planning report GLA/2259a/01 20 May 2019 Sun Wharf, Creekside, in the Borough of

planning application no. DC/18/110290

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

The proposal Redevelopment to provide three new buildings ranging in height up to 17 storeys to provide 233 residential units and approximately 1,363sqm commercial floorspace (B1/B2 Use Class), 254sqm flexible commercial floorspace (B1/B2/A3) and associated works.

The applicant The applicant is Bellway Homes Ltd and Peabody Homes Ltd, the architect is Stockwool.

Strategic issues Principle of development: High density residential led mixed use development in an opportunity area supported. The applicant and Council must explore opportunities to increase employment floorspace. Further detail must be submitted to justify the proposed co-location of residential with industrial uses. (paragraphs 14-21)

Affordable housing: The development proposes 35% affordable housing by habitable room with a 60:40 split between LAR and shared ownership. As this is an industrial site, the fast track threshold is 50% affordable housing and would therefore subject to the Viability Tested Route. GLA officers are currently in the process of reviewing the submitted viability assessment in order to ensure that the maximum level of affordable housing is achieved. (paragraphs 22-28)

Urban design: Confirmation of extent of public realm; increase active frontage along the Creek edge; daylight/sunlight impact on Kent Wharf and inward facing proposed units should be addressed in full; enhance walking route to the station along Creekside; the identified protected vista extension views should be assessed within the TVIA; and façade details required. (paragraphs 34-44)

Transport: A revised TA is required; cycle parking redesigned in accordance with LCDS standards; residents prevented from applying for parking permits in the event of a CPZ being introduced; disabled parking incorporated for the commercial uses; and revised draft servicing, construction logistics and travel plans are required. (paragraphs 45-59)

Outstanding issues relating to play space, inclusive design, energy and drainage would also need to be addressed.

Recommendation That Lewisham Council be advised that the application does not yet comply with the London Plan, for the reasons set out in paragraph 63 of this report; but that the possible remedies set out in that paragraph could address these deficiencies.

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Context

1 On 5 March 2019, the Mayor of London received documents from Lewisham Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008, the Mayor has to provide the Council with a statement setting out whether he considers that the application complies with the London plan and the reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 1A, 1B and 1C of the Schedule to the 2008 Order: • 1A – “Development which comprises or includes the provision of more than 150 houses, flats or houses and flats.” • 1B – “Development (other than development which only comprises the provision of houses, flats or houses and flats) which comprises or includes the erection of a building or buildings – c) outside Central London and with a total floorspace of more than 15,000 square metres.” • 1C – “Development which comprises or includes the erection of a building of one or more of the following descriptions – c) the building is more than 30 metres high and is outside of the City of London.”

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

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

5 The scheme relates to an irregular shaped, 0.7 hectare site to the east of Creekside in Deptford. The site is currently occupied by low rise B8 warehouse buildings (4,400 sq.m).

6 The site is bounded by Kent Wharf, which is a newly completed residential led mixed use development (GLA Ref. D&P/3497/02 and LPA Ref. DC/14/89953), to the north; Deptford Creek to the east; Network Rail railway arches to the south; and Cockpit Arts (a creative industries business incubator) to the west. Medium rise residential blocks (forming the Crossfields Estate) and the Sue Godfrey Nature Park are adjacent to the site. To the east of the site on the opposite side of Deptford Creek are commercial buildings (located within LB ). The Deptford Creekside Conservation Area wraps around the site to the west and south. The railway viaduct to the south of the site is Grade II listed.

7 The site is located within the Deptford Creek/ Greenwich Riverside Opportunity Area, an Area of Regeneration and a SHLAA housing site. In respect of local designations, the site is allocated as a Mixed Use Employment Location (Ref. SA11) in Lewisham Council’s Site Allocations Document comprising employment uses including creative industries, office, workshop development and housing.

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8 The A200 Creek Road, part of the Strategic Road Network, is approximately 250 metres to the north, while the A2 Deptford Broadway/Deptford Bridge, part of the Transport for London Road Network, is approximately 500 metres to the south. The site has a Public Transport Access Level (PTAL) of 3, with three bus routes within 300 metres, Deptford railway station within 700 metres and Deptford Bridge (DLR) station within 800 metres.

