SITE DESIGNATIONS
ADDRESS: 54 Kennington Road, London, SE1 7BJ
Application Number: 16/06317/FUL Case Officer: Luke Farmer
Ward: Bishops Date Received: 08/11/2016
Proposal: Demolition of existing 'Days Inn' hotel (162 beds) and erection of a 5 to 13 storey (plus basement and mezzanine) new hotel (Class C1) (355 beds), with ancillary restaurant, bar and cafe and a ground floor 115sqm community unit (Use Classes D1, D2, B1 - affordable workspace), with associated landscaping and public realm works.
Drawing numbers: LI56-207-02-02-001; LI56-207-02-02-002; 01-91-001; 01-91-002; 01- 91-003; 01-91-004; 01-91-005; 01-91-006; 01-91-007; 01-91-008; 01-91-009; 13C063_001; 13C063_002; 02-03-099 D; 02-03-100 D; 02-03-101 D; 02-03-102 D; 02-03- 106 D; 02-03-107 D; 02-03-108 D; 02-03-109 D; 02-03-110 D; 02-03-111 D; 02-03-112 D; 02-03-113 C; 02-05-001 B; 02-05-002 B; 02-05-003 B; 02-05-004 B; 02-05-005 B; 02-05- 006 B; 02-05-007 B; 02-05-008 B; 1180-HED-MP-L-DET-00-1001; 1180-HED-MP-L-DET- 00-1002; 1180-HED-MP-L-DET-00-1003; 1180-HED-MP-L-DET-00-1005; 1180-HED-MP- L-DET-00-1006; 1180-HED-MP-L-DET-00-1007; 1180-HED-MP-L-DET-00-1008; 1180- HED-MP-L-DET-00-1011; 1180-HED-MP-L-DET-00-1012; 1180-HED-MP-L-DGA-000- 0001; 1180-HED-MP-L-DGA-000-0002; 1180-HED-MP-L-DGA-000-0004; U(12)200; U(-- )001; 02-04-001; 1180-HED-MP-L-DGA-000-0008 P01.
Documents: Design and Access Statement; Planning Statement; Townscape, Visual and Heritage Statement; Transport Assessment; Transport Addendum; Travel Plan; Delivery and Servicing Management Plan – Amended March 2017; Outline Construction Management Plan – March 2017; Air Quality Assessment; Arboricultural Impact Assessment; Landscape and Public Realm Statement; An Historic Environment Desk- Based Assessment; Basement Impact Assessment; BREEAM New Construction (2011) Assessment; Civil and Structural Engineering Stage 2 Report; Daylight and Sunlight Report by Point 2 Surveyors; Daylight and Sunlight VSC Analysis (Colwyn House: deck access removed); Daylight and Sunlight Daylight Distribution Analysis (Colwyn House: deck access removed); Daylight and Sunlight: Sunlight on Ground Analysis (Proposed 21st March); Daylight and Sunlight: Sunlight on Ground Analysis (Proposed 21st June); Daylight and Sunlight: Sunlight on Ground Analysis (Existing 21st March); Daylight and Sunlight: Sunlight on Ground Analysis (Existing 21st June); Energy Assessment Rev. B; Sustainability Statement; Environmental Noise Survey; Light Pollution Assessment; Flood Risk Assessment; Desk Study, Detailed Site Investigation and Risk Assessment Report; Groundwater Analysis dated 27 February 2017; Wind Microclimate Assessment; Ventilation Equipment; Statement of Community Involvement.
RECOMMENDATION:
1. Resolve to grant conditional planning permission subject to any direction that may be received following referral to the Mayor of London and subject to completion of an agreement under Section 106 of the Town and Country Planning Act 1990 of the planning obligations listed in this report.
2. Agree to delegate authority to the Director of Planning, Transport and Development to:
Finalise the recommended conditions as set out in this report including such amendments, additions and/or deletions as the Director of Planning, Transport and Development (in consultation with the Planning Committee Chair) considers reasonably necessary; and Negotiate, agree and finalise the planning obligations as set out in this report pursuant to Section 106 of the Town and Country Planning Act 1990, including adding to, amending and/or deleting the obligations detailed in the heads of terms as the Director of Planning, Transport and Development (in consultation with the Planning Committee Chair) considers reasonably necessary.
3. That if the Section 106 Agreement is not signed by 30 May 2017 the Director of Planning, Transport and Development be given delegated powers to consider refusing the application in the absence of a legal agreement.
4. In the event that the committee resolves to refuse planning permission and there is a subsequent appeal, delegated authority is given to officers, having regard to the heads of terms set out in the report, to negotiate and complete a document containing obligations pursuant to Section 106 of the Town and Country Planning Act 1990 in order to meet the requirements of the Planning Inspector.
Applicant: Cranborne Enterprises Agent: Jones Lang LaSalle Limited Limited Relevant site designations: Type of designation Applicable designation Central Activities Zone (CAZ) Waterloo Flood Zone 3 Archaeological Priority Area North Lambeth
LAND USE DETAILS
Site area 0.30 hectares
Use Class Use Description Floorspace (Gross External Area) Existing C1 Hotel 6,809 square metres (sqm)
Proposed C1 Hotel 15,237 sqm D1/D2/B1 Community Use / 115 sqm Affordable Workspace
PARKING DETAILS
Car Parking Car Parking Bicycle Motorbike Spaces Spaces Spaces Spaces (general) (Disabled) Existing 22 2 0 0 Proposed 0 0 35 0
EXECUTIVE SUMMARY
The application is for the demolition of the existing hotel and the complete redevelopment of the site to provide a new 355 bedroom hotel of 4* accommodation, an increase of 193 rooms from the existing 162 bedroom hotel. The hotel would also include a number of ancillary uses such as a restaurant, café, bar and business centre, and a separate community use/ affordable workspace unit, which would provide an active frontage to the sections of the site facing Kennington Road and Lambeth Road.
The land uses and quantum of development is considered to be appropriate in this central London location with excellent access to public transport facilities and nearby tourist attractions. Despite the proposed intensification of the existing hotel use at the Site, this would not be at the expense of other land uses in the area locally. The Development would not impact unacceptably on neighbouring properties, and furthermore it would not impact unacceptably on local environmental conditions.
The proposed replacement buildings are considered to be appropriate in their siting, scale, form and detailed design, noting that despite their additional height, they would integrate well with the adjacent buildings and would cause no harm to any of the surrounding heritage assets or local views. Were it to be considered that less than substantial harm would be caused, this would be appropriately offset by sufficient public benefits that the scheme would provide. The land uses and quantum of development is considered to be appropriate in this central London location with excellent access to public transport facilities and nearby tourist attractions. Despite the proposed intensification of the existing hotel use at the Site, this would not be at the expense of other land uses in the area locally.
The proposed development would provide acceptable standards of hotel accommodation, would not impact unacceptably on the neighbouring properties, local environmental conditions and the local transport system. Furthermore, the scheme would provide employment and training benefits for local people during the construction phase of the development and in the end use of the site.
Officers consider that the development would be in compliance with the Development Plan for the Borough. Officers are therefore recommending approval of the scheme, subject to conditions and completion of a Section 106 Agreement.
PLANNING OFFICER’S REPORT
Reason for referral to PAC: The application is reported to the Planning Applications Committee in accordance with (1)(ii) of the Committee’s terms of reference as it relates to a major application for the creation of more than 1,000sqm of commercial floorspace.
SITE AND SURROUNDINGS
1.1 The application site (‘the Site’) lies at the central London junction on two main roads, Kennington Road (A23) and Lambeth Road (A3203). To the north it is bounded by Cosser Street, off which the Site draws its vehicular access. To the west is Morton Place which links via an alleyway along the side of the Site to Lambeth Road. The Site is therefore entirely surrounded by public realm.
1.2 The Site is a 'brownfield' previously developed land which in the past has been redeveloped a number of times, covering the entire street block. However today the buildings on the Site cover a smaller footprint than previously, being surrounded by an area of hardstanding and softer landscaping.
Figure 1: Site Location (site in red)
Figure 2: Site Location; the green line indicates the extent of the ownership of the applicant and the red line indicated the extent of the application boundary
Figure 3: Aerial view of the site (facing east)
1.3 The building form, an 'S' shape in plan, has a uniform height of ground plus five storeys. There are additional sloping roofs on each individual section of the building, containing plant, and a central lift tower, which is again slightly taller. The tallest element on the Site is therefore 23 metres above street level. The current buildings were built in 1981, initially for hostel accommodation and later for student housing. The buildings were converted into the current hotel use in 1998.
1.4 The Site benefits from a vehicular access from Cosser Street to an on-site car parking area (a total of 24 parking spaces). The Site also makes use of the existing on-street coach parking facilities on Cosser Street and further afield on Lambeth Road opposite the Imperial War Museum to the south west.
1.5 In terms of the surrounding properties, most notably the Site backs onto Colwyn House of the Briant Estate, which is a five-storey block of flats. To the west of the Site is a 3- storey terrace to Lambeth Road and 130 Lambeth Road. Lambeth Towers and International House are located opposite the Site on Lambeth Road. These are residential and student accommodation buildings respectively, both are 11-storeys in height.
Figure 4: The existing Days Inn Hotel when viewed from the opposite side of the junction of Kennington Road and Lambeth Road and at the beginning of Geraldine Mary Harmsworth Park
Figure 5: View of the Site from Lambeth Road looking east
Figure 6: View of the Site from Kennington Road looking south
1.6 The Site contains 6,809sqm of gross floorspace and 162 bedrooms. There are ancillary hotel uses such as back-of-house areas, bar and a breakfast room.
1.7 The Site is not located within a conservation area and the building is not listed. There are a number of statutory listed and locally listed building in close proximity to the Site, and the Site is located opposite the West Square Conservation Area (within the London Borough of Southwark). The Site is also opposite the Imperial War Museum, a Grade II listed building. Lambeth Palace, which is a Grade I listed building is approximately 510 metres to the south-west. Furthermore, the Site is located within an Archaeological Priority Area.
1.8 The Site is located within Environment Agency Flood Zone 3. The Site lies within the Central Activities Zone (CAZ) but outside the Waterloo Opportunity Area. Transport for London rates it as having a Public Transport Accessibility Level of 6B - the highest available. The Site is within the Waterloo ‘W’ Controlled Parking Zone (CPZ).
PROPOSAL
2.1 The proposed development (‘the Development’) is for the demolition of the existing ‘Days Inn’ hotel and the erection of a new hotel between 5 and 13 storeys in height. The maximum height of the proposed hotel would be approximately 43 metres and it would provide 355 bedrooms of 4* accommodation, an increase of 193 rooms from the existing 162 bedroom hotel.
2.2 The hotel will include a number of ancillary facilities at ground floor level, including a restaurant, bar and café and a gym and business/meeting area at basement level. A 115sqm community use unit is also proposed and would be located on the Lambeth Road side of the building at ground floor level. This unit is proposed to have a flexible D1, D2, B1 (affordable workspace) Use Class.
2.3 The Development would result in the loss of a number of trees on the site and adjacent street trees (further details of this is provided below). A new landscaping and public realm scheme has been proposed to mitigate the loss of these trees. 2.4 The hotel entrance would front onto Kennington Road, with the tallest element of the building (13-storeys) positioned on the corner of the site at the junction of Kennington Road and Lambeth Road. The building would step down to 5-storeys in height along the Lambeth Road elevation and 6-storeys in height along the Kennington Road elevation.
Figure 7: View of the proposed scheme from the opposite side of the junction of Kennington Road and Lambeth Road and at the beginning of Geraldine Mary Harmsworth Park
Figure 8: View of the proposed scheme from the opposite side of Kennington Road 2.5 In terms of the detailed design, the building would mainly be constructed from brickwork, with a curved brick used at the corners. Curved glass is also proposed that the corners, which is emphasised most in the front of the building on Kennington Road, and in the corner of the tallest section of the building at the junction of Kennington Road and Lambeth Road. The ground and mezzanine floors would include double height glazing, with secondary signage proposed behind the glazing.
2.6 The vehicular access to the site would remain as existing on Cosser Street. Whilst no car parking is proposed, this would provide a drop-off area for vehicles, including taxis. Short stay coach parking would take place on Cosser Street as per the current arrangement. Servicing would take place in Morton Place, also as existing. Refuse and recycling would be stored internally, but collected in this area.
RELEVANT PLANNING HISTORY
3.1 DG/H/HD/DH/6498: Erection of a hostel on the Surrey Lodge Site, Lambeth. Deemed Consent Given 12.12.1977.
3.2 98/00080/FUL: The change of use from student hostel to hotel together with alterations to the elevations, erection of porte cochere, formation of a new vehicular access, provision of a car/taxi set down and ancillary parking. Application Permitted 23.06.1998.
3.3 The proposed development has been subject to a number of pre-application requests. In addition, a Planning Performance Agreement (PPA) was entered into between the applicant and the Council, where a series of meetings were held to develop the scheme.
3.4 16/03913/EIASCR: Screening request in respect of an Environmental Impact Assessment in relation to a new hotel of approximately 15,550 square metres of gross floorspace (an uplift of no more than 10,676sqm) for a hotel development of up to 360 bedrooms in a building of up to 12 storeys plus part mezzanine level and screened plant (at its highest point no more than 45 metres above street level) with a ground floor restaurant, bar, class D1 community use, meeting rooms, gym and other ancillary hotel uses, removal and replacement of street trees, additional street planting and landscaping. There will also be a minor relocation of the vehicle entrance along Cosser Street, re-providing two-way entry to a turning circle, and a new servicing bay on Morton Place. No further action was taken on 21.07.2016.
CONSULATIONS
4.1 Statutory and Internal/External Consultees
4.1.1 Conservation and Design: Support has been expressed for the scheme and the comments have been incorporated below in the ‘Conservation and Design’ section below.
4.1.2 Transport and Highways: Requested further clarification on the trip generation analysis, coach parking and servicing. Also requested that the developer contributes to providing an on-street blue badge bay in place of existing bay parking, which has been shown to be under-used. Finally, suggested that cycle hire facilities may need to be increased subject to comments from Transport for London.
Further details were given to clarify the points referred to above, and following the receipt of this, no further comments or objections were raised.
4.1.3 Transport for London (TfL): Requested the following in order to mitigate the impacts of the development on the transport network: - Taxi rank provided at the site and a provision within the Hotel Management Plan for management of taxi movements;
- At minimum of one blue badge space installed ahead of occupation;
- Coach arrangements to be managed appropriately with further details required on overnight coach parking;
- Cycle Hire contribution of £150,000 for a new 27 space cycle docking station outside the Site on Kennington Road;
- Pedestrian crossings to be considered on Kennington Road;
- Construction Logistics Delivery and Servicing plans to be secured by condition, with all construction measures implemented in partnership with the Nine Elms Construction Logistics Co-ordination Team;
- Travel Plan to be secured by and monitored by Section 106 Agreement.
4.1.4 Arboricultural Officer: No objection, subject to conditions requiring full details of the new landscaping scheme as well as conditions ensuring the protection of the trees that are to be retained.
4.1.5 London Borough of Southwark: No objection, but requested clarity on the routes that would be used during the construction phase of the Development given the potential impact on Southwark roads. Specifically, it is requested that access/egress to the Development using Blackfriars Road and Elephant and Castle is avoided as far as possible due to the high volume of construction vehicles already in these areas.
4.1.6 Historic England: Raised a concern regarding the potential views of the building above Lambeth Palace from occasional vantage points (Views 13 and 14 within the submitted townscape visual and heritage assessment). It was noted that should the Development break above the roofline on Lambeth Palace, it risks diminishing the articulation of this roofscape and causing harm, albeit less than substantial harm.
4.1.7 Historic England (Archaeology): No objection, but requested a condition be added requiring a two-stage process of archaeological investigation comprising first, evaluation to clarify the nature and extent of surviving remains, followed, if necessary, by a full investigation.
4.1.8 Greater London Authority: Support was given for the intensification of the hotel use at the site and community use unit. The broad design principles are also supported given the underutilisation of the existing site and its location within the CAZ. It was concluded however that in terms of the surrounded heritage assets, the proposals would result in a less than substantial harm to historic significance of Lambeth Palace and the Imperial War Museum; but this harm would be outweighed by the public and townscape benefits of the scheme. In addition, a wind study was requested in order to address the requirements of London Plan Policy 7.7D. Further discussions were also requested regarding the points raised by TfL regarding transport.
4.1.9 Environmental Health: No Objection, but requested a number of conditions regarding the operation of the Development to ensure that it would not impact unacceptably on neighbouring properties with regard to noise and odours.
Further assessments were also requested regarding land contamination and a wind study. Following the receipt of these documents, no objections were raised.
4.1.10 Sustainability Consultants: No objections raised subject to conditions. 4.1.11 Waste Collection: Further details regarding waste collection was requested.
4.1.12 Environment Agency: No objection were raised.
4.1.13 Secured by Design Officer: Welcomed that measures have been proposed to prevent any external seating being potentially used by rough sleepers, and requested clarification on the access of the separate ground floor unit, which should be separate from the main building. Conditions have been requested ensuring the Development achieves Secured by Design standards and also regarding a crime prevention strategy, with details to include CCTV and security management information.
4.1.14 Thames Water: No objection, subject to a condition be added requiring a piling method statement to be submitted for approval, due to the potential for piling to cause damage to subsurface infrastructure.
4.2 Other Consultees
4.2.1 Waterloo Community Development Group: Concerns were raised with regard to the height of the Development and also suggested that retail uses at ground floor would be preferable to the proposed restaurant use.
4.3 Adjoining owners/occupiers
4.3.1 A site notice was displayed from 23.11.2016 to 14.12.2016 and the application was advertised in the local paper on 23.11.2016. The statutory consultation period ended on 14.12.2016. In response to consultation, 65 letters of representation have been submitted.
