17/00311/Ful & 17/00312/Lb

17/00311/FUL & 17/00312/LB

ADDRESS: County Hall Riverside Building Westminster Bridge Road London SE1 7PB Application Number: 17/00311/FUL Case Officer: Mitchell Deaves Ward: Bishops Date Received: 31.01.2017 Proposal: Change of use of part third floor to offices, co-working offices and managed business and meeting space (Use Class B1a), together with the installation of new extract vents/grilles to north east and south elevation, plant machinery at roof level, and other associated internal modifications. Drawing numbers: P01; P02; P03; P03 01; P03 02; P03 03; P04; P04 01; P04 02; P04 03; P05; P05 01; P05 02; P05 03; P06; P07-01; P07-02; P07-03; P07-04; P07-05 Rev. A; P08-01; P08-02; P08-03; P08-04; P08-05; P11; P12; P13; 300 Rev. C; Unnumbered drawing – bike store location plan Documents: Planning Statement prepared by Savills, Design and Access Statement prepared by Synergy Architects; Heritage Statement prepared by Synergy Architects; Transport Statement prepared by Mayer Brown; Energy and Sustainability Statement prepared by Hodkinson Consultancy RECOMMENDATION:

1. Resolve to grant conditional planning permission subject to the satisfactory completion of a Section 106 Agreement.

2. Agree to delegate authority of the Director of Planning and Development to:

- Finalise the recommended conditions; and - Negotiate, agree and finalise the recommended planning obligations pursuant to Section 106 of the Town and Country Planning Act 1990.

3. Delegate authority to the Assistant Director of Planning and Development to refuse planning permission in the event that the Section 106 Agreement is not completed on the grounds that the development would have an unacceptable impact on local labour in construction.

4. In the event that the committee resolves to refuse planning permission and there is a subsequent appeal, delegated authority is given to Officers, having regard to the heads of terms set out in the report, to negotiate and complete a Section 106 Agreement in order to meet the requirements of the Planning Inspector.

Associated Application: Listed Building Consent Application Number: 17/00312/LB Proposal: Installation of new extract vents/grilles to north east and south elevation, plant machinery at roof level, and other associated internal modifications, in association with the proposed change of use of the third floor to offices, co-working offices and managed business and meeting space (Use Class B1a), as proposed under planning application reference 17/00311/FUL. Drawing numbers: P01; P02; P03; P03 01; P03 02; P03 03; P04; P04 01; P04 02; P04 03; P05; P05 01; P05 02; P05 03; P06; P07-01; P07-02; P07-03; P07-04; P07-05 Rev. A; P08-01; P08-02; P08-03; P08-04; P08-05; P11; P12; P13; 300 Rev. C; Unnumbered drawing – bike store location plan Documents: Planning Statement prepared by Savills, Design and Access Statement prepared by Synergy Architects; Heritage Statement prepared by Synergy Architects; Transport Statement prepared by Mayer Brown; Energy and Sustainability Statement prepared by Hodkinson Consultancy RECOMMENDATION:

1. Resolve to grant conditional listed building consent.

2. Agree to delegate authority of the Director of Planning and Development to finalise the recommended conditions.

Applicant: Agent: etc. Venues Savills 33 Margaret Street London W1G 0JD

SITE DESIGNATIONS

Relevant site designations: Type of designation Applicable designation Listed Building Grade II* Conservation Area (CA) South Bank (CA38) Opportunity Area Waterloo Central Activities Zone (CAZ) Archaeological Priority Area North Lambeth

LAND USE DETAILS

Site area 2.13 hectares

Use Class Use Description Floorspace (Gross Internal Area) Existing Sui Generis Government Office 2,779m2 Proposed Class D1 Office 2,779m2

EXECUTIVE SUMMARY

The application is for the change of use of part of the third floor of the south wing of County Hall to offices, co-working offices and managed business and meeting space (Use Class B1a), together with the installation of new extract vents/grilles, plant machinery at roof level, and other associated internal modifications.

The proposed change of use would result in the reinstatement of 2,779m2 disused floorspace, which is highly constrained given its vast size, heritage designation and level of refurbishment required. The scheme would deliver an additional 50 employees as well as ongoing employment turnover by way of the co-working and meeting floorspace, within the Central Activities Zone.

Less than substantial harm would be caused to the significance of the listed building and the works would secure the long term use of these currently vacant and unusable spaces. The site would benefit from a full and comprehensive program of repairs, restoration and upgrading of services bringing these spaces back into use.

The proposed development would not impact unacceptably on the neighbouring properties and the local transport system. Furthermore, the scheme would provide employment and training benefits for local people during the construction phase of the development and in the end use of the site. Officers consider that the development would be in compliance with the Development Plan for the borough. Officers are therefore recommending approval of the scheme, subject to conditions and completion of a Section 106 Agreement.

PLANNING OFFICER’S REPORT

Reason for referral to PAC: The application/s are reported to the Planning Applications Committee in accordance with (1)(ii) of the Committee’s terms of reference as they relate to a major application for the change of use of more than 1,000sqm of floorspace.

1 SITE AND SURROUNDINGS

1.1 The application site is part of the wider County Hall complex, a Grade II* listed building within the South Bank Conservation Area (CA38). The application relates specifically to part of the third floor of the south wing, which is accessed via the main entrance on Belvedere Road. The gross internal floor area measures approximately 2,779m2.

1.2 The third floor, along with other upper floors, has remained as ‘shell and score’ since 1991, when the Greater London Council (GLC) vacated County Hall. Figure 1 below shows the existing condition of the third floor.

