98 York Road, Battersea in the London Borough of Wandsworth Planning Application No

planning report D&P/3099a 6 May 2015 98 York Road, Battersea in the London Borough of Wandsworth planning application no. 2014/7103

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

The proposal Demolition of existing buildings and erection of mixed-use development of up to seventeen storeys (three-storey podium with fourteen storey, eleven storey and 2 six storey buildings above) to provide: car showroom and workshop with ancillary cafe on ground, first and second floors; 192 residential units above; landscaped amenity deck at podium level; basement car park with 87 vehicle and 200 cycle parking spaces; 29 parking space for customers at ground floor level. The applicant The applicant is Linden (York Road) LLP and the Dutton-Forshaw Motor Company; the architects are GRID and the planning agent is Rapleys LLP.

Strategic issues Wandsworth Council has resolved to refuse permission for this application. The Mayor must consider whether the application warrants a direction to take over determination of the application under Article 7 of the Mayor of London Order 2008. Having regard to the details of the application, the matters set out in the committee report and the Council’s draft decision notice there are no sound planning reasons for the Mayor to intervene in this particular case and therefore no basis to issue a direction under Article 7 of the Order 2008. Should the scheme be considered at appeal or a revised application submitted the applicant should have regard to the matters raised in this report on: housing; affordable housing; urban design; inclusive access; transport; and climate change mitigation.

The Council’s decision In this instance Wandsworth Council has resolved to refuse permission. Recommendation That Wandsworth Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct that he is to be the local planning authority.

page 1 Context

1 On 8 January 2015, the Mayor of London received documents from Wandsworth Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Categories 1A and 1C of the Schedule to the Order 2008:

“1A 1. Development which comprises or includes the provision of more than 150 houses, flats or houses and flats;

1C 1. Development which comprises or includes the erection of a building of one or more of the following descriptions:

(a) The building is more than 25 metres high and is adjacent to the River Thames”.

2 On 18 February 2015,the Mayor considered planning report D&P/3099a , and subsequently advised Wandsworth Council that the application did not comply with the London Plan, for the reasons set out in paragraph 75 of that report; but that the possible remedies set out in that paragraph could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. On 16 April 2015, Wandsworth Council resolved to refuse planning permission for the application. The application was recommended for approval by officers but was refused by Committee and on 24 April the Council advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, or issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application The Mayor has until 7 May 2015 to notify the Council of his decision and to issue any direction.

4 The Council’s draft decision notice includes the following reason for refusal:

The proposed massing and design by reason of the density of the development would constitute an unneighbourly form of development that would result in an unacceptable level of harm to the amenities of the occupants of neighbouring properties through overlooking and loss of privacy. As such the proposal is contrary to Policy DMS1 of the Development Management Policies Document 2012, the Second Proposed Submission Version 2014 and Policy 3.4 of the London Plan, March 2015.

5 The Mayor’s decision on this case, and the reasons, will be made available on the GLA’s website www.london.gov.uk. Article 7: Direction that the Mayor is to be the local planning authority

6 The initial policy test regarding the Mayor’s power to take over and determine applications referred under categories 1 and 2 of the schedule to the Order is a decision about who should have jurisdiction over the application rather than whether planning permission should ultimately be granted or refused.

7 The policy test consists of the following three parts, all of which must be met in order for the Mayor to take over the application: a) significant impact on the implementation of the London Plan; b) significant effects on more than one borough; and c) sound planning reasons for his intervention.

page 2 8 It should be noted that, as the proposals fall within category 1A of the schedule to the order, test (b) does not apply.

9 While it is acknowledged that the proposals would contribute towards employment and housing in Wandsworth, in this instance given the scale of the proposals, the refusal of the planning permission is not considered to have a significant impact on the implementation of the London Plan. The application therefore fails test (a) above.

10 Given that the proposals fail test (a), there are no sound planning reasons for the Mayor’s intervention under test (c).

11 In order for the Mayor to issue a direction that he is to be the local planning authority, all relevant policy tests must be met. Given that the tests have not been met, there is no basis to issue a direction under Article 7.

Issues outstanding

12 Notwithstanding the above, should the scheme be considered at appeal or a revised application be submitted the applicant should have regard to the matters considered below. Principle of development

13 At stage 1, the applicant was advised that the principle of mixed-use development on the site was acceptable, subject to further information being provided for the increase in the car showroom floorspace. The applicant has set out that the internal layout of the car dealership meets a specific brief and that the size is appropriate to the future occupiers, which minimises the risk of the floorspace remaining vacant. The applicant also considers that, should the dealership vacate the premises in the future, a number of alternative uses could be accommodated within the footprint of the building due to the large floor to ceiling heights. The Council’s committee report sets out that the reprovision of the sui generis floorspace is supported in local policy.

14 The concerns raised at stage 1 regarding the sui generis floorspace have been addressed and the increase in this is acceptable in strategic terms. Housing

Affordable housing

15 GLA officers considered the proposed affordable housing offer at stage 1 to be very low, at 16%. Additionally, GLA officers considered that it should be possible for all affordable housing to be delivered on site.

16 Since stage 1, the Council, with its independent assessors, has negotiated an increase in affordable housing from 16% to 26%, which equates to fifty shared ownership units on site. The applicant had also agreed to an additional commuted sum of £500,000 towards off site affordable housing. The Council’s independent assessors have confirmed that this is the maximum reasonable amount of affordable housing that could be achieved. The increase in affordable housing is supported.

17 While this offer would not comply with London Plan objectives to provide 60% of all affordable housing as social/affordable rent and 40% as intermediate housing, the option to include social rent was explored. The assessment concluded that only seventeen social rented units could be provided, with no commuted sum. The committee report sets out that the Assistant Director of Housing Strategy and Development considered it preferable to maximise the amount of affordable housing on site through the intermediate housing offer.

page 3 18 GLA officers support the increase in affordable housing and issues raised at stage 1 have been addressed.

