planning report PDU/1414b/01 23 February 2011 8 Albert Embankment, Vauxhall
in the London Borough of Lambeth planning application no. 10/04473/FUL
Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008
The proposal Refurbishment and extension of the Grade II listed fire station and the construction of seven new buildings to rear, ranging in height from 5 to 15-storeys to contain a mixed-use development comprising a new fire station, 293 residential units, 5,000 sq.m. of class B1 floor space, retail uses, parking, with associated public realm and landscaping works. The applicant The applicant is Albert Embankment LLP, and the architect is Liftshutz Davidson Sandilands.
Strategic issues The principle of a residential-led mixed-use development in the Vauxhall/Nine Elms Opportunity Area is in the interest of good strategic planning in London. However, concern is raised over the design of buildings D and F. Further information is also required on access, affordable housing, children’s play space, climate change and transport to ensure compliance with London Plan policies.
Recommendation
That Lambeth Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 115 of this report; but that the possible remedies set out in paragraph 117 of this report could address these deficiencies.
Context
1 On 27 January 2011 the Mayor of London received documents from Lambeth 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 9 March 2011 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.
page 1 2 For this application the Mayor has delegated his planning function to Sir Simon Milton, Deputy Mayor and Chief of Staff. This report sets out information for the Deputy Mayor’s use in deciding what decision to make.
3 The application is referable under the following Schedules to the Order 2008:
- Category 1A ”Development which comprises or includes the provision of 150 houses, flats, or house and flats”.
- Category 1B “Development which comprises or includes the erection of a building or buildings in central London and with a total floorspace of more than 20,000 sq.m.”
- Category 1C “Development which comprises or includes the erection of a building more than 25 metres high adjacent to the River Thames and a building more than 30 metres high outside the City of London.”
- Category 3E “Development which does not accord with one of more provisions of the development plan in force in the area in which the application site is situated; and comprises or includes more than 2,500 sq.m. of retail (A1-A5), business (B1) and non-residential institutions (D1) floorspace.”
- Category 4 “Development in respect of which the local planning authority is required to consult the Mayor by virtue of a direction given by the Secretary of State under article 10(3) of the GDPO (in this instance the development exceeds the threshold plane for the Background Assessment Area of Protected Vistas 2A.2, 2B.1 and 4A.2).
4 Once Lambeth 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.
5 The Deputy Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description
6 The application site is made up of three parcels of land that stretch west to east from the Albert Embankment to Newport Street. The front site is bounded to the south by Black Prince Road, to the east by Lambeth High Street and to the west by the A3036 Albert Embankment, which is part of the Transport for London road network. The middle site is located directly to the east of the front site, on the opposite side of Lambeth High Street and the third site is located on the junction of Black Prince Road and Newport Street on the eastern side of the railway viaduct.
7 The site is owned by the London Fire Brigade, which continues to operate from the Grade II listed building that fronts Albert Embankment. This building, constructed in 1937, has been the subject of extensions and alterations, including a basement and ground floor wing constructed in the 1970’s. Adjoining this is a listed drill tower, and beyond that, the second parcel of land fronting Lambeth High Street contains a four-storey office block with two storey workshop buildings behind it. The third site is a hard standing area used for informal parking by the fire brigade. The total site covers an area of approximately 1.2 hectares.
8 The wider area is made up of a mixture of medium to high-density residential buildings, hotels, office and industrial units. Of note is Southbank House, a Grade II listed building to the south of the middle site, which was previously the head office of the former Doulton Lambeth Pottery works and features an ornate corner tower.
page 2 9 The site has a public transport accessibility level of 6a, on a scale of 1 to 6 where 6 is most accessible. The site is in close proximity to the Vauxhall transport interchange, providing mainline rail, Victoria line Underground services, and numerous bus connections.
Figure 1: Aerial view of site (source: submitted Design and Access Statement)
Details of the proposal
10 The scheme proposes refurbishment and extension of the Grade II listed fire station building fronting Albert Embankment, to contain a new fire station and associated functions for the London Fire Brigade on part basement and ground floors of 8 Albert Embankment, with 90 residential flats above. The adjoining drill tower would be refurbished for fire brigade use.
11 To the rear, a series of seven buildings, ranging in height from five to fifteen storeys would be constructed for mixed-use purposes, including residential, offices, studio workshops, retail and other business floor space.
12 In total, the scheme entails 2,721 sq.m. of fire station floor space, together with 4,919 sq.m. of commercial floor space, 639 sq.m. retail space, and 293 residential units.
13 Listed building and conservation area consent are also being sought from the Council.
Figure 1: proposed building heights with previous scheme in orange (source: submitted Design and Access Statement) page 3 Case history
14 This planning application is a revised scheme, following a previous planning application and pre-application discussions held in 2009 and 2010. The previous application was referred to the GLA in March 2010, whereby concerns were raised by the Deputy Mayor in relation to the height and location of some of the buildings, the affordable housing offer, children’s play space, inclusive design, energy and transport. Following the recommendation by the Council that the application be refused, and advice that the Deputy Mayor was content for the Council to determine the case itself, the applicant chose to withdraw the application before the decision was issued.
15 There have not been any pre-application meetings prior to the submission of the current application but a series of pre-application meetings were held in relation to the previous application, including a presentation by the applicant to the Mayor and Deputy Mayor in September 2009. Strategic planning issues and relevant policies and guidance
16 The relevant issues and corresponding policies are as follows:
Principle of development London Plan; PPS1 Density London Plan; PPS3; Housing SPG; draft revised interim Housing SPG Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft Density London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing SPG EiP draft Tall buildings/views London Plan; RPG3A, London Plan; RPG3A, Revised View Management Framework SPG Urban design London Plan; PPS1 Historic Environment London Plan; PPS5 Ambient noise London Plan; the Mayor’s Ambient Noise Strategy; PPG24 Child play space London Plan; Providing for Children and Young People’s Play and Informal Recreation SPG Inclusive design and access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM) Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG Transport London Plan; the Mayor’s Transport Strategy; PPG13 Crossrail draft London Plan Alteration; draft Crossrail SPG; Vauxhall/Nine Elms. Battersea Opportunity Area Planning Framework
17 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 Lambeth Unitary Development Plan 2007, the adopted Lambeth Core Strategy and the London Plan (Consolidated with Alterations since 2004).
