update at the beginning of

a day. Okay, so when I've concluded my opening remarks I'll invite the

appellant, the council and the Royal Sixth Party to each make a brief opening

statement. This will help everybody to understand the main arguments and set

the scene. Then I will hear from any interested parties who wish to speak and I've already

taken a list of your names. And those who give evidence will normally be expected to

answer questions on their evidence from the opposing party's advocate and I may also have

some questions. Following interested parties' contributions and in order to set the scene

on the design of the proposed development, the Appellant's Architect Mr Barbeloff will

provide a factual presentation on the design of the proposed development and you should

be able to view that on the screens to either side of the dais.

In terms of the round table session that's programmed for this afternoon, that is programmed

to discuss flood risk and we're expecting attendance by people from the Environment

Agency and that is an opportunity for me to ask a number of questions of primarily the

and the Environment Agency in respect of flood risk.

On day two, there will be a round table discussion

on a range of issues which have been raised

by residents of Thames Walk and Albion Riverside.

And following this, the main issues

on character and appearance, heritage and planning

will be dealt with through formal presentation

of evidence and cross -examination.

The Council's witness on urban design and heritage,

Mr Ely will go first. The Appellant Advocate will have the opportunity to cross -examine

him and the Council's Advocate may then put some questions in re -examination. And there

will be an opportunity for any interested parties intending to ask questions in support

of the proposal and I may also have some questions. Then we will hear from Dr Jubb who will provide

his evidence for the Battersea Society and this will be followed by evidence from the

Appellant's Townscape and Architectural Quality Witness Mr Barbeloff. It's expected on Friday

that Dr Mealy will present his evidence in the same way with evidence in chief, cross

examination by the Council on Rule 6 and re -examination by the Appellant. And again local residents

who oppose the proposal may also ask questions of the appellant's witnesses.

I will ask questions at any stage in proceedings.

In week two, the same process will be followed for the two planning witnesses,

so that's Ms Chambers for the council and Mr Marginson for the appellant.

And if I can ask witnesses please to answer the question that is asked of you.

During cross -examination this will normally be a yes or a no,

which you will then be able to qualify afterwards.

conceding a point does not necessarily mean you have lost the case.

But stalling and having to be asked a question on multiple occasions by an advocate is not helpful to me or to the inquiry.

During the second week of the inquiry, as relevant to roundtable discussions and possibly in gaps between other evidence being heard,

I will hear discussions on conditions and planning obligations.

This is standard procedure. It does not indicate that I have made my mind upon the case and

it doesn't weaken the Council or the Rule 6 Party's continued opposition to the proposal.

Rather, if the appeal succeeds, any conditions imposed on the Planning Commission need to

have been considered carefully by all parties. After the evidence has been heard, I will

hear closing submissions from the Council, the Rule 6 Party and the appellant and I would

grateful for word copies of the closing statement to be provided electronically.

Following closing submissions and pending any applications for costs, I will close the

inquiry. If any applications for costs are to be made, this should be done before I close

the inquiry, but I am also required to remind you that I may initiate an award of costs

whether or not any application has been made by the parties. If I do this, it will follow

written procedure with the relevant party after the appeal decision is

issued and can I just take the opportunity now to cheque whether there

is any intention at this point to submit an application for costs. Mr Harris.

Not at this time, I'll keep it under review. Thank you. Mr Edwards.

The council's position is the same. Thank you. Thank you and Mr Walton.

None at all. Thank you. Okay and at the moment the programme suggests that I will conduct a formal site

visit on Thursday the 26th of March. Obviously if I'm not in London that day because of the tube

strikes that may be somewhat difficult but I'd just like to confirm that I visited the site and

and viewed it from public land, both in mid -February and yesterday.

And yesterday I carried out the site visit itinerary.

So I am familiar with the surroundings.

Obviously if any viewpoints are subject to considerable discussion during the inquiry,

I am very willing to go back.

The suggestion was during the case management conference

that the site visit did not need to be accompanied and as I've said I undertook

it unaccompanied yesterday for some hours. This should come as no surprise

given I think I mapped it at about 15 and a half kilometres but I'd just like

to take the opportunity to cheque the main party's views on whether an

accompanied site visit is necessary, whether that be next week or at some

other point depending on tube strikes. Mr Harris. No we think that probably what

you've done is sufficient but we welcome you going back we certainly don't think

you need to be accompanied. Thank you. Mr Edwards. I agree mum. Thank you. Mr Walton.

Agree. Okay thank you. And just in terms of breaks the programme allows for breaks

and this morning's session allows for the openings next and then a break after

the openings before we hear from interested parties. Are there any

issues with the length of the lunch break? I think I've allowed an hour each

time. Is that acceptable to all parties? Thank you.

I just want to ask, have you made a night visit to the site? That was suggesting that

there will be a great impact on the river and night on this tower.

I was intending to do so later this week.

Were you taking people with you or just on your own?

No that would be on my own. If anybody does want to point out any particular points that

I should go and stand at though, I'm very happy to do so.

I don't know if there will be people who would like to direct you to certain aspects of the site at night.

People who are not interested in the site.

Okay, well if I undertook a site visit at night with others there,

I would need attendance from the Appellant and the Council and the Rule 6 party.

Well I think it's a significant feature of this government at night.

Can I suggest a way forward on this that obviously there was a itinerary agreed

for the between the appellant and the local plan of I think the Royal Sixth Party for

your visit yesterday we might discuss the matters between us and do the same

thing in terms of a nighttime visits and obviously it's a matter for you

ultimately but that may or create the need for representatives of all the main

parties to accompany you. Okay that would certainly be acceptable to me if you

could liaise with Mr. Gibbon and get his views on which viewpoints and

anybody else's views indeed. Anything from the appellant on this?

That's very sensible. Okay and just in terms of viewpoints the letter that went

out, the second notification letter, did also ask for anybody to email viewpoints

in and it was my understanding that I don't think there was anything

dramatically different from the viewpoints that were already included in

the walking route which is available on the core documents page.

Thank you, you got there for CD206. So if anybody wants to have a look at that

and wants to liaise with the council in the breaks, that would be very helpful.

But yes, it was my intention to go and have a look later this week.

Okay, right. So on subsequent days, we'd be looking at starting at 10 o 'clock

with the exception of Tuesday the 24th and the rationale for that was that

I think we had quite a lot to cover that day.

But we'll keep timings under review as we go on.

If the advocates think further adjournments or breaks are necessary, please do let me

know.

And can I just double cheque with the council where the witness normally sits in inquiries

in Wandsworth?

The middle.

Okay.

Thank you.

So it's helpful if the interested parties in due course can come down and sit there

and obviously they'll change over but anybody who's up in the gallery, if you can perhaps come down in the break

between sessions and then be ready to jump in as needed.

Okay, and can I just double cheque, are we able to leave items in the room or in retiring rooms?

Yep, okay, thank you.

And are there any evening meetings that we need to be aware of?

Thank you.

Okay, so that concludes my opening remarks.

Are there any queries about procedure or other matters before we start?

start. No? Okay. In that case could I ask the appellant's advocate Mr. Harris to

make a short opening statement on behalf of his client. I've reduced it to writing

so I'll ask that that be handed out. Thank you and that will be ID03. Thank

Thank you very much.

Thank you.

It has got some photographs in it of the existing site which are redundant now because you have

told us you have been to the site.

Thank you.

This inquiry has the opportunity to demonstrate that the planning system has the flair, flexibility

and responsiveness to meet the urgent spatial needs of its capital city through the addition

of an elegant building of exemplary quality, one that will transform for the better the

borough's relationship with its river and the borough's most important crossing of that

river. The proposal has the unique potential at a time of pressing housing need to provide

a confident, high -quality residential building, delivering a new and mixed community with

a remarkable 50 % affordable housing. A grant of permission for this proposal will provide

a clear signal that the planning system is taking its role in promoting economic growth,

confidence and the provision of housing and affordable housing delivery seriously.

Proposition 1. The existing building harms both the setting of the listed Battersea Bridge

and the local wider townscape hereabouts. This first proposition is the starting point

and however much one would want to wish it away, it is, if you've been to the site, self -evident

and obvious. The existing building lies in an important prominent riverside location

at the southern end of an important crossing at the Grade 2 listed Battersea Bridge adjacent

to the Thames Path and within the Ransoms Dock focal point of activity. The Thames Path

here, as you'll know, is a national trail and one of the most important public rights

of way in the country. And yet, the existing building fails to positively contribute to

townscape or the riverside character area and harms the setting of the listed

bridge. It is mediocre or worse. It's a speculative, a -contextual and

architecturally poor quality with extensive inactive frontages that rise

above a plinth with grilled vents to a car park. The dark private

frontage lacks vibrancy and movement and fails to engage with its surroundings. It

has no street presence with a high brick retaining wall facing towards

Battersea Bridge and service areas occupying much of the rear.

The Thames path to its north fails to comply with accessibility standards containing steep

steps and ramps with unused space along the frontage resulting in a poor contribution

to the public realm.