Housing choice

19 The Council was asked at stage 1 to confirm that the proposed housing mix would be in line with local needs. The committee report sets out that the provision of one bedroom units is 16%, which is below the maximum set out in local policy, and the proportion of family accommodation would meet the 5% minimum set out in local policy. GLA officers are therefore satisfied that the Council has assessed the unit mix against local needs and that the proposed unit mix is acceptable.

Children’s playspace

20 Officers raised queries regarding the anticipated child yield at stage 1, as this could not be confirmed until the final tenure split was fixed. The committee report explains that the proposals would result in eighteen children initially and 27 over time, using the Borough’s population yield calculator. The podium amenity area would comprise 1,622 sq.m. of open space, in which the required 270 sq.m. of playspace could be accommodated. Informal opportunities for play are demonstrated in the landscaping details. In addition, a condition was recommended for details of landscaping, which would include details of children’s playspace. Officers support this approach, which addresses concerns raised at stage 1. Any future planning permission for a revised or appeal proposal should include this condition. Urban design

21 While the proposed height and massing did not pose any strategic concern at stage 1, it was recommended that the Council should confirm whether the height of the proposals is acceptable, due to local policy setting out that tall buildings are likely to be inappropriate on this site. The committee report explains that the current policy position regarding the acceptability of tall buildings in this location is under review, and that the site’s policy context could change significantly. However, as limited weight can be afforded to this at present, the committee report contains a thorough assessment of the design of the proposals, including an assessment against criteria in the Council’s tall building policy. It concludes that the form, scale and massing of the buildings represents a considered response to the site’s context where the height of the buildings would be compatible with the character and sensitivity of the location, addressing the point raised at stage 1. GLA officers share the view put forward in the committee report.

22 GLA officers also recommended at stage 1 that the cafe unit on the southern edge of the car showroom should be designed so that it could function as a self-contained retail unit, contributing to generating activity on the public realm. While it is welcomed that the cafe would be open to members of the public as well as customers, this point should be considered in any revised or appeal scheme.

23 In line with stage 1 comments, details of materials have been secured by condition. Overall, as set out at stage 1, the proposed design of the proposals is broadly acceptable in strategic terms. Inclusive access

24 At stage 1, the applicant was asked to confirm the wheelchair unit mix. While the applicant has explained that the wheelchair unit mix is set out in the design and access statement, there is still a discrepancy between the text, which states that all wheelchair units would be two bedroom, three person units, and the sample layouts, which range from one bedroom, one person to two bedroom, three person units. For any revised or appeal proposals, the applicant should confirm the mix of wheelchair units, and the wheelchair units should be secured by condition. The GLA welcomes the Council’s approach to recommending that the occupational therapist is consulted on the layout of the affordable wheelchair units.

page 4 25 Officers suggested at stage 1 that consideration should be given to a second lift in block D, or a lift traffic analysis should be provided. The applicant has responded, stating that for block D, there are only seven storeys actually served by the lift, i.e. the oversized ground floor and the six residential storeys above the podium. Notwithstanding this, the applicant has provided a lift traffic analysis. This demonstrates that the performance would be above the minimum guideline standards. As there would be no wheelchair units proposed in block D, and as the applicant has assessed the impact of the single lift arrangement, this is acceptable.

26 In response to stage 1 comments, the applicant has clarified that access from the lift cores to the Podium Garden would be level and has provided a plan to demonstrate this.

27 As suggested at stage 1, a car parking management was included in the draft heads of terms.

28 While the proposals would be broadly acceptable in inclusive access terms, any revised or appeal application should take account of the comments regarding wheelchair units. Transport for London’s comments

29 In regard to TfL’s Stage 1 comments, adequate clarifications or revisions were made, or suitable conditions identified able to address the matters raised. Mechanisms to secure electric vehicle charging points, CPZ parking permit restrictions, car club membership, travel plans, a car parking management plan, construction logistics / management plan, and a delivery and servicing management plan were set out as section 106 heads of terms. Additionally, the requested £100,000 contribution towards the cycle hire scheme, and a contribution of £12,350 towards bus shelter upgrade works were also secured. While not referenced in the committee report, there would be a need to enter into a section 278 agreement with TfL in order to deliver the proposed public realm works on York Road.

30 In the event of an appeal or revised scheme, TfL would request all the above details, conditions and obligations be secured on any subsequent planning permission to mitigate the impact of the development. Climate change mitigation

31 Following comments from stage 1, the applicant has provided further information regarding overheating, cooling, the site heat network and the CHP. The Council also recommended a draft condition requiring the development to be built in accordance with the energy strategy, securing a minimum of 35.4% site-wide reduction in CO2 emissions. The Council has recommended a condition securing the proposed surface water drainage scheme, as well as ensuring that the proposal is carried out in accordance with the flood risk assessment.

32 The application is acceptable in terms of climate change mitigation and the proposed energy, flooding and drainage conditions should be secured for any revised or appeal proposals.

Response to consultation

33 The application was advertised by site and press notice, and 983 neighbour consultation letters were sent.

34 There were 101 responses received, twelve of which were in support and 89 of which were objections. Two responses were also sent directly to the Mayor.

page 5 35 The two responses sent directly to the Mayor were both objections from the same objector and can be summarised as follows:

 The proposals would significantly impact on daylight and overshadowing to existing residential units in Orbis Wharf, Altura Tower and Bridges Wharf; significant reduction in daylight of up to 98% to existing residential; proposals set precedent for overlooking and developments which block light; extent and height of the proposed development exceeds developments in locality; impact on privacy; volume, density and height of tower are unnecessary and should be a maximum of five storeys; parking stress would worsen; section 106 obligations should be publically available.