18 The draft replacement London Plan, published in October 2009 for consultation is a relevant material consideration, together with the Vauxhall Nine Elms Battersea Opportunity Area Planning Framework (consultation draft, 2009).
page 4 The Vauxhall Nine Elms Battersea Opportunity Area Planning Framework
19 The consultation draft Vauxhall-Nine Elms-Battersea (VNEB) Opportunity Area Planning Framework (hereafter referred to as “the OAPF”) was published in November 2009 and is also a material consideration. Whilst still in draft form, the OAPF has been produced by the GLA in collaboration with Wandsworth and Lambeth councils, other public authorities, landowners and other key stakeholders. It sets out a comprehensive framework for the VNEB area, including a land use strategy, estimates of development capacity, a package of transport interventions, public realm and tall buildings strategies and an energy master plan. In terms of development capacity, the preferred option is revised scenario 5 which would deliver a minimum of 16,000 new homes and 20-25,000 new jobs across the opportunity area.
20 The findings of the TfL-led strategic transport study for the Opportunity Area recommend that a major public transport intervention is required in order to enable high density development in line with the London Plan. The study tested a number of transport options and concluded that an Underground extension with an intermediate stop in the Nine Elms area, supported by a wider package of interchange, rail and underground station, bus, highway, pedestrian and cycling enhancements and improved river transport is required to provide an acceptable level of additional transport capacity.
21 A public realm and highways modelling strategy has also been commissioned by TfL, and makes recommendations for the Albert Embankment Area, namely improvements to the traffic corridor, riverwalk, viaducts and local roads including Lambeth High Street, which falls within the application area.
22 A Development Infrastructure Funding Study (DIFS) has also recently been completed for the opportunity area. The DIFS considered the infrastructure requirements in the opportunity area and the costs of providing it, examined the ability of development in the opportunity area to generate section 106 contributions based on an assessment of development viability, and compared the potential section 106 contributions and other potential funding sources with the costs of providing the infrastructure. It recommended tariff charges per residential unit and per square metre of non-residential development based on what developments in the opportunity should reasonably be able to afford, subject to alternative affordable housing scenarios. The DIFS recommendations have been incorporated into a consultation draft revised section 106 chapter for the OAPF, which is available to download from the GLA website at: http://www.london.gov.uk/who-runs-london/mayor/publications/planning/vauxhall-nine-elms- battersea-s-106.
23 Based on the proposed tariff levels and the alternative scenarios of 15% and 40% affordable housing provision, the total contribution that would be expected from this development under each scenario is set out in the table below.1 Discussion will be required to determine the appropriate contribution based on the applicant’s 28.8% affordable housing offer.
Residential Office Retail Total (293 units) (4,919 sq.m.) (639 sq.m.) contribution 15% affordable £11,720,000 £787,040 £95,850 £12,602,890 housing 40% affordable £7,325,000 £787,040 £95,850 £8,207,890 housing
1 The total contribution has been calculated on the basis that the entirety of the existing floorspace on the site is ‘sui generis’ as per the information provided on the planning application form. It excludes the replacement fire station facility. page 5 Principle of development
24 The site falls within the indicative boundary of the Central Activities Zone (CAZ) as shown on map 5G.1 of the London Plan. London Plan policy 5G.2 and draft replacement London Plan (DRLP) policy 2.10 set out strategic priorities for the CAZ, which include developing and implementing the frameworks for the CAZ opportunity areas to realise their opportunities for local communities as well as providing additional, high quality strategic development capacity. Policy 5B.2 of the London Plan seeks to accommodate commercial development associated with business, tourism and retail within the Central Activities Zone.
25 Vauxhall, Nine Elms and Battersea are identified as an opportunity area by policy 5E.2 of the London Plan and Annex 1 of the DRLP, on the basis that the area is capable of accommodating substantial new jobs and homes. Policy 5E.2 states that new developments in the opportunity area “will be expected to maximise residential and non-residential densities and to contain mixed uses.” The DRLP identifies an indicative capacity of 15,000 new jobs and a minimum of 10,000 new homes in the opportunity area over the plan period.
26 The provision of a mixed-use development, including residential accommodation, is supported by London Plan policy 3A.1 and policy 3.3 of the draft replacement London Plan, which seeks to increase London’s supply of housing. Policy 3A.3 seeks to ensure that development proposals achieve the maximum intensity of use compatible with the local context, the design principles in policy 4B.1 of the London Plan and 3.5 of the DRLP and with public transport capacity.
27 Policy 3A.18 of the London Plan and policy 3.17 of the DRLP seeks to resist the net loss of, and increase the provision of, social infrastructure and community facilities such as fire stations to meet future demand and existing deficiencies.
28 The principle of the re-provision of a state of the art fire station and mixed-use residential- led redevelopment is therefore in accordance with London Plan policies. Housing
29 London Plan policy 3A.1 seeks to increase London’s supply of housing and sets a London- wide target of 30,500 additional homes per year between 2007/8 and 2016/17. Table 3A.1 sets borough housing targets, of which Lambeth’s is 1,100 additional homes per year between 2007/8 and 2016/17.
30 Draft replacement London Plan policy 3.3 seeks provision of at least an annual average of 33,400 additional homes across London up to 2015/16. Table 3.1 sets annual average housing provision monitoring targets for London boroughs, of which Lambeth’s is 1,255 units.
