planning report D&P/3606/01 23 September 2015 201-207 Shoreditch High Street in the London Borough of Hackney

planning application no. 2015/2403

Strategic planning application stage 1 referral Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008

The proposal Demolition of existing buildings and structures and erection of a part 7, part 10 and part 30 storey building (plus 2 levels of basement) comprising office (Class B1) and hotel (Class C1) accommodation with ancillary retail, restaurant, event space, lounge and amenity areas; roof terraces; refuse and recycling facilities; cycle parking; servicing and plant; and landscaping The applicant The applicant is HG (Europe) Shoreditch Limited and Folgate Estates Limited the architect is Gensler

Strategic issues The application is in the City Fringe Opportunity Area and the proposals have the potential to contribute strongly towards the objectives of the Draft City Fringe OAPF. In order for the scheme to be considered acceptable in London Plan terms further work is required in relation to Equalities, employment, urban design, climate change and transport. Recommendation That Hackney Council be advised that the application does not fully comply with the London Plan, for the reasons set out in paragraph 90 of this report; but that the possible remedies set out in paragraph 91of this report could address these deficiencies.

Context

1 On 21 August 2015 the Mayor of London received documents from Hackney Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 1 October 2015 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

page 1 2 The application is referable under the following categories of the Schedule to the Order 2008:

 Category 1B “Development which comprises the erection of a building or buildings with a total floorspace of more than 15,000 square metres;

 Category 1C “Development which comprises or includes the erection of a building that is more than 30 metres in height”.

3 Once Hackney Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 has been taken into account in the consideration of this case.

5 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description

6 The site lies within South Shoreditch, at the southern end of the borough of Hackney and is within the City Fringe Opportunity Area and the Central Activities Zone (CAZ) as identified in the London Plan. It is also within protected vista 8A.1: St. Pauls’s from Westminster Pier as set out in the London View Management Framework (LVMF). The site is within a locally designated Priority Employment Area (PEA) and the South Shoreditch Conservation Area. There are a number of listed and locally listed heritage assets in the vicinity of the site.

7 The site is approximately 0.19 hectares and is bounded by Shoreditch High Street to the east, the Village Underground cultural space to the west and Fairchild Street to the south. The north of the site is partially bounded by Hollywell Lane and partially by a car park which sits under the Kingsland Viaduct between the rear of the existing buildings and Hollywell Lane. The site is currently occupied by a wine merchant, a health spa and ancillary parking.

8 Shoreditch High Street, Great Eastern Street and Holywell Lane all form part of the Transport for London Road Network (TLRN). The site is highly accessible by public transport, with Shoreditch High Street London Overground station being 300 metres to the east and and National Rail services also within walking distance at Old Street station 900 metres to the west, and 800 metres to the south. There are also 14 bus services within walking distance of the site on Shoreditch High Street, Great Eastern Street, Bethnal Green Road and Worship Street. As such, the site records the highest possible public transport accessibility level (PTAL) of 6b. The nearest cycle hire docking station is available on New Inn Yard approximately 200 metres to the north of the site.

Details of the proposal

9 The proposed development would result in a mixed‐use building with floor space comprising 11,866 sq.m (GIA) of office (B1)accommodation and 14,244 sq.m (GIA) of hotel (C1) accommodation, as well as plant and servicing space.

10 The office element includes office accommodation and facilities for coworking, breakout areas, meeting areas, and event / lecture space for conferences, talks and exhibitions. The hotel

page 2 element includes 200 guest rooms and ancillary retail, restaurant, event space, fitness rooms, lounge and amenity areas. The proposed scheme would have two levels of basement, a ground floor and 29 upper levels. The building would comprise three different elements of 7, 10 and 30 storeys. The tallest part of the building would rise to a total height of 106.81 metres above street level (121.31 metres AOD).

Proposed land use Floorsapce (sq.m.) Hotel – guest rooms 8,661 Hotel – shared facilities (ancillary retail, 5,583 restaurant, event space, fitness rooms, lounge and amenity areas) Total Hotel Floorspace (Class C1) 14,244 Office – core office accommodation 8,276 Office – shared facilities (co‐working, breakout 3,590 areas, meeting areas, event / lecture space) Total Office Floorspace (Class B1) 11,866 Plant and servicing (including refuse and cycle 3,530 facilities) Total Floorspace 29,640

Table 1: Floorspace breakdown

Case history

11 On 16 April 2014 a pre-application meeting was held at the offices of Gensler in Aldgate House between the applicant and GLA officers to discuss proposals for a mixed-use application comprising approximately 12,000 sq.m of office floorspace, 10,000 sq.m of hotel floorspace and 6,000 sq.m of shared facilities (touch‐down space; break‐out areas; small scale retail; and hospitality). The proposals included a tall building of up to 30 storeys.

