planning report PDU/1999b/01 23 November 2011 Over-station development, Royal Arsenal in the London Borough of Greenwich planning application no.11/2382/O

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 A hybrid (part detailed and part outline) planning application for the erection of 592 dwellings and 4,688 sq.m. of non-residential floorspace (for uses within classes A1,A2, A3 A5 B1 and D1), with full details of 165 senior living units, two basement levels and ground floor commercial uses, associated landscaping, access, car parking, cycle parking and refuse and recycling facilities; and outline proposals for the erection of the remaining 427 dwellings and associated landscaping.

The applicant The applicant is Berkeley Homes (East Thames) Ltd and the architects are Lifschutz Davidson Sandilands.

Strategic issues The key issues relate to an increase in the number of residential units and the amount of commercial (particularly retail) space, and changes the design of the buildings for which outline permission has previously been granted. Other issues include transport, energy, children’s play space and equalities.

Recommendation That Greenwich Council be advised that while the application is generally acceptable in strategic planning terms it does not fully comply with the London Plan, for the reasons set out in paragraph 91 of this report; but that the possible remedies set out in paragraph 93 of this report could address those deficiencies.

Context

1 On 17 October 2011, the Mayor of London received documents from Greenwich 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 25 November 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. This report sets out information for the Mayor’s use in deciding what decision to make.

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

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

1B- “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings—(c) outside Central London and with a total floorspace of more than 15,000 square metres.” 1C- “Development which comprises or includes the erection of a building of one or more of the following descriptions—(c) the building is more than 30 metres high and is outside the City of London.”

3 Once Greenwich 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 hybrid application relates to an irregular-shaped site, 1.47-hectares in size, earmarked for the location of a future Crossrail Station in Woolwich, but presently vacant following the cessation of its use as a public car park. A location plan showing the site and its relationship to the masterplan boundary for The Warren/ Royal Arsenal site as a whole is provided below:

Figure 1: Location map showing the application site in the south–east corner of the masterplan boundary. (Source: applicant’s Design & Access Statement). 6 The highly accessible site, which is within the designated town centre boundary, is surrounded on the north by the Grade II Listed former Royal Carriage Factory, part of which has been redeveloped as phase 1 of The Warren/Royal Arsenal masterplan and is now known as The Armouries; on its immediate south by the A206 Plumstead Road which forms part of the Strategic Road Network (SRN); on the east by Arsenal Way, from which vehicular access is derived via Arsenal Lane; and on the west by Verbruggen’s House, another Grade II Listed building situated within Dial Arch Square. The Dial Arch Block is a Grade II Listed courtyard officers’ house, situated directly northwest of the application site.

7 The nearest section of the Transport for London Road Network (TLRN) is the A205 John Wilson Street, some 650m west of the site. The site also benefits from an extensive bus network

page 2 and access to Woolwich Arsenal station, located approximately 300m away to the south, and which accommodates both DLR and national rail services. A limited river service to Waterloo Pier is also available from the site. As such it has been demonstrated that the site records an excellent public transport accessibility level (PTAL) of 6 on a scale of 1-6, where 6 is the highest. The accessibility of the site will also be further improved in the near future, with the arrival of Crossrail. Details of the proposal

8 These phase 4 proposals will form part of the masterplan development, for which Greenwich Council granted outline permission in February 2011, to deliver a residential-led mix of uses, including 3,711 new homes and 26,362 sq.m. of non-residential floorspace on 15.5 hectares of land at The Warren/Royal Arsenal in Woolwich.

9 This application relates to the site of Blocks J1, J2 and J3 on the approved masterplan of February 2011. The outline approval was for a mixed-use development of the site, comprising 585 residential units and 3,354 sq.m. of non-residential space in a series of buildings ranging from 5 to 22 storeys in height; and the sitting beneath those buildings of a ‘station box’ to accommodate the passenger platforms and tunnel of the proposed Woolwich Crossrail Station; with the station building located at ground floor.