Details of the proposal

9 The application proposes the redevelopment of the site to provide three new buildings ranging in height from 3 to 17 storeys including the 233 residential units, 1,363 sq.m. of flexible commercial floorspace (Class B1/B2) and 254 sq.m. of flexible commercial floorspace (B1/B2/A3). Case history

10 Pre-application discussions were held with GLA officers on 12 May 2017. The meeting covered the following key topics: principle of development, housing, affordable housing, urban design, inclusive design, transport and climate change. The pre-application site included the Cockpit Arts building to the south west of the site, but this element has been omitted from the current proposals. The advice contained within the pre-application note pre-dated the publication of the draft London Plan in December 2017. Strategic planning issues and relevant policies and guidance

11 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is Lewisham’s Core Strategy (June 2011), Development Management Local Plan (November 2014), Site Allocations Document (June 2013) and the London Plan (Consolidated with Alterations since 2011) (2016).

12 The following are also relevant material considerations:

• The National Planning Policy Framework and National Planning Practice Guidance.

• The draft London Plan (2017) incorporating the Mayor's August 2018 Minor Suggested Changes which should be taken into account on the basis explained in the NPPF.

• Draft Lewisham Local Plan (November 2015).

13 The relevant issues and corresponding policies are as follows:

• Industrial land London Plan; Land for Industry and Transport SPG; Industrial Intensification Practice Note; • Housing London Plan; Housing SPG; Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG; Affordable Housing and Viability SPG; • Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG; • Inclusive design and heritage London Plan; Accessible London: achieving an inclusive environment SPG • Energy and drainage London Plan; Sustainable Design and Construction SPG; Mayor’s Environment Strategy; • Transport London Plan; the Mayor’s Transport Strategy; SPG.

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Principle of development

14 The existing site comprises 4,400 sq.m. of B8 warehousing but does not form part of a Strategic Industrial Land (SIL) or Locally Significant Industrial Site (LSIS) designation. In accordance with the Policy E4 of the draft London Plan, the site would therefore constitute Non-Designated Industrial Site (NDIS). The draft London Plan Policy E4 seeks to maintain a sufficient supply of industrial land and premises for industrial and related functions across SIL, LSIS and NDIS with no overall net loss of industrial floorspace capacity.

15 Notwithstanding this, the application site forms part of a Mixed Use Employment Location (Ref. SA11) in Lewisham Council’s Site Allocations Local Plan comprising employment uses including creative industries, office, workshop development and housing. The allocation specifies that 20% of built floorspace should be provided as employment. Lewisham’s Core Strategy Spatial Policy 2 states that in the Deptford Creekside area the Council will support regeneration and growth through the redevelopment of designated underutilised employment sites for a mix of uses including residential and a significant element of employment space, at Mixed Use Employment Locations (MELs).

16 Whilst the delivery of creative commercial workspace is welcomed, the employment offer should be strengthened further to better reflect the aspirations of the Local Plan and draft Policies E4 and E7 of the London Plan.

17 As set out in the applicant’s planning statement, the proposals would deliver 1,583 sq.m. (NIA) of commercial floorspace which amounts to just 9% of the overall quantum of floorspace proposed. Furthermore, this figure includes the flexible B1/B2/A3 254 sq.m. unit, which may be utilised as restaurant/ cafe and therefore cannot be relied upon to contribute to the employment floorspace requirement. In terms of the overall quantum of commercial floorspace across the allocation (including the Kent Wharf development, retained Cockpit Arts building and units under the network rail arches), the1, total commercial floorspace figure given by the applicants amounts to 17%. However, this figure is further reduced when omitting the proposed flexible B1/B2/A3 unit and it is questioned whether the flexible B1/D1/D2 uses approved under Kent Wharf scheme would deliver true employment floorspace as defined by the local site allocation. Given that the proposals would involve the loss of up to 4,400 sq.m. (GIA) of industrial floorspace, the principle of mixed use redevelopment would only be supported if the quantum of genuine employment (Class B) floorspace is increased such that the overall quantum of genuine employment floorspace across the wider allocation amounts to 20% of the total NIA.