12 Whilst the proposed mix of uses and a tall building within this location were potentially supported on this site, the applicant was advised that the equalities issue related to the sauna facility currently on the site needed to be addressed before any development proposals could be considered acceptable in principle.

13 The design approach was broadly supported, although the applicant was encouraged to pay particular attention to how the scheme interfaces with proposals to the north, as well as the potential impact on local and strategic views, the South Shoreditch conservation area, and local heritage assets. Inclusive design and climate change matters were not discussed in detail at the meeting.

page 3

Figure 1: Indicative vertical breakdown of uses (Source: Design and Access Statement, Gensler 2015)

Strategic planning issues and relevant policies and guidance

14 The relevant issues and corresponding policies are as follows:

 Equal opportunities London Plan;  Mix of uses London Plan; Draft City Fringe Opportunity Area Planning Framework  Employment London Plan; Draft City Fringe Opportunity Area Planning Framework  Hotels London Plan;  Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG  Tall buildings/views London Plan, London View Management Framework SPG

page 4  Inclusive design London Plan; Accessible London: achieving an inclusive environment SPG;  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy  Transport London Plan; the Mayor’s Transport Strategy;  Crossrail London Plan; Mayoral Community Infrastructure Levy

15 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2010 Hackney Core Strategy and the 2015 Hackney Development Management Local Plan and the London Plan (Consolidated with Alterations since 2011). 16 The following are also relevant material considerations:  The National Planning Policy Framework, Technical Guide to the National Planning Policy Framework and National Planning Practice Guidance.  The Minor Alterations to the London Plan (public consultation ended 22 June 2015).  The Draft City Fringe Opportunity Area Planning Framework (public consultation ended 13 February 2015).  The Central Activities Zone Draft Supplementary Planning Guidance (public consultation started 15 September 2015)

Principle of development

Equality of opportunity

17 The Mayor and the GLA have a statutory duty to promote equality, and equality of opportunity arising from the GLA Act 1999 and the Equality Act 2010. London Plan policy 3.1 sets out the Mayor’s commitment to meeting the needs and expanding opportunities for all Londoners – and where appropriate, addressing the barriers to meeting the needs of particular groups and communities. This is considered key to tackling the huge issue of inequality across London. Development proposals are expected to protect and enhance facilities and services that meet the needs of particular groups and communities.

18 One of the businesses currently occupying the site is the Chariots sauna facility, operating for and used by the LGBT community. Chariots runs three other such facilities in London and the Shoreditch site is reported to be the busiest such facility in London as well as the largest in Europe. As such this is clearly a significant facility that meets the needs of this particular group and its loss should be resisted in the absence of adequate justification or provision for replacement, in line with London Plan policy 3.1. At pre-application stage the applicant demonstrated an awareness of this issue and explained that this was currently being considered in ongoing discussions with the operators of Chariots sauna. It was explained that the operators may have planned to leave for some time and that this was a business decision separate from this planning application. This, however, has yet to be confirmed. GLA officers strongly encourage further discussions with the sauna operators with a view to confirming the situation with regard to a the loss of this facility. This point needs to be addressed before any development proposals can be considered acceptable on this site.

page 5 Mix of uses

19 The site is located within the Central Activities Zone (CAZ) and within the City Fringe/Tech City Opportunity Area. The draft Opportunity Area Planning Framework (OAPF) indicates the potential for the area to deliver 70,000 new jobs and 8,700 new homes.

20 London Plan policies 4.2 and 2.10 encourage the renewal and modernisation of existing office stock in viable locations to improve its quality and flexibility, seeking increases in current stock where there is evidence of sustained demand for office based activities. London Plan policy 2.13 deals with development in Opportunity Areas. The draft City Fringe OAPF envisages the expansion of employment floorspace in the inner core area to support London’s critical mass of financial and business services and the growth of the digital-creative sector in Tech City. The applicant’s proposal to provide 11,866 sq.m. of new office floorspace in this location is therefore welcomed.

21 The proposed touch-down and break-out spaces, the small scale retail and the hospitality uses are recognised as being important in supporting the continued role of Tech City as a vibrant business quarter, with abundant informal networking opportunities and "third space" provision for start-ups. As such these uses are supported in line with the draft City Fringe OAPF.

