52-54 Lime Street & 21-26 Leadenhall, 27 & 27A

Home , Leadenhall Street, Lime Street (ward), St Mary Axe, Willis Building (London)

planning report PDU/3015/02 30 January 2013 52-54 Lime Street & 21-26 Leadenhall, 27 & 27A Leadenhall Street and 34-35 Leadenhall Street and 4-5 Billiter Street in the City of London planning application no. 12/00870/FULEIA

Strategic planning application stage II 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 Demolition of existing buildings and redevelopment with a 39-storey (190 metre) office-led mixed use development The applicant The applicant is W.R. Berkley Corporation and the architect is Kohn Pedersen Fox

Strategic issues The provision of new high quality office floorspace in the heart of the City of London is strongly supported.

Strategic issues relating to tall buildings, views and World Heritage Sites, urban and inclusive design, climate change and transport have been satisfactorily resolved.

The Corporation’s decision

In this instance the Corporation of London has resolved to grant permission. Recommendation That the Corporation of London be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal or direct that he is to be the local planning authority.

Context

1 On 1 October 2012 the Mayor of London received documents from the Corporation of London notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Category 1C of the Schedule to the Order 2008:

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

page 1 following descriptions—

(b) the building is more than 150 metres high and is in the City of London

2 On 7 November 2012 the Mayor considered planning report PDU/3015/01, and subsequently advised the Corporation of London that. the application did not comply with the London Plan, for the reasons set out in paragraph 60 of the above-mentioned report; but that the possible remedies set out in that paragraph of that report could address these deficiencies.

3 A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report. On 15 January 2013 the Corporation of London decided that it was minded to grant planning permission and on 18 January 2013 it advised the Mayor of this decision. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged, direct the Corporation of London under Article 6 to refuse the application or issue a direction to the Corporation of London under Article 7 that he is to act as the Local Planning Authority for the purposes of determining the application. The Mayor has until 31 January 2013 to notify the Corporation of his decision and to issue any direction.

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 has been taken into account in the consideration of this case.

5 The decision on this case, and the reasons will be made available on the GLA’s website www.london.gov.uk.

Update

6 At the consultation stage the Corporation of London was advised that the application did not comply with the London Plan, for the reasons set out in paragraph 60 of the above-mentioned report; but that the possible remedies set out in that paragraph of that report could address these deficiencies:

 World Heritage Sites and listed buildings: In order to ensure compliance with London Plan policy 7.10, the applicant should provide an explicit assessment of the impact of the proposal on the WHS, clearly linked to its Outstanding Universal Value, integrity, authenticity and significance.

 Inclusive design: the entrance and lift arrangements require further explanation in order to ensure compliance with London Plan policy 7.2.

 Climate change: further information is required before the carbon savings can be verified. The shortfall in on-site CO2 savings should be met off-site, in order to ensure compliance with London Plan policy 5.2.

 Transport: cycle and car parking provision complies with London Plan policies 6.9 and 6.13. Further information and conditions are required in order to ensure compliance with London Plan policies 6.3, 6.7, 6.14 and 8.3.

page 2 World Heritage Site

7 In response to the Mayor’s initial comments the applicant has provided a statement assessing the potential impacts of the proposed development on the Outstanding Universal Value of the Tower of London WHS, based on the methodology of the London World Heritage Sites – Guidance on Settings SPG. This concludes that the proposed development will not adversely impact on the Tower of London WHS and is compliant with the GLA’s London Plan policy 7.10.

8 English Heritage note that the City’s eastern cluster is already visible from within the Inner Ward of the Tower of London and that this development will cause an additional degree of harm by adding additional bulk and scale to the consented tower at 22-24 Bishopsgate [the Bishopsgate Tower/Pinnacle]. The City’s view, which is shared by GLA officers, is that the building would be viewed as an integral part of the compact eastern cluster, not as an incongruous isolated feature, and that this cluster is a distinctive and accepted townscape feature of the wider setting of the World heritage Site.

Inclusive design

9 The applicant has provided further information regarding the accessibility of the upper car of the double stack lift, which is acceptable. The applicant has also retained the revolving doors as main means of access, in order to maintain climate control, with separate accessible doors. This is acceptable.