31 The proposed development includes 293 residential units, which represents 26% of the borough’s existing annual homes target and 23% of its draft replacement London Plan target. This is welcomed, in line with London Plan policy 3A.1 and DRLP policy 3.3.
page 6
32 The proposed residential mix is as follows:
Table 1: Proposed housing mix Unit Tenure Housing Market Affordable Total by Unit Type Total by Unit Unit Type SPG Intermediate Social Type (%) Studios 6 0 0 6 2% 1% 1-bed 78 6 17 101 34% 31% 2-bed 77 5 15 97 33% 3-bed 55 21 7 83 28% 38% 4-bed 0 6 0 6 2% 30% 5-bed plus 0 0 0 0 0 Total by Tenure 216 39 38 293 100% 100% Total by Tenure (%) 74% 13% 13% 100% Total by habitable 613 107 141 rooms (%) (71%) (12%) (16%) 100% Tenure split 107 141 habitable rooms/% (43%) (56%) 100%
Affordable housing
33 London Plan policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements.
34 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified.
35 Policy 3.13 of the DRLP establishes the approach to negotiating affordable housing on site, and states that “The maximum reasonable amount of affordable housing should be sought when negotiating on individual private residential and mixed use schemes” taking account of a range of factors including local and regional requirements, the need to encourage rather than restrain development, and viability.
36 Where borough councils have not yet set overall targets as required by policy 3A.9, they should have regard to the overall London Plan targets. It may be appropriate to consider emerging policies, but the weight that can be attached to these will depend on the extent to which they have been consulted on or tested by public examination. In this instance, Lambeth Council’s Core Strategy has recently been adopted and seeks to deliver 7,700 net additional dwellings across the borough between 2010/11 and 2016/17 in line with London Plan targets, and a further 8,800 more homes by 2024/25. At least 50 per cent of housing should be affordable where public page 7 subsidy is available, or 40 per cent without public subsidy, subject to housing priorities and, where relevant, to independently validated evidence of viability, or where there is a clearly demonstrable benefit in a different mix in the case of housing estate regeneration. The mix of affordable housing should be 70% social rented and 30% intermediate.
37 Of the 293 residential units, the applicant proposes that 77 are affordable, equating to 26% of the residential units and 28.8% of habitable rooms. The tenure split of 56% social rented and 43% intermediate. The applicant suggests this is the maximum reasonable amount possible given the current market condition and the exceptional development costs of the Grade II listed fire station and has submitted a Three Dragons viability review to support its assertions that the scheme cannot deliver any further affordable housing.
38 The Council has advised that the toolkit would be independently verified by consultants to test its assertions. In agreeing the acceptability of the affordable housing offer, consideration will need to be given to the applicant’s grant funding presumption in light of the Government’s spending review, together with details of any engagement with any housing associations, and whether there are other financial obligations that may impact upon the offer. Given the intention to build this proposal in phases (so as to enable the continued operation of the fire station), it would be appropriate to consider the need for any review mechanisms as part of a section 106 agreement, should permission be granted, as market values may fluctuate with time. It would also be appropriate to consider the potential repercussions of introducing an element of affordable rent to the scheme. In this respect, further discussion with the applicant and the Council is required in relation to the affordable housing offer before the application is reported back at Stage 2.
Tenure split
39 London Plan Policy 3A.9 states that affordable housing targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that within the affordable element 70% of housing should be social and 30% intermediate provision, and of the promotion of mixed and balanced communities. The policy makes reference to the promotion of mixed and balanced communities and paragraph 3.51 seeks an appropriate balance between social and intermediate housing, having regard to the circumstances of the area.
40 Policy 3.12 of the DRLP states that within the 13,200 affordable homes per year target, the Mayor will, and boroughs and other partners should, seek to ensure that 60% is social housing and 40% is intermediate.
41 Within the proposed affordable housing, 56% of units would be social rented and 43% would be intermediate. In this instance, the proposed tenure split falls below the London Plan and DRLP targets, and further discussion is required with the Council, including advice from housing officers, in order to establish to what extent the tenure split reflects local needs. Again, it may also be appropriate to consider whether there would be any repercussions from introducing an affordable rent element to the scheme.
Mix of units
42 London Plan Policy 3A.5 encourages a full range of housing choice. This is supported by the London Plan Housing Supplementary Planning Guidance, which seeks to secure family accommodation within residential schemes, particularly within the social rented sector, and sets strategic guidance for councils in assessing their local needs. Policy 3.12 of the DRLP states that within affordable housing provision, priority should be accorded to family housing. Recent guidance is also set out in the London Plan Interim Housing Supplementary Planning Guidance (April 2010) and draft replacement London Plan policy 3.8, which seeks to widen housing choice.
page 8 Also relevant is policy 1.1C of the London Housing Strategy, which sets a target for 42% of social rented homes to have three or more bedrooms.
43 As noted in table 1 above, the scheme is made up of approximately 34% 1-bed units, 61% 2/3 bed units, and less than 2% 4-bed plus units. The majority of the accommodation proposed in this scheme is one and two bed flats, with less than a third comprising 3-bed plus units. However, scheme does provide over 70% of all social rented units with 3 bedrooms or more, which is in accordance with strategic guidance.
44 It is acknowledged that the mixed-use nature of the scheme, and its density are such that a higher proportion of 3-bed and 4-bed units could add pressure to the limited amenity space, and may generate a need for additional amenity space, which would be difficult to design into the scheme in an acceptable manner. However, in order to comply with the London Plan and Housing SPG, further discussion is required before the application is referred back at Stage 2, to establish to what extent the determined mix reflects local needs, together with confirmation from the Council’s housing department that it is satisfied that the proposed unit mix will meet the needs of its residents.