22 There is an identified need for hotel rooms in this part of London and additional rooms can complement and support the other uses on site, as well supporting the development of the Tech City business cluster. The inclusion of a 200 room boutique hotel is supported in line with London Plan policy 4.5 and the draft City Fringe OAPF.

23 London Plan policy 2.11 states that development within the CAZ should increase office floorspace and include a mix of uses that includes housing, unless there are exceptional circumstances where such a mix demonstrably conflicts with other policies of the London Plan. Within this part of the CAZ and throughout the City Fringe OA there is a concern over the loss of office space to housing and the threat that insufficient future levels of office provision, particularly small and affordable offices, could harm the competitiveness of this nationally important office location and jeopardise the future growth of the Tech City business cluster. Furthermore, the introduction of residential uses at this site could potentially undermine nearby employment uses as well as those associated with the Night Time Economy. As such, a mixed-use scheme that includes offices but does not include residential development is considered acceptable in this location.

24 London Plan Policy 4.3, Para 4.17 states that exceptions (to providing housing) can be permitted where mixed uses might compromise broader objectives, as set out above, and in such circumstances, contributions to off-site housing provision should be required as part of a planning agreement. The applicant should therefore liaise with Hackney Council with a view to agreeing a suitable contribution towards off-site affordable housing, to be secured by section 106 agreement. GLA officers welcome further discussions with the applicant and Hackney Council Officers with regards to the level of contribution secured and how any affordable housing would be delivered.

25 Provided that the issues highlighted above, concerning equalities and off-site housing contributions, can be addressed then the proposed mix of land-uses in this part of the City Fringe can be supported.

page 6 Employment

26 As stated above, the ongoing supply of employment floorspace within the City Fringe Opportunity Area is a strategic concern. The quantum and type of employment floorspace proposed is therefore of critical importance with any development proposals. The applicant proposes 11,866 sq.m of B1 office floorspace and this can be subdivided if necessary, so that it can be used flexibly as demand dictates. This approach is strongly supported. Furthermore this provision represents a significant uplift in employment generating floorspace from the approximately 2,450 sq.m of A1 and sui generis floorspace currently on site and this is welcomed in line with the draft City Fringe OAPF.

27 The ongoing supply of affordable workspace is of particular concern in the City Fringe as it is crucial for enabling the levels of start-up activity that will continue to make the area so attractive to talent and inward investment. The supporting material sets out how the proposals have been designed to appeal to the digital-creative sector. The office element incorporates a range of facilities in addition to the core workspace areas. These include co‐working space, breakout areas, meeting areas (formal and informal) and event / lecture space. These facilities are located at Levels seven to nine within ‘The Shed’ space which comprises a glazed volume above the Shoreditch High Street block.

28 The applicant explained at pre-application that they envisage the affordable workspace to be delivered as a co-working space managed by either themselves or an established workspace provider. This is welcomed in line with the draft City Fringe OAPF, however, details of the level of provision, management and how this can be secured by Hackney Council should be provided before the Mayor sees this application again. GLA officers welcome the opportunity to be involved in ongoing discussions around this where necessary.

Urban design

29 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within chapter seven which address both general design principles and specific design issues. London Plan Policy 7.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage and World Heritage Sites, views, the public realm and the Blue Ribbon Network. New development is also required to have regard to its context, and make a positive contribution to local character within its neighbourhood (policy 7.4).

30 The site is in a very prominent location, on a key node within the City Fringe and relatively underdeveloped, with buildings contributing little to the townscape or legibility terms. The architectural approach attempts to reference the fragmented character of Shoreditch and the City Fringe and would offer a distinctive new landmark at a point of transition between the townscape of the City and that of inner East London. The scheme will introduce high quality street frontages and activity, and improvements to the public realm whilst contributing positively to the emerging context of recently built and proposed tall buildings in the immediate area. The proposals will provide an interesting juxtaposition with smaller, older buildings nearby.

31 The main entrance lobby for the hotel is proposed at the west end of Fairchild Street, set back from the junction with Great Eastern Street. Entrance arrangements for the office element are via a porous ground floor along both the eastern and southern elevations of the office building. Fairchild Street is the main vehicular access and a shared surface is proposed for the

page 7 whole length of the street. There are several roof terraces at level 7 for the shared workspace, level 10 for events and a fitness terrace at level 13 facing Hollywell Lane.