The existing building within the close and immediate setting of Battersea Bridge harms

the appreciation of the significance of the bridge and as a result harms that setting.

The potential to remove this harm by redevelopment is evidently appropriate in

townscape and heritage terms and given that the existing building is six

storeys high, redevelopment at mid -storey levels, the local plan maximum for the

site, is not a justifiable or deliverable proposition as the evidence will show.

Any assessment of the impact of the proposal on character and appearance,

your item number one, and impact on heritage assets,

part of your item number two,

must as a matter of fact and law

have regard to the existing state and function of the site

and the heritage and townscape harms it causes.

A failure properly to assess and understand

this existing condition would result

in a fatally flawed assessment overall, the photographs.

Proposition two, the location can accept a landmark building.

The evidence considered site specifically and in depth

for the first time at this inquiry will establish that the acceptability of the site in the

context of its location and truly up -to -date policy to accept a high -quality tall building

such as that proposed. Sir Terry Farrell and Farrell's know and have mapped London authoritatively

over decades. Their London buildings, including Thameside buildings, have become recognised

as enduring pieces of integrated townscape and icons of the capital. The justification

and opportunity to add height at this specific riverside location was identified by Sir Terry

himself before his loss of health.

He guided the thought processes, ideas, and concept sketches in this case, and in many

ways this building represents his last work, a culmination of his fascination with accurately

scribing the shape of London and its river.

And it's not difficult to see why.

Battersea Bridge has a wide strategic and historic importance within the development

of London's urban structure.

It's built on a historic crossing point, which formed one of the earliest river crossings,

thus playing a significant role in the shape of London and in the historic role of the

borough, at this, its northernmost gateway.

The bridge itself, you'll have seen, is elegant, pragmatic, and functional, but still hugely

historically significant.

And the proposed site can reinforce the historic and functional importance of the crossing,

also supporting orientation and wayfinding across the river, and importantly at the same

time by removing a clear and mediocre detractor to the close setting of the bridge.

The bridge also has a distinct position within the sequence of London bridges, located at

a dramatic bend in the river, which allows an open quality and visual relationship with

both banks and their associated Thames reaches.

The very horizontality of the river in this area is already punctuated by tall buildings,

many also of great architectural quality, which add life, activity, and rhythm to the

riverscape.

The presence of such taller buildings makes an important contribution to the character

of this reach, and this very varied character is already part of the local distinctiveness

of the area, which consequently has been identified as having a low sensitivity to change in the

urban design study.

A building of height at this location along the bend of the river would form part of a

wider linear sequence of markers and add to local distinctiveness at a location which

can and should accept optimised change.

At a local level also, a tall building in this location will complete the Ransom Dock

urban area as the last remaining large site to be regenerated. The Albion Wharf

development by Farrell's friend and rival Norman Foster is a building of

very great scale and flamboyance. The proposal is the long stroke of a sinewy

exclamation mark which runs alongside the river and its associated wharf. The

Farrell's proposal will at one location allow the narrative linking two of the

greatest post -World War II architects and their work.

It will again at once appropriately complete the Albion Wharf exclamation while making

the regeneration of the wider industrial bank and helping to contribute to the completion

of a new, vibrant and active place.

When explored against the existing context and extant and emerging policy, the approach

of Farrell and Farrell's to this site is thus both justified and inspired.

Proposition 3, the new proposal, will enhance the setting of the bridge and the important

Thameside townscape character. The proposed development will substantially improve the

setting of the listed bridge, the character and appearance of the area, and the way in

which the townscape functions. At its base, the new building will have an active and welcoming

edge through a colonnaded frontage on the river, with a river -facing café as well as

five -arch colonnade that incorporates active uses along Battersea Bridge Road.

The proposals will deliver vastly improved high -quality public realm, including a generous

riverside space and enhancements to the National Important Thames Path.

The base of the building itself is an homage to the Bridge, creating drama and interest

for users of the road and the Bridge itself.

This will all result in a clear benefit to the setting of the historic asset and to people's

experience of the spatial townscape in the local area. It will hugely improve the way in which the area functions.

The two -part massing of the new building is contextually sensitive to the ransomed dock area, with the lower block

speaking directly to the mid -rise scale of the neighbouring Albion Riverside and the RCA development. The taller element of the tower

addresses the river directly and provides the marker for Battersea Bridge within the wider town and river scapes.

The tower has a slender vertical form reflecting the alignment of the bridge approaches.

Its curvy linear bow responds to the river and to the sinuous features of Albion Riverside.

When seen from both upstream and downstream, the scale of the building will be perceived

in the dramatic wide spatial context of the broad expanse of the Bending River,

which will clearly not be dominated.

The tower responds to both the greater scaled elements at Ransom's Dock and the pattern

of other towers along this stretch of the river.

The tower will, like others, be perceived with and from lower scaled areas.

These relationships are acceptable and do not cause harm in an area where such variation

in scale contrasts are already part of the character.

As explained by Dr Meale, the appeal scheme makes a positive contribution to the townscapes

but does not harm any locally identified or strategic views.

In relation to the effect on the setting of heritage assets,

your second main item, the proposals

have evolved and have been carefully designed

to remove or reduce harm to the setting of assets,

including the Church of St. Mary, Chelsea Royal Hospital,

Battersea Bridge, Battersea Park,

and the nearby conservation areas.

They are the five areas identified in the report

to committee as being the main heritage assets. The identified low level of less than substantial

harm to Albert Bridge has a clear and convincing justification and this harm is comfortably

outweighed by the public benefits. Now, it is true that the Council identify a different

level of harm to heritage assets to the appellant and of course heritage harm is always to be

given considerable weight and importance. Notwithstanding that, the Council, both at

decision -making stage and in evidence to this inquiry formally agree that even a greater

level of less than substantial harm identified by the appellant would be outweighed by the

public benefits of the proposal, and that heritage matters thus do not give rise to

a reason for refusal.

If of course the level of heritage and public benefits are greater or are to be weighed

more profoundly than those identified by the Council, then the justification for tall buildings

required by the framework and the development plan would inevitably be more emphatic.

See below.

A diversion.

These first three propositions have been carefully chosen and should be familiar, at least to

the council.

That is because not only are they self -evidently correct, but they also represented the council's

first formal pre -application response to a similar proposal.

Thus, the council formally accepted from the very outset in this case, A, quotes the existing

building detracts from the setting of the listed building in the Battersea Road street

scene. B, the proposal offers an opportunity to replace it with a building of much greater

architectural quality. And C, a tall building in this location next to Battersea Bridge,

a gateway to the borough, would act as a landmark and reference point. And I give you the reference

to that correspondence in the footnote. The essence of this advice remains valid. And

The Council's site -specific response to this proposal was,

and we say, remain sensible, accurate, and positive.

Proposition four, the proposal represents

exemplary architecture at this location.

We will shortly hear the design presentation

from the scheme architect who will explain

far better than we in opening the design rationale

for this high -quality scheme.

Its height and massing strategy with its base,

middle, and top of the building designed to respond

to context give rise to a building of elegance.

The simple architecture, including horizontal expression, terracotta panels, the vertical recess and the crown of the tower,

result in a well -proportioned and contextual building of the quality expected by policy and of this architectural house.

The London Plan, as you will know, rightly requires all tall buildings to be of exemplary quality.

The London Plan provides for this in D9 and the GLA at no stage has indicated that this proposal is in breach of this requirement.

The Council also has not during the application process taken any issue with the detailed

design quality of the proposal.

There is no design quality or, as we have seen, heritage reason for refusal.

Proposition 5, the local plan is A, out of date insofar as it seeks to protect existing

local density and character, B is deliberately not to be read as a bar to tall buildings

here and C, seeks to protect heritage assets from harmful impacts of tall buildings unless

the impact is outweighed by the public benefits.

We spend a lot of time on the policy so I'll be very brief. Policy LP 4 of the Wandsworth

Local Plan sets out the policy for tall and mid -rise buildings in the borough but it also

makes clear that all applications for tall buildings will be assessed against the criteria

set out in part C and D of D9 of the London Plan.

The tall and mid -rise building zones referred to in the policy are based on the UDS dated

23 September 2021, which itself was based on the version of the NPPF dated February

2019, and those zones are said to be there to help steer selection of appropriate sites.

Of course, the present NPPF has removed previous requirements which sought to protect existing

character from increases in density, including, for example, the removal of paragraph 130

of the December 2023 version, which said density may be inappropriate if the resulting built

form would be wholly out of character with the existing area.

That difference of emphasis is retained and expanded upon in the present emerging NPPF

that you have already asked us to discuss.

The emerging NPPF is addressed here, as it must be, because if it comes into force during

the determination period, it's sensible for all parties to have discussed it here.

It places yet greater emphasis on increasing densities yet further in urban areas.

The Government intends, and it's a clear direction of travel, for substantial weight to be given

to redeveloping underused land and buildings and creating additional homes.

There's also proposed to be a substantive change to policy to direct that densities

for residential and mixed -use developments within settlements should increase, and that

the existing character of an area, though relevant, should not preclude development

which otherwise makes the most of an area's potential.