Climate change

10 The applicant has clarified the output tables for projected carbon savings, as requested at stage I. The applicant has also provided details of future connection to a district heat network and this has been secured by condition. Currently the application does not deliver 25% carbon savings, required by the London Plan. The City has imposed a condition requiring incorporation of further measures to reduce carbon dioxide by at least 25% and the applicant is confident that this can be achieved. However, in line with policy 5.2 E the applicant has agreed to a payment towards carbon offsetting elsewhere, should it not prove possible to reach the 25% target. The Corporation has agreed to secure this via condition/section 106 agreement, along the following lines:

11 Condition 12 amended to add at end “in the event that a 25% reduction cannot be achieved on-site any shortfall may be provided off-site or through a cash in lieu contribution in accordance with Policy 5.2E.”

12 Section 106 agreement to include the following provisions:

"Cash in lieu contribution" means a sum calculated in accordance with the formula set out in clause [¶.1]

Substantive Obligations

[¶.1] The cash in lieu contribution shall be calculated in accordance with the formula below:

Cash in lieu contribution = (T – R) x Y x cost of shadow price of carbon at the time Where T is the target amount of CO2 (expressed in tonnes) which reflects 25% of the Development's annual CO2 emissions if constructed in accordance with Part L of the 2010 Building Regulations R is the reduction in the amount of CO2 emitted by the Development per year (expressed in tonnes) achieved by the implementation of carbon reduction measures as determined by

page 3 reference to the report submitted to the Council in discharge of condition 32 of the Planning Permission.

Y is the number of years for which contribution is payable, being 30 years.

13 This is acceptable in this instance.

Transport for London’s comments

14 At consultation stage, TfL raised concerns about the quantum of accessible parking proposed, the need to facilitate the Mayor’s Cycle Hire scheme, the condition of local bus stops, the travel plan along with the need to secure a Crossrail contribution, Delivery and Servicing Plan (DSP) and Construction and Logistics Plan (CLP).

15 The applicant has since identified that there are nine existing accessible parking bays located within 300m of this site. These are sufficient to cater for the needs of any disabled users of the development and therefore the only proposed disabled parking bay is deemed acceptable by TfL.

16 TfL understands that the provision of a new Cycle Hire docking station on site would conflict with both the proposed public realm and future pedestrian desire lines. It has also not proven feasible to expand any of the existing nearby docking stations. Nevertheless, taking into account both the cycle parking and staff facilities proposed, TfL considers that, on balance, this application conforms with London Plan policy 6.9.

17 A deficiency in bus stop facilities has been identified. However, taking into account the constrained footways, the provision of any additional passenger waiting facilities was considered unfeasible by TfL.

18 A Delivery & Servicing Plan, Construction Logistics Plan and Travel Plan have all been secured by condition. The implementation of the latter has been included within the draft section 106 Heads of Terms. These are all welcomed by TfL.

19 A Crossrail contribution is also included, however no figure has been stated. Written confirmation has nevertheless been received from the Corporation stating that the full Crossrail SPG amount of £4,774,860 will be included within the final section 106 agreement. While this is welcomed, the Corporation is reminded that any Crossrail contribution is not negotiable as subject to the SPG, and that the full figure should be definitely committed to within any draft section 106 agreement and Heads of Terms.

20 In summary, TfL considers that the above measures will mitigate the impact of this development and that, on balance, the application is now in conformity with London Plan transport policies. Response to consultation

21 In response to the site notice and neighbour consultation, one neighbouring occupier raised concern regarding views/visibility and daylight/sunlight. This issue has been addressed in the Corporation’s committee report. The Church Manager, St Helen’s Church raised concern regarding the impact of development during construction and sought confirmation that a construction management plan would be required. This has been secured by condition.

page 4 22 Design Council – consider the proposal could make a valuable addition to the City, both through its contribution to London’s skyline and to the City’s historic network of routes and spaces, but have two regrets; that the scheme does not demonstrate exemplar sustainability standards and the lack of pre-application engagement.

23 English Heritage – concludes that the proposal does not have a detrimental impact on the Mayor’s strategic views but will cause an additional degree of harm to the setting of the Tower of London World Heritage Site by adding additional bulk and scale to the City’s Eastern Cluster.