32 The proposals are generally well thought out and offer the potential to form a high quality mixed-use scheme in this prominent location. The main entrance lobby for the hotel is at the western part of the street, whereas the office entrance is towards the east. This is supported, as is the proposal to use Fairchild Street as the principal pedestrian and vehicular entrance route for as this results in a defined building line along this street and will enable the diversion of taxis away from the main traffic arteries of Great Eastern Street and Shoreditch High Street.

Figure 2: Layout of proposals (Source: Design and Access Statement, Gensler 2015)

33 The proposal to provide a publically accessible ‘touch down’ space at ground floor is welcomed as this will help to activate the ground floor and surrounding public realm and draw people into the building via multiple points of entry from the public facing edges of the block. The applicant’s proposal for transparency and porous frontages at ground floor onto the corner of Fairchild Street/Shoreditch High Street are welcomed as it contributes positively to street-based activity and responds well to comments made at pre-application stage.

34 There is an opportunity to bring the space to the north of the site, under the railway viaduct, back into public use at some point post-construction. This was discussed at pre- application stage and the applicant was asked to explore means of minimising servicing frontage and opening up the northern ground floor frontage to respond effectively, should the space be delivered in the future. The applicant was also asked to give consideration to means of activating this edge in the interim period, avoiding areas of blank and under-utilised frontage.

35 The applicant has responded by acknowledging the opportunity to respond to the Shoreditch Village proposals and potential future development on land immediately to the south of Hollywell Lane. Despite this, the design has not changed to reflect comments made at pre-

page 8 application stage. It is acknowledged that there is an issue with land-ownership and uncertainty surrounding future plans for the site immediately to the north, however, it is disappointing that the applicant has not made an effort to show what at least could be possible, and how the proposals could positively relate to this site and the Shoreditch Village beyond. There remain concerns that this could result in a problematic unused space along Hollywell Lane and the applicant is encouraged to examine ways of addressing this before the Mayor sees this application again. This should include details of how pedestrian routes will be clearly delineated from servicing access through subtle level changes and/or the strategic planting of street trees/positioning of furniture.

Figure 3: CGI image of proposals, as viewed from junction of Commercial Road and Shoreditch High Street looking north (Source: Design and Access Statement, Gensler 2015)

page 9 Tall buildings / strategic views/ historic environment

Tall buildings

36 London Plan (2011) policy 7.7, which relates to the specific design issues associated with tall and large-scale buildings, are of particular relevance to the proposed scheme. This policy sets out specific additional design requirements for tall and large-scale buildings, which are defined as buildings that are significantly taller than their surroundings and/or have a significant impact on the skyline and are larger than the threshold sizes set for the referral of planning applications to the Mayor.

37 The site sits at a prominent nodal point at the southern edge of the Shoreditch Triangle, and the applicant intends to utilise this to introduce a distinctive landmark building in a similar fashion to the proposed Art’otel at the western corner of the triangle. The Design Access Statement sets out how the proposals respond to and mediate between the scale of the emerging Bishopsgate Goods Yard scheme and the consented high rise development further to the south along Bishopsgate. This approach is supported and the proposed height and massing should sit comfortably in this context while being of sufficient scale to act as a landmark, denoting a gradual increase in the heights of existing and emerging development further towards the City.

38 Subject to the applicant successfully addressing the points raised below, relating to impact on the historic environment, the massing arrangement of a podium block containing office space with a taller hotel block above of smaller footprint, is supported. Furthermore the varying setbacks of building edges and roof lines proposed will form a well-proportioned and distinctive building.

Strategic Views

39 London Plan Policies 7.10 and 7.11, which set out the Mayor’s approach to protecting the character of strategic landmarks as well as London’s wider character. The proposals have particular potential to impact the following strategic views identified in the London View Management Framework, which are considered to be highly sensitive:

 1A.1 Alexandra Palace: Panorama from the viewing terrace, south western section.

 2A.1 Parliament Hill: The summit, looking towards St Paul’s.

 3A.1 Kenwood: The viewing gazebo- in front of the orientation board.

 4A.1 Primrose Hill: The summit- looking towards St Paul’s Cathedral

 5A.2 Greenwich Park: Panorama from the General Wolfe statue- north-east of the statue

 6A.1 Blackheath Point: Broad panorama near the orientation board

40 The TVIA demonstrates that in each instance the impact is minor and the resulting effect neutral, with the setting of St. Paul’s not significantly affected. The potential impact becomes even less significant when taking into account the nearby emerging schemes that include tall buildings.

41 The scheme lies within the background assessment area of view 8A.1, however is not of sufficient height to be visible behind St. Paul’s. The TVIA also tested the potential impact in views

page 10 10A.1, 15B.1, 15B.2, 16B.1, 16B.2, 17B.1, 17B.2, 18B.1, 25A.1, 25A.2, 25A.3. In each case the proposals were not visible and therefore would have no impact.