In this context, to the extent that LP4 and the building zones identified in the UDS seek

to protect existing density and pre -existing low -rise character, they are out of date.

Insofar as they seek to protect the more statically protected and senior heritage assets, it is

level of harm identified by the council. Moreover, when interpreted correctly, LP4 does not and

should not act as a bar to the grant of planning permission for tall buildings which fall outside

tall building zones. And to be fair, that's not the council's case. The inspectors examining

the local plan proposed modifications to LP4 to ensure that it complied with policy D9

of the London Plan and to ensure that it does not prohibit the development of tall buildings

outside of tall building zones. Both D9 and LP4 read together permit tall buildings outside

of tall building zones based on an assessment against detailed criteria including visual

function functional and heritage impact. As will be explained in the evidence the proposal

complies with these criteria and thus meets the policy. In fact as I've said that's the

council's position the proposals could be acceptable if their impact is acceptable and

irrespective of the zoning of the site. That's the issue for the inquiry.

Finally, policy protects heritage assets from tall building impacts,

but the policy, both national and strategic, allows permission to be

granted where the public benefits of a proposal,

which can include heritage benefits, outweigh harm caused if

any. As explained above, it's common ground between both the appellant and

the council that the level of heritage harm caused

on either party's expert evidence by this proposal

would be outweighed by the public benefits,

however defined and weighed in this case.

Proposition six, the penultimate proposition,

the application site is unique in both its location,

which I've spoken about, which as a result produces

and allows the provision of an appropriate

residential tall building, but also the provision

of much needed 50 % affordable housing.

For the reasons already mentioned above

and as will be explored in evidence,

this is an extraordinary location.

The outstanding location is not only a townscape opportunity, but it also drives values to

a very significant degree, which means that the scheme is able to deliver 110 new residential

units with 54 of these, which is 50 % by habitable room, unheard of in London at the minute,

as affordable housing, all at social rent levels.

This is a unique and totemic opportunity to optimise the delivery of housing and affordable housing on this Brownfield site.

This is particularly so given the house building crisis in London and the fact that there were no social rented affordable housing starts at all in Wandsworth in the years 2024 to 2025.

The need for a step change in policy is particularly acute in London at present.

The annual requirement for housing on all tenures is now 88 ,000 net additional homes

per annum.

And London is not coming anywhere close to delivering these figures and there has been

a dramatic decrease in housing completions over the last 18 months, a decrease that won't

figure in the five -year land supply or housing development targets.

Towards the end of 2025, such was the emergency that the government and the

Mayor of London, recognising that there's a perfect storm, issued new emergency

measures to tackle the house building crisis in London. In these circumstances,

nothing less than substantial weight should be given to these benefits,

housing and market and affordable housing provided by the proposal. Housing

benefits are already agreed with other benefits to outweigh any heritage harm.

allowing such harms to be given considerable weight and importance.

If appropriate, substantial weight is, as we say it should,

be given to the delivery of 110 new units,

then such a balance would be yet more emphatic, as mentioned above.

Proposition 7, there are no other planning issues

which require the refusal of this brownfield regeneration.

Paragraph 125C of the NPPF provides that substantial weight

should be given to the value of using suitable brownfield land

within settlements for homes.

and other identified needs, and that such proposals should be approved unless substantial

harm would be caused. The direction of travel set out in the emerging NPPF is intended to

further strengthen this imperative. The issues raised by the Battersea Society and third

parties are all addressed in evidence and in the report to committee. There is no time

in this short opening to address them in full, and I mean no disrespect that I haven't done

that, save to say that they also do not come close to amounting to substantial harm in

the circumstances of the case.

Neither the counsel nor the appellant regard the EA objection as giving rise to a reason

to turn away the benefits of the proposal, and that, on examination, is clearly accurate.

The issue now appears, we'll see this afternoon, but it now appears to be one of the necessity

or otherwise of conditions which can be considered later today and imposed by you if proven necessary

but we don't think they are.

Overall, for the reasons that will be fully addressed

in evidence of this inquiry,

we ask, ma 'am, that permission for the appeal scheme

should be granted. Those are our opening submissions.

Thank you, Mr Harris. Could I ask the council's advocate,

Mr Edwards, to make a short opening statement

on behalf of the council?

Yes, ma 'am. We have reduced our short opening statement

to writing. I can ask that that be distributed to you

and to others now.

The

London Borough of Wandsworth as the local planning authority on 24 April of last year

refused planning permission for the appellant's proposal,

and it did so for two reasons.

The second of those reasons concerned the absence

of a completed planning obligation.

This reason for refusal has been overcome by the agreement,

as between the appellant and the local planning authority,

of a draught planning obligation, which

delivers what the local planning authority considers

to be necessary.

The agreement of a draught planning obligation

is without prejudice plainly to the local planning

authorities' fundamental objection to the scheme

on the grounds expressed through reason for refusal one.

The local planning authority's concern as expressed

through reason for refusal one is

that the proposed development is simply too high

and is of a scale which generates

a sharp and discordant relationship

to its surroundings and which harms substantially

the character of its surroundings, both localised

and over a wider distance.

This impact, we say, gives rise to a clear conflict

with the development plan which is not outweighed by other material considerations.

For the avoidance of doubt, the local planning authority does not oppose the principle of

redevelopment of the appeal site.

It is the form of the redevelopment that is proposed that the local planning authority

objects fundamentally to and opposes.

The planning authority will address its concerns as expressed through reason for refusal one

and your first main issue through the evidence to be given to the inquiry by Mr.

Ely and by Miss Chambers.

At this stage, we make the following short points.

First, the local planning authorities local plan was adopted in July of 2023.

As is required of it by policy D9A and B of the London Plan 2021,

the local plan defines at what height a building is considered to be a tall

or a mid -rise, be tall or mid -rise,

as well as defining locations where tall buildings

and mid -rise buildings may be appropriate.

The local planning authority identifies the appeal site

as within a zone suitable for mid -rise buildings.

And a mid -rise building on the appeal site

is identified as a building of six storeys.

The appeal site, notably,

is not within any tall building zone.

Tall building zones, 03 and 04,

are located respectively to the east beyond Battersea Bridge Road

and to the west of the appeal site.

That's the wrong way around, that should be to the west and to the east of the appeal site.

To the west beyond Battersea Bridge Road and to the east of the appeal site.

Within those two tall building zones, the appropriate height is 7 to 12 storeys or 21 to 36 metres.

The appeal site was excluded from both of those two tall building zones

and the appeal proposal extends to 29 storeys, including its ground floor,

with a rear block to the south of up to 11 storeys.

As such, it is of a height which is well in excess of that which is appropriate

for the mid -rise zone in which it's located.

Indeed, it is over double what is appropriate within the two tall building zones

to the west and to the east.

The recently adopted local plan was prepared in response to the urban design study

of 2021 prepared by Arup.

The Urban Design Study, or UDS, informed the growth strategy of the local plan and formed part of the evidence base against which the soundness of what was to become the 2023 local plan was examined.

It appears to be accepted by all participants to this inquiry that the UDS is a material consideration in the determination of the appeal, as plainly it is.

The UDS sets out the justification for the height range for tall and mid -rise buildings.

And the UDS also sets out the justification for the identification of tall and mid -rise building zones,

including those comprising and in the vicinity of the appeals site.

The inspectors who examined the soundness of the submitted draught of what is now the adopted local plan

found the UDS to be a proportionate and robust response to identifying tall buildings.

and the appellant too seems to accept that the UDS is a robust and reliable document,

as indeed it is.

It provides a clear and compelling justification for the identification of the appeal site

as appropriate for a mid -rise but not a tall building zone.

The appellant's attempt to secure a change to the zoning of the appeal site and to the

local plan parameters for future development of the site before...

So that's before a superfluous,

through the local plan examination process did not succeed.

Let's read that sentence again.

The appellant's attempt to secure a change to the zoning of the appeal site

and to the local plan parameters for future development of the site

through the local plan examination process did not succeed.

The appellant's proposal is for a very tall building,

but the appeal site is located outside any tall building zone.

The proposal exceeds materially, indeed fivefold,

the height appropriate for a mid -rise zone in which it is located.

And the proposed development gives rise to a conflict with policies D9 of the London

Plan and LP4 and PM9 of the Local Plan in these respects at least.

However, the Planning Authority's case goes further.

The heightened scale of the proposed development gives rise to townscape and visual impacts

that will be experienced over an extensive area and which we say generates substantial

conflict and harm to the spatial character of the areas of both Wandsworth and the Royal

Borough of Kensington and Chelsea in which these impacts will be experienced.

These impacts, which are identified and explained in detail in Mr. Ealy's evidence, give rise

to a conflict with the range of considerations identified in D9 and LP4, leading, we say,

to a clear and substantial conflict with the parts of both policies as a whole.

We will not in this short opening statement rehearse Mr. Eby's assessment.

We do however make the point that his concerns about the height and scale of the proposed building

are reflected in the views of others whose assessments deserve indeed command considerable weight.