4.3.2 58 letters of objections were received, a summary of the concerns raised is set out below:
Summary of objections Response Land Use There is not a need for more hotel See section 6.1. rooms in this area. Housing should be proposed at this As an existing hotel site, policy seeks to site instead of a new hotel. retain the same level of hotel facilities at the site. It is likely that residential use would only have been supported in principle where the same level of hotel facilities were also proposed as a mixed- use development. However, as this is not what has been proposed, the application has been considered on its own merits. Design The proposal is out of scale for its See section 6.2 parts (a) and (b). context, negatively affecting the character of the area. International House opposite the site is not a good precedent for a similarly sized building. Were these proposals to be Each application would be assessed on its approved, it may trigger other own merits and would not necessarily set a similarly sized development in the precedent. area. The detailed design offers no See section 6.2 part (a). aesthetic improvement and bears no relationship to other local buildings. The top section of the building for plant should be finished in brickwork as per the rest of the building. The proposal would have an See section 6.2 parts (b) and (d-h). adverse impact on the setting of the historic Imperial War Museum and Geraldine Mary Hemsworth Park. The proposal would harm the See section 6.2 parts (b) and (d-h). significance and setting of the surrounding buildings, some of which are listed buildings. Amenity Loss of sunlight to Geraldine Mary See section 6.4 and the ‘Daylight and Harmsworth Park and block Sunlight’ and ‘Privacy’ sections. With daylight and sunlight to the regard to Geraldine Mary Harmsworth immediately adjacent residential Park, it is considered that the Development units and result in a loss of privacy. would result in a minimal loss of sunlight Also, the loss of sunlight to Colwyn during the evening and as such is House may result in an increase in acceptable in this respect. heating bills. The commercial uses at ground See section 6.4 and the ‘Noise’ section of floor should be limited to the report. Kennington Road and not encroach on the residential areas to the rear due to associated noise concerns. The proposed bar may result in See section 6.4 and the ‘Noise’ section of people frequenting around Cosser the report. Street in the same way people do from the Steam Engine Pub, causing disruption to the residents in Colwyn House. Reflection from glass and metal Whilst full details of materials would be could have a detrimental effect on requested as a condition, it is considered amenity. that glare from the materials would not harm the safety of pedestrians, cyclists and motorists. Neon signage could impact upon Any illuminated advertisements are likely to the residents. require express advertisement consent as a separate permission, as required under The Town and Country Planning (Control of Advertisements) (England) Regulations 2007. The applicant’s Noise Assessment See section 6.4 and the ‘Noise’ section. does not appear to have taken account of the increased deliveries that will take place on Morton Place. The re-siting of the proposed The additional commercial uses in this area building may result in an increase in are considered acceptable with regard to noise to the adjacent properties on potential noise creation. See section 6.4 Lambeth Road. and the ‘Noise’ section for a further analysis. Transport There will likely be an increase in See section 6.5 and the ‘Deliveries and deliveries and taxi journeys, Servicing’ and ‘Taxis’ sections. A condition concerns with increase in traffic on would be attached also, limiting the hours Morton Place. Could this not take of when deliveries are permitted to take place on Cosser Street and could place. Were this to be proposed to be the delivery times be limited? amended at a later date, a further application would be required to amend the condition, in which a statutory consultation would be undertaken with the surrounding properties.
Whilst there will be a likely increase in taxis, generally vehicle movements to the site are anticipated to decrease given the ‘car-free’ nature of the development and the promotion of more sustainable methods of transport. There would be no parking See section 6.5 and the ‘Car Parking’ provided, which could cause section. problems for residents parking in the local area. Public transport systems in the area The applicant would be liable to pay a CIL are not sufficient to accommodate contribution should planning permission be the additional demand for use that granted, where monies could be put would be created by the proposed towards infrastructure improvements, development. including transport systems. In addition, the applicant is willing to enter into a Section 106 Agreement to provide new cycle hire facilities in close proximity to the Site. Concerns regarding safety of Details would be required in the form of a people during construction phase of Construction Management Plan, which the building and also on the area would be requested as a condition of an generally. approval. Further details have been provided in the draft Construction Management Plan as explained at section 6.5 of the report. Concerns that the existing coach Details have been provided within the parking space on Cosser Street submitted Delivery and Servicing would become overused, which Management Plan (DSMP) regarding the could have a detrimental impact on management of the coach parking. Further 3 Cosser Street were coaches to be details have been provided within the parked for long periods of time with amended DSMP in terms of coach parking engines running. management, and following the receipt of these details, the application is considered acceptable in this respect. Landscaping The associated landscaping would See section 6.2 part (i), noting it is not mitigate the loss of trees and considered that the loss of the trees could result in increased air themselves would not significantly impact pollution. upon existing air pollution levels. Reassurances are required for the Full details are requested as a condition of protection of the retained trees to the permission. the rear of the site. The extent of the footprint appears The footprint of the proposed building as though it will result in a reduction would be within the site extents with new in size of the pavement. paving proposed to the existing pavement areas, the width of these would be sufficiently wide. Other The proposed community use unit It is considered by Officers that as a whole, does not mitigate the damage the the Development would bring sufficient Development would do to the area. public benefits to outweigh any harm found. See the conclusion section of the report. The public consultation carried out The level of consultation carried out by the by the applicant prior to submitting applicant is considered acceptable and in the application was inadequate. accordance with the Council’s Statement of Community Involvement. It is unclear whether the proposed The proposed figure would not be in figure of 200 jobs would be in addition to the existing jobs at the site. addition to the existing jobs and There would also be a requirement to whether the existing employees are provide a proportion of operational jobs to local, or whether the new jobs local people, with details requested as part created would be for local people. of the s106. See section 6.9. It is unclear whether the gym would The applicant has confirmed that the gym be publically accessible. would be made available to hotel guests as well as the public. The walkway through to Colwyn Whilst this area forms outside the House from Lambeth Road should ownership of the applicant, the applicant is be kept as wide as existing for however willing to enter into a s106 security reasons, and other security obligation to provide public realm measures should be included to improvements in this area. See the section prevent ‘rough sleepers’. 6.11 and the ‘Secured by Design’ section. The proposed bar, café and There is not a policy to prevent further uses restaurant may take away business such as these in principle, and it is from other premises in the area. considered that such ancillary uses are appropriate for the type and size of hotel proposed and the location of the site in the CAZ. There is already too much The construction impacts will be sought to construction work going on in the be minimised through the submission of a area causing disruption, this would Construction Management Plan, noting it add to that. would not be possible to combine the construction with any other surrounding developments. As requested by the London Borough of Southwark, where possible construction routes would be sought away from the areas of Blackfriars Road and Elephant and Castle where there is already a lot of construction taking place. The statutory public consultation A total of 4 site notices were placed around was inadequate. the site, together with a newspaper advert and 500 consultation letters were sent. The level of public consultation was above the statutory requirement. Concern if planning permission is A further planning application would be given that the developer could required in this instance, and this would request additional floors without require a further statutory consultation. further consultation. Not material planning considerations Property owners of Colwyn House This is not a material planning should be compensated for any consideration. loss of earnings during the construction phase of the proposed development. The types of jobs created would be This is not a material planning low paid service jobs. consideration.
4.3.3 6 letters of support were received, summary of the points raised are set out below:
Summary of support Response Land Use There is a need for more hotel rooms in London, which would See section 6.1 boost the local economy. of the report. Design A building up to 13-storeys in height would not be out of place See section 6.2 and the existing building is due for replacement. of the report.
POLICIES 5.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise.
5.2 The development plan in Lambeth is the London Plan (2015) (as amended by the Minor Alterations to the London Plan 2016), and the Lambeth Local Plan (2015).
5.3 The National Planning Policy Framework was published in 2012. This document sets out the Government’s planning policies for England including the presumption in favour of sustainable development and is a material consideration in the determination of all applications.
5.4 The current planning application has been considered against all relevant national, regional and local planning policies as well as any relevant guidance. Set out below are those policies most relevant to the application, however, consideration is made against the development plan as a whole.
5.5 The London Plan (2015) (as amended by the Minor Alterations to the London Plan, 2016):
- Policy 2.10: Central Activities Zone – Strategic Priorities - Policy 2.11: Central Activities Zone – Strategic Functions - Policy 2.12: Central Activities Zone – Predominantly Local Activities - Policy 3.16: Protection and Enhancement of Social Infrastructure - Policy 4.3: Mixed Use Development and Offices - Policy 4.5: London’s Visitor Infrastructure - Policy 5.1: Climate Change Mitigation - Policy 5.2: Minimising Carbon Dioxide Emissions - Policy 5.6: Decentralised Energy Networks - Policy 5.7: Renewable Energy - Policy 5.9: Overheating and Cooling - Policy 5.15: Water Use and Supplies - Policy 5.17: Waste Capacity - Policy 5.21: Land Contamination - Policy 6.8: Coaches - Policy 6.9: Cycling - Policy 6.10: Walking - Policy 6.13: Parking - Policy 7.3: Designing Out Crime - Policy 7.6: Architecture - Policy 7.7: Location and Design of Tall and Large Buildings - Policy 7.8: Heritage Assets and Archaeology - Policy 7.10: World Heritage Sites - Policy 7.11: London View Management Framework - Policy 7.12: Implementing the London View Management Framework - Policy 7.14: Improving Air Quality - Policy 7.15: Reducing and Managing Noise, Improving and Enhancing the Acoustic Environment and Promoting Appropriate Townscapes - Policy 8.2: Planning Obligations - Policy 8.3: Community Infrastructure Levy
5.6 Lambeth Local Plan 2015 (LLP):
- Policy D4: Planning Obligations - Policy ED2: Business, Industrial and Storage Uses Outside Key Industrial Business Areas (KIBAs) - Policy ED7: Evening Economy and Food and Drink Uses - Policy ED12: Hotels and Other Visitor Accommodation - Policy ED14: Employment and Training - Policy EN1: Open Space and Biodiversity - Policy EN4: Sustainable Design and Construction - Policy EN5: Flood Risk - Policy EN6: Sustainable Drainage Systems and Water Management - Policy Q2: Amenity - Policy Q3: Community Safety - Policy Q5: Local Distinctiveness - Policy Q7: Urban Design: New Development - Policy Q9: Landscaping - Policy Q10: Trees - Policy Q12: Refuse/Recycling Storage - Policy Q13: Cycle Storage - Policy Q15: Boundary Treatments - Policy Q20: Statutory Listed Buildings - Policy Q22: Conservation Areas - Policy Q23: Undesignated Heritage Assets: Local Heritage List - Policy Q25: Views - Policy Q26: Tall and Large Buildings - Policy S2: New or Improved Community Premises - Policy T1: Sustainable Travel - Policy T2: Walking - Policy T3: Cycling - Policy T6: Assessing Impacts of Development on Transport Capacity - Policy T7: Parking - Policy T8: Servicing
5.7 Regional Guidance
5.7.1 Relevant publications from the GLA:
- Accessible London: Achieving and Inclusive Environment SPG (2014) - The Control of Dust & Emissions During Construction & Demolition SPG (2014) - Character and Context SPG (2014) - Central Activities Zone SPG (2016) - Sustainable Design and Construction SPG (2014) - London View Management Framework SPG (2012) - London World Heritage Sites SPG (2012) - Planning for Equality and Diversity in London SPG (2007) - Use of Planning Obligations in the Funding of Crossrail, and the Mayoral Community Infrastructure Levy SPG (2013)
5.8 Local Guidance / Supplementary Planning Documents (SPDs):
5.8.1 Relevant local guidance and SPDs for Lambeth:
- Advertisement & Signage Guidance - Parking Survey Guidance - Refuse & Recycling Storage Design Guide - Waste & Recycling Storage and Collection Requirements - Air Quality Planning Guidance Note - Lambeth Local Views Study
- Draft Section 106 SPD
PLANNING OFFICER’S ASSESSMENT
6.1 Land Use
6.1.1 The Site contains a 162 bedroom hotel as existing. The hotel use at the Site is well established having operated there since building’s conversion in 1998. The proposed redevelopment of the Site would result in a creating on a new 4-star hotel with a maximum of 355 bedrooms. The Development would result in an increase of 193 bedrooms.
6.1.2 London Plan Policy 4.5 states that there is a requirement to provide 40,000 net additional hotel bedrooms by 2036, of which at least 10 per cent should be wheelchair accessible. The policy also states that there is a preference for new visitor accommodation to be located either within the CAZ or a town centre where there is good public transport access to central London. This requirement is reinforced by LLP Policy ED11.
6.1.3 In August 2013, the GLA published working paper 58 – Understanding the demand for and supply of visitor accommodation in London to 2036 which revised the potential additional rooms required across London from 40,000 to 42,900 by 2036. This paper sets out net additional room estimates from 2015 to 2035 that informed the target in the London Plan 2015.
6.1.4 This study by the GLA makes it clear that the figure for net additional rooms includes all serviced accommodation - hotels, bed and breakfast establishments, guesthouses and hostels.
6.1.5 The GLA study breaks the London wide target down to indicative estimates at borough level. The indicative estimate for Lambeth is 2,000 net additional serviced rooms between 2015 and 2036 (GLA Working Paper 2013, table S2-2). This indicative estimate is included as Monitoring Indicator 15 in the monitoring framework for the adopted LLP.
6.1.6 The baseline figure for monitoring progress in Lambeth against Local Plan Monitoring Indicator 15 is the overall number of serviced rooms in the borough in March 2015.
6.1.7 The Lambeth Hotels and Other Visitor Accommodation 2016 document provides the most up-to-date data regarding hotel accommodation within the borough. The figure for completed serviced rooms in May 2013 (as outlined in the 2013 Hotels and Other Visitor Accommodation in Lambeth document) was 3,856 serviced rooms (including Hostels). According to the London Development database, the figure for net increase in serviced rooms across the borough between May 2013 and March 2015 was 578 rooms. Therefore the monitoring baseline figure for March 2015 is 4,434 serviced rooms. 6.1.8 A total of 1,257 of additional serviced rooms have either been completed since the baseline figure was set in March 2015. A further additional 462 serviced rooms are currently unimplemented or have planning permission pending a Section 106 Agreement. Were all of these to be completed, a total of 281 additional serviced rooms would be required in order to achieve the indicative target of 2,000 additional serviced rooms within Lambeth between 2015 and 2036. The application proposes a net increase of 193 bedrooms on the Site, which would not result in the indicative borough- wide London Plan target being exceeded even were all of the unimplemented permissions and pending planning permissions to be built out. It is noted that other planning applications have been submitted since this assessment, which could result in the indicative target being exceeded. However, subject to an assessment on other matters, the fact that the indicative target for the borough may be exceeded were all of these schemes to be built out is not considered to be a concern of Officers, given the existing hotel use of the site and as the borough wide target is only an indicative target for a London-wide policy target, of which this scheme would contribute towards.
6.1.9 The Site is located within the CAZ but outside the Waterloo Opportunity Area. However, as an existing hotel site in a central London location with excellent access to public transport, and located opposite the major visitor attraction of the Imperial War Museum, it considered that the proposed intensification of the hotel use is acceptable, subject to a further assessment on other matters given in the remainder of the report including design, amenity and transport impacts.
6.1.10 As noted by the applicant, the CAZ SPG indicates that no over concentration of uses should occur at the expense of other strategic land uses. The Lambeth Hotels and Other Visitor Accommodation 2016 document advises that there are approximately 2,994 serviced rooms in Bishops ward and that there are another 710 under construction, and 56 approved but not under construction. Bishops ward currently accounts for almost 68% of Lambeth’s stock of serviced rooms, however this is set to drop to 65% once all serviced rooms under construction are completed, and would further reduce to 60% if all approved serviced rooms are constructed.
6.1.11 Whilst there are other hotels located in the vicinity of the site, given the mixed character of the area and the existing land use of the Site, it is considered that the proposals would not be contrary to the requirement to prevent an over concentration of uses within the CAZ.
6.1.12 It is also relevant that the Site falls within an area which is experiencing significant growth and change. Although there are a number of serviced rooms currently being added to the existing stock in Bishops ward, this is not harming the balance of uses in the area. These additional serviced rooms are being constructed alongside a significant number of new residential dwellings, health, retail, food and drink premises, offices, student housing, public transport infrastructure and community premises. Such uses are being provided in projects such as the Shell Centre, the Waterloo Station development, Oasis Academy, Elizabeth House, and 111 Westminster Bridge Road.
Other Associated Land Uses 6.1.13 A number of ancillary facilities are proposed at the Site including a restaurant, café and bar on the ground floor, and a gym, business centre with several meeting rooms at basement level. It is considered that such uses are appropriate for a hotel with an anticipated 4-star rating, however a further assessment is required on potential amenity and transport impacts that may result from these uses. This is provided in Sections 6.4 and 6.5 below. It should however be noted that the restaurant, café and bar uses at ground floor will provide an active frontage to the building along the Kennington Road and Lambeth Road elevations, and will act as a continuation of the retail offer of the Kennington Road Local Centre which is located immediately to the north of the Site on Kennington Road. This is considered by Officers to provide an improvement on the existing situation.
Community Use/Affordable Workspace
6.1.14 The Development also includes a separate community use / affordable workspace within a 115sqm unit located at the western end of the site along Lambeth Road. The applicant has indicated that there has been interest for the use of this unit by local education institutions, namely Morley College and Lambeth College. To ensure that the unit is occupied, the applicant has also proposed that this unit could provide affordable workspace. As the applicants are offering affordable workspace as possible use for the unit Officers consider that it would be appropriate to secure this through a clause in the Section 106 Agreement. Nevertheless, both uses are supported in this area by LLP Policies ED2 and S2 given the Site’s location in the CAZ with a main road frontage and with excellent public transport links.
6.2 Conservation and Urban Design
6.2.1 This section of the report considers the conservation (heritage) and urban design matters arising from the Development. It is set out below under the following sub headings:
(a) Scale, massing, layout and appearance
(b) Tall buildings and views
(c) Legislative and national policy considerations
(d) Impact on heritage assets: Conservation Areas
(e) Impact on heritage assets: Listed Buildings
(f) Impact on heritage assets: Locally Listed Buildings/Structures and Archaeological Priority Area
(g) Impact upon heritage assets: Summary
(h) Assessment of harm versus benefits
(i) Public realm improvements, trees and landscaping
6.2.2 The Council’s Conservation & Design Officer’s comments are cross-referred within the following sub-sections below where relevant.
(a) Scale, massing, layout and appearance
6.2.3 LLP Policy Q5 states that development should provide a positive response to the local context and historical character, and where proposals deviate from this, it should be demonstrated how the proposal clearly delivers design excellence and how it will make a positive contribution to its local and historic context.
6.2.4 LLP Policy Q7 seeks new development to be of a high quality design which has a bulk, scale, mass, siting, building line and orientation which adequately preserves or enhances the prevailing local character. It should be built of durable, robust and low- maintenance materials and have well considered fenestration.
6.2.5 The footprint of the existing building is set back from the corner of Kennington Road and Lambeth Road, with landscaping and car parking provided to the front. The proposed building would be sited close to this junction and would be tallest in this part of the Site. As a result of this, the building would have a greater visual prominence at the junction of these two roads. This on its own is not considered to be harmful to the character of the area, with a further assessment on the loss of trees given later in the report.
