P7065

SE1 55 LANT STREET,

PLANNING STATEMENT PLANNING

& STATEMENT OF COMMU & STATEMENT

NITY INVOLVEMEN NITY

T

17/11/2020

www.rolfe-judd.co.uk

P7065

On behalf of Damgate Freeholds Limited SE1 55 LANT STREET,

Blocks A and B

Lant Street,

PLANNING STATEMENT PLANNING

London,

SE1

Planning Statement

OF COMMU & STATEMENT

NITY INVOLVEMENT NITY

RJP: P7065 November 2020 17/11/2020

www.rolfe-judd.co.uk

Contents

1.0 Introduction 1

1.1 Summary 1

1.2 Planning Statement 2

1.3 Supporting Application Documents 3

2.0 The Application Site and Surrounding Area 4

2.1 Site Description & Location 4

2.2 Planning History of The Site 5

2.3 Surrounding Area 7

3.0 Pre-Application, Consultation and Withdrawn Application 10

3.1 Pre-Application Advice (ref. 18/EQ/0262 & 18/EQ/0401) 10

3.2 Statement of Community Involvement 11

3.3 Previously Withdrawn Application (ref. 20/AP/1272) 12

4.0 The Application Scheme 15

4.1 Overview 15

4.2 Detailed Description 15

5.0 Relevant Planning Policies 18

5.1 The Adopted Development Framework 18

5.2 National Planning Policy Framework (2019) 18

5.3 The London Plan (2016) and Intend to Publish London Plan (2019) 20

5.4 Southwark Local Plan 23

6.0 Planning Considerations 25

6.1 Principle of Development 25

6.2 New Housing 26

6.3 Affordable Housing 26

6.4 Unit Mix 27

6.5 Heritage 28

6.6 Design Considerations 29

6.7 External Amenity & Play Space 31

Planning Statement i

6.8 Daylight, Sunlight and Overshadowing 32

6.9 Transport 34

6.10 Refuse 35

6.11 Energy and Sustainability 36

6.12 Flood Risk 37

6.13 Planning Obligations and Community Infrastructure Levy (CIL) / Draft Heads of Terms 37

7.0 Conclusion & Planning Balance 38

Planning Statement ii

1.0 Introduction

1.1 Summary

1.1.1 This planning statement has been prepared by Rolfe Judd Planning Ltd on behalf of the applicant, Damgate Freeholds Ltd, in support of a planning application for the erection of one additional storey on Blocks A and B to create 9 new residential homes, in addition to a new rooftop terrace and associated waste and cycle storage.

1.1.2 The overall site comprises three residential blocks:

- Block A (Flats 1-47 & 2 & 6), Sanctuary Street, London SE1 1EA

- Block B (Flats 2-33), Isaac Way, London SE1 1EE

- Block C (Flats 1-12), Gaitskell Walk, London SE1 1EF

1.1.3 However for this application, Block C will not form part of the proposed development and the figure below is for informational purposes only.

1.1.4 The key benefits of the application scheme are as follows:

 Efficient use of a previously development site for high-quality and accessible homes in the airspace above the existing building.

Planning Statement 1

 Erection of one additional storey on the two existing residential blocks (Blocks A and B) to accommodate 9 high-quality new homes, ranging in size to accommodate some family-sized homes.

 Spacious private external amenity space via balconies, designed in accordance with the Draft London Plan.

 New communal roof terraces.

 Secure cycle storage within the undercroft for new residents, in accordance with the Draft London Plan Cycle Standards.

 Car-free development

 Additional associated waste storage at ground floor level for new residents.

 The design of the building incorporates high-quality and contemporary light stone colour cladding with full- height double glazing to ensure the façade design and materiality provides a positive contribution to the streetscene and surrounding historic environment.

 Adopts inclusive design standards to ensure the new residential homes are accessible to all users.

 Adopts sustainable design and energy efficient measures to mitigate and reduce any potential carbon emissions on-site.

1.1.5 For the purpose of the planning application, the application scheme is described as follows:

“Erection of one additional storey on Blocks A and B to create 9 no. residential units, including a new roof terrace and associated waste and cycle storage at basement and ground floor level”

1.2 Planning Statement

The purpose of this statement is to support a planning application for the erection of a single storey extension on Blocks A and B for 9 new homes, including other associated works. In particular, this statement identifies and describes the key opportunities and constraints presented by the proposed development.

1.2.1 The statement provides a comprehensive analysis of the relevant planning policy framework at national, strategic and local levels. As such, the planning statement is structured as follows:

Section 1: Introduction Section 2: The Application Site and Surrounding Area Section 3: Pre-Application, Consultation and Withdrawn Application Section 4: The Application Scheme Section 5: Relevant Planning Policies Section 6: Planning Considerations Section 7: Conclusion and Planning Balance

Planning Statement 2

1.3 Supporting Application Documents

1.3.1 This planning statement should be read in conjunction with the following additional documents, which accompany the application:

 Planning Application Form, Certificates and CIL Form – prepared by Rolfe Judd Planning Ltd

 Existing and Proposed Drawings – prepared by GML Architects

 Design & Access Statement – prepared by GML Architects

 Viability Appraisal – prepared by Bespoke

 Heritage Statement – prepared by Heritage Collective

 Daylight Sunlight Report – prepared by Avison Young

 Statement of Community Involvement – prepared by Rolfe Judd Planning Ltd (contained within this Planning Statement)

 Energy Assessment – contained within the Design and Access Statement

 Transport Assessment – prepared by Caneparo Associates

 Construction Environment Management Plan – prepared by Ridge & Partners LLP

 Noise Impact Assessment – prepared by Hann Tucker

 Air Quality Assessment – prepared by Air Quality Assessments Ltd

 Development Charter Engagement Summary – Damgate Freeholds Ltd / Rolfe Judd Planning Ltd

 Draft Planning Obligations – Rolfe Judd Planning Ltd (contained within this Planning Statement)

Planning Statement 3

2.0 The Application Site and Surrounding Area

2.1 Site Description & Location

2.1.1 The application site (Blocks A and B) is located within a residential estate fronting Lant Street, Sanctuary Street, Isaac Way, and Weller Street. The site is located west of Borough Station in the London Borough of Southwark. The three blocks are five storeys in height (above basement), and are in sole residential use (Class C3).

Blocks A, B and C (above), on Sanctuary Street, Isaac Way, and Weller Street, Southwark

2.1.2 Block A is the largest of the three residential blocks, located on the corner between Sanctuary Street and Lant Street. It currently comprises 50 privately-rented residential homes, with 32 x 1-bed units and 18 x 2-bed units.

2.1.3 Block B is the central block situated within the courtyard of Isaac Way. It comprises a mix of 22 privately-rented homes (12 x 1-bed units & 10 x 2-bed units) and 10 affordable homes (5 x 1-bed units, 2 x 2-bed units, 3 x 3-bed units).

2.1.4 Block C is an L-shaped property situated between neighbouring properties on Weller Street. The block contains affordable housing and is managed by Wandle Housing Association Limited; a registered social housing landlord. There are 12 homes in total; 6 x 1-bed units and 6 x 2-bed units.

2.1.5 The main pedestrian entrance to Blocks A and B is provided from Sanctuary Street.

2.1.6 Currently, 70 parking spaces are provided for the residential blocks at basement level, 7 of which are blue-badge parking spaces. In addition to this, there are 30 cycle spaces. The basement carpark entrance is accessible via Sanctuary Street and Weller Street, and through the main cores of Blocks A and B.

Planning Statement 4

2.1.7 The existing refuse and recycling storage for each of the residential blocks are separately located at the ground floor level. All refuse storage facilities are enclosed and secured.

2.1.8 There is approximately 739sqm of communal amenity space at the ground floor level; of which 306sqm is dedicated to soft landscaping (i.e. green areas), and 433sqm is hard landscaping.

2.1.9 The site has a PTAL rating of 6b, which indicates excellent access to public transport and amenities including numerous bus routes running along Borough High Street. It is also within short walking distance to Borough tube station.

2.1.10 None of the buildings are listed, however the site is located within the Liberty of the Mint Conservation Area, which is recognised as a ‘tightly-knit urban realm, with high quality examples of historic and modern social housing, former warehouses, 19th century townhouses, some with commercial premises at ground floor, public houses and a large Victorian board school’ (The Liberty of the Mint Conservation Area Appraisal, 2018).

2.1.11 The site is also located in the Bankside, Borough and London Bridge Opportunity Area, and the Core Central Activities Zone (CAZ).

2.2 Planning History of The Site

2.2.1 Prior to the construction of the three residential blocks currently at the site, the history of the application site can be traced back through historical maps and photographs from The London Picture Archive, dating early 20th century.

2.2.2 Lant Street, as recognised within the Liberty of the Mint Conservation Area Appraisal, runs east to west through the centre, and its width suggests it was once a street comprised of a series of terraced buildings.

Map 1: The application site boundary annotated onto a 1914 OS Map (extracted from the Heritage Statement, Heritage Collective)

2.2.3 As shown in Map 1 above, the majority of the site once comprised a Cart and Wheel Works, and the southern element of the site once formed part of a series of Georgian terraced houses.

Planning Statement 5

2.2.4 Below, is an historic photograph from The London Picture Archive (Photo 1 dated. c.1920), depicts an early twentieth century setting of the former Georgian terraces and corner pub at the junction of Weller Street and Lant Street. The former pub, ‘The Prince of Wales’, is today a six-storey residential building (known as 2 Weller Street), which lies adjacent to Block C.

Photo 1: Prince of Wales, 25 – 35 Lant Street / Weller Street (formally Little Lant Street), dated 1920.