Density
45 London Plan policies 4B.1 and 3A.3 outline the need for development proposals to achieve the highest possible intensity of use compatible with local context, the design principles of the compact city, and public transport accessibility. Table 3A.2 of the London Plan provides guidelines on density in support of policies 4B.1 and 3A.3. Policy 3A.3 of the London Plan aims to maximise the potential of a site taking account of local context, London Plan design principles and public transport capacity. Table 3A.2 of the London Plan provides a framework for assessing density based on habitable rooms and dwellings per hectare. DRLP policy 3.4 and Table 3.2 moves away from ‘maximise’ to ‘optimise’ taking into account all those matters in existing policy but with greater emphasis on local context and the design principles set out in Chapter 7 of the draft plan.
46 The application documents suggest a density of 848 habitable rooms per hectare. However, as set out in paragraph 3.35 of the Interim Housing SPG, in a mixed-use scheme such as this with the allocation and layout of uses that is proposed, a straight calculation of dwellings per hectare or habitable rooms per hectare (based on the overall site area), is not an appropriate measure of density. Further discussion is required in relation to this matter, as based on the net residential floor space, it is apparent that the residential density is more in the range of 1,100 habitable rooms per hectare which is at the far end of the guidance range.
47 Notwithstanding the results of the above analysis, it is acknowledged that the transport accessibility and the built context could support a high-density development on the site, compatible with the design principles of Policy 4B.1. Compliance with other policies, particularly those relating to design quality, scale of development social infrastructure, open space and play space, is also necessary. As noted below, there are concerns in relation to these points, which require further discussion and information.
48 In order for a high density to be acceptable, the application would need to be exemplary in all other respects and provide a high quality living environment (including adequate provision of amenity space, an appropriate level of affordable housing, a good mix of unit sizes, high quality design and resolution of all transport and climate change issues).
Tall buildings / views
49 London Plan policies 4B.8 and 4B.9 (and policy 7.7 of the DRLP) relate to the specific design issues associated with tall and large-scale buildings, and are of particular relevance to the proposed scheme. These policies set out specific additional design requirements for tall and large- page 9 scale buildings, which are defined as buildings that are significantly taller than their surroundings and/or have a significant impact on the skyline and are larger than the threshold sizes set for the referral of planning applications to the Mayor.
50 The development is within the Background Assessment Area of protected views from Parliament Hill and Primrose Hill, as set out in the Mayor’s London View Management Framework SPG (revised, July 2010), and buildings D and F exceed the consultation threshold plane. The applicant has undertaken an visual assessment of views from Parliament Hill and Primrose Hill (assessment points 2B.1 and 4A.1) which shows that the scheme not be visible, as it will be obscured in these views by existing development. However, the documents need to be revised to reflect the revised SPG, which updates the analysis requirements from these locations. Specifically, an analysis from viewpoint 2A.2 (the summit of Parliament Hill) is required.
51 The development will be visible in the south-facing river prospect view from Westminster Bridge, but will be viewed against existing and proposed buildings of similar heights. Officers are satisfied that the buildings will have no negative impacts on any protected views, or the setting of the World Heritage Site at Westminster.
52 The proposed heights of the buildings are within the height range of the consultation draft Vauxhall Nine Elms Battersea Opportunity Area Planning Framework document. Urban design
53 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage, views, and the Blue Ribbon Network. The draft replacement London Plan reinforces these principles, with new development required to have regard to its context, and reinforce or enhance the character, legibility and permeability of the neighbourhood (policy 7.1).
Effect on listed buildings
54 There are two Grade II listed buildings on the site, and one immediately adjacent. Consideration of the effects of the proposal on these buildings is required, in conjunction with the guidance offered within PPS5 and the London Plan’s policies to protect London’s built heritage. In considering the previous application, the Deputy Mayor raised particular concerns over the height and location of some of the proposed buildings.
55 The former fire station building (building A), which is presently the dominant building on the site, would have a glass and steel extension added to the upper floors. This has been reduced from two storeys in the previous application, to a single storey in the current application. Its predominantly glass appearance will offer a lightness to the extension that will not unduly weigh against the building, and retain its symmetrical proportions. The height is appropriate and would reinstate the historically even roofline of this part of the embankment. Additionally, the profile and roofline of the original building will remain clearly distinguishable from the extension. Officers have no objection to this element of the proposal.
56 Concerns were previously raised regarding the height of building C, and the current scheme has amended this building, such that it now comprises a single storey element. This reduction enables the listed drill tower to be seen from the river. More importantly, it enables building A, which is impressive and imposing, in part due to its isolation from adjoining buildings, to remain as such. These alterations respect the scale of the listed buildings on the site and are supported. page 10 57 As with the previous iteration of the scheme, the taller buildings D and F would continue to have an effect on the isolation and symmetrical effect of building A when viewed from across the river. Although it could be argued that taller buildings set behind other buildings are a regular part of the townscape within this area, the separation distance between building A and building D is not large enough to offer a clear separation. The height reduction of building D, compared to the previous scheme, barely affects this situation in views across the river, and further consideration should be given to reducing the heights of these buildings to provide deference to building A. It is appreciated that other taller buildings to the rear of the development are proposed, such as that at 81 Black Prince Road, as well as other nearby buildings such as Hampton House, and that these will move behind the field of the proposed building when viewed from different positions along the northern bank of the Thames. However building A’s symmetry is best appreciated from directly in front of the building (around view L2 in the applicant’s townscape assessment), from a publicly accessible and well-traversed location – where the only visible buildings to the rear of building A will be those proposed on the site.
58 The Grade II listed Southbank House is outside the site but abuts its southern boundary. Although taller buildings will be built directly behind Southbank House, this building is appreciated predominantly from close, street level views, and there is no objection to the scheme on this basis. The removal of the existing control centre and replacement with building B (which is taller but will have a sympathetically designed facade) is acceptable.