 The objector is not against reasonable development, but the proposed seventeen, 25 and thirty storey towers are beyond reasonable; the applicant’s response that there would be no detriment to the privacy of existing residents from a fourteen storey development is insulting; loss of sunlight of 70-80% for well over half of the existing neighbouring homes is far beyond acceptable; the development could have been limited to a reasonable six storeys and tiered to allow for daylight and sunlight.

36 Three responses were received from local amenity groups, summarised below:

 Battersea society: objects as not in accordance with policies and objectives of local plan; overdevelopment; fails to meet needs for successful integration of this and other sites within a masterplan for the area; height and design are detrimental to effect of tall buildings on the townscape; contrary to policy stating that this site is not suitable for a tall building; outline masterplan would have negative impact on the area as not endorsed; new buildings would block off views through existing blocks, tower over neighbouring buildings and contradict more sensitive approach being taken by other landowners in the area; unacceptable visual impact on surrounding areas; fail to support and complement surrounding land use pattern and local community; massing and scale would fail to create a form that is well integrated into surrounding development; failure to link across York Road through York Gardens to Clapham Junction; increased stress on transport and traffic capacity in already heavily trafficked area; full review of transport and road capacity is required; lack of affordable housing.

 Candlemakers Management Company Ltd: proposal is over development; unduly dense; buildings too high and dominant; out of character fronting York Road; detrimental to residential amenities; site not appropriate for tall buildings as set out in policy; seventeen storey towers would be dominant and oppressive; density is excessive; height scale and amount of tall buildings in such close proximity to surrounding residential development would present over dominant and oppressive view with overlooking from high level flats at minimal distance; sunlight and daylight would be significantly affected; site does not facilitate access between the river, York Gardens and Clapham Junction; housing mix does not accord with policy; proposed affordable housing does not accord with policy; impact on highway network have not been adequately addressed.

 Wandsworth Conservatives: the design is of poor quality; dense, block like development which dominates the road and surrounding buildings; will result in loss of light and privacy; contrary to policy DMS4b; negative impact on the local transport system; proposals run contrary to objective of Winstanley Estate regeneration to improve public access from the River through the Clapham Junction.

37 The twelve letters of support raised the following points:

 As an employee of the dealership, the proposals will provide a great place to work and will be a good investment for the area’s future;

page 6  Opportunity for local recruitment as the business expands;  Refusal of permission could result in the closing of the business;  Proposals are an intelligent approach to a difficult proposal;  Proposals will result in additional job and apprenticeship opportunities;  Proposals appropriate to context;  Wider benefits to area include housing and affordable housing as well as jobs;  Improvement on existing brownfield land;  Design complements proposals for Winstanley Estate.

38 The letters of objection raised the following points:

 Design: proposals are too tall; proposals would be an eyesore; oppressive; massing; unsympathetic to surrounding neighbourhood; contribution to the over development of the area; height exceeds policy restrictions; impact on privacy of neighbouring properties; overshadowing; height of building close to heliport could result in accidents; proposals should be developed as part of a comprehensive masterplan for the area; too dense; unattractive, overwhelming design;  Amenity: views from existing residents; loss of light to neighbouring properties; loss of daylight; no community benefits; noise; disruption from building work;  Sustainability: impact on air quality; impact on flooding; impact on sewer system;  Transport; roads and trains already at capacity; lack of car parking; impact on Bridges Court road in terms of parking and congestion; impact on bus capacity;  Social infrastructure: impact on schools, doctors, police; no community benefits; open space deficiency;  Housing: would be bought by overseas investors and would not provide genuine housing for local people; lack of affordable housing.

39 The other statutory consultees responded as follows:

 English Heritage: no comments.  Environment Agency: no objections subject to conditions.  Thames Water: no objection subject to conditions and informatives.  Natural England: proposals is unlikely to affect any statutorily protected sites or landscapes; standing advice on protected species should be applied; incorporation of green infrastructure is recommended; Council should consider securing biodiversity enhancements.  Hammersmith & Fulham Council: no comments.

40 Council officers have thoroughly assessed the design and impact of the proposals in the committee report and addressed the concerns raised by statutory consultees. The stage 1 report and this report have addressed the substantive land use, density and design issues which are all broadly considered to be acceptable by GLA officers. However, the Council’s planning committee refused the application on the basis of massing, design and density, considering that this would result in unacceptable harm to the amenities of occupants of neighbouring properties through overlooking and loss of privacy.

41 The committee report suggested a number of conditions and heads of terms to address the concerns raised in the stage 1 report and from other statutory consultees and these should be included in any future planning permission for the site.

42 The Council also received the London Heliport’s response after the committee. It set out a number of concerns relating to:

page 7  Effect of the proposals causing any downwind turbulence and shear effect on circulation of wind across the London Heliport take-off and climb surfaces, landing platform and manoeuvring area;  Obstruction safety lighting and architectural lighting of the building and reflective quality of glazed and other reflective surfaces including rooftop solar energy panels;  Lighting of cranes;  Management of traffic during the demolition, excavation and construction phases of development; and  Management of uncontained waste and building material packaging.

43 The response set out a number of additional assessments, detailed design considerations and further information that would be required to ensure that the London Heliport operation is not caused to be restricted either during development or upon completion for safety reasons. These comments should be taken into account for any revised or appeal proposals for the site. Legal considerations

44 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. Financial considerations

45 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so).

Conclusion

46 Having regard to the details of the application, the matters set out in the committee report and the Council’s draft decision notice there are no sound planning reasons for the Mayor to intervene in this particular case and therefore no basis to issue a direction under Article 7 of the Order 2008.

47 Should the scheme be considered at appeal or a revised application submitted the applicant should have regard to the issues raised in this report and the appropriate conditions and section 106 heads of terms should be secured for any future planning permission.

for further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Katie Walker, Case Officer 020 7983 4976 email [email protected]

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page 9

planning report D&P/3099a 18 February 2015 98 York Road, Battersea in the London Borough of Wandsworth planning application no. 2014/7103

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

The applicant The applicant is Linden (York Road) LLP and the Dutton-Forshaw Motor Company; the architects are GRID and the planning agent is Rapleys LLP.

