London Borough of Islignton Local Plan Examination Matter 2 Area

London Borough of Islington Matter 2 – Area Spatial Strategies

General Matters

2.1 Is the overall strategy set out by the area spatial strategies justified?

2.1.1 Yes. The approach to the area spatial strategies is also explained and assessed in the Integrated Impact Assessment chapter 4 (pages 91-99) (document reference PD4). As the IIA explains, the spatial strategies are based on key areas where the level of change expected over the plan period requires specific spatial policies for managing growth. The principle of growth and development is already established in the spatial areas through the adopted Core Strategy. The Core Strategy featured seven key area policies including Bunhill and Clerkenwell, the borough’s four town centres and two other key areas of change around key transport hubs and regeneration areas. These key areas have been carried forward into the Draft Local Plan.

2.1.2 An explanation of the approach to the area spatial strategies is provided in Topic Paper – Vision, Objectives, Policy PLAN 1 and Spatial Strategies (document reference SD20). As set out in the Topic Paper, the issues that existed when the spatial areas were derived continue to exist, with the spatial strategy reflecting the areas where growth and development needs have been and continue to be focused and recognising constraints for growth elsewhere.

2.1.3 A further explanation of the approach to the Area Spatial Strategies is set out in LBI03 (LB Islington response to the Inspectors letter INS04). The spatial strategy areas already accommodate established functions and land uses and these areas have the greatest capacity to accommodate future growth, with around 80% of the growth identified from allocated sites taking place in spatial strategy areas. Targeting growth towards the spatial strategy areas therefore responds to the identified need for land supply and opportunity from changing needs for different uses with spatial policies there to help guide the competing pressures for land use as well as to ensure that growth and change is accommodated sustainably.

2.1.4 Within the context of the above there are not considered to be any reasonable alternatives to the overall strategy set out by the area spatial strategies.

2.2 To be positively prepared, should each area spatial strategy set out indicative delivery figures in terms of residential and employment uses?

2.2.1 The indicative delivery figures for each spatial area are set out in the Site Allocations document at Table 1.2 and the Bunhill and Clerkenwell Area Action Plan at Table 4.2. These tables provide a clear illustration of the growth assumption associated with sites and read alongside the spatial strategies help the plan to be positively prepared in setting out how each area can contribute towards objectively assessed needs.

London Borough of Islington Matter 2 – Area Spatial Strategies

2.3 Are all of the area spatial strategy diagrams suitably legible?

2.3.1 It is acknowledged that in some instances some of the text can be difficult to read in the Regulation 19 Strategic and Development Management Policies. This is due to the way the software compressed the document when it was published which has effected the resolution of some of the images. A high resolution version of the document was produced for printing purposes and can be uploaded alongside or in replacement of the document that is currently online to assist with legibility.

2.4 Does the Plan adequately address the issue of neighbourhood planning? 2.4.1 Yes. Islington has no 'made' neighbourhood plans at present. However, the Plan acknowledges 'made' neighbourhood plans are part of the Development Plan paragraph 1.6 of the Strategic and Development Management Policies document. Each DPD also sets out how the AMR will also provide information on neighbourhood planning1. Paragraph 5.4 of the Strategic and Development Management Policies document highlights the role that neighbourhood plans can play in the designation of local green spaces. Through providing clarity about which policies are considered to be strategic, the Plan provides a clear framework for neighbourhood forum to use in the production of future neighbourhood plans.

Strategic and Development Management Policies DPD Policy SP2 – King’s Cross and Pentonville Road 2.5 To be positively prepared and justified, should the approach to residential use in the area spatial strategy be set out?

2.5.1 The approach to residential uses on specific sites is set out in relevant site allocations, while other policies in the plan provide a framework for the approach to residential use in different circumstances. A large part of the spatial policy area to the north and east is made up of established residential uses. As recognised in paragraph 2.10 high-density, office retail and housing development has taken place on both sides of the Camden/Islington boundary. Aside from the established residential areas and specific site allocations where residential is recognised a key land-use challenge is how competing land uses can be balanced, particularly given King’s Cross development as a key commercial designation, with high profile tenants in the area creating a ‘halo’ effect. In this context a key role of SP2 in being positively prepared is to reflect the opportunity for the King’s Cross area to help meet Islington’s significant projected jobs growth over the plan period through protecting and intensifying business uses. The spatial policy reflects this in identifying existing employment locations (the King’s Cross Priority Employment Location is one of the largest in the borough) and also opportunities for further commercial-led development. Within this

1 Paragraph 10.7 of Development Management Policies, paragraph 5.8 of Bunhill and Clerkenwell Area Action Plan and paragraph 10.8 of Site Allocations. 2

London Borough of Islington Matter 2 – Area Spatial Strategies

context part of the spatial area is within the CAZ. It is proposed to add some additional commentary on residential use in the supporting text.

Proposed modification Amend text as follows: 2.13 The remainder of the Spatial Strategy area – outside of the PELs – may also be appropriate for the development of business floorspace as the ‘halo effect’ from the King’s Cross central development continues. North of the canal it is recognised that there is a predominantly residential character where the development of business uses will be considered in line with relevant policies including B2 and H2.

……

Add new paragraph: 2.24 Housing development will come forward on sites allocated for housing. It is recognised that smaller windfall housing development, including through the utilisation of permitted development rights, will also come forward in the area over the plan period.

2.6 If residential use is considered to be unacceptable in the area spatial strategy area, does this comply with the NPPF and the London Plan?