Figure 1: The existing condition of the third floor

1.3 County Hall as a whole is occupied by a range of uses, including the London Dungeons, the Sea Life London Aquarium, Marriot Hotel, Premier Inn, and the Shrek Experience. It is noted that the fourth floor was recently granted permission for mixed use development including office, conference, meeting, function and event space (Ref. 15/06903/FUL). The fourth floor also remained vacant subsequent to the disbandment of the GLC in 1991, however this permission has now been implemented and the floor is back in use.

1.4 The site lies within the Central Activities Zone (CAZ), and has a Public Transport Access Level (PTAL) rating of 6b, which is considered ‘excellent’. The site is also located within Environment Agency Flood Zone 3.

2 PROPOSAL

2.1 Full planning permission is sought for the change of use of part of the third floor of the south wing of County Hall to offices, co-working offices and managed business and meeting space, together with the installation of new extract vents/grilles, plant machinery at roof level, and other associated internal modifications. The above description is regarded as wholly Use Class B1a (Office), however the proposed use of the third floor would comprise two elements, discussed in further detail below. Listed building consent is sought for the installation of new extract vents/grilles to north east and south elevation, plant machinery at roof level, and other associated internal modifications, in association with the proposed change of use of the third floor to offices, co-working offices and managed business and meeting space.

2.2 Part of the third floor (Wing 4) would be traditional office space occupied by etc. Venues as their head office and would accommodate approximately 50 employees. The remainder of the third floor would provide co-working offices and managed business and meeting space. It would comprise a separate reception area, several smaller meeting rooms, one larger co-working office room and ancillary facilities such a toilets, coffee/lounge area and cafe. Meeting rooms would be available for use by the applicant’s (etc. Venues) head office staff or rented by companies and other organisations. The ‘co-working’ area would be used for meetings or for general office use, but the key characteristic would be that all of the space would be used wholly for Use Class B1 business purposes. Figure 2 below shows the proposed third floor arrangement (traditional office floorspace hatched in grey). Further detail can be seen on submitted drawing no. P04 ‘General Arrangement’.

Figure 2: Proposed third floor arrangement 2.3 Given the shell and core condition of this section of County Hall, a number of internal alterations are proposed in order to facilitate the proposed use of the space, mainly consisting of the insertion of internal partition walls. External alterations are also proposed including new extraction vents along the elevations and plant machinery behind the pitched roof. For the external works planning permission is sought and listed building consent is sought for both the external and internal works.

3 RELEVANT PLANNING HISTORY

3.1 There is an extensive planning history for County Hall as a whole, relating to the numerous changes of use and building alterations that have occurred over time, however much of this is not relevant to the third floor. The relevant planning history is as follows:

3.2 DC/92/1290/RGH/12459: Planning permission was granted on 05.01.1993 for the ‘Change of use from local government offices to a hotel, conference and business centre, health club, children's education centre and ancillary uses, together with alterations to the Members Courtyard and the construction of lift shafts’.

3.3 12/01350/FUL: Planning permission was granted on 23.10.2012 for the ‘Internal refurbishment and restoration at 4th floor level with the installation of a new opening in the structural core, the inclusion of an AC plant on the 7th floor and the installation of a comms condenser to existing roof’. It isn’t clear whether this permission was implemented, but this would have now lapsed.

3.4 15/06903/FUL: Planning permission was granted on 29.04.2016 for the ’Change of use of the fourth floor from office (B1) to dual use as office (B1) and/or a conference, meeting room, function and events use with ancillary facilities (D1), involving the demolition of internal walls and the widening of doorways including the insertion of new internal walls, replacement of panes from existing inner lightwell elevations windows with extract grilles, installation of a flue to service the kitchen area and the installation of new plant machinery on roof’. Whilst attending a site visit on 23.02.2017 it was confirmed that this permission has since been implemented.

3.5 15/06904/LB: Listed building consent was granted on 29.04.2016 for ‘Demolition of internal walls and the widening of doorways including the insertion of new internal walls, replacement of panes from existing inner lightwell elevations windows with extract grilles, installation of a flue to service the kitchen area and the installation of new plant machinery on roof, in association with the proposed change of use of the fourth floor from office (B1) to dual use as office (B1) and/or a conference, meeting room, function and events use with ancillary facilities (D1), as proposed under planning application reference 15/06903/FUL’. Whilst attending a site visit on 23.02.2017 it was confirmed that this permission has since been implemented.

3.6 16/06419/LDCP: Application for a certificate of lawfulness (proposed) with respect to the use of part of the third floor for class B1 purposes. The application was withdrawn on 19.01.2017.

4 CONSULATIONS

4.1 Historic England Advised that the Local Planning Authority are authorised to determine the application for listed building consent as it thinks fit. However, concerns were expressed with regards to the proposal to remove four fire surrounds and to place them in storage. It was noted that the fireplaces are a feature contributing to the building’s significance, and that removing an original internal feature to storage brings with it a risk of it being lost and never reused or reinstated. It was recommended that the fireplaces are retained and covered, with adequate ventilation.

4.2 Environmental Agency

It was noted that no Flood Risk Assessment was submitted, and the site is located in Flood Zone 3 which is defined as having a ‘high probability’ of river and sea flooding by the ‘Flood risk and coastal change’ section of the National Planning Practice Guidance (PPG). However, given the nature of the application and being located at 3rd floor it was considered that it would unlikely alter the vulnerability classification from ‘less vulnerable’ in line with the ‘flood risk and coastal change’ section of the National PPG. Therefore, despite a Flood Risk Assessment not being provided the Environment Agency did not object to the application. This is further discussed in section 6.6 of the report.

4.3 Lambeth Design & Conservation

Advised that the proposed works have been justified as necessary and appropriate to delivering a beneficial scheme for the listed building. Adequate justification has been provided demonstrating the works are likely to preserve the significance of the heritage asset, subject to conditions. This is further discussed in section 6.2 of the report.