2.2.5 Below is a later historic photograph (dated 1947), facing east down Lant Street. This historic photograph shows a greater image of the former Georgian terraces, and Lant Street itself.

2.2.6 At the far end of the photograph below, the former terraced homes which stood here now form part of Block A of the application site. Across the street and at the far end of the photograph is a warehouse. That same warehouse is located at the junction of Lant Street and Sanctuary Street today, although is now vacant.

Photo 2: Facing East down Lant Street (25 – 53 Lant Street), dated 1947.

Planning Statement 6

2.2.7 It is unknown when the former Georgian terraces were demolished, although it is known from the site’s planning history that a former single-storey warehouse operated on the application site sometime after the homes were demolished and prior to site’s use today. The last tenant who had occupied the warehouse had vacated 18 months prior to a planning application being submitted to the Council in December 2000, which included the redevelopment of the site.

2.2.8 That planning application (ref. 00/AP/1820) was granted planning permission on 08 January 2003 subject to a legal agreement to secure 22 affordable homes. The description of development includes:

‘Demolition of warehouse and loading bay and erection of 3 no 5 storey blocks of flats comprising of 55x 1 bed, 36x 2 bed and 3 x 3 bed flats (i.e, 72 private units and 22 affordable units). 70 off-street car parking at basement level and 30 cycle storage spaces.’

2.2.9 According to the committee report (dated July 2001) the former industrial site was the source of noise and traffic complaints. Therefore, the ‘alternative use of the site for residential purposes [was] considered acceptable in principle’ and the mix of homes, including ‘their layout and internal floor areas [were in compliance] with the Council’s standards’.

2.2.10 A previous related application (ref. 20/AP/1272) was submitted in May 2020, and subsequently withdrawn on 12th November 2019 for:

‘Construction of one additional storey on each of the three existing residential blocks to create 16 no. residential units and the provision of one additional bedroom to an existing residential unit in Block C, including a new roof terrace, and associated waste and cycle storage at basement and ground floor level.’

2.2.11 Please refer to Section 3 and Section 6 of this Planning Statement for further information on the changes to the withdrawn scheme.

2.2.12 There have been no other significant planning applications related to the site since the original planning permission was granted in January 2003.

2.3 Surrounding Area

2.3.1 The site is adjacent to the Peabody Marshalsea Estate, which is located north on Marshalsea Road. The Peabody Marshalsea Estate consists of three Victorian blocks which were originally built in the late 19th Century.

2.3.2 Marshalsea Road (which runs north-west/east to the north and beyond the application site) has seen some new development in recent years, and this has delivered additional residential accommodation for the borough. More notably, in January 2016 planning permission was granted at 280 Borough High Street for the erection of a part-five and part-seven storey building comprising nine new residential units with commercial use on the lower and ground floor level (ref. 15/AP/4770). See full planning history below.

2.3.3 In recent years there has also been some relevant permissions within the Liberty of the Mint Conservation Area, which include:

Planning Statement 7

12-14 Marshalsea Road

In June 2017, an application was allowed on appeal for an ‘Extension of the existing mansard roof to create a full storey (6th floor) to match the buildings below and the erection of a new mansard roof above, together with the change of use of part of the ground floor accommodation at no.14 from an office (Use Class B1(a)) to a cafe (Use Class A1/A3) and the change of use of the first, second, third, fourth and fifth floors of no.14 from offices (Use Class B1(a)) to 5 x two bedroom flats and the use of the new roof level accommodation as 2 x one bedroom flats; together with refuse and cycle storage at ground floor level’ under ref. W/16/3165639.

24 Marshalsea Road

Planning permission was granted on 20 February 2015 for the ‘Erection of a fourth floor roof extension to Flat 7’, under application ref. 14/AP/4735.

2.3.4 Other permissions within the surrounding area include:

133-135 Great Suffolk Street

Planning permission was granted on 25 January 2019 for the ‘Replacement of existing mansard roof extension with new floor over the building footprint and an additional rooftop extension, replacement of existing facade of the building with a new one, replacement of plant and equipment, existing fenestration and entrance and courtyard gates and provision of cycle spaces’ under application ref. 18/AP/3105.

Southwark Fire Station

Planning permission and Listed Building Consent were granted on 2 November 2018 for the ‘Redevelopment of the site including alterations and extensions to listed buildings for a mixed use scheme to provide a new secondary school with 6th form (up to 1150 pupils), 199 residential units in buildings up the 10 storeys in height, 234 sqm of flexible commercial or community use (Class A1, A3, B1, D1, D2), a 139 sqm Gym, associated landscape and public realm works, cycle parking, disabled parking and servicing access; and the redevelopment of land at Grotto Place for the provision of a new sports hall (1,452sqm) and external multi use games facility and landscaping’ under application ref. 17/AP/0367 and 17/AP/0368.

280 Borough High Street

Planning permission was granted on 22 January 2016 for the ‘Demolition of existing building and erection of a part five-storey, part seven-storey building comprising a commercial unit at lower-ground and ground-floor level (Use Class A1/A2/A3), 9no. self-contained dwellings above and associated refuse, recycling and cycle storage facilities and roof terraces’ under application ref. 15/AP/4770.

16-18 Marshalsea Road

Planning permission was granted on 17 July 2014 for ‘the change of use of the building from office (use class B1) to retail/financial services (use classes A1/A2) on the ground floor, residential (use class C3) on the upper floors (floors

Planning Statement 8

1-4), to create 4x2 bed and 4x3 bed flats and the addition of a single storey roof extension to create a 2 bed flat with a private terrace’ under application ref. 13/AP/3367, and varied by 14/AP/3675.

Brandon House, 180 Borough High Street

Planning permission was granted on 13 September 2013 for the ‘Demolition of existing building and erection of a building (with basement) up to eight storeys in height (maximum 28.50m at corner) fronting Marshalsea Road and Borough High Street comprising office / retail floorspace (Class B1 / Class A use) and 96 residential units; erection of a four storey mews building to the rear (13.10m) comprising 4 residential units; provision of open space with ancillary plant, car parking and servicing, works of hard and soft landscaping and new pedestrian access to Borough High Street together with other associated and enabling works’ under application ref. 11/AP/2012, an varied by 14/AP/2695.

2.3.5 The surrounding area comprises a mix of uses, though predominantly residential use (Class C3), particularly on Santuary Street, Marshalsea Road and Lant Street. The application site is also located near Borough Station, where a mix of other uses operate, including Class A1 (Starbucks, Café Riva), Class A3/A4 (The Trinity, Al Masar, Gladstone Pub), Class B1 (Fluxx Ltd., Simon Whitehead Architects), Class D1 (Charles Dickens Primary School, Banana Moon Day Nursery).

2.3.6 Mint Street Adventure Playground is located less than one minute’s walk from the site offering high-quality child’s play spaces and allotment areas for children to grow their own plants and herbs. There are large green spaces and an outdoor urban gym. Little Dorrit Park, Newington Gardens and Tabard Gardens are also examples of other designated London parks and green spaces within close proximity to the site.

Planning Statement 9

3.0 Pre-Application, Consultation and Withdrawn Application

3.1 Pre-Application Advice (ref. 18/EQ/0262 & 18/EQ/0401)

3.1.1 As highlighted within Paragraphs 39 - 44 of the NPPF (2019), the applicant has actively engaged with the Local Planning Authority in two pre-application consultations in 2018 to attain formal advice. The NPPF notes that early engagement has significant potential to improve the efficiency and effectiveness of the planning application process for all parties. Good-quality pre-application discussion enables there to be better coordination between public and private resources and improved outcomes for the wider community.

3.1.2 The applicant held two pre-application meetings (ref. 18/EQ/0262 & 18/EQ/0401) with Southwark Council, the first on 27 September 2018 and a follow-up meeting was later held on 3 December 2018 to discuss further development on design.

3.1.3 The initial scheme requested advice for additional massing on the three five-storey residential blocks, to provide 26 new residential units.

 Block A: 13 residential units, 5 one bedroom and 8 two bedroom

 Block B: 10 residential units, 3 one bedroom, 3 two bedroom, and 4 three bedroom; and

 Block C: 3 residential units, 1 studio and 2 three bedroom

3.1.4 Following the initial pre-application meeting held on 27 September 2018, it was considered by the Council that:

 Extending upwards on the three existing residential blocks was acceptable in principle.

 Block A – The Council considered that a two-storey extension on the corner of Lant Street and Sanctuary Street was potentially acceptable, but a reduction should be made to the length of the two-storey element along Sanctuary Street.

 Block B – The Council accepted that the block sits slightly lower than blocks either side, and therefore creating additional floorspace above would be acceptable.

 Block C – The Council considered only one additional storey would be acceptable, and should extend higher than the adjacent corner building.

3.1.5 The revised scheme was presented to officers following the initial comments received at the first meeting. There were substantive reductions in height to Block A and Block B with both buildings still having two storey extensions but substantially set back and Block C as a one storey extension. Key comments received from officers were support for the principle of the scheme and for the reductions made to the initial scheme but a recommendation that all extensions should be single storey only. Key concerns were over the views in the recently adopted Conservation Area and how the extension to Block A particularly could be viewed in longer views.

Planning Statement 10

3.1.6 More information on how cycle provision and refuse provision would be provided should be submitted with the application.

3.1.7 Overall officers were supportive of the scheme and subject to the detailed design matters, daylight evidence and the reductions suggested considered the scheme could be supported.

3.2 Statement of Community Involvement

3.2.1 In line with Paragraphs 39, 40 and 128 of the NPPF, the applicant has actively engaged with the local community and those affected by the proposed development to allow the evolution of design to take account of the views of the community.