18 Given that the proposals would involve the co-location of industrial uses with residential, in accordance with draft London Plan Policies E7 and D12, the applicant would need to demonstrate that the industrial and related activities on site or surroundings are not compromised in terms of their continued efficient function, access, service arrangements, and days/ hours of operation noting that many businesses have 7-day / 24 hour access and operational requirements; and the intensified industrial is completed in advance of any residential being occupied.

19 Furthermore, appropriate design mitigation should be provided in any residential element to ensure compliance with the above, with particular consideration given to safety and security, the layout, orientation, access, and delivery arrangements of the uses in order to minimise conflict; design quality, public realm, visual impact and amenity for residents; agent of change principles; vibration and noise; and air quality including dust, odour and emissions. However, this has not been addressed in the application. A full assessment of impact against these policies must be undertaken and any measures required to mitigate against the development’s impact on proposed and surrounding industrial uses specified. The suitability of Class B2 (heavy industry) uses within a predominantly residential scheme in this regard is questioned as they are

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usually associated with more antisocial/ polluting uses. If B2 uses are to be successfully integrated into the scheme a clear strategy as to how they might successfully co-exist with residential and surrounding uses must be put forward.

20 It is not clear from the submission whether the commercial units are capable of industrial (particularly B1c/B2) occupation. The detailed specifications of the proposed commercial units would be built to are required to ensure that they would be genuinely attractive to industrial (Class B1c/B2) tenants. The applicant should refer to the Mayor’s Industrial Intensification Primer and the Industrial Intensification and Co-location Study for further details.

21 The site is located within an Opportunity Area and is an identified SHLAA site where housing delivery is expected to be maximised. Policy 3.3 of the London Plan sets Lewisham an annual housing delivery target of 1,385 units per annum, Policy H1 of the draft London Plan increased this target to 2,117 per annum. Therefore, this scheme would represent 17% of Lewisham Council’s current London Plan annual target and therefore would be strongly supported, subject to the satisfactory resolution of the issues raised above. Housing

22 The application proposes to provide 233 units with the following mix:

1 bed 2 bed 3 bed Units Hab rooms

Market 51 78 22 151 424

Intermediate 13 21 0 34 89

Social Rent 19 14 15 48 140

83 113 37 233 653

23 London Plan Policy 3.12 seeks the maximum reasonable amount of affordable housing. The Mayor’s Affordable Housing and Viability SPG establishes a minimum pan-London threshold level of 35% affordable housing (without grant) with a strategic target of 50%. However, given that this scheme is being brought forward on industrial land and will result in a net loss in industrial capacity, the scheme should deliver at least 50% affordable housing in accordance with draft London Plan Policy H5. Lewisham’s Core Strategy Policy 1 states that the Borough would seek the maximum provision of affordable housing, with a strategic target of 50%, subject to viability testing with a 70:30 split in favour of social rented housing.

24 Policy H7 of the draft London Plan and Affordable Housing Viability SPG sets out a preferred tenure split of at least 30% low cost rent (social or affordable rent), at least 30% intermediate (with London Living Rent and shared ownership being the default tenures), and the remaining 40% to be determined by the LPA to achieve mixed and balanced communities. For any affordable housing provided beyond 35%, their tenure is flexible provided that they are genuinely affordable and take account of local housing need in accordance with draft London Plan Policy H7.

25 As the scheme proposes 35% affordable housing by habitable room, the scheme would need to follow the Viability Tested Route. GLA officers are currently undertaking a review of the viability assessment to ensure that the maximum level of affordable housing is achieved. The results of this review will be shared with the applicants and the Council in due course. Likewise,

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the Council’s independent review of the applicant’s viability assessment should be shared with the GLA on receipt.