4.4 Lambeth Transport

The council’s transport planning officer advised that the site has excellent access to public transport with a PTAL of 6b and is located within controlled parking zone Waterloo ‘W’, which is in operation from Monday to Friday between 08.30am to 06.30pm and on Saturdays from 08.30am to 01.00pm. In accordance with these times parking within the parking bays is restricted to residents. As such there is less likely to be any traffic congestion resulting from the staff and visitor cars during these times. However, to further mitigate the demand of private car use the council’s transport planning officer suggests that there should be access to membership of a car club on a commercial basis.

It was also advised that the applicant has submitted a transport statement including details of trip analysis, a delivery and servicing plan and a construction management plan for the proposed works. All details are considered acceptable and should be subject to conditions ensuring the development is carried out in accordance with the details.

Concerns were initially raised with the proposed cycle parking details. This is further discussed in section 6.4 of the report.

4.5 Bioregional sustainability consultants

The council’s sustainability consultants (Bioregional) advised that the submitted energy and sustainability statement demonstrates the proposal would deliver acceptable and appropriate development, subject to conditions. This is further discussed in section 6.5 of the report.

4.6 Public consultation A total of 21 letters were distributed to neighbouring owners/occupiers, a site notice was displayed from 15.02.2017 to 08.03.2017 and a notice was published in the local newspaper (Lambeth Weekender) on 15.02.2017.

No public representations were received in response to the consultation.

5 POLICIES

5.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise.

5.2 The development plan in Lambeth is the London Plan (2015) and the Lambeth Local Plan (2015).

5.3 The National Planning Policy Framework was published in 2012. This document sets out the Government’s planning policies for England including the presumption in favour of sustainable development and is a material consideration in the determination of all applications.

5.4 The current planning application has been considered against all relevant national, regional and local planning policies as well as any relevant guidance. Set out below are those policies most relevant to the application, however, consideration is made against the development plan as a whole.

5.5 The London Plan (2015) Policy 2.10: Central Activities Zone – Strategic Priorities Policy 2.11: Central Activities Zone – Strategic Functions Policy 2.13: Opportunity Areas and Intensification Areas Policy 4.1: Developing London’s Economy Policy 4.2: Offices Policy 4.5: London’s Visitor Infrastructure Policy 6.3: Assessing Effects of Development on Transport Capacity Policy 6.9: Cycling Policy 6.13: Parking Policy 7.8: Heritage Assets and Archaeology Policy 8.2: Planning Obligations Policy 8.3: Community Infrastructure Levy

5.6 Lambeth Local Plan (2015) Policy D4: Planning Obligations Policy ED2: Business, Industrial and Storage Uses outside KIBAs (Key Industrial Business Areas) Policy ED3: Large Offices (Greater than 1,000sqm) Policy ED6: Town Centres Policy ED14: Employment and Training Policy T1: Sustainable Travel Policy T3: Cycling Policy T6: Assessing Impacts of Development on Transport Capacity Policy T7: Parking Policy T8: Servicing Policy EN4: Sustainable Design and Construction Policy EN5: Flood Risk Policy Q2: Amenity Policy Q11: Building Alterations and Extensions Policy Q13: Cycle Storage Policy Q20: Statutory Listed Buildings Policy Q22: Conservation Areas Policy PN1: Waterloo

5.7 Supplementary Planning Documents Building Alterations and Extensions (2015) Section 106 (draft, 2013)

6 ASSESSMENT

6.1 Land Use

The application site comprises part of the third floor of the south wing of County Hall, which was vacated in 1991 following the disbandment of the GLC. The last known use was the functioning of the GLC as ‘government offices’. Review of the Land Use Gazetteer (3rd edition) confirms ‘Government Office, containing committee rooms etc.’ and ‘Town Hall’ as Use Class sui generis. For this reason, assessment is required as to the acceptability of the change of use of the third floor to Use Class B1.

Policy 2.10 of the London Plan has regard to the Central Activities Zone (CAZ), of which this site forms part. The policy states that the Mayor will ensure that development of office provision is not strategically constrained and that provision is made for a range of occupiers. Further, Policy 2.11 aims to seek solutions to constraints on office provision imposed by heritage designations without compromising local environmental quality, including through high quality design to complement these designations. This scheme would deliver office provision within a Grade II* listed building. Further assessment of design and conservation considerations is included in part 6.2 below.

Policy 4.2 of the London Plan seeks to increase the current stock of offices where there is authoritative, strategic and local evidence of sustained demand for office based activities. In response to this, Local Plan Policy ED3 has specific regard to large offices (greater than 1,000m2) and states that proposals for offices greater than 1,000m2 will be supported in the Central Activities Zone.

From a land use perspective the proposed use of vacant floorspace within one of the borough’s most significant buildings is strongly supported. The proposed change of use to facilitate 2,779m2 of additional Class B1a office space would result in the reinstatement of the disused floorspace. The scheme would deliver an additional 50 employees within the borough, as well as ongoing additional employment turnover by way of the co-working and meeting floorspace which is supported within the CAZ. The mix of traditional office floorspace along with the ‘co-working’ and serviced office arrangement (both of which are Class B1a) would add to existing activities within the CAZ. The proposed use of the long-term vacant floor area as Class B1a floor space is supported within the local development framework, particularly policies 2.10 and 4.2 of the London Plan and policy ED3 of the Lambeth Local Plan. For these reasons the principle of the change of use is supported.

6.2 Design and Conservation

Legislative framework and national policy considerations

This section sets out the legislative and national policy context for the officer assessment of the impact of the development proposal on the historic environment and its heritage assets.

