planning report D&P/4156/01 19 July 2017 74-78 Long Lane, Borough in the London Borough of Southwark planning application no. 17/AP/2122
Strategic planning application stage 1 referral Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008.
The proposal Demolition of the existing building and the erection of a mixed-use 15 storey building comprising up to 172 co-living units (sui generis) with shared amenity space and ancillary residential facilities, co-working office space (Class B1) with ancillary facilities, together with basement, access, servicing, cycle storage, plant and public realm. The applicant The applicant is Spaces London Bridge, and the architect is MAKE.
Strategic issues Principle of development: the proposed mix of uses including modern commercial co-working floorspace and residential accommodation within this part of the CAZ are supported (paragraphs 13 to 17). Housing & affordable housing: the proposed co-living residential product is supported in principle subject to the development demonstrating exemplar residential quality. The lack of affordable housing offer at this stage is wholly unacceptable. The financial viability assessment is currently subject to robust interrogation by GLA officers to ensure that the maximum reasonable contribution towards affordable housing is delivered (paragraphs 18 to 23). Residential quality: the poor standard of residential quality is unacceptable. The applicant must increase the proportion of larger rooms, reduce the number of units sharing the largest floors, and significantly increase the size of communal facilities. (paragraphs 25 to 27). Urban design: the applicant must give further consideration to the lower massing elements to achieve a simpler, slender and elegant overall built form (paragraph 34). Inclusive design: an element of blue badge parking should be provided from the outset (paragraph 38). Further revisions and discussion is sought with respect to the above-mentioned points, and others associated with housing (paragraphs 18 and 20), inclusive design (paragraph 36), sustainability (paragraph 37) and transport (paragraphs 40 to 43).
Recommendation That Southwark Council be advised that the application does not comply with the London Plan for the reasons set out in paragraph 48 of this report; but that the possible remedies set out in that paragraph could address these deficiencies.
page 1 Context
1 On 20 June 2017 the Mayor of London received documents from Southwark Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 31 July 2017 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.
2 The application is referable under categories 1A and 1C of the Schedule to the Order 2008:
• 1A – “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”
• 1C – “Development which comprises or includes the erection of a building more than 30 metres high outside the City of London.”
3 Once Southwark Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.
4 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description
5 The application site comprises a four storey warehouse building, flanked by three storey extensions that is in partial commercial/storage use and is located at the junction of Crosby Row and Long Lane, to the east of Borough High Street in the London Borough of Southwark. The site is bounded by Long Lane to the north, Pilgrimage Street to the east, Southall Place to the west, and a small three-storey commercial parade with residential above to the south. Long Lane is served by a bus route and Borough Underground Station and London Bridge station are within a five and ten minute walk respectively. As a result the site benefits from an excellent Public Transport Accessibility Level of 6b, on a scale of one to six, where six is excellent.
6 The surrounding context is a mix of residential, commercial and community uses, with a school and Guy’s Hospital in relatively close proximity. With regards to the scale of existing buildings in the vicinity of the site, the predominant height ranges from four to seven storeys in height, with taller buildings such as the Empire Square development immediately adjacent to the application site which rises to approximately 25 storeys at its tallest and the 21 storey residential towers on the Kipling Estate further to the west of the site on Weston Street.
7 The site does not contain any listed buildings and is not located within a conservation area. The Borough High Street and the Liberty of the Mint conservation areas are located to the north-west of the site with Tennis Street forming the eastern boundary of the former. The Grade II* listed Church of St George the Martyr is located within the closest part of this conservation area adjacent to Borough Underground Station. Trinity Church Square Conservation Area lies some distance to the south of the site and the western boundary of the Bermondsey Street Conservation Area lies to the north-east past the Kipling Estate. With regards to strategic policy designations the site is located within the Central Activities Zone (CAZ).
