Deliverability of the ASH proposal on Central Hill: ASH response to Lambeth Labour Council

Fiona Cliffe
Capital Programme Manager
24 June 2016


‘Following the February 2016 Resident Engagement Panel (REP) meeting the Council has sort to establish a constructive dialogue with Architects for Social Housing (ASH) so their proposals for Central Hill could be considered.’

‘The Council has now had the chance to review the ASH proposal and this report sets out a summary of the Council’s findings.’

Architects for Social Housing undertook to produce an architectural proposal for The Alternative to Demolition of Central Hill estate pro bono publico and with very limited financial resources. Lambeth Labour Council has not provided us with a brief, a housing needs survey, a measured survey of the existing estate, a consultant team, a criteria for deliverables, and of course we have received no payment. Not a single member of Lambeth Council, including the Cabinet Member for Housing and Ward Councillor for Crystal Palace, attended ASH’s formal presentations of our proposals: not when we presented to the Central Hill community in February 2016; nor again when we presented to the Residents Engagement Panel in May. Instead, with the backing of PRP Architects, Lambeth Council dismissed our design proposals even before they were published; and they continue to refuse to answer our Freedom of Information request to see their viability assessments months after it was issued. So Lambeth Labour Council’s ‘dialogue’ with us has been anything but ‘constructive’; on the contrary, it has been unrelentingly negative, dismissive and obstructive. Finally, as further evidence of their unwillingness to engage in ‘constructive dialogue’, Lambeth Labour Council has not invited ASH to discuss the issues they raise in this report, or to present our responses, which we are, therefore, publishing here.


Process of evaluation

‘The evaluation carried out by the Council is based on three key considerations:

  • ‘The deliverability of the proposed design when assessed against basic design, structural and planning principles;
  • ‘The feasibility of delivering the proposals within the financial constraints the Council finds itself in, and;
  • ‘The ability of Lambeth to fund the refurbishment costs for the 456 tenanted and leasehold homes on Central Hill and the value for money of this investment.’

The intention of ASH’s design proposal is to illustrate that there are alternatives to demolition that need to be explored for reasons that we have laid out in our critique of Lambeth Council’s Criteria for Demolition, which relate to the social and environmental costs of demolition and redevelopment, and which both Lambeth Council and PRP Architects have failed adequately to consider. The comments from Lambeth Council that follow in this report demonstrate their complete unwillingness to explore the proposals ASH has put forward in a constructive way, and their desire to dismiss them as quickly and quietly as possible based on fabricated figures, withheld information, inaccurate assessments, false claims and deliberate misunderstandings. The point of this commentary is to point out only the most glaring and cynical of these, which raise serious doubts about the integrity of the councillors making decisions about the homes and lives of thousands of Lambeth Borough residents.

Deliverability of ASH Proposals

1. Design and Planning

‘The 250 ‘new build’ homes would be subject to local planning requirements and this would require at least 40% of the new homes to be affordable.’

‘The planning requirements set out a certain mix of property sizes (i.e. 1 beds, 2 beds, 3 beds etc.) and at present the ASH proposal provides too many 1-bedroom homes and not enough family sized homes.’

This is factually inaccurate. In fact, ASH’s design proposal, including the retained existing homes, has a better mix of homes than Option D in PRP Architects’ scheme, which was presented to the residents earlier this year. Nearly 50 per cent of Central Hill Estate following ASH’s refurbishment and infill proposal would be 3 bedroom homes or greater, while only 29 per cent of PRP Architects’ scheme provided 3 bedrooms or more.


‘An initial commentary given by architects, planners, building control and general views were provided to ASH on 14 April 2016 and the Council’s urban designers, PRP, have further reviewed the proposals submitted by ASH and the commentary below summarises the key issues identified in the review:

  • ‘Buildings over four storeys in height will require lift access and therefore where you have buildings in excess of four storeys in the ASH proposal new lift access will need to be provided. This will have both design and cost considerations which the ASH proposal has not undertaken.’