2.6.1 Residential use is not considered to be unacceptable. The approach to residential use in the area outside the CAZ and PEL is picked up through other policies in the plan and Site Allocations. Assumptions for residential growth through site allocations are set out in the Site Allocations document (PD2) and topic paper (SD23). Other policies in the plan also provide the framework for competing land-uses to be prioritised and the circumstances in which residential use will be considered. The approach complies with the NPPF and London Plan.

2.7 For the Policy to be effective should the boundary of the knowledge quarter be defined?

2.7.1 The Knowledge Quarter (KQ) is defined as a partnership of 89 academic, cultural, research, scientific and media organisations located in a one-mile radius around King’s Cross, Euston Road and Bloomsbury2. It is a phenomenon that has emerged in recent years in Camden where world class institutions started to cluster in the area surrounding King’s Cross/St Pancras and Euston Stations. However because it is still emerging in Islington there is no defined boundary at this stage. The development of the KQ in the borough will be kept under review and it may be formally defined in a future review of the plan. Part B of spatial policy SP2 seeks the maximisation of business floorspace in this area to support the expansion of the KQ in Islington.

2 https://www.knowledgequarter.london/wp-content/uploads/2017/12/Knowledge-Quarter_Connection-and-Trusts.pdf (pages 02/03) 3

London Borough of Islington Matter 2 – Area Spatial Strategies

2.8 Is the approach of Policy SP2 to residential moorings justified?

2.8.1 Yes, the approach to residential moorings set out in Policy SP2 is justified as it balances the competing interests in use and enjoyment of the canal waterspace and corridor, including the use for boaters and navigation, as an open space, and a green space and biodiversity habitat. The Council supports development of new residential moorings where appropriate, including where they do not impact on leisure provision, and where there is no detrimental impact on the canal with regard to character, nature conservation, and air quality. Refer to question 3.57 for information on how the identified needs of boat dwellers will be met by the Local Plan.

2.9 Is the Central Activity Zone (CAZ) boundary in this area spatial strategy justified?

2.9.1 As part of the recommendations to review employment designations in the ELS (2016), the study considered that the council might review the CAZ boundary, in light of the pressures from the City economy3. This is also acknowledged by in Islington Local Plan: Scope of the Review report (PD11)4. This recommendation was considered general (not specific to this area spatial strategy). There is no evidence to support a change to the CAZ boundary at this time, particularly given the emerging nature of the KQ around King’s Cross and impacts of the wider King’s Cross Central scheme which is not yet complete. This would be considered as part of a future plan review.

Policy SP3 – Vale Royal / Brewery Road Locally Significant Industrial Site 2.10 Is the boundary of the Vale Royal / Brewery Road Locally Significant Industrial Site justified based on existing uses? It would be helpful if the Council could supply a map illustrating the use of each building/site within the boundary.

2.10.1 Yes, it is justified. The boundary of the Vale Royal/Brewery Road LSIS defines Islington’s most significant concentration of industrial activity and it carries over the established boundary of the site from the adopted Local Plan. Section 6.2 of the ELS includes a site assessment of the Vale Royal/Brewery Road LSIS. This was part of the assessment of all employment designations which involved a review of each site with the objective of identifying significant changes in their use, condition, occupier mix and so on since earlier assessments. The Vale Royal/Brewery Road LSIS study denotes the uniqueness of this area’s built form and townscape, characterised by big footprint industrial style buildings which is in contrast with the finer grain, traditional character of the surrounding area and

3 Employment Land Study (Examination Library ref: EB4). Management Summary, Recommendations: within the CAZ, p.vii 4 Islington Local Plan: Scope of the Review report, November 2016, paragraph 4.14, p. 21: https://www.islington.gov.uk/~/media/sharepoint-lists/public- records/planningandbuildingcontrol/publicity/publicconsultation/20162017/20161125islingtonlocalplanscopeoftherevie w.pdf

London Borough of Islington Matter 2 – Area Spatial Strategies

adjacent post-war building estates, recognising that there is only a minor proportion of housing mainly on the edges of the LSIS. The study classifies the character of this area as ‘warehouse style employment’5.

2.10.2 Further, the Council has carried out a recent review of land uses in the Vale Royal and Brewery Road LSIS as part of the London Industrial Land Supply Study 2020 that AECOM are preparing on behalf of the GLA, which provides evidence of land use for sites in the area. Some of the sites identified as warehouse use have ancillary office within them. This map is provided at Appendix 1.

2.11 Is the approach of Policy SP3 to the provision of industrial uses and office uses justified based on proportionate and up-to-date evidence, and consistent with the London Plan and national policy?

2.11.1 Yes. Spatial policy SP3 builds directly from the findings in the Employment Land Study, which identified the Vale Royal/Brewery Road LSIS as the most significant concentration of industrial activity in the borough, recommending its protection and support with intensification of uses through the provision of hybrid space in the context of its industrial function6.

2.11.2 Paragraphs 8.35 and 8.36 of the Employment Topic Paper7 refers to the NPPF requirement which reflects the need for planning policies and decisions to recognise and address the specific locational requirements of different sectors. The Vale Royal/Brewery Road LSIS is itself a cluster of predominantly industrial sites and businesses, which have specific location requirements, including the need to be located geographically close to the main area they serve, which is the CAZ. Paragraph 82 also makes a specific reference to the provision for storage and distribution operations at a variety of scales and in suitably accessible locations. It is considered that the findings from the ELS in relation to this spatial area remain up to date as the protection of LSIS from further incursion of office uses ensures the availability of sites for storage and distribution operations, which have experienced increasing demand for a range of reasons, including growth in e-commerce.