24 Natural England – issued standing advice regarding biodiversity enhancement and consideration of impact on local nature conservation sites/landscapes/species. Also highlighted need for development to complement and where possible enhance local distinctiveness of local landscapes (in the context of the Tower of London World Heritage Site and Thames Path National Trail).

25 Thames Water – requested conditions/informatives regarding surface water drainage, piling impact, non-return valves, petrol/oil receptors, trade effluent consent and water supply infrastructure. These matters have been addressed by condition/informative/section 106 agreement.

26 Environment Agency – provided standing advice with respect to flood risk. Article 7: Direction that the Mayor is to be the local planning authority

27 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance the Council has resolved to grant permission with conditions and a planning obligation, which satisfactorily addresses the matters raised at stage I, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

28 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. Financial considerations

29 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government guidance in Circular 03/2009 (‘Costs Awards in Appeals and Other Planning Proceedings’) emphasises that parties usually pay their own expenses arising from an appeal.

page 5 30 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.

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

32 The proposed development will provide a striking addition to the City’s skyline, increasing the supply of high quality office floorspace in a highly accessible location. The applicant has demonstrated that the outstanding universal value of the Tower of London World Heritage Site will not be harmed and has resolved outstanding issues relating to inclusive design, climate change and transport.

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]

page 6

planning report PDU/3015/01 7 November 2012 52-54 Lime Street & 21-26 Leadenhall, 27 & 27A Leadenhall Street and 34-35 Leadenhall Street and 4-5 Billiter Street

in the City of London planning application no. 12/00870/FULEIA

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 Demolition of existing buildings and redevelopment with a 39-storey (190 metre) office-led mixed use development.

The applicant The applicant is W.R. Berkley Corporation and the architect is Kohn Pedersen Fox

Strategic issues The provision of new high quality office floorspace in the heart of the City of London is strongly supported.

Other strategic issues for consideration include tall buildings, views and World Heritage Sites, urban and inclusive design, climate change and transport.

Recommendation That the Corporation of London be advised that while the application is generally acceptable in strategic planning terms, on balance the application does not yet comply with the London Plan. The reasons and the potential remedies set out in paragraph 60 of this report could address these deficiencies.

Context

33 On 1 October 2012, the Mayor of London received documents from the Corporation of London notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 9 November 2012 to provide the Corporation 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 7 34 The application is referable under Category 1C of the Schedule to the Order 2008:

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

(b) the building is more than 150 metres high and is in the City of London;

35 Once the Corporation of London 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.

36 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 has been taken into account in the consideration of this case.

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

38 The 0.33 hectare site is bound to the north by Leadenhall Street, to the west by Lime Street, to the east by Billiter Street and by the Willis Building at 51 Lime Street to the south. It comprises three existing buildings, each of seven storeys: 52-54 Lime Street and 21-26 Leadenhall Street (Prudential House), 27 & 27A Leadenhall Street (Allianz Cornhill House) and 34-35 Leadenhall Street and 4-5 Billiter Street (Winterthur House).

39 The site is surrounded by a number of existing tall buildings forming the ‘Eastern Cluster’ of the City of London, including the Lloyd’s Building (88 metres), the Willis Building (125 metres),

page 8 30 St Mary Axe (the ‘Gherkin’, 180 metres) and 122 Leadenhall Street (the ‘Cheesegrater’, 225 metres, under construction).

40 There are a number of listed buildings in the vicinity of the site. The grade I listed Lloyd’s Building is located to the immediate west and the grade I listed St Andrew Undershaft Church is to the immediate north. The grade II listed 20-21 Billiter Street, 37-39 Lime Street and 147, 148 and 139-144 Leadenhall Street are also nearby.

41 The nearest section of the Transport for London Road Network (TLRN) is the A10 Gracechurch Street, 220m to the west of the site. The neighbouring Leadenhall Street is the nearest section of the Strategic Road Network (SRN).

42 The site is well served by buses with a total of 27 bus routes available within 640m of the site; equivalent to an 8 minute walk. The nearest bus stops are located on Leadenhall Street, 80m away to the west of the site, served by 5 bus routes (25, 242, 388, 26 and 8).

43 There are eight London Underground lines accessible within 960 metres walking distance of the site (Central, Northern, Circle, Hammersmith & City, Metropolitan, District and the Waterloo & City). The nearest station is Aldgate (Metropolitan, Circle and Hammersmith & City), located approximately 400 metres away to the north east; equivalent to a five minute walk.