10 Since the outline permission was granted, however, Crossrail Ltd has undertaken a cost- efficiency engineering review of its original design; culminating in a reduction in depth of the station box and the size of the station building, along with their relocation some 18 metres to the east of its approved position. This has brought the estimated cost of the Crossrail proposal at Woolwich to within fundable limits, but in turn triggered the need for a major review of the parameters for the approved over-station development.

11 This ‘hybrid’ (part detailed and part outline) planning application now seeks permission for the construction of 592 dwellings and 4,688 sq.m. of non-residential floorspace. The proposals represent an increase in residential provision, from the consented 585 to 592 units (an increase of 7 units); and a 1,334 sq.m. increase in the amount of speculative commercial space from 3,354 sq.m. to 4,688 sq.m. (approximately 40% over the consented scheme).

12 Full permission is sought for the details of 165 ‘Extra Care’/affordable units to be located above the Crossrail Station Box, two basement levels and all ground floor uses with associated access, car and cycle parking, and refuse and recycling facilities.

13 Outline permission is sought for the remaining 427 market sale dwellings to be located in residential towers on the southern side of the site, above the basement and ground floor retail levels, with internal and external design reserved for determination at a later date.

14 The development would comprise three ‘Extra Care’(affordable housing) blocks, ranging from ground plus 6 to ground plus 7 floors, to be situated along the north boundary of the site of the site abutting Arsenal Way; three blocks of open market residential towers, ranging from ground plus 10 to ground plus 20 floors, situated along the southern boundary with Plumstead Road; and two additional market residential towers, ranging from ground plus 6 to ground plus 13 floors, situated on the west side of the main pedestrian route between Plumstead Road and the proposed Station Square.

15 The purpose of the detailed application is to facilitate the immediate construction and fitting out of the Crossrail station box, to which the proposed development is closely linked, within the construction timeframe prescribed for that project; whilst securing an ‘outline only’ permission for the residential towers likely to be delivered over a longer timescale.

page 3 Case history

16 In September 2009, the Mayor allowed Greenwich Council to grant outline permission for a revised masterplan for the redevelopment of The Warren/Royal Arsenal site, following confirmation that a Crossrail station would be located within the site; and that the developer, Berkeley Homes, had also acquired the Waterfront Leisure Centre car park in the north-western corner of the site and the right to align the existing Woolwich Park on the north-east with the A206 Beresford Street.

17 The revised scheme was for 3,711 residential dwellings and 26,362 sq.m. of commercial space; including a 150-room hotel, retail units, bars/restaurants, offices, a healthcare facility, a nursery, museum, and a combined heat and power plant; with associated landscaping, open space, car parking and access arrangements. The revised approval notice was issued by the Council in February 2011.

18 Various phases of the approved masterplan have been implemented; however, in the light of inevitable changes in circumstances over the relatively lengthy timescale needed to deliver such an extensive project, Berkeley Homes has been compelled to submit separate planning applications rather than reserved matters, to reflect any significant deviation from the parameters set within the original outline permission.

19 In September 2011, Berkeley Homes sought pre-application advice from the GLA for the submission of a hybrid (part detailed and part oultline) planning application for the construction of 592 dwellings and 4,720 sq.m. of non-residential floorspace; with full details of the construction of 165 ‘Extra Care’ units to be located above the proposed Crossrail Station Box, all ground floor uses and two basement levels, associated access arrangements, car and cycle parking space, refuse and recycling facilities; and outline proposals for the erection of the remaining 427 dwellings and associated landscaping.

20 The matters to be reserved for future consideration were the internal and external design of the 427 dwellings to be located in residential towers on the southern side of the site, above the basement and ground floor retail levels.