These include the Council's design review panel, the Greater London Authority,

the Royal Borough of Kensington and Chelsea and in terms of impact on the historic environment, Historic England.

It is notable that these consultees, including statutory consultees, are at one in terms

of identifying appreciable levels of harm that arise from, in particular, the height

of the proposed building.

Unsurprisingly, given that the appeal site is within Inner London, it forms part of the

setting of a range of heritage assets, including some of the highest sensitivity located both

on the north and the south sides of the River Thames.

The local planning authority has identified harm to the significance of a range of designated

heritage assets as a consequence of the proposed development.

And if accepted by you, this harm should form part of the planning balances.

The Planning Authority has however made clear that the public benefits of the scheme are

such that the heritage harm is outweighed and the Local Planning Authority does not

seek the dismissal of the appeal on grounds of harm to heritage assets.

The Local Planning Authority most certainly does however seek dismissal of the appeal

on the basis of substantial harm to spatial character.

If, as the local planning authority contends,

conflict with policies D9 of the London Plan

and PM9 and LP4 of the local plan arise

so as to give rise to a conflict with the development plan as a whole,

then the appeal should be refused

unless material considerations justify a different outcome.

In terms of the MPPF, it is common ground now

that the local planning authority is not in deficit

in terms of housing supply,

nor has it been found to have failed the delivery test.

The tilted balance provided for within paragraph 11D is not engaged.

The MPPF requires that new development adds to the quality of the area in which it's located,

is visually attractive as a result of good architecture,

and is sympathetic to the character and history, including the surroundings,

surrounding built environment and landscape setting.

By reason of excessive height and scale,

this development is very far off meeting what is required by paragraph 135

and indeed other design -related policies of the MPPF,

including, for example, paragraphs 131 and 139.

The MPPF does, of course, seek effective use of land,

including brownfield land within settlements,

not leased through paragraph 125c.

However, here we say the support for such development is displaced

by the substantial harm to spatial character that would arise.

The appeal proposal delivers benefits, including through the delivery of new homes and public realm improvements,

and these and other benefits must be attributed weight.

The extent of weight to be attributed to the quantum and tenure of the affordable housing offer,

which on its face exceeds policy requirements, will need to be explored in evidence.

The Planning Authority's case is that on the required balance, these benefits taken as a whole do not justify the harm caused

or outweigh the statutory presumption arising from development plan conflict.

Planning permission should be refused and the appeal dismissed.

And, ma 'am, in due course, that is what I will be inviting you formally to do.

Those are the short opening submissions on behalf of the local planning authority.

Thank you very much, Mr Edwards.

Can I ask Mr Walton, on behalf of the Battersea Society,

to please make a short opening statement?

Yes, Madam, they have been distributed now. We have seven copies, actually, because I

have one.

Thank you very much. That is ID05.

So over to you, Mr Walton, whenever you are ready.

Yes, and will these be placed on the website?

Yes.

So you want an electronic copy at some point?

It would be helpful if all of the documents that have been submitted so far today, so

that's ID01 to ID05 could all be placed on the core document library, so if people

could provide electronic copies to the council that would be most helpful.

Not to Alison Dyson?

Sorry?

Not to the case officer at Pins.

No, because she doesn't have control of the...

You can copy her in, but she doesn't have control of the court documents.

Mr Grainger would be more helpful.

Thank you.

Thank you, madam.

OK, so it's a short opening statement on behalf of the consortium,

which I'll explain or restate the members of.

Well, in fact, on the front cover, if I can just draw your attention,

And just to confirm the list of parties that you referred to earlier on, this opening statement

is made on behalf of the Battersea Society, the Chelsea Society, the Chaney Walk Trust,

Friends of Battersea Park, the Putney Society and the Wandsworth Society.

Madam, this opening statement is presented by myself, William Walton, a member of the

of local interest groups comprising, as I say,

I will repeat, the Battersea Society, the Chelsea Society,

the Cheney -Walt Trust, the Friends of Battersea Park,

the Putney Society, and the Wandworth Society.

And I will say, just slightly to part,

that when Dr. Jubb presents his evidence,

his witness statement, in the appendix to that,

there will be a list, and I think also reference

to the number of members that each society has within it.

And I also want to say very briefly that societies do,

their membership is based in large part upon a fee.

So it's not simply something that people just sign up to,

it is something that they actually subscribe to.

These local groups have been accorded Rule 6 status

at this planning appeal inquiry.

And the refusal of permission for the development

of a 29 -storey tall building at 1 Batsy Park, sorry, for the development, into the refusal

of permission for the development of a 29 -storey tall building at 1 Batsy Bridge Road, London,

SW 11 3 BZ.

These parties speak with one voice and with one intention, to present their collective

case to the Inspector in the belief that the appeal for the proposed Glass Mill Tower should

be dismissed.

Each of the six separate groups in the consortium has been involved in making representations

to Wontworth Council, hereafter referred to as a council, in respect of the Glassmoor

Development Proposal from the very earliest stages in the planning process.

They attended various public consultation meetings and made written objections to the

original and then the later revised planning application.

Moreover, at an even earlier stage, most were involved in making representations to the

Council during the formulation of its currently adopted local plan.

In short, these civically minded groups have engaged in the planning process at every relevant

stage in relation to this development.

Links to the websites for each of the groups are contained at Appendix A of Dr Jobs'

statement. It is instructive to note that 763 objections were received by the Council

to the original planning application and a further 660 to the later revised version.

This underscores the widespread concerns and depth of anger prompted by what many people

consider to be an inappropriately tall building located within an area designated in a very

recently adopted local plan for much more modest scale projects.

And I will say just briefly that we endorse the opening statement made by Mr Edwards.

It is acknowledged that many of the representations were received in support of the scheme, and

we know that there are supporters here today of the scheme, and we will deal with this

later on in the consortium's evidence.

These six separate groups supported the decision of the Council to refuse planning permission

for the proposed development. Nevertheless, to ensure that their collective voice is heard

and to ensure that all of the relevant issues are properly put to the Inspector, the Consortium

decided to apply for Rule 6 status for this Appeal inquiry in January 2026 and the Consortium

duly submitted its statement of case, Timelessly or Timelessly, in January 2026.

To this effect I will be presenting one witness on behalf of the consortium.

That is Dr Michael Jubb, MBE, a longstanding resident of Batsy and current Chairman of

the London Forum of Amenity and Civic Societies.

He will present evidence on planning policy, design, heritage impact and other issues relevant

to the appeal proposal.

As you will see from this witness statement when it's distributed, Dr. Jubb has a long -standing interest in urban history

and has served on the Battersea Society's Planning Committee for nearly 10 years.

During that time, he has appeared at the Examination Public for the Council's Local Plan in 2022 and at its Partial Review in 2025.

To add to his credentials as a witness at this inquiry, he also serves as Chair of the Council's Conservation and Heritage Advisory Committee.

Sorry, that's the end of the sentence. So let me go on to the consortium's case.

At Section C of his evidence, Dr. Michael Jubb will consider whether the appeal proposal is an appropriate form of development for the Glass Mill site.

His evidence will demonstrate that the appeal proposal fails to accord with the statutory

requirements set out in Section 38 .6 of the Planning Compulsory Purchase Act 2004 and

restated at paragraph 48 of the MPPF 2024.

As he will explain, this is because the proposal fundamentally conflicts with the development

plan, being the London plan of 2021 and the ones with local plan 2023, and also that there

There are no material considerations that should indicate that this conflict should

be set aside.

First he will demonstrate the appeal proposal breaches London Plan, hereafter LP, Policy

D9B, in that the scheme is located within an area designated in the ones with local

plan at appendix 2 for buildings restricted to a maximum of six storeys in height, being,

as I say, mid -rise.

And that due to the significant effect on the townscape

and important heritage,

it fails to meet the various requirements laid down

in London Plan Policy D9C.

Second, he will show that the proposal fails to comply

with the recently adopted ones with Local Plan Policy PM9,

as well as the LP4B, as already alluded to.

The appeal site is not located within a tall building zone on the Wandsworth Thames riverside

stretch.

Dr. Jubb will also demonstrate that the tall building's policies in the Wandsworth Focal

Plan are themselves the product of a methodical, robust and considered analysis of the scope

for such structures across the borough.

These policies reflect the findings and recommendations contained within the urban design study which

which Mr Edwards referred to a few minutes ago,

that study being a detailed investigation commissioned

by the council and conducted by Arup in 2020,

which Dr. Jubb will refer to in his evidence.

This urban design study concluded

that the Wandsworth Riverside area

was not an appropriate location

for the height and size of a building subject to this appeal.

Or certainly this particular site was not suitable

for that height building.

or indeed any building of, no part of the stretch is obviously identified for buildings

of height anywhere remotely close to what's been proposed.

Instead it proposed that the height of buildings be limited to seven to 12 storeys for the

inner section of the block between the Albert Bridge and the Bathsea Bridge and furthermore

it concluded that the outer part of the block, including the appeal site, be restricted simply

to mid -rise buildings to be no taller than six storeys.