Strategic issues Strategic issues with regards to land use principles, housing, affordable housing, urban design, inclusive access, transport and climate change mitigation are relevant to the proposals.

Recommendation That Wandsworth Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 75 of this report; but that the possible remedies set out in that paragraph could address these deficiencies.

page 10 Context

1 On 8 January 2015 the Mayor of London received documents from Wandsworth Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 18 February 2015 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 1A and 1C of the Schedule to the Order 2008:

“1A 1. Development which comprises or includes the provision of more than 150 houses, flats or houses and flats;

1C 1. Development which comprises or includes the erection of a building of one or more of the following descriptions:

(b) The building is more than 25 metres high and is adjacent to the River Thames”.

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

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

5 The site is 98 York Road in Battersea. The site is bounded to the north by the Heliport Industrial Estate, to the south and west by Bridges Court and to the east by York Road. The site is approximately 150 metres east of the River Thames and is within the Thames policy area. The surrounding area is mixed in character and uses. Historically the area was industrial, however the character is changing to include new residential and commercial uses. To the west, between the river and the site, are the Orbis Wharf and Vicentia Quay buildings. These are 10 – 17 storey buildings with commercial uses at ground floor and residential above, as well as a hotel. Beyond York Road, to the east of the site, are York Gardens, and the Winstanley and York Road residential estates.

6 The site is currently occupied by a two storey Lookers Volkswagen garage, with a large forecourt to the west. The site is allocated in Wandsworth’s site specific allocations document (2012) as part of the larger Dovercourt site, together with the Heliport Estate and Heliport House. It is allocated in both the adopted and emerging site allocations documents for mixed use development including residential, incorporating the replacement of use classes B1 - B8 on site and related sui generis uses. The allocation also sets out that tall buildings, i.e. those over nine storeys tall, are likely to be inappropriate on the site.

7 The Prices Candle factory site to the south of the site, for which planning permission for the mixed use redevelopment of the site was refused, is allocated in the adopted and emerging site allocations documents for residential use. Heliport House to the north of the site has been granted planning permission for a fifteen storey tower to sit on top of the existing five storey building. The York Road Business Centre site to the north of the site is allocated in the adopted and emerging documents for residential and employment floorspace. The Council is also investigating a Housing

page 11 Zone on land between Clapham Junction and York Road which would provide a significant uplift in residential development and quality.

8 Both York Road (A3205) and Battersea Bridge Road (A3220) are part of the Transport for London Road Network (TLRN). Three bus routes serve the site from the nearest bus stops on York Road, with a further four services available within walking distance. Clapham Junction is the nearest station to the site, with London overground and national rail services. Cycle Hire stations are within approximately 350 metres and 400 meters of the site, at Fawcett Close (east) and Hibbert Street (to the southwest). Cycle Superhighway 8 runs along York Road at this point, linking Wandsworth with Westminster. Clapham Junction is included in the Crossrail 2 safeguarding consultation which recently finished. The site is also close to the landing point of the permitted Diamond Jubilee Bridge which would link Wandsworth with Hammersmith and Fulham. The site has a public transport accessibility level (PTAL) rating of 3 on a scale of 1 to 6 where 6 is most accessible.

Details of the proposal

9 The proposals are for the redevelopment of the site to provide a three storey car showroom, with residential units above. The new car sales area of the showroom would front York Road, and the used car area would front Bridges Court. The residential units would be arranged in four towers that sit on top of the three storey podium formed by the car showroom. Block B, on the south west of the site, and block D, on the north east of the site, would each be six storeys above podium level. Block A, to the north west of the site, would be eleven storeys above podium level, and block C, to the south east of the site, would be fourteen storeys above podium level.

10 The podium would provide a communal amenity space between the four towers, and residential car and cycle parking would be provided at basement level. Case history

11 A pre-application meeting was held at City Hall on 8 September 2014 to discuss the proposal. The applicant was advised that the principle of the development was supported, provided that the increase in car showroom floorspace was fully justified. Officers raised urban design concerns in terms of the activity at ground floor on the Bridges Court elevations and the applicant was advised to consider including a commercial entrance on the western elevation as well as widening the residential entrances on either side of the building. Further information was also required on density, affordable housing, children’s playspace, inclusive access, transport and climate change mitigation. Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

 Land use principles London Plan;  Housing London Plan; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context SPG  Affordable housing London Plan; Housing SPG; Housing Strategy;  Density London Plan; Housing SPG  Urban design London Plan; Shaping Neighbourhoods: Character and Context, SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG  Access London Plan; Accessible London: achieving an inclusive environment SPG;

page 12  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy;

13 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Wandsworth Core Strategy 2010, the Wandsworth Development Management Policies Document 2012, the Wandsworth Site Specific Allocations Document 2012 and the Wandsworth Proposals Map 2012, and the 2011 London Plan with alterations.

14 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework;  The draft Further Alterations to the London Plan (FALP), intend to publish version as submitted to the Secretary of State 2014; and  The Wandsworth Local Plan review submission version documents (2014).

Principle of development

Car showroom

15 The proposed development would result in an increase in sui generis floorspace for the proposed Volkswagen dealership. The planning statement accompanying the application explains that the new car dealership would have a floorspace of 10,479 sq.m. GEA, however the planning application refers to GIA floorspaces. The applicant should confirm the increase in the size of the existing car showroom.

16 The planning statement accompanying the application sets out that there would be an increase in the number of jobs from 73 to 103 and that the increase in the dealership would bring significant investment to the Borough, which is welcomed. Although the reprovision of sui generis floorspace is supported in local policy, the applicant should provide further information to give comfort that that the proposals would not result in vacant floorspace and to ensure that activity is encouraged in line with London Plan policy 7.3.