21 In its written advice dated 23 September 2011, GLA officers concluded that the preliminary proposals were generally well-presented and proceeding in the right direction, subject to a formal submission with all relevant details provided for the assessment of a planning application. Strategic planning issues and relevant policies and guidance

22 The relevant issues and corresponding policies are as follows:

 Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, Housing Strategy; Assembly draft Revised Housing Strategy; Interim Housing SPG; Housing SPG EiP draft  Affordable housing London Plan; PPS3; Housing SPG, Housing Strategy; Assembly draft Revised Housing Strategy; Interim Housing SPG; Housing SPG EiP draft; Affordable Rent draft SPG; Assembly draft Early Minor Alteration to the London Plan  Density London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing SPG EiP draft  Retail/town centre uses London Plan; PPG13, PPS4  Urban design London Plan; PPS1

page 4  Tall buildings/views London Plan; RPG3A, Revised View Management Framework SPG; revised draft View Management Framework  Historic Environment London Plan; draft World Heritage Sites SPG; PPS5; Circular 07/09  Transport/parking London Plan; Assembly draft Early Minor Alteration to the London Plan; the Mayor’s Transport Strategy; PPG13; Land for Transport Functions SPG  Crossrail London Plan; draft Mayoral Community Infrastructure Levy; Crossrail SPG  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the spatial needs of London’s diverse communities SPG; Diversity and Equality in Planning: A good practice guide (ODPM); Equalities Act 2010  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; Mayor’s Climate Change Mitigation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy; Sustainable Design and Construction SPG

23 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 2006 Greenwich Unitary Development Plan and the 2011 London Plan.

24 The following are material planning considerations, to which appropriate weight should be accorded:

 The Greenwich ‘Draft Core Strategy with Development Management Policies’.

 The Early Minor Alteration to the London Plan

 Greenwich Site Allocations Development Plan Document Land use policy and the mix of uses

25 The principle of a residential-led, mixed-use development of The Warren/Royal Arsenal site is established by an extant permission, reinforced in the Council’s UDP (policy W3), its Draft Core Strategy with Development Management Policies (where it is identified as a ‘location for strategic development’) and in the London Plan, which identifies Woolwich as an ‘opportunity area’ with significant capacity for additional homes and jobs.

Housing

Density

26 London Plan policy 3.4 aims to optimise the housing output of development sites in different locations, depending on the local context, character and public transport accessibility. In this instance, the residential density is based on the proposed total of 592 units, although the mix of unit sizes for the 427 units, for which outline permission is sought, is unknown at this stage and cannot, therefore, be expressed in habitable rooms per hectare.

page 5 27 The overall density is calculated to be close to the indicative maximum of 405 units per hectare, stated in the London Plan density matrix (table 3.2) for a site in a central location with an excellent public transport accessibility level of 6; which is likely to improve with the introduction of a Crossrail service at the doorstep of the scheme.

28 Based on the existing and potentially higher level of accessibility, the proposed housing density is acceptable in strategic planning terms.

Housing choice

29 London Plan Policy 3.8 and the associated supplementary planning guidance promote housing choice and seek a balanced mix of unit sizes in new developments. The London Housing Strategy sets out strategic housing requirements and policy 1.1C of the strategy includes a target for 42% of social rented homes to have three or more bedrooms.

30 The 165 senior living units would comprise 57 one-bedroom units and 108 two-bedroom units. Given the nature of senior living, however, no three bedroom units are included within this scheme. The tenure split of the accommodation is detailed in the affordable housing section of this report.

31 The applicant should provide an indication of the mix of unit sizes which they are intending to deliver within the outline part of the application.

Housing quality

32 London Plan Policy 3.5 promotes quality in new housing provision and sets out minimum space standards at Table 3.3. The Mayor will produce a new Housing SPG (a draft of which was put before the London Plan EIP) on the implementation of policy 3.5 for all housing tenures; drawing on his London Housing Design Guide. Paragraphs 3.37 –3.39 provide further guidance on indicators of quality that the proposed SPG will cover.

33 Against the minimum space standards of 50 sq.m. for a one bed (two person) unit and 61 sq.m for a two bed (three person) unit, the development would provide unit sizes of 55-62 sq.m. and 66-81 sq.m. respectively. The relatively generous sizes reflect the needs of the potential occupier but are separate from the requirement to provide 10% wheelchair accessible or adaptable homes- an issue addressed elsewhere in this report.