59 The heights and scale of the other buildings around the site are appropriate and the revisions compared with the previous scheme are welcomed.
Landscaping and materials
60 The proposed materials are welcomed, and will provide a high-quality finish to the development. Although the level of direct sunlight into the internal courtyards will be limited, the highly developed urban context of the spaces is understood, and the public realm and landscaped areas will provide welcoming and attractive spaces. Although these spaces would in turn be of better quality if the scale of the surrounding blocks were reduced, as set out above.
Residential quality
61 The Mayor has recently published his interim Housing Design Guide and Housing SPG EiP draft. Aspects of this, notably the minimum space standards for dwellings, are also reflected in the draft replacement London Plan. Although these do not strictly apply to this non-grant funded scheme, they do provide (along with the emerging Housing SPG – EiP version) a demonstration of good practice. The applicant also confirms that the same building quality is provided for the affordable and market accommodation.
62 The application documentation states that development of the scheme occurred prior to the publication (and draft publication) of the London Housing Design Guide, however, the applicant confirms that the affordable units have been designed to meet the Housing Design Guide, so as to enable them to attract grant funding. Furthermore, many of the principles of the documents have been incorporated with regard to internal housing layout generally, and the accommodation schedule demonstrates that most of the proposed dwellings exceed the minimum space standards as set out within the draft replacement London Plan, with just some of the remaining dwellings just under the standards. The exception is dwellings within building A, whereby the designers have had to design accommodation within the constraints of the heritage building, which is accepted. Amenity space is provided in the form of communal roof gardens, and most flats have a private balcony or winter garden. The total on-site amenity provision is 6,115 sq.m, which exceeds the Council’s expected level of private and communal amenity space.
page 11 63 Some of the proposed flats would experience substandard levels of daylight, and whilst this can be expected in dense inner-urban environments, again it is noted that if the issues raised in relation to building heights were addressed, these should be improved. Light levels would be worst within some flats of building A, although it is accepted that this is a heritage building and a balanced judgement of retaining heritage features while providing a reasonable level of new housing.
64 Building F contains single-aspect flats that face directly onto the railway. Balconies have been provided to enable residents access to private outdoor space, but the proximity of the railway and aspect of the flats could result in a poor quality residential environment. As noted in the Mayor’s Housing Design Guide and emerging Housing SPG, single aspect units that will be subjected to noise levels that fall within NEC Category C of PPG24 are discouraged. Consideration of alternative options is not demonstrated within the design and access statement.
65 The development will contain a complementary mix of uses and the separation of fire station and residential uses is well considered. Internal routes within the development are appropriate, although the applicant should reconsider the location of wheelchair parking bays and in relation to their distance to residential cores. Active frontages are provided on the external elevations. Ambient noise
66 London Plan policy 4A.20 ‘Reducing noise and enhancing soundscapes’ requires that noise sensitive development should be separated from major sources of noise wherever practicable. Corresponding policy 7.15. The advice contained in Planning Policy Guidance note 24 (PPG24): Planning and noise is also relevant.
67 The dominant noise sources in the area of the proposed development are road and railway traffic and the applicant’s noise assessment indicates that monitored noise levels place the site into the NEC C and B, as defined by PPG24. However, part of the site falls within NEC D during the night, and PPG24 advises that planning permission should normally be refused.
68 Whilst it is noted that the applicant has located residential accommodation above the railway viaduct, there is a concern in relation to the noise that may be generated by the industrial use at the lower levels, together with the ambient noise from rail. As noted above, there is some concern about single aspect units that would be subjected to high levels of noise.
69 The noise assessment demonstrates that high noise levels would affect the development, and that the facade of the proposed development would be required to provide sufficient attenuation to ensure that the guideline internal noise levels conditions are met. Particular attention will need to be paid to glazing which faces the railway, with provision made for trickle vents in order to make the living conditions for residents acceptable. The Council should ensure that appropriately worded conditions are imposed in this respect, including a requirement that maximum noise levels are not exceeded. Further consideration should also be given to the layout of the single aspect units facing the railway, as noted above.
Children’ play space
70 Policy 3D.13 of the London Plan and policy 3.6 of the draft replacement London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs”. Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 116 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, page 12 with under-5 child playspace provided on-site. As such the development should make provision for 1,160 sq.m. of playspace, of which approximately 330 sq.m. should be provided on-site for under 5 year olds.
71 As was the case with the previous application, the proposal does not include any designated child play space and it is intended that the residents of the development make use of existing play facilities in the surrounding area. It is noted that the Council recommended a reason for refusal on these grounds when considering the previous scheme, before the application was withdrawn. The Mayor’s SPG clearly states that provision for children under-5 must be made on site. The proposal should therefore be amended to include 330 sq.m. of designated child play space for younger children.
72 Whilst the applicant has submitted photographs of surrounding parks, and has provided some details of the local playable spaces or playgrounds, including their facilities, size, accessibility and suitability of the space for play and recreation, it remains unclear as to the capacity of these spaces, when considering this scheme along with other existing and permitted developments. The applicant suggests that there is the potential for a contribution to be made to improving play space in public parks, however further discussion is required with the Council in order to be satisfied that a contribution would be suitable or appropriate mitigation. This is particularly in light of the recent appeal decision for Vauxhall Bondway, where the Inspector noted that Vauxhall area is an area of open space deficiency, and that financial contributions could not necessarily relieve the pressure on existing facilities.
73 At present, it is not possible to ascertain whether the proposal provides access to good quality designated play space for the residents, and further discussion is required before the application is reported back at Stage 2, so as to ensure that the scheme complies with policy 3D.13 of the London Plan. Inclusive design and accessibility
74 Policy 4B.5 of the London Plan and 7.2 of the draft replacement London Plan expects all future development to meet the highest standard of accessibility and inclusion. This, together with the London Plan’s supplementary planning guidance ‘Accessible London: achieving an inclusive environment’, underpins the principles of inclusive design and the aim to achieve an accessible and inclusive environment consistently across London. Policy 3A.5 of the London Plan and policy 3.8 of the draft replacement London Plan requires all new housing to be built to ‘Lifetime Homes’ standards and 10% of all new housing to be designed to be wheelchair accessible to meet the full range of housings needs.