Historic environment

42 London Plan Policy 7.8 ‘Heritage Assets and Archaeology’ states that development should identify, value, conserve, restore, re-use and incorporate heritage assets where appropriate. The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the tests for dealing with heritage assets in planning decisions. In relation to listed buildings, all planning decisions should “have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses” and in relation to conservation areas, special attention must be paid to “the desirability of preserving or enhancing the character or appearance of that area”.

43 The NPPF states that when considering the impact of a proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation, and the more important the asset, the greater the weight should be. Significance is the value of the heritage asset because of its heritage interest, which may be archaeological, architectural, artistic or historic, and may derive from a heritage asset’s physical presence or its setting. Where a proposed development will lead to ‘substantial harm’ to or total loss of the significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss. Where a development will lead to ‘less than substantial harm’, the harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.

44 London Plan Policy 7.8 also applies to non-designated heritage assets. The NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application, and a balanced judgement is required having regard to the scale of any harm or loss and the significance of the heritage asset.

45 The applicant has provided qualitative visual analysis (QVAs) as part of the townscape and visual impact assessment (TVIA) to examine the potential impact the proposed development would have on strategic views and the settings of several conservation areas and listed buildings. The TVIA includes views of the proposed development from the 27 most significant local views, shown in Figure 4.

46 When assessing the potential impact of the proposed scheme it is important to note the changing built form and context of the immediate area, in particular with regard to proposed major schemes including tall buildings. These are summarised in Table 2. The TVIA includes wireframe images of these schemes and allows the application to be assessed in relation to what is there now, what is consented and what is emerging in terms of built form. These schemes are also highlighted in Figure 4.

Letter on Map Development Max height (Storeys) Status (Figure 2) A The Stage 40 Consented B Principle Place 50 Consented C Bishopsgate Goodsyard 26,30,38,46 Submitted D Shoreditch Village 9 Consented

Table 2: Major emerging schemes in the immediate vicinity of the site

page 11

Figure 4: Map showing site, emerging schemes (see table 1) and local views assessed in TVIA. The red shaded boundary in the centre is the application site.

47 The site sits within the South Shoreditch conservation area. As such the development proposals have the potential to impact on the setting of South Shoreditch conservation area, as well as the settings of the Brick Lane and Fournier Street and Elder Street conservation areas and several listed buildings. In the following views the proposals would have a significant impact on the settings of these conservation areas:

 07- Junction of Commercial Road and Hanbury Street, looking north west towards the site.

 08- Junction of Kingsland Road and Hackney Road, looking south towards the site.

 14- Junction of Bethnal Green Road and Sclater Street, looking west towards the site

 11- Junction of Brick Lane and Sclater Street, looking west towards the site

 17- Commercial Street railway bridge, looking north-west towards the site

 01- Buxton Street/ Allen Gardens looking west towards the site

page 12  03- Junction of Old Street and Great Eastern Street, looking south-eastwards

48 In each view the potential impact is significant within the current build context. This impact, however, does not result in an effect which could be deemed as causing substantial harm. Furthermore the effect becomes diluted and is significantly reduced when considering the consented and emerging proposals, as the scheme would become visible as part of a larger cluster, appear less significant when viewed closer to the larger scale development or be almost entirely screened.

49 Views 15, 16 and 23 demonstrate that the proposed development will impact the setting of the Grade II listed Georgian buildings at 187-191 Shoreditch High Street as well as South Shoreditch conservation areas. This impact, however, is not considered harmful. The smaller element of the scheme will appear in scale with these buildings and complete the frontage along Shoreditch High Street at the apex of the Shoreditch Triangle, which is beneficial in townscape terms.

50 View 18 examines the view from the junction of Shoreditch High Street and Fluer de Lis Street looking north towards the site. The impact upon this view will be major, with most of the taller element clearly visible above the roofline of the buildings on the west of Shoreditch High Street and the shorter element appearing to the left off the railway bridge crossing Shoreditch High Street. The impact, however, is significantly reduced when considering the emerging and consented schemes nearby and outweighed by the public benefits of the scheme which include bringing an underused site into more intensive use resulting in increased employment capacity and improved wayfinding, legibility and public realm.

51 The following views showed that the proposals could have a significant impact on the settings of the South Shoreditch conservation area:

 12- Junction of Norton Folgate and Spital Square, looking north towards the site.