3.2.2 Paragraph 128 of the National Planning Policy Framework (NPPF, February 2019) states that:

‘Design quality should be considered throughout the evolution and assessment of individual proposals. Early discussion between applicants, the local planning authority and local community about the design and style of emerging schemes is important for clarifying expectations and reconciling local and commercial interests. Applicants should work closely with those affected by their proposals to evolve designs that take account of the views of the community. Applications that can demonstrate early, proactive and effective engagement with the community should be looked on more favourably than those that cannot.’

3.2.3 This Statement of Community Involvement and Response to Development Consultation Charter provides a summary of the consultation to date and on-going engagement into the future. The consultation on this Application Scheme has been undertaken in line with Southwark Council’s Development Consultation Charter and Statement of Community Involvement (2008).

3.2.4 Pre-application discussions and engagement have been held with Southwark officers, key stakeholders and the wider public.

3.2.5 It is fundamental to the applicant (Damgate Freeholds Ltd) that all members of the local community are consulted as part of the development process. The applicant appreciates all comments and comments made upon the application scheme, including the design in the run up to submission and during the application process.

3.2.6 A summary of public engagement for the application scheme is outlined below:

 Leaflets delivered to the Application Site’s Residents & Neighbours – 14th December 2019

 A meeting with Wandle Housing Association (Block C Social Housing Landlord) – 16th December 2019

 A meeting with Gladstone Arms Public House – December 2019

 A meeting with Houston Lawrence Management (Application Site’s Property Management) – January 2020

 A Site Visit & Meeting with Peabody (Douglas Buildings) – 05 February 2020

Planning Statement 11

3.2.7 The full details of each of the meetings are further detailed within the Development Management Charter, which has been submitted with the application.

3.3 Previously Withdrawn Application (ref. 20/AP/1272)

3.3.1 In May 2020, the Applicant submitted an application for:

‘Construction of one additional storey on each of the three existing residential blocks to create 16 no. residential units and the provision of one additional bedroom to an existing residential unit in Block C, including a new roof terrace, and associated waste and cycle storage at basement and ground floor level.’

3.3.1 The Applicant was in regular discussions with the Council throughout the application process and following the consultation period, the Applicant was made aware that there were design issues that had been raised by the Design and Conservation Officer. The key issues are summarised as follows:

 The architectural treatment, notably the ‘double height architectural language’, and additional storeys read as ‘incoherent’ and ‘unbalances the hierarchy of the existing blocks’.

 The existing blocks on-site are some of the highest in the conservation area at five storeys, therefore particular attention would need to be considered in regards to the scale and massing and the impact these proposed additional storeys would have on the character and appearance of the Liberty of the Mint Conservation Area.

 Western views along Lant Street appear ‘overly dominant’ and eastern views along Trundle Street would ‘rise above the corner block which in itself is problematic’. The flank elevation of Block B onto the Charles Dickens School playground was considered ‘challenging’ despite some attempts to set-back the additional storey.

 The additional storey on Block C failed to maintain the established hierarchy in Trundle Street, with it appear taller than its neighbour on the corner, which as the corner block should maintain pre-eminence.

 The proposal as currently submitted would not preserve and enhance the conservation area and was therefore considered not to comply with local and national planning policy and guidance in the adopted conservation area appraisal.

3.3.2 A meeting was held on 2nd September 2020 with the Planning Officer and Design and Conservation Officer to address the issues raised and to discuss potential solutions.

3.3.3 Overall it was a very positive and proactive meeting whereby the Council highlighted areas of the scheme which would need to be further refined. These included:

 Reductions to the overall height – The additional storey appears out of proportion compared to the host building below.

Planning Statement 12

 Softening of the additional storey’s edges and further set-backs to mitigate a ‘cliff face’ effect on Block B to Charles Dickens School – Further definition would help mitigate the ‘uncomfortable’ appearance of the additional storey.

 Façade treatment requires a degree of subservience – The proposed design was considered to emphasise the roof extension and appears ‘striking’ from the views provided.

3.3.4 The Applicant’s heritage consultant highlighted the historic evolution of the area and its fragmentation over time, stating that the additional height would be perceived as an ‘incremental’ change to the surrounding conservation area. Also, given the vacant land adjacent to Block B was taken by Charles Dickens School for a playground, Lant Street’s continuity has significantly changed. It was agreed by both parties that the current buildings do not make a positive contribution to the conservation area, and that a slightly higher roof extension would not imbalance the street frontage.

3.3.5 It was also highlighted in the meeting that the materials do create a completely separate definition between the existing and proposed building which in-turn sets out a clear hierarchy between the existing brick building, built around 2003, and the new which should be read as a later addition.

3.3.6 In addition to the above and to enable the scheme to move forward, it was confirmed by the Applicant that it would not be practical for the Applicant to pursue Block C in the scheme, or in any future application. This resulted in two proposed homes and the extension to an existing home in Block C to be omitted from the scheme entirely.

3.3.7 It was acknowledged in the meeting that in policy terms, there would be stronger justification to bring forward a 9-unit scheme that consists of more family homes, including 1 x 4-bed unit.

3.3.8 Overall, the Council supported the progress that had been made and agreed for the Applicant to continue preparing the amended scheme.

3.3.9 On 5th October 2020, the Applicant’s team had prepared two options for the 9-unit scheme prior to the final submission; Option A and Option B. Overall the proposed scheme included 1 x 2-bed unit, 3 x 3-bed units and 1 x 4- bed unit in Block A, and 3 x 2-beds and 1 x 3-bed in Block B. The scheme also omitted a spacious and long balcony serving one of the proposed homes in Block A, given it would already achieve sufficient outdoor space on the other side of the balcony facing onto the site’s courtyard. Thus achieving greater set-backs from the courtyard elevation away from the Peabody Buildings opposite. The difference between Option A and Option B is that the latter presented a further set-back on Block A which fronted Lant Street.

3.3.10 The Council confirmed their preference for Option B, where they agreed in principle to the overall changes:

 The set-back on the northern edge of Block A was supported, as it significantly reduced the impact of the top storeys on the neighbouring Peabody buildings when viewed from Sanctuary Street. This was considered a key view in the conservation area, as stated by the Council.

 The set-backs on the additional storeys shown from the Peabody side / courtyard perspective of Blocks A and B and the view from the Charles Dickens School of Block B demonstrated a more ‘sympathetic

Planning Statement 13

relationship’ to each of these neighbouring buildings. The frame was considered to relate more closely with the accommodation and presented a less dominant structure at the top of the building.

 Option B presents further set-backs to align with the accommodation below, which were considered ‘more desirable’. The recessive character of Option B was a better design approach in the Council’s opinion.

 Further consideration should be given to the glass balconies for the roof top terraces as these may be raised by Building Control, recommendations were made for metal railings as they would be more appropriate for a conservation area.

3.3.11 It was concluded that the Council was satisfied with the proposed changes, including the omission of Block C and the set-backs on Blocks A and B as were shown in Option B.

3.3.12 In summary the Applicant has listened to the comments raised during the application process and has successfully integrated the recommendations within the proposed development. As demonstrated above, the scheme has been amended to create a successful design which will provide for much needed additional homes in the Borough. The details of the scheme will be expanded upon within this Planning Statement.

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4.0 The Application Scheme

4.1 Overview

4.1.1 The proposed development is described as follows:

“Erection of one additional storey on Blocks A and B to create 9 no. residential units, including a new roof terrace and associated waste and cycle storage at basement and ground floor level”

4.2 Detailed Description

4.2.1 The proposed development seeks to make efficient use of the site by retaining the existing building and creating one additional storey in the airspace above Blocks A and B. The additional storey on each of these two blocks will accommodate 9 new homes, comprising 4 x 2-bed homes, 4 x 3-bed homes and 1 x 4-bed home.

4.2.2 Set out below is a schedule of the proposed new homes in further detail:

Block A

Unit no. Beds Area (sqm Private Amenity Child Yield GIA) Space (sqm)

A1 3 87sqm 11sqm 0.42

A2 2 78sqm 11sqm 0.11

A3 4 109sqm 12sqm 0.98

A4 3 89sqm 11sqm 0.42

A5 3 102sqm 13sqm 0.42

- Total: 15 Total: 465sqm Total: 58sqm Total: 2.35

Block A Total (Existing & Proposed) Residential Mix: 32 x 1-bed units (58%), 19 x 2-bed units (35%), 3 x 3- bed unit (5%), and 1 x 4-bed unit (2%).

Block B

Unit no. Beds Area (sqm Private Amenity Child Yield GIA) Space (sqm)

B1 2 77sqm 34sqm 0.11

B2 2 82sqm 10sqm 0.11

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B3 2 82sqm 20sqm 0.11

B4 3 89sqm 13sqm 0.42

- Total: 10 Total: 330sqm Total: 77sqm Total: 0.75

Block B Total (Existing & Proposed) Residential Mix: 17 x 1-bed units (47%), 15 x 2-bed units (42%), 4 x 3- bed units (11%).

4.2.3 As demonstrated above, all of the proposed homes will meet the Nationally Described Space Standards and each home is served by spacious private amenity space to meet the Draft London Plan Standards. Additionally, 151sqm of communal outdoor space is also proposed at roof level of Block B for the use of all residents, including existing residents.

4.2.4 The scheme achieves dual-aspect living in the majority of the proposed homes. However two homes have single- aspect outlook due to site constraints. Both of these homes are south-facing, which will benefit from good levels of sunlight throughout the day, and in addition they have spacious outdoor amenity space to ensure each of these units offer a high standard of living. All homes are served by full-height glazing to maximise natural light.