Those conclusions were largely accepted by the planning inspectors at the examination

into the Wandsworth Local Plan and, as stated, incorporated into the policies which formed

the reasons for refusal for the current glass mill scheme.

As Dr Jubb will remind this inquiry, the inspector to the Wandsworth Local Plan examination concluded

that any tall buildings outside of designated tall building zones should be extraordinary

rather than ordinary. And that's at paragraph 117 of the inspector's report. It is the consortium's

view that this test must therefore apply for tall buildings within the mid -rise zone as

well as those in the high -rise zone where the appeal scheme, as I say, the mid -rise

zone being where the appeal scheme is located. Dr Jubb does not accept that the appeal tower

is extraordinary in design and appearance and, you know, by extension or do any of the

consortium accept that.

Moving on at section D of his evidence, Dr. Jubb examines the claims made by the appellant

about the effect that the scheme would have on the wider townscape and the spatial character

of the area.

As Dr. Jubb will note, the guidelines for the Landscape and Visual Impact Assessment,

the third edition, acknowledge that assessments of visual impact inevitably contain an element

of subjectivity and that the evaluation task is an art rather than a high science.

And proceeding from this premise, Dr. Jubb will take issue with the conclusions reached

in the appellant's Built Heritage Townscape Visual Impact Assessment, or the BHTVIA, which

I'm sure we're going to hear a lot about over the next few days, that the scheme would only

have low to modest impact on views from such places as the Chelsea Embankment, Beaufort

Street, Batsy Park, and that should be Park rather than par, I apologise, Batsy Bridge,

Albert Bridge, Chelsea Bridge, and Batsy Bridge Road, Chaney Walk, and many other places.

Instead, he will argue that the scheme will be an incongruent structure and will jar with

the surrounding area.

He will also argue that the structure is not exceptional or extraordinary of extraordinary

architectural quality I've already stated.

This lack of congruity with the surrounding area stems, as Dr. Jubb will argue, from a

combination of the height and isolation of the Glass Mill site relative to other tall

buildings within this immediate area of London.

It will be much higher than most other tall buildings within the built heritage townscape

visual impact area.

Furthermore, it will not be part of a cluster.

Instead, it will be some distance from other tall buildings located at Vauxhall, Bassey

Power Station, World's End, Chelsea Waterfront and Monteveteran.

As is evident from the documents submitted by the appellant in support of the planning

application and in its statement of case, it is apparent that it considers that a critical

argument in favour of the scheme is that the 29 -storey building will act as a marker signifying

at entrance to the borough.

But as Mr. Jubb will contend, there is little policy support for this marker argument.

Moreover, he will show that many of the other markers cited by the appellant in their various

documents such as the Shard do not correspond historically or geographically to the various

claimed partner bridges along the River Thames.

In Section E of this evidence, Dr. Jubb will argue that the methodological approach used

by the appellant to assess the impact of the proposed scheme on nearby designated heritage

assets, fails to comply with the approach recommended by the GLA.

Instead of preparing a separate heritage impact assessment, the appellant has prepared a built

Heritage Townscape Visual Impact Assessment document to assess the impact of the proposed

scheme on the townscape and on the setting of designated heritage assets.

Dr Jubb will argue that this approach fails to give proper consideration to heritage issues

with the result that the impacts are materially understated and the conclusions that stem

from it flawed.

He will also state that the appellant's built heritage,

townscape, visual impact assessment,

fails to give proper consideration

to the issue of cumulative impact.

That is to say the impact that the proposed tall building

would have in combination with existing

and permitted tall buildings on the setting

of designated heritage assets.

The submitted BHTVIA is thus at odds with the London Plan, Policies HC1C and Policy

D9C, and also at odds with the guidance prepared by Historic England and the GLA.

Dr. Jubb will then argue that because Historic England and the Council were largely reliant

on the contents of the appellant's BHTVIA document

to formulate their assessment.

In some instances, they also understated the harm

that would flow from the scheme

on the setting of designated heritage assets.

From paragraph 59 onward, in Dr. Jubb's witness statement,

which I say will be disruded on Thursday,

Dr. Jubb will identify those heritage assets

where the assessment of the likely impacts

is at variance with that given by one or more

of the appellant, Historic England, and the council.

These instances of understatement within the appellant's

study include, for example, the Westbridge Road

Conservation Area, Chaney Walk, Bassey Bridge,

St. Mary's Church, and Albert Bridge.

In section F, Dr. Jubb will argue that the proposed scheme

will be too large, too great in mass,

and too high for the site's footprint.

As he notes, the scheme would maximise development capacity

as opposed to optimising it.

And we note that there is a difference,

so as advised under policy D9LP.

Maximising and optimising are not

to be treated as synonymous or interchangeable terms,

but are instead quite different.

and Dr. Jubb will give evidence on that.

After that, he will examine the impact of the appeal proposal

on the public realm, and that will be at Section G of his evidence.

As he will note, the scheme will not lead to any material improvements

to the adjacent Thames path, and I won't say there to any significant improvements.

He does acknowledge, as I say later on, that there will be improvements,

but we don't believe or he doesn't believe significant.

It will therefore represent a missed opportunity

for what is an important public asset.

Under other matters of his evidence, Section H,

Dr. Jubb will consider the issue of transport, office space,

daylight, sunlight, and overlooking,

play space, and public consultation.

He will explain that the use of the River Thames

for the removal of demolition spoil and the delivery materials has been dismissed without

any conclusive evidence or investigative reports. He will also argue that the scheme will contribute

to short -term congestion resulting in the loss of valuable office space and provide and over

providing for children's, sorry under providing for children's play space with no access for

occupants of the open marking housing units. Moving on, he will argue that the level of

public support claimed by the appellant for the scheme is based in large part upon the

results of a survey of surveys or leaflets conducted and distributed by the appellant

that contained a series of leading questions designed to direct respondents to give what

amounted to predetermined answers. These surveys were supplemented by what is understood to

be a pre -drafted letter of support for respondents to sign.

Finally, Dr. Jubb will perform the planning balance, and that's at Section I of his proof

of evidence. He acknowledges that the scheme will provide several potential benefits in

the form of high quality, affordable work space, affordable housing, and we do not resile

from that, community space at a peppercorn rent, a restaurant, improvements to the Thames

Path, space for public art, funds to promote public transport improvements, and short to

medium -term employment benefits. However, for reasons that will be set out, he concludes

that jointly and severally these benefits do not outweigh the appeal proposal's clear

conflicts with planning policy. And finally, in my conclusions, Madam, for the reasons

set out above, I respectfully request that you dismiss the appeal and refuse planning

permission for the proposed glass mill development. And that's the end of my submission.

Thank you Mr Walton. Just looking at the time, we're running very slightly behind, but if we stick with coming back after a break at 11 .45 that hopefully allows some of the people with more time constraints to be heard first.

So just before we take a break, I'd just like to advise everybody that the live streaming remains on during the break.

So you will be being filmed,

but you will only be audible if there are microphones on. So I suggest if you're having any private conversations

and you don't want to be lip -read, don't stay in the room.

But just so you know. And in terms of

coming down if people could come down from the gallery if they're speaking so

that people can easily make their way to the seat with the microphone at the

front for being an interested party. Okay so the time is now 11 .33 if we take a

break until 11 .45. Okay Mr Riddle.

still on the date this afternoon?

It will depend on how long it takes other people to be heard.

And I do have a roundtable discussion timetable

for this afternoon.

Recommendation on that could be back,

because I'm just trying to get a little bit.

Yes, sure.

What time are you thinking you would be able to be back?

I would hope to be back by 2 .30.

Okay, well if you're not back before Mr Barbeloff gives his presentation, I don't have a problem with hearing from Mr Riddle after if that's okay with everybody else.

Perfectly fine for us, certainly.

Okay, so if you make your way back and make me aware that you're here, Mr Riddle, that's fine.

Very much.

I will see everybody else at 11 .45.

Thank you.

Is it behaving differently?

Okay, the time is 11 .45.

If everybody could take their seats, please.

While that's happening, Mr Hamadouche approached a member of our team

just because he was closest, he's had to leave for a family emergency.

I don't know any more than that.

Right. Well, if Mr Hamadouche does feel the need to return at some point, then we'll cross

that bridge when we come to it in terms of taking.

The council will try and get that message to him.

Yes. Okay. But understood, thank you very much for letting me know.

Okay, so the first interested party I've got in the list is Mr Littlewood. Could you

come and just sit down at the microphone here? Right, so Mr Littlewood, you're speaking

in support, so just to clarify because a member of the public asked me during the break, if

somebody is speaking in support the opposing advocates can ask questions of them. So in

this instance that would be the council and the Rule 6 party. It is not the opportunity

for other interested parties to ask questions of them. If an interested party wishes to

ask questions of witnesses later, certainly opposing interested parties can ask questions

of the appellant's witnesses in due course. But just to clarify.

Okay, so over to you Mr Littlewood. Thank you.