Every new building with over four storeys is already provided with two lifts to allow for wheelchair access. The only location in which we propose new homes to be entered above the fourth floor is on the roof extensions to the prospect blocks (Site 15 in our proposal). We have now shown that, if necessary, lifts can easily be provided to access these new flats. We understand that, although it is desirable that floors at the fourth level and below be accessed by a lift, in mitigating circumstances the lift can be omitted according to the Minor Alterations to the London Plan (MALP):

‘3.48A. As set out in Approved Document M of the Building Regulations – Volume 1: Dwellings, to comply with requirement M4 (2), step-free access must be provided. Generally this will require a lift where a dwelling is accessed above or below the entrance storey. The application of requirement M4 (2) has particular implications for blocks of four storeys or less, where historically the London Plan has not required lifts. Boroughs should seek to ensure that dwellings accessed above or below the entrance storey in buildings of four storeys or less have step-free access. However, for these types of buildings this requirement may be subject to development-specific viability assessments and consideration should be given to the implication of ongoing maintenance costs on the affordability of service charges for residents. Where such assessments demonstrate that the inclusion of a lift would make the scheme unviable or mean that service charges are not affordable for intended residents, the units above or below the ground floor that cannot provide step free access would only need to satisfy the requirements of M4(1) of the Building Regulations.’ (my italics)

This exception potentially includes any buildings that are entered at fourth floor but for whom lifts would be prohibitively expensive. As they have done with the prohibitively expensive Lambeth Homes Standard, imposing this requirement at the cost of what can be afforded by the existing residents is another indicator of Lambeth Labour Council’s desire to socially cleanse residents from their homes under the guise of ‘improving’ them. If it’s a choice between walking up four flights of stairs to their homes and being moved four miles away from their homes, we believe residents will choose the former.


  • ‘The location of the tall buildings is not seen as appropriate and would have a difficult relationship both with the existing Victorian buildings and the retained low-rise blocks of Central Hill.’

In the absence of any clear designation, it is not clear which ‘tall buildings’ this comment is referring to. As part of our planning response to this in our previous statement we wrote:

‘Building new buildings next to existing ones will inevitably create new relationships between the new and existing buildings. This is the nature of building in cities. Good design should mean this is not a problem but an opportunity. Cities are not homogeneous places. The distinctive character of Crystal Palace is rooted in the eclectic mix of architectural styles, as the area has evolved since the citing of The Crystal Palace, including four- and five-storey converted Victorian mansions, two-storey dwellings west of Roman Rise, and 5-8-storey blocks of 1960s flats on the south side of Central Hill. The ground-breaking and award-winning architecture of Central Hill Estate is a key element in the story of the area. A palimpsest of different styles built up over time is what makes cities exciting, vibrant and interesting, the sites of cumulative memory. ASH’s proposal celebrates the existing architecture and community, while also offering the potential for new homes. There is no reason why the design of the new buildings cannot be sensitive to the existing context.’

  • ‘A minimum 10% of units are required to be wheelchair-accessible or easily adaptable for residents who are wheelchair users.’

ASH’s plans provide a minimum of 12 per cent new flats with wheelchair access, with the potential for more if necessary. All our new ‘infill’ blocks over four floors high are provided with lifts, and can accommodate as many wheelchair-accessible flats as are required. So this is not an issue but a careless or deliberate misreading of our proposal.

  • ‘Proposed external staircase for access to upper level roof extensions block the existing north-south public access routes and cannot be built whilst retaining the required access on the public stairs.’

Although the access to upper floors does in some places conflict with existing routes, this does not have significant implications for the existing estate, as there are always alternative routes through the estate. Where it is possible, we have designed the access stair to allow access beneath or alongside these new access points. Once again, we believe that the eviction of residents from their homes is considerably more disruptive than the alternation of a few routes through the estate. This displays a willful desire by Lambeth Council to fabricate paper-thin excuses to reject ASH’s proposal, and flies in the face of common sense and, more importantly, the presumed integrity of the Council’s report.