2.11.3 Policy SP3 is also consistent with the London Plan, Policy E6 of the London Plan relates to LSIS. It requires boroughs to make clear the range of industrial and related uses that are acceptable in LSIS including, where appropriate, hybrid or flexible B1c (former)/B2/B8 suitable for SMEs and distinguish these from local employment areas that can accommodate a wider range of business uses. Policy E6 identifies as suitable those Inner London sites providing sustainable distribution services for the CAZ. The Vale Royal/Brewery/Road LSIS is an example of such sites and therefore suitable for this

5 Vale Royal/Brewery Road LSIS Height Study, December 2016 (Examination Library ref: EB15) – section 1.5.1 p.13, 1.5.2 p.14 and 1.3.1 p.7. 6 Employment Land Study (Examination Library ref: EB4) - Management Summary, Recommendations: outside the CAZ, p.vii 7 Employment Topic Paper, February 2020 (Examination Library ref: SD16) – paragraphs 8.35 and 8.36, p.58 5

London Borough of Islington Matter 2 – Area Spatial Strategies

designation. During the Regulation 19 consultation, the Mayor’s conformity opinion was in support of the Council’s approach to safeguard and promote industrial land in this existing LSIS designation and the central servicing function. The GLA response stated the following: “It is clear that the proposed allocations within the Vale Royal/Brewery Road LSIS are for the retention and intensification of industrial uses which is supported by the Mayor and is closely aligned with draft new London Plan Policies E4 and E6.”

2.12 Would Policy SP3 unreasonably restrict the growth of the creative industry within the spatial strategy area, including Tileyard Studios and is this supported by the evidence base?

2.12.1 The Vale Royal/Brewery Road LSIS accommodates, amongst other occupiers, a cluster of creative production businesses that operate from industrial premises, many of which are running at capacity and are looking to expand in the LSIS. This is supported by the Employment Land Study, paragraphs 6.2.12 to 6.2.1, which provides evidence of occupiers in the area which require warehouse type premises. Paragraph 5.80 of the Employment Topic Paper provides a further analysis and evidence of the presence of the creative production sector in the LSIS. Furthermore, during the Regulation 19 Consultation, representations from local creative production businesses based in the LSIS voiced concerns about the constraints that they faced in finding suitable industrial premises in the borough.

2.12.2 The proposed spatial policy SP3 recognises the contribution of businesses related to the music and entertainment industry in the area, including Tileyard Studios, and seeks to support this successful economic cluster through protecting existing uses. However, it makes clear that new proposals to expand music and entertainment industry uses/cluster must be in line with the land use policy in the new Local Plan8.

2.12.3 Further, the Mayor’s Regulation 19 consultation response to this policy also recommended that B2 and B8 uses are prioritised over light industrial in the Vale Royal/Brewery Road LSIS. This is to support the provision of 'last mile' distribution/logistics, 'just in time servicing', waste management and recycling as well as land to support transport functions; considering the area’s strategic position in relation to the CAZ. The Council considers that prioritising B2 and B8 uses over B1c is not appropriate, particularly given the need to accommodate the growing creative production sector in the borough, which the council strongly supports. The Mayor’s own evidence and policies are supportive of the creative production sector and of the so called “maker space”. The policy approach set out in the draft Local Plan is a reasonable approach and is appropriate for Islington’s circumstances. The council specifically notes the Mayor's strategic evidence which notes the importance of these particular uses, given the scale of losses across London in recent years9.

8 Employment Topic Paper, February 2020 (Examination Library ref: SD16) – paragraphs 8.35 and 8.32, p.57 9 Employment Topic Paper, February 2020 (Examination Library ref: SD16)– Paragraphs 8.35 and 8.29, p.56 6

London Borough of Islington Matter 2 – Area Spatial Strategies

2.13 Is it justified to restrict office uses from a site where it is the existing use?

2.13.1 Yes. The policy does not restrict the provision of office uses completely but limits this use to ensure that the primary industrial function of the spatial area is not undermined by other development pressures. This approach is an evolution of the adopted Local Plan policy DM 5.3 which recognises the impacts that other uses could have on the primary function of the Vale Royal/Brewery Road industrial cluster. Paragraphs 8.21 to 8.27 of the Employment Topic Paper provide a more detailed analysis of this issue and a justification as to why large quantum of office development in the area constrains the supply of industrial floorspace.

2.14 Is the assertion in Policy SP3 Part C that additional non-industrial uses would undermine the industrial function of the area justified?

2.14.1 Yes, as outlined in paragraph 8.21 of the Employment Topic Paper (SD16), at the time of preparing Core Strategy and Development Management policies the principal threat to the industrial function of the designated LSIS was housing and other non-business uses which is why policy strongly resists those uses. Paragraphs 8.21 to 8.27 of the Employment Topic Paper explores in more detail why office is perceived as a use that could potentially complement and support the LSIS provided there is no impact on its primary economic function (see also policy DM5.3 and its supporting text). Following the recommendations in the Employment Land Study for the Vale Royal/Brewery Road LSIS10, the proposed policy considers the provision of small quantum of office as part of hybrid space development in the LSIS. The provision of hybrid space is considered in the context of the primary industrial function of the LSIS and paragraph 8.42 of the Employment Topic Paper provides further justification on this approach, which is also in accordance with the priority for the industrial uses outlined in London Plan Policy E4. The IIA Examination Addendum (Table 1.17: Assessment of Alternatives for Policies SP3, B1 and B2 LSIS) tested the alternative scenario of co-location of industrial uses with office intensification. The conclusion was that if office uses are intensified it could compromise the long term sustainability of the LSIS as the area works as a functional industrial cluster. Whilst other uses such as offices and housing can be promoted in other wider locations throughout the borough, opportunities for development/ intensification of industrial uses are very limited in the borough. Therefore, the scope for intensification of industrial uses is particularly important in this LSIS.