Legislative framework

The following legal commentary is provided.

Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 (“PLBCAA”) provides that in considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.

Section 72(1) PLBCAA provides that in the exercise, with respect to any buildings or other land in a conservation area, of any functions under or by virtue of (amongst others) the planning Acts, special attention shall be paid to the desirability of preserving or enhancing the character or appearance of the conservation area.

The South Lakeland District Council v Secretary of State for the Environment case and the Barnwell Manor case (East Northamptonshire DC v SSCLG) establish that “preserving” in both s.66 and s.72 means “doing no harm’.

National Policy

Paragraph 17 of the NPPF sets out 12 “core planning principles” that should underpin both plan-making and decision-taking. Those principles include the following:

“Planning should always seek to secure high quality design and should conserve heritage assets in a manner appropriate to their significance so that they can be enjoyed for their contribution to the quality of life of this and future generations”.

The NPPF defines a “heritage asset” as:

“A building, monument, site place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest”.

The definition includes both designated heritage assets (of which, a Listed Building and a Conservation Area are relevant here) and assets identified by the Local Planning Authority (including local listing).

“Significance” is defined within the NPPF as being:

“the value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic. Significance derives from a heritage asset’s physical presence, but also from its setting”.

Paragraph 129 of the NPPF requires local planning authorities to identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting its setting), taking account of the available evidence and any necessary expertise. That assessment should then be taken into account when considering the impact of the proposal on the heritage asset, to avoid or minimise conflict between the heritage asset’s conservation and any aspect of the proposal.

Paragraphs 131 and 132 of the NPPF provide as follows:

‘131. In determining planning applications, local planning authorities should take account of: - the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; - the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and - the desirability of new development making a positive contribution to local character and distinctiveness.’

‘132. When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional…’

Paragraph 133 of the NPPF deals with substantial harm to, or total loss of significance, of a designated heritage asset. Paragraph 134 of the NPPF provides that where a development proposal will lead to less than substantial harm to the significance of the designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.

Officers also have regard to the accompanying Planning Practice Guidance to the NPPF in respect of conserving and enhancing the historic environment.

Approach required

Turning to consider the application of the legislative and policy requirements set out above, the first step is for the decision-maker to consider each of the designated heritage assets (referred to hereafter simply as “heritage assets”) which would be affected by the proposed development in turn and assess whether the proposed development would result in any harm to the heritage asset.

The decision of the Court of Appeal in Barnwell Manor confirms that the assessment of the degree of harm to the heritage asset is a matter for the planning judgement of the decision-maker. However, where the decision-maker concludes that there would be some harm to the heritage asset, in deciding whether that harm would be outweighed by the advantages of the proposed development the decision-maker is not free to give the harm such weight as the decision-maker thinks appropriate. Rather, Barnwell Manor establishes that a finding of harm to a heritage asset is a consideration to which the decision-maker must give considerable importance and weight in carrying out the balancing exercise.

There is therefore a “strong presumption” against granting planning permission or listed building consent for development which would harm a heritage asset. In the Forge Field case the High Court explained that the presumption is a statutory one. It is not irrebuttable. It can be outweighed by material considerations powerful enough to do so. But a Local Planning Authority can only properly strike the balance between harm to a heritage asset on the one hand and planning benefits on the other if it is conscious of the statutory presumption in favour of preservation and if it demonstrably applies that presumption to the proposal it is considering.

The case-law also establishes that even where the harm identified is less than substantial (i.e. falls within paragraph 134 of the NPPF), that harm must still be given considerable importance and weight.

Where more than one heritage asset would be harmed by the proposed development, the decision-maker also needs to ensure that when the balancing exercise is undertaken, the cumulative effect of those several harms to individual assets is properly considered. The decision-maker might for example conclude that there are adverse impacts on heritage features which individually and cumulatively result in less than substantial harm. However, less than substantial harm does not mean insignificant harm. Considerable importance and weight must be attached to each of the harms identified and to their cumulative effect.

What follows is an officer assessment of the extent of harm which would result from the proposed development to the scoped heritage assets provided by the applicant as part of its submission. This addresses the impact of the development on the South Bank Conservation Area and the Grade II* listed County Hall. Both an individual assessment against each heritage asset as well a cumulative assessment is provided. This is then followed by an assessment of the heritage benefits of the proposals.

In reaching their assessment, officers have taken into account the Conservation and Design Officer’s comments who has carried out an assessment of the significance required by paragraph 129 of the NPPF.

Heritage asset: South Bank Conservation Area (SBCA)

The Council’s Conservation and Design Officer has considered the impact of the development on the character and appearance of the South Bank Conservation Area. Given that the application proposes mostly internal alterations and discretely positioned external alterations facing internal to the site, it is considered that the proposed development would not harm and would preserve the character and appearance of the South Bank Conservation Area, in accordance with Policy Q22 of the Lambeth Local Plan. Therefore there is no need to assess the public benefits of the scheme against any harm to the South Bank Conservation Area.

Heritage asset: Grade II* listed building – County Hall

County Hall is located on Belvedere Road and fronts onto the River Thames. It was built between 1911 and 1933 and was designed by Ralph Knott. The building received its Grade II* listing in October 1951. The listing description reads as follows:

‘Long symmetrical main west elevation to river. Five storeys of Portland stone ashlar with a steep mansard roof with dark tiles and 2 tiers of dormers. Rusticated ground floor and end pavilions. Deep concave central section in segmental curve of 19 bays, windows framed in giant Ionic order. Attic stage above has round windows alternating with carved escutcheons. Varying classical window treatments. Dramatic emphasis provided by tall niches, at salient points, holding heroic size sculptured figures. Other elevations similar, but eastern (entrance) front simpler. South front has members' entrance though tall arch to high vaulted passage leading to inner courtyard.’