Affordable housing

34 London Plan Policy 3.12 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mixed-use schemes. In doing so each council should have regard to it’s own overall target for the amount of affordable housing provision. This target should take account of the requirements of London Plan Policy 3.11, which include the strategic target that 60% of new affordable housing should be for social rent and 40% for intermediate rent or sale.

35 The Mayor has published an early minor alteration to the London Plan to address the introduction of affordable rent, with further guidance set out in a draft Affordable Rent SPG. With regard to tenure split the Mayor’s position is that both social rent and affordable rent should be included within the 60%.

36 While the Mayor has set a strategic investment benchmark that across the affordable rent programme as a whole rents should average 65% of market rents, this is an average investment

page 6 output benchmark for this spending round and not a planning policy target to be applied to negotiations on individual schemes.

37 Policy 3.12 is supported by paragraph 3.71, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit or other recognised appraisal methodology is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified. Paragraph 3.75 highlights the potential need for re-appraising the viability of schemes prior to implementation.

38 Greenwich Council’s draft Core Strategy (policy H3) requires that developments of 10 or more homes and residential sites of 0.5 hectares should include at least 35% affordable housing. The exact percentage, distribution and type of affordable housing would be determined by the particular circumstances and characteristics of the site, subject to the completion of an affordable housing viability assessment.

39 In this instance, however, the legal agreement associated with the outline permission for The Warren/Royal Arsenal site, provides that 25% of the total housing provision should be affordable, and within that, one third should be allocated for social renting, one third for shared ownership and one third as key worker housing.

40 All 165 senior living units proposed in phase 4 of the approved scheme would be affordable. The provision represents 27.9% of the total proposed for the current application site, which is slightly above the requirement for the masterplan area as a whole. The affordable housing would comprise social rented and shared ownership tenures, the breakdown of which would be as follows:

1 bed (2 person) 2 bed (3 person) total shared ownership 10 41 51 (31%) social rented 47 67 114 (69%) total 57 (35%) 108 (65%) 165 (100%)

41 As the table indicates, no three-bedroom units would be provided within the scheme, but the ratio of social rented to intermediate accommodation exceeds the London Plan target of 60:40.

42 It is pertinent to note, however, that in cumulative terms, the proposals for 592 residential units in phase 4 would bring combined total of units approved and proposed within the masterplan boundary to 1,587; of which 494 units (300 in phase 1; 29 in phase 3 and the 165 proposed in phase 4) or 31.1% are or would be affordable housing. It is evident, therefore, that the delivery of affordable housing is, so far, well on track to meet or exceed the 25% provision agreed in the outline.

Children’s play space

43 Policy 3.6 of the London Plan sets out that “development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site.

44 The outline application excludes any details of the housing mix for the majority (72%) of residential units proposed within the scheme, which poses significant difficulty in calculating the potential child yield for the development. On the other hand, the one and two-bedroom units, for

page 7 which a detailed application has been submitted, is specifically intended for senior residents and therefore, unlikely to accommodate families with children.

45 These constraints notwithstanding, the applicant’s design and access statement provides details of children’s play strategy comprising doorstep and neighbourhood play areas integrated into a play-friendly residential environment, rather than secluded or fenced off to form ‘play ghettoes’. The provision would include water features, open space, facilities for children to play and places for children’s carers to sit and supervise. In addition, all the residential units would benefit from private balconies.

46 Four landscaped courtyards, approximately 3,051 sq.m. in size, would be provided on a podium between the proposed private residential towers and above the ground floor commercial units, for the exclusive use of occupiers of the development, however, the landscaping details of these are reserved for future consideration. The senior living units would also include private landscaped and roof gardens, totalling 581sq.m.

47 Within the public realm, Station Square would provide 2,256 sq.m. of high quality hard and soft landscaping, including water features, to define the Crossrail Station and offer a positive environment for leisure and relaxation. These external spaces would complement and be connected to other spaces within the Royal Arsenal boundary and Woolwich town centre, by well-defined pedestrian routes.