4.2.5 The existing building is constructed predominantly of red brick, therefore the proposal has sought to adopt contrasting and ‘lightweight’ materials to help breakdown and balance the dominant brickwork. The proposed additional storey on each of the blocks is to be constructed in horizontal bands of light stone cladding.

4.2.6 The existing lift core will be extended to provide level access from the street and lower ground level to the new homes. All proposed homes are to be ‘Accessible and Adaptable’ in accordance with the requirements of Building Regulations Part M4(2).

4.2.7 In accordance with the Draft London Plan Standards, the proposed development includes 18 new long-stay cycle spaces; all of which will be securely provided at lower ground level in the form of 2-tier racks and Sheffield stands. It is also proposed for 1 mobility scooter space with a charging point. Additionally, 2 short-stay cycle spaces will provided for visitors. The proposed development is car-free.

4.2.8 The proposal also includes additional refuse storage for the new residents in the courtyard at ground floor level. In total, this will accommodate 1,463L for general waste and 975L for recycling.

4.2.9 Overall, the proposed scheme seeks to promote sustainability through design and adopt energy-efficient technologies

to help mitigate CO2 emissions on-site. In doing so, the proposal seeks to:

 Retain the existing building and add new floor area in the airspace above, which in-turn helps prolong the lifespan of the building and negates a new cycle of carbon production through the process of demolition of the building for an entirely new building.

 Provide new long-stay and short stay cycle spaces to encourage sustainable travel and healthy lifestyles.

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 Provide a car-free development

 Provide low-carbon technologies to meet the Energy Hierarchy requirements, such as PV panels, and passive and active design measures, i.e. double-glazing.

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5.0 Relevant Planning Policies

5.1 The Adopted Development Framework

5.1.1 The legal framework for determining all planning applications is outlined within the Town and Country Planning Act 1990 (as amended) and the Planning and Compulsory Purchase Act 2004. The application scheme has been designed and assessed against planning policy guidance ranging from National, Strategic and Local policy guidance.

5.1.2 In consideration of this application scheme, the relevant development plan for Southwark Council comprises the following documents;

 Saved Southwark Plan Policies (2007)

 Core Strategy (2011)

 The London Plan (2016)

5.1.3 The New Southwark Plan Proposed Submission Version: Proposed Modifications for Examination (January 2020) was issued to the Secretary of State in January 2020 for their comments. In August 2020, the Council submitted ‘Proposed Changes to the Submitted New Southwark Plan’ and additional information and evidence for consultation following receipt of the Inspector’s initial matters and concerns in April 2020. Therefore, this document and the draft local policies form a material consideration in respect to the application scheme.

5.1.4 The Intend to Publish London Plan (2019) was issued to the Secretary of State in December 2019 for their comments. This version will effectively be the adopted Plan and the policies contained within this Plan will be given significant weight in the determination of planning applications, and will replace those in the current London Plan (2016).

5.2 National Planning Policy Framework (2019)

5.2.1 The National Planning Policy Framework (NPPF) was published in February 2019. At the core of the NPPF is a presumption in favour of achieving sustainable development.

5.2.2 The NPPF outlines the criteria against which development proposals will be considered ‘sustainable’ having regards to three mutually interdependent objectives which planning must consider together; economic, environmental and social. Paragraph 8 of the NPPF states that within the planning system, each role should;

 An economic objective – building a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth and innovation and productivity; and by identifying and coordinating the provision of infrastructure;

 A social objective – supporting strong, vibrant and healthy communities, by ensuring the supply of housing meet the needs of present and future generations; and by creating a high quality built environment, with

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accessible local services that reflect the community’s needs and support its health, social and cultural well- being; and

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

5.2.3 Paragraph 11 states that there is a presumption in favour of sustainable development. For decision-taking this means approving development proposals that accord with the development plan without delay; and where the development plans or policies relevant in determining applications are out-of-date, granting permission unless:

i. The application of policies in the Framework that protect areas or assets of particular importance provides clear reasons for not accepting the development proposed; or

ii. Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or specific policies.

Housing

5.2.4 In terms of housing, Paragraph 59 states that in supporting the Government’s objective of significantly boosting housing supply, it is important that a sufficient amount and variety of land can come forward where it is needed and land that attains permission for housing redevelopment is delivered without unnecessary delay.

5.2.5 Paragraph 62 states that where a need for affordable housing is identified, planning policies should expect it to be met on-site unless:

a. Off-site provision or an appropriate financial contribution in lieu can be robustly justified; and

b. The agreed approach contributes to the objective of creating mixed and balanced communities.

5.2.6 Further to the above, Paragraph 67 on ‘Identifying land for homes’ states that planning policies should identify a sufficient supply and mix of sites, taking into account availability, suitability and likely economic viability.

Making Effective Use of Land

5.2.7 Paragraph 117-118 states that planning policies should promote an effective use of land in meeting the need for homes and other uses. Planning policies should also promote and support the development of under-utilised land and building, especially when such proposals can help meet identified needs for housing. More particularly, under part e) of Paragraph 118, it states that planning policies and decisions should support opportunities to use the airspace above existing residential for new homes through upward extensions.

5.2.8 The NPPF (2019) recognises that Local Planning Authorities should take a proactive role in helping to bring forward land that may be suitable for meeting development needs, and in particular brownfield sites.

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Design

5.2.9 Paragraph 124 and 125 highlight that good design is a key aspect in achieving sustainable development, which in turn helps create better places to live. To support this, local plans should set out a clear design vision, so that applicants may have certainty about what is likely to be acceptable.

5.2.10 Paragraph 127 states that planning policies and decisions should ensure that developments:

 will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development;

 are visually attractive as a result of good architecture, layout and appropriate and effective landscaping;

 are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities);

 establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit.

Heritage

5.2.11 Paragraph 189 stipulates that in determining applications which affect heritage assets, Local Planning Authorities will require proposal’s to detail the significance of surrounding heritage, including any contribution made by their setting.

5.2.12 Applications affecting heritage assets will be determined on the basis of:

a. The desirability of sustaining and enhancing the significance of heritage assets;

b. The positive contribution that conservation of heritage assets can make to sustainable communities;

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

5.2.13 Paragraph 200 states that Local Planning Authorities should look for opportunities for new development within Conservation Areas, to enhance or better reveal their significance. Furthermore, proposals that preserve or enhance the historic setting and also make a positive contribution should be treated favourably.

5.3 The London Plan (2016) and Intend to Publish London Plan (2019)

5.3.1 The current 2016 Plan (The London Plan consolidated with alterations since 2011) remains the adopted Development Plan at the Strategic level. However, following the Examination in Public, the Intend to Publish London Plan has been issued to the Secretary of State for their comments and this version will effectively be the adopted

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Plan and the policies contained within this Plan will be given significant weight in the determination of planning applications, and will replace those in the current London Plan (2016).

5.3.2 The adopted London Plan (2016) policies relevant to the application scheme include:

 Policy 3.3 – Increasing Housing Supply

 Policy 3.5 – Quality and Design of Housing Developments

 Policy 3.6 – Children and Young People’s Play and Informal Recreation

 Policy 3.8 – Housing Choice

 Policy 3.9 – Mixed and Balanced Communities

 Policy 3.10 – Definition of Affordable Housing

 Policy 3.11 – Affordable Housing Targets

 Policy 5.1 – Climate Change Mitigation

 Policy 5.2 – Minimising Carbon Dioxide Emissions

 Policy 5.3 – Sustainable Design and Construction

 Policy 5.7 – Renewable Energy

 Policy 5.12 – Flood Risk Management

 Policy 5.15 – Water Use and Supplies

 Policy 5.16 – Waste net self-sufficiency

 Policy 6.1 – Strategic approach

 Policy 6.9 – Cycling

 Policy 7.2 – An Inclusive Environment

 Policy 7.4 – Local Character

 Policy 7.6 – Architecture

 Policy 7.8 – Heritage Assets and Archaeology

5.3.3 The following policies from the Intend to Publish London Plan (2019) are relevant to the Application Scheme:

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 Policy GG2 – Making the Best Use of Land

 Policy GG4 – Delivering the Homes Londoners Need

 Policy D1 – London’s Form, Character and Capacity for Growth

 Policy D4 – Delivering Good Design

 Policy D5 – Inclusive Design

 Policy D6 – Housing Quality and Standards

 Policy D7 – Accessible Housing

 Policy H1 – Increasing Housing Supply

 Policy H4 – Delivering Affordable Housing

 Policy H5 – Threshold Approach to Applications

 Policy H6 – Affordable Housing Tenure

 Policy H10 – Housing Size Mix

 Policy HC1 – Heritage Conservation and Growth

 Policy S4 – Play and Information Recreation

 Policy SI2 – Minimising Greenhouse Gas Emissions

 Policy SI8 – Waste Capacity

 Policy SI12 – Flood Risk Management

 Policy T1 – Strategic Approach to Transport

 Policy T5 – Cycling

5.3.4 Supplementary Planning Guidance by the Mayor of London is also a material consideration in the determination of the planning application. The relevant guidance is:

 Housing SPG (March 2016)

 Accessible London: Achieving an Inclusive Environment

 Sustainable Design & Construction

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5.4 Southwark Local Plan

5.4.1 The Saved Southwark Policies (2007) and the Core Strategy (2011), set out the borough’s planning policies to guide development in future housing, employment, retail, infrastructure and other land uses over a plan period of 15 years. The Core Strategy also sets out the strategy for Southwark’s places and core policies for development within the borough up until 2026.

5.4.2 The New Southwark Plan Submission Version: Proposed Modifications for Examination (2020) was submitted to the Secretary of State in January 2020. Subsequently in August 2020, the Council submitted ‘Proposed Changes to the Submitted New Southwark Plan’ and additional information and evidence for consultation following receipt of the Inspector’s initial matters and concerns in April 2020. Therefore, this document and the draft local policies will play a material consideration in relation to the Application Scheme.