Thank you, ma 'am. My name is Mark Littlewood. I'm a local resident in Wandsworth and have

been since 2003 when I bought a two bedroom flat in the Falklands Estate on Grant Road.

Since 2003, the value of that property has multiplied three times over, which is very

good news for me. It has made me the best partner of half a million pounds, but is not

a sustainable approach to our housing system and is grossly unfair to those who are attempting

to get on the housing ladder. For decades now, I've been personally committed to greatly

expanding development in the UK in general, but in London in particular, and I am deeply

concerned about the lack of housing that is available in the capital city in particular.

When developments have happened more proximate to me than the one under consideration at

this inquiry, I have occasionally had questions of the developers, but have basically been

enormously supportive of them.

For example, the grad pad that has recently been built, a few years ago, was constructed

right next to my block of flats on Grant Road.

I'm looking forward to the wider development

at the back of Clapham Junction in the years to come.

We've already heard from,

in the appellant's opening statement,

the, I think, under -ambitious housing target for London,

but the fact that we are falling enormously short of it.

And I think it is quite impossible

to be in favour of more house building in general,

whilst being against virtually every specific scheme

that is put forward.

The downsides of development as a general economic rule

are concentrated and often heartfelt and genuine

amongst those who suffer them.

The upsides are much more diversified,

much more widespread, and much harder to measure,

but that does not mean that they are not real.

I've had the opportunity today,

thank you to my, thanks to my flexible working arrangements,

to be able to come and share my thoughts

about why I'm keen for this project to go ahead,

and I would say, with no apology,

dozens and dozens more of this ilk.

I claim only to speak for myself, but I suspect that a good number of people minded of my

particular opinion that development is to be greatly welcome simply don't have the opportunity

to give up a morning of their time and share their thoughts or the time to go through every

last detail of the proposed plan.

The benefits to those of us not immediately in the area, this doesn't impact upon me directly,

it's not in my line of sight,

I do go to that area relatively frequently,

but it's a good chunk of distance away,

will be the overspill effects.

I'm not undertaking personally now

that I will definitely visit the restaurant

that's proposed if it is built,

but the fact that amenities and facilities

will be expanding in the Wandsworth area

is extremely good news,

and the overspill effect of that, better still.

More residents are able to demand and pay for more services,

has an effect right throughout the borough,

one that I wish to be a beneficiary of.

I want to see not just London,

but in particular the borough I live in,

growing and improving and developing.

And we appear for many years to have a problem

moving the dial in that direction.

The present ratio of mean incomes to average household costs in London is about 12 to 1.

That is about the worst ratio anywhere in the Western world.

Manhattan is similar.

Most of the rest of the United States of America and almost the entirety of Western Europe,

you would find a ratio of 3 or 4 to 1.

I don't pretend that the construction of a new site with 110 units, but about half of

them being categorised as affordable, will immediately alter that ratio overnight.

But it is one small incremental step in that direction.

And my heartfelt plea to this inquiry is if we are serious about our general house building

target. If we are serious about putting houses in this borough and this city within the reach

particularly of young people on average salaries, then schemes such as this sort must go ahead

even if amended rather than being blocked.

Mr Edwards, do you have any questions for Mr Littlewood?

Yes, I do. Just points of clarification, if I may. Mr Littlewood, good morning. I was

just seeking to establish where your flat is that you refer to relative to the appeal

site. Grant Road is just on the south side of Clapham Junction.

That's right. On Grant.

Thank you. So it's obviously some way from the appeal site.

It is, yeah. I use Battersea Park a lot, but it's not in my immediate line of sight.

as you confirm, thank you.

Secondly, Mr. Bond, I've listened with interest

to the representations you made,

plainly the council disagrees with those.

But are you involved in the development industry at all?

I'm not involved in the development industry.

What do you do for a living?

I run a public communications agency called PopCon,

and I'm involved with a number of television channels.

Are you involved with the appellants at all?

With the appellant company?

No, I don't even know,

with one person I know who is involved in the project,

but I don't know his role in it.

Thank you very much indeed.

Thank you.

Thank you, ma 'am.

Mr. Walton.

Just a couple of questions, just a little word.

I take your views and I understand them

and they're well stated and heartfelt.

Would you accept, I suppose,

it's a rather obvious question that we live within a planning system.

And the question, I suppose, that arises from that is,

do you accept essentially that the council have the right to refuse schemes like this

based upon issues of what they regard as the size of the character appearance or the visual impact?

Well, clearly, except we live within a planning system, that's a statement of fact,

not a statement of opinion.

I'd need many more than five minutes at the microphone

to explain to you the ways I think the planning system

should be changed and how there should be more

compensatory elements and less bureaucratic elements in it

and that I think it should be sped up.

And I think there's an awful lot to learn from

similar other western jurisdictions who seem to have

considerably fewer problems in building housing

and not just housing, other infrastructure projects

quickly and cheaply compared to the horrific problem

that appears to affect the UK in general

and London specifically.

I want to resist the possibility of going into

a sort of student tutorial with you

because I'm sure it would be very interesting,

but very briefly you mentioned compensatory.

Would that be some sort of cosy and bargaining system

rather than a conventional regulatory system

which we have in the United Kingdom?

Yes.

So essentially, your position is that you would scrap

the planning system as we have it at the moment.

I wouldn't scrap the planning system,

but I would radically amend the Town and Country Planning

Act of 1947, which I think has been an enormous barrier

to development and has not been contiguous

with beautiful development since.

In fact, the scale and beauty of development prior

to that act enormously out -trumps the record

of British architecture after that act.

That may be the case, but I just don't want to pursue this too far, but are you suggesting

a compensatory system would be a system that, whether something was built or not, would

depend upon whether a neighbour or whoever would be prepared to accept compensation,

and therefore the role of the local council in determining applications that would be

abolished?

No, the local council would likely, in my system, be a facilitator of that negotiation,

because the complicatory principle is a complex one.

It is not like compulsory purchase.

You could well be dealing with many hundreds,

possibly thousands of different residential properties

which are affected in a manifold of different ways

at different possible disadvantages

and a facilitator to bring together

those who are potentially harmed

by either short -term noise,

long -term disruption of some sort,

I think is a good role for a local council to play.

And if I could completely rewrite the planning system

from scratch, rather than giving my rather modest evidence

to a single inquiry, that's the direction

I would like to take it in.

Okay, thank you.

No further questions.

Thank you very much, Mr. Littleton.

Thank you.

It only appears to take two mics being on at the same time.

Mr. McGivin, sorry, you put your hand up.

I'm not sure whether you heard me earlier

mentioned that, and I may have misunderstood you when you asked me the question earlier,

but in terms of asking Mr. Littlewood questions, it's the role of the advocates.

So you can, as an interested party, ask questions, but you can only ask questions of the

appellant's witnesses because you are, if you are objecting to the scheme as an interested party, you can...

No, but you're not an advocate for either the council or the Royal Six Party who are

able to ask questions of Mr Littlewood. But later, when we get to the evidence for the

appellant, you can certainly ask questions of the appellant's witnesses at that point.

Hopefully that's clear. Thank you very much for your time, Mr Littlewood. I appreciate

you having hung around and given us your opinion this morning and thank you.

Thanks for the opportunity, ma 'am.

No worries. Mr Riddle has departed for now, so Ms Baston, sorry to keep you waiting.

And if you'd just like to make a start, thank you.

Is that working?

Great, brilliant.

Right, my name is Sarah Basden.

I came to live in Battersea many years ago

and have moved from various different houses

and currently live next door

in the Elpin Riverside development.

I believe in the rule of law, I believe in rules,

and I believe in local democracy

and for local agency, for local residents.

I also believe in development.

Really can't be more excited about something

being developed next door, but the rule

was in the local plan, and I think it was,

I don't know which part in the local plan,

but the rule was that it was not going to be

higher than six storeys.

The developer knew that when they bought the block.

I would have loved to have bought that block

if I knew that I could have had something a bit taller.

But the rule is six storeys for a reason.

And it's been thought through thoroughly.

And I would like that to be upheld.

There are so many other things I could say.

But I'd also like to say that I am very pro -social housing.

And I think we've gone off track slightly here

talking about social housing because this development,

So it's making lots of promises, which is great,

but I don't think this is the answer to our issue locally,

and I think we should take that to another forum

and try and solve that problem, because it is an issue.

I hope that's enough.

Thank you, if that's what you want to say,

then that's enough, Ms. Basdon.

Absolutely.

Mr. Harris, do you have any questions

for Ms. Basdon at all?

No, I don't.

you'll appreciate that we take issue with that but I mean no disrespect by

not asking you any questions but those matters will be addressed fully through

the rest of the inquiry. Thank you very much. Thank you very much. Thank you I

appreciate your time Ms. Baston. Okay so

Mr. Hamadouch was unavailable now and I don't think has returned since. Mr. Canning

Would you like to come forward?

Over to you, Mr Canning.

Good morning, ma 'am.

Thank you for this opportunity to participate.

I, like the previous person, am a great respecter and believer in local democracy and these

things.

It's very interesting to hear the opening statements from both and for my fellow residents

here as well.

and so when I say my views, they're my views

from my perspective as a local person.