Residential-led mixed-use development

17 Notwithstanding the need for further explanation for the increase in the car showroom floorspace, the principle of a residential mixed-use development on this site is supported. Policies 3.3 and 3.4 of the London Plan recognise the need for housing in London and table 3.1 of the London Plan sets an annual target of 1,145 new homes for Wandsworth in the period 2011-2021, increased to 1,812 new homes per annum in the FALP for the period 2015 – 2025. The proposals comprise 192 new dwellings, which would contribute towards the housing target for the borough and is welcomed.

18 Mixed-use developments that optimise sites for housing are in line with Policies 3.4 and 4.3 of the London Plan and therefore the principle of the proposed residential development with commercial uses at ground floor is supported in strategic terms, subject to the appropriate justification for the increase in car showroom floorspace.

page 13 Housing

Affordable housing provision

19 The application has been accompanied by an affordable housing statement. This sets out that thirty of the units (16%) are proposed as affordable, in the form of nineteen 1-bed units and eleven 2-bed units and would comprise the whole of block D. The statement sets out evidence to support that the proposed mix is in line with local needs, however the Council should confirm this.

20 In addition to the proposed on-site affordable housing, the affordable housing statement sets out that a further £842,000 would be available to either fund further affordable housing on- site, or as a commuted sum to the Council.

21 London Policy 3.12 prioritises on-site affordable housing and also states a cash in lieu payment should only be accepted where this would have demonstrable benefits in furthering the affordable housing and other policies in the London Plan. Any such contribution should be ring- fenced and, if appropriate, pooled to secure additional affordable housing either on an identified site elsewhere, or as part of an agreed programme for the provision of affordable housing. GLA officers consider that it should be possible to provide all affordable housing on-site, however if the applicant and the Council agree that a contribution would be more beneficial, a robust case demonstrating the exceptional circumstances of the site would need to be set out and the contribution would need to be secured by section 106 agreement.

22 The overall affordable housing provision appears very low given the relatively high residential sale values and proximity to the Thames. Referrals to the GLA in inner London locations are consistently achieving affordable housing levels of 25 – 30%. A viability appraisal has been provided to the Council, which concludes that the proposed affordable housing provision is the maximum reasonable amount. Before the application is referred back to the Mayor at stage II, the Council’s independent assessment of the viability appraisal must be submitted to the GLA to confirm that the maximum reasonable amount of affordable housing would be achieved. If the assessment demonstrates that the scheme can afford to deliver a greater amount of affordable housing, any additional affordable housing should be provided on site, in line with London Plan Policy 3.12.

23 Policy 3.12 of the London Plan and the Housing SPG note that there are circumstances where boroughs should consider whether it is appropriate to put in place provisions for re- appraising the viability of schemes prior to implementation, in order to maximise affordable housing provision. Given the possibility to phase the development, such an approach might be appropriate for this scheme, particularly given the length of time that could pass from the initial toolkit appraisal to actual build out and also given the current, low affordable housing offer. The draft section 106 agreement would need to be provided to the GLA as part of the Stage 2 referral.

24 London Plan policy sets out that affordable housing should be provided at a ratio of 60:40 social or affordable rent to intermediate. The affordable housing statement sets out that the proposed affordable provision would be all intermediate units, although affordable rent could be provided should funding from the Council be available. Regardless of whether funding is received from the Council, the affordable provision should include both social/affordable rent and intermediate tenures. Full justification for the final tenure mix would be required prior to the stage II referral, including how it corresponds to local need as set out by the Council’s housing department.

page 14 Housing choice

25 London Plan Policy 3.8 requires different sizes and types of dwellings to meet different needs. The indicative housing mix is 25% one bed units, 71% two bed units and 4% three bed units. This provides a range of unit sizes, however the Council should confirm that this is in line with local needs.

Residential standards and quality

26 The planning statement and design and access statement set out that all units meet the Mayor’s space standards, and exceed them in most cases, which is welcomed. The proposed floor plates limit the number of units to a maximum of six per core, encouraging a strong sense of ownership over communal spaces. In addition, 70% of units would be dual aspect with the majority of single aspect units being smaller units, and there are no north facing single aspect units within the proposals which is supported.

Amenity space

27 The planning statement states that each unit will have a balcony or winter garden which would be sized in accordance with the Mayor’s standards, whereas the design and access statement sets out that the balconies would be a minimum of 4 sq.m., which is below the 5 sq.m. standard as set out in the Mayor’s Housing SPG. There would, however, be a communal amenity space of 1,622 sq.m. provided at podium level. As every unit has a balcony and a large communal amenity space would be provided, there is an acceptable amount of amenity space within the proposals.

Children’s play space

28 Policy 3.6 of the London plan refers to children’s play space and guidance on this is provided in the Mayor’s ‘Shaping neighbourhoods: Play and informal recreation’ SPG. The SPG requires 10 sq.m. of playspace per child to be provided on site. The design and access statement includes information on playspace provision, stating that playspace for under fives would be provided on site in excess of GLA standards. The numbers used in the playspace calculation in the design and access statement are, however, based on 174 residential units as opposed to the proposed 192. In addition, the current affordable housing mix is unknown and this would alter the child yield, therefore impacting the amount of playspace required. Once the affordable housing details are finalised, the child yield for the proposals should be recalculated and this should be specified prior to the stage II referral.

29 Notwithstanding the need to confirm the anticipated number of children for the proposals, GLA officers are encouraged to see that 465 sq.m. of doorstep playspace would be provided within the podium landscaping on site. Details of this should be secured by condition on any planning permission.

30 The applicant has undertaken a study of nearby play areas to cater for older children, and has identified York Gardens and Harroway Gardens as within 400 metres and Meryick Road and Fred Wells Gardens as within 800 metres of the site. The Council should confirm whether any financial contribution towards these open spaces would be required as a result of the proposals and should secure any such contribution by section 106 agreement.