75 The applicant’s design and access statement confirms that all the residential units will meet the Lifetime Homes criteria. A total of 29 units (10%) of units would be wheelchair accessible, or easily adaptable, meeting HABINTEG guidance. Detailed floor plans for the typical wheelchair flats, comprising a mix of one, two and three bed units, has been provided, and the units would be allocated across the development. Further clarification as to how the scheme goes beyond the Lifetime Homes criteria, and also how the units would be allocated across tenures, should be provided before the application is referred back to the Mayor.
76 As noted elsewhere, the number of accessible parking bays would not equate to the number of wheelchair accessible units. This does not therefore reflect best practice standards, which require one space per wheelchair unit, and at least one beside each lift core in accordance with the lifetime homes standards. At present, the location of the accessible parking bays on the middle site would necessitate a convoluted access route to entrances and cores, and it is not clear on the rationale for the chosen parking spaces. Further consideration should be given to their number and location, so as ensure that provision equates to the demand from disabled residents and visitors, that the bays are effectively enforced, that needs are met and that disabled people are page 13 not prevented from living or working in this development, or visiting it, due to a lack of suitable parking.
77 In terms of the external environment, policy 7.5 of the draft replacement London Plan requires that public spaces should be secure, accessible and easy to understand. The existing site is relatively level, and the scheme proposes improvements to Lambeth High Street, which runs through the middle of the site to create new public realm. There are drop-off points available beside all entrances to buildings, and courtyards and podiums are to be designed to be fully accessible. The office and retail space would have level entrances and lift access, and the fire station would also be designed to building regulation requirements for public buildings. Sustainable development
78 The London Plan climate change policies as set out in chapter 4A collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising decentralised energy supply, and incorporating renewable energy technologies with a target of 20% carbon reductions from on-site renewable energy. The policies set out ways in which developers must address mitigation of, and adaptation to, the effects of climate change. Policies 4A.2 to 4A.8 of the London Plan focus on how to mitigate climate change, and the carbon dioxide emissions reduction targets that are necessary across London to achieve this.
79 The corresponding policies in the draft replacement London Plan are set out in Chapter 5. These policies follow the same general approach with respect to the energy hierarchy but places greater emphasis on minimising carbon dioxide emissions and making use of decentralised energy systems and networks.
Energy – climate change mitigation
80 Policies 4A.4-11 of the London Plan require a reduction in a development’s carbon dioxide emissions through the use of passive design, energy efficiency and renewable energy measures. The London Plan requires developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures and prioritising decentralised energy, including renewable technologies.
81 In considering the previous application, officers were generally satisfied that the applicant had broadly followed the energy hierarchy, however, there were some points of clarification that were required in relation to the heat network and CHP system. Considering each of these points again in term, the following is noted:
Be lean – energy efficient standards
82 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, energy efficient lighting and optimised controls.
83 Based on the information provided, the proposed development does not appear to achieve any carbon savings from energy efficiency alone compared to a 2010 Building Regulations compliant development, which are applicable to this current application. Using 2010 Building Regulations compliance software, the applicant should model, and commit to, additional measures that can be adopted to enable the development to exceed 2010 Building Regulations compliance through energy efficiency alone.
page 14 Be clean – district heating
84 The development is within the vicinity of Vauxhall Nine Elms, where there are plans for an area district energy network. As such, the main development is being designed to allow future connection to external district heating networks when the opportunity arises.
85 Two energy centres are proposed for the main development, one on the front and one on the middle site. The energy centres will be linked together by the site heat network. A separate energy centre is proposed for the rear site. The energy centres will provide heat to all commercial units, as well as the residential units.
86 In order to be satisfied regarding the deliverability and phasing, the applicant should provide further information on the phasing constraints to adopting a single energy centre for the front/middle sites. For example, the floor area of a single energy centre, accommodated in the first phase, and capable of supplying the whole site, should be provided and compared to the 114 sq.m. already planned for building B.
Combined Heat and Power
87 The energy centre in the middle of the site will incorporate a 228kWe gas fired CHP. This will be sized to supply the domestic hot water load and approximately 20% of the space heating load for the front and middle sites. Load profiles have been provided in support of the sizing of the CHP units.
88 A 5kWe gas fired micro CHP unit is proposed to serve the small rear site network.
89 A reduction in regulated carbon dioxide emissions of 347 tonnes per annum (19%) will be achieved through this second part of the energy hierarchy.
Cooling
90 A range of passive design features will be incorporated in the development including high performance glazing, high levels of thermal mass and shading features. While most of the residential units will be passively cooled, a proportion of the market residential units will be provided with active cooling. The fire station, retail, restaurant and offices will also be actively cooled.
Be green
91 The applicant is proposing the installation of 483 sq.m. of photovoltaic (PV) panels, producing a reduction of 21 tonnes per annum (1%) in carbon emissions over and above those due to energy efficiency and combined heat and power. The potential for greater contributions from photovoltaic panels are constrained due to the roof space being limited due to other factors, such as green roofs. The proposed location of the PV panels has been identified on roof drawings, taking into account other proposed uses for the space. This is welcomed, and the minimum area for the PV panels should be secured by way of condition.
92 It is acknowledged that the potential for other renewable technologies is constrained due to the characteristics of the site and the extent to which they could be successfully integrated with combined heat and power.