page 2 Details of the proposal
8 The proposals seek the demolition of the existing building and the development of the site to provide a mixed-use fifteen storey building comprising 172 co-living rooms (sui generis) with shared amenity space and ancillary residential facilities, co-working office space (Class B1) with ancillary facilities, together with basement, access, servicing, cycle storage, plant and public realm. Case history
9 The applicant engaged in initial pre-application discussions with GLA officers in January 2017 where the proposed development of this site for a mixture of commercial and residential accommodation within this part of the CAZ was supported in principle. Further information on the existing and proposed employment uses was requested in addition to further detail on the potential residential quality of the co-living product proposed. In addition to the above, further discussion was required regarding affordable housing and a number of issues specifically relating to urban design, inclusive design, sustainable development and transport were raised. Officers note that the quantum of commercial floorspace has been revised and increased following this advice. Strategic planning issues and relevant policies and guidance
10 The relevant strategic issues and corresponding policies are as follows:
• Principle of development London Plan; • Housing & affordable housing London Plan; Housing SPG; Housing Strategy; draft Affordable Housing and Viability SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context, draft SPG; • Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; London Housing Design Guide; Shaping Neighbourhoods: Play and Informal Recreation SPG • Inclusive design London Plan; Accessible London: achieving an inclusive environment SPG; • Sustainable development 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 • Transport London Plan; the Mayor’s Transport Strategy;
11 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 2011 Southwark Core Strategy; saved policies of the 2007 Southwark Plan; and the London Plan 2016 (Consolidated with Alterations since 2011).
12 The National Planning Policy Framework, Technical Guide to the National Planning Policy and National Planning Practice Guidance; the Central Activities Zone Supplementary Planning Guidance (March 2016) and the Draft New Southwark Plan (2017) are also relevant material considerations following are also relevant material considerations.
page 3 Principle of development
13 The site is located in the Central Activities Zone (CAZ). London Plan Policies 2.11 and 4.3 of the London Plan seek to ensure that proposals to increase office floorspace within the CAZ include a mix of uses, including housing. Furthermore, as recognised in the London Plan, as well as being an economic hub, the CAZ is a place where many people live, including many people who also work there and therefore, the availability of a range of homes in the CAZ helps support its strategic function. However, it is also important to make sure that this does not compromise the strategic functions in other parts of the CAZ. A balanced approach to addressing both the strategic functions of the CAZ and its role as a residential area is therefore required.
14 London Plan Policy 4.2 seeks to support the management and mixed use development and redevelopment of office provision to improve London’s competiveness and to address the wider objectives of the plan. It also seeks to meet the needs of the central London office market, consolidate and extend the strengths of a diverse office market and encourage the renewal and modernisation of the existing office stock. Increases in stock will be sought where there is authoritative, strategic and local evidence of sustained demand.
15 The existing building is currently partially occupied by office and warehouse storage uses, is underused and provides poor quality commercial floor space. It is understood that it currently provides approximately 2,084 sq.m. of B1 accommodation. The proposed mixed-use development includes 2,026 sq.m. of flexible co-working office space at ground, first and second floors to replace the existing poor quality floor space. While the development would result in a minor overall reduction of office floor space (60 sq.m.), it is recognised that the proposed commercial space would be of a much higher quality that is suited to modern requirements and therefore renewal and modernisation of the existing underused floor space is supported. The proposed co-working office space is expected to support approximately 347 jobs over a range of public and semi-private spaces suitable to differing commercial requirements, which is a significant increase from the 86 jobs supported by the current employment use which further supports the proposed employment intensification of the site. It is understood that the applicant is currently exploring existing workspace models in London to help inform its management of this space and further information on this aspect of the scheme, including rental costs and lease arrangements, and whether the floor space will include a proportion of affordable workspace should be provided for assessment prior to the Mayor determining this application.
16 London Plan Policy 3.3 affirms the Mayor’s determination to work with relevant partners to increase London’s housing supply by an average of 32,210 net additional homes to meet the need identified in the plan, enhance the environment, improve housing choice and affordability, and to provide better quality accommodation for Londoners. To achieve that figure, the London Plan sets an annual target of 2,736 additional dwellings in Southwark for the ten-year period from 2015 to 2025. Therefore the principle of including residential accommodation in the proposal is supported in strategic planning terms.
17 Overall, in light of the above policy framework, the proposed mix of uses including modern commercial floorspace and residential accommodation within this part of the CAZ are supported in principle.
page 4 Housing
Shared living
18 The residential component of the scheme will be delivered as a co-living private rental product aimed at young people who want to stay for longer periods than traditional short stay accommodation and comprises 172 non-self-contained, en-suite one person units with communal facilities. In planning terms this is classified as a large-scale HMO and would be Sui Generis in use class. The building will be under single management by the applicant and a management strategy has been submitted demonstrating how the whole development will be managed. Further information should be provided demonstrating how the development will positively integrate into the surrounding communities.