Figure 9: The tallest section of the building would be sited at the junction of Kennington Road and Lambeth Road
6.2.6 As explained, the tallest section of the building would be positioned at the junction of Kennington Road and Lambeth Road. A further analysis on the principle of a tall building and its impact on local views is given later in the report. The massing is however considered acceptable, noting the appropriate step-downs that would be provided, with the northern and western wings of the building stepping-down to a similar height as existing, which would respect the scale of the local context of the buildings to the west on Lambeth Road and to the north on Kennington Road.
Figure 10: Lambeth Road elevation showing how the building would step down toward the adjacent properties
Figure 11: Elevation of the site from Cosser Street, showing Colwyn House to the right-hand side of the elevation
6.2.7 In terms of the detailed design, it is considered that this is of a high quality and the final choice of a light coloured cream brick is welcomed. The pale brick colour positively responds to the stock brick tones that contribute to Lambeth’s local distinctiveness. The building would be well grounded with the use of double height bays at ground/mezzanine and first/second floors, providing sufficient importance to the ground floor uses. The top of the building would have a glazed lightweight appearance with metal fins to provide screening, with the use of metal being closely tied to its proposed use within the ‘punched’ window openings below, which themselves are considered to be well ordered and a positive response to the local distinctiveness of the area surrounding the site. Furthermore, the use of curved glass and brickwork particularly at the corner of the tallest element of the building at the junction of Kennington Road and Lambeth Road, would provide greater importance to the corners of the building and added articulation to the overall design of the building.
Figure 12: Elevational treatment to lower section with use of double height bays at ground/mezzanine and first/second floors
Figure 13: Treatment of the top of the building
6.2.8 In summary, it is considered that the building will have a calm and well-mannered character, which is important given the prominence of the Site and the presence of numerous heritage assets nearby (assess later in the report). The proposed building would represent a significant improvement on the existing hotel.
6.2.9 As stated by the Conservation and Design Officer, the indicative detailed drawings provided within the Design and Access Statement are welcomed, but conditions are recommended so that full detailed drawings are provided together with sample materials and sample window and façade details.
(b) Tall buildings and views analysis
6.2.10 The report will now turn to the principle of a tall building as part of the development, with this being one of the main points for objection following public consultation.
6.2.11 In terms of the height of the proposed building, at its tallest point it would be 13 storeys (43 metres high). The Site is not located within an area which has been identified as being inappropriate for tall buildings as set out by LLP Policy Q26. 6.2.12 LLP Policy Q26 (tall buildings) adopts an ‘impact led’ approach towards the assessment and is supportive of tall building development where it is not harmful. This approach was in part influenced by recognition that the northern half of Lambeth is characterised by post-war and recent tall buildings– solo and in groups - which are an established characteristic of Lambeth’s built form. In this instance Officers do not consider the impact of the building will be harmful.
6.2.13 There are existing tall building on the Kennington Road and Lambeth Road junction and the proposed building is of a comparable height. The principle of height in this location is not considered in itself problematic in townscape terms. The placing of the tallest element of the proposal on the corner of Lambeth Road is appropriate given the importance of this section of the Site. Furthermore, the careful stepping down to the west is considered a positive response to the setting of the sensitive historic buildings along Lambeth Road.
6.2.14 The Site falls within the London View Management Framework (LVMF) View 19 (Lambeth Bridge) and in the backdrop of View 23 (Bridge over the Serpentine, Hyde Park to Westminster) and View 27 (Parliament Square to Palace of Westminster). The Site is also within the local viewing corridors of the Brockwell Park Panoramic View (View N from Brockwell Park to the City), and Norwood Park Panoramic View. London Plan Policies 7.10, 7.11 and 7.12 and LLP Policy Q25 seek to prevent harm being caused to the significance of strategic views.
Figure 14: LVMF 19A.1 – Lambeth Bridge (downstream)
6.2.15 As shown in Figure 14, (the Development is illustrated by a dotted line) the proposal would have no impact upon the LVMF view from Lambeth Bridge towards Lambeth Palace, as the Development would be completely screened from view by the palace itself. In terms of the other protected views, the Site only falls within the backdrop of these views and Officers consider that it would not have an adverse impact upon them.
Figure 15: View from west of Imperial War Museum over Geraldine Mary Harmsworth Park as existing
6.2.16 It is acknowledged that in some areas surrounding the Site, the building would result in a loss of openness and have a significantly greater visual prominence when compared with the existing building. This is particularly evident when stood within the adjacent Geraldine Mary Harmsworth Park and in the grounds of the Imperial War Museum. As stated above, Officers consider that the tall element of the building has been appropriately sited, and in conjunction with the high architectural quality of the building, it would not be visually harmful, especially in the areas closer to the Site where the articulation of the design can receive a greater level of appreciated.
Figure 16: View from Kennington Road to the south
Figure 17: View from Lambeth Road to the west
6.2.17 The views analysis provided sufficiently demonstrates that the proposal will not result in harm being caused to the significance of strategic or local views.
(c) Legislative and national policy considerations
6.2.18 This section sets out the legislative and national policy context for the officer assessment of the impact of the development proposal on the historic environment and its heritage assets.
Legislative Framework
6.2.19 The following legal commentary is provided:
6.2.20 Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 (“PLBCAA”) provides that in considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority 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.
6.2.21 Section 72(1) PLBCAA provides that in the exercise, with respect to any buildings or other land in a conservation area, of any functions under or by virtue of (amongst others) the planning Acts, special attention shall be paid to the desirability of preserving or enhancing the character or appearance of the conservation area.
6.2.22 The South Lakeland District Council v Secretary of State for the Environment case and the Barnwell Manor case (East Northamptonshire DC v SSCLG) establish that “preserving” in both s.66 and s.72 means “doing no harm’. National Policy
6.2.23 Paragraph 17 of the NPPF sets out 12 “core planning principles” that should underpin both plan-making and decision-taking. Those principles include the following:
“Planning should always seek to secure high quality design and should conserve heritage assets in a manner appropriate to their significance so that they can be enjoyed for their contribution to the quality of life of this and future generation”.
6.2.24 The NPPF defines a “heritage asset” as:
“A building, monument, site place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest”.
6.2.25 The definition includes both designated heritage assets (of which, Listed Buildings and Conservation Areas are relevant here) and assets identified by the local planning authority (including local listing)
6.2.26 “Significance” is defined within the NPPF as being:
“the value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic. Significance derives from a heritage asset’s physical presence, but also from its “setting”.
6.2.27 Paragraph 129 of the NPPF requires local planning authorities to identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting its setting), taking account of the available evidence and any necessary expertise. That assessment should then be taken into account when considering the impact of the proposal on the heritage asset, to avoid or minimise conflict between the heritage asset’s conservation and any aspect of the proposal.
6.2.28 Paragraphs 131 and 132 of the NPPF provide as follows:
131. In determining planning applications, local planning authorities should take account of:
the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation;
the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and
the desirability of new development making a positive contribution to local character and distinctiveness.
132. When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional. 6.2.29 Paragraph 133 of the NPPF deals with substantial harm to or total loss of significance of significance of a designated heritage asset.
6.2.30 Paragraph 134 of the NPPF provides that where a development proposal will lead to less than substantial harm to the significance of the designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.
6.2.31 Paragraph 135 of the NPPF deals with non-designated heritage assets as follows:
135. The effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect directly or indirectly non designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.
6.2.32 Paragraphs 137 and 138 of the NPPF are as follows:
137. Local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites and within the setting of heritage assets to enhance or better reveal their significance. Proposals that preserve those elements of the setting that make a positive contribution to or better reveal the significance of the asset should be treated favourably.
138. Not all elements of a World Heritage Site or Conservation Area will necessarily contribute to its significance. Loss of a building (or other element) which makes a positive contribution to the significance of the Conservation Area or World Heritage Site should be treated either as substantial harm under paragraph 133 or less than substantial harm under paragraph 134, as appropriate, taking into account the relative significance of the element affected and its contribution to the significance of the Conservation Area or World Heritage Site as a whole.
6.2.33 Officers have also had regard to the Planning Practice Guidance in respect of conserving and enhancing the historic environment.
Approach required
6.2.34 Turning to consider the application of the legislative and policy requirements set out above, the first step is for the decision-maker to consider each of the designated heritage assets (referred to hereafter simply as “heritage assets”) which would be affected by the proposed development in turn and assess whether the proposed development would result in any harm to the heritage asset.
6.2.35 The decision of the Court of Appeal in Barnwell Manor confirms that the assessment of the degree of harm to the heritage asset is a matter for the planning judgement of the decision-maker.
6.2.36 However, where the decision-maker concludes that there would be some harm to the heritage asset, in deciding whether that harm would be outweighed by the advantages of the proposed development (in the course of undertaking the analysis required by s.38(6) PCPA 2004) the decision-maker is not free to give the harm such weight as the decision-maker thinks appropriate. Rather, Barnwell Manor establishes that a finding of harm to a heritage asset is a consideration to which the decision maker must give considerable importance and weight in carrying out the balancing exercise. 6.2.37 There is therefore a “strong presumption” against granting planning permission for development which would harm a heritage asset. In the Forge Field case the High Court explained that the presumption is a statutory one. It is not irrebuttable. It can be outweighed by material considerations powerful enough to do so. But a local planning authority can only properly strike the balance between harm to a heritage asset on the one hand and planning benefits on the other if it is conscious of the statutory presumption in favour of preservation and if it demonstrably applies that presumption to the proposal it is considering.
6.2.38 The case-law also establishes that even where the harm identified is less than substantial (i.e. falls within paragraph 134 of the NPPF), that harm must still be given considerable importance and weight.
6.2.39 Where more than one heritage asset would be harmed by the proposed development, the decision-maker also needs to ensure that when the balancing exercise in undertaken, the cumulative effect of those several harms to individual assets is properly considered.
6.2.40 What follows is an Officer assessment of the extent of harm which would result from the Development to the scoped heritage assets provided by the applicant as part of its submission. This includes Conservation Areas, and neighbouring Listed Buildings. Officers agree with the scope of assessment provided by the applicants. Both an individual assessment against each heritage asset as well a cumulative assessment is provided. This is then followed by an assessment of the public benefits of the proposals.
6.2.41 In reaching their assessment, Officers have taken into account the Design Officer comments. Officers have also taken into account the judgements reached in the Applicant’s Townscape, Visual and Heritage Statement and the comments of HE.
(d) Impact on Conservation Areas
6.2.42 The following conservation areas either adjoin the Site or are located nearby to the Site:
- The Albert Embankment Conservation Area, located to the north-west of the Site,
- The Lambeth Walk and China Walk Conservation Area, located to the south of the Site across Lambeth Road,
- The West Square Conservation Area, which is sited to the south-east of the Site across Kennington Road and Lambeth Road within the adjacent London Borough of Southwark,
- The Walcot Conservation Area, which is sited to the south of the Site,
- The Lambeth Palace Conservation Area, which is sited to the west of the Site,
- The Lower Marsh Conservation Area, which is sited to the north of the Site.
Figure 18: The conservation areas that surround the Site
6.2.43 The applicant’s comprehensive Townscape, Visual and Heritage Assessment (TVHA) is based on viewpoints agreed with Officers at pre-application stage. These include view points from within the adjacent London Borough of Southwark. It is considered that although a new building would be visible in a historic context, it doesn’t automatically mean that its impact would be adverse. Consideration has to be given to the form and character of the building, its materials and detailing etc. As stated above, Officers consider the design of the Development to be of a high quality and appropriate within its context. In the streetscene views provided by the applicant the building appears dignified as a result of a combination of the regular punched openings, simple and robust forms and the use of a pale cream brick. The impact on the setting of the surrounding conservation areas is considered by Officers to be negligible. Although it isn’t evident in any of the views provided, the building will also read alongside the existing tall buildings on the south side of Lambeth Road albeit it has a different (which Officers consider to be more contextual) character. Officers therefore consider that no harm would be caused to the setting of any of the surrounding designated conservation areas.
(e) Impact on Statutory Listed Buildings
6.2.44 The following statutory listed buildings surround the Site:
- Grade I listed Lambeth Palace, located to the west of the Site, - Grade II listed Imperial War Museum, located to the south-east of the Site within the adjacent London Borough of Southwark, - Grade II listed terrace of 136-160 Lambeth Road, located to the west of the Site, - Grade II listed buildings of 53-57 Kennington Road, and the adjacent locally listed buildings of 59 to 69 Kennington Road, all located opposite the Site to the east, - Grade II listed buildings of 96-102 Lambeth Road, and the adjacent locally listed 94 Lambeth Road, all located to the east of the Site. 6.2.45 As per the national policy and LLP Policy Q20, development should conserve and not harm the significance/special interest of statutory listed buildings and should not harm the significance of their setting (including views to and from).
Imperial War Museum (Grade II Listed)
6.2.46 Similar to the assessment given above regarding impact on conservation areas, it is considered that although a new building would be visible in a historic context to a listed building, it doesn’t automatically mean that its impact would be adverse. This is particularly apparent with regard to the setting of the Imperial War Museum. View 5 in the applicant’s TVHA shows the view of the Development from Mary Harmsworth Park and next to the Grade II listed Imperial War Museum. The building would be clearly visible from this view, and it is noted that the GLA consider that less than substantial harm would be caused. However, given the distance of the Site from the Imperial War Museum, the comparable height of the adjacent Lambeth Towers and the high standard of design as previously discussed, it is considered by Officers that no harm would be caused to the setting and historical significance of the Imperial War Museum.
Figure 19: View from Imperial War Museum as existing
Figure 20: View from Imperial War Museum as proposed
Figure 21: View from west of Imperial War Museum over Geraldine Mary Harmsworth Park as existing
Figure 22: View from west of Imperial War Museum over Geraldine Mary Harmsworth Park as proposed
Lambeth Palace (Grade I Listed)
6.2.47 As part of the views analysis provided in the TVHA, a number of wireframe outlines have been provided on the Development in the backdrop of Lambeth Palace, a Grade I listed building. It has been demonstrated that it would not be possible to see any of the proposed building in these important views of Lambeth Palace. Where any parts of the building would be visible (as shown in View 13 and possibly 14), these would only be very minor glimpses of the building above the roofline and only when stood on a small part of Lambeth Bridge or possibly on the embankment north of the river. Furthermore, when in leaf, the trees in front of Lambeth Palace would remove any intrusions from view entirely. Given the very minor impact on the view of Lambeth Palace from only a select number of viewpoints, Officers considered that no harm would be caused to the setting and historical significance of the Imperial War Museum. Again, it is noted that both Historic England and the GLA consider that less than substantial harm would be caused.
Figure 23: View of Lambeth Palace from Lambeth Bridge, with the proposed building outlined and not visible in this view
Figure 24: View of Lambeth Palace from Lambeth Bridge, where the very top of the building would be visible, but not considered harmful
Figure 25: View of Lambeth Palace from the north side of the river, where it would not be possible to see the building in the backdrop
Other Listed Buildings
6.2.48 With regard to the potential impact of the Development on the other statutory listed buildings that surround the Site, it is considered that their historical significance and setting would be preserved and no harm would result. In terms of the statutory listed buildings that are closer to the Site than Lambeth Palace in particular, the high quality design and justification for the additional height at this important junction of Kennington Road and Lambeth Road, would be more apparent in these areas, providing more legibility to the local streetscape.
(f) Impact on Locally Listed Buildings/Structures and Archaeological Priority Area
6.2.49 The following locally listed buildings/structures and archaeological priority area surround the Site:
- 59 to 69 Kennington Road, located opposite the Site to the east, - 94 Lambeth Road, located to the east of the Site, - Public house located on Cosser Street (Steam Engine), - Police Station, located to the north of the Site on Kennington Road, - Public house, located to the west of the Site at the junction of Cosser Street and Hercules Road, - Water trough located on the pavement immediately outside of the Site on Lambeth Road and within the Site boundary, - North Lambeth Archaeological Priority Area. 6.2.50 It is considered that the Development would preserve the setting of the buildings and structures on the local list that surround the Site. In terms of the water trough, as this is located in the area where public realm enhancements are proposed, a Section 106 obligation will be required to ensure that this is appropriately re-installed on the pavement area outside the Site. Furthermore, with regard to the Archaeological Priority Area which the Site is located within, comments were received from Historic England noting that the desk based Archaeological Assessment found that the Site exhibits moderate potential for prehistoric remains to be present, low-moderate potential for Roman and post-medieval archaeological deposits to be present and a low potential for all other archaeological periods. A condition has been requested by Historic England to ensure that any archaeological remains of interest are appropriately preserved.
Figure 26: Locally listed water trough located outside the Site on Kennington Road
(g) Impact upon heritage assets: summary
6.2.51 In conclusion, whilst the Development would be clearly visible in the setting of a number of heritage assets, given the minor intrusions to views of significance such as Lambeth Palace, and given the conclusions regarding the detailed design as explained in subsections (a) and (b) of this section, it is considered that the Development would result in no harm on the surrounding heritage assets.
(h) Assessment of harm versus benefits
6.2.52 Public benefits are defined within the NPPG. It advises that public benefits:
“may follow from many developments and could be anything that delivers economic, social or environmental progress as described in the National Planning Policy Framework. Public benefits should flow from the proposed development. They should be of a nature of scale to be of benefit to the public at large and should not just be a private benefit. However, benefits do not always have to be visible or accessible to the public in order to be genuine public benefits.
Public benefits may include heritage benefits” 6.2.53 Officers have concluded that no harm would be caused to any of the heritage assets surrounding the Site as a result of the Development. It is noted however that Historic England consider that less than substantial harm would be caused to the setting of the Grade I listed Lambeth Palace, and the GLA consider that as well as this, less than substantial harm would be caused to the setting of the Grade II listed Imperial War Museum. Were Members to agree with this assessment or consider that less than substantial harm would be caused to any of the other heritage assets surrounding the Site, it is Officer’s advice that sufficient public benefits would arise from the development to outweigh this harm. The Development would as such accord with paragraph 134 of the NPPF. In deciding whether the public benefits outweigh harm members should apply the test explained in paragraphs 6.2.34 to 6.2.41 above. Members are reminded that a finding of harm to a heritage asset is a consideration to which the decision maker must give considerable importance and weight in carrying out the balancing exercise.
6.2.54 In terms of the public benefits that would arise from the Development, these are discussed throughout the report, but in summary these are considered to be as follows:
Social/Community Benefits
- Public realm improvements - Ancillary retail uses to provide an active frontage along Kennington Road and Lambeth Road, with natural surveillance this provides - Community use / affordable workspace unit
Economic Benefits
- Providing a viable future for the site - Investment in local economy through use of hotel - Local job creation, with S106 obligations to require minimum percentage of local employees through construction phase and during end use of site, and financial contributions towards employment and training
Environmental Benefits
- Optimising brownfield land - High quality architectural design - Improved recycling facilities - Promotion of more sustainable methods of transport to and from the Site - Sustainable features within the design - High quality landscaping scheme with enhanced biodiversity
(i) Public realm improvements, trees and landscaping
6.2.55 The application proposes public realm improvements around the Site in the form of a well thought out hard and soft landscaping scheme. A number of trees are proposed to be removed, including street trees, with a new planting scheme proposed to mitigate their loss.