 13- Junction of Worship Street and Curtain Road looking north-east towards the site.

 19- junction of Plough Yard and Hearn street looking north towards the site and the Grade II listed 5 Fairchild Place

 21- Junction of Great Eastern Street and Curtain Road, looking south-east.

 22- Junction of King John Court and New Inn Yard, looking south

52 In these instances the views are less sensitive and the existing buildings and cleared sites currently have low heritage value. The potential effect is beneficial in townscape terms, and is either removed entirely through screening or becomes negligible when considering the consented schemes at Principle Place and The Stage.

53 View 5 examined the impact on a view from the junction of Bishopsgate and Middlesex Street looking north. Here the lower and upper floors of the proposal would be visible, terminating the view along Bishopsgate and into Shoreditch. The potential impact is minor, and this becomes diluted further when considering the cumulative impact along with the proposed scheme at Principle Place, which would rise above the roofline of buildings along the western edge of Bishopsgate. View 20 examines the impact from the junction of Curtain Road and Scrutton Street, looking east. Here the upper floors of the tallest element would be visible above the roofline of buildings on the southern edge of Scrutton Street. This view contains buildings of lesser architectural significance and is less sensitive, the effect is therefore neutral.

page 13 54 Views 24 and 25 demonstrate the potential for a major impact on the setting of buildings at the apex of the Shoreditch Traingle, within the South Shoreditch conservation area. These buildings, however, are of lesser architectural interest immediately adjacent to the site and as such the views are of low sensitivity. The proposals will introduce a new building of high quality architecture and as such improve the overall townscape quality and the setting of the conservation area.

55 Views 26 and 27 examine the potential impact on the setting of the Grade I listed Geffrye Museum from within its garden. The assessments suggest that the impact will be negligible, however, this is difficult to determine because of the presence of foliage within the photographs used. Given the importance of the heritage asset in question and the need to examine the potential impact to a view of such sensitivity, the applicant is required to provide additional view assessments using photographs taken at a time when foliage was not present. This is to examine the worst case scenario and thoroughly test the potential impact on the setting of the Grade I listed Geffrye museum.

Conclusion

56 The design and layout are generally well thought out and the architectural approach supported. The context to the north of the site and along Hollywell Lane is changing and, whilst acknowledging difficulties associated with uncertainty surrounding the site immediately to the north, the applicant is encouraged to look again at ways the scheme could positively relate to that site and the emerging Shoreditch Village scheme.

57 TVIA provided by the applicant demonstrates that the proposed development will have a an impact on several local views and therefore to the setting of the conservation areas. In cases where the impact is significant, however, it is not considered to cause substantial harm and the significance of the effect will reduce when emerging development is delivered. Furthermore, any harm would be outweighed by the public benefits of the scheme, subject to the applicant satisfactorily addressing the points raised elsewhere in this report. In order to confirm that this is the case, the applicant should confirm the dimensions used for the emerging Bishopsgate Goodsyard scheme (as this has changed substantially recently) and provide a new QVA in relation to the potential impact the proposals may have on the setting of the Grade I listed Geffrye museum, as outlined above.

Inclusive design

58 The aim of London Plan Policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and inclusion. Inclusive design principles if embedded into the development and design process from the outset help to ensure that all of us, including older people, disabled and deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity.

59 The design and access statement provided includes an accessibility statement explaining the inclusive design principles that have been considered and how they have been applied. The site is parking free but a vehicle drop off space is provided directly outside the hotel entrance which will be designed as a disabled parking space, which is supported. The site is well served by public transport, with adequate seating, shelter, WCs and lifts available for disabled users where appropriate.

60 The applicant states that it is the intention of the proposals to make the building useable and permeable by all through innovative use of materials, surfacing, finishes and inclusive design of fixtures and fittings. The applicant has committed to providing 10 (5%) wheelchair accessible

page 14 rooms, as well as application of the standards set out in Building Regulations 2013 Part M in relation to heights, widths, finishes and surfaces and this is welcomed. Seating is to be provided outside of all meeting rooms and close to the hotel reception desk. All reception desks, bars and self-service areas will include a lowered section to accommodate wheelchair users if necessary.

61 The applicant has provided a detailed wayfinding strategy and table of considerations further explaining the design rationale and showing how the specific access needs of disabled people, have been integrated into the proposed development. Furthermore, the applicant has provided information explaining how inclusion will be maintained and managed beyond construction, and how staff training will be tailored accordingly. As such the proposals respond well to the requirements of London Plan policy 7.2. Climate change

62 The London Plan climate change policies as set out in Chapter 5 collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising decentralised energy supply, and incorporating renewable energy. The policies set out ways in which developers must address mitigation of, and adaptation to, the effects of climate change.