26 A 60:40 split between London Affordable Rent and shared ownership is proposed. The Council has confirmed that they are comfortable with this split and complies with the provisions of draft Policy H7. Furthermore, the shared ownership units are proposed to be affordable to residents with an income of up to £67,500 and therefore qualifies as genuinely affordable in line with the current Annual Monitoring Report. Rent level assumptions and income thresholds must be secured accordingly by the Council in the S106 agreement.

27 It is understood that 35% affordable housing offer is made without the benefit of grant funding. As Peabody is a named strategic partner benefiting from access to the Mayor’s affordable homes programme funding, the applicant must explore the use of grant to increase the affordable housing offer. The with grant affordable housing figure should be confirmed prior to Stage 2.

28 Both early implementation and late stage reviews would need to be secured within the s106 in accordance with the Affordable Housing and Viability SPG and draft London Plan.

Housing choice

29 London Plan Policy 3.8 and draft London Plan Policy H12 encourage a full range of housing choice. Policy H12 ‘Housing size mix’ of the draft London Plan states that boroughs should not set prescriptive dwelling size mix requirements for market and intermediate homes; and for low cost rent, boroughs should provide guidance on the size of units required to ensure affordable housing meets identified needs.

30 The scheme would provide a good mix of homes including a good proportion (16%) of family-sized 3 bed homes. Although the scheme does not provide the target 42% family sized affordable homes, the proposed housing mix does not raise any strategic planning concerns.

Playspace

31 In accordance with London Plan Policy 3.6 and draft London Plan Policy S4, development proposals that include housing should provide play space for children based on the short and long- term needs of the expected child population generated by the scheme. Further detail is provided in the ‘Shaping Neighbourhoods: Play and Informal Recreation’ SPG which a benchmark of 10 sq.m. of useable child play space to be provided per child. The total play space required based on the guidance set out in the Mayor’s Shaping Neighbourhoods: Play and Informal Recreation SPG is 658 sq.m.

32 A total of 359 sq.m. of on-site playspace is currently proposed within the public realm, at podium and roof level. This represents almost half of the total playspace required. This under- provision should be fully justified having regard to the accessibility of existing play provision in the area in accordance with the Play and Informal Recreation SPG. On site play space for under 5s should be provided on site as a minimum.

33 The draft London Plan Policy S4 requires playspace to be fully accessible and should be able to be accessed safely from the street by children and young people independently. Further details of how the proposed play space would be accessed and what age groups the playspaces are intended for are requested. There are concerns over the location of the play space within the public realm to the south of the site given the proximity to proposed commercial units and therefore potential conflict with service vehicles. Furthermore, it has not been demonstrated

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that the roof space would provide a suitably safe, secure space for children to play. These issues should be addressed in full in prior to Stage 2.

Urban design

34 The design principles in Chapter 7 of the London Plan and Chapter 3 of the draft London Plan requires all developments to achieve a high standard of design which responds to local character, enhances the public realm and includes architecture of the highest quality that defines the area and makes a positive contribution to the streetscape and cityscape.

Density

35 The London Plan and draft London Plan also both require developments to make the most efficient use of land and to optimise density, using an assessment of site context and a design-led approach to determine site capacity. The scheme would have a net density of 933hr/ha (333 units/ha). This significantly exceeds the guidance ranges in Table 3.2 of the London Plan and thresholds for increased scrutiny of design quality set out in draft London Plan Policy D6 (Part C). Given the location of the site within the Opportunity Area and is an identified SHLAA site, the increased density on this site could be supported subject to the scheme delivering the maximum level of the affordable housing as well as a significant and viable employment offer.

Layout and public realm

36 The general layout principles of introducing two perimeter blocks positioned to enable the future development of the Cockpit Arms block and to create new zones of public realm within the site and along the Creekside are supported.

37 As discussed at pre-application stage, the success of the proposals depends on the Network Rail land to the south coming forward to provide public open space along the railway viaduct. The applicant should seek to secure this as without the adjacent land, the public open space on the site would be substandard.