Figure 27: Trees to be removed are hatched in red
6.2.56 The following trees are proposed to be removed:
Tree Number and Type Category Location H1 – Hawthorn B Along Lambeth Road boundary Along Kennington Road H2 – Hawthorn B boundary Along Kennington Road G6 (T1) – Raywood Ash C boundary Along Kennington Road G6 (T2) – Raywood Ash C boundary G8 (T1) – Raywood Ash C Along Lambeth Road boundary G8 (T2) – Raywood Ash C Along Lambeth Road boundary G8 (T3) – Raywood Ash C Along Lambeth Road boundary G8 (T4) – Raywood Ash C Along Lambeth Road boundary T9 – Raywood Ash C Along Lambeth Road boundary T10 – Tree of Heaven C Along Lambeth Road boundary T11 – Tree of Heaven C Along Lambeth Road boundary T12 – Tree of Heaven C Along Lambeth Road boundary Along Lambeth Road boundary G13 (T1) – Tree of Heaven B at western end of site Along Lambeth Road boundary G13 (T2) – Tree of Heaven B at western end of site Located within the site by T14 – London Plane B servicing area off Morton Place T2 – London Plane A Along Cosser Street boundary T3 – London Plane A Along Cosser Street boundary
6.2.57 The existing street trees along Kennington Road and Lambeth Road would be retained, as would the large London Plane street tree located in Morton Place. The only on-site tree to be retained would be the large London Plane tree (T15) located at the rear of the site in Morton Place.
6.2.58 A new high quality planting scheme is proposed to the front of the Site on Kennington Road and three additional plane trees would be planted as street trees on Kennington Road (one tree proposed) and Lambeth Road (two trees proposed) to fill existing gaps. A further five Birch trees and three Field Maple trees are proposed to be installed along Kennington Road immediately outside the Site, adjacent to the new on-site landscaping scheme to the front of the proposed new hotel. Figure 28: Proposed public realm scheme
6.2.59 In terms of new on-site planting, it is proposed to plant three trees along Cosser Street to replace the two on-site plane trees that are to be removed; and to install a number of small and large trees to the front of the Site.
6.2.60 New planters and public seating would also be provided which are supported and would be subject to further design considerations when details are submitted via a landscaping condition.
6.2.61 In order to provide a coherent hard landscaping scheme, new paving is proposed across the Site extending into the adopted areas of footpath. York stone is proposed for the adopted areas of footpath on Kennington Road and Lambeth Road, a material used widely throughout the Borough and the TfL network, allowing for ready repair and replacement by statutory service providers, if required. New landscaping would also be installed to the rear of the Site, including the existing alleyway between the Site and 130 Lambeth Road which provides access to the Briant Estate from Lambeth Road. This is currently a closed-off space, but the security of this space would be much improved following landscaping improvements, less imposing boundary treatments and by providing natural surveillance from the Site onto this area.
Figure 29: The existing alleyway to the Briant Estate from Lambeth Road and existing boundary treatment to this area
6.2.62 A raised table is proposed at the junction of Cosser Street and Kennington Road to provide level access to the front of the Site, which would itself be a shared surface for vehicles and pedestrians and help slow traffic when entering the site. This would be constructed from granite kerbs to top and bottom, and Macadam surfaces to the ramp face.
6.2.63 A raised table and shared surface is also proposed along Morton Place, largely due to the distorted highway and pavement caused by the mature London Plane street tree, which is proposed to be retained. Similar materials are proposed as with the new raised table to Cosser Street, with products such as City Pave by Tobermore used for the granite paving.
Figure 30: Morton Place, which will be repaved as a shared surface, helping to address the issue of the buckled pavement caused by the existing street tree which will be retained
6.2.64 It is acknowledged that the Development would result in a significant loss of existing tree coverage. The majority of the existing trees that would be lost are located to the front of the Site around the existing car parking area, and along the Lambeth Road boundary. These trees are mostly poor specimens and have become rather misshapen and untidy in appearance due to their close spacing along the southern boundary of the Site. The Development is however proposed to be car-free, and the car parking area is not being retained. In order to make the best use of the Site, it has been proposed to remove these trees and position the tallest element of the building in this location, which has otherwise been found acceptable. The hard and soft landscaping scheme proposed would open this frontage area up to pedestrians, where the Site at present is closed-off at the front from the public footways of Kennington Road and Lambeth Road.
6.2.65 Furthermore, trees to the rear of the Site and along Cosser Street would be removed, also to allow for footprint of the building to make better use of the Site and to therefore extend into these areas. Officers consider that this can be supported given the comprehensive and high quality hard and soft landscaping scheme proposed.
6.2.66 In summary, the proposed hard and soft landscaping scheme is of a high standard and would provide improvements to all sides of the Site, both within the Site boundary and outside the Site. The loss of existing trees that by the Development would be suitably mitigated by the well thought out replacement tree planting, landscaping and public realm scheme. Conditions and Section 106 obligations would ensure the delivery of these landscaping and public realm improvements, and also to protect existing retained trees during construction.
Figure 31: Illustrative view of the public realm works from Cosser Street along Kennington Road
6.3 Standard of Hotel Accommodation 6.3.1 In terms of the accessibility of the hotel against the policy requirement to provide rooms of which at least 10 per cent are wheelchair accessible, it is proposed that 5 per cent of the rooms would be constructed and fitted out to be fully accessible on completion. A further 4.8 per cent of the rooms would be sized and laid out to be fully accessible but would not have the final fittings provided. Should a demand arise for additional accessible rooms, these would be able to be easily fitted out without major construction work. Therefore, a total of 9.8 per cent of the rooms would be either accessible or readily adaptable, which is considered acceptable.
6.3.2 With regard to the standard of hotel accommodation, the applicants have stated that the hotel will be 4 star rated. All rooms would have access to a window, and whilst the rooms to the rear of the Site facing Colwyn House would be overshadowed somewhat by the surrounding development, given the rooms would be occupied on a short term basis, this is considered acceptable. The quality of the accommodation is considered to be in accordance with the requirement of LLP Policy ED12(c).
6.4 Amenity
6.4.1 The Development would increase the footprint, bulk and massing when compared to the existing building, as well as bringing about an intensification in the uses at the Site. The surrounding area has a mix of building heights and uses, these are however regarded to be predominantly residential in nature. The following section provides a background to the surrounding properties closest to the Site.
6.4.2 To the west of the Site is Colwyn House (a 5-storey block of flats, Nos. 1-25), and 130 and 132 Lambeth Road, which form the end of the terrace along Lambeth Road, noting that the adjoining property (No. 130 Lambeth Road), does not have windows to the flank elevation facing the Site. The Steam Engine Public House is also located west of the Site but does not provided any residential accommodation above.
6.4.3 57-69 Kennington Road is to the east of the Site. These properties are typically 4- storeys in height with commercial uses at ground floor and residential uses on the upper floors.
6.4.4 To the north of the Site are 1-7 McAuley Close, these are 2-storey houses with rear gardens, and 2-3 Cosser Street, which have three floors of flats above ground floor commercial uses.
6.4.5 To the south of the Site is International House, which is a block of student accommodation, and Lambeth Towers which is an 11-storey block of flats with ground floor commercial uses.
6.4.6 LLP Policy Q2 seeks to protect the amenity of existing neighbours and the visual amenity of the community as a whole. This is measured in terms of potential impacts in relation to outlook and privacy, daylight and sunlight, noise and vibration, microclimate-wind, air quality and impacts during construction. An assessment of the Development’s impact upon amenity is provided below.
Daylight and Sunlight 6.4.1 A Daylight/Sunlight Assessment has been undertaken by Point 2 Surveyors on behalf of the applicants. The Local Planning Authority appointed Schroeders Begg surveyors (SB) review to the submission. As is usual practice by the LPA (amongst others) the instruction to SB was limited to advise on the suitability of the methodology of assessment carried out by the Point 2 Surveyors, the criteria employed for the study, the conclusions reached from those criteria and the results obtained. SB did not run their own model of the Site or calculations, but relied upon that provided by Point 2 Surveyors.
Methodology
6.4.2 Two methods of measurement should be used to measure daylight impacts: (1) Vertical Sky Component (VSC); and (2) Daylight Distribution (DD). VSC assesses the quantum of skylight falling on a vertical window and DD (also referred to as No Sky Line) the distribution of direct skylight in a room space.
6.4.3 VSC is calculated from the centre of a window on the outward face and measures the amount of light available on a vertical wall or window following the introduction of visible barriers, such as buildings. The maximum VSC value is almost 40% for a completely unobstructed vertical wall or window. The BRE guidance suggests that if the VSC is greater than 27%, enough skylight should still be reaching the window of the existing building. Any reduction below this level should be kept to a minimum.
6.4.4 Should the VSC with development be both less than 27% and less than 0.8 times its former value, occupants of the existing building shall notice a reduction in the amount of skylight they receive. The guide says: “the area lit by the window is likely to appear gloomier, and electric lighting will be needed more of the time”.
6.4.5 The DD method is a measure of the distribution of daylight at the ‘working plane’ within a room. For the DD assessment the ‘working plane’ means a horizontal ‘desktop’ plane 0.85m in height for residential properties. The DD divides those areas of the working plane which can receive direct sky light from those which cannot. If a significant area of the working plane receives no direct sky light, then the distribution of daylight in the room will be poor and supplementary electric lighting may be required. The BRE Guidelines state that if the area of a room that does receive direct sky light is reduced by more than 20% of its former value, then this would be noticeable to its occupants.
6.4.6 For the benefit of the reader, it should be noted that the number of points of assessment vary between the two differing methods of measurements. VSC looks at windows, of which there can be more than one serving a room. DD looks at rooms only.
6.4.7 Typically, it is recommended that VSC and DD are utilised for consideration on daylight losses resulting from the proposal to existing neighbouring residential since it is a comparative test.
6.4.8 The BRE Guide advice is not mandatory since ‘although it gives numerical guidelines, these should be interpreted flexibly since natural lighting is only one of many factors in site layout design’. Whilst the BRE Guide does not categorise levels of impact beyond ‘noticeable’, standardised EIA terminology can be utilised to consider classification of the impacts on neighbouring properties, especially in respect of impacts of ‘minor adverse effect’, ‘moderate adverse effect’ and ‘major adverse effect’ with definitions including as follows below.
6.4.9 Factors tending towards minor adverse impact include:
- Only a small number of windows or limited area of open space are affected; - The loss of light is only marginally outside the guidelines; - An affected room has other sources of skylight or sunlight; - The affected building or open space only has a low level requirement for skylight or sunlight; - There are particular reasons why an alternative less stringent guideline should be applied (such as the mirror scenario).
6.4.10 Factors tending towards a major adverse impact include:
- A large number of windows or large area of open space are affected; - Where loss of light is greater than 50% of guideline levels; - All the windows in a particular property are affected; - The affected indoor or outdoor spaces have a particularly strong requirement for skylight or sunlight (e.g. living room in a dwelling or a children’s playground).
6.4.11 Sunlight is measured using Annual Probable Sunlight Hours (APSH). Sunlight is measured using a sun indicator which contains 100 spots, each representing 1% of APSH. Where no obstruction exists, the total APSH would amount to 1486 hours and therefore each spot equates to 14.86 hours (for London) of the total annual sunlight hours. The number of spots is calculated for the Baseline and Proposed Development scenarios during the whole year and also during the winter period and a comparison made between the two. This provides a percentage of APSH for each of the time periods for each window assessed.
6.4.12 The 2011 BRE Guidelines note that:
6.4.13 “In housing, the main requirement for sunlight is in living rooms, where it is valued at any time of day, but especially in the afternoon…It is viewed as less important in bedrooms and in kitchens, where people prefer it in the morning rather than the afternoon”
6.4.14 “all main living rooms of dwellings…should be checked if they have a window facing within 90° of due south. Kitchens and bedrooms are less important, although care should be taken not to block too much sun”; and
6.4.15 “If the main living room to a dwelling has a main window facing within 90° of due north, but a secondary window facing within 90° of due south, sunlight to the secondary window should be checked.”
6.4.16 “…a south facing window will, in general, receive most sunlight, while a north facing one will receive it only on a handful of occasions. East and west facing windows will receive sunlight only at certain times of day”.
6.4.17 “Balconies and overhangs above an existing window tend to block sunlight, especially in summer. Even a modest obstruction opposite may result in a large relative impact on the sunlight received”.
6.4.18 With regard to existing surrounding receptors, the BRE Guidelines provide that a window may be adversely affected if a point at the centre of the window receives
- Less than 25% of the APSH during the whole year, of which 5% APSH must be in the winter period; and
- Receives less than 0.8 times its former sunlight hours in either time period; and
- Has a reduction in sunlight for the whole year more than 4% APSH. 6.4.19 Overshadowing: The transient overshadowing plots illustrate the extent of the gardens and amenity spaces assessed that will receive direct sunlight as existing and proposed at a given time. The transient overshadowing plots comprise an illustrative tool showing the changing levels of direct sunlight received by amenity space throughout the day on the dates assessed.
6.4.20 The BRE ‘test’ for a development’s overshadowing impacts relates to the area of an amenity space that receives more than two hours of sunlight on 21 March (the Spring Equinox). The guide states: “…for it to appear adequately sunlit throughout the year, at least half of a garden or amenity area should receive at least two hours of sunlight on 21 March. If, as a result of new development, an existing garden or amenity area does not meet the above, and the area which can receive two hours of sun on 21 March is less than 0.8 times its former value, then the loss of sunlight is likely to be noticeable”.
6.4.21 As a minimum the assessment has therefore considered the area of amenity the gardens and amenity spaces assessed that can receive more than two hours of direct sunlight on this date.
Scope of the assessment
6.4.22 Residential windows and rooms of the following properties have been assessed for the purposes of daylight and sunlight impacts as a result of the Development:
1) Colwyn House, Briant Estate 2) The Steam Engine pub 3) 1-7 McAuley Close (odd numbers only) 4) 2-3 Cosser Street 5) 52 Kennington Road (Se1 Dental Centre) 6) 57-69 Kennington Road (odd numbers only) 7) International House 8) Lambeth Mission and St. Mary’s 9) Lambeth Walk Group Practice 10) 44 Kennington Road (Pharmacy) 11) 130 Lambeth Road 12) 132 Lambeth Road
6.4.23 Figure 32 below shows the assessment models which were used.
Figure 32: Assessment models used, existing and proposed
6.4.24 Point 2 Surveyors also tested the neighbouring gardens to Colwyn House, 130 and 132 Lambeth Road, The Steam Engine pub, and 1-7 McAuley Close (odd numbers only).
Assessment of the Results – Daylight to existing residential buildings
6.4.25 The assessment provided demonstrates that the Development would adhere to BRE Guide target criteria with regard to daylight for all of the surrounding properties tested, other than Colwyn House, 63 and 65 Kennington Road, and International House. The following provides an assessment on where there would be failings. 6.4.26 In terms of the Vertical Sky Component (VSC), reductions in daylight to neighbouring properties from the effect of the Development adhere closely to the BRE Guide target criteria with reductions not being greater than 20% with the main exception of Colwyn House to the west and 3 No. isolated rooms within International House.
6.4.27 The daylight losses to International House in terms of VSC are not considered to be significant in the context of the Site. In terms of Colwyn House, the windows which face towards the Site are typically set-back within a deck access walkway and not all windows serve ‘habitable rooms’ / applicable for assessment; it is apparent that many windows serve hallways, bathrooms and kitchen windows (‘galley’ style / not anticipated to dine within). However, there are clearly a number of habitable rooms which face the site within Colwyn House. These are mainly bedrooms which are set- in the deck access, with living rooms to the very southern end of the wing of the building that faces the Site (labelled within the Daylight and Sunlight Report as rooms R1/10, R1/11, R1/12, R1/13 and R1/14). It should be noted that these rooms are not hindered by the deck access. The rooms at the junction of the wing facing the Site and the northern wing are also not hindered by the deck access and are mostly used as living rooms. These are labelled within the submitted Daylight and Sunlight Report as rooms R15/10, R16/11, R16/12, R16/13 and R16/14. Following a site visit by Officers it is noted that these rooms are larger than shown in the submitted Daylight and Sunlight Report and do in fact benefit from a secondary window to the north. An assessment is applicable to such rooms as highlighted, but it should be noted that the majority of the habitable rooms including the living rooms are to the rear elevation facing onto the communal garden area to the south-west.
Figure 33: Typical arrangement of the flats within 1-25 Colwyn House facing the Site. The windows either side of the entrances either serve toilets, bathrooms or additional windows to the kitchens, the single pane window to the left of the image serves a kitchen, and the three- pane window serves a bedroom
Figure 34: Colwyn House within the Briant Estate (rooms to end of block to left serve living rooms and labelled as R1/10, R1/11, R1/12, R1/13 and R1/14 within the submitted Daylight and Sunlight Report
Figure 35: The rear of 1-25 Colwyn House; all flats benefit from an aspect to the rear to the south-west
6.4.28 Reductions in VSC for bedrooms and living rooms to 1-25 Colwyn House typically range up to 29% at ground floor, 27% at 2nd / mid floor and 27% at 4th / top floor, which is considered acceptable in this urban context, where due to a tighter grain of development compared to suburban areas, reductions between 20-30% are not considered to be excessive.
6.4.29 Furthermore, the arrangement of Colwyn House is such that the deck access / underside of the soffit above the head of the windows provides an inherent obstruction to skylight. The BRE guidance recognises such aspects and allows for isolated review of the proposed massing without the balconies present. The guidance explains as an example that if the proposed VSC with the balcony present results in at least a 20% loss compared to the existing value with the balcony, but if the same analysis was undertaken without the balconies present and the proposed VSC without the balcony present results in under a 20% loss compared to the existing value without the balcony, this would show that the presence of the balcony, rather than the size of the new obstruction, was the main factor in the relative loss of light.