63 London Plan policy 5.2 states that development proposals should make the fullest contribution to minimising carbon dioxide emissions in accordance with the following energy hierarchy:

1. Be lean: use less energy

2. Be clean: supply energy efficiently

3. Be green: use renewable energy

64 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include low energy lighting and mechanical ventilation with heat recovery.

65 The demand for cooling will be minimised through solar control glazing and external shading (vertical control fins) with the largest glazing including integrated blinds. The applicant has assessed the solar gain limits and there are few instances of the solar gain being exceeded, in one case significantly. The applicant should review the glazing strategy and work to ensure that the limit is met. The updated BRUKL sheet should be provided demonstrating compliance with the solar gain limit, any additional measures required should be detailed.

66 The development is estimated to achieve a reduction of 79 tonnes per annum (7%) in regulated carbon dioxide emissions compared to a 2013 Building Regulations compliant development.

67 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development. The applicant has investigated the possibility of connecting to neighbouring developments and identified the potential Bishopsgate Goods Yard development as the most suitable for connection. As the Bishopsgate Goods Yard development does not have planning permission the applicant is proposing an on-site solution at this time. The applicant should continue to explore this opportunity as the design progresses.

page 15 68 The London Heat Map identifies a proposed network to the south of the site. The applicant should therefore contact the Hackney Council energy officer to determine the current progress of the network and whether there is an opportunity for connection. Evidence of correspondence should be provided.

69 The applicant is proposing to install a site heat network. The applicant should confirm that all apartments and non-domestic building uses will be connected to the site heat network. A drawing showing the route of the heat network linking all buildings on the site should be provided.

70 The site heat network will be supplied from a single energy centre located in the basement. The applicant should confirm that all non-domestic building uses will be connected to the site heat network.

71 The applicant is proposing to install two 150kWe gas fired combined heat and power units as the lead heat source for the site heat network. The combined heat and power units are sized to provide the domestic hot water load, as well as a proportion of the space heating. This will achieve a reduction in regulated carbon dioxide emissions of 204 tonnes per annum (19%).

72 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 96 sq.m. (12kW) of Photovoltaic (PV) panels on the roof of the development.

73 This will contribute an additional reduction in regulated carbon dioxide emissions of 4 tonnes per annum (less than 1%). Whilst it is acknowledged that there is limited space for additional PV, the applicant should investigate installing high efficiency panels (e.g. 17-20%) in order to maximise the on-site carbon savings. Updated results should be provided.

74 The applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole. The current proposal include measures that would give an overall reduction of 287 tonnes of carbon dioxide per year in regulated emissions compared to a 2013 Building Regulations compliant development. This is equivalent to an overall saving of 26%, however, falls short of the targets within London Plan Policy 5.2. While it is accepted that there is little further potential for carbon dioxide reductions onsite, the applicant should liaise with Hackney Council to ensure that the short fall in carbon dioxide reductions (equivalent to 96 tonnes of carbon dioxide per annum) is met off-site. The applicant should also investigate measures that would maximise the savings that could be made through installation of PV cells, as outlined above. The comments above should be addressed before the application can be considered compliant with London Plan climate change policy. Transport

75 The car-free nature of the scheme is welcomed, however, the applicant is required to provide a minimum of one Blue Badge disabled parking bay on site. The proposed 216 cycle spaces are also welcome but clarification is required as to how the spaces are allocated between the respective uses across the development.

76 In order to overcome the need for onsite coach parking, the applicant advises that they will not accept coach bookings. Whilst this should be secured through the section 106 agreement, the applicant is urged to reconsider provision of a coach waiting area either on site or within the vicinity, to be provided in accordance with London Plan policy 6.13.

77 Transport for London are currently developing a £12.4m ‘Shoreditch Triangle Scheme’ which will improve local pedestrian and cycling facilities in the vicinity of the site. The project is funded to the end of the feasibility design stage. A considerable element of the emerging scheme

page 16 will address the additional pedestrian demand from this scheme as well as improve the public realm on Shoreditch High Street and is therefore necessary to make this development necessary. In accordance with London Plan policies 6.9 and 6.10 the applicant should provide a contribution towards the scheme’s delivery, comparable with that currently sought from the adjacent development at Bishopsgate Goodsyard. This is to be secured by section 106 agreement. The applicant is encouraged to enter further discussions with Transport for London concerning this, as well as how the applicant’s indicative highway improvements can be incorporated into his scheme.