5.4.3 Those policies deemed relevant in the determination of this application include:

Saved Policies (2007)

 Policy 3.2 – Protection of Amenity

 Policy 3.4 – Energy Efficiency

 Policy 3.7 – Waste Reduction

 Policy 3.11 – Efficient Use of Land

 Policy 3.12 – Quality in Design

 Policy 3.13 – Urban Design

 Policy 3.15 – Conservation of the Historic Environment

 Policy 3.16 – Conservation Areas

 Policy 4.2 – Quality of Residential Accommodation

 Policy 4.3 – Mix of Dwellings

 Policy 5.3 – Walking and Cycling

Core Strategy Policies

 Strategic Policy 5 – Providing New Homes

 Strategic Policy 6 – Homes for People on Different Incomes

 Strategic Policy 7 – Family Homes

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 Strategic Policy 12 – Design and Conservation

 Strategic Policy 13 – High Environmental Standards

New Southwark Plan Policies

 Draft Policy P1 – Social Rented and Intermediate Homes

 Draft Policy P2 – New Family Homes

 Draft Policy P4 – Private Rented Homes

 Draft Policy P1 – Design of Places

 Draft Policy P13 – Design Quality

 Draft Policy P14 – Residential Design

 Draft Policy P17 – Efficient Use of Land

 Draft Policy P19 – Conservation Areas

 Draft Policy P52 – Cycling

 Draft Policy P61 – Reducing Waste

 Draft Policy P67 – Reducing Flood Risk

 Draft Policy P69 – Energy

5.4.4 The following Supplementary Planning Guidance is relevant to the proposed development:

 Southwark Affordable Housing SPD – September 2008

 Southwark Affordable Housing Draft SPD – June 2011

 Residential Design Standards SPD – 2011 and subject to a technical update in March 2015

 Southwark Interim Planning Policy Guidance: Technical Housing Standards – October 2015

 Southwark Development Viability SPD – March 2016

 Section 106 and CIL SPD – 2015, addendum to the SPD – January 2017

 The Liberty of the Mint Conservation Area Appraisal – November 2018

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6.0 Planning Considerations

6.1 Principle of Development

6.1.1 Part 11 of the NPPF (2019) on ‘Making Effective Use of Land’ states that decisions should promote and make as much use from previously-developed or suitable ‘brownfield’ land to meet the identified need for new homes, particularly where land supply is constrained and available sites can be used effectively. Most notably, Part e) of Paragraph 118 states that planning policies and decisions should support opportunities to use the airspace above existing residential for new homes.

6.1.2 The Intend to Publish London Plan (2019) recognises the significance of rooftop development in bringing forward new homes. Draft London Plan Policy GG2 (Making the best use of land) identifies that London’s population is set to grow from 8.9 million today to around 10.8 million by 2041. The policy encourages new development on ‘brownfield’ sites and to explore ways to intensify the use of suitable land to unlock new homes. Draft London Plan Policy GG4 (Delivering the homes Londoners Need) further supports this, and states that housing delivery is not keeping pace with the overall housing need. Therefore, London must look to deliver new homes through every available means, including through the use of brownfield sites.

6.1.3 The efficient use of existing land is further resonated at the local policy level. Southwark’s Saved Policy 3.11 (Efficient Use of Land) and Draft Policy P17 (Efficient Use of Land) stipulate that all development proposals should ensure that they maximise the use of land, whilst considering other factors, such as:

 Protecting the amenity of neighbouring occupiers

 Ensuring a satisfactory standard of accommodation and amenity for future occupiers of the site

 Positively responding to local context

 Ensuring the scale of development is appropriate to the availability of public transport

6.1.4 A Cabinet Report was published in September 2019 by ‘Southwark’s Social Regeneration, Great Estates and New Council Homes. The report titled “New Council Homes rooftop development principles and programme update” recognises there is an acute housing need for Southwark residents, and it is in the Council’s interest to tackle the housing crisis and address the potential for upward extensions on existing blocks.

6.1.5 This report is focused on council homes, however the importance of reviewing roof top development as a contributor to new housing for the future is considered favourably throughout the report. It highlights that there is potential for thousands of new homes in the borough to be delivered ‘through upward extensions on blocks that are well configured and within their life cycle’.

6.1.6 In consideration of the above policies and the recently published Cabinet Report, this application scheme brings forward the opportunity to deliver new homes by effectively using the airspace above the existing residential blocks, without the need of additional land. It is therefore considered that by making full use of this brownfield site that the

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application scheme is in compliance with the NPPF (2019), draft London Plan Policies GG2 and GG4, and Southwark’s Saved Policy 3.11 and Draft Policy P17.

6.1.7 Since the submission of the withdrawn application the Government has introduced new permitted development rights for additional roof storeys on modern apartment buildings (and dwellinghouse and mixed use schemes). Whilst these permitted Development Rights do not apply to the application site as it lies within a Conservation Area the principle for securing additional homes through building new build accommodation on top of existing properties is fully established and strongly supported at a national level.

6.2 New Housing

6.2.1 Paragraph 59 of the NPPF (2019) on ‘Delivering a Sufficient Supply of Homes’ states that it is important that a variety of land can come forwarded where needed in order to support the Government’s objective of significantly boosting the supply of new homes.

6.2.2 The current London Plan Policy 3.3 (Increasing Housing Supply) states that Southwark’s current annual housing target is 2,736, however the Intend to Publish London Plan Policy H1 (Increasing Housing Supply) identifies a ten- year housing target of 23,550 to match the recommendations of the Inspector’s Panel Report and Panel Recommendations (Published October 2019).

6.2.3 The fifteenth Annual Monitoring Report (AMR) was published by the Mayor of London in October 2019. It highlights that Southwark’s total net conventional homes completions between 2017/18 was 818 against the current London Plan target of 2,736 net additional homes. Of this figure, 7 were non-conventional homes and 638 homes were recorded as long-term vacant, which indicates a total of 173 homes successfully delivered between 2017/18. This equates to only 6% against the London Plan housing target for Southwark; which shows a significant shortfall.

6.2.4 Southwark’s current Strategic Policy 5 (Providing New Homes) highlights that 1,900 net new homes will be delivered solely in Bankside, Borough and London Bridge Opportunity Area to meet housing needs. For Southwark’s housing targets overall, the draft New Southwark Plan (Proposed Submission Version) states there should be enough sites to build at least 2,736 new homes to match annual housing targets set out under the current London Plan.

6.2.5 In consideration of the housing targets above and the undersupply of homes from 2017/18, it is considered that Southwark will require a significant amount of new homes. Given the constraints in development in differing parts of the borough and especially in Bankside, Borough and London Bridge Opportunity Area, the effective use of rooftop space for more housing should be encouraged and supported.

6.2.6 The creation of 9 new homes within this application scheme shall help meet the borough’s housing targets and thereto, make efficient use of the existing site through an upward extension. Therefore, the application scheme is fully compliant with the NPPF (2019), London Plan Policy 3.3, Intend to Publish London Plan Policy H1, and Southwark’s Strategic Policy 5.

6.3 Affordable Housing

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6.3.1 Affordable housing is considered to be social-rented, affordable-rented and intermediate housing under current London Plan Policies 3.10 (Definition of Affordable Housing) and 3.11 (Affordable Housing Targets); 60% of affordable housing provision should be made for social and affordable rent, and 40% for intermediate rent or sale. However, the Intend to Publish London Plan Policies H4 (Delivering Affordable Housing), H5 (Threshold Approach to Applications), and H6 (Affordable Housing Tenure) sets the threshold level at 35% for affordable housing provision for schemes which introduce 10 or more new homes.

6.3.2 The NPPF states in paragraph 63 that provision of affordable housing should not be sought for residential developments that are not major developments. The application scheme is not a major scheme. This is also mirrored at Local Policy level, under Strategic Policy 6 and Saved Policy 4.4 on affordable housing.

6.3.3 Southwark’s emerging Draft Policy P1 states that:

‘development that creates 9 homes or less must provide the maximum amount of social rented and intermediate homes or a financial contribution towards the delivery of new council social rented and intermediate homes with a minimum of 35% subject to viability.’

6.3.4 In accordance with the NPPF, Policy 4.4 of the Southwark Plan, Policy 6 of the Core Strategy and London Plan policies 3.10 to 3.12, no on site contributions or off site contributions should be sought. Notwithstanding that affordable housing is not required; this application is accompanied by a Viability Assessment to assess the economic viability in accordance with the Council’s Viability SPD and draft Policy P1.

6.4 Unit Mix

6.4.1 The current London Plan Policy 3.5 (Quality and design of housing developments) highlights that the design of all new housing developments should aim to enhance the quality of local places, taking into consideration local character, density and tenure among other factors. Essentially, the London Plan encourages a balanced mix of tenures across all boroughs to create more socially inclusive environments (London Plan Policy 3.9).

6.4.2 Intend to Publish London Plan Policy H10 (Housing Size Mix) and Southwark’s Saved Local Policy 4.3 (Mix of Dwellings) stipulate that higher proportion of one and two bed units are acceptable within central and urban locations. Whilst Southwark’s Strategic Policy 7 (Family Homes) supports three or more bed units within the London Bridge Opportunity Area, particularly for major residential developments.