48 Nonetheless, prior to any further referral of this case back to the Mayor, the applicant should provide an indicative mix for the 427 open market units, to enable calculation of the potential child yield of the development and a subsequent assessment of the children’s play provision against the strategic benchmark. Retail space/town centre issues

49 The application site is within the Woolwich town centre boundary, albeit, some 115 metres outside the nearest core and secondary shopping frontages. It is, therefore, a genuine out-of- centre site, wherein the national guidance in PPS6 supports the development of new retail space of an appropriate scale.

50 Whilst the revision proposes a 40% increase in the quantum of retail and non-residential space over the consented scheme for this site, the proposed 4,688 sq.m. would bring the total amount of class A1-A5 space approved for the Royal Arsenal to 7,317 sq.m. This is still significantly short (by approximately 1,482 sq.m.) of the total 8,799 sq.m of class A space for which outline permission has already been granted.

51 A retail impact assessment was submitted in support of the original outline application. It concluded, in respect of the potential impact on Woolwich town centre, that ”the development will not have an adverse impact on the vitality and viability of Woolwich Town Centre. On the contrary, due to the application site’s location within the defined town centre, and the introduction of a new population with significant expenditure available to be spent within it, the proposal will contribute positively to the vitality and viability of the centre.”

52 This conclusion was accepted by Greenwich Council in its decision to grant outline permission for the Royal Arsenal masterplan. The proposed increase in class A space in relation to phase 4, remains entirely within the consented limit.

53 The Council’s officers propose to impose a planning condition requiring a separate approval in writing if any of the proposed shops exceed a specified size (500 sq.m.), to avoid over-provision of non-shopping uses within class A.

page 8 Urban design

54 Good design is central to all objectives of the London Plan, in particular the objective to create a city of diverse, strong, secure and accessible neighbourhoods to which Londoners feel attached whatever their origin, background, age or status. Policies contained within chapter seven specifically look to promote development that reinforces or enhances the character, legibility, permeability and accessibility of neighbourhoods by setting out a series of overarching principles and specific design policies related to site layout, scale, height and massing, internal layout and visual impact.

55 The proposed development is reasonably well designed, maximising the potential of the site, responding will to its surrounding context and adding to the public realm network in the area. The following comments and observations refer to specific aspects of the proposal that need further consideration or are particularly welcomed.

Layout

56 The proposed changes in layout from the existing approval result in a reduction in the permeability of the site. However this reduced permeability is not a concern as the proposed size of the larger block is not too large in size, and the route that has been removed did not link to any other important routes in the area.

57 There is, however, concern about the quality of the route between the station and the main block of development. A significant section of this route is flanked by the inactive rear of the Crossrail station, undermining overlooking and activity along it. The applicant and Cross rail should reconsider whether such a large and blank expanse on the southside of the station square is necessary and Crossrail in particular are urged to review this aspect of the station design. The location of the residential core adjacent to the station block and the two retail units opposite are likely to provide enough overlooking and activity on to this route to make it feel safe and well used and are critical to its success. However, it is important that the retail units have entrances directly from this route as well as on Plumstead Road and Arsenal Lane to help bring activity on to it and improve its quality.

58 There is also concern over the quality of Arsenal Lane. Whilst locating entrances to cores along it will contribute towards activating the space, there are significant sections of the development that create a blank elevation at pedestrian level. This is a concern as it undermines opportunities for pedestrian activity and overlooking on to it, making it feel like a service route which is unsafe and underused. Consideration needs to be given to reducing the amount of frontage taken up by these uses.

Height, scale and massing

59 London Plan (2011) policy 7.7, which relates to the specific design issues associated with tall and large-scale buildings, are of particular relevance to the proposed scheme. This policy sets out specific additional design requirements for tall and large-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.

60 As outlined in the pre-application note, the concept of a tall building in this location has been accepted in principle, as part of the masterplan outline approval. Nonetheless, and with regard to the revised massing, a views assessment in relation to protection of townscape and heritage features has been requested, and is still required.

page 9 61 A tall building in this location has the potential to provide a visual marker for the proposed Crossrail station from within the town centre, and for passengers emerging from the DLR and mainline stations at Woolwich Arsenal. Any recognisable design features within the building, to help intending passengers link the building with the location of the stations, and improve the overall legibility of the town centre will be welcomed.