78 In accordance with London Plan policy 6.9, the proposals should facilitate the expansion of the cycle hire scheme. An additional cycle hire docking station within the local area would cost £200,000. The location should be agreed with Transport for London and Hackney Council with funding allocated through the Council’s CIL.

79 It is understood that the applicant wishes to remove an existing crossover on Shoreditch High Street and this along with any other agreed works, referred to above, will need to be facilitated through a section 278 agreement.

80 The applicant has submitted a Framework Travel Plan which has been verified through the ATTrBuTE testing system and has deemed acceptable. The final version should be secured and implemented through the section 106 agreement. Minor amendments should be made to the Construction Logistics Plan before it can be approved. The CLP should also address any impact on the adjacent railway viaduct.

81 The applicant has also provided a Delivery and Servicing Plan (DSP). The DSP will also require minor amendments and the applicant should liaise directly with Transport for London for guidance on the amendments required. Both the DSP and CLP should be secured by condition prior to demolition and construction works commencing.

82 In summary, it is expected that a contribution will be secured within the section 106 agreement towards the ‘Shoreditch Triangle Scheme’ with appropriate CIL funding allocated towards the provision of additional cycle hire capacity. A Crossrail contribution will also need to be included in the section 106 agreement. In addition, a coach facility and Blue Badge provision should be provided within the vicinity of the site and clarification is required regarding cycle parking. Finally, a CLP and DSP should be secured by condition in addition to a travel plan secured through the section 106 agreement. Community Infrastructure Levy

83 The Mayor has introduced a London-wide Community Infrastructure Levy (CIL) to help implement the London Plan, particularly policies 6.5 and 8.3. The Mayoral CIL formally came into effect on 1 April 2012, and it will be paid on commencement of most new development in Greater London that was granted planning permission on or after that date. The Mayor's CIL will contribute towards the funding of Crossrail

84 The site is also within the area where planning obligations for Crossrail should be sought. The mechanism for contributions to be made payable towards Crossrail has been set out in the Mayor’s Supplementary Planning Guidance (SPG) “Use of planning obligations in the funding of Crossrail, and the Mayoral Community Infrastructure Levy” (April 2013). The SPG states that contributions should be sought in respect of uplift in floorspace for B1 office, hotel and retail uses (with an uplift of at least 500 sq.m).The site is within Central Charging Zone and therefore on the basis that there is an uplift of 14,244 sq.m of hotel and 11,866 sq.m of office use with a loss of 800 sq.m of A1 use, then a contribution of £2,458,124 should be secured in the section 106 agreement.

page 17 85 The applicant should note however, that the Mayor’s CIL charge will be treated as a credit towards the section 106 liability and therefore only the larger of the two amounts will normally be sought. Notwithstanding this, Hackney Council should include the full Crossrail sum within the section 106 agreement.

86 London borough councils are also able to introduce CIL charges which are payable in addition to the Mayor’s CIL. Hackney Council has adopted a scheme as of 1 April 2015. See the Council’s website for more details. Local planning authority’s position

87 Hackney Council’s position is as yet unknown. Legal considerations

88 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

89 There are no financial considerations at this stage. Conclusion

90 Whilst the application is broadly supported, it does not yet comply with the London Plan. There are still areas that need addressing specifically in relation to equalities, mixed-use policy, employment, urban design, climate change and transport as outlined in this report.

91 The following changes might, however, remedy the above-mentioned deficiencies and lead to the application becoming compliant with the London Plan:

 Equalities: Satisfactorily addressing the issue related to loss of the sauna facility

 Exception to the mixed-use policy: Securing of a satisfactory off-site affordable housing contribution by section 106 agreement.

 Employment: Provide details of the level of affordable workspace provision, management and how this can be secured by Hackney Council should be provided

 Urban Design: Give further consideration as to how the application can positively relate to the emerging context to the north, specifically the site between the proposals and Hollywell Lane. Provide further visual assessment to confirm the potential impact on the setting of the Grade I listed Geffrye Museum.

page 18  Climate change: Liaise with Hackney Council and commit to offsetting the shortfall in carbon dioxide reduction in relation to London Plan targets, as well as consider ways of adding additional PV cells in order to maximise the carbon dioxide savings possible by use of this technology.

 Transport: Carry out further work and commit to making appropriate contributions to address issues raised in paragraphs 75-84.

for further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Matt Christie, Case Officer 020 7983 4409 email [email protected]

page 19