  • ‘The thickness of the walls as shown are not consistent and are generally insufficient to achieve compliance with Approved Building Regulations, Part L requirements. This is important, as when these are corrected it will require the buildings to increase in size, which will also increase the cost.’

ASH’s proposal is a feasibility exercise, and was based on an Ordnance Survey map at 1:500 scale, so quibbling over this level of detail has very little value except as an indicator of Lambeth Council’s attitude. All external walls on our designs have been shown at 400mm or in some cases 350mm, and it is perfectly possible to achieve part L requirement with these dimensions, depending on wall construction. ASH has not been provided with a more accurate survey by Lambeth Labour Council, so more detailed drawings at this stage would have little purpose. This comment – which frankly is not worthy of an architectural practice – illustrates a persistent desire for a level of detail that is entirely unnecessary at this stage of design, and once again the Council’s desire to fabricate reasons for rejecting ASH’s proposal.

  • ‘Roof extensions and infill elements create Daylight and Sunlight issues.’

All new buildings will, by definition, have an effect on the existing environment, some more than others. We have not been shown that our designs contravene residents’ Rights to Light. If they do, this can be easily mitigated as part of the ongoing design process. Once again, we firmly believe that the existing residents will have access to better amenities in their current homes within the ASH scheme, than if their homes are demolished as part of Lambeth Labour Council’s redevelopment proposal.

  • ‘There is a concern that in order to integrate the new homes above existing homes you would need to run services through existing properties.’

There are plenty of options to deal with services at a detail design stage. Again, we have been provided with no detailed services drawings or surveys, so are unable to make any assumptions. Building on top of existing homes, however, is a common solution to the densification of London, and the concerns raised are inconsistent with its use in contemporary housing. Lambeth Council really are clutching at straws here.

  • ‘There is a concern over the weight of the new homes above existing homes and whether the existing homes could take the additional load.’

At our request Arup Engineers have already carried out a preliminary desktop study to show that a single story extension is more than likely to be acceptable. Lambeth Labour Council, however, have refused to appoint an engineer to follow up this survey. This is a further example of the Council demonstrating that they have no interest in establishing the genuine viability of this proposal.

  • ‘Without further detailed design solutions it cannot be determined whether the above issues can be resolved. However, even if resolved the physical deliverability of ASH’s proposals need to be considered against 2 & 3 below.’

A classic example of ‘kettle logic’. If Lambeth Labour Council were genuinely interested in exploring whether or not these issues can be resolved in order to produce a viable alternative to demolition, they would commission the necessary work to be done. That they have chosen not to demonstrates, contrary to their excuses about the condition of the returned kettle, their desire to dismiss all alternatives out of hand.

2. Financial Feasibility

‘The Council undertook a financial appraisal of the ASH proposal and this is found in Appendix 3. Where available the Council has used cost information provided by ASH; where this was unavailable the Council provided the financial assumptions.’

‘The financial appraisal for the 250 new build homes shows a negative Net Present Value of £6.6m. This means that the money generated through the combined rents of the private homes and Council rent homes is insufficient to pay for the costs of building the new homes. The Council would therefore need to find additional money to make the ASH proposal achieve a break even position.’

‘This also means that there is no additional money generated by the 250 new homes and therefore there is no money generated to pay for the refurbishment of the existing homes on Central Hill.’

‘The Council could not therefore recommend this as a deliverable option.’