6.4.30 Following the submission of a further assessment where the inherent obstruction of the deck access is removed, there are only isolated exceptions where reductions are beyond a 20% reduction (but not exceeding circa 27%) which on balance is still considered reasonable in the overall urban context. This analysis also takes account for the fact the windows to the very southern end of the block facing the Site are already not hindered by the deck access. These rooms are used as living rooms. 6.4.31 The following table provides the instances where surrounding residential rooms have a VSC under 27% and would be reduced by over 20% as a result of the Development. Please note that for Colwyn House, the results are shown with the deck access removed as explained above, but only for the 3 bottom floors which would be worst affected by the Development. However, the results to all 5 floors to the very southern rooms are given as these are not hindered by the deck access (rooms R1/10-14). The full results for the remaining floors are given within the submitted Daylight and Sunlight Report but only with the deck access in-situ:
Existing VSC Proposed VSC Room Use of Room % Loss VSC (%) (%) Colwyn House R1/10 – GF Living Room 18.74 14.22 24.12 R3/10 – GF Kitchen 21.57 17.06 20.91 R4/10 – GF Kitchen 22.72 18.06 20.51 R5/10 – GF Hall/Toilet/Bathroom 23.87 19.02 20.30 R8/10 – GF Hall/Toilet/Bathroom 17.70 13.47 24.42 R1/11 – 1F Living Room 21.07 15.69 25.53 R3/11 – 1F Kitchen 23.61 18.53 21.52 R4/11 – 1F Kitchen 24.83 19.69 20.70 R5/11 – 1F Hall/Toilet/Bathroom 25.96 20.73 20.17 R8/11 – 1F Hall/Toilet/Bathroom 19.54 15.09 23.23 R1/12 – 2F Living Room 23.60 17.30 26.69 R2/12 – 2F Hall/Toilet/Bathroom 23.11 18.21 21.19 R3/12 – 2F Kitchen 25.66 20.02 21.98 R4/12 – 2F Kitchen 26.91 21.30 20.85 R8/12 – 2F Hall/Toilet/Bathroom 21.08 16.49 22.19 R1/13 – 3F Living Room 26.31 19.15 27.21 R1/14 – 4F Living Room 29.34 21.40 27.06 International House R1/141 Unknown 31.11 24.37 21.66 R2/141 Unknown 31.07 24.84 20.06 R1/142 Unknown 32.79 26.10 20.41
Figure 36: Key for room numbering for Colwyn House for table above. Analysis given is for Daylight Distribution, existing and proposed (deck access in-situ) 6.4.32 For the separate aspect of Daylight Distribution review (i.e. the extent of room area that can receive direct skylight at the working plane), all reductions generally do not exceed 20% (thus satisfactory) with the exception of Colwyn House and isolated rooms within 57-69 Kennington Road and International House opposite, although Officers consider on balance, not a significant adverse effect.
6.4.33 With regard to Colwyn House, thus similarly for the VSC analysis, typically Daylight Distribution reductions to habitable rooms range up to 25% at ground floor, 28% at 2nd / mid floor and 35% at 4th / top floor. It should be noted that where Daylight Distribution reductions occur, this is only to the living rooms to the very south of the wing facing the Site, and to the kitchens, bathrooms and hallways, and not to any bedrooms.
6.4.34 As discussed previously, the kitchens have not been considered to be ‘habitable’ rooms for the purpose of this assessment given their ‘galley’ style arrangement which is not suitable to dine in. However, as stated previously, given the deck-access arrangement, it is apparent that the deck access / underside of the soffit above the head of the windows provides an inherent obstruction to direct skylight and the BRE recognises such aspects and allows for isolated review of the proposed massing without the balconies present within the assessment (to remove the inherent obstruction / sensitivity to such windows). On that basis, there are only isolated exceptions where reductions are beyond a 20% reduction (but not exceeding circa 28%) which on balance is still considered reasonable in the overall context. Whilst the reductions in Daylight Distribution to the southern-most rooms of Colwyn House would remain at the levels noted above due to not being obstructed by the deck access, it is considered acceptable on given the urban context of the site.
6.4.35 The following table provides the instances where surrounding residential rooms would have Daylight Distribution figures reduced by at least 20% by the Development. As with the VSC analysis, please note that for Colwyn House, the results are shown with the deck access removed for the 3 bottom floors which would be worst affected by the deck access and Development. The results to all 5 floors are given to the very southern rooms (rooms R1/10-14, which aren’t hindered by the deck access). The full results for the remaining floors are given within the submitted Daylight and Sunlight Report but only with the deck access in-situ:
% Loss Daylight Room Use of Room Distribution Colwyn House R1/10 – GF Living Room 24.8 R3/10 – GF Kitchen 22.8 R4/10 – GF Kitchen 22.2 R1/11 – 1F Living Room 26.0 R3/11 – 1F Kitchen 21.1 R1/12 – 2F Living Room 28.1 R3/12 – 2F Kitchen 24.9 R1/13 – 3F Living Room 31.7 R1/14 – 4F Living Room 34.7
63 Kennington Road R1/103 Unknown 24.8
65 Kennington Road R1/109 Unknown 22.0 R1/113 Unknown 32.6
International House R1/141 Unknown 22.5
6.4.36 In summary, the instances where the Development would result in daylight losses beyond BRE guidance is mostly limited to Colwyn House, with isolated losses to properties on Kennington Road and to International House. In terms of Colwyn House, the main impact on habitable rooms would be to the living rooms that face east and towards the Site. These windows are positioned at the southern end of the wing that faces the Site and are not hindered by the deck access, as is the case with many of the other windows on this elevation. However, it is considered that good levels of daylight would be retained to these rooms despite the failings that occur beyond BRE guidelines, which are not considered to be excessive in the urban context of the site.
Assessment of the Results – Sunlight to neighbouring properties
6.4.37 Point 2 Surveyors have reviewed sunlight to neighbouring properties and as per the BRE Guide, for assessment of windows that face within 90 degrees of south (assessment of windows that face within 90 degrees of north is not applicable on the basis that the availability of sunlight is already limited).
6.4.38 The main building applicable for review is Colwyn House, which would be subject to some reductions in the receipt of sunlight. All of the other properties tested meet the BRE guidance with exception to windows contained within The Steam Engine pub and a ground floor window at 52 Kennington Road (SE1 Dental Centre). However, as both of these properties are understood to be in commercial occupation, the overall sunlight effect is considered minor.
6.4.39 In reference to sun important rooms (i.e. living rooms) at Colwyn House which were reviewed, there is one corner room that has been analysed, which is a living room of the ground floor where the south-eastern wing of Colwyn House meets the northern wing. This rooms benefits from two windows, one facing north-east and one facing north. Whilst there is an opening facing south, this is in fact a solid door providing access into this room, and therefore is not applicable for assessment. It is noted that there are no openings immediately above this facing south and therefore none of the above rooms are applicable for assessment either. 6.4.40 Whilst there are living rooms in the very southern end of the wing facing the site, these face north-east and ordinarily on this basis are not required to be assessed as per the BRE guide. This is also the case for all other rooms along this elevation of Colwyn House. Therefore, the loss of sunlight to these rooms is considered to be acceptable, noting the flats within this block would still benefit from the receipt of sunlight in the afternoon to the main habitable rooms in most cases, facing south-west, of which the Development would not have an impact upon.
Assessment of the Results – Sunlight to neighbouring gardens/amenity spaces
6.4.41 For sunlight levels to neighbouring amenity, the daylight/sunlight report provided a detailed review of the impact of the Development on neighbouring gardens and amenity areas in terms of the BRE Guide 2 hour amenity test on 21st March (spring equinox), with details given below in Figure 37.
Figure 37: Overshadowing analysis for neighbour amenity areas existing and proposed at the 21st March equinox. Areas in yellow are areas which would receive 2 hours of sunlight at the equinox, with percentage figures stating amount of amenity areas that would receive 2 hours of sunlight at the equinox
6.4.42 For shadowing to Colwyn House, whilst there are some reductions, the main garden and amenity spaces still either retain 50% or more of the amenity area receiving 2 hours of sun on the ground at the equinox or where below this value, reductions not falling below 0.8 times former value and so closely meet the BRE Guide target criteria. The only areas analysed with reductions beyond the target criteria are to some of the secondary and garden areas in front of Colwyn House (albeit receive fairly minimal sunlight currently at the equinox). However, these are not the main gardens and amenity to these flats (which instead is located at the rear of the block which do satisfy the BRE Guide target criteria). In summary, Officers consider that there is no significant adverse effect.
6.4.43 For shadowing to the neighbouring properties of 130 and 132 Lambeth Road, for the BRE Guide 2 hour test, the rear amenity space to these properties has 0% sunlight in the existing and proposed scenario at the equinox. The test has also been extended to consider for mid-summer and for No. 130 there is no reduction (37.4% sunlight in existing and proposed scenario) and for No. 132 there is a negligible change (54.9% sunlight in existing and 55.0% in proposed scenario). In summary, the impact of the Development on the amenity areas to these properties is acceptable, with almost no effect at all.
6.4.44 In terms of the other surrounding properties, it is considered that the impact of the Development on these amenity areas would be negligible and closely adhering to BRE Guide target criteria.
Assessment of the Results – Conclusion
6.4.45 The proposed massing height of the Development is greatest at the Kennington Road / Lambeth Road junction and then with terracing down at the north and western ends. Overall, the Development represents an increase in the footprint (and of differing arrangement) and height to that of the existing ‘Days Inn’ hotel building on the Site (the existing hotel being more uniform in height and ‘s-shaped’ in plan arrangement). Therefore, the Development does result in reductions in daylight and sunlight. However, in consideration of the Daylight and Sunlight Report prepared by Point 2 Surveyors and following Officer’s assessment, such reductions typically adhere fairly close to the target criteria within the BRE Guide and in consideration of the urban context, on that basis, are reasonable.
Outlook and Sense of Enclosure
6.4.46 The main impact of the Development in terms of outlook would be to properties at the rear of the Site on Cosser Street and Morton Place, including Colwyn House and those adjacent to the Site on Lambeth Road.
6.4.47 The separation distance between 130 Lambeth Road would be reduced from 4.6 metres to 3 metres. However, the northern and south-western wings of the proposed building would have a similar bulk and massing as the existing building, and the rear of the building would align with the rear of the adjacent terrace on Lambeth Road. It is also noted that the adjacent property of 130 Lambeth Road has no windows facing directly towards the Site. Given the above, the levels of outlook in these areas would not be unacceptably reduced.
Figure 38: The rear of the adjacent property of 130 Lambeth Road
6.4.48 In terms of outlook from other surrounding properties, separation distances would be retained of approximately 19 metres to Colwyn House, 13.5 metres to the properties on Cosser Street across the road from the Site, 41 metres to the properties on Kennington Road across from the road from the Site, and 27 metres to the properties on Lambeth Road across the road from the Site. Given these distances and the concentration of the bulk of the building to the front of the Site away from the surrounding properties, it is considered that the Development would not result in an unacceptable loss of outlook on these properties or result in a sense of enclosure.
Noise
6.4.49 The application was accompanied with an Environmental Noise Survey which has been reviewed by the Council’s Environmental Health advisors. Conditions are recommended to ensure all plant equipment does not have an unacceptable impact on neighbouring amenity with regard to noise. A condition is also proposed to ensure that the hotel rooms themselves would not be unacceptably impacted upon by noise transfer through the building.
6.4.50 In terms of the operation of the building, the concerns raised during the public consultation are noted regarding potential noise issues from the ground floor uses. The location of the bar, restaurant and café are considered appropriate, as they would provide an active frontage to the corner junction of Kennington Road and Lambeth Road. The bar in particular is not anticipated to propose to play loud music or hold large functions given its size, but if this were to be proposed, further details would need to be sent to the Council for approval, as a condition. Furthermore the outdoor seating would be limited in size, located away from surrounding residential properties and on a busy stretch of highway. A condition is suggested to restrict the use of the outdoor seating area beyond 22:30, which is similar to other bars and public houses in the area.
6.4.51 The servicing of the premises would take place to the rear of the building on Morton Place. This reflects the existing situation and whilst there is an anticipated increase in delivery numbers per day, subject to a condition restricting the hours of delivery and a management plan regarding deliveries and servicing, it is considered that the noise generated from the servicing of the building would not be unacceptable. Furthermore, the storage of all waste within the building will help mitigate the impact of any additional deliveries that will likely be required.
Privacy
6.4.52 The proposal would retain similar separation distances to surrounding properties as per the existing building, noting however closer distances to the rear in particular. Officers consider that there would be limited opportunities for any direct overlooking to occur given the orientation of the proposed building in relation to the surrounding buildings, and where this would occur such as to the Cosser Street elevation, the distance of the opposite buildings across the road is considered to be sufficient.
Odours
6.4.53 The proposed hotel would include an ancillary restaurant at ground floor, with the kitchen extracts proposed to front onto Cosser Street, also at ground floor level. It is anticipated that a high level of odour control would be required to ensure that the Development does not have an unacceptable impact on neighbouring amenity in this respect. Further details on the extract system should be requested as a condition together with its planned maintenance.
Wind
6.4.54 It is noted that the GLA had initially had concerns regarding the potential for the Development to adversely affect its surroundings in terms of the pedestrian environment. Following this, a wind study was undertaken, which demonstrates that the Development would not have an unacceptable impact on local conditions with regard to wind, as required by LLP Policy Q26. The Council’s Environmental Health advisors have reviewed the submission and consider that no mitigation measures would be required.
Solar Glare
6.4.55 LLP Policy Q26 requires tall buildings to not have an unacceptable impact on its surroundings with regard to reflected solar glare. The proposed building would be a glass clad and a significant proportion of the façade constructed out of brickwork. Officers therefore consider that the Development would not result in an unacceptable level of solar glare.
6.5 Transport
6.5.1 LLP Policy T1 states that the Council will promote a sustainable pattern of development in the Borough, minimising the need to travel and reducing dependence on the private car.
Access to the Site
6.5.2 The Development would have a vehicular access to the front of the Site for car/taxi pick-up and drop-off. This is as per existing provision off Cosser Street.
6.5.3 Servicing would take place in Morton Place, again as existing, with a designated service bay being provided. This would be sufficiently sized to allow a 10 metre vehicle to enter, park, turn-around and leave the site in forward gear. When parked, the delivery vehicle would not prevent access for vehicles to the adjacent Briant Estate.
Figure 39: The red arrows indicate the car/taxi pick-up and drop-off route, whilst the cyan arrows represent the servicing access
Trip Generation 6.5.4 Given the excellent access to public transport and the central London location of the hotel, it is anticipated that the majority of guests and visitors would arrive at the Site by public transport or by foot. It is acknowledged that taxi and coach movements would also occur given the nature of the use. The table below provides that anticipated total movements to the Site, and the mode of transport:
AM Peak Hour PM Peak Hour Daily Mode 08:00-09:00 17:00-18:00 07:00-22:00 Car 6 1 20 Car Passenger 6 4 37 Bus 16 17 168 Train 84 88 864 Underground 105 105 1067 Taxi 14 16 161 Cycle 2 0 11 Walk 124 146 1538 Coach 2 2 28 Motorcycle 3 0 4 Total 362 379 3898
6.5.5 The table below provides details of the anticipated increase in trips to the Site when compared to the existing situation:
AM Peak Hour PM Peak Hour Daily Mode 08:00-09:00 17:00-18:00 07:00-22:00 Car -2 -7 -60 Car Passenger -2 -4 -43 Bus 10 10 104 Train 51 53 523 Underground 74 64 662 Taxi 9 10 108 Cycle 2 0 11 Walk 121 143 1506 Coach 1 1 17 Total 259 270 2832
6.5.6 As can be seen in the above mentioned figures, car movements are anticipated to decrease, due to the fact that the existing car parking area would not be re-provided at the Site. The largest increase in movements is pedestrians (walking) and is predominantly associated with the proposed café, where it is anticipated that these pedestrian movements will be associated with passing trade as opposed to new trips on the network. It is also noted that cycle movements given in the above mentioned assessment are quite low. A further analysis on this matter is provided below.
Cycling
6.5.7 LLP Policy T3 requires development to provide cycle parking in accordance with London Plan requirements. An internal cycle store is proposed at the rear of the Site, accessed off Morton Place and would have storage for a total of 32 bicycles. Shower facilities would be provided on-site for staff utilising the cycle storage to travel to the Site. On-street cycle parking would be provided on Lambeth Road for 16 bicycles in the form of Sheffield Stands. In total there would be cycle parking for 48 bicycles, which is considered appropriate for the proposed use, meeting the London Plan requirements.
6.5.8 TfL have provided comments regarding the envisaged cycle modal share for staff and guests travelling to the Site. Based on the applicant’s draft Travel Plan the envisaged cycle modal share for staff is 7% with an anticipated future year target of 8%. For hotel guests the modal share is 0%. TfL considers that these targets could be increased noting the demand for the use of TfL cycle hire facilities around other London hotels and other tourist hotspots. Furthermore, TfL is experiencing a rise in the number of causal users of docking stations in the area.
6.5.9 Comments received by TfL consider that the proximity of the Site to central London and the investment in local cycle infrastructure, (particularly at Westminster Bridge Road, Quietway schemes and the cycle grid as well as the future Waterloo City Hub project), cycle hire is likely be a popular mode of transport to and from the Site, increasing the demand on the network by approximately 15-25%. Furthermore, given the nature of the use of the Site, guests staying at the hotel are unlikely travel to and from the hotel on their own bicycle. Assuming even a 5% target for guests to use cycle hire facilities, this could result in 28 trips at 80% occupancy rates of the hotel. These trips cannot however be accommodated at the existing cycle docking stations near to the Site along Kennington Road and Sail Street. The Kennington Road docking station is ranked within the top 25% most used docking stations across London. TfL also confirm that other docking stations within the local area are similarly busy and therefore an increase in facilities is required to meet existing and future demand. TfL do not consider that it is possible to extend the existing docking stations along Sail Street and Kennington Road due to a lack of available pavement space in these areas, as well as issues relating to the location of utilities.
6.5.10 In light of the above, it has therefore been recommended by TfL that a new docking facility is required to be along the Kennington Road frontage and serviced from Cosser Street. A new docking station would need to be secured by a Section 106 Agreement, with the applicant agreeing to pay a contribution for the facility. The principle of a contribution has been agreed by the applicant. It is anticipated that a new docking station would be required altogether, with this positioned immediately outside of the Site on Kennington Road. Servicing of this facility would need to take place on Cosser Street. A formal loading bay would not be required, but amendments would be required to the existing parking restrictions on this road to allow for the servicing of this facility. This would require a further contribution from the applicant of £6,500, which again would be secured within the Section 106 Agreement.
Car Parking 6.5.11 The Site would not provide any car parking, and given the excellent access to public transport. This is supported by Officers given the other methods of transport available to users of the Development to arrive to and leave from the Site. Furthermore, as the Site is located within a CPZ, it would not be possible for staff or visitors to park within the surrounding streets during the restricted hours of the CPZ.