2.15 Is the generic height restriction across the spatial strategy area justified and supported by proportionate evidence?

2.15.1 Yes. Building heights in the context of the LSIS is covered in paragraphs 5.28 and 8.44 of the Employment Topic Paper.

2.16 Is the approach of Policy SP3 Part G justified, with particular regard to development being ‘clearly sub-ordinate’ to Maiden Lane tower?

10 Employment Land Study (Examination Library ref: EB4). Management Summary, Recommendations: outside the CAZ, p.vii 7

London Borough of Islington Matter 2 – Area Spatial Strategies

2.16.1 Yes, the approach is justified and supported by the Vale Royal/Brewery Road LSIS Building Height Study, which recognises the Maiden Lane Tower as significantly taller than other buildings in this area, and considers that any other additional tall building to the north of the railway would weaken the cluster and be incongruous to the industrial character of the area and the residential environment in Camden and Islington11. The Council considers that this directs the developer and architect to an appropriate built scale while not stipulating a height expressed in metres. Note at PHM minor modification (SDM-MO13) has been consulted on to provide clarification in the supporting text.

2.17 Would the intensification of industrial uses within the spatial strategy area, have any unacceptable environmental impacts?

2.17.1 The environmental impacts that have been identified in relation to the intensification of industrial uses are not considered to have unacceptable effects and can be managed effectively by spatial policy SP3 . Air quality has been considered in the formulation of the draft Local Plan Policies. Paragraphs 3.105, 3.107 to 3.132 in the Sustainability Topic Paper (SD27), explain in more detail how environmental impacts, air quality in particular, have been considered against the policy. Environmental impacts were considered as part of the IIA Examination Addendum. This assessment concluded that the strategic location of the LSIS enables shorter journeys and supply chains, contributing positively to improving air quality, while providing industrial, storage, distribution and other uses that are increasingly essential to the functioning of London’s economy and meeting the needs of its growing population and the aspect of its role in servicing the Central London Economy. The spatial policy ensures that the business travel is minimised by protecting the existing location as a business cluster, while at the same time encouraging more sustainable ways of travel and improvements on pedestrian connections to achieve more liveable neighbourhood.12 2.17.1 The council considers that the intensification of industrial uses in this spatial strategy area serves a strategic purpose to accommodate the growth of ‘clean industries’ which is evidenced in the GLA’s London Industrial Land Demand Study and explained in detail in paragraphs 5.59 to 5.68 of the Employment Topic Paper. Further, there are a number of additional policies in relation to sustainability and sustainable transport which also apply broadly to new development in the borough. Policy SP3 provides a clear reference to these requirements.

(Please note the Council’s proposed approach of using planning conditions to secure uses within Class E will be considered under Policy B2) Policy SP4 – Angel and Upper Street

11 Vale Royal/Brewery Road LSIS Height Study, December 2016 (Examination Library ref: EB15) – Chapter 3, section 3.2 – Proposed heights, p.29 12 IIA Examination Addendum, March 2021 (Examination Library ref: PD4a) – Table 1.35: Assessment of Area Spatial Strategies for SP1 to SP3 8

London Borough of Islington Matter 2 – Area Spatial Strategies

2.18 To be positively prepared and justified, should the approach to residential use in the area spatial strategy be set out?

2.18.1 Angel and Upper Street Spatial Strategy Area has some unique constraints and designations compared to other area spatial strategies that include town centres. Angel Town Centre is a classified major town centre that is partly included in the CAZ to the south. Angel is also designated as a Cultural Quarter and the spatial strategy area boundary is tightly drawn to the Angel Town Centre and the Upper Street LSA.

2.18.2 The area does already include housing and significant numbers of dwellings have been delivered in recent years. Housing on large sites is addressed through site allocations although the site allocations document envisages a small amount of residential growth. The implementation of significant amounts of new housing would compromise the retail, leisure, culture and business floorspace priorities here. The area is constrained by surrounding dense residential development. Further encroachment of residential development into the majority of the spatial strategy area would compromise evidenced priority land uses being met. However, residential use is not precluded in certain circumstances in line with Policy R4 Part D (now F) which would permit residential on upper floors not involving change of use of existing main town centre uses provided criteria (ii), (iii), (v), (vi), (vii) are met. Given residential use is not a priority in the spatial strategy area it is considered that R4 is sufficient to address residential extensions on upper floors to existing residential uses in LSA locations.

2.19 If residential use is considered to be unacceptable in the area spatial strategy area, does this comply with the NPPF and the London Plan?

2.19.1Residential use is not considered to be unacceptable in the spatial strategy area as a whole. Residential use is resisted in the PSA and rest of Angel Town Centre in order to not compromise the meeting of evidenced need for business, retail, leisure and cultural uses and the effective operation of these. The answer to 2.18 explains further the reasoning behind this approach.