38 The northern block has predominantly active commercial frontage with residential cores located at the corners to provide legible entry points which is welcomed. The southern block is less successful and includes a large amount of servicing/energy centre frontage along the Creek edge. The link between blocks D1 and E4 is also flanked with refuse/substation frontage which will limit the amount of activity and surveillance onto this important area of the site. The applicant is encouraged to explore options for increasing the amount of commercial frontage along the Creek edge and located refuse stores away from prominent building corners; however, it is acknowledged that the block layout means that there will inevitably be a certain degree of inactive frontage flanking onto the public realm.

Residential quality

39 The proposed units would comply with the space standards as set out in the Technical housing standards – nationally described space standard and Mayor’s Housing SPG and Policy D4 of the draft London Plan. However, confirmation is required that the units will meet the internal dimensions and external space standards as identified within draft Policy D4.

40 At the upper levels, the residential layouts are efficient with cores distributed to create no more than 7 units sharing the same core at each level and a reasonable proportion of dual aspect overall. It is noted that the majority of single aspect units would have good outlook over the Creek and deck access has been used to avoid any north facing single aspect units which is

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welcomed. ADF analysis should ensure that inward facing units in particular are designed to optimise daylight penetration to living spaces.

Height and massing

41 The heights and massing approach has evolved positively through consultation with the Council and GLA. The proposed arrangement is consistent in scale with neighbouring schemes and makes provision for the future development of the wider area. Positioning the tallest element at a prominent corner of the site alongside the Creek edge is supported in townscape terms however, at present this portion of the site is isolated from key routes towards the station and the applicant is encouraged to work with Network Rail to enable a more direct pedestrian link along the Creekside.

42 The daylight/ sunlight impact of the scheme on the neighbouring Kent Wharf in respect of some of the units at lower levels scheme is of significant concern. The applicant must seek to address these issues in full prior to Stage 2. Daylight/sunlight analysis should also confirm that the overshadowing impacts of the tower onto the square and wider public realm have been minimised through its form and orientation.

Architecture

43 The intention to introduce a simple and refined approach to the architecture is welcomed, with the use of brickwork creating a strong residential character. The applicant should ensure sufficient detail is included in the application to secure exemplary design quality through to completion. Particular attention should be given to depth of window reveals, rooflines and ground frontages.

Protected views

44 The site is within the Protected Vista Extension from Primrose Hill summit to St Paul’s Cathedral (View 4A.1). The northern edge of the site is within also within the Protected Vista Extension from the Centre of the Bridge over the Serpentine to the Palace of Westminster (View 23A.1). Neither of these views have been recognised in the application documents. Verified images of the scheme from this viewpoint must be provided in order to assess any impact the proposal may have on this view to ensure no harm would result to their composition as required by London Plan Policy 7.12 and Policy HC4 of the draft London Plan. Heritage

45 The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the statutory duties for dealing with heritage assets in planning decisions; which should “have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.” In relation to conservation areas, ‘in the exercise of planning powers within a conservation area, the decision maker is required to pay special attention to the desirability of preserving or enhancing the character or appearance of that area’. In relation to listed buildings ‘for development which affects a listed building or its setting, the decision maker shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses’.

46 The NPPF states that when considering the impact of the proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation; significance can be harm or loss through alteration or destruction of the heritage asset or development within its setting. Policy HC1 of the draft London Plan, like London Plan Policy 7.8, states that development should conserve heritage assets and avoid harm. A series of

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townscape views have also been analysed. Overall, the scheme is considered to have a neutral impact upon the conservation area and townscape. It is also considered that the development would have a neutral impact on the setting of the Grade II listed Railway Viaduct. In line with the NPPF, London Plan and draft London Plan, the development would preserve the setting of both heritage assets. Inclusive design

47 London Plan Policy 7.2 and draft London Plan Policy D3 require that all new development achieve the highest standards of accessible and inclusive design and can be used safely, easily and with dignity by all; are convenient and welcoming with no disabling barriers; are flexible and response; and realistic. There is no obvious definition between pedestrian and vehicular routes through the site and more detail must be provided as to how servicing activities on site would be managed to prevent conflict. The provision of a suitably sized fire evacuation lift within each core over 18 metres should be provided in accordance with Policy D3.