19 The London Plan recognises the increasingly important role the private renting sector (PRS) has in meeting Londoners’ diverse housing requirements and in Policy 3.8B a1 sets out that the planning system must provide positive and practical support to sustain the contribution of this sector in addressing housing needs and increasing housing delivery. This position is reinforced in the Mayor’s draft Affordable Housing and Viability SPG (2016). In light of the above, the proposed residential product is supported in principle, subject to achieving exemplar residential quality and delivering the maximum reasonable contribution towards affordable housing. As set out in paragraphs 22 to 29 below, serious strategic concerns are raised with regards to the quality of the proposed residential environment, which is unacceptable, and must be addressed before the development can be fully supported.
20 As set out during pre-application discussions, the applicant should provide further information on any eligibility criteria to be applied to prospective tenants, residential lease terms, information on the expected average occupation and how it will ensure that the units remain in single occupancy for information.
Affordable housing
21 One of the key principles of this specific PRS model is that it is targeted at young professionals who would otherwise be unable to afford to rent purpose built, single occupancy accommodation in the local area and therefore the rent levels for the proposed accommodation will be set at levels affordable to this identified group. This is supported by the PRS demand study undertaken by the application and submitted as part of the application. The applicant should provide further information on the weekly rental costs of the different size of units proposed and how this compares to alternative comparable rental products currently available in the local market for assessment purposes.
22 Notwithstanding the above, as advised during pre-application discussions, large scale HMO’s, such as the proposed development, should make the maximum reasonable contribution towards affordable housing. This contribution should be in the form of an off-site contribution to conventional C3 affordable housing rather than an on-site discounted rent, as this type of accommodation is not considered suitable as a form of affordable housing. This is in recognition that while a build to rent product can help meet an identified non-statutory housing need, in this specific case young professionals, large scale HMO’s should make a contribution towards meeting the statutory need for affordable housing and that off-site contributions are strategically considered the most appropriate way of the achieving this. All such contributions should be clearly and transparently spent through the Council’s affordable housing programme to deliver additional identifiable conventional (C3) affordable housing units.
page 5 23 At the time of writing, the applicant is yet to make an affordable housing offer. This is wholly unacceptable. A financial viability assessment has been provided for review and the assumptions in the FVA are currently subject to robust interrogation by GLA officers to ensure that the maximum reasonable contribution towards affordable housing is delivered. GLA officers will work with the Council and the applicant to ensure that the scheme delivers the maximum reasonable contribution towards affordable housing in line with the principles of the Draft Affordable Housing and Viability SPG.
Residential quality
24 London Plan Policy 3.5 requires that housing developments should be of the highest quality internally, externally and in relation to their context, with further guidance provided in the Mayor’s Housing SPG. While it is accepted that the Housing SPG standards are not strictly applicable to the type of housing proposed the applicant has been strongly encouraged to meet them wherever possible throughout pre-application discussions.
Unit type Average size (sq.m) No. units % units City Plus 13.5 86 50% City Loft 20 66 38% City Extra (accessible) 16-26 20 12%
25 The proposals include three different unit types which are set out in the above table. While it is recognised that co-living residential units fall within a sui generis use class rather than the standard residential uses, these unit types fall significantly below the minimum residential space standards of 37 sq.m. as set out in the London Plan. To justify this approach, the applicant has carried out a detailed assessment of the proposed single occupancy units against the double bedroom floor area and head room standards for a share-flat in a Nationally Prescribed Space Standards and Southwark’s Residential Design Standards compliant unit which shows that the quantum of private living space in each unit, excluding en-suite facilities (11.5 – 18.5 sq.m.) will exceed these minimum standards. A comparison has also been carried out which demonstrates that residents would benefit from a larger amount of living space (including kitchen, bathroom facilities (bathrooms are private in the proposed scheme) and external amenity space), than that which would typically be shared by an individual living in a house share that complies with both local and national residential space standards. This approach is unacceptable. The proposed co-living product is not a typical residential environment and is not considered comparable to a usual house share as the number of individuals sharing communal facilities is significantly higher. As such the assessment does not demonstrate residential quality.