Exterior of the building:

Regarding the proposed extract grilles to the top corner panes of many of the third floor windows, the Conservation and Design Officer notes that all of the proposed alterations are to windows on the more informal internal courtyards/lightwells. This is considered acceptable in principle as these works would be reversible and due to their discreet and informal locations, would not harm the special historic interest of the listed building.

New air-conditioning equipment is proposed to the roof of County Hall. The air handling units and condensers would be discretely located on the flat roofed areas and would only be visible from the upper floor windows to the main internal courtyard area of the south wing of County Hall, or from visitors on the London Eye. As such these are considered acceptable and would not harm the special architectural or historic interest of the listed building, in accordance with Policy Q20 of the Lambeth Local Plan.

Interior of the building:

The Council’s Conservation and Design Officer has noted that the third floor is currently in a very poor condition, having been left vacant for almost 30 years. The site is a difficult space to utilise due to its vast size, and the refurbishment and its occupation by a compatible use is welcomed. It should be noted that during the site visit for this application, officers visited the fourth floor to view the works carried as part of previously approved development (Ref. 15/06904/LB), also completed by the applicants etc. Venues. The quality of the workmanship was regarded as exceptional; the space had been transformed and every last detail had been carried out sympathetically to the fabric and historic character of the building. In light of the above and having viewed the documents for this scheme, the conservation and design officer considers that the proposed works are likely to preserve the significance of the heritage asset.

In response to the concerns raised by Historic England, council’s conservation and design officer notes that two fireplaces would need to be removed and placed in the storage room of County Hall to facilitate the part change in floor levels. Whilst it is noted the removal of the original fireplaces does pose risks for a feature contributing to the significance of the heritage asset, the proposed removal has been considered in context to delivering the wider benefits of the scheme including increased employment etc. In accordance with Paragraph 134 of the NPPF the proposal would lead to less than substantial harm to the significance of the designated heritage asset, and this harm is weighed against the public benefits of the proposal, including securing its optimum viable use. In light of the submitted documents and drawings, conservation officer advice and a site visit to observe examples of recent work, it is considered the proposed scheme is based on a full understanding of the significance of the listed building. Less than substantial harm would be caused to the significance of the listed building and the works would secure the long term use of these currently vacant and unusable spaces. The site would benefit from a full and comprehensive program of repairs, restoration and upgrading of services bringing these spaces back into use.

The Council’s Conservation and Design Officer has considered the heritage assets individually and collectively and assessed the impact of the development, advising that less than substantial harm would result. Officers concur with these findings. ‘Case law has established that even where the harm is less than substantial that harm must be given considerable weight and importance. Having given considerable weight to the removal of the fireplaces officers consider that the identified harm would be outweighed by the public benefits derived from the development. As such the proposed development is considered acceptable in conservation and design terms. To ensure the special interests of the heritage asset and wider conservation area are protected it is recommended conditions are imposed on any approval. The conditions should ensure materials to match the existing adjacent work, historic flooring to be retained in situ, as well as pre-commencement details regarding the removal and storage of the fireplaces and the location and screening of plant equipment located at roof level.

6.3 Amenity

Noise

The only external alterations of particular note in terms of their potential impact on amenity is the new servicing equipment located at roof level and the possible noise impacts. It is considered that all new servicing equipment would be located a sufficient distance from residential windows, with the nearest residential windows located approximately 40 metres away, across Belvedere Road in the West Block of County Hall. As such the proposed development would have an acceptable impact on amenity. Officers recommend that a standard condition is added, requiring the noise levels from the air-conditioning equipment to be below a standard set level when measured from the nearest residential window. The condition should require noise from any mechanical equipment or building services plant to not exceed the background noise level L90B (A) 15 minutes, when measured outside the window of the nearest noise sensitive or residential premises.

6.4 Transport

Car Parking

Policies contained within the London Plan and the Lambeth Local Plan seek to restrict developments’ access to parking permits within Controlled Parking Zones where alternative modes of transport are available and where public transport accessibility is high. The application site has excellent access to public transport given its Central London location. Car parking is provided to the front of County Hall along Belvedere Road, which is a private road and in the same ownership as that of County Hall itself. Due to the excellent public transport accessibility that the site benefits from the proposed development would not generate a significant level of car parking and given the existing car parking provided along Belvedere Road, it is unlikely that parking permits for the CPZ or membership to a car club would be required as such. Therefore in this instance and following comments received from the Council’s Transportation Officer, it is not deemed necessary to restrict the proposed development as permit-free nor ensure membership to a car club is agreed.

Cycling

The submitted transport statement details that given the nature of the proposal being located at third floor of County Hall, there is no opportunity for dedicated cycle facilities. Instead, the transport statement identifies the location and provision of several public cycle parking stands as well as Santander Cycle Hire bays. The council’s transport planning officer has considered the proposal and originally advised that the lack of cycle parking would not be acceptable given the large amount of additional office floorspace proposed. However, following negotiations with the applicant it is proposed to use the existing cycle parking facility within the sub-basement of County Hall. The landlord of County Hall has confirmed that 10 spaces would be made available solely for the users of the proposed third floor use.