I mean no disrespect to my fellow residents.

I'm a youngish person, not so young anymore.

I was when I first came to this area

and kind of fell in love with it.

Made a large group of friends and stayed here

over a decade now.

Thoroughly enjoyed it, moved down various parts.

I now find myself on Chatfield Road.

I'm now raising my family here.

Me and my wife, we have a young son now, three years old.

But we are slowly losing our friendship group.

People we've known for a long time are struggling to find places to live in this area, struggling

places they can find a family.

We too have found it difficult to find a place that is suitable, that is big enough that

that we can afford.

And for that reason, and as one of the core tenants,

why I strongly support this development,

I understand its size is large,

but with that large size, it does bring

a significant amount of affordable and social housing

that I think this area strongly needs.

Furthermore, I'm looking to set up my own startup,

as is my partner, and again, we've struggled

with flexible and available space to do that.

This development, again, comes with that additional space,

which in London and expressly, as we all know in this area,

is at a premium, it's hard to find.

I enjoy, given the location I'm currently in,

I enjoy taking the Thames Walk path,

I enjoy going up and down that with my son,

especially when he was younger and couldn't stop crying,

it was a great way to get out of the house

for a couple of hours.

And I'm a whole supporter of more being along there

for us to participate in more restaurants, more cafes and more stuff.

So to keep it brief and to summarise, I understand the impact on the area,

I understand some of the comments from other residents,

but I believe we need to encourage more development.

I believe we need more developers this size and I believe we need more amenities.

Thank you so much. Thank you all.

Thank you, Mr Canning.

Mr Edwards, do you have any questions for Mr Canning?

Yes, I do. I'm getting points of clarification.

and good morning, Mr. Canning.

Chatfield Road, where you live, I've just looked on Google,

that's off York Road, is that right?

Correct, yes.

And that's obviously some distance to the,

what is it, the west of the appeal side,

going towards the Wandsworth Bridge roundabouts, isn't it?

Correct, yes.

Thank you very much indeed.

Secondly, you mentioned that you are involved in a startup,

as is your wife, what business are you in, Mr. Canning?

So I currently work for a US defence tech firm.

US, sorry?

a defence tech firm and my partner works for a

law tech firm.

Sorry, a what?

A law, legal tech, software firm.

Okay.

No connexion to property or development.

You're not involved in the development industry?

No involvement at all, no.

And your startup, is that going to be involved

in the development industry at all?

Defence tech.

Defence tech, thank you very much.

Thank you, Mr. Cannon.

Mr. Walton.

My only question is just clarification of the surname. Is it Canning or Cally?

Canning, C -A -L -N -I -N -G.

Sorry, sir.

C -A -L -N -I -N -G.

Okay.

Yeah, I don't have any questions.

Thank you very much for your time, Mr Canning. I don't have any questions for you either.

Okay, so we have heard from Mr. Canning.

Then I have Sir Christopher Edwards.

Thank you.

If you could just make sure you turn the microphone on, thank you very much.

Okay, thank you.

Well, thank you for allowing us to have an input.

My name is Sir Christopher Edwards.

I've been a resident of Thames Walk for 30 years,

and so obviously I have a very personal interest

in what's happening today.

We've had a number of key points which have been made

by the appellants, and the appellants has, I think,

rightly talked about Terry Farrell, Sir Terry Farrell.

Now, I know Sir Terry Farrell and knew Sir Terry Farrell extremely well.

When I was Vice Chancellor of Newcastle University, I was responsible for getting him to develop

the Farrell Centre, in fact, in Newcastle.

In that centre, we have wonderful examples of what Terry Farrell has done.

Unfortunately, it's not clear to this committee that Terry Farrell had been ill for several

years and died last year.

And I think that I'm a great admirer of many of his

buildings, including ones along the Thames,

but it just is in relationship to where this building is.

It's an elegant building, it just happens to be

in the wrong place.

And I think that the word which most appropriately

describes that is ludicrous.

Ludicrous is defined as foolish, unreasonable, and absurd.

And I think that's what many people feel when they first

see this building.

And it's in the dictionary definition then,

worthy of mockery or laughter,

but unfortunately it's not very funny,

particularly for people who are living in the flats.

And it's had disastrous consequences now for several years.

Obviously in fact people living there

just are worried about what's gonna happen.

The party wall effect is going to be a real nightmare.

If you've ever lived next door to a place

which has had pile driving,

you'll understand how this goes on and on and on and on.

The pile driving, in fact, involved in this tower

is going to be appalling.

So if you're a party wall to that, it is dreadful.

I want to make two really key points which haven't really

come out before.

The first is the Tenors Walk Residents Association

own the land, which is the road, in fact, actually,

which has access to the apartments and the glass

mill from the back.

And we have an agreement, in fact,

with the owners of the glass mill.

And in this clause, in fact, of that,

it's quite clear that they are allowed

to have access to that road and to park there.

But there's a very specific statement which says,

but not so as to cause any obstruction to other road users.

And I think that that's a really key statement

because it's absolutely obvious

that if you're looking at the practical aspects

of putting up this building,

they would want to have access both from Bassy Bridge Road

and from the back.

And we could actually on that basis in fact stop the lorries

in fact simply parking and blocking our road at the back.

So it's first practical thing.

The next thing that relates very specifically

to Albert Bridge.

And I think Albert Bridge is the most beautiful bridge

I think we all agree.

But despite the original work of Sir Joseph Bezelgette

and the 1973 GLC columns that were put in to support the bridge,

it is a very fragile bridge.

It is not called the Trembling Lady for nothing.

And it has just been closed for a year because of major problems.

Now, I think it's very important to use this as a worked example of what, in fact, happens.

Closing this has immediately produced chaos.

I was on a 170 bus going from here, from Wandsworth, in fact, actually to Basterd Bridge the other day.

It took us 20 minutes, in fact, to get onto Basterd Bridge Road, just waiting in the bus.

There was absolute chaos because everyone was trying to get, obviously, to Albert Bridge originally,

going down there, that's completely blocked.

And so, if effectively, Basterd Bridge development, in fact, then coincided, and this could easily happen,

with a further closure of the Albert Bridge,

I'm afraid you've got a total disaster.

Because at the moment what's suggested is

that there will be need to be probably 700 lorries,

in fact, of concrete for the foundations,

in fact, of the new tower.

And they are all having to apparently come from the south

because of the potential damage to the bridge.

And so you can just imagine the effect

of having those lorries and what it would mean,

in fact, in terms of traffic across the bridge.

It would come to an end.

So the appellant in fact actually said

that there will be a huge improvement

in the way the area functions effectively,

probably for several years,

it would stop functioning altogether.

So I think you've got to realise

that the decision you make in this appeal

is going to have potentially quite disastrous,

fairly immediate consequences

and we've all got to wake up to the fact,

yes, I am supportive of housing,

in fact, and having social housing.

Absolutely.

And that is, in fact, something we all need and want

to support.

But I'm afraid that when they went round,

basically asking people if they supported social housing,

and then signed them up, in fact,

as being supportive of the tower,

I personally think that that is a fairly unfortunate way

of approaching getting support for your development.

So I think that this appeal is to me a critical way, in fact, of us looking at do we support social housing?

Tick yes. Do we support social housing here? The answer is no, because what we're talking about is a tower.

This is really an excuse. And then there's the question is, is it legally binding that they would have to put up 50 cent social housing if this is not profitable?

and I'm told that it's not.

So that to me, in fact, becomes a really crucial point.

To allow this to go ahead and then

to find that there wasn't any social housing

would be extraordinary.

So I hope that we can, in fact, all come

to a common sense conclusion.

We did, in fact, actually have a sensible local plan

which tried to define and discuss it

over a long period of time what was reasonable height.

And this is completely unreasonable.

And I hope that this will be, in fact, a logical discussion

which in fact actually will be unemotional

and will come to a sensible conclusion.

So thank you.

Thank you very much.

Mr. Harris, do you have any questions?

Just a few, please.

Sir Terry Farrell and Newcastle University,

you mentioned the connexion.

Why do you think the university and you were the Vice -Chancellor

embraced him as one of their most talented alumni?

Well, because basically, when I went to Newcastle,

in fact, as Vice Chancellor, we worked very closely together

in fact, on a plan for Newcastle, in fact,

on how we could bring his skills together.

So I have absolutely no doubt about his skills,

not just in relation to building, but in fact,

the environment.

But I'm unfortunately having to say,

is that his involvement in this, in fact, is very different.

Yes, all right.

You said you enjoyed and appreciated and admired

many of his Thames -side buildings.

Yeah, and if you go along the Thames, in fact, MI5

and everything else, these are appropriately placed

and are fine.

What we're talking about here is something

unfortunately is inappropriately placed.

and as I've indicated, the potential effect

on local traffic, et cetera, is disastrous.

Okay, just want to push you a little further on that.

We've got Lott Road Power Station,

which is along the same reach.

That's one of the ones that you admire, is it?