2.20 Is the Cultural Quarter designation justified and supported by proportionate evidence?

2.20.1 Yes, the Cultural Quarter at Angel Town Centre will help to retain and enhance the established successful cultural activity prevalent in these areas. The Retail and Leisure Study, 2017, paragraph 6.17 identified that there were 233 leisure service outlets in 2016; this is the largest provision of service type in the centre and the most prominent type of town centre use overall. This is equivalent to 33.57% of total provision and is significantly above the national average of 23.50%. Angel therefore has a strong leisure offer, which is varied and provides a wide choice for customers and visitors to the centre.

2.20.2 The Retail and Leisure Study, 2017, paragraph 11.65 found through the Household Telephone Interview Survey (HTIS) that The West End (31%) is the most popular for theatre followed by the Almeida Theatre, Islington (10.9%), Barbican Centre (7.6%) and the National Theatre (7.5%). The most popular music venues were the O2 Arena, Greenwich (21.6%) and Barbican Centre (10.7%). These findings demonstrate Angel is

London Borough of Islington Matter 2 – Area Spatial Strategies

competitive on a city-wide scale for theatre use and this is a unique function that warrants enhancement.

2.20.3 Policy HC5 of the London Plan encourages the identification of Cultural Quarters to protect and/or promote cultural activity. Cultural Quarters can be defined around existing clusters of cultural uses or be used to develop new clusters. The designation at Angel is consistent with the London Plan’s intent of cultural quarters and the Mayor welcomed and supported this inclusion in the Mayor’s Regulation 18 response.

2.20.4 Further justification for the inclusion of Angel as a Cultural Quarter is provided in Topic Paper SD22 paragraphs 10.8 – 10.12.

Policy SP5 – Nag’s Head and Holloway 2.21 To be positively prepared and justified, should the approach to residential use in the area spatial strategy area be set out?

2.21.2Part H of Policy SP5 encourages office use above ground floor retail where the operation of the retail use is not affected. This does not preclude residential development but encourages office use. Site allocation NH1 includes residential on upper floors on the large Morrison’s supermarket site, demonstrating compliance with the NPPF paragraph 85f by identifying appropriate sites for residential development. A modification is proposed which specifically references residential use within the policy as set out below.

Proposed modification Add new part N as follows:

Residential development is considered acceptable on sites allocated for this purpose. Small-scale residential use on upper floors outside the Primary Shopping Area of the Town Centre may be acceptable where it does not adversely impact the commercial function of the centre and where the ability of commercial uses in the area to operate effectively is not compromised.

2.22 If residential use is considered to be unacceptable in the area spatial strategy, does this comply with the London Plan and NPPF?

2.22.1 Residential use is not considered to be unacceptable in the spatial strategy area as a whole. Please see answer to question 2.21. See response also to question 8.7.

2.23 Is Part l inconsistent with Policy H6 in terms of when additional student accommodation may be considered acceptable?

2.23.1 Yes, to address the inconsistency an additional modification (SDM-MO19) has been consulted on as part of the Pre hearing modifications consultation which clarifies the need to be consistent with policy H6.

2.24 Is Part K justified in relation to the removal of the Isledon Road / Tollington Road gyratory system? 10

London Borough of Islington Matter 2 – Area Spatial Strategies

2.24.1 Part K is justified in relation to the removal of the Isledon Road/ Tollington Road gyratory system. The purpose of this removal is to address the present traffic dominance on the A1 (Islington Transport Strategy 2020, p66), thereby providing better conditions to promote sustainable modes of transport, improve the street environment and to reduce air pollution. The gyratory system serves the Nag’s Head, Seven Sisters Road and Finsbury Park Shopping Centres and encourages vehicles to travel at higher speeds through these areas, which has a negative impact on pedestrian safety in the area (Nag’s Head Town Centre Strategy, 2007, pp13-14). It is noted that this is a long term ambition of the Council and if a gyratory removal scheme were to be brought forward it would be consulted on extensively by TfL.

Policy SP6 – Finsbury Park 2.25 Is the identification of Finsbury Park as a CAZ satellite location for business uses, with the potential for small and medium-sized enterprises (SME) occupation, justified and supported by proportionate evidence?

2.25.1 The spatial policy identifies that Finsbury Park as a satellite location because the Finsbury Park station is well connected to the CAZ through the Piccadilly and Victoria line as well as the wider South East. The ELS specifically states in its conclusions on the spatial distribution of activity that 'while given its hyper-connectivity, Finsbury Park could be a potential satellite location'13 and goes onto say in conclusion that ‘generally, Finsbury Park is the most viable location for encouraging non-CAZ B-use employment generating development, thanks to its excellent transport links’. The central area has seen significant increases in business floorspace in recent years with the delivery of the City North development scheme14. Also rents in Finsbury Park are relatively lower than the CAZ making ability for SME to establish here more viable.

2.25.2 During the last years the Council has created a number of new affordable workspaces in Finsbury Park to accommodate and support entrepreneurial activities in the area which will help deliver social value outcomes for the local community. The council is promoting and enhancing the nascent fashion, tech and creative industries in the area15,therefore, it is essential that the spatial policy recognises the potential that this area has for SME occupation. There are also several site allocations for tall buildings in Finsbury Park which are allocated for significant amount of office space, allowing a satellite CAZ function to be met. Overall, Finsbury Park is a town centre with a variety of retail, leisure and cultural uses that would provide a desirable location for businesses and its workers.