Section 6.9 of the London Plan details the minimum standards for cycle parking provision. Table 6.3 states a minimum of 1 space per 90m2 of B1 floorspace. The proposed development would result in the creation of 2,779m2 of floorspace, meaning a minimum provision of approximately 30 cycle spaces would be required to ensure policy compliance. However, as previously noted not all of the B1 floorspace would be for ‘traditional’ office use. Drawing PO4 ‘General Arrangements’ indicates that approximately 510m2 of floorspace would be used as the head office for etc. Venues, which results in the need to provision 5 cycle spaces. An additional 5 spaces would be available for the remainder of the floor. The remaining floorspace would be used for co-working and managed business and meeting space on an ongoing short to medium term basis. The applicants note that workers would not be familiar with the cycle parking arrangements at the site and would not have security access to the subbasement level of County Hall, meaning the take up of spaces would be far less than what policy requires. Furthermore, the applicant has stated that an additional 10 spaces is the maximum amount available within the subbasement level. Anything beyond this amount would require additional provision within other levels of County Hall and would result in further interference to the listed building. On balance, the council’s transport planning officer considers this justification acceptable and the proposed provision 10 spaces would be adequate for the development. Officers agree with this recommendation as the 10 dedicated cycle spaces would be available in conjunction with the existing public cycle parking stands and Santander Cycle Hire bays located close to the site. As such, the provision would be acceptable to meet the demands of the proposed development, in accordance with section 6.9 of the London Plan and policies T3 and T6 of the Lambeth Local Plan.

The location of the cycle storage facility proposed is considered acceptable in principle, however given it would be located in the subbasement, further details will be required in relation to how visitors would be directed to the cycle store. This information can be secured by way of a condition.

Servicing/Deliveries/Refuse and Recycling County Hall is currently serviced via the servicing yard located within County Hall and accessed via Belvedere Road at the junction with Chicheley Street. It is proposed that the deliveries and servicing arrangements including refuse and recycling management, will be accommodated within the existing servicing management system, where deliveries need to be booked at least 24 hours in advance. Following comments received from the council’s transport planning officer, the proposed servicing arrangements are considered acceptable subject to a condition requiring full compliance with the submitted Transport Statement.

Construction Management

It is proposed to install a hoist along Belvedere Road in order to provide a quick and accessible route in which construction equipment can enter the site.

Figure 3: Proposed hoist for the construction phase

Whilst the hoardings and associated skip will block a small section of Belvedere Road, it has been successfully demonstrated that this would not block the safe operation of the road as a 10 tonne vehicle can successfully pass the hoist and associated hoardings, and the pedestrian footway will not be impeded. The council’s transport planning officer has confirmed that the proposed construction management is acceptable subject to a condition requiring full compliance with the submitted Transport Statement.

6.5 Sustainability

Policy EN4 of the Lambeth Local Plan states that all major non-residential refurbishment of existing buildings and conversions over 500sqm floorspace should meet at least BREEAM Non-Domestic Refurbishment ‘Excellent’ unless it is demonstrated that it is not technically feasible or viable to do so, in which case proposals should demonstrate a ‘Very Good’ rating with a minimum score of 63%.

Given the constraints of the building which has a grade II* listing, the applicant has stated that it would only be possible to achieve BREEAM Non-Domestic Refurbishment rating of ‘Very Good’ with a score of 60.49% which fails to meet the requirements of policy EN4 of the Lambeth Local Plan. However, following comments from the Council’s Sustainability Consultants (Bioregional), it is considered reasonable that a BREEAM score of 63% would not be feasible for this development given that the host building is grade II * listed. However, conditions have been requested by Bioregional to ensure that the minimum score of 60.49% at pre- estimation stage will be achieved.

6.6 Flooding

County Hall is located within the Flood Zone 3, which has a high probability of river flooding. Policy EN5 of the Lambeth Local Plan states that the Council will seek to minimise the impact of flooding in the Borough through permitting appropriate development in such areas. The policy also requires a Flood Risk Assessment to be provided, which has not been submitted by the applicant. However, the application site is located at third floor level and is not a highly sensitive use (compared with residential per se); therefore the proposed development would unlikely alter the vulnerability classification from ‘less vulnerable’ (in line with the ‘flood risk and coastal change’ section of the National PPG) to flooding. As such the application is acceptable in this respect.

6.7 Employment and Training

Policy ED14 of the Lambeth Local Plan seeks to use planning obligations that secure employment opportunities and apprenticeships both during the construction phase of major developments and post-construction, so that local residents are given access to the right skills training so that they can take advantage of opportunities created by new development.

As part of a section 106 agreement, the Council will require the applicant to commit to such obligations and as part of this the Council will require a completed ‘Employment and Skills Plan’ and ‘Worksmart’ document, setting out how the development will aim to achieve the targets set within the section 106 agreement. A financial contribution will also be required towards Local Labour in Construction.

6.8 Planning Obligations and CIL

Policy D4 of the Local Plan refers to circumstances in which the Council can seek S106 Planning Obligations to mitigate the impact of development on the local infrastructure or secure additional facilities that are required as a result of the development coming forward. The Council developed a draft S106 Planning Obligations Supplementary Planning Document (SPD) in 2013. Together with the obligations stated in section 6.7, the proposed development will require a contribution of £3,750 towards Local Labour in Construction together with a monitoring fee of £500. The applicant has agreed to make these contributions, which will form part of the s106.

The contribution of £3,750 towards Local Labour in Construction was calculated on the basis of an estimated capital construction cost of £1,500,000.00. The draft S106 SPD states that a standard charge for training will be made of £2,500.00 per £1 million of capital construction costs and the contribution has been calculated on this basis and using the Council’s S106 toolkit which is available on the Council’s website. The contribution will be used by the Council towards the recruitment, initial training and ongoing skills development and sustained employment for local construction trainees. This contribution will be due prior to the commencement of the development to ensure that it is used in association with the construction phase.