6.4.3 The New Southwark Plan Draft Policy P2 (New Family Homes) is applicable to major residential developments (i.e. proposals for 10 dwellings or more) and categorises the percentage of 3 bed+ homes depending on three separate locations; Central Zone and Action Area cores, Urban Zone, and Suburban Zone. The application site is located within the CAZ where a minimum of 20% of homes with three or more bedrooms are sought. Although the application is a minor scheme and Draft Policy P2 is not applicable, the application scheme will offer an appropriate housing mix of 4 x 2-beds, 4 x 3-beds and 1 x 4-bed unit. Of which, the total proposed family homes equates to 55.5%. This is considered to be an appropriate mix for this location and offers an opportunity for more families to live in this desired central location.

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6.4.4 The application scheme makes effective use of a brownfield site to create 9 new homes with a variety of unit mixes, including family homes. The overall housing mix is appropriate for this central location and is in accordance with London Plan Policy 3.5 and Intend to Publish Policy H10, including Southwark’s Saved Policy 4.3, Strategic Policy 7 and Draft Policy P2.

6.5 Heritage

6.5.1 Under Paragraphs 192 – 193 of the NPPF (2019), Local Planning Authorities are expected to consider the impact of development on the significance of their heritage assets, and any potential harm is outweighed by the public benefits. In this circumstance, the application scheme is considered to create no harm.

6.5.2 The adopted London Plan Policy 7.8 (Heritage Assets) and the Intend to Publish London Plan Policy HC1 (Heritage Conservation and Growth) emphasise that development proposals should demonstrate a clear understanding of the historic environment and heritage values, and their relationship to their surroundings. Primarily, proposals should continue to conserve and enhance the historic environment.

6.5.3 Southwark’s Strategic Policy 12 (Design and Conservation) and Saved Policies 3.15 (Conservation of the Historic Environment) and 3.16 (Conservation Areas), including draft Local Policy P19 (Conservation Areas) mirror the strategic policies above. The Liberty of The Mint Conservation Area Appraisal (2018) provides an overview of Lant Street/Weller Street/Mint Street:

‘Lant Street runs east/west through the centre of the conservation area. Its width suggest a once grand street, with the school and buildings at the corner of Borough High Street forming part of the wider historic network. The demolition of the Georgian terraces fronting the in the post WWII era give clues to the former hierarchical placement of the street; however to-day this has been somewhat lost. The central part of Lant Street from Bittern Street to Sanctuary Street is disconnected, partially by the use of the former route as a playground for the school, but also the 20th century re-development of Lantern House, Trundle House, Isaac Way and the Rise building. These have done little to assist in reinstating continuity within the townscape.’

6.5.4 This part of the Liberty of the Mint Conservation Area has undergone significant redevelopment over the years, and thereto has introduced a wide range of building typologies and heights. To demonstrate a clear understanding of the surrounding historic environment, the Applicant has submitted a Heritage Statement, which has been prepared by Heritage Collective.

6.5.5 The Heritage Statement shows views looking west from Borough High Street towards Sanctuary Street and Lant Street, and highlights:

The three buildings on the application site are located to the rear of the Douglas Buildings …but are not visible from Marshalsea Road or Mint Street. They only come into view when passing through the main covered entrance into the open courtyard at the rear. They form a neutral element, at best, within the setting of the Douglas Buildings, occupying the site of a former cart and wheel works which probably had a similar impact on their setting.

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6.5.6 The Heritage Statement concludes that the application scheme would result in a minor change to the overall appearance, but there would be no harm and it continues to enhance The Liberty of the Mint Conservation Area. Following further design amendments to the scheme from the previously withdrawn application, it is considered that the proposed single-storey extension above Blocks A and B have achieved a more sympathetic design with the surrounding building heights, which are known to be varied. The choice of contemporary materials will make a positive contribution to the overall appearance of the existing site, which is considered to be a ‘neutral element, at best, within the setting’. The contrasting materials provide an excellent opportunity to help lift the building’s heavy brickwork appearance and should be read as a later addition to the building that would make only an ‘incremental’ change to the surrounding conservation area, as highlighted in the support Heritage Statement.

6.5.7 In summary it is considered that the application scheme will not harm the significance of the heritage asset and will preserve the character and appearance of the conservation area, in accordance with the NPPF (2019), London Plan Policy 7.8 and Intend to Publish London Plan Policy HC1, including Southwark’s saved Policies 3.15 and 3.16, Strategic Policy 12, and draft Policy P19.

6.6 Design Considerations

Exemplary Design

6.6.1 Further to discussions with the Council at the pre-application stage, officers considered that the creation of new residential units across all three existing residential blocks was acceptable in principle, but the scheme must sensitively consider its design within this historic location.

6.6.2 Paragraph 124 and 127 of the NPPF (2019) on ‘Achieving Well-Designed Places’ states that good design plays a key role in creating better places to live and embodies sustainable development. The NPPF further highlights that early discussions between applicants, the local planning authority and the community about the design of the scheme is essential to engage views and expectations, and in turn effectively evolves the design scheme.

6.6.3 The current London Plan Policy 7.6 (Architecture) states that architectural design should make a positive contribution to the wider cityscape and should incorporate the highest quality materials appropriate the site’s context. The Intend to Publish London Plan Policy D1 (London’s Form, Character and Capacity for Growth) mirrors the current London Plan, and further states that there should be a focus on detail and practicality of use through the use of attractive and robust materials.

6.6.4 Further to the above, Southwark’s saved policies 3.12 (Quality in Design) and 3.13 (Urban Design), and draft Local Policy P13 (Design Quality) highlight that development must provide a high-quality design which responds positively to the local context by using durable and quality materials.

6.6.5 The application scheme utilises sustainable materials which provide a contemporary addition, with a simple material palette that will help create a subservient character to the proposed extension. The application scheme accords with the above policies by providing the following:

 Dual and triple-aspect living accommodation in the majority of the homes

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 Each unit has private outdoor amenity space via balconies

 All habitable rooms are provided with natural light, ventilation and outlook

 Provision of high-quality materials

 Large glazing to maximise on natural light

 All units have bedroom and living room floor-to-ceiling heights of 2.5m

6.6.6 The final design is distinctive and high quality. It has been designed to be sympathetic within this historic part of the Borough, and will continue to enhance The Liberty of the Mint Conservation Area. The applicant has successfully engaged in early discussions with the Council through pre-application advice and via subsequent meetings in association with the previously withdrawn application. The application scheme’s design has, as a result, been discussed and developed further to create a sustainable and high-quality design, in accordance with the NPPF (2019), London Plan Policy 7.6, and Intend to Publish Policy D1, including Southwark’s saved Policy 3.12, 3.13, and draft Policy P13.

Density

6.6.7 In consideration of the above design particulars, Paragraphs 122 - 123 of the NPPF (2019) on ‘Achieving Appropriate Densities’ states planning policies and decision should support development which makes efficient use of land and policies should encourage optimal use of sites that can potentially deliver higher densities. In such circumstances, optimising the use of land to meet identified need for new housing will be tested robustly at examination, and should include the use of minimum density standards for city and town centres, including other locations that are well served by public transport. These standards should seek a significant uplift in the average density of residential development within these areas.

6.6.8 London Plan Policy 3.4 (Optimising Housing Potential) outlines that development should optimise housing within the relevant density range. The site is identified as being within a ‘Central’ location (in Table 2 of the London Plan 2016), and has a PTAL of 6b; the density target is between 650 -1,100 habitable rooms per hectare.

6.6.9 The site area measures 0.26ha, and the existing and proposed habitable rooms as part of this application scheme will be 230. This calculates to 885 habitable rooms per hectare, which is within the targeted density range as outlined above. The application scheme is considered to make full use of the existing buildings on the site to deliver much needed housing for the borough and provides a high-quality design which complies with the NPPF, and both the London Plan and Southwark’s Local Plan on housing delivery and design standards.

6.6.10 The Intend to Publish London Plan (2019) follows a design-led approach to optimise site capacity. Draft Policy D3 ‘Optimising site capacity through design-led approach’ states all development must make the best use of land by following a design-led approach, taking into consideration the site’s context. Development proposals are expected to respond positively to the local area in terms of appearance, layout and scale with regard to the surrounding building forms and proportions. It is also encouraged that new proposals should facilitate active travel with convenient cycle parking and legible entrances, among other factors such as delivering appropriate outlook, privacy and amenity.

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6.6.11 It is considered that the application scheme optimising as much of the site as possible through an upward extension. The proposed single storey extension across each of the three blocks is within an appropriate height range for the local context, where higher elements exist within close proximity to the site.

Inclusivity

6.6.12 The current London Plan Policies 3.5 (Quality and design of housing developments), 3.8 (Housing Choice) and 7.2 (An inclusive environment) state that housing developments should be of the highest quality and be inclusive to all with no disabling barriers, to meet Building Regulations Part M4(2).

6.6.13 Intend to Publish London Plan Policies D4 (Delivering Good Design) and D5 (Inclusive Design) mirror the above policy, ensuring that all new developments are designed to meet diverse needs and can be used with dignity by all.

6.6.14 Southwark’s Strategic Policy 12 (Design and Conservation) and Saved Local Policies 3.12 (Quality in Design) and 3.13 (Urban Design) highlight that development should aim to achieve high quality design. Proposals should also consider inclusive design measures to ensure there is suitable access for mobility-impaired users. Draft Local Policies P11 (Design of Places) and P13 (Design Quality) echo these design requirements.

6.6.15 This application scheme has carefully considered inclusivity within its design, and all dwellings are designed to be wheelchair accessible and adaptable, in compliance with the London Plan, and Building Regulations Part M4(2) ‘Accessible and adaptable dwellings’.

6.7 External Amenity & Play Space

6.7.1 London Plan (2016) Policy 3.6 on ‘Children and Young People’s Play and Informal Recreation’ states that development proposals which include housing are expected to make provision for play and informal recreation, based on the expected child population. The Intend to Publish London Plan Policy S4 ‘Play and Informal Recreation’ further iterates this requirement, and stipulates that at least 10sqm of playspace should be provided per child, which provide a stimulating environment and are safely and easily accessible.