26 The typical residential floor is laid out around a central lift core which opens out onto a dual aspect communal lounge and kitchen space with corridors leading off to individual rooms. This layout enables natural light to penetrate the heart of the building and the internal communal spaces/corridors and reduces the length of corridors to individual rooms which is welcomed. However, the proposals for 27 to 28 units per floor at the lower levels and the intense pressure this will place on communal facilities is not supported and raises serious strategic concerns with regards to the quality of the internal residential environment proposed on these floors. Significant concerns are also raised with regards to the overall liveability of the smallest City Plus rooms, particularly as these are located on the lower residential floors where a large proportion of these units are single aspect and north facing, and where the communal facilities will be most intensely used. The applicant must therefore reduce the number of units sharing an individual floor, increase the proportion of larger units, and significantly increase the size of the associated communal facilities, in order to provide a higher quality internal living environment. This will help to reduce the number of north facing single aspect units and the number of units sharing the most intensely occupied residential floors to reflect strategic
page 6 residential quality aspirations. Adequate management arrangements must be put in place to ensure that the communal areas are maintained and cleaned and applicant should however confirm that all residents will have access to all communal facilities on all floors within the development.
27 Notwithstanding the above, the design principle of maximising daylight into the proposed units through large, glazed, chamfered windows is welcomed as is the aspiration to maximise floor to ceiling heights, achieving 2.75 metres at its tallest which exceeds the Housing SPG standard. The applicant should consider expanding the landscaped terraces to further maximise their visual amenity value.
28 On the basis of the above, significant revisions to the application are required to ensure the proposed co-living product provides the highest residential quality and before it can be supported from a strategic perspective. GLA officers will work with the applicant and the Council to address the serious concerns raised.
Residential density
29 Given the characteristics of the site, the public transport accessibility level (PTAL) of 6b, and its central location, the London Plan density matrix (Table 3.2 in support of London Plan Policy 3.4) would suggest a residential density of between 650 to 1,100 habitable rooms per hectare (hr/ha) for a traditional residential development on this site. The proposed development includes 172, single occupancy, one bedroom units which comprise 172 habitable rooms. On the basis of the site area of 0.105 hectares, the residential density would be 1,638 hr/ha.
30 Notwithstanding the above, it is acknowledged that the density ranges recommended in Table 3.2 of the London Plan should not be applied mechanistically. Furthermore, the nuances regarding the occupancy rates of the residential model proposed that results in a higher density than traditional C3 residential development are recognised. As described above, the development will provide a well-considered building that relates well to the surrounding public realm with publicly accessible cafe and workspace facilities, in a very accessible location. However, those issues raised above with regards to affordable housing and residential quality, in addition to the urban design issues set out below must be satisfactorily addressed before the proposed residential density can be appropriately assessed.
Urban design
31 As set out at the meeting, the development provides an opportunity to significantly improve the pedestrian experience along this part of Long Lane, as the existing building provides little contribution to animating the public realm. This is exemplified by the long flank wall along the pedestrian walkway at Southall Place and the predominantly blank frontage along Pilgrimage Street. Overall, it is considered that the proposed building layout successfully addresses the existing site conditions and has the potential to deliver a number of positive contributions to the pedestrian experience in this area.
32 The provision of a double-height, glazed, commercial podium at ground floor incorporating the main entrances on the prominent corners of the site providing access to the proposed flexible exhibition/community space, ground floor public work space and cafe/bar will help provide activity and passive surveillance onto the surrounding public realm and help integrate the development into the existing community. The location of the majority of ‘back of house’ uses on the southern elevation also helps maximise the amount of active frontages on the key public facing edges and pedestrian routes. The setting back of the ground floor building line along Long Lane and Southall Place to provide a more generous public realm and the opportunity for ground floor activity to spill
page 7 out on to Southall Place is strongly welcomed and will help contribute towards place making. The improvement and activation of Southall Place also provides the opportunity for the development to help reinvigorate the public space at the adjacent Empire Square development and opportunities to highlight its existence are encouraged.