Yes, I think the whole question

of the power station development

has been done in a reasonable and sensible way

and didn't in fact have adverse local effects, yes.

Good, okay, thank you.

That's relevant to other issues in the case.

Lastly then, because you speak with passion, no doubt,

but you're also using adjectives that we don't generally

hear at inquiries such as this, such as ludicrous, laughable,

and in respect to the bridge, disastrous.

So just so that members of the public can gage

where to go on this, the bridge is owned by the public.

operated and run by Transport for London, isn't it?

They're the highway authority for the bridge,

and they're responsible for its structure, aren't they?

And they have been consulted on the application

and raised no objection, do they?

Have you asked them what happens when Albert Bridge closes?

Have you asked them that question?

The way it works, Mr. Edwards, is that I ask the questions...

Yes or no? Sorry, have you asked the question?

application.

So TFL have been consulted about the application as a whole, haven't they?

Well I'm just asking you a quick question.

Have you, in fact you haven't obviously asked them that question.

Okay.

So I'll ask the question again and then I'll move on.

TFL, who are the highway authority responsible for the operation of the bridge as a highway

authority, and for the fabric of the bridge, have been consulted about this application,

haven't they?

Yes, but I think we've got to move from what I call theory to practise. If you in fact

go and have a look at the breach now, you will see what practise actually shows.

Our next question, as a reasonable authority, have they raised any objection to the proposal,

having understood the proposal? Have they raised any objection?

Well, I don't know, but all I'm just saying is that we have got at the moment a situation

which you ought to personally observe, and just understand that as residents, unfortunately,

we have to every day put up with this.

Well, I've heard that. But before suggesting to your fellow residents, who no doubt take

your word with great weight, that the situation is going to be disastrous, don't you think

it might have been appropriate to advise them that TfL had considered these matters and

have raised no objection?

Well we can discuss that perhaps another time but what I'm just saying is at this meeting

I think it is crucial that this is considered.

Thank you very much.

Thank you. I just have one question which is going back to the CV I'm afraid. You said

you were Vice Chancellor of Newcastle University, what time period was that across?

So I was Vice Chancellor from 2000 to 2007.

Okay, so just to notify the inquiry that you were Vice Chancellor at the same period that

I was undertaking my Masters in Town planning at Newcastle University. Shock, horror, it's

a small world of planning.

I hope I gave it to you personally.

I don't think our paths ever crossed that I recall. Do you recall ever meeting me?

Sorry, I didn't hear that.

Did you ever meet me whilst we were at Newcastle University at the same time?

Meet Terry Farrell?

No, did you meet me?

Meet you? Not knowingly. My apologies.

Thank you. Just making it clear in the interests of reducing any risk of conflict of interest,

We've already had some discussion about conflicts of interests at the case management conference in the past.

Okay, but and yes, I did go to the School of Architecture and Planning and Landscape

at which Sir Terry Farrell had various

documents within the library.

Okay, thank you. I don't have any further questions. So thank you very much for your time today. Okay. Thank you. Thank you.

I think in terms of people that are still in the room, I had David Woodell. Would you

like to come and speak, please? Okay, over to you.

Thank you very much for allowing me to speak.

I'm David Waddell, a member of the committee

of the Cheney Walk Trusts, and also the Council

of the Chelsea Society, both rule six parties

that have tabled formal objections as immunity associations

and as members of the Battersea Society Alliance

of Rule Six Parties.

More specifically, I lived on Cheney Walk

for over 30 years, immediately west of Battersea Bridge,

and directly opposite the appeal site at 1 Battersea Bridge.

This huge 103 metre above Ordnance Data tower

that conflicts with both the London plan

and the Wandsworth local plan will directly overwhelm

and severely harm by height and light pollution

the settings of the Cheney, River Thames,

and Lots Road conservation areas.

There are three of them.

where there are numerous listed buildings

and much -loved heritage riverside,

popular and enjoyed by hundreds of residents,

pedestrians, and visitors every day.

Above all, the tower is not located

in a designated tall building zone,

hence it should not be permitted.

Secondly, Battersea Bridge is an acknowledged traffic

and accident black spot.

In the five -year period up to the 31st of December 2020,

the bridge experienced 63 recorded collisions

with 72 casualties and three fatalities.

Whilst TFL, after some 20 years of delay,

installed new and safer junctions in the period

2022 to 2025 that much improved safety,

these have significantly delayed journey times.

Those delays will clearly be further

and seriously compromised during the construction period

and indeed long thereafter by the introductions

of some 300 to 400 new residents

and social and other facilities

on this tightly constrained site

that adequate access to sustain numerous daily residential

and logistic servicing movements.

Thirdly, the erection of the proposed tower, some three times the height of adjacent buildings,

will almost inevitably act as a precedent for applications to create a harmful and welcome

cluster of super high towers in this totally unsuitable and inadequate location.

On behalf of residents and friends of Chelsea Riverside, I respectfully urge rejection of

this appeal. That is the end of my statement.

Thank you very much. Mr Harris, do you have any questions for Mr Padel?

No thank you. These are matters which will be dealt with in the roundtable and in the

rest of the inquiry. Thank you.

Thank you and I don't have any questions for you either. Thank you very much for your time.

Just checking, anybody else wishing to speak, obviously Mr Riddle is looking to come back

later today. Mr Hamadouche is very welcome to come back at another time if that's suitable for him.

Is there anybody else in the room who didn't state they wish to speak earlier but is suddenly

driven to the need to speak? Sir, would you like to come forward to the microphone?

Good morning.

Thank you.

I think we're just about in afternoon.

Can I just ask your name first, please, sir?

I'm going to give you that now.

My name is Gerard Connolly.

I'm a Battersea resident of 50 years.

I'm against the glass mill.

The idea of building a large tower on the south corner

of Battersea Bridge is madness.

Traffic and congestion.

Approaches to the bridge are always crowded,

with that's West Bridge from the west,

Park Gate from the east,

both joining the approach as well as Battersea Church Road

from the west, and Hester Road and Howie Street,

both joining from the east.

All of this within 120 yards of the entrance of the bridge itself.

Excuse me.

Also, add to this the complication of accommodating busses and bikes,

ambulances and fire engines, it should be clear to anyone that the area cannot take

more development or the bridge any more traffic.

Indeed, the first day the bridge was shut, it took me two hours on the approach to Battersea

Bridge to actually get onto the bridge.

Two, the building has been rejected.

The idea of building a huge tower on this site has already been rejected once, as no

local residents either side of the river supported this.

There were campaigns by the developer, apparently writing in multiples, to express support,

which appear to have been fake.

The architects tried to draw comparisons with the Palace of Westminster on the basis that

London bridges traditionally are cited by a tower.

This is preposterous.

The purpose of the tower is to build yet more flats

south of the river which will be sold off -plan

to people abroad who just want an investment in London.

I fully support social housing and would prefer to see

an entire social housing complex there of a limited scale.

Aesthetically, this is an abomination and will tower over historic Chelsea and Victorian

Battersea. The building has nothing to commend it. It is a stand -alone structure. This is

purely a money -making development to the detriment of London's. Thank you.

Thank you. Would you be willing to answer any questions that Mr Harris might have?

Sure.

Thank you. Mr Harris?

Thank you very much. Any further interested parties who wish to speak? No? Okay. So just

thinking, we're obviously quite far ahead of time at the moment, given that it's often

necessary to anticipate a large number of interested parties. So would the parties prefer

to do the presentation for Mr Barbeloff now or would it be preferred to have a lunch break

now and perhaps come back in an hour?

I think we couldn't do it now but we could probably do it within 15 or 20 minutes to

set up. But if you preferred to stick more to the timetable, it is 12 .26, we'd certainly

be happy to come back after lunch when we could be certain that all of the IT is working.

We'd be asking you to come down a level here as well. Maybe to have a break now would be

the sensible thing so that we can make sure all the gremlins are out of the system, if

there are any.

Yes, hopefully there are no gremlins, only Mogwai. Mr Edwards, what's your view?

I agree, Mr Granger indicates it's going to take a little bit of time to sort the IT out

and the individual who is responsible for that

seems to have left the room and gone somewhere,

so it's going to take a while, I think.

Okay.

First gremlin from the environment.

Right. Thank you. Mr Walton, any views?

Sorry. Only to concur with what Mr Edwards said.

Okay. So, we're now at 12 .26.

I suggest we take a lunch break and we come back at 1 .30.

If that's acceptable to everybody.

In terms of interest parties, you are obviously very welcome to stay and watch the rest of

the day.

If there are any interest parties who come along later who wish to speak, we'll try and

fit them in as and when they come back.

And obviously you can watch it on the live stream.

But otherwise, the inquiry is adjourned until 1 .30.

Thank you very much.

Thank you.

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Glassmill planning appeal - Day 1 Morning - Tuesday 17 March 2026, 9:00am - Wandsworth Council Webcasting

Glassmill planning appeal - Day 1 MorningTuesday, 17th March 2026 at 9:00am

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Glassmill planning appeal - Day 1 Morning
Tuesday, 17th March 2026 at 9:00am