Density

31 The planning application states that the net residential density of the proposals is 532 units per hectare, or 1,488 habitable rooms per hectare. The applicant should confirm that this density figure has been derived in accordance with paragraph 1.3.47 of the Mayor’s Housing SPG.

page 15 32 Wandsworth’s site allocations document considers that the site is urban, with a PTAL that varies across the site and is subject to change as nearby transport improvements are made. The GLA considers that the site is central in character with a PTAL of 3, and therefore the density guideline set out in table 3.2 is for 65 - 240 units per hectare or 300 – 650 habitable rooms per hectare. The planning statement and transport assessment consider that a manual assessment of the site result in it having a PTAL of 6b, due to its proximity to Clapham Junction station. As stated at pre-application stage, officers are concerned that the proposed route to Clapham Junction from the site is not a clear or common route and does not genuinely reflect the proximity of the site to Clapham Junction. For the purposes of this report, the site is considered to have a PTAL of 3.

33 While the proposed density is above the guidelines set out within the London Plan’s density matrix, the residential quality of the proposals is high, providing units in excess of London Plan standards, few units per core, 70% dual aspect units and private and communal amenity space. The height, scale and massing is considered appropriate to the emerging context and the layout of the proposals is well thought out. As such, the density is acceptable in this instance.

Urban design

34 The applicant has submitted masterplanning work for the overall Dovercourt Site, which is welcomed and demonstrates that the scheme would successfully integrate with the adjacent site. In response to the masterplanning exercise and comments at pre-application stage, the applicant has modified the layout of block D to ensure that it would not impinge on or prejudice the east-west route anticipated as part of the wider Dovercourt site.

35 The proposed height and massing present no strategic concern given the changing context of the area, the height of adjacent developments and proposals, and the current industrial character of the wider area. Wandsworth Council’s site allocation document, however, considers that tall buildings, i.e. those of nine storeys and above, are likely to be inappropriate on this site. The Council should confirm whether the height of the proposals is acceptable, taking the changing context of the area into consideration.

36 The podium approach is supported as it can accommodate uses at ground floor level that animate and define the public realm, and can also provide private amenity space for the residents above whilst allowing the residential blocks above to be orientated to optimise daylight into residential units.

37 At pre application stage, officers were concerned with the extent that the car showroom would provide sufficient animation, activity and surveillance to Bridges Court. The applicant has sought to mitigate this by locating a cafe unit on southern edge of the car showroom, which is welcomed. The applicant should design this so that it could function as a self-contained retail unit, separate from the car showroom and with its own entrance, which would contribute to generating activity on the public realm. The western edge of the car dealership was also of concern at pre- application stage. This elevation would be glazed, providing overlooking onto public realm, and the two cores on this elevation would also help generate activity, which is supported.

38 The submitted drawings and the design and access statement demonstrate a high quality of materials and detailing. These should be secured by condition to ensure that a high quality of design would be built through. Inclusive access

39 London Plan Policy 3.8 is concerned with housing choice. The design and access statement sets out that all of the residential units would meet lifetime homes standards and that five would be fully wheelchair accessible, with a further ten being easily adaptable for wheelchair users. This

page 16 equates to 10% of the total number of units, in line with London Plan standards. The design and access statement states that all of the wheelchair accessible and adaptable units would be two bedroom, three person flats, however the sample layouts demonstrate a mix of wheelchair units. The applicant should confirm the mix of wheelchair units, and the Council should confirm that the final mix is in line with local needs.

40 The parking plans show that 10% of car parking spaces (nine spaces) would be disabled parking spaces. The design and access statement sets out that, depending on demand, the parking spaces could be increased should the ten easily adaptable units become wheelchair units. A car parking management plan should set out the arrangements for this and should be secured by condition. The disabled parking spaces would be located close to the lift cores, in line with policy. Four adapted cycle spaces and two mobility scooter spaces for residents are also proposed, in line with comment made at pre-application stage.

41 No wheelchair units would be provided in Block D, which has one lift. As suggested at pre- application stage, consideration should be given to the provision of a second lift, or a lift traffic analysis should be provided to justify one lift. This would make the building safer in case of fire for disabled people who may be visiting this building and may not be able to use stairs.

42 The design and access statement sets out that there is level access to the podium garden, however it also states that it is accessed via a gentle up sloping ramp. The applicant should clarify that there is level access to the residential blocks from the podium, and should provide a plan setting out the levels for the podium amenity space.

Transport for London’s comments

Car Parking

43 Existing floorspace and parking levels are not clearly set out in the application documents. The proposed car showroom comprises approximately 9000 sq.m. GIA over the ground, first and second floors. 26 standard and three wheelchair accessible spaces are proposed at ground floor level for customer use. TfL requires further clarification of the commercial car parking levels and use before they are able to consider accordance with London Plan Policy 6.13.

44 The proposed number of wheelchair accessible spaces is insufficient to meet the anticipated 103 employees. The applicant should set out how need has been assessed and how staff take up of spaces is to be managed, both to ensure that sufficient parking for those staff and customers. Any staff or customer parking areas should provide 10% active and 10% passive electric vehicle charging point provision.

45 The proposals include 87 residential parking spaces within the basement level (a 0.45 ratio). The applicant considers that the site benefits from an excellent PTAL 6b (excellent) whereas but TfL calculates this to be 3 (medium). Inadequate explanation of how the higher level has been calculated has been provided. Nonetheless, the proposed residential parking level for a PTAL 3 site, in anticipation of proposed or planned improved pedestrian links in the area, is considered to be acceptable. Of those 87 spaces, nine would be wheelchair accessible. The Council should secure 20% active and 20% passive electric vehicle charging point provision by condition. As set out above, the system of allocation and availability of parking spaces should be set out in a car parking management plan, with specific reference to how wheelchair accessible spaces would be available on the basis of demand.