33 With regards to height and massing, the building is broken down into a number of massing elements which respond to the surrounding townscape character with the tallest elements fronting onto Long Lane, with the massing behind breaking down to smaller elements to address the residential scale of the buildings to the south. The tallest element is located in the north-west corner of the site and reaches fifteen storeys in height which seeks to address the Crosby Row/Long Lane junction at a key north-south route towards London Bridge and the taller buildings towards Borough High Street and the Empire Square tower. The proposed scale within the CAZ does not raise any in principle objections and the views demonstrate that the proposed massing sits relatively comfortably within the existing urban townscape. Furthermore, in accordance with London Plan 7.7 the proposed development will deliver a number of significant public realm improvements at the base of the building, providing animation to the public realm through provision of publicly accessible cafe, community/exhibition space and flexible co-working space.
34 The rationale of stepping down the massing to respond to the adjacent context is generally supported, subject to the satisfactory outcome of detailed daylight and sunlight impact assessment on neighbouring properties, in particular those closest residential units in the Empire Place development. The building orientation combined with the stepping back from Southall Place will help minimise overshadowing to the smaller scale residential dwellings that share the southern site boundary. Notwithstanding the above, the applicant is strongly encouraged to give further consideration to the lower massing elements in the longer views from the south looking north (Great Dover Street, Pilgrimage Street and Manciple Street) to achieve a simpler, slender and elegant overall built form as the current massing appears overly complex and dominant.
Heritage
35 The applicant has provided a townscape and visual impact assessment including a series of views agreed in consultation with the Council from around the application site. These include views from within the Trinity Square and the Liberty of the Mint conservation areas. The development would be visible from the junction of Trinity Street and Globe Street on the edge of the Trinity Square Conservation Area. The development will appear in the background of the long view when looking away from the area, will form part of the existing urban context of Borough High Street and is considered to have a neutral impact on the conservation area. The applicant has also included a view from Marshalsea Road within in the Liberty of the Mint Conservation Area looking towards the site and the southern portion of the Borough High Street Conservation. The Grade II* listed Church of St George the Martyr forms the focus of this view and therefore the Mayor must have special regard to the desirability of preserving the listed structure or its settings. The proposed development will be entirely screened by the existing Empire Square tower and does not cause harm to the listed church or the conservation areas. Inclusive design
36 It is recognised that Building Regulations standards for wheelchair accessible and adaptable units are not applicable to the proposed co-living product; however, the applicant has sought to meet these standards where possible, which is welcomed, particularly with regards to circulation, turning and general navigation by wheelchair users. The City Extra units are identified as being accessible for wheelchair users due to their larger size, although some of the larger City Loft units may also be suitable. In total, it is proposed that twenty units will be suitable for wheelchair users which equates to approximately 12% of the total number of units. These units should be spread
page 8 throughout the development as much as possible and it should be clarified whether one of the proposed lifts will be suitable to be used as an evacuation lift in case of emergency to allow people who require level access to safely evacuate the building with dignity and minimal need for assistance.
37 The applicant has submitted a detailed inclusive access statement which is welcomed and demonstrates that inclusive design has been considered throughout the design process in order to ensure that the residential and flexible co-working spaces will be accessible and navigated by all. The principles set out in the statement are supported and the Council should ensure these commitments are carried through to the detailed design stages and secured by condition.
38 Notwithstanding the above, given that some wheelchair accessible/adaptable units are to be provided some blue badge parking should be provided from the outset and this should be discussed with the Council. The applicant should identify the location of the pick-up and drop-off point on Pilgrimage Street should be indicated and that suitable kerbs (both dropped and full height suitable for taxi ramps) will be provided. Sustainable development
Energy strategy
39 In accordance with the principles of London Plan Policy 5.2 the applicant has submitted an energy statement, setting out how the development proposes to reduce carbon dioxide emissions. In summary the proposed strategy comprises: energy efficiency measures (comprising a range of passive design features and demand reduction measures); a communal heat network powered by a combined heat and power (CHP) unit that is designed for future connection to a district heat network; and, renewable technologies including photovoltaic panels and air source heat pumps (ASHPs). Based on the strategy proposed the scheme would achieve a 38% reduction in carbon dioxide emissions compared to 2013 Building Regulations compliant development. Whilst broadly supported, GLA officers require further information to verify the savings claimed including further detail on the size and location of the site heat network and the energy centre and demonstrating that the CHP engine has been optimised before considering ASHPs. Detailed technical comments have been issued directly to the applicant which should be addressed in full to ensure compliance with London Plan energy policy.