13 Paragraphs 7.7.6 and 8.7.2 ELS (EB4) 14 Paragraph 6.3.28 ELS (EB4) 15 Paragraph 2.70 of the Strategic and Development Management Policies, September 2019 (PD1). 11

London Borough of Islington Matter 2 – Area Spatial Strategies

2.26 Is the approach to residential development in the area spatial strategy justified and consistent with national policy?

2.26.1 Yes. The approach to residential use is set out in part E of the policy. Residential use is not considered to be unacceptable in the spatial strategy area as a whole. Only the PSA of Finsbury Park Town Centre is considered to be inappropriate for residential use. Residential use is positively planned for in the rest of the town centre and in LSAs where located on upper floors to preserve ground floor space for main town centre uses and locate residential uses on upper floors where residential amenity can be preserved. A modification has been made to SP6 for consistency with SP7. See answer to question 2.27. See also response to question 8.7 (Matter 8).

2.26.2 Policy SP6 is consistent with the NPPF which requires at paragraph 85 for policies to promote the long term vitality and viability of town centres by allowing them to grow and diversify in a way that can respond to rapid changes in the retail and leisure industries. A number of sites are allocated with an element of residential, including FP3, FP5, FP7, FP9, FP11, FP13, FP14, Islington’s spatially constrained yet viable town centres require the PSA and ground floor units in the town centre to be retained in commercial use in order to meet the identified floorspace growth and retain a commercial environment that enhances the vitality of these centres. The policy is also consistent with NPPF paragraph 85(f) by locating residential on appropriate sites on upper floors and outside the PSA, retaining commercial vibrancy whilst also ensuring sufficient amenity of new residents in the long term.

2.27 Is the approach to residential development in the area spatial strategy consistent with Policy SP7?

2.27.1 A modification is proposed to ensure consistency.

Proposed modification Amend text as follows:

E. In principle, residential development will only be suitable on upper floors in the Town Centre. Acceptability on upper floors will be judged on a case-by-case basis, factoring in the need to conserve sufficient ancillary space to allow commercial uses to continue to operate successfully as well as other considerations such as amenity impacts.

E. Residential development is considered acceptable on sites allocated for this purpose. Small-scale residential use on upper floors outside the Primary Shopping Area of the Town Centre may be acceptable where it does not adversely impact the commercial function of the centre and where the ability of commercial uses in the area to operate effectively is not compromised.

2.28 Is the approach of Policy SP6 to the specialist shopping area at Fonthill Road justified?

2.28.1Fonthill Road is designated as a Specialist Shopping Area in the adopted Local Plan which has helped its specialist and concentrated fashion function being retained. The

London Borough of Islington Matter 2 – Area Spatial Strategies

street is considered to have the strongest identity of all the shopping streets within Finsbury Park town centre. The street provides a specialist clothing retail offer including a large number of party and bridal dress shops. All units along the street are occupied by independent retailers. Unlike the rest of the centre, provision here is mainly retail, with very few service or leisure occupiers. This unique offer attracts visitors from across and outside of the borough16. 2.28.2 The ELS(2016) identifies Fonthill Road as a recognised clothing fashion cluster and there is a case for building on its brand, and giving it a formal identity. That is why Policy R7 seeks to build on the success of policy DM4.9 by implementing a 75% retail use target threshold to gauge whether the specialist shopping function is being retained and enhanced. The Fonthill Road SSA is a small part of Finsbury Park Town Centre overall and the approach here is considered to be proportionate especially in light of Class E flexibility of existing uses in much of the town centre.

2.28.3 Policy R7 protects and supports Islington’s Specialist Shopping Area at Finsbury Park (Fonthill Road) and an array of markets. The alternative considered was to have a more relaxed Specialist Shopping Area approach alongside the thresholds for the PSA within which the SSA is located. [IIA march 2021, pg 147] The assessment notes that allowing a wider range of uses in SSAs could potentially see increased provision of other retail and services, albeit adding to those already provided in Finsbury Park and Angel; however, on the other hand, the appraisal notes that the alternative policy approach would also likely diminish the function and character of SSAs and affect their unique selling proposition which is important to attracting customers and visitors from outside the borough. On balance whilst the positive effect of a more flexible approach would be to allow more freedom for businesses to respond to changing circumstances with the introduction of new uses which could support the continuation of the SSA the submission policy provides more certainty and protection which ultimately is considered positive for the wider town centre.

Policy SP7 - Archway 2.29 Is the approach to residential development in the area spatial strategy justified and consistent with national policy

2.29.2 Policy SP6 is consistent with the NPPF which requires at paragraph 86 for policies to promote the long term vitality and viability of town centres by allowing them to grow and diversify in a way that can respond to rapid changes in the retail and leisure industries. Islington’s spatially constrained yet viable town centres require the PSA and ground floor units in the town centre to be retained in commercial use in order to meet the identified floorspace growth and retain a commercial environment that enhances the vitality of these centres. The policy is also consistent with NPPF paragraph 86(f) by locating residential on appropriate sites on upper floors and outside the PSA, retaining commercial vibrancy whilst also ensuring sufficient amenity of new residents in the long term. Part I recognises the role of residential in the spatial strategy area. See response also to question 8.7 (Matter 8).

16 Retail and Leisure Study, 2017, paragraph 9.10 13

London Borough of Islington Matter 2 – Area Spatial Strategies

2.30 Is the approach to residential development in the area spatial strategy consistent with Policy SP6?

2.30.1 The approach to residential in SP6 has been clarified for consistency above in 2.27. A small modification is proposed for consistency.