46 The applicant has stated that a CPZ permit-free section 106 requirement would also be secured with the Council and this is supported by TfL.

page 17 Cycle parking

47 There are 200 spaces to serve residential occupiers, ten visitor spaces, and eighteen employee spaces. This is in line with current London Plan standards, however the ‘intend to publish’ version of the FALP would increase the residential cycle parking provision to 337 for the proposals. In the event of a decision being made following the adoption of the higher FALP standards, the higher level should be secured through revised plans, or reserved by condition. A showering / changing / storage area for staff is also proposed. It is noted that one group of cycle bays is obstructed by car storage space. A condition should also be secured to specify details and final location of staff cycle storage areas and this should be discharged in consultation with TfL where these affect York Road.

Trip Generation

48 Commercial trip generation has been carried out using site survey data and a TRAVL site. Residential levels are based upon TRICS sites and 2011 method of travel to work census data (as Ward level) which is acceptable.

Public transport

49 The proposed development would exert a greater demand upon the local Cycle Hire Stations (CHS) which are already amongst the most heavily used in the borough. The immediate site locality also represents a gap in the network, with local stations lying more than 350-400 metres from the site. A contribution of £200,000 and land for a 27 cycle station is considered appropriate for the development. It is noted that the site includes public and private highway land, with communal amenity space only found above the podium which is not accessible to the public. Land for the CHS will therefore need to come forward on highway land. Further discussion between the applicant, the Council and TfL is necessary to determine the most appropriate location, though it is anticipated that land within the York Road frontage may offer the most suitable site for a CHS. The applicant should revise the plans for this area to incorporate the CHS, with the final detail to be incorporated within a section 106 / section 278 agreement.

50 A scheme of hard and soft landscaping is already set out for the York Road frontage, which would include a relocated bus shelter. In order to effectively encourage usage of more sustainable bus services, the upgrading of this shelter to a Landmark London shelter, as part of the public realm works in this location, should be secured. The cost of the upgrade would be £12,350, and this should be secured by section 106 / section 278 agreement.

Pedestrian Environment

51 TfL welcomes the introduction of highway and public realm improvements to the private highway of Bridges Court, which shall be secured by condition. Subject to the satisfactory incorporation of an upgraded bus shelter and a CHS, the development would accord with London Plan Policy 6.10.

52 The site is close to the permitted Diamond Jubilee Bridge which would link Wandsworth with Hammersmith and Fulham on the north side of the Thames. This link is supported by TfL, who understand that the Council is exploring opportunities for financial contributions towards the bridge which could provide a continuous link through the housing estates and proposed regeneration to the south towards Clapham Junction station.

Servicing and Construction

53 Residential servicing is proposed to occur mainly from a short layby at the north western corner of the site, on the eastern side of Bridges Court, immediately north of the basement parking

page 18 entrance. The length of layby appears to inhibit use by vehicles larger than transit type vans, and the carriageway width of Bridges Court would lead to obstruction of traffic were vehicles to wait on the main carriageway surface. This may lead to obstruction of the basement entrance, or of Bridges Court, and TfL requests that the applicant clarify or amend their proposals in this area.

54 In line with London Plan Policy 6.14, a Delivery and Servicing Plan (DSP) and Construction Logistics Plan (CLP), prepared in line with TfL guidance, should be secured by section 106 agreement. In regard to the CLP, TfL wishes to ensure that construction vehicles are fitted with cycle specific safety equipment, including side-bars, blind spot mirrors and detection equipment to reduce the risk of collisions on the capital’s roads. TfL requests that these requirements be submitted for approval by the council prior to commencement. The DSP should be submitted for approval prior to first occupation of the development.

Travel Plan

55 A framework travel plan, prepared in accordance with the BREEAM standards, has been submitted. Detailed travel plans should be secured, enforced, funded, and monitored as part of a section 106 agreement. Though the framework travel plan does not set out a full range of detailed targets, reference is made to a goal of realising the predicted cycling mode share of 10%. This is not an appropriate target and other financial measures to encourage mode shift such as cycle vouchers and car club membership should also be secured in the section 106 agreement.

Mayoral CIL

56 In accordance with London Plan Policy 8.3, the Mayoral Community Infrastructure Levy (CIL) came into effect on 1st April 2012. All new developments that create 100 m² or more of additional floor space are liable to pay the Mayoral CIL. The levy is charged at £50 per square metre of additional floor space in the borough of Wandsworth. Due to the inconsistent information provided within the application, TfL is unable to determine the correct level of contribution that will be required.

57 Wandsworth council has adopted its local CIL and this includes financial contributions towards transport improvements as set out in the regulation 123 list. Infrastructure should be funded in addition to site specific mitigation measures set out above and not duplicated.

Climate change mitigate

Energy efficiency standards

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

59 The demand for cooling will be minimised through the inclusion of green/brown roofs on all available roof space, light coloured bricks on the majority of the buildings, solar control glazing and external shading through balconies and louvres. An overheating analysis has been carried out within Part L for both the domestic and non-domestic uses. The applicant should provide Part L compliance data sheets from the sample overheating assessments to support the assessment.

page 19 60 The sample residential units have been assessed through dynamic simulation in line with CIBSE TM52 to ensure that mechanical cooling is not required to maintain comfort in summer months. The applicant states that criterion two of the TM52 assessment will not be met for the lounge area in one of the dwellings. The applicant should revise designs to ensure that all TM52 criterions are met for each of the sample dwellings modelled. Assessing the sample dwellings against CIBSE TM49 is recommended.

61 The applicant is proposing that the penthouse apartments are provided with mechanical cooling. As the overheating assessment suggests that the units may not overheat, the applicant should consider omitting the air conditioning in order to maximise the carbon savings, in line with Policy 5.9 of the London Plan. Mechanical cooling is also proposed for the showroom and offices of the car dealership, therefore the applicant should provide information on the control strategy for ensuring that any air conditioning system installed on site is only used when needed.