44 In addition, there are three Network Rail stations providing suburban and national rail services accessible within 880 metres and an eleven minute walk of the site (Cannon Street , Liverpool Street and Fenchurch street). From 2019, Crossrail services will also be available from Liverpool Street station. The site has been estimated to have an excellent public transport accessibility level (PTAL) of 6b, on a scale of 1-6 where 6 is most accessible.

45 This location is also served by the Mayor’s Cycle Hire Scheme. Two docking stations are located within 300 metres of the site (three minute walk), at St Mary Axe and Jewry Street.

Details of the proposal

46 Full planning permission is sought for an office-led mixed use development comprising a single tall building with a maximum height of 190 metres above ground (39 storeys). The proposed mix of uses is as follows:

Use Floorspace (square metres GEA) Office (B1) 54,613

Retail (A1 & A3) 1,072

Plant & storage 3,584

Total 59,269

Table 1: proposed mix of uses

Case history

47 A pre-planning application meeting was held on 21 August 2012.

page 9 Strategic planning issues and relevant policies and guidance

48 The relevant issues and corresponding policies are as follows:

 World city role London Plan  Mix of uses London Plan  Urban design London Plan;  Tall buildings/views London Plan, Revised View Management Framework SPG  Historic Environment London Plan; World Heritage Sites SPG; Circular 07/09  Transport London Plan; the Mayor’s Transport Strategy;  Crossrail London Plan; Mayoral Community Infrastructure Levy; Crossrail SPG  Parking London Plan; the Mayor’s Transport Strategy  Access London Plan; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Climate change London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy

49 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 City of London Core Strategy 2011, the saved policies of the City of London Unitary Development Plan 2002 and the 2011 London Plan.

50 The following are also relevant material considerations:  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework  The City of London Development Management Development Plan Document (Issues and Options, July 2011)  The draft Revised Early Minor Alteration to the London Plan

Principle of development

51 London Plan policies 2.10, 2.11 and 4.2 are relevant to consideration of the application. Policies 2.10 and 2.11 define the strategic priorities and functions of the central activities zone, which include sustaining and enhancing the City of London as a strategically important, globally- oriented financial and business services centre. Development proposals to increase office floorspace within CAZ should provide for a mix of uses including housing, unless such a mix would demonstrably conflict with other policies in the plan. Policy 4.2 provides the strategic policy direction for office provision including the need to meet the distinct needs of the London office market and encourage the renewal and modernisation of the existing office stock.

52 The application will result in a significant increase in office floorspace in the heart of the City of London. The provision of new, high quality office space in this location will support the strategic priorities and functions of the central activities zone as set out in London Plan policies 2.10 and 2.11. The provision of housing on this site would conflict with those strategic priorities and functions and would not be appropriate. The application is also consistent with the objectives of London Plan policies 4.2 and 4.3 and in land use terms is strongly supported.

page 10 Tall buildings, views and heritage

53 London Plan 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. Policies 7.10, 7.11 and 7.12, which set out the Mayor’s approach to protecting World Heritage Sites and the management of designated views, are also important considerations.

Tall buildings

54 The application site is within the Eastern Cluster of the City of London, which is an established location for tall buildings. The principle of a tall building on this site is consistent with London Plan policy 7.7.

Strategic views

55 The proposed development is not located within any strategic viewing corridors and is not within the St Paul’s Heights policy area. It will, however, be visible in a number of London Panoramas and River Prospect views identified in the London View Management Framework (LVMF). In the panoramic views from Alexandra Palace (1A.1), Parliament Hill (2A.1), Kenwood (3A.1), Primrose Hill (LVMF 4A.1), Greenwich Park (5A.2) and Blackheath Point (6A.1), it will read as part of the existing cluster of tall buildings. In all of these views, the ability to recognise and appreciate the strategically important landmarks of St Paul’s Cathedral and the Palace of Westminster is maintained.