Transport
Walking, cycling and access
40 The proposed cycle parking for the commercial floorspace meets the London Plan standard for this use class. With regards to the co-living accommodation, the most appropriate cycle parking standards to apply are those for C3 and C4 uses and there is currently a short fall of 67 long stay cycle parking spaces for the residents. Given the location of the development and that the targeted residents and employees are in groups most likely to cycle provision above the minimum standard would be appropriate and this should therefore be increased.
41 A financial contribution of £180,000 towards a new cycle hire docking station to meet the increased demand on the cycle hire network from the development, and the provision of a wayfinding system, such as Legible London signing, to promote walking to local facilities and transport are required.
page 9 Car Parking
42 Future residents should be exempt from applying for permits (except for blue badge holders) in the local area and this should be secured via the section 106 agreement. The applicant should note those comments regarding disabled parking in paragraph 36 above.
Travel planning, delivery and servicing and construction planning
43 The mode share targets for walking and cycling in the submitted travel plan are low given the target demographic and this should be increased in the final version which should be appropriately secured. The production of a delivery and servicing plan is welcomed but the number of trips appears to be very low given the likelihood for a high frequency of home deliveries. A final revised plan together with a construction logistics plan should be secured by condition.
Community Infrastructure Levy
44 The Mayor has arranged boroughs into three charging bands. The rate for the London Borough of Wandsworth is £35/sq.m. The required CIL should be confirmed by the applicant and Council once the components of the development or phase thereof have themselves been finalised.
Local planning authority’s position
45 It is understood that the Council had a number of unresolved issues relating to affordable housing, scale and massing and impact on amenity of neighbouring residents prior to submission. Discussions are ongoing between the applicant and the Council. A committee date is not yet known. Legal considerations
46 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
47 There are no financial considerations at this stage.
page 10 Conclusion
48 London Plan policies on CAZ, mixed-use development, housing and affordable housing, urban design, inclusive design, sustainable development and transport are relevant to this application. The scheme does not yet fully comply with the London Plan for the reasons set out below. The resolution of these issues could, nevertheless, lead to the application becoming compliant with the London Plan and should therefore be addressed prior to the Mayor’s decision making stage: • Principle of development: the proposed mix of uses including modern commercial co- working floorspace and residential accommodation within this part of the CAZ are supported. • Affordable housing: the lack of a clear affordable housing offer at this stage is wholly unacceptable. The financial viability assessment is currently subject to robust interrogation by GLA officers to ensure that the maximum reasonable contribution towards affordable housing is delivered. The applicant should provide further information on the weekly rental costs and how this compares to alternative comparable rental products currently available in the local market for assessment purposes.
• Housing: the applicant should provide further information on any eligibility criteria to be applied to prospective tenants, residential lease terms, information on the expected average occupation and how it will ensure that the units remain in single occupancy.
• Residential quality: the poor standard of residential quality is unacceptable. The applicant must increase the proportion of larger rooms, reduce the number of units sharing the largest floors, and significantly increase the size of communal facilities. • Urban design: the proposed scale within the CAZ does not raise any in principle objections. The applicant must give further consideration to the lower massing elements in the longer views from the south looking north to achieve a simpler, slender and elegant overall built form.
• Inclusive design: inclusive access and design has been considered throughout the design of the development. However, an element of disabled parking should be provided from the outset, in addition to details on the pick-up and drop-off location and clarification that one of the lifts is suitable to be used as an evacuation lift in the case of an emergency.
• Energy: GLA officers require further information to verify the savings claimed including further detail on the size and location of the site heat network and the energy centre and demonstrating that the CHP engine has been optimised before considering ASHPs.
• Transport: additional cycle parking should be provided together with a contribution towards cycle hire and improved wayfinding.
for further information, contact GLA Planning Unit (Development & Projects Team): Juliemma McLoughlin, Assistant Director - Planning 020 7983 4271 email [email protected] Sarah Considine, Senior Manager - Development & Projects 020 7983 5751 email [email protected] Shelley Gould, Strategic Planning Manager – Development Decisions 020 7983 4803 email [email protected] Jonathan Finch, Case Officer 020 7983 4799 email [email protected]
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