62 It appears that different values have been used in the CHP analysis (0.5) and the overheating analysis (0.3). The applicant should confirm the intended g-value for the development and the values used and review the inputs used in each modelling exercise as this could have implications on both overheating and carbon emission performance of the development.

63 The development is estimated to achieve a reduction of 28 tonnes per annum (8%) in regulated CO2 emissions compared to a 2013 Building Regulations compliant development. Sample SAP worksheets and BRUKL worksheets for the development including efficiency measures alone should be provided to support the savings claimed.

District heating

64 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development. The applicant has, however, provided a commitment to ensuring that the development is designed to allow future connection to a district heating network should one become available, which is supported in line with London Plan Policy 5.6.

65 The applicant is proposing to install a site heat network which would be supplied from a single energy centre located in the basement of the block. Further information on the floor area of the energy centre should be provided and the applicant should confirm that all apartments and non-domestic building uses will be connected to the site heat network.

Combined Heat and Power

66 The applicant is proposing to install a 35 kWe gas fired CHP unit as the lead heat source for the site heat network. The CHP is sized to provide the domestic hot water load, as well as a large proportion of the space heating (approximately 80% of the total heat load). A reduction in regulated CO2 emissions of 73 tonnes per annum (23%) will be achieved through this second part of the energy hierarchy. This savings from the CHP appear to be quite high and could be to do with the high number of running hours (and heat demand met), and therefore the applicant should refine the CHP strategy as the design progresses to ensure that the proposed running hours and subsequent carbon savings can be met without resulting in heat dumping.

67 Information should be provided on the management arrangements proposed for the system given that the management and operation of small CHP systems can significantly impact their long term financial viability.

page 20 Renewable energy technologies

68 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install photovoltaic (PV) panels on the roofs of the buildings. Roof plans have been provided along with an indicative plan of the PV layout. A reduction in regulated CO2 emissions of 24 tonnes per annum (9%) will be achieved through this third element of the energy hierarchy.

Overall carbon savings

69 The overall proposed carbon dioxide savings meet the target set within Policy 5.2 of the London Plan however the comments above should be addressed before the carbon savings and compliance with London Plan energy policies can be verified.

Flooding

70 The application has been accompanied by a flood risk assessment. The site is within Flood Zone 3a and the floor risk assessment confirms that the site is defended to 1 in 1000 years protection by the Thames Tidal Defences. Furthermore, the assessment states that the site would not be affected by likely flood level following a breach to those tidal defences. Therefore the proposal is acceptable in principle in flood risk terms.

Surface Water Run-off

71 The FRA states that surface water attenuation tanks, brown roofs and landscaping will be installed in order that the development achieves at least a 50% reduction on the discharge rates of the current site, for the 1 in 100 year storm event. This approach is in line with London Plan Policy 5.13. These aspects of the proposals should be confirmed and secured via an appropriate planning condition. Local planning authority’s position

72 Wandsworth Council’s position is currently unknown. Legal considerations

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

74 There are no financial considerations at this stage.

page 21 Conclusions

75 London Plan policies on land use principles, housing, affordable housing, urban design, inclusive access, transport and climate change mitigation are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

 Land use principles: the overall principle of mixed-use development including housing is welcomed, however the applicant should provide further justification for the increase in car dealership floorspace.  Affordable housing: the maximum reasonable amount of affordable housing should be provided on site; the current affordable housing offer appears very low; the Council’s independent assessment of the applicant’s viability appraisal should be provided to the GLA prior to stage II referral; the affordable housing provision should include both social rent and intermediate housing.

 Housing: the overall residential quality is high and density is acceptable; the Council should confirm that the proposed housing mix is in line with local needs; details of on-site playspace should be secured by condition; any contributions towards playspace as a result of the development should be secured by section 106 agreement.

 Urban design: the height, scale and massing of the proposals raise no strategic issues; materials and detailing should be secured by condition.

 Inclusive access: the mix of wheelchair accessible units should be clarified; a car parking management plan should be secured by condition to ensure that one wheelchair space per wheelchair adaptable unit would be available if required; a second lift should be incorporated into block D; a levels plan for the podium level amenity space should be provided.

 Transport for London: wheelchair accessible parking should be provided for customer and staff needs; electric vehicle charging points should be secured by condition; cycle parking levels should be revised to FALP standards and details secured by condition; a contribution of £200,000 is required for a cycle hire station site and installation; a contribution of £12,350 is required for bus shelter upgrade; residential loading and servicing provision should be clarified; a delivery and servicing plan and a construction logistics plan should be secured by section 106 agreement or condition; travel plans should be secured through section 106 agreement; clarification of existing and proposed floor areas is required to calculate CIL payment.

 Climate change mitigation: the applicant should provide Part L compliance data sheets from the sample overheating assessments; the design should be revised to ensure all TM52 criterions are met for each of the sample dwellings ; the applicant should consider omitting the air conditioning for the penthouse apartments and information on the control strategy for mechanical cooling should be provided; the intended g-value for the development should be confirmed; sample SAP worksheets and BRUKL worksheets for the development including efficiency measures alone should be provided; further information on the floor area of the energy centre should be provided; all apartments and non-domestic buildings should be connected to the site heat network; the applicant should refine the CHP strategy to ensure that the proposed running hours and subsequent carbon savings can be met; information on the management arrangements for the CHP should be provided; details of surface water attenuation tanks, brown roofs and landscaping should be secured by condition.

page 22 76 On balance, the application does not comply with the London Plan, however the remedies set out above might lead to the application becoming compliant with the London Plan.

for further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager (Development & Projects) 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Katie Walker, Senior Strategic Planner (Case Officer) 020 7983 4976 email [email protected]

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