Climate change adaptation
93 The London Plan promotes five principles in policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribute to heat island effects; minimise solar gain in summer; contribute to flood risk reduction, including applying page 15 sustainable drainage; minimising water use; and protect and enhance green infrastructure. Specific policies cover overheating, living roofs and walls and water. These policies have also been carried over into the draft replacement London Plan. Policy 4A.3 of the London Plan requires all development proposals to include a sustainability statement. Further guidance on this policy is given in the London Plan Sustainable Design and Construction SPG. In addition, London Plan policies 4A.3, 4A.11, 4A.14 and 4A.16 require the inclusion of sustainability measures within developments (policies 5.10 to 5.15 of the draft replacement London Plan).
94 The applicant has prepared a sustainability statement that follows the Mayor’s SPG. A series of measures which would together assist in achieving a BREEAM ‘Very Good’ for the commercial uses and a Code for Sustainable Homes (CfSH) “Level 3”‟ for the residential units. BREEAM and CfSH pre-assessments have also been submitted as part of the application submission. A range of general sustainability measures are proposed, including sustainable construction practices, energy efficient appliances, 100% water metering and low flow appliances, a waste strategy and water conservation measures. A grey water recycling system for the fire station to serve the internal fire station operations is proposed, and it is intended that the scheme will achieve 50% attenuation of the site’s surface water run-off at peak times using sustainable urban drainage systems and green/garden roofs. These measures are strongly supported, and should be secured through planning conditions. Transport
95 London Plan policy 3C.1 and 3C.2, together with DRLP policies 6.1 and 6.3 seek to integrate transport and development and ensure that there is sufficient transport capacity to allow for travel generated by new development.
96 As noted above, as part of the emerging Opportunity Area Planning Framework TfL has completed a strategic transport study for the Opportunity Area. The findings recommend that a major public transport intervention is required in order to enable high density development in line with the London Plan and GLA’s preferred ‘revised scenario 5’ and support regeneration within the Vauxhall, Nine Elms and Battersea Opportunity Area. Based on the scale and density of uses proposed both the study and the draft-planning framework conclude that existing constraints and limitations on public transport, infrastructure and highways present a major barrier to the future development of the area.
97 The strategic transport study has tested an extension to the Northern Line as an option and concluded that an underground extension with an intermediate stop in the Nine Elms area, supported by a wider package of measures including transport improvements around the Vauxhall area as well as bus, highway, pedestrian and cycling enhancements and improved river transport throughout the opportunity area is required to provide an acceptable level of additional transport capacity and improve public transport accessibly to meet the demands generated by new residential, retail and commercial developments such as this proposal.
98 During the consideration of the previous application, a number of concerns and queries were raised in relation to trip generation, residential car parking, cycle parking, servicing, pedestrian movement and facilities, in order to make the travel plan acceptable. A contribution towards local and regionally strategic transport improvements was also sought. TfL welcomes that the applicant has submitted an amended trip generation methodology which is inclusive of 3 TRAVL sites which are comparable in terms of public transport and car parking.
Parking
99 The current scheme proposes a total of 179 car parking spaces, 21 of which are allocated to the London Fire Brigade for its on-going operational needs. The level of operational parking
page 16 relating to the LFB use is deemed acceptable. No car parking has been allocated to office/commercial space, which is also welcomed.
100 The remaining 158 spaces are proposed to serve the 293 residential units, this equates to 0.54 spaces per unit. It is understood that 18 disabled parking spaces are proposed. However, in light of the fact that disabled parking should be provided at a minimum of 10% of the proposed residential units, the proposed level is unacceptable. A minimum of 1 disabled space should also be provided in an accessible location for each other additional land use.
101 As advised during the consideration of the previous application, the level of residential parking is deemed as excessive particularly in relation to the high public transport accessibility level (PTAL 6a), the Central London location and levels of traffic and congestion on surrounding roads. In addition, recent residential developments in this area have come forward and been approved with minimal levels of car parking (i.e. car-free to 0.2 spaces per residential unit). The draft Vauxhall Nine Elms Battersea OAPF (November 2009) sets out a maximum parking ratio of 0.25 for residential development across the Opportunity Area. It is therefore considered that the proposal fails to comply with London Plan policy 3C.23 and draft replacement London Plan policy 6.13 with respect to the level of residential car parking. The applicant would also be expected to agree to exclude all occupiers of the development from eligibility for on-street parking permits – this would need to be secured as part of a section 106 legal agreement.
Cycle parking
102 The transport assessment states that 294 cycle parking spaces will be provided for the residential element of the development with a further 39 spaces for the commercial uses, five for retail/restaurant, with nine allocated for the London Fire Brigade. This is generally in line with TfL’s cycle parking standards. The development will also provide a number of easily accessible short stay visitor spaces at street level, which is supported, so too proposals for the occupiers of the office use and retail/restaurant space to provide shower and changing facilities for staff within their units. The application is in conformity with London Plan policy 3C.22 and draft replacement London Plan policy 6.9.
Public realm and landscaping
103 As noted above, TfL has undertaken a public realm and highways study that focuses on improvements to/opportunities for Vauxhall gyratory, Albert Embankment and Nine Elms Lane. A preferred option has been identified for Albert Embankment and Vauxhall Gyratory aimed at improving the overall quality of public realm and pedestrian connections and linking to Central London as well as the wider Opportunity Area. It is essential that TfL and the Council be fully consulted on the detailed design of the landscaping proposals, in particular the section fronting on Albert Embankment.
104 The applicant will be required to enter into a Section 278 agreement for any proposed works on the highway, for which TfL is the highway authority, including works to the footway on Albert Embankment.
105 In order to accord with London Plan policy 3C.21 and DRLP policy 6.10, and to improve wayfinding from the development to the surrounding area, a contribution towards improving off- site pedestrian and public realm improvements will be expected as part of the wider transport contribution.