56 In the river prospect views from Thames side at Tate Modern (13B.1), Waterloo Bridge (15B), the South Bank (16B.2) and Hungerford Bridge (17B), the proposed development would appear as a new object on the skyline, clearly forming part of the existing cluster of tall buildings. Its profile is angled towards the centre of the cluster. The separation between St Paul’s Cathedral and the cluster is maintained. From London Bridge: downstream (11B.2), the majority of the proposal will be concealed by 20 Fenchurch Street, currently under construction, and there will be no adverse impact on the setting of the Tower of London World Heritage Site.

57 From the Tower Bridge viewing plaque, the proposed development will appear to the immediate right of the Willis Building. In the proposed view, it appears to be the tallest building in the cluster. In the cumulative view, the Pinnacle is the tallest building, followed by the ‘Cheesegrater.’ In both cases, the proposed development contributes to the consolidation of the cluster of tall buildings and the setting of the Tower of London World Heritage Site is unharmed.

58 The assessment of views is comprehensive and the proposal complies with London Plan policies 7.11 and 7.12.

World Heritage Sites and listed buildings

59 The proposed development is in the setting of the Tower of London World Heritage Site (WHS). As part of the Townscape, Heritage and Visual Impact Assessment, the applicant has assessed views from within the WHS and those in which both the buildings in the WHS and the proposal will be visible. An animation of the proposal’s appearance from within the Inner Ward of the Tower of London has also been provided. Based on the information provided, officers are of the view that the proposal is unlikely to cause adverse impacts on the WHS or its setting. However, in order to ensure compliance with London Plan policy 7.10, the applicant should provide a statement explicitly assessing the impact of the proposal on the WHS, clearly linked to its

page 11 Outstanding Universal Value, integrity, authenticity and significance. The assessment methodology is set out in the London’s World Heritage Sites – Guidance on Settings SPG, available at http://www.london.gov.uk/publication/world-heritage-sites-spg.

60 The proposed development affects the setting of a number of listed buildings, including the grade I listed Lloyd’s building and St Andrew Undershaft Church. The setting of the Lloyd’s building will be improved by the creation of the new public space and the sloping profile of the proposal will reveal more of its form than is currently visible in views along Leadenhall Street. The setting of the Church will also be improved by virtue of the juxtaposition with the proposal. The simple glazed facade of the new building will allow a greater appreciation of the Church’s form and masonry detailing when viewed from the north. This is considered an improvement on the existing situation and is welcomed. The application complies with London Plan policy 7.8.

Urban design

61 The proposal has been designed to respond to its immediate and wider context and to complement existing and proposed tall buildings in the eastern cluster. Its angular, sloping profile is a direct response to the existing and emerging composition of the cluster. It will reinforce and help to balance the profile of the cluster. Overall, the form and massing of the building is appropriate to its context and the proposal is of a very high architectural quality, consistent with London Plan policies 7.4, 7.6 and 7.7.

62 The ground floor arrangement provides for a new public space adjacent to Lime Street, a double height office entrance lobby, new retail frontage onto Leadenhall Street and the new public space, widening of the pedestrian route connecting Billiter Street and Lime Street and consolidation of servicing access from Billiter Street. The new public square will offer an improved setting for the Lloyd’s and Willis buildings and will complete the network of routes and spaces in the block bounded by Leadenhall Street, Billiter Street, Fenchurch Avenue and Lime Street. The combination of lobby at retail spaces at ground level will provide a high proportion of active frontage, including opportunities for activity at the weekend. In this regard the proposal complies with London Plan policies 7.1, 7.3 and 7.5.

63 The design and access statement seeks to demonstrate that inclusive design principles have been incorporated in the scheme design and how inclusion will be managed and maintained. Whilst the majority of the building spaces and services will be fully accessible for all users, the provision of bi-parting doors to the office entrances would be preferred over revolving doors, which require separate power assisted doors for wheelchair users and are not inclusive. Furthermore, the double deck lift arrangements described in section 8.2.4 of the design and access statement require further explanation in respect of wheelchair access to the upper floors in order to ensure compliance with London Plan policy 7.2.

64 Overall, the proposal is well considered and appropriate to its context. It will provide an attractive new building, make a positive contribution to London’s skyline, consolidate and enhance an existing tall building cluster, increase and enhance the public realm, and complies with London Plan design policies.

page 12 Climate change

Climate change mitigation

Energy strategy

65 The applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole. The proposals are broadly acceptable; however, further information is required before the carbon savings can be verified.