The mathematical calculations that ASH was provided with as part of Appendix 3 are, in fact, inaccurate and incorrect, and so cannot be used as the basis for assessing the viability of our proposals. Taking as an example this excerpt (below) from the viability assessment for our proposal produced for Lambeth Council by Airey Miller Construction Management, it can be seen that the assessment relates to one of our infill sites (Site 1) on which ASH has proposed building 30 new flats. The number of dwellings proposed is clearly indicated in the top line of the table as 30. As we go down the page, the chart at the bottom identifies the percentage of flats that will be for private and council rent, respectively, the total percentage of which therefore needs to add up to 100 per cent, with the total number of flats coming to the 30 indicated. However, as we see, only 1 flat for private rent out of the 30 has been accounted for, with 12 for council rent, a total of only 13 new flats. Where, then, have the other 17 private flats gone? Presumably the income from the rent of these private flats has not been added to the overall income from this building, so it’s no surprise that this site have been shown, as a result, to be ‘unviable’, with a negative pre-finance net present value (NPV). Is this simply a sloppy error by Lambeth Council, or a deliberate attempt to make our proposals ‘unviable’?


We have to assume the latter, because on top of these basic mathematical errors that we know of, ASH has not been provided with the assumptions on which these calculations were based. We have been informed by the Independent Advisors on the Residents Engagement Panel, however, that these are different from the assumptions on which PRP Architects’ initial viability assessment was based. ASH has made a Freedom of Information request for the calculations on which this appendix was based, which conflict with those used for the scheme by PRP architects, but we have been told by Lambeth Council that these ‘cannot be provided’. Specifically, they wrote to us that:

‘In all the circumstances of the case, the public interest in maintaining the exemption outweighs the public interest in disclosing the information until the scheduled publication date. Therefore, the information is not provided to you.’

It is unclear, however, exactly what public interest is served in withholding the information pertaining to the viability assessment of both the ASH and PRP Architects schemes on Central Hill; but Lambeth Council has refused to answer further questions. Again, this is another example of the way in which Lambeth Council have sought to obstruct and dismiss our proposal. Lambeth Labour’s self-appointed designation as the ‘Cooperative Council’ is already something of a running joke, but nobody will be laughing when its deliberate attempts to pervert democratic process leads to the demolition of the homes of over a thousand residents on Central Hill estate. As far as we are concerned, therefore, the viability of the ASH proposal has not been sufficiently established, and we have no confidence in the assessment that Lambeth Labour Council has provided.

3. Investment Requirement for Central Hill

‘To reiterate the point above, as it is such a fundamental one, the ASH proposal does not address the issue of how to fund the costs to refurbish the 456 tenanted and leasehold homes on Central Hill.’

‘The ASH proposal would still require the Council to find the money to refurbish the new homes from existing budgets as the ASH proposal would not generate a positive receipt.’

In fact, there are several possibilities for funding the refurbishment of Central Hill Estate, such as forming a Tenant Management Organisation, or transferring the ownership of the estate to the residents, who can then borrow money against them to build the ASH proposal. Neither, however, has been explored by Lambeth Labour Council. We have not seen Lambeth Council undertake any explorations into alternative funding strategies – which, once again, demonstrates an unwillingness on their part genuinely to explore all the options open to the Central Hill community.

Other Considerations

‘As raised in the commentary of ASH’s initial proposals, there are potential issues with building over leasehold homes – all blocks have leasehold interests. Under the leases Lambeth reserves the right to build on adjacent land but does not reserve the right to alter the building in which the flats are contained. Potentially, the ‘enjoyment’ of other residents on the estate can be obstructed or interfered with and so they would have the right to object. The service charging and maintenance issues between Homes for Lambeth and the HRA will be complex.’

Building on top of leaseholders’ homes is, in fact, standard practice in other London boroughs, so it’s clearly not a fundamental problem to anyone who knows what they’re talking about, as opposed to someone making unfounded assertions confirming already reached conclusions. For example, as part of their ‘Hidden Homes’ project, Wandsworth Conservative Council has built new homes on top of Abbott House in Balham. Plenty of the existing homes are owned by leaseholders, as can been seen from the sale records of the flats. And it is our understanding that Lambeth Labour Council did, in fact, explore the possibility of building homes on top of the existing homes on the Hemans Estate. Is Lambeth Council now saying that it has different leasehold agreements with leaseholders there?