Servicing and deliveries, travel plan
106 Where possible all servicing activities should take place ‘off-street’. In this respect, further evidence is required to demonstrate that no other options exist but to service the front and rear
page 17 sites ‘on-street’, and the middle site using the central ‘public space’ as proposed. In addition the applicant is expected to ensure that any ‘off-site’ mitigation measures are provided to enable servicing to take place in a safe and efficient manner.
107 The applicant has agreed to prepare a full delivery and servicing plan prior to occupation of the development, together with a construction logistics plan prior to the commencement of works. Both these documents will need to be agreed by the local planning authority in consultation with TfL and be secured using planning conditions. Further work is required before TfL can be content that this applicant complies fully with London Plan policy 3C.25 Freight strategy and draft replacement London Plan policy 6.14 Freight.
108 A framework travel plan has been submitted and reviewed. This has passed the ATTrBuTE test, which is welcomed, however further work on objectives, measures and budget and funding is required before the plan can be deemed to be acceptable. A car parking management plan should also be included. The travel plan assessment, which identifies required improvements, will be forwarded to the applicant. The travel plan must be secured, enforced, monitored, reviewed and funded through any proposed section 106 agreement.
Mitigation/section 106 contributions
109 The Mayor’s SPG: Use of planning obligations in the funding of Crossrail (July 2010) states that the VNEB opportunity area represents a ‘special case’ and whilst the SPG omits this area from the Central London charging area, it does so on the basis that ‘development will be making contributions towards other regionally important transport infrastructure which will enable the quantitative and qualitative optimisation of development to meet the objectives of the London Plan’.
110 As noted previously, the draft Vauxhall Nine Elms Battersea OAPF (Nov 2009) concludes that a major transport intervention, supported by a wider package of interchange, rail and Underground station, bus, highway, pedestrian and cycling enhancements and improved river transport is required to provide an acceptable level of additional transport capacity and improve public transport accessibly to meet the demands generated by new residential, retail and commercial developments such as this proposal.
111 In line with the approach taken on other recent schemes in the area, TfL expects a significant contribution towards strategic transport improvements. The scale of this contribution must reflect the levels set out in the draft section 106 Chapter (Feb 2011) and supporting VNEB Development Infrastructure Funding Study (Oct 2010). As set out in paragraphs 22 and 23 of this report, further discussions between the applicant, Council, GLA and TfL are required in relation to this matter. Local planning authority’s position
112 Lambeth Council is currently considering the application, but has not advised on its position to-date. Legal considerations
113 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 page 18 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
114 There are no financial considerations at this stage.
Conclusion
115 London Plan policies on the principle of development, density, housing, urban design, access, affordable housing, child play space, climate change and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:
Principle of development: The principle of the re-provision of a state of the art fire station and residential-led mixed-use redevelopment within the Central Activities Zone and Vauxhall/Nine Elms Opportunity Area is consistent with London Plan policy. Housing: In the absence of an appraisal of the applicant’s financial viability report, it is not possible to establish if the affordable housing is the ‘maximum reasonable amount’, in accordance with policy 3A.10 of the London Plan. The housing mix and tenure are also inconsistent with strategic planning guidance. Density: The application fails to demonstrate that an exemplar development would be delivered so as to justify such a high density. Urban design: The proposal, by reason of the height and scale of buildings D and F, is inconsistent with London Plan policy 4B.1 and 4B.10. Child play space: The proposal provides no on-site designated child play space for children under 5 and it is not possible to ascertain whether the proposal provides access to good quality designated play space for the residents. The proposal does not comply with policy 3D.13 of the London Plan. Access: The applicant has committed to meeting Lifetime Homes standards, together with the provision of 10% wheelchair accessible units. However, insufficient information has been provided in order to demonstrate that the scheme accords with London Plan policies 3A.5, 3D.7 and 4B.5. Climate change mitigation: The applicant has broadly followed the energy hierarchy in Policy 4A.1. Sufficient information has been provided to understand the proposals as a whole and to verify carbon dioxide savings in principle. However, further clarification is required in relation to specific issues.
Climate change adaptation: The proposal includes sustainable urban drainage, green roofs and a grey water recycling systems. As such the proposal complies with London Plan policies 4A.9, 4A.11 and 4A.14.
Transport: TfL has a number of concerns about the development proposals and requires further work and information before this application could be considered acceptable in terms of London Plan transport policies.
116 Whilst the application is broadly acceptable in strategic planning terms. On balance, the application does not comply with the London Plan.
page 19 117 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:
Housing and affordable housing: Further information is required in relation to the housing mix and tenure, together with verification of the applicant’s financial appraisal to demonstrate that the affordable housing level is the maximum reasonable amount. Review mechanisms for securing phased viability assessments should also be discussed before the application is referred back to the Mayor. Density: Further discussion is required in relation to the residential density of the scheme. The applicant should address the issues raised in relation to design, residential quality, and play space in order to provide a rationale for proposing such a significantly high density. Urban design: Further amendments are required to building D and F to provide deference to building A. Further information regarding the residential environment of the single aspect units is also required. The amendments and further information should be submitted before the application is referred back to the Mayor. Children’s play space: The proposal should be amended to include 330 sq.m. of on-site designated child play space for children under the age of five. Further information should also be submitted in relation to the capacity of surrounding play space for older children before the application is referred back to the Mayor. Inclusive design and accessibility: Details of how the residential units would comply with Lifetime Homes and wheelchair accessibility standards is required before the application is referred back at Stage 2, together with details of tenure. Climate change mitigation: Further information is required in relation to energy efficiency measures and district heating before the application is referred back to the Mayor.
Transport: Further information and amendments in relation to car parking, servicing, pedestrian movement and facilities is required to make the travel plan acceptable. Further discussion is required in relation to mitigation measures and contributions towards local and regionally strategic transport improvements before the application is referred back to the Mayor.
for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Samantha Wells, Case Officer 020 7983 4266 email [email protected]
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