Energy efficiency

66 A range of passive design features and demand reduction measures are proposed to reduce the CO2 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 an automatic lighting control system and heat recovery from office extract systems. The demand for cooling will be minimised through solar control glazing.

67 The development is estimated to achieve a reduction of 190 tonnes per annum (20%) in regulated CO2 emissions compared to a 2010 Building Regulations compliant development, as shown in table 1.

68 However, the applicant should provide further evidence of these projected savings, as the BRUKL output extract included in the energy strategy references a building of 1,039 sq.m., which does not appear to relate to the proposed development.

District heating

69 The applicant has identified that the City of London ‘CitiGen’ district heat network is within the vicinity of the proposed development. The network is, however, currently over a mile away so is not currently viable for connection. However, it is noted that planning has commenced on a proposed extension which would bring the network within closer proximity to the site. The applicant should therefore provide a firm commitment to ‘future proofing’ for connection and this should be secured by condition or in the section 106 agreement.

70 To this end the applicant should provide details of correspondence with the network provider outlining potential for connection and timescales where available.

71 Details of the location and size of energy centre at the proposed development (showing space for heat exchangers etc. to allow future connection) should be provided.

72 The applicant should confirm that a building heat network will be installed and that all building uses (offices and retail) will be connected to the network.

Combined heat and power (CHP)

73 The applicant has investigated the feasibility of CHP. However, due the nature of the heat load, CHP is not proposed. This is accepted in this instance.

Renewable energy technologies

74 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 200 sq.m. of solar photovoltaic (PV) panels on the roof of the building.

page 13 75 A reduction in regulated CO2 emissions of at least 11 tonnes per annum (1%) will be achieved through this third element of the energy hierarchy (see table 1 below).

Total residual Regulated CO2 emissions regulated CO2 reductions emissions (tonnes per (tonnes per (per annum) annum) cent) Baseline i.e. 2010 Building 932 Regulations Energy Efficiency 742 190 20 CHP 742 - - Renewable energy 731 11 1 Total 211 21

Table 2: CO2 emission reductions from application of the energy hierarchy

76 A reduction of 211 tonnes of CO2 per year in regulated emissions compared to a 2010 Building Regulations compliant development is expected, equivalent to an overall saving of 21%.

77 The on-site CO2 savings fall short of the targets within Policy 5.2 of the London Plan. Whilst it is accepted that there is little further potential for CO2 reductions on site, in liaison with the City Corporation, the applicant should ensure the short fall in CO2 reductions, equivalent to approximately 28 tonnes of CO2 per annum, is met off-site.

Climate change adaptation

78 The applicant has submitted a sustainability statement, which demonstrates how the scheme responds to London Plan climate change adaptation policies and includes relevant BREEAM pre-assessments demonstrating that the scheme can meet the ‘very good’ standard. A number of measures are proposed to reduce carbon dioxide emission and make the most efficient use of natural resources. Specific measures include an automatic lighting control system, high efficiency water fittings, implementation of a sustainable urban drainage system and use of materials from FSC sources. Sufficient information has been provided to demonstrate compliance with the London Plan.

Transport

Car parking

79 The development is proposed to be car free, with the exception of one disabled parking space located within the servicing area. However, TfL questions whether this level of blue badge provision is sufficient considering the scale of development. In recognition of the space constraints affecting the servicing area, appropriate on-street blue badge parking provision that can serve the site should be identified.

Cycle parking

80 A total of 363 cycle parking spaces are proposed within the basement to serve the office land use. This is equivalent to one space per 150 sq.m. of office space. In addition, six visitor spaces are proposed within the new public realm area to the south east of the site. Furthermore, to cater for the retail employees each unit is proposed to include one internal cycle parking space. TfL considers this provision compliant with the London Plan standards and policy 6.9. It is also

page 14 welcomed that all staff employed on site will have access to shower and changing facilities. TfL would welcome further discussion with the applicant and the Corporation on this matter.

Cycle hire

81 Taking into consideration the demand for the Cycle Hire scheme in the area and given that it will directly benefit the scheme, mitigation measures towards the future phase of intensification and extension of the scheme will be sought. Therefore, in line with London Plan policy 6.9, safeguarding of land to facilitate a future docking station is required.