Proposed modification Amend part I text as follows:

2.31 Is the Cultural Quarter designation justified and supported by proportionate evidence?

2.31.1 The Cultural Quarters at Archway Town Centre will help to enhance the existing yet often hidden cultural activity prevalent in Archway. See Cultural Quarter related response in LBI03 which addresses why an alternative was discounted. The SD22 Topic Paper at chapter 10 further justifies the inclusion of Archway as a Cultural Quarter. There are 23 cultural organisations in Archway identified by the Council’s Inclusive Economy Team. 2.31.2 The Retail and Leisure Study (paragraph 8.48) identifies Archway’s limited night time economy as a limitation of the town centre. Attracting a wider range of good quality eateries and bars would help to bolster the night time economy and attract visitors from further afield. The cultural quarter designation aligns with and facilitates this need being met. 2.31.3 Policy HC5 of the London Plan encourages the identification of Cultural Quarters to protect and/or promote cultural activity. Cultural Quarters can be defined around existing clusters of cultural uses or be used to develop new clusters. The Council deem that the designation at Archway is consistent with the London Plan’s intent of cultural quarters and the Mayor welcomed and supported this inclusion at Regulation 18 stage.

Policy SP8 – Highbury Corner and Lower Holloway 2.32 To be positively prepared and justified, should the approach to residential use in the area spatial strategy area be set out?

2.32.1 The approach to residential uses on specific sites is set out in relevant site allocations, while other policies in the plan provide a framework for the approach to residential use in different circumstances. The boundary of the spatial policy area is focused on the station, the gyratory and the Local Shopping Area. Whilst the wider area away from Holloway Road and Upper Street is more residential in nature, residential uses are limited in the spatial strategy area itself as the boundary is tightly drawn to include the commercial areas. Table 1.2 in the Site Allocations document shows that a small amount of residential (50 units) is identified over the plan period. 14

London Borough of Islington Matter 2 – Area Spatial Strategies

2.33 If residential use is considered to be unacceptable in the spatial strategy area, does this comply with the NPPF and the London Plan?

2.33.1 Please see response to 2.32. Residential use is not considered to be unacceptable in the spatial strategy area as a whole. Bunhill and Clerkenwell AAP Policies BC1 – BC8 Policy BC1

2.34 Are the minimum percentages of office floorspace within Part B justified and supported by robust evidence?

2.34.1 Yes, the minimum percentages of office floorspace within BC1 part B are justified and supported by robust evidence. Islington has a significant need for additional office floorspace. Additional office floorspace is required to facilitate business and job growth in Bunhill and Clerkenwell, Islington, and London. The Employment Land Study shows that employment growth projections for Islington for the period 2014-2036 forecast an additional 50,500 jobs, the majority of which are office based jobs. When translated into floorspace requirements, this equates to a requirement for an additional 400,000sqm of office floorspace. Set against this demand, for several years the borough has been losing significant amounts of business floorspace. Between 2015 and 2018 a total of 42,675sqm of office floorspace was lost through redevelopment. Much of this loss is as a result of the office to residential permitted development right. High demand for offices, low supply due to a lack of available land, and ongoing losses to existing supply has created a severely constrained supply demand balance, where demand far outstrips supply. This could be detrimental to sustaining a successful economy and accommodating further economic growth in Islington. The Employment Land Study recommends intensification of office floorspace in the CAZ and recommends prioritising site assembly to provide grade A office floorspace to maintain and enhance the area’s role in supporting London’s strategic business role17. 2.34.2 Covid19 has impacted the office market in Islington however the picture is one more of adjustments rather than radical change. In the tech belt rents remained stable over 2020, and in Q4 2020 the vacancy rate decreased during the quarter from 5.6% to 5.3%. There continues to be limited supply of new build grade A office space, with 60% of the 2.5 million sqft currently under construction already pre let. In the city rents decreased by 5% during the second half of 2020. In Q4 2020 vacancy rates in the city increased from 6.7% to 8.6% but partly due to a significant increase in supply of 29% on the previous quarter18 2.34.3 GLA economics have modelled economic scenarios for London and predict a gradual return to economic growth, with London’s economy is predicted to reach pre-crises levels in Q1 of 2022. 2.34.4 London also remains attractive to international investors, according one global investment tracker a total figure this year is £46bn is intended to be deployed in London, representing a modest 5% decrease on 2020 figures in light of Brexit and Covid19. In London, the

17 page 137 18 Source: https://www.avisonyoung.co.uk/central-london-office-analysis/q4-2020

London Borough of Islington Matter 2 – Area Spatial Strategies

shortage of supply combined with expected growth in new businesses means that every London submarket is predicted to see prime headline rents continue to rise, with city core rents predicted to rise by 2.7% annually for the next five years19 .

2.34.6 The CAZ is the location with the most demand for Grade A office space, and office development in the CAZ can benefit from agglomeration benefits associated with its central London location and access to similar and supporting uses, connections to other office sub markets including the City, the West End, and Canary Wharf.

2.34.7 Further detail on this matter can be found in the Topic Paper – Bunhill and Clerkenwell Area Action Plan” (SD15).

2.35 Should the policy be more flexible to allow for a higher proportion of residential use, where it is proven to be necessary to enhance the viability of a commercial-led mixed-use scheme?

2.35.1 No . Whilst in general residential development has a higher value when compared to commercial development, the difference between the two is not a significant one.