48 Of the 233 units proposed, only 9 (3%) will be provided as wheelchair user dwellings in accordance with M4(3) of the Building Regulations and 15 (6%) of units would comply with M4(2) standards, accessible and adaptable dwellings. This does not comply with London Plan or draft London Plan Policy D5 which requires 10% to be provided as wheelchair user dwellings and all remaining units to be accessible and adaptable. The scheme must be amended to meet London Plan and draft London Plan policy. Environment

Energy

49 The applicant must provide the following additional information and revisions in order to ensure compliance with London Plan, draft London Plan policies and GLA Energy Assessment Guidance: commit to higher carbon savings through energy efficiency alone; use gas boilers of 91% efficiency for the non-domestic; report the energy demand following energy efficiency measures; information on the percentage of the glazing ratio over the façade; complete the overheating checklist; receipt of the Dynamic Overheating Analysis; details of a potential future connection to a district heating network; details of the site-wide heat network; details of the energy centre; CHP should be removed; and PV maximised.

Drainage

50 The Flood Risk Assessment for the proposed development generally complies with London Plan Policy 5.12 and draft New London Plan Policy SI.12. However, the Flood Warning and Evacuation plan should be revised to clarify the time for breach flood waters to reach the site, and specifically address access and security provisions required to facilitate first floor refuge. In addition, the applicant should agree appropriate measures with the Environment Agency to ensure the performance of the current flood defences and provide for future defence maintenance and raising in line with the TE2100 plan over the life of the development.

51 The surface water drainage strategy for the proposed development does not yet comply with London Plan Policy 5.13 and draft Policy SI.13, as it does not give appropriate regard to the drainage hierarchy and greenfield runoff rate. Further details on how SuDS measures at the top of the drainage hierarchy will be included in the development, and how greenfield runoff rate will be achieved should be provided. Additional attenuation storage volume calculations, attenuation tank dimensions, and SuDS maintenance information should also be provided.

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52 The proposed development generally meets the requirements of London Plan Policy 5.15 and draft London Plan Policy SI.5. The applicant should also consider water harvesting and reuse to reduce consumption of wholesome water across the entire development site. This can be integrated with the surface water drainage system to provide a dual benefit.

53 The detailed technical comments have been sent to the applicant and the Council. Transport

Walking, cycling and the public realm

54 The analysis of walking opportunities within the Transport Assessment (TA) demonstrates that there are a large number of schools, shops and other facilities within reasonable walking distances of the site. However, it does not assess the quality of these routes or propose improvements, contrary to Policy T2 of the draft London Plan. Key routes from the site include Creekside and Bronze Street, which are the main access routes to Deptford and Deptford Creek stations. They are both relatively poor quality and have very narrow footways in places. Furthermore, the TA acknowledges that the site is poorly served by pedestrian crossings yet proposes no remedial action. As required by TfL’s TA guidance, a comprehensive assessment of key routes from the site should be undertaken and remedial action proposed and funded, either prior to the determination of the application or secured through the Section 106 agreement.

55 The TA acknowledges two distinct clusters of road traffic collisions, one at the junction of Creekside with the A200 Creek Road, the point at which the Cycle Superhighway is accessed, and one at the junction of Creekside with Deptford Church Street on the walking route to Deptford Creek DLR station. However, the TA proposes no remedial action to address the concerns this poor road safety record raises. The applicant should propose remedial action and contribute to improvements as necessary.

Cycle parking

56 The TA proposes to exceed the London Plan and draft London Plan requirements in respect of total cycle parking spaces which is welcomed. However, it fails to comply with draft London Plan Policy T5 and adopted London Plan Policy 6.9 in respect of compliance with London Cycle Design Standards (LCDS). This is primarily because all long-stay parking is proposed on two-tier racks which would not be accessible to all users/cycles and the cycle stand spaces; the cycle store gives rise in a particularly secluded part of the development and therefore the safety and security of users could be put at risk; and the number and width of doors does not accord with LCDS standards. The applicant should redesign the cycle store and access arrangements to ensure that it complies with LCDS prior to determination.