6.7.2 Whilst the requirements of each of these policies are noted, the application scheme is only able to work within the parameters of the existing site, given it is rooftop development. The application scheme maximises private amenity spaces by including spacious balconies to ensure there is sufficient outdoor space. Additionally, new families with children can make use of the existing communal spaces located at ground floor level, and Mint Street Park which offers play space and is only a short walking distance from the Application Site (less than 5 minutes).

6.7.3 Given the application scheme comprises a rooftop development on brownfield land, London Plan Policies 3.6 and Draft Policy S4 would not be wholly applicable. However, the Applicant has carefully considered the inclusion of private amenity space and the following policies below are relevant to the application scheme.

6.7.4 Intend to Publish London Plan Policy D6 (Housing Quality and Standards) outlines that new development should aim to maximise the provision of dual aspect living accommodation, and provide a minimum of 5sqm of private outdoor amenity space for 1-2 person units. An additional 1sqm should be provided for each additional occupant.

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6.7.5 At the local level, residential development will be considered favourably where they achieve good quality of living conditions, namely a suitable amount of outdoor space with adequate privacy and outlook (Southwark’s Saved Policy 4.2 - Quality of Residential Accommodation & draft policy P13 – Residential Design).

6.7.6 Southwark’s Residential Design Standards (2015) sets out the standard of design expected from residential development in Southwark to meet housing need. In this document it is stipulated that all new developments must provide adequate and usable outdoor amenity space, including a mixture of both private and communal spaces. For flatted development containing three bedrooms or more, 10sqm of private amenity space would be required. For two bedrooms or less, 10sqm of private amenity space is recommended however it is recognised that where this is not possible, as much space as possible should be provided. In particular, for balconies/terraces/roof gardens there must be a minimum of 3sqm to count towards private amenity space.

6.7.7 The proposed residential units have been designed to include individual private balcony spaces to ensure there is appropriate external amenity space for all occupiers. The proposed balcony’s range in size per unit, and sufficiently provide the minimum requirements. The proposed roof terrace on Block B also provides 151sqm. Please refer to the table in Section 3 of this Planning Statement for further details. The outdoor amenity standards of the proposed residential units meet the London Plan, Housing SPG requirements and Southwark’s Residential Design Standards (2015).

6.7.8 In addition to the private balconies and roof terraces, the site has 306sqm of existing soft landscaping at the ground floor level which provides additional green spaces for all residents. The site is also within a few minutes’ walk from Mint Street Adventure Playground, which offers high-quality child’s play spaces and allotment areas for children to grow their own plants and herbs. There are also large green spaces for leisure and an outdoor urban gym. Therefore, the site and surrounding area provides adequate external amenity spaces and communal spaces for families with children.

6.7.9 The application scheme provides 134sqm of private amenity space (i.e. via the balconies), and 740sqm of existing communal space at ground floor level, and 151sqm of new rooftop terrace space on Block B, which equates to an overall total of 1,025sqm of amenity space, which is wholly in accordance with the draft London Plan Policy D6, Southwark’s Saved Policy 4.2 and draft Policy P13.

6.8 Daylight, Sunlight and Overshadowing

6.8.1 The draft New London Plan highlights that the design of development should create sufficient daylight and sunlight for new residential units, taking into consideration minimum ceiling heights, design of individual layouts and dual aspect living (Intend to Publish London Plan Policy D6 – Housing quality and standards).

6.8.2 Southwark’s Saved Policy 4.2 (Quality of Residential Accommodation) and draft Local Policy P13 (Design Quality) highlight that new residential development will be considered favourably where they provide sufficient natural daylight, sunlight and outlook for the existing occupiers and neighbouring residents.

6.8.3 To demonstrate the application scheme’s design is acceptable in terms of daylight and sunlight, this application is accompanied by a Daylight and Sunlight Report.

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6.8.4 The Daylight and Sunlight Report has assessed the impact of the application scheme on neighbouring dwellings that are considered to have the potential to experience a change to their existing daylight and sunlight amenity. This includes the existing residents in Blocks A and B and adjoining neighbouring properties within close vicinity to the application site.

6.8.5 Following the previously withdrawn scheme (ref. 20/AP/1272), the application scheme has again been reduced in height and the previously proposed additional floor to Block C have been omitted from the scheme entirely.

6.8.6 As highlighted in the submitted daylight report for application ref. 20/AP/1272, the following neighbouring buildings are unaffected

 1 to 128 Douglas Buildings: All windows pass the VSC and Daylight distribution test. All but three windows pass the sunlight ASPH test. The three exceptions are ground floor windows that will see a reduction in excess of 20%; however they all retain a winter sunlight value of 4%, which is still considered good in the context of an inner-city environment.

 11 Marshalsea Road: All windows pass the VSC and Daylight distribution test. All but two windows pass the sunlight ASPH test. Two windows will see a noticeable reduction in annual sunlight, however they are located within the north-west facing elevation and therefore do not have a reasonable expectation of receiving the BRE guideline values. In additional, these serve a room with multiple windows, two of which retain excellent sunlight values, far in excess of the guidelines and therefore the room will remain very well sunlit.

 52-56 Lant Street: All windows pass the VSC and all but two meet the daylight distribution test. The remaining two rooms at third floor are only marginally above the 20% guidelines, with reductions of 22.40% and 24.74%. Also, these rooms retain daylit room areas of 69% and 71%, which should considered very good in context and exceed the current values enjoyed at lower floors. All windows pass the sunlight ASPH test.

 1-9 Trundle House: As Block C has been removed from the scheme there will be no impact on this property.

6.8.7 In regard to the effects on the existing windows within Blocks A, B and C the following effects are identified:

 Block A: All windows pass the VSC and all but one window meet the daylight distribution test. The one window relates to a bedroom located at third floor. This will retain 0.76 of its former value and daylight to 75% of the room.

 Block B: The VSC assessment results confirm that the majority of the windows will either experience reductions of existing VSC that are unlikely to be noticeable by virtue of retain 0.8 of their former value or retain in excess of the default BRE recommendation of at least 27% VSC. The remaining six windows will experience daylight reductions ranging between 21% and 28%, however as the existing values are low, small reductions result in disproportionate percentage change and these reductions are considered acceptable in the context of an urban environment. For daylight distribution 61 or 68 windows pass the test and the other seven windows the reductions range from 20.21% to 43.93%, however the rooms in question

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retain daylight to approximately 50% of the room area or greater, which is often considered acceptable in an urban location. For sunlight there are some reductions 17 will satisfy the annual sunlight guidelines of 25% or 0.8 of their former value. However, due to orientation, the majority of the remaining windows have low existing values, such that they see a disproportionate percentage change. It should also that some of these windows serve rooms that are lit by multiple windows and therefore which enjoy the benefit the cumulative sunlight from each.

 Block C: All windows pass the VSC and Daylight distribution test. For sunlight 11 windows assessed, 9 will satisfy the annual sunlight guidelines of 25% or 0.8 of their former value. One of remaining window will see a reduction of 21.74%, only marginally above the 20% guideline. The final window at ground floor has a low existing value, such that although there will be a 50% reduction, this only equates to 3% APSH and will therefore unlikely to be noticeable.

6.8.8 The Daylight and Sunlight assessment confirms that the vast majority of windows and rooms to existing and neighbouring residential properties will not experience a noticeable reduction in daylight and sunlight in accordance with BRE Guidelines. The Report concludes:

“…the proposed works adhere to the general principle of to the BRE guidelines in respect of sunlight and daylight to the existing receptors. In our opinion the London Borough of Southwark’s planning policy on daylight and sunlight will be satisfied.”

6.8.9 The application scheme is within a central London (CAZ) location and as an inner London location the levels of daylight expected would be commensurate with this context.

6.8.10 As demonstrated by the findings in the Report, the application scheme will satisfy the Council’s Saved Policy 4.2 and Draft Policies P13 and P14 in regards to daylight and sunlight levels. On the basis of these results, the application scheme should be considered acceptable.

Amenity

6.8.11 Southwark Saved Policy 3.2 (Protection of Amenity) stipulates that all new developments must protect the amenity of an area and the quality of life for people living in the borough, particularly from noise disturbance. Therefore, as part of this application, a Construction Environment Management Plan (CEMP) has been prepared to outline proposed hours of work. Specifically, the report outlines that works will take place during standard hours of work during the day and no undertaking of noisy works shall take place on Sundays, Bank Holidays and Public Holidays. These prescribed work hours will be agreed with Southwark Council.

6.9 Transport

6.9.1 The current London Plan Policy 6.1 (Strategic approach) and the Intend to Publish London Plan Policy T1 (Strategic approach to transport) stipulate that development proposals should help to reduce Londoner’s dependency on cars and alternatively choose walking, cycling and public transport. In light of this, the current London Plan Policy 6.9

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(Cycling), including the Intend to Publish London Plan Policy T5 (Cycling) and Southwark’s Saved Policy 5.3 (Walking and Cycling) and Draft Policy P52 (Cycling) encourage development proposals to secure provision for cycle parking.

6.9.2 By recognising the benefits of cycling on health and wellbeing, the application scheme offers a car-free development and includes 18 new long-stay cycle parking spaces within the basement level where there are already existing provisions for residential occupants, and 2 short-stay spaces for visitors.

6.9.3 A Transport Statement has been prepared by Caneparo Associates in support of this application. The report concludes that the proposed residential units are acceptable in transport and highways terms and the number of cycle spaces proposed is in accordance with the Intend to Publish New London Plan standards.