62 However, as noted at the pre-application meeting, the Mayor is concerned that applications for tall buildings submitted in outline format may not meet his aspirations for high quality development. GLA officers recommend that the guidance within the CABE/EH Guidance for tall buildings document is followed in the first instance. The Mayor would need to be satisfied that the tall buildings component would be of sufficient detail to enable him to determine that a sufficient design quality would be obtained. A detailed design code and development specification is expected. To date the applicant has provided indicative details of the plans, sections and elevations of the towers and visualisations of the towers in key views have been requested. The overall indicative design quality is acceptable, although the applicant should look to varying the design of the westernmost tower as set out in paragraph 69

Residential design standards

63 The London Housing Design Guide (LHDG) sets out a number of aspirations that would ensure the design and layout of residential developments will be of the highest quality both in their internal design and the impact they will have on the surrounding area.

64 London Plan policy 3.5 sets out requirements for the quality and design of housing developments including minimum space standards for new development. All units in the proposed scheme need to meet these standards.

65 As previously highlighted, there appears to be a high number of single-aspect residential units in the proposal. A breakdown of single-aspect and double-aspect housing would be welcomed. Further consideration should therefore be given to the design of these new homes. Of particular concern is the occurrence of single-aspect, north-facing housing within the extra care housing facility and the relative isolation of the facility from street level.

66 This is accompanied by a long corridor at podium level, which is contrary to the advice in the London Housing Design Guide. Although it is appreciated that there are operational requirements that have led to this design, the applicant should investigate alternatives such as bringing some of the communal facilities down to ground floor level, creating the connectivity required for staff at ground floor or mezzanine level and reducing the number of homes accessed off each core at podium level.

67 Extra care schemes should be permeable to the wider community and careful design can help to create a community hub providing active participation and engagement between the residents and the local community e.g. a healthy living cafe, which would help to tackle the social exclusion and isolation that older people can experience. Connecting some of the communal facilities to the adjacent streets would help to promote active ageing and independence, whereby older people can lead active and fulfilling lives and feel part of the community and reduce the level of inactive frontage on Arsenal Lane.

68 The reorientation of the Crossrail station entrance from the street frontage to Dial Arch Square reduces its potential visibility from Plumstead Road and the town centre. The incorporation of signage or other legibility opportunities within the front facade, to ensure that the location of the station is obvious and memorable, would be welcomed.

page 10 69 The use of masonry as the primary building material, reflecting the historic use of brick in the area, is supported. However, given the scale of the proposal, and the light colours proposed, the quality of the brick and detailing will be crucial in ensuring its success. Within the initial sketches, the constant use of a singular typology can appear overpowering. The architect’s suggestion of a different treatment on the westernmost tower could offer a partial solution to this, as well as the issues of views impact and station legibility already discussed within this report.

Equalities

70 The 2010 Equality Act places a duty on public bodies, including the GLA, in the exercise of their functions, to have due regard to the need to advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it. This requirement includes removing or minimising disadvantages suffered by persons who share a relevant protected characteristic that are connected to that characteristic and taking steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it. The Act defines protected characteristics and includes age and disability. The GLA in the discharge of its planning function must engage this duty, in so far as it is applicable to a particular case.

71 In this instance, 28% of the residential accommodation would be designed and allocated for senior living. Condition 13 of the outline permission for the development of The Warren/Royal Arsenal, provides that all dwellings on the site should be built to Lifetime Homes standards; that 10% of the affordable (i.e. ‘extra care’) accommodation should be built to full wheelchair accessible standards, whilst 10% of the homes for open market sale should be easily adaptable to wheelchair standards with minimal structural change. Transport for London’s comments

72 A total of 263 car parking spaces are being proposed on site, which equates to a ratio of 0.44 spaces per unit. While this is in accordance with London Plan standards, it is noted that this level of provision represents an increase of 49 spaces when compared to the 2011 approved masterplan for the site. TfL strongly recommends that this is reduced, to provide a level more commensurate to what was previously agreed, particularly given the highly accessible nature of the site. In line with London Plan Policy 6.13, 20% of parking spaces associated with this phase of development should be fitted with active electric vehicle charging points (EVCP), with an additional 20% of spaces having passive provision.