The section 106 agreement will also require the applicant to submit an Employment and Skills Plan and Worksmart document outlining the approach that the applicant will take to delivering target employment, apprenticeship outcomes and engagement with schools and education providers both throughout the construction phase and in post- construction phase regarding employment opportunities for local people within the proposed conference facility. The applicant has begun discussions with Lambeth Working regarding this.

If the application is approved and the development is implemented, a liability to pay the Lambeth and Mayoral Community Infrastructure Levy (CIL) may arise. The Council’s CIL Team will confirm with the applicant whether a CIL payment will be required following the granting of planning permission.

Allocation of CIL monies to particular infrastructure projects is not a matter for consideration in the determination of planning applications. Separate governance arrangements are being put in place for borough infrastructure needs, and locally through the Cooperative Local Investment Plan initiative.

7 CONCLUSION

7.1 Assessment concludes that the proposed change of use would result a positive outcome, complying with the relevant policies of the local development framework. The third floor of County Hall, a grade II* listed building, would be brought back into use; providing an employment generating use where there has been zero employment since 1991; and providing a use which would supplement existing activities in an easily accessible and strategic Central London location. Further, the proposed external and internal alterations to the listed building are considered acceptable subject to conditions and would preserve the special interest of the heritage asset and wider conservation area.

7.2 For the abovementioned reasons the proposal is supported by officers and is recommended for approval, subject to conditions and a section 106 agreement, as discussed within the report.

8 RECOMMENDATIONS

8.1 Full Planning Permission – Ref. 17/00311/FUL

1. Resolve to grant planning permission, subject to the satisfactory completion of a section 106 agreement and conditions.

2. Agree to delegate authority of the Director of Planning and Development to:

a. Finalise the recommended conditions; and b. Negotiate, agree and finalise the recommended planning obligations pursuant to Section 106 of the Town and Country Planning Act 1990.

4. In the event that the committee resolves to refuse planning permission and there is a subsequent appeal, delegated authority is given to Officers, having regard to the heads of terms set out in the report, to negotiate and complete the Section 106 Agreement in order to meet the requirements of the Planning Inspector.

8.2 Listed Building Consent – Ref. 17/00312/LB

1. Resolve to grant listed building consent, subject to conditions.

2. Agree to delegate authority of the Director of Planning and Development to finalise the recommended conditions.

Recommendation A: Planning Permission Conditions and Informatives

Conditions

1 Time limit The development to which this permission relates must be begun not later than the expiration of three years beginning from the date of this decision notice.

Reason: To comply with the provisions of Section 91(1)(a) of the Town and Country Planning Act 1990 (as amended by Section 51 of the Planning and Compulsory Purchase Act 2004).

2 Approved Plans The development hereby permitted shall be carried out in accordance with the approved plans listed in this notice.

Reason: For the avoidance of doubt and in the interests of proper planning.

3 Noise - Plant Noise from any mechanical equipment or building services plant shall not exceed the background noise level L90B(A) 15 minutes, when measured outside the window of the nearest noise sensitive or residential premises.

Reason: To protect the amenities of adjoining occupiers and the surrounding area (policy Q2 of the London Borough of Lambeth Local Plan (2015)).

4 Construction Management The development hereby approved shall be carried out in full accordance with the Construction Management measures set out in the Transport Statement (Mayer Brown, January 2017).

Reason: To avoid hazard and obstruction being caused to users of the public highway and to safeguard residential amenity, in accordance with policies Q2 (Amenity), T8 (Servicing) and EN4 (Sustainable design and construction) of the Lambeth Local Plan (2015).

5 Servicing The development hereby approved shall be serviced in full accordance with the Servicing measures set out in the Transport Statement (Mayer Brown, January 2017).

6 Sustainability and BREEAM The development shall be implemented in accordance with the approved Energy & Sustainability Statement (Hodkinson, January 2017) and within 6 weeks of work starting on site a full Design Stage calculations under the National Calculation Method shall be submitted to and approved in writing by the Local planning Authority to show that the development will be constructed in accordance with the approved Sustainability Statement.

Reason: To ensure that the development is of a sustainable design and construction in accordance with Policy EN4 (Sustainable design and construction) of the Lambeth Local Plan (2015).

7 Sustainability and BREEAM Within three months of work starting on site a BREEAM Refurbishment and Fit-out 2014 (or such equivalent standard that replaces this) Design Stage certificate and summary score sheet must be submitted to and approved in writing by the Local Planning Authority to show that a Very Good (minimum score 60) rating will be achieved and all mandatory BREEAM Excellent credits will be achieved excluding WST 03.

Reason: To ensure that the development is of a sustainable design and construction in accordance with Policy EN4 (Sustainable design and construction) of the Lambeth Local Plan (2015).

8 Sustainability and BREEAM Within 6 weeks of first occupation of the building(s) a BREEAM Refurbishment and Fit- out 2014 (or such equivalent standard that replaces this) Post Construction Review certificate and summary score sheet must be submitted to and approved in writing by the Local Planning Authority to show that a Very Good (minimum score 60) rating has been achieved and all mandatory BREEAM Excellent credits have been achieved excluding WST 03. All the measures integrated shall be retained for as long as the development is in existence.

Reason: To ensure that the development is of a sustainable design and construction in accordance with Policy EN4 (Sustainable design and construction) of the Lambeth Local Plan (2015).

9 Sustainability and BREEAM Prior to first occupation of the building(s) evidence (e.g. photographs, installation contracts and as-built certificates under the National Calculation Method) should be submitted to the Local Planning Authority and approved in writing to show that the development has been constructed in accordance with approved Sustainability Statement.

Reason: To ensure that the development is of a sustainable design and construction in accordance with Policy EN4 (Sustainable design and construction) of the Lambeth Local Plan (2015).