As to the ‘enjoyment’ of existing tenants: it is far more likely to be ‘obstructed’ or ‘interfered’ with as a result of a full demolition scheme than with some additional housing. With demolition, residents will not be able to ‘enjoy’ their existing homes and amenity spaces at all. Even if they are able to afford to return to the estate, which is highly unlikely, the amenities proposed as part of PRP Architects’ scheme would be considerably less than they currently enjoy. With adequate resources, ASH is quite capable of ensuring that no Rights to Light are infringed upon.

As to the complexity of service charging: again, we recommend that Lambeth Labour Council look at other councils that are doing exactly this. The fact that it is ‘complex’ should not be a reason to demolish an entire estate, or is the Council claiming incompetency? Given their inability understand ASH’s proposals, this would be the one thing in this report that is true.


‘Lambeth’s key priority is to build “More and Better Homes” and so any proposal has to look at how many additional homes can be delivered – specifically affordable homes, and also how it can deliver investment to the Lambeth Homes Standard for the retained Lambeth stock.’

‘The proposal by ASH would be challenging to deliver in light of the constraints highlighted above, in particular in building above existing homes, and the Council considers a more realistic and achievable figure would be 128 new homes.’

The council has not provided any evidence of how they have arrived at this new figure, which they have plucked from the sky, nor illustrated that they have tried to mitigate any of the constraints highlighted, most of which are due to the constraints of their comprehension and honesty in considering them.

‘The financial assessment of the costs given by ASH and income for the development of 250 homes shows a negative net present value of –£6.6m. As such the proposal is not feasible to be developed.’

ASH disputes this figure, which once again has been produced from thin air. We have not seen any accurate figures for its calculation, or the assumptions by which these figures were reached. To reiterate what we said above: the only figures ASH has been provided with are mathematically incorrect, and therefore cannot be trusted. The same might be said of the Council that, whether through incompetence or deliberately, provided us with those figures.

‘The ASH proposal will not generate any surplus money to fund the refurbishment of the existing homes and so residents will see no benefit other than the development of 250 new homes on their estate.’

We do not believe, or accept, that this is correct, as we do not have confidence in the viability assessment produced. In order for us to assess the veracity of Lambeth Labour Council’s viability assessment, we need to see it and have it independently assessed. As we have said, though, Lambeth Labour Council has refused to provide us with this assessment. Readers may come to their own conclusions as to why not.

‘In light of the assessment the Council cannot recommend the ASH proposal as a deliverable option and it will not be considered as part of the consultation with Lambeth tenants, leaseholders and freeholders on Central Hill.’

Contrary to this report, to which an architectural practice of PRP’s standing should be ashamed to contribute, ASH is convinced, and can show to anyone willing to attend our presentations – as Lambeth Labour Council is not – that our ‘Alternative to Demolition’ scheme is the most socially, environmentally and financially viable future for Central Hill Estate. Our proposal may be viewed on our blog here, and we reiterate that our designs are part of a feasibility study, and can be developed in further consultation with residents to meet their needs, rather than the investment opportunities of property speculators on London’ s housing market.

Finally, before ASH is asked to defend its proposals against the fabricated and disingenuous appraisals of a report such as this, Lambeth Labour Council has a duty to the residents of Central Hill Estate to answer the many questions about the social and environmental costs of their proposed redevelopment scheme. To this end, ASH has outlined these questions in our text Criteria for Estate Demolition: ASH Response to Lambeth Labour Council, which we recommend as further reading for both residents and councillors alike. We look forward to receiving Lambeth Council’s response.

Geraldine Dening
Architects for Social Housing

Below is PRP Architect’s Design Compliance Risk Assessment for ASH’s proposal, on which Lambeth Council’s report is based, with ASH’s point-by-point response. All the images reproduced in this post may be viewed in greater detail on request.

Architects for Social Housing is a Community Interest Company (no. 10383452). Although we do occasionally receive minimal fees for our design work, the majority of what we do is unpaid and we have no source of public funding. If you would like to support our work, you can make a donation through PayPal:

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s