73 The quantum of proposed development appears to have increased slightly from what was previously agreed, with the effect that the proposed Crossrail station entrance would now be set back from its western boundary, whereas it was originally intended that they would aligned with one another. In order to ensure that the development will be capable of properly accommodating the future Crossrail station entrance, the applicant should demonstrate that they have considered the two in relation to one another, and how they would both operate in terms of urban design and community safety. In particular, it needs to be demonstrated that no blind corners would be created in the vicinity of the eventual station entrance, and that the approach to the station entrance would be appropriately animated. While this may be considered further as part of a future detailed application, additional information is required at this stage in order to confirm that an appropriate design can be accommodated, in accordance with London Plan policies 6.1 and 6.2.

74 Since the outline application was determined, it is now proposed for Barclays Cycle Superhighway Route 4 (CS4) to be introduced from London Bridge to Woolwich by 2015. CS4 will aim to strengthen and improve cycle linkages towards both the Thames Path cycle route, and into the Royal Arsenal at No 1 Street and Warren Lane, in order to provide better access for cyclists

page 11 living within the development. This will however require some carriageway, footway and cycle- track renewal and improvement works near to the site, for which additional funding, estimated at £150,000, will be required. Given that these improvements would directly benefit occupiers of the development, TfL would request that this sum is secured through revision of the s106 agreement, in accordance with London Plan Policy 6.9. It should be noted that while TfL made a similar request in relation to the Phase 3 proposals, only one contribution of £150,000 is required to implement the improvements identified above, and would therefore suggest that this sum is paid by whichever phase of development gets implemented first.

75 In accordance with London Plan policy 6.14, a construction logistics plan (CLP), delivery and servicing plan (DSP), and travel plan should be secured by condition for this particular phase of the scheme. The plans should be aligned with any plans secured for the site as a whole.

76 In summary, while TfL is generally satisfied that the application is in accordance with the consented masterplan for the site, it would however strongly recommend that car parking levels are reduced, EVCPs are provided, and a financial contribution is secured towards improving cycle links through the site, as further detailed above. In addition, further information is required on the interface between this scheme and the proposed Crossrail station. Community Infrastructure Levy

77 In accordance with London Plan policy 8.3, the Mayor of London proposes to introduce a London-wide Community Infrastructure Levy (CIL) that will be paid by most new development in Greater London. Following consultation on both a Preliminary Draft, and then a Draft Charging Schedule, the Mayor has formally submitted the charging schedule and supporting evidence to the examiner in advance of an examination in public. Subject to the legal process, the Mayor intends to start charging on 1 April 2012. Any development that receives planning permission after that date will have to pay, including:

 Cases where a planning application was submitted before 1 April 2012, but not approved by then.  Cases where a borough makes a resolution to grant planning permission before 1 April 2012 but does not formally issue the decision notice until after that date (to allow a section 106 agreement to be signed or referral to the Secretary of State or the Mayor, for example),.

78 The Mayor is proposing to arrange boroughs into three charging bands with rates of £50/ £35/£20 per square metre of net increase in floor space respectively (see table, below). The proposed development is within the London Borough of Greenwich where the proposed Mayoral charge is £35 per square metre. More details are available via the GLA website http://london.gov.uk/ .

79 Within London both the Mayor and boroughs are able to introduce CIL charges and therefore two distinct CIL charges may be applied to development in future. At the present time, borough CIL charges for Redbridge and Wandsworth are the most advanced. The Mayor’s CIL will contribute towards the funding of Crossrail.