6.10 Refuse

6.10.1 The current site has existing bin stores in each of the three residential blocks. For Block A, the existing refuse stores are located within the entrance walkway from Sanctuary Street. Refuse stores for Block B are currently located within the existing courtyard and for Block C; the refuse stores are located within the access way from Weller Street.

6.10.2 The application scheme comprises additional associated refuse storage for the proposed new homes. Therefore, we address both the strategic and local policy guidance below to calculate the refuse required as part of the scheme.

6.10.3 The current London Plan Policy 5.16 (Waste Net Self-Sufficiency) and Intend to Publish London Plan Policy SI8 (Waste Capacity) present measures to manage London’s waste which includes minimising waste, encouraging the reuse of and reduction in the use of materials, exceeding recycling/composting levels, among more. As such development proposals should aim to deliver sustainable and robust materials, and find sensible ways to contribute towards renewable energy generation.

6.10.4 Southwark’s saved Local Policy 3.7 (Waste Reduction) and draft Policy P61 (Reducing Waste) highlight that development proposals should provide adequate provision for recycling, composting and waste disposal, collection and storage facilities on-site. Southwark’s Waste Management Guidance Notes on Residential Developments (2014) outlines the waste requirements, in line with the British Standard (BS5906 Waste Management in Buildings), as the following:

 Total weekly refuse (L) = 30L per unit + 70L per bedroom

 Recycling provision (L) = Total weekly refuse (L) x 0.5

 Residual waste provision (L) = Total weekly refuse (L) x 0.75

6.10.5 The application scheme comprises 9 new residential homes with a mix of tenures. Therefore the refuse provision has been calculated on the basis of the above requirements and will provide 1,463L refuse and 975L recycling for Blocks A and B. These are to be located within a dedicated area in the courtyard at ground floor level. The application scheme’s refuse and recycling provision shall therefore be compliant with policy on waste requirements.

6.10.6 For further details of the waste provision, please refer to the Design and Access Statement.

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6.10.7 In addition to the above, Southwark’s draft Policy P61 further states that development proposals must demonstrate how the waste management hierarchy will be applied during construction. This application scheme is accompanied by a Construction Environmental Management Plan by Ridge & Partners, which demonstrates how waste management will be treated in relation to the hierarchy:

i. Avoid creating waste; then

ii. Reduce the amount of waste produced; then

iii. Prepare waste materials for re-use; then

iv. Recycle and compost waste materials; then

v. Recover energy from waste materials; then

vi. Dispose waste materials in landfill; and

Provide adequate recycling, composting and waste disposal, collection and storage facilities on-site; or

Provide a suitable off-site waste management strategy that does not adversely impact amenity, access or the environment where on-site waste management provision is not possible.

6.11 Energy and Sustainability

6.11.1 The current London Plan Policies 5.1 – 5.7 (Climate Change Mitigation), and 5.15 (Water Use and Supplies) and Intend to Publish London Plan Policy SI2 (Minimising greenhouse gas emissions) emphasise that the mayor seeks to achieve an overall reduction in London’s carbon dioxide emissions. To achieve this, development proposals should follow the energy hierarchy of ‘Be lean, Be clean, Be green’.

6.11.2 The Draft Local Plan promotes environmentally sustainable design, including energy efficient measures such as heating, cooling, water efficiency, sustainable materials and sustainable operation. The Plan seeks to promote zero- carbon development by requiring all developments to demonstrate that on-site carbon dioxide emissions are mitigated by utilising less energy and integrate best practice sustainable design standards.

6.11.3 The proposed development comprises the following energy-efficient measures:

 Passive and active design measures (via double-glazing, internal curtains / blinds, and external spaces)

 Installation of PV Panels across the development

6.11.4 It is therefore considered that the proposed measures for reducing CO2 emissions as part this development shall meet the minimum requirements for energy efficiency, as set out under the strategic and local policies above.

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6.12 Flood Risk

6.12.1 The current London Plan Policy 5.12 (Flood Risk Management), Intend to Publish London Plan Policy SI12 (Flood Risk Management) and Southwark’s draft Policy P67 (Reducing Flood Risk) state that development proposals in general should ensure that flood risk is minimised and mitigated both on and off-site.

6.12.2 The site is located in Flood Zone 3, which is classified as having an annual probability of flooding greater than 1 in 100, but benefits from The Thames Barrier flood defence. This ensures that the site is protected from flooding caused by tidal surges in the River Thames. Aside from the Thames, there are no other watercourses that may pose a potential risk of flooding to properties within the borough.

6.12.3 Given the application scheme comprises an additional storey above Blocks A and B only and no below-ground works will be required, it is considered that the development will not give rise to an increased risk of flooding and the proposed homes will not be at risk if a flood event were to occur.

6.13 Planning Obligations and Community Infrastructure Levy (CIL) / Draft Heads of Terms

6.13.1 The applicant is willing to enter into a legal agreement with the London Borough of Southwark to cover any relevant Planning Obligations, and will seek to agree the wording of the agreement during the course of this application. It is considered a legal agreement pursuant to Section 106 of the Town and Country Planning Act 1990 is the most appropriate agreement in this instance.

6.13.2 The agreement is likely to include details relating to the management of elements of the application scheme. The contributions and obligations are likely to include the following:

- Transport matters pertinent to the application scheme

- Car-free Restriction

- Carbon offsetting contribution

6.11.3 Planning obligations assist in mitigating the impact of unacceptable development to make it acceptable in planning terms. Planning obligations may only constitute a reason for granting planning permission if they meet the statutory tests as set out under Regulation 122 contained within the Community Infrastructure Levy Regulations 2010.

6.13.3 The Application Scheme is also subject to the Community Infrastructure Levy (CIL). The site is located within Zone 2 of Southwark’s CIL charging schedule (December 2017). Southwark’s CIL charging schedule states that Class C3 (residential) development within ‘Zone 2’ will be charged at a rate of £218 per sqm. The Mayor’s MCIL2 Charging Schedule rates for Southwark (Band 2) will be charged at a rate of £60 per sqm. This CIL is payable to both the Council and the Mayor. CIL payments will assist in the delivery of infrastructure, transport, health and education facilities within the Borough.

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7.0 Conclusion & Planning Balance

7.1.1 The application scheme seeks planning permission for the for the erection of one additional storey on Blocks A and B to create 9 new residential homes, in addition to a new rooftop terrace and associated waste and cycle storage.

7.1.2 On balance, the proposed development will make efficient use of the airspace above this brownfield site, which sits within an accessible location in the London Borough of Southwark; providing high-quality residential homes.

7.1.3 The proposed development of this site has evolved through pre-application consultation with Southwark Council, the public and stakeholders, and a previously withdrawn application (20/AP/1272) whereby the Applicant and Council engaged in further discussions to help amend the scheme. In light of this, the design has been further developed to accord with the earlier advice and recommendations received. The application scheme is considered to be consistent with the relevant planning policies set out under the London Plan, the current and emerging development framework for Southwark Council and is in accordance with the aims outlined in the National Planning Policy Framework (NPPF).

7.1.4 The application site is located within the Liberty of the Mint Conservation Area, which is considered to be an area of special architectural and historic interest that the Council seek to preserve and enhance. The application scheme will create a minor change to the appearance of the Conservation Area but will overall preserve and enhance its special significance for the following key reasons:

 There is no expansion to the footprint of the application site as it comprises an upward extension.

 The additional storey on Blocks A and B will be slightly above the recommended height for the conservation area but in a way that would be incremental rather than overly prominent.

 The architectural changes and fragmentation on Lant Street and surrounding streets have altered the character of the Conservation Area, therefore the impact of the additional storey on Blocks A and B is considered to be minor.

 The existing blocks are recognised to be a neutral element within the conservation area, therefore the additional height will add visual interest to the site and break-up the heavy brickwork appearance.

7.1.5 The Council currently has a target of 1,900 new homes solely in Bankside, Borough and London Bridge Opportunity Area, and 2,736 new homes borough-wide under the New Southwark Plan. The proposed development will positively contribute towards the above housing targets, and in particular family homes.

7.1.6 The application scheme has been designed to respect the local historic context in terms of scale and massing, following earlier pre-application advice and in compliance with heritage policies, particularly the NPPF (2019), London Plan Policy 7.8 and Intend to Publish London Plan Policy HC1, including Southwark’s saved Policies 3.15 and 3.16, Strategic Policy 13, and draft Policy P19.

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7.1.7 The proposed design will be of a high-quality and will meet high standards of sustainability in accordance with design policies; NPPF (2019), London Plan Policy 7.6, and Intend to Publish Policy D1, including Southwark’s saved Policy 3.12, 3.13, and draft Policy P14.

7.1.8 Additionally, the application scheme has been designed so that the height of the single storey extension is subservient in appearance to the host building of Blocks A and B, and so that it is within an appropriate height in light of the wider conservation area. The Applicant has submitted a supporting Daylight and Sunlight Assessment which confirms that a vast majority of windows and rooms to existing and neighbouring residential properties will not experience a noticeable reduction in daylight and sunlight in accordance with BRE Guidelines and will satisfy the Council’s Saved Policy 4.2 and Draft Policies P13 and P14.

7.1.9 Overall, the application scheme is wholly in accordance with the current London Plan (2016) and Intend to Publish London Plan (2019), including Southwark’s current local plan and Draft New Southwark Plan.

7.1.10 In accordance with Section 38(6) of the Planning and Compulsory Purchase Act (2004) applications should be determined in line with the development plan unless there are material planning considerations to indicate otherwise. The application for the redevelopment of Blocks A and B is fully in line with the development plan and planning permission should be granted.

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