6.5.12 As requested by both TfL and the Council’s Transport Officer, one blue badge parking bay will be required. It is suggested that an existing on-street parking bay on Cosser Street is adapted to become a blue badge parking bay, with the cost borne by the applicant and secured as part of the Section 106 Agreement. Details have been provided by the applicant to demonstrate that the existing bays are underused, and therefore its conversion would not have an unacceptable impact on local car parking facilities. As suggested by TfL, further spaces may be required subject to demand; this would need to be monitored as part of the hotel’s Travel Plan.
Coach Parking
6.5.13 In accordance with London Plan Policy 6.13, the Development needs to accommodate for both short-stay coach parking and overnight coach parking.
6.5.14 In terms of short-stay coach parking, it is proposed to utilise the existing coach parking bay on the north side of Cosser Street. This bay permits coach parking for a maximum stay of 15 minutes. In addition, it has been established that there are further coach parking bays for 5-6 standard size coaches approximately 150 metres to the east of the Site on Lambeth Road adjacent to the Imperial War Museum. These are subject to a maximum stay of 4 hours, Monday-Friday between 08:30-18:30.
6.5.15 It is anticipated that there would be a total of 28 coach trips to and from the Site per day (modelled between 07:00 and 22:00), which represents an increase of 17 coach trips over the same period from the existing situation. During the peak periods of 08:00- 09:00 and 17:00-18:00 it is anticipated that the Development would generate an increase in trips of one additional trip for each period, resulting in a total of two trips for each of the peak periods. It is considered that the demand for short-stay coach parking can be accommodated using the existing coach parking facilities on Cosser Street primarily or those on Lambeth Road should there be a requirement to do so.
6.5.16 It is noted that there is a planned closure of Hercules Road immediately south of its junction with Cosser Street, meaning that coaches can only access the Site from Hercules Road in a southbound direction, whereby they can turn left onto Cosser Street and enter the coach parking bay in forward gear, and then leave the bay in a forward gear and onto Kennington Road. Were coaches to arrive at the Cosser Street parking bay from Kennington Road, they would be required to turn around at the junction with Morton Place, so they can leave the bay onto Kennington Road in a forward gear. This is due to the fact that Cosser Street is a one-way street immediately to the west of its junction with Morton Place, with traffic only permitted to travel in an eastbound direction.
6.5.17 Tracking analysis has been provided demonstrating that either access option would be possible without any significant impact on the operation of the highway generally, noting that the use of Morton Place for turning is unlikely to be problematic given this is not a through-road and Cosser Street with relatively low levels of traffic. As explained within the amended Delivery and Servicing Management Plan (DSMP), a Delivery and Servicing Co-ordinator (DSC) would be appointed by the hotel prior to occupation. The DSC would book all coach arrivals time slots to ensure that a maximum of one coach is servicing the Site at any one time on Cosser Street. Furthermore, the banksmen would ensure the safe turning of coaches were they to arrive from Kennington Road and need to turn around utilising Morton Place.
Figure 40: Tracking analysis of coaches arriving either from Hercules Road from the north (above) or from Kennington Road from the east (below), noting whilst coaches would be required to swing-out into Hercules Road to turn left onto Cosser Street, this would not be problematic given the planned closure of Hercules Road immediately to the south of this junction
6.5.18 In terms of overnight coach parking, it is noted that there is a ban on commercial vehicles parking on-street in the surrounding area, meaning coaches cannot park overnight in the coach bay on Cosser Street. TfL provide details on its website of overnight parking facilities for coaches, and a plan of this is attached at Appendix 4 of the amended DSMP. The nearest coach park to the Site is New Covent Garden Market in the Vauxhall area. The DSC would monitor is the Development to ensure that it is operating in accordance with the DSMP. This will safeguard the Development with regard to coach parking should any issues arise, particularly with regard to overnight coach parking where there may be a change in the accessibility to the currently mentioned parking facilities. Whilst TfL have requested further detail on overnight coach parking, it is considered by Officers that its management as proposed by the DSMP, is acceptable.
Taxis 6.5.19 The Development proposes a taxi drop-off area to the front of the hotel with space allocated for one vehicle to remain idle whilst picking up or dropping off guests, whilst at the same time allow other vehicles to pass around unhindered and leave the Site in forward gear. An assessment was undertaken to calculate the likely maximum number of taxi trips to the hotel. The busiest time for taxi trips to and from the hotel is anticipated to be between 18:00-19:00 with a maximum of 27 trips. Officers consider that the pick- up and drop-off loop to the front of the hotel would be sufficient to accommodate this demand on site. Transport Officers note however that this analysis did not take account of later movements after 22:00 when other forms of transport are less suitable. Whilst there may be similar levels of taxi movements at night to that modelled, it is still considered that the demand for taxi movements can be accommodated on site at these times, also noting that the surrounding roads would be quieter.
Figure 41: Tracking analysis of vehicular movements of a minibus entering and leaving the Site
6.5.20 In TfL’s representations they have requested for a formal taxi rank be provided either on-site or immediately adjacent to the Site to accommodate the anticipated increase in taxi movements to and from the hotel. TfL consider that a taxi rank is required particularly in terms of pick-up, to reduce the impact of guests and visitors hailing taxis from the side of the road, which may cause a detrimental impact on the operation of the surrounding highways. Officers do not consider that a taxi should be provided by the Development as the proposed in-and-out loop and drop-off area to the front of the hotel considered to be sufficient to meet demand. Furthermore, as part of the Hotel Management Plan, details can be provided to ensure that the hotel staff will assist guests in hailing or booking taxis, so that they can arrive within the hotel in-and-out loop area where possible, thus reducing the impact on the local highway network.
Pedestrian Movement 6.5.21 The pedestrian audit submitted by the applicants has been assessed and TfL have noted a lack of crossings on Kennington Road between its junctions with Lambeth Road and Westminster Bridge Road. Given the projected flows from the London Underground network at Waterloo and Lambeth North stations, the pedestrian movement in these areas is of great importance.
6.5.22 The potential for a new pedestrian crossing has been considered, but following discussions between the Council’s Transport Officer and TfL, it was considered to not be necessary. Within this assessment it was noted that there are junction improvements proposed by the Council at the Westminster Bridge Road junction, where a new crossing will be installed across the arm of Kennington Road. These junction improvement works are anticipated to commence within the next year and be operational prior to the completion of the construction works to redevelop the Site.
Deliveries and Servicing
6.5.23 The Development proposes deliveries and servicing to take place at the rear of the Site on Morton Place, as per the existing arrangement. Morton Place is not a through- road and given the access required to the front of the Site and the restrictions caused by existing junctions, this is considered the most appropriate location for deliveries. A turning head would be provided at the southern end of Morton Place, so that the loading bay could accommodate 10 metre rigid vehicles. A swept path analysis has been provided to demonstrate that vehicles up to this size can access the on-site loading bay, turn and leave in forward gear. It has also been demonstrated that when such a vehicle is parked in the service bay, it would be possible for vehicles to access the adjacent Briant Estate unhindered, including emergency vehicles (such as fire engines and ambulances). It is anticipated that the majority of vehicles servicing the Site will be 7.5T (8m) vehicles. Servicing vehicles would be parked at an angle in order to provide clearance to the Briant Estate, but it is likely that they would wish to park at such an angle due to ease of access when parking, and also due to ease of loading and unloading to and from the building, which would take place at the northern section of the loading bay. As stated by the DSMP, the DSC will ensure that all deliveries are booked in the access to the Briant Estate is maintained and the servicing bay is kept clear from parked vehicles. This would ensure that there is no impact on the local road network. The applicant has confirmed that deliveries would be restricted during the morning and evening peak hours and discouraged outside of the normal operating hours of 07:00 – 20:00. Officers recommend that a condition is imposed to restrict deliveries to between these times.
Figure 42: Swept path analysis of a 10 metre vehicle accessing the servicing area on Morton Place, which would then be able to turn around without accessing the adjacent Briant Estate and leaving the site in forward gear onto Cosser Street
Figure 43: Swept path analysis of a fire engine accessing the Briant Estate when a 10 metre vehicle (image to the left) and an 8 metre vehicle (image to the right) is parked in the loading bay 6.5.24 Concerns have been raised by residents with regard to the potential impacts that may be caused by deliveries and servicing, especially given the proposed intensification of the uses at the Site. It is anticipated that there would be an increase in service vehicles from 5 vehicles per day as existing, to 11 per day (1 is a small van, 6 are larger vans, and 4 are 2-axle HGVs). Comments have been provided from local residents regarding the likely routes servicing vehicles would make to and from the Site, with concerns that the servicing area on Morton Place could be accessed via Hercules Road and then onto Cosser Street to the west of its junction with Morton Place, which in turn could affect the residential properties in this area. As explained previously, an approved highways scheme is due to be implemented within the next year which would result in Hercules Road no longer being a through-road. Access to vehicles would be restricted immediately to the south of the junction of Hercules Road and Cosser Street. Therefore vehicles would not be able to access the Site via from the south via Hercules Road. Whilst vehicles would be able to access the Site via Hercules Road if arriving from the north, it would be quicker and easier for servicing vehicles to access the Morton Place servicing area via the Kennington Road and Cosser Street junction. Furthermore, as Cosser Street is a one-way street immediately to the west of its junction with Morton Place with vehicles only permitted to travel in an eastbound direction, vehicles would not be able to leave the Site or servicing area via Hercules Road to the west. As stated within the DSMP, delivery drivers will be notified of access routes to the Site.
6.5.25 In light of the above, it is considered likely that deliveries required for the proposed uses would not impact unacceptably on neighbouring properties subject to the restriction of deliveries outside the hours given above, a restriction on the size of service vehicles accessing the site at 10m in length and a condition requiring compliance with the submitted amended Delivery and Servicing Management Plan.
6.5.26 In terms of the management of the refuse facilities, refuse would be stored internally and made available on street for collection as required. No details have been provided on the management of this, but will be requested as a condition.
Construction Management
6.5.27 A draft Construction Management Plan (CMP) has been submitted with the application. It is anticipated that the construction period and amount of construction traffic required will be as follows:
- Demolition: 12 weeks, average 9 HGVs per day - Foundations: 22 weeks, average 17 HGVs per day - Construction: 50 weeks, average 7 HGVs per day
6.5.28 The draft CMP states that construction traffic would enter the site off Kennington Road and Lambeth Road, away from Cosser Street and Morton Place. This is considered appropriate given the difficultly in reaching access points in these areas for construction traffic, as well as the proximity of residential premises. As the construction contractor is not yet know to the Council a final CMP would be required as a condition to ensure that any potential impact on the highway network or local amenity is mitigated.
6.6 Sustainable Design and Construction 6.6.1 The London Plan sets out the Mayor’s vision for London to become: “a world leader in improving the environment locally and globally, taking the lead in tackling climate change, reducing pollution, developing a low carbon economy and consuming fewer resources and using them more effectively”. LLP Policy EN4 requires development to meet the highest standards of sustainable design and construction feasible, relating to the scale, nature and form of the proposal. The LLP also requires major non-residential developments to accord with BREEAM requirements, where at least BREEAM ‘Excellent’ should be achieved, unless it is demonstrated that it is not technically feasible or viable to do so, in which case proposals should demonstrate a ‘Very Good’ rating with a minimum score of 63%.
6.6.2 London Plan Policy 5.2 states that development proposals should make the fullest contributions to minimising carbon dioxide emissions in accordance with the following energy hierarchy:
1. Be lean: use less energy 2. Be clean: supply energy efficiently 3. Be green: use renewable energy
6.6.3 The Development as a whole is anticipated to achieve a 36.44% reduction in carbon dioxide emissions over Building Regulations requirements, which meets the London Plan requirements. The applicant has demonstrated that all opportunities to reduce carbon dioxide emissions have been maximised through such measures as the provision of photovoltaic solar panels, allocation of space to connect to a District Heat Network (DHN) should one become available, and through using a Combined Heat and Power (CHP) system. The Energy Assessment also takes account for the fact that hot water usage is likely to be higher than other non-domestic premises, given that a hotel use is proposed. Similarly, due to the high servicing requirements of the building, active cooling has been proposed, and sufficient evidence has been provided to demonstrate that the building would overheat without a cooling system. Conditions and Section 106 obligations will be used to ensure compliance with the Energy Assessment and to require the building to connect to a future District Heat Network should one become available.
6.6.4 The BREEAM New Construction pre-assessment indicates that the building would achieve an ‘Excellent’ rating with a score of 76.29%, which meets the London Plan policy requirement.
6.7 Flood Risk and Land Stability
6.7.1 The Site is located within Environment Agency Flood Zone 3, and therefore considered to have a high risk of fluvial flooding. However, it should be noted that this risk is reduced by the flood defence systems along the River Thames. No bedrooms are proposed at basement or ground floor level, and it is therefore considered that the Development would not give rise to any likely effects in relation to flood risk. The submitted Flood Risk Assessment (FRA) recommends a number of mitigation measures, and the owner of the Site is recommended to subscribe to the ‘Floodline Warning Direct’ service offered by the Environment Agency. The Environment Agency provided comments and raised no objections to the proposed development in terms of flood risk matters.
6.7.2 Thames Water have provided comments on the application and whilst no objections have been raised, they request that a condition is added to any planning approval requiring a Piling Method Statement to be submitted. This will ensure that any damage to underground sewer infrastructure can be prevent. 6.7.3 LLP Policy EN6 requires that sustainable drainage systems (SuDS) are incorporated in development proposals to mitigate and enhance the development’s impact on flood risk, water quality and habitat/amenity value. Whilst the Site would result in an increase in impermeable areas, it is proposed to introduce flow controls, attenuation tanks and bio-retention tree pits to provide a sustainable drainage solution and reduce the overall surface water flow rates from the development. Subject to the installation of such measures, the application is considered acceptable in this regard.
6.7.4 In accordance the NPPF it is necessary for applicants to consider the suitability of the site for the proposed development in terms of ground conditions and land instability. An assessment has been provided by the applicants on land stability and following the recommendations of the Council’s Building Control department, the proposals are considered acceptable in this respect.
6.8 Employment and Training
6.8.1 LLP Policy ED14 seeks to use planning obligations that secure employment opportunities and apprenticeships during the construction phase of major developments and during the operation of the end use, so that local residents are given access to the right skills training so that they can take advantage of opportunities created by new development. The draft SPD on Section 106 obligations requires major developments to commit to providing a minimum of 20% of all construction jobs created by the development to local people. Furthermore, a minimum of 10% of all construction jobs created by the development is required to be provided for trainees and apprentices.
6.8.2 The development will provide a wide variety of employment opportunities through the demolition and construction phases. Furthermore, the hotel currently employs 38 full time staff and 21 part time staff; it is anticipated that proposed Development will increase this to 150 full time staff and 50 part time staff.
6.8.3 As part of a clause in the Section 106 Agreement, the Council would require the applicant to commit to obligations to employ local people both through the construction phase and in the end use. The clause will also require a completed ‘Employment and Skills Plan’ and ‘Worksmart’ document, setting out how the Development will aim to achieve these targets. A financial contribution will also be required towards Local Labour in Construction as this would be secured through an obligation through a Section 106 Agreement.
6.9 Planning Obligations and CIL
6.9.1 LLP Policy D4 and Annex 10 sets out the Council’s policy in relation to seeking planning obligations and the charging approaches for various types of obligation. For contributions that are not covered by Annex 10, the Council’s approach to calculating contributions is guided by its July 2013 revised draft S106 Planning Obligations Supplementary Planning Document (SPD) produced for consultation. The July 2013 revised draft S106 Planning Obligations SPD arose from a review of the S106 Planning Obligations SPD that was adopted in 2012.
6.9.2 The planning obligations that are proposed are considered necessary to make the development acceptable in planning terms, are directly related to the development and are fairly and reasonably related in kind and in scale to the development. They are therefore compliant with the requirements of Regulation 122 of the Community Infrastructure Levy Regulations 2010.
6.9.3 The proposed obligations to be secured through the S106 Agreement are as follows:
Obligation:
Securing the conversion of one on-street parking bay on Cosser Street to a blue badge bay, with a financial contribution of £10,000 required to pay for the conversion, paid to the Council.
Securing a financial contribution towards new TfL cycle hire facilities in the vicinity of the Site, and were this to be installed immediately outside the Site on Kennington Road, this would include a financial contribution to the Council of £6,500 for highway alterations on Cosser Street to allow for servicing of the new facility.
Travel Plan Monitoring Fee of £1,000.
A clause requiring the developer to enter into a s.278 highways agreement to deliver the highways alterations including the raised table at the junction of Cosser Street and Kennington Lane and the shared surface on Morton Place. Also, to ensure the delivery of the public realm improvements around the Site, including the new paving to footways around the Site, landscaping to the rear alleyway to the Briant Estate and the repair works to the plinths of the locally listed water trough on Lambeth Road.
Securing a Local Labour in Construction financial obligation of £137,500.00 (£2,500 per £1 million construction costs of £55,000,000).
Securing an Employment and Training financial obligation of £41,170.56 (based on an employment yield of 200).
Securing employment and training opportunities including apprenticeships, procurement, training and brokerage arrangements, both through the construction phase of the development and in the end use of the building.
Requiring the submission of a Hotel Management Plan.
Requiring the Site to be connected to a District Heat Network should one become available and the connection be feasible.
Secure the Development as Business Parking Permit-free.
Should the Flexible Use Unit be brought forward as a Class B1(a) Use, it shall be secured as an affordable workspace in perpetuity.
Monitoring fee of 5% of total financial contributions (subject to agreement on TfL docking station contribution).
6.9.4 If the application is approved and the development is implemented, a liability to pay the Lambeth and Mayoral Community Infrastructure Levy (CIL) will arise. The Council’s CIL Team will confirm with the applicant the required CIL payment following the granting of planning permission, but it is envisaged that the Development will generate a Lambeth CIL liability of £855,899.75 and a Mayoral CIL liability of £299,005.00.
6.9.5 Allocation of CIL monies to particular infrastructure projects is not a matter for consideration in the determination of planning applications. Separate governance arrangements are being put in place for Borough Infrastructure needs, and locally through the Cooperative Local Investment Plan initiative.
6.10 Other Planning Issues
Secured by Design
6.10.1 Development is required to minimise the risks of opportunistic crime, anti-social behaviour and fear of crime in accordance with London Plan Policy 7.3 and LLP Policy Q3.