Mayoral CIL London boroughs Rates charging zones (£/sq. m.) Zone

page 12 1 Camden, City of London, City of Westminster, Hammersmith £50 and Fulham, Islington, Kensington and Chelsea, Richmond- upon-Thames, Wandsworth

2 Barnet, Brent, Bromley, Ealing, Greenwich, Hackney, £35 Haringey, Harrow, Hillingdon, Hounslow, Kingston upon Thames, Lambeth, Lewisham, Merton, Redbridge, Southwark, Tower Hamlets

3 Barking and Dagenham, Bexley, Croydon, Enfield, Havering, £20 Newham, Sutton, Waltham Forest

Climate change

80 Chapter 5 of the London Plan sets out the approach to climate change and requires developments to make the fullest contribution to minimizing carbon dioxide emissions. The policies 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. Energy

Be Lean Energy efficiency standards

81 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 low specific fan power and energy efficient lighting. The demand for cooling will be minimised through the use of solar control glazing and thermal mass.

82 The development is estimated to achieve a reduction of 5 tonnes per annum (0.7%) in regulated CO2 emissions compared to a 2010 Building Regulations compliant development.

Be Clean

District heating

83 The Royal Arsenal development is served by a site heat network supplied from an existing central energy centre built in the early stages of construction. The applicant proposes that the development connects to the existing site heat network, with domestic hot water and space heating demands of the dwellings and non-domestic building met from this source. This is supported. A drawing showing the route of the heat network linking all buildings on the development should be provided.

Combined heat and power

84 The applicant is proposing that the installed gas fired CHP capacity in the existing Royal Arsenal Riverside energy centre is increased by 290kWth to provide approximately 75% of the total

page 13 heat demand of the development. A reduction in regulated CO2 emissions of 317 tonnes per annum is envisaged through this second part of the energy hierarchy.

Be Green

Renewable energy technologies

85 The applicant has investigated the feasibility of a range of renewable energy technologies but is not proposing to install any renewable energy technology for the development.

Overall carbon savings

86 The estimated regulated carbon emissions of the development are 362 tonnes of CO2 per year after the cumulative effect of energy efficiency measures and CHP has been taken into account. This equates to a reduction of 322 tonnes of CO2 per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 47%.

87 The carbon dioxide savings exceed the targets set within Policy 5.2 of the London Plan. Local planning authority’s position

88 Council officers propose to report this application to the Planning Board on 20 December 2011 with a recommendation for approval. Legal considerations

89 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

90 There are no financial considerations at this stage. Conclusion

91 London Plan policies on housing, children’s play space, retail/town centre, the mix of uses, urban design, transport, equalities and energy are relevant to this application. In general, the application complies with these policies but not with others, for the following reasons:  Housing: The applicant should provide an indicative unit mix breakdown for the 427 units for which outline permission is sought.

page 14  Children’s play space: Inadequate details are provided in the outline application to allow calculation of the child yield of the residential scheme or subsequent assessment of the provision of play space against the strategic benchmark. (see comments above).

 Design: The application proposals for tall buildings are submitted in outline form. The applicant should provide additional visualisations of the towers from key views. The applicant should also review the design and external appearance of the Crossrail Station.

 Transport: TfL considers that the car parking levels are excessive; provision has not been made for electric vehicle charging points and that there is a need to improve cycle links through the site detailed in this report.

92 Whilst the application is broadly acceptable in strategic planning terms, on balance, the application does not fully comply with the London Plan.

93 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Housing: Provide an indicative breakdown of unit mix.

 Children’s play space: The applicant should provide an indicative mix of the private residential accommodation proposed within the development to enable proper assessment of the children’s play space, prior to any further referral of this case back to the Mayor.

 Design: The applicant should provide additional illustrative information in respect of tall buildings and should review the station square elevation of the Crossrail station.

 Transport: TfL recommends a reduction in car parking provision; the installation of electric vehicle charging points within the development and a financial contribution towards the improvement cycle links through the site as indicated in paragraphs 72-76 of this report.

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] David Blankson-Hemans, Senior Strategic Planner, Case Officer 020 7983 4268 email [email protected]

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