Buses

82 In line with London Plan policy 6.7, and to promote inclusive access for all users of the proposed development, the applicant should undertake an assessment of the two nearby bus stops located on Leadenhall Street and identify a schedule of works required to improve them, if proven necessary. Upon receipt of the audit, a capped contribution of up to £10,000 per bus stop maybe requested to ensure full compliance with accessibility guidelines.

Travel planning

83 A framework workplace travel plan has been submitted, which is welcomed. However, this has been reviewed in accordance with the ATTrBuTE assessment tool and regrettably has failed. The content must therefore be improved before it can be deemed acceptable. TfL is satisfied, however, that this can be undertaken at the implementation stage. It is expected that the Corporation will secure, enforce, monitor, review and ensure the funding of the travel plan through the section 106 agreement to ensure conformity with London Plan policy 6.3.

Freight, servicing and construction

84 It is proposed that servicing for all land uses within the proposed development be undertaken from a dedicated ground floor loading bay accessed from Billeter Street. TfL has reviewed the provided swept path analysis and considers these arrangements to be satisfactory. However, a delivery and servicing plan (DSP) and construction and logistics plan (CLP) should both be secured by condition to ensure full compliance with London Plan policy 6.14.

Community Infrastructure Levy

85 In accordance with London Plan policy 8.3, Community Infrastructure Levy, the Mayor agreed to commence CIL charging for developments permitted on or after 1 April 2012. It is noted that the proposed development is within the City of London, where the Mayoral charge is £50 per square metre Gross Internal Area (GIA). The levy will raise £300 million towards the delivery of Crossrail. Further details can be found at: http://www.london.gov.uk/publication/mayoral- community-infrastructure-levy.

Crossrail

86 The mechanism for contributions to be made payable towards Crossrail is set out in the Mayor’s Supplementary Planning Guidance (SPG) ‘Use of planning obligations in the funding of Crossrail’ (July 2010) and the London Plan. The SPG states that contributions should be sought in respect of uplift in floorspace for B1 office, hotel and retail uses (with an uplift of at least 500 sq.m.). The site is within the Central London charging zone. In order to enable TfL officers to calculate the required contribution, the applicant should set out the existing and proposed GIA floorspace for the aforementioned chargeable land uses.

page 15 87 The applicant should note, however, that the Mayor’s CIL charge will be treated as a credit towards the section 106 liability and therefore only the greater of the two sums will be sought. Notwithstanding this, City Corporation should include the full Crossrail sum within the section 106 agreement.

Summary

88 TfL has no objection to the proposed development in principle. However, before the application can be considered to be in conformity with the London Plan the following is required. The applicant will need to undertake an audit of local bus stops. In addition, a DSP and CLP will need to be secured by condition with the Travel Plan and Crossrail contribution secured by section 106 agreement. Further discussion is also required how the proposals will facilitate the Cycle Hire scheme. Local planning authority’s position

89 The application is likely to be considered by the City Corporation’s planning and transportation committee in January 2013. At the time of writing this report, the City Corporation’s formal position on the scheme is unknown. Legal considerations

90 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

91 There are no financial considerations at this stage. Conclusion

92 London Plan policies on offices, tall buildings, views and heritage, urban and inclusive design, climate change and transport are relevant to this application. The application complies with some of these policies but not with others and on balance does not yet fully comply with the London Plan; the reasons and the potential remedies to issues of non-compliance are set out below:  Offices: The principle of office-led mixed use development in this location complies with London Plan policies 2.10, 2.11, 4.2 and 4.3 and is strongly supported.  Tall buildings: The principle of a tall building on this site is consistent with London Plan policy 7.7; the scheme is of a high design quality that will make a positive addition to London’s skyline.

page 16  Strategic views: The impact of the proposal on strategic views has been assessed in accordance with the London View Management Framework. The application complies with London Plan policies 7.11 and 7.12.

 Urban design: The proposed development is of a high architectural quality, will increase and enhance the public realm, and complies with London Plan policies 7.1, 7.3, 7.4, 7.5, 7.6 and 7.7.

 Inclusive design: the entrance and lift arrangements require further explanation in order to ensure compliance with London Plan policy 7.2.

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] Claire O’Brien, Senior Strategic Planner 020 7983 4269 email claire.o’[email protected]

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