6.10.2 The proposals have included a number of measures to ensure the Development would achieve the objectives of the above mentioned policies. Namely, the inclusion of active frontage uses along the Kennington Road and Lambeth Road and to part of the Cosser Street frontage in the form of a restaurant. Additionally, passive surveillance would be provided to the rear of the Site on Morton Place due to the location of the general manager’s office next to the loading bay.
6.10.3 It is proposed to include CCTV cameras around the Site at all vehicular and pedestrian access points as well as a lighting scheme to reduce the risk of crime. Further details are required by the applicants regarding these points, and conditions have therefore been recommended. It is also proposed that all seating would be designed to discourage rough sleeping on them. Again, further details are required through a condition.
6.10.4 Concerns have been raised through the public consultation process regarding the security risk presented by the alleyway to Colwyn House between the Site and the adjacent properties on Lambeth Road. Officers however consider that the measures detailed above are appropriate to minimise the risks of crime in this area and at the Site as a whole.
Environmental Impact
6.10.5 An application was made to the Council on the 30.06.2016 for a Screening Opinion (ref. 16/03913/EIASCR) as to whether the proposed redevelopment required an Environmental Impact Assessment (EIA) for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (as amended). An assessment was undertaken in accordance with the Regulations, specifically an assessment of the Development in the light of the criteria in Schedules 1 and 2, and it was concluded that the Development would not be an EIA development.
Air Quality
6.10.6 The submitted Air Quality Assessment has concluded that the Development would not be air quality neutral with respect to transport due to the modelled benchmark trip rate for the hotel given in the submitted Travel Plan. However, as part of the final Travel Plan that would be secured by a condition (and monitored through the Section 106 Agreement), it is anticipated that further improvements would be made in promoting more sustainable methods of transport for people travelling to and from the site. For example, new Cycle Hire facilities would be provided by the applicant as part of the Section 106 Agreement. Other mitigation measures have been suggested to prevent excessive levels of dust being created during the construction phase. Further details will be requested in the CMP, referred to in the ‘Transport’ section of the report.
Land Contamination 6.10.7 Paragraph 120 of the NPPF requires development requires development to prevent unacceptable risks from land contamination. This is reaffirmed by London Plan Policy 5.21. One round of site investigation has been carried out and it has concluded that the risks are low, demonstrating that demolition can commence. As the main investigation was constrained by the presence of the building, the initial trial pits were focused primarily on exposing foundations. Further conditions are required for the construction phase of the Development to ensure any potential land contaminants are appropriately managed.
6.11 Procedural Matters
6.11.1 The application is referable to the Mayor under the provisions of the Town and Country Planning (Mayor of London) Order 2008. The application has been referred to the Mayor at ‘Stage 1’. Before Lambeth can issue a decision on this application it will need to refer the application again to the Mayor at Stage 2; at which point the Mayor will have the opportunity to elect to become determining authority, direct refusal, or allow Lambeth to proceed and issue the decision in line with its resolution.
CONCLUSION
7.1 The proposed redevelopment of the Site would provide a new 355 bedroom hotel of 4* accommodation, an increase of 193 rooms from the existing 162 bedroom hotel. The hotel would also include a number of ancillary uses such as a restaurant, café, bar and business centre, and a separate community use unit, which would provide an active frontage to the sections of the site facing Kennington Road and Lambeth Road.
7.2 The land uses and quantum of development is considered to be appropriate in this central London location with excellent access to public transport facilities and nearby tourist attractions. Despite the proposed intensification of the existing hotel use at the Site, this would not be at the expense of other land uses in the area locally. The Development would not impact unacceptably on neighbouring properties, and furthermore it would not impact unacceptably on local environmental conditions.
7.3 The proposed replacement buildings are considered to be appropriate in their siting, scale, form and detailed design, noting that despite their additional height, they would integrate well with the adjacent buildings and would cause no harm to any of the surrounding heritage assets or local views. Were it to be concluded that less than substantial harm would be caused, this harm would be appropriately offset by sufficient public benefits that the scheme would provide.
7.4 The Development would provide acceptable standards of hotel accommodation, and would not impact unacceptably on the local transport system. Furthermore, the scheme would provide employment and training benefits for local people during the construction phase of the development and in the end use of the site.
7.5 Officers consider that the development would be in compliance with the Development Plan for the Borough. Officers are therefore recommending approval of the scheme, subject to conditions and completion of a Section 106 Agreement.
RECOMMENDATION 8.1 Resolve to grant conditional planning permission subject to any direction that may be received following referral to the Mayor of London and subject to completion of an agreement under Section 106 of the Town and Country Planning Act 1990 of the planning obligations listed in this report.
8.2 Agree to delegate authority to the Director of Planning, Transport and Development to:
Finalise the recommended conditions as set out in this report including such amendments, additions and/or deletions as the Director of Planning, Transport and Development (in consultation with the Planning Committee Chair) considers reasonably necessary; and Negotiate, agree and finalise the planning obligations as set out in this report pursuant to Section 106 of the Town and Country Planning Act 1990, including adding to, amending and/or deleting the obligations detailed in the heads of terms as the Director of Planning, Transport and Development (in consultation with the Planning Committee Chair) considers reasonably necessary.
8.3 That if the Section 106 Agreement is not signed by 30 May 2017 the Director of Planning, Transport and Development be given delegated powers to consider refusing the application in the absence of a legal agreement.
8.4 In the event that the committee resolves to refuse planning permission and there is a subsequent appeal, delegated authority is given to officers, having regard to the heads of terms set out in the report, to negotiate and complete a document containing obligations pursuant to Section 106 of the Town and Country Planning Act 1990 in order to meet the requirements of the Planning Inspector.
Conditions and Reasons
1. The development to which this permission relates must be begun not later than the expiration of three years beginning from the date of this decision notice.
Reason: To comply with the provisions of Section 91(1) (a) of the Town and Country Planning Act 1990 (as amended by Section 51 of the Planning and Compulsory Purchase Act 2004).
2. The development hereby permitted shall be carried out in accordance with the approved plans listed in this notice, other than where those details are altered pursuant to the requirements of the conditions of this planning permission.
Reason: Otherwise than as set out in the decision and conditions, it is necessary that the development be carried out in accordance with the approved plans for the avoidance of doubt and in the interests of proper planning.
3. Prior to the commencement of development above ground level and notwithstanding the details shown on the drawings hereby approved, detailed construction drawings of all external elevations (at scale 1:10) including the following items shall be submitted to and approved in writing by the Local Planning Authority. The development shall not be carried out other than in accordance with the approved details unless otherwise agreed in writing by the Local Planning Authority.
- Detailed elevations; - Details of windows (including technical details, opening methods, elevations, reveal depths, plans and cross sections); - Details of entrances, canopies and doors (including technical details, elevations, surrounds, reveal depths, plans and sections); - Details of roof treatments, cills and parapets; - Details of rainwater goods (including locations and fixings); - Details of boundary treatments including external walls, fences and gates; - Details of external furniture, lighting and ramps; - Vents, extracts, flues and ducts.
Reason: To ensure that the external appearance of the building is satisfactory and to protect the privacy of adjoining occupiers (Policies Q2, Q5 and Q7 of the London Borough of Lambeth Local Plan 2015).
4. Prior to the commencement of development above ground level a schedule of all materials to be used in the external elevations, including samples and a 1:1 scale sample panel of a typical bay window (or an amalgam of typical façade details), shall be submitted and approved in writing by the Local Planning Authority. The development shall not be carried out other than in accordance with the approved materials and details unless otherwise agreed in writing by the Local Planning Authority.
Reason: Details are required prior to the commencement of the development above ground level to ensure that the external appearance of the building is satisfactory (Policies Q5 and Q7 of the London Borough of Lambeth Local Plan 2015).
5. Notwithstanding the details shown on the drawings hereby approved, fritting shall be applied to all hotel room windows (to a height of 0.80 metres above finished floor level) prior to the installation of the glazing to the hotel rooms. Full details (of the design and density of the fritting) shall be submitted to and approved in writing by the Local Planning Authority prior to the installation of the glazing to the hotel rooms. The development shall not be carried out other than in accordance with the approved details unless otherwise agreed in writing by the Local Planning Authority.
Reason: To ensure that the external appearance of the building is satisfactory and to preserve the privacy of the occupiers of the development and surrounding properties (Policies Q2, Q5 and Q7 of the London Borough of Lambeth Local Plan 2015).
6. Notwithstanding the provisions of Article 3 and Class A of Part 2 of Schedule 2 of the Town and Country Planning (General Permitted Development) Order 2015 as amended (or any Order revoking or re-enacting that Order) no gates, fences, walls or other means of enclosure other than those shown on the approved plans (including those which may be agreed pursuant to other conditions of this consent) shall be erected at the site without the prior approval of the Local Planning Authority.
Reason: To ensure the Local Planning Authority suitable control over the details of the development (Policy Q15 of the London Borough of Lambeth Local Plan 2015).
7. At least 10% of the hotel accommodation shall be wheelchair accessible or be readily adaptable to be wheelchair accessible.
Reason: To secure appropriate access for disabled people, in accordance with London Plan Policy 4.5 (2016).
8. No non-road mobile machinery (NRMM) shall be used on the site unless it is compliant with the NRMM Low Emission Zone requirements (or any superseding requirements) and until it has been registered for use on the site on the NRMM register (or any superseding register).
Reason: To ensure that air quality is not adversely affected by the development in line with London Plan (2016) Policy 7.14 and the Mayor’s SPG: The Control of Dust and Emissions During Construction and Demolition.
9. A Travel Plan shall be submitted to and approved in writing by the Local Planning Authority prior to the uses hereby permitted commencing. The measures approved in the Travel Plan shall be implemented prior to the uses hereby permitted commencing and shall be so maintained for the duration of the use, unless the prior written approval of the Local Planning Authority is obtained to any variation.
Reason: To ensure that the travel arrangements to the site are appropriate and to limit the effects of the increase in travel movements (London Plan 2016) Policies 6.3 and 6.13, and London Borough of Lambeth Local Plan 2015 Policy T7).
10. No demolition or development shall commence until full details of the proposed construction methodology, in the form of a Method of Demolition and Construction Statement, have been submitted to and approved in writing by the Local Planning Authority. The Method of Demolition and Construction Statement shall include details regarding:
a) The notification of neighbours with regard to specific works; b) Advance notification of road closures; c) Details regarding parking, deliveries, and storage; d) Details regarding dust mitigation; e) Details of measures to prevent the deposit of mud and debris on the public highway; and f) Any other measures to mitigate the impact of construction upon the amenity of the area and the function and safety of the highway network.
No demolition or development shall commence until provision has been made to accommodate all site operatives', visitors' and construction vehicles loading, offloading, parking and turning within the site or otherwise during the construction period in accordance with the approved details. The demolition and development shall thereafter be carried out in accordance with the details and measures approved in the Method of Demolition and Construction Statement.
Reason: Development must not commence before this condition is discharged to avoid hazard and obstruction being caused to users of the public highway and to safeguard residential amenity from the start of the construction process (Policy 7.14 of the London Plan (2016); and London Borough of Lambeth Local Plan 2015 Policies T6 and T8).
11. Prior to the occupation of the development hereby permitted, details of the provision to be made for cycle parking shall be submitted to and approved in writing by the Local Planning Authority. The cycle parking shall thereafter be implemented in full in accordance with the approved details before the use hereby permitted commences and shall thereafter be retained solely for its designated use.
Reason: To ensure adequate cycle parking is available on site and to promote sustainable modes of transport (Policies T1, T3 and Q13 of the London Borough of Lambeth Local Plan 2015).
12. Prior to the commencement of the uses hereby permitted, details of waste and recycling storage and waste management for the development shall be submitted to and approved in writing by the Local Planning Authority. The waste and recycling storage shall be provided in accordance with the approved details prior to the commencement of the uses hereby permitted, and shall thereafter be retained solely for its designated use. The waste and recycling storage areas/facilities should comply with the Lambeth’s Refuse & Recycling Storage Design Guide (2013), unless it is demonstrated in the submissions that such provision is inappropriate for this specific development.
Reason: To ensure suitable provision for the occupiers of the development, to encourage the sustainable management of waste and to safeguard the visual amenities of the area (Policies Q2 and Q12 of the London Borough of Lambeth Local Plan 2015).
13. The development hereby approved shall be operated in accordance with the submitted Delivery and Servicing Management Plan (March 2017), and shall be maintained as such for the duration of the use.
Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally, and to avoid unnecessary hazard and obstruction to the public highway (Policies EN4, EN7, and T8 of the London Borough of Lambeth Local Plan 2015).
14. There shall be no deliveries to the premises hereby permitted shall take place other than within the following times:
- 07:00 Hours to 20:00 Hours – All week.
Reason: To ensure that the delivery arrangements to the building as a whole are appropriate and to limit the effects of the increase in travel movements and impacts on neighbouring amenity (Policies Q2 and T8 of the London Borough of Lambeth Local Plan 2015).
15. No demolition below ground level or development shall take place until a stage 1 written scheme of investigation (WSI) has been submitted to and approved by the Local Planning Authority in writing. For land that is included within the WSI, no demolition below ground level or development shall take place other than in accordance with the agreed WSI, and the programme and methodology of site evaluation and the nomination of a competent person(s) or organisation to undertake the agreed works.
If heritage assets of archaeological interest are identified by stage 1 then for those parts of the site which have archaeological interest a stage 2 WSI shall be submitted to and approved by the Local Planning Authority in writing. For land that is included within the stage 2 WSI, no demolition below ground level/development shall take place other than in accordance with the agreed stage 2 WSI which shall include:
A. The statement of significance and research objectives, the programme and methodology of site investigation and recording and the nomination of a competent person(s) or organisation to undertake the agreed works
B. The programme for post-investigation assessment and subsequent analysis, publication & dissemination and deposition of resulting material. This part of the condition shall not be discharged until these elements have been fulfilled in accordance with the programme set out in the stage 2 WSI.
Reason: Development must not commence before this condition is discharged to safeguard the heritage of the borough by ensuring that any archaeological remains that may exist on site are not permanently destroyed (Policy 7.8 of the London Plan (2016).
16. No piling shall take place until a Piling Method Statement (detailing the depth and type of piling to be undertaken and the methodology by which such piling will be carried out, including measures to prevent and minimise the potential for damage to subsurface sewerage infrastructure, and the programme for the works) has been submitted to and approved in writing by the Local Planning Authority in consultation with Thames Water. Any piling must be undertaken in accordance with the terms of the approved Piling Method Statement.
Reason: To ensure that the pilling works would not have an unacceptable impact upon the local underground sewerage utility infrastructure.
17. The development shall be constructed and operated thereafter to ‘Secured by Design Standards’. A certificate of accreditation to Secured by Design Standards shall be submitted to the Local Planning Authority for approval in writing prior to the occupation of the development.
Reason: To ensure that the development maintains and enhances community safety (Policy Q3 of the London Borough of Lambeth Local Plan 2015).
18. Prior to the occupation of the development hereby permitted, a Crime Prevention Strategy Plan shall be submitted to and approved in writing by the Local Planning Authority. The use hereby permitted shall thereafter be operated in accordance with the approved details. The submitted details will include the following:
a) Location and management of all CCTV cameras; b) How the operation and management of the facilities will reduce the risks of crime and enhance community safety.
Reason: To ensure that the development maintains and enhances community safety (Policy Q3 of the London Borough of Lambeth Local Plan 2015).
19. No building hereby permitted shall be occupied until the sustainable drainage scheme for the site has been completed in accordance with the submitted details. The sustainable drainage scheme shall be managed and maintained thereafter in accordance with the agreed management and maintenance plan.
Reason: To manage the water environment of the development and mitigate the impact on flood risk, water quality, habitat and amenity value (Policies EN5 and EN6 of the London Borough of Lambeth Local Plan 2015).
20. Prior to the commencement of building works above ground of the relevant part of the development, full details of any internal and external plant equipment and trunking, including building services plant, ventilation and filtration equipment and commercial kitchen exhaust ducting / ventilation and their on-going maintenance, shall be submitted to and approved in writing by the Local Planning Authority. All flues, ducting and other equipment shall be installed in accordance with the approved details prior to the use commencing on site and shall thereafter be maintained in accordance with the manufacturer's instructions and approved on-going maintenance plan.
Reason: To ensure that no nuisance or disturbance is caused to the detriment of the amenities of future residential occupiers or of the area generally (Policy Q2 of the London Borough of Lambeth Local Plan 2015).
21. The use hereby permitted, or the operation of any building services plant, shall not commence until an assessment of the acoustic impact arising from the operation of all internally and externally located plant has been submitted to and approved in writing by the Local Planning Authority.
The assessment of the acoustic impact shall be undertaken in accordance with BS 4142: 2014 (or subsequent superseding equivalent) and current best practice, and shall include a scheme of attenuation measures to ensure the rating level of noise emitted from the proposed building services plant is 5db less than background.
The use hereby permitted, or the operation of any building services plant, shall not commence until a post-installation noise assessment has been carried out to confirm compliance with the noise criteria. The scheme shall be implemented in accordance with the approved details and attenuation measures, and they shall be permanently retained and maintained in working order for the duration of the use and their operation.
Reason: To protect the amenities of adjoining occupiers and the surrounding area (Policy Q2 of the London Borough of Lambeth Local Plan 2015).
22. Prior to the commencement of development a scheme of noise and vibration attenuation shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall achieve the habitable room standard as detailed in BS8233:2014 with no relaxation for exceptional circumstances and must include details of post construction validation. The approved noise and vibration attenuation measures shall thereafter be retained and maintained in working order for the duration of the use in accordance with the approved details.
Reason: To ensure that no nuisance or disturbance is caused to the detriment of the amenities of future occupiers (Policy Q2 of the London Borough of Lambeth Local Plan 2015).
23. Prior to commencement a detailed assessment of the lighting scheme detailed in Max Fordham Report J4845: Kennington Road dated September 2016 must be submitted to and approved in writing by the Local Planning Authority. The assessment must demonstrate that the impact of the proposed scheme complies with the Institute of Lighting Professional’s Guidance notes for the reduction of obstructive light and appropriate mitigation measures must be designed by a suitably qualified person in accordance with the recommendations to ensure compliance with environmental zone E4 in the ILP document “Guidance Notes for the Reduction of Obtrusive Light GN01:2011.
Before commencement of operation of the approved lighting scheme the applicant shall appoint a suitably qualified person to validate that the lighting scheme as installed conforms to the recommendations for environmental zone E4 in the ILP document “Guidance Notes for the Reduction of Obtrusive Light GN01:2011”.
Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally (Policy Q2 of the London Borough of Lambeth Local Plan 2015).