10 Materials All new external works and finishes and works of making good to the retained fabric, shall match the existing adjacent work with regard to the methods used and to material, colour, texture and profile, unless shown otherwise on the drawings or other documentation hereby approved.

Reason: To ensure that the external appearance of the building is satisfactory, that it preserves and enhances the character and appearance of the conservation area and protects the setting and interest of the listed buildings. In accordance with policies Q8 (Design quality: construction detailing), Q11 (Building alterations and extensions), Q20 (Statutory listed buildings) and Q22 (Conservation Areas) of the Lambeth Local Plan (2015).

11 Plant Equipment Notwithstanding the approved drawings, the proposed plant equipment shall be adequately set back from the front of the roof and screened as not to be visible from all other windows within this courtyard area. Full details shall be submitted and approved by the Local Planning Authority prior to the commencement of the relevant works. The development shall thereafter be constructed in accordance with the approved details and shall be retained as such for the duration of the use hereby approved.

Reason: To ensure that the development preserves and enhances the character and appearance of the conservation area and protects the historic interest and character of the listed building. In accordance with policies Q8 (Design quality: construction detailing), Q11 (Building alterations and extensions), Q20 (Statutory listed buildings) and Q22 (Conservation areas) of the Lambeth Local Plan (2015).

12 Cycle Parking Notwithstanding the approved Transport Statement (Mayer Brown, January 2017), storage for a minimum of 10 bicycles shall be provided within the subbasement area shown on the approved plans prior to the first use of the development hereby permitted and shall thereafter be retained solely for its designated use. Furthermore, prior to the first use of the development hereby permitted, the following information shall be submitted to the Local Planning Authority and approved in writing:

(a) detailed drawings of the cycle storage together with detailed drawings of its location and access arrangements; and (b) information on how workers/visitors associated with the development will locate and access the cycle store.

The development shall thereafter be constructed in accordance with the approved details and shall be retained as such for the duration of the use hereby approved.

Reason: To ensure adequate cycle parking is available on site and to promote sustainable modes of transport (Policies T1, T3 and Q13 of the London Borough of Lambeth Local Plan (2015)).

Informatives

1. This decision letter does not convey an approval or consent which may be required under any enactment, by-law, order or regulation, other than Section 57 of the Town and Country Planning Act 1990.

2. Your attention is drawn to the provisions of the Building Regulations, and related legislation which must be complied with to the satisfaction of the Council's Building Control Officer.

3. Your attention is drawn to the need to comply with the requirements of the Control of Pollution Act 1974 concerning construction site noise and in this respect you are advised to contact the Council's Environmental Health Division, who should also be contacted with regard to the extraction of fumes from the premises.

4. Your attention is drawn to Sections 4 and 7 of the Chronically Sick and Disabled Persons Act 1970 and the Code of Practice for Access for the Disabled to Buildings (B.S. 5810:1979) regarding the provision of means of access, parking facilities and sanitary conveniences for the needs of persons visiting, using or employed at the building or premises who are disabled.

5. You are advised of the necessity to consult the Council’s Highways team prior to the commencement of construction on 020 7926 9000 in order to obtain necessary approvals and licences prior to undertaking any works within the Public Highway including Scaffolding, Temporary/Permanent Crossovers, Oversailing/Undersailing of the Highway, Drainage/Sewer Connections, Hoarding, Excavations (including adjacent to the highway such as basements, etc), Temporary Full/Part Road Closures, Craneage Licences etc.

Recommendation B: Listed Building Consent Conditions

Conditions

1 Time Limit The development to which this permission relates must be begun not later than the expiration of three years beginning from the date of this decision notice.

Reason: To comply with the requirements of Section 18(1) (a) of the Planning (Listed Buildings and Conservation Areas) Act 1990.

2 Approved Plans The development hereby permitted shall be carried out in accordance with the approved plans listed in this notice.

Reason: For the avoidance of doubt and in the interests of proper planning.

3 Materials All new external and internal works and finishes and works of making good to the retained fabric, shall match the existing adjacent work with regard to the methods used and to material, colour, texture and profile, unless shown otherwise on the drawings or other documentation hereby approved.

Reason: To ensure that the external appearance of the building is satisfactory, that it preserves and enhances the character and appearance of the conservation area and protects the setting and interest of the listed buildings. In accordance with policies, Q20 (Statutory listed buildings) and Q22 (Conservation Areas) of the Lambeth Local Plan (2015).

4 Historic Flooring Notwithstanding the approved drawings, no permission is granted for the removal of any historic parquet flooring and these shall be retained in situ. Any new parquet flooring shall exactly match the historic parquet flooring in terms of size and material.

Reason: To ensure that the development protects the historic interest and character of the listed building. In accordance with policy Q20 (Statutory listed buildings) of the Lambeth Local Plan (2015).

5 Fireplaces Notwithstanding the approved drawings, full details on the method of removal and storage of the fireplaces shall be submitted and approved by the Local Planning Authority prior to the commencement of the relevant works. The works shall thereafter be completed in accordance with the approved details and maintained for the duration of the use hereby approved.

6 Plant Equipment Notwithstanding the approved drawings, the proposed plant equipment shall be adequately set back from the front of the roof and screened as not to be visible from all other windows within this courtyard area. Full details shall be submitted and approved by the Local Planning Authority prior to the commencement of the relevant works. The development shall thereafter be constructed in accordance with the approved details and shall be retained as such for the duration of the use hereby approved.

Reason: To ensure that the development preserves and enhances the character and appearance of the conservation area and protects the historic interest and character of the listed building. In accordance with policies, Q20 (Statutory listed buildings) and Q22 (Conservation areas) of the Lambeth Local Plan (2015).