Car parking

57 The draft London Plan would expect this development to be car-free except for accessible parking spaces for disabled users. There is no Controlled Parking Zone (CPZ) in the area although there it is understood that there may be plans to extend an existing CPZ to this area. To enforce the general car-free nature of the development, it is recommended that the Section 106 agreement makes residents ineligible for residents’ parking permits in any future CPZ, and that the development should contribute to the cost of consulting on and subsequently implementing the CPZ if appropriate.

58 In accordance with Policy T6.1 and T6.5 of the draft London Plan and Policy 6.13 of the London Plan blue badge spaces should be provided for the commercial units.

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Conditions and obligations

59 Planning conditions or other legal mechanisms must be secured in relation to delivering the key transport mitigation measures detailed above, including: servicing, construction logistics and management, and a travel plan, with the latter focused on encouraging the use of active and more sustainable modes of travel. Local planning authority’s position

60 Lewisham Council planning officers are independently reviewing the applicant’s Financial Viability Assessment and currently targeting planning committee in July. Legal considerations

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

62 There are no financial considerations at this stage. Conclusion

63 London Plan policies on principle of development, housing and affordable housing, urban design, inclusive design, climate change, flood risk, drainage and water and transport are relevant to this application. The following issues should be considered:

• Principle of development: High density residential led mixed use development in an opportunity area supported. The applicant and Council must explore opportunities to increase employment floorspace. Further detail must be submitted to justify the proposed co-location of residential with industrial uses.

• Affordable housing: The development proposes 35% affordable housing by habitable room with a 60:40 split between LAR and shared ownership. As this is an industrial site, the fast track threshold is 50% affordable housing and would therefore subject to the Viability Tested Route. GLA officers are currently in the process of reviewing the submitted viability assessment in order to ensure that the maximum level of affordable housing is achieved.

• Playspace: The under-provision of play space should be justified. The measures be put in place to ensure the safety and security of the users of the proposed playspace has not been specified. The playspace within the central courtyard should be moved to a more appropriate location, away from the path of servicing vehicles.

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• Urban design: Assurances are required that the Network Rail land to the south would contribute to on-site public realm; increase active frontage along the Creek edge; daylight/sunlight impact on Kent Wharf and inward facing proposed units should be addressed in full; enhance walking route to the station along Creekside; the identified protected vista extension views should be assessed within the TVIA; and façade details required.

• Heritage: The impact of the scheme on heritage assets would be neutral and would preserve their significance.

• Inclusive design: The scheme should be amended to provide 10% as wheelchair user dwellings and all remaining units to be accessible and adaptable in accordance with draft London Plan Policy D5. The provision of a suitably sized fire evacuation lift within each core over 18 metres should be provided in accordance with Policy D3.

• Energy: Further information and amendments are required to demonstrate compliance regarding: energy efficiency; use of gas boilers; energy demand; glazing ratio; overheating checklist; Dynamic Overheating Analysis; details of a potential future connection to a district heating network; details of the site-wide heat network; details of the energy centre; CHP should be removed; and PV maximised.

• Drainage: Further information is required in respect of the Flood Risk and Evacuation Plan; whether any measures required to flood defences to protect the development; further details on how SuDS measures will be included in the development, and how greenfield runoff rate will be achieved; and the applicant should also consider water harvesting and reuse to reduce consumption.

• Transport: The TA does not assess the quality of walking routes to the site and propose improvements; the cycle parking should be redesigned to LCDS standards; residents should be prevented from applying for parking permits in the event of a CPZ being introduced; disabled parking should be provided for the commercial uses; and revised draft servicing, construction logistics and travel plans are required.

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for further information contact GLA Planning Unit, Development & Projects Team: Juliemma McLoughlin, Chief Planner 020 7983 4271 email [email protected] John Finlayson, Head of Development Management 020 7983 2632 email [email protected] Kate Randell Team Leader 020 7983 4783 email [email protected] Hannah Thomas, Principal Strategic Planner (case officer) 020 7983 4281 email [email protected]

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