24. No development other than demolition shall commence until the following components of a scheme to deal with the risks associated with contamination of the site have been submitted to and approved in writing by the Local Planning Authority:
i) A site investigation scheme, based on previous findings to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off- site; ii) The site investigation results and the detailed risk assessment resulting from a); iii) An options appraisal and remediation strategy giving full details of the remediation measures required and how they are to be undertaken; iv) A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in iii) are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action.
The development shall thereafter be implemented in accordance with the details and measures approved.
Reason: Development must not commence before this condition is discharged to safeguard future users or occupiers of this site and the wider environment from irreversible risks associated with the contaminants which are present by ensuring that the contaminated land is properly treated and made safe before development. Depending on the outcome of any ground investigation and subsequent risk assessment, it may be necessary for remediation to be carried out. If this is the case, it will be necessary to demonstrate that any work has been carried out effectively and the environmental risks have been satisfactorily managed (Policies 5.21 of the London Plan (2016) and EN4 of the London Borough of Lambeth Local Plan 2015).
25. Prior to occupation of any part of the development, a verification report demonstrating completion of the works set out in the approved remediation strategy and the effectiveness of the remediation shall be submitted to and approved in writing by the Local Planning Authority. The report shall include results of sampling and monitoring carried out in accordance with the approved verification plan to demonstrate that the site remediation criteria have been met. It shall also include any plan (a “long-term monitoring and maintenance plan”) for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action, as identified in the verification plan, and for the reporting of this to the Local Planning Authority.
Reason: To safeguard future users or occupiers of this site and the wider environment from irreversible risks associated with the contaminants which are present by ensuring that the contaminated land is properly treated and made safe before development. (Policies 5.21 of the London Plan (2016) and EN4 of the London Borough of Lambeth Local Plan 2015).
26. If, during development, contamination not previously identified is found to be present at the site then no further development shall be carried out until the developer has submitted, and obtained written approval from the Local Planning Authority for, an amendment to the remediation strategy detailing how this unsuspected contamination will be dealt with.
Reason: To safeguard future users or occupiers of this site and the wider environment from irreversible risks associated with the contaminants which are present by ensuring that the contaminated land is properly treated and made safe before development. (Policies 5.21 of the London Plan (2016) and EN4 of the London Borough of Lambeth Local Plan 2015).
27. The use of the outdoor seating area to the bar shall be limited to within the following times:
- 08:00 Hours to 22:30 Hours – All week.
Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally (Policy Q2 of the London Borough of Lambeth Local Plan 2015).
28. Notwithstanding the provisions of the Town and Country Planning (Use Classes) Order 1987 or the Town and Country Planning (General Permitted Development) Order 2015 (as amended) (or any orders revoking and re-enacting those orders with or without modification) the ‘community facility’ shown on the proposed ground floor plan (drawing number 02-03-100 D) shall not be used for any purpose other than for purposes that fall within Use Classes B1, D1 or D2 in the Schedule to the Town and Country Planning (Use Classes) Order 1987.
Reason: To ensure that no nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers or users of the area generally (Policy Q2 of the London Borough of Lambeth Local Plan (2015)).
29. No trees other than those shown to be removed on the approved Tree Removal Plan (Drawing Number: 5567-D-2 A) and referenced to in the approved Arboricultural Report prepared by Hayden’s Arboricultural Consultants dated 01/09/2016 (Ref No.5567) shall be felled, pruned, uprooted, damaged or otherwise disturbed without the prior written agreement of the Local Planning Authority.
Reason: To ensure the retention of, and avoid damage to, the retained trees on the site which represent an important visual amenity to the locality (Policies Q2, Q9 and Q10 of the London Borough of Lambeth Local Plan 2015).
30. Prior to the commencement of the development hereby approved, the following details shall be submitted to the Local Planning Authority for written approval:
(a) A Tree Protection Plan that accords with Section 7 of BS5837:2012 and relates to all retained trees on the site;
(b) Details of all proposed Access Facilitation Pruning required to permit the development. Thereafter, the approved works shall be carried out in accordance with BS3998:2010;
(c) An Arboricultural Method Statement in accordance with section 7 of the BS5837:2012 relating to (i) the removal of existing hard surface material and installation of new surfacing within the root protection area of retained trees and (ii) the associated lowering or building up of soil levels around the retained trees;
(d) Details of a scheme of Arboricultural Site Supervision and Tree Protection Monitoring. The details shall include an on-site ‘Pre-commencement’ meeting to include the Lambeth Council’s Arboricultural Officer as part of the site induction process.
The development shall thereafter be implemented in strict accordance with the approved details listed above. The approved details of the Tree Protection Plan shall be put in place before any machinery, demolition, materials storage or development commences on the site.
Reason: To ensure the retention of, and avoid damage to, the retained trees on the site which represent an important visual amenity to the locality (Policies Q2, Q9 and Q10 of the London Borough of Lambeth Local Plan 2015).
31. Prior to commencement of above ground building works, a specification of all proposed soft landscaping and tree planting has been submitted to and approved in writing by the Local Planning Authority. The scheme of soft landscaping shall include details of the quantity, size, species, position and the proposed time of planting of all trees and shrubs to be planted, together with an indication of how they integrate with the proposal in the long term with regard to their mature size and anticipated routine maintenance and protection. All tree, shrub and hedge planting included within the above specification shall accord with BS3936:1992, BS4043:1989 and BS8545:2015 and current Arboricultural best practice.
Reason: To ensure a satisfactory and appropriate landscape scheme relative to the development in order to comply with Policy Q9 of the London Borough of Lambeth Local Plan 2015.
32. All planting, seeding or turfing comprised in the approved details of landscaping shall be carried out in the first planting and seeding season following the occupation of the development hereby permitted or the substantial completion of the development, whichever is the sooner. Any trees, hedgerows or shrubs forming part of the approved landscaping scheme which within a period of five years from the occupation or substantial completion of the development die, are removed or become seriously damaged or diseased shall be replaced in the next planting season with others of similar size and species, unless the Local Planning Authority gives written consent to any variation.
Reason: To ensure a satisfactory and appropriate landscape scheme relative to the development in order to comply with Policy Q9 of the London Borough of Lambeth Local Plan 2015.
33. The development shall be implemented in accordance with the approved Energy Strategy (Rev. B) and shall not commence until full Design Stage calculations under the National Calculation Method have been submitted to and approved in writing by the Local Planning Authority to show that the development will be constructed in accordance with the approved Energy Strategy and achieve at least a 35% reduction in carbon dioxide emissions over that required by Part L of the Building Regulations 2013.
Prior to first occupation of the building(s) evidence (e.g. photographs, installation contracts and as-built certificates under the National Calculation Method) should be submitted to the Local Planning Authority and approved in writing to show that the development has been constructed in accordance with approved Energy Strategy and achieved at least a 35% reduction in carbon dioxide emissions over that required by Part L of the Building Regulations 2013.
Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan (2016) Policy 5.2 and London Borough of Lambeth Local Plan (2015) Policy EN3.
34. The development shall be implemented in accordance with the approved Energy Strategy and the relevant works shall not commence until details of the proposed solar PV array has been submitted to and approved in writing by the Local Planning Authority. The PV panelling shall be installed in accordance with the approved details and retained as such for the duration of the use.
Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan (2016) Policy 5.2 and London Borough of Lambeth Local Plan (2015) Policy EN3.
35. Details of an extensive green roof which shall be compliant with GRO Green Roof Code 2011 shall be submitted to and approved in writing by the Local Planning Authority prior to the implementation of the relevant part of the development hereby approved.
The submission must provide/comprise the following information:
a) Details on materials used in the design, construction and installation of the green roof based on the Green Roof Code and the use of biodiversity based extensive/semi- intensive soils; b) Details on substrate and plants used in the green roof, based on a commercial brick-based aggregate or equivalent with a varied substrate depth of 80 -150mm planted with 50% locally native herbs/wildflowers in addition to a variety of sedum species; c) Details on additional features to the proposed green roof, such as areas of bare shingle, areas of sand for burrowing invertebrates and individual logs or log piles; d) An ecological management and maintenance plan including landscape features and a cross section of the green roof.
The development shall be carried out strictly in accordance with the green roof details approved, shall be maintained as such thereafter and no alterations to the approved scheme shall be permitted without the prior written consent of the Local Planning Authority.
Prior to first occupation of the building(s) evidence that the green roof has been installed in accordance with the approved details should be submitted to and approved by the Local Planning Authority prior to first occupation.
Reason: To ensure that the development has an acceptable level of sustainability (Policy EN4 of the London Borough of Lambeth Local Plan 2015).
36. Within 3 months of work starting on site a BREEAM UK New Construction 2014 (or such equivalent standard that replaces this) Design Stage certificate and summary score sheet must be submitted to and approved in writing by the Local Planning Authority to show that an Excellent rating will be achieved.
Within 3 months of first occupation of the building(s) a BREEAM UK New Construction 2014 (or such equivalent standard that replaces this) Post Construction Review certificate and summary score sheet must be submitted to and approved in writing by the Local Planning Authority to show that an Excellent rating has been achieved. All the measures integrated shall be retained for as long as the development is in existence.
Reason: To ensure that the development has an acceptable level of sustainability (Policy EN4 of the London Borough of Lambeth Local Plan 2015).
Informatives
1) This decision letter does not convey an approval or consent which may be required under any enactment, by-law, order or regulation, other than Section 57 of the Town and Country Planning Act 1990.
2) Your attention is drawn to the provisions of the Building Regulations, and related legislation which must be complied with to the satisfaction of the Council's Building Control Officer.
3) You are advised to consult the Council's Environmental Health Division concerning compliance with any requirements under the Housing, Food, Safety and Public Health and Environmental Protection Acts and any by-laws or regulations made there under.
4) Your attention is drawn to the provisions of The Party Wall Act 1996 in relation to the rights of adjoining owners regarding party walls etc. These rights are a matter for civil enforcement and you may wish to consult a surveyor or architect.
5) You are advised of the necessity to consult the Council's Streetcare team within the Public Protection Division with regard to the provision of refuse storage and collection facilities.
6) You are advised of the necessity to consult the Council’s Highways team prior to the commencement of construction on 020 7926 9000 in order to obtain necessary approvals and licences prior to undertaking any works within the Public Highway including Scaffolding, Temporary/Permanent Crossovers, Oversailing/Undersailing of the Highway, Drainage/Sewer Connections, Hoarding, Excavations (including adjacent to the highway such as basements, etc), Temporary Full/Part Road Closures, Craneage Licences etc.
7) Regarding construction management, please note the comments received by LB Lambeth Officers, TfL and from the LB Southwark, who advised that clarity is required on routes that would be used during the construction phase of the development given the potential impact on Southwark roads. Access / egress to the proposed hotel development using Blackfriars Road and the Elephant and Castle should be avoided as far as possible due to the high volume of construction vehicles already in these areas. Furthermore, HGV vehicles should avoid peak hours when using Southwark roads. It is further advised by TfL that all construction measures should be implemented in partnership with the Nine Elms Construction Logistics Co-ordination Team.
You are advised to contact Nick Greaves (020 7926 0331 and [email protected]) at the LB Lambeth to discuss the final construction management plan regarding:
- Enabling works – Licences (Hoarding/Scaffold/Fence/Crane/Cherry Picker/Mobile tower/hoist), Temporary restrictions (TTRO’s) required to facilitate construction and any temporary access requirements (Crossovers). - Highways Investment under Section 278/38 of the Highways Act 1980 – The applicant should be made aware that only our approved term contractor works on the public highway, therefore any S278/S38 projects need to be programmed in advance to avoid delays when it comes to construction.
8) You are advised that this permission does not authorise the display of illuminated advertisements at the premises and separate consent may be required from the Local Planning Authority under the Town and Country Planning (Control of Advertisements) Regulations 1992.
9) The Environment Agency strongly recommends that the applicant consults their Pollution Prevention Guidance notes (PPGs). These are aimed at a wide range of industries and activities that have the potential to cause pollution. They can be downloaded from their website (www.environment-agency.gov.uk)
10) Regarding condition 15, written schemes of investigation will need to be prepared and implemented by a suitably qualified professionally accredited archaeological practice in accordance with Historic England’s Guidelines for Archaeological Projects in Greater London. This condition is exempt from deemed discharge under schedule 6 of The Town and Country Planning (Development Management Procedure) (England) Order 2015.
It is envisaged that the archaeological fieldwork would comprise the following:
Evaluation
An archaeological field evaluation involves exploratory fieldwork to determine if significant remains are present on a site and if so to define their character, extent, quality and preservation. Field evaluation may involve one or more techniques depending on the nature of the site and its archaeological potential. It will normally include excavation of trial trenches. A field evaluation report will usually be used to inform a planning decision (predetermination evaluation) but can also be required by condition to refine a mitigation strategy after permission has been granted.
11) With regard to condition 16, the applicant is advised to contact Thames Water Developer Services on 0800 009 3921 to discuss the details of the piling method statement.
12) For information on the NRMM Low Emission Zone requirements and to register NRMM, please visit “http://nrmm.london/”.
13) Thames Water comments are as follows:
Waste Comments
Following initial investigation, Thames Water has identified an inability of the existing waste water infrastructure to accommodate the needs of this application. Should the Local Planning Authority look to approve the application, Thames Water would like the following 'Grampian Style' condition imposed. “Development shall not commence until a drainage strategy detailing any on and/or off site drainage works, has been submitted to and approved by, the local planning authority in consultation with the sewerage undertaker. No discharge of foul or surface water from the site shall be accepted into the public system until the drainage works referred to in the strategy have been completed”. Reason - The development may lead to sewage flooding; to ensure that sufficient capacity is made available to cope with the new development; and in order to avoid adverse environmental impact upon the community. Should the Local Planning Authority consider the above recommendation is inappropriate or are unable to include it in the decision notice, it is important that the Local Planning Authority liaises with Thames Water Development Control Department (telephone 0203 577 9998) prior to the Planning Application approval.
Surface Water Drainage
With regard to surface water drainage it is the responsibility of a developer to make proper provision for drainage to ground, water courses or a suitable sewer. In respect of surface water it is recommended that the applicant should ensure that storm flows are attenuated or regulated into the receiving public network through on or off site storage. When it is proposed to connect to a combined public sewer, the site drainage should be separate and combined at the final manhole nearest the boundary. Connections are not permitted for the removal of groundwater. Where the developer proposes to discharge to a public sewer, prior approval from Thames Water Developer Services will be required. The contact number is 0800 009 3921. Reason - to ensure that the surface water discharge from the site shall not be detrimental to the existing sewerage system.
Thames Water requests that the Applicant should incorporate within their proposal, protection to the property by installing for example, a non-return valve or other suitable device to avoid the risk of backflow at a later date, on the assumption that the sewerage network may surcharge to ground level during storm conditions.
There are public sewers crossing or close to your development. In order to protect public sewers and to ensure that Thames Water can gain access to those sewers for future repair and maintenance, approval should be sought from Thames Water where the erection of a building or an extension to a building or underpinning work would be over the line of, or would come within 3 metres of, a public sewer. Thames Water will usually refuse such approval in respect of the construction of new buildings, but approval may be granted for extensions to existing buildings. The applicant is advised to visit thameswater.co.uk/buildover
No piling shall take place until a piling method statement (detailing the depth and type of piling to be undertaken and the methodology by which such piling will be carried out, including measures to prevent and minimise the potential for damage to subsurface sewerage infrastructure, and the programme for the works) has been submitted to and approved in writing by the local planning authority in consultation with Thames Water. Any piling must be undertaken in accordance with the terms of the approved piling method statement. Reason: The proposed works will be in close proximity to underground sewerage utility infrastructure. Piling has the potential to impact on local underground sewerage utility infrastructure. The applicant is advised to contact Thames Water Developer Services on 0800 009 3921 to discuss the details of the piling method statement.
‘We would expect the developer to demonstrate what measures he will undertake to minimise groundwater discharges into the public sewer. Groundwater discharges typically result from construction site dewatering, deep excavations, basement infiltration, borehole installation, testing and site remediation. Any discharge made without a permit is deemed illegal and may result in prosecution under the provisions of the Water Industry Act 1991. Should the Local Planning Authority be minded to approve the planning application, Thames Water would like the following informative attached to the planning permission: “A Groundwater Risk Management Permit from Thames Water will be required for discharging groundwater into a public sewer. Any discharge made without a permit is deemed illegal and may result in prosecution under the provisions of the Water Industry Act 1991. We would expect the developer to demonstrate what measures he will undertake to minimise groundwater discharges into the public sewer. Permit enquiries should be directed to Thames Water’s Risk Management Team by telephoning 02035779483 or by emailing [email protected]. Application forms should be completed on line via www.thameswater.co.uk/wastewaterquality.”
Thames Water recommends the installation of a properly maintained fat trap on all catering establishments. We further recommend, in line with best practice for the disposal of Fats, Oils and Grease, the collection of waste oil by a contractor, particularly to recycle for the production of bio diesel. Failure to implement these recommendations may result in this and other properties suffering blocked drains, sewage flooding and pollution to local watercourses.
Water Comments
Thames Water recommend the following informative be attached to this planning permission. Thames Water will aim to provide customers with a minimum pressure of 10m head (approx 1 bar) and a flow rate of 9 litres/minute at the point where it leaves Thames Waters pipes. The developer should take account of this minimum pressure in the design of the proposed development.
No piling shall take place until a piling method statement (detailing the depth and type of piling to be undertaken and the methodology by which such piling will be carried out, including measures to prevent and minimise the potential for damage to subsurface water infrastructure, and the programme for the works) has been submitted to and approved in writing by the local planning authority in consultation with Thames Water. Any piling must be undertaken in accordance with the terms of the approved piling method statement. Reason: The proposed works will be in close proximity to underground water utility infrastructure. Piling has the potential to impact on local underground water utility infrastructure. The applicant is advised to contact Thames Water Developer Services on 0800 009 3921 to discuss the details of the piling method statement.
Supplementary Comments
Waste - The surface water drainage strategy for this development should follow policy 5.13 of the London Plan. Typically Greenfield run off rates of 5l/s/ha should be aimed for using the drainage hierarchy. The hierarchy lists the preference for surface water disposal as follows; Store Rainwater for later use > Use infiltration techniques, such as porous surfaces in non- clay areas > Attenuate rainwater in ponds or open water features for gradual release > Discharge rainwater direct to a watercourse > Discharge rainwater direct to a surface water sewer/drain > Discharge rainwater to the combined sewer.
Background documents – Case file (this can be accessed via the planning Advice Desk, Telephone 020 7 926 1180).
For advice on how to make further written submissions or to register to speak on this item, please contact Democratic Services, 020 796 2170 or email.