2.35.2 As illustrated in figure 2.17.1 on page 9 of Council’s Draft Local Plan Viability Study (December 2018) (EB17), the viability study adopted a residential sales value of £1,200 per square foot for the northern portion of Islington’s section of the CAZ, and further adopted a residential sales value of £1,395 per square foot in the southern portion of Islington’s section of the CAZ.

2.35.3 In respect to capitalised office values within the south of the borough, Table 4.12.1 on page 25 of the Council’s Draft Local Plan Viability Study (December 2018) (EB17) outlined that within the viability study a rental value of £650 per square metre was adopted for office floorspace which was capitalised with a yield of 5% and also further adopted a 12 month rent free period. This would give a capitalised value for office floorspace of £13,333 per square metre or £1,239 per square foot before the deduction of purchaser’s costs.

2.35.4 It is evident from comparison between the capitalised office value per square foot of £1,239 for office floorspace in the south of the borough with the residential sales values per square of £1,200 and £1,395 adopted within Islington’s section of the CAZ, that there is a fairly marginal difference in value between office floorspace and residential floorspace.

2.35.5 The introduction of residential use within the CAZ is therefore not required to cross- subsidies other commercial land uses, as the high value generated by office developments would be capable of viably supporting other supporting commercial land uses within commercial-led mixed-use schemes.

2.35.6 This is further illustrated through a review of recent permissions within Islington’s part of the CAZ which demonstrates that the market is readily delivering either schemes comprising solely of office floorspace or commercial-led mixed-use schemes without any element of residential use.

19 source: https://content.knightfrank.com/research/104/documents/en/the-london-office-market-report-q4-2020- 7863.pdf 16

London Borough of Islington Matter 2 – Area Spatial Strategies

2.36 Is Policy BC1 positively prepared as regards making adequate provision for commercial uses such as sports and leisure uses, food and drink uses and retail? Will the policy thresholds for office use deter such schemes?

2.36.1 Yes, Policy BC1 is positively prepared with regard to making adequate provision for commercial uses such as sports and leisure, food, drink, and retail uses. The policy allows 10% of the uplift in floorspace to be these other uses in the City Fringe Opportunity Area, and 20% of the uplift in the remainder of the Bunhill and Clerkenwell Area. This will allow these supporting uses to be located in the Bunhill and Clerkenwell Area, supporting the mix and balance of uses in the area. There is capacity to develop approximately 8,300sqm of retail and leisure floorspace in the Bunhill and Clerkenwell AAP site allocations in the plan period (Site Allocation Topic Paper, document SD23, page 9). While Policy BC1 will stop non-office commercial uses in larger schemes being the sole or majority use, there remains adequate capacity to meet the needs of the area and to provide a mix and balance of uses. The policy prioritises office development in the Central London area given the importance of this use in providing employment and economic growth and the limited supply of sites. Other commercial uses including sport and leisure uses and food and drink uses may be developed outside of the Bunhill and Clerkenwell Area without being part of an office led mixed use development.

2.37 Is the reference to ‘majority’ of floorspace in Part C sufficiently clear and therefore effective or should it be quantified by a percentage?

2.37.1 Yes, the reference to the majority of the floorspace, meaning more than half of the floorspace, is sufficiently clear.

2.38 To ensure the effectiveness of Site Allocation BC50, should Part D (ii) be amended to make explicit reference to B1(c) medical and research uses?

2.38.1 No, there is no need to amend BC1 part D(ii) to make explicit reference to B1(c) medical and research uses to ensure effectiveness of BC50. Use Class B1, and the sub-classes of B1(a), B1(b), and B1(c) has been replaced by Class E. As such modification BC-M02 removed reference to B1(c) from Policy BC1 Part D(ii), and modification BC-M49 removed reference to B1(a) and B1(b) from site allocation BC50.

2.38.2 The allocation of BC50 states that development may include some office space and research space linked to overarching higher education, medical, and/or research uses. The Council considers that this is a clear allocation.

2.39 Should Part D (iii) include reference to non-residential institutions?

2.39.1 No. Policy BC1 Part D(iii) states is the exception for where a proposal is publicly funded or serves a public service, such as educational, medical, or research institutions. This could include non-residential institutions, however the Council consider that this is clear without setting out the additional use classes or types that could fall under the criteria for a publicly funded use or a use serving a public purpose.

2.40 Should Part D (iv) be amended to provide additional flexibility for predominantly residential areas and semi residential areas?

London Borough of Islington Matter 2 – Area Spatial Strategies

2.40.1 The Council has considered this question and agree that a modification is justified to Policy BC1 Part D(iv) to change the exception in this criterion to apply to ‘predominantly residential areas’ instead of ‘wholly residential areas’ as currently drafted. The Council considers that there will be areas which are predominantly (but not wholly) residential where introduction of new office uses may be better suited to development of residential uses instead of offices, considering character, amenity, and the desirability of predominantly residential locations for office users. This modification allows a greater degree of planning judgement to be exercised in the implementation of this land use policy.

Proposed modification

Policy BC1 Part D(iv): “development which is proposed in wholly predominantly residential parts of the AAP area, such as housing estates”

2.41 Should Part D include an additional criterion to allow for mixed-use developments that provide enhanced social value and enhanced provision of community facilities?

2.41.1 No. Where community facilities are proposed they will be allowed under Policy BC1(iii) as the community facility will serve a public purpose. With regard to social value Policy SC4 states that development is encouraged to maximise social value. Under Policy BC1 this could be provided in a use with serves a public purpose, or as a use in an office led mixed use development that meets the office floorspace targets of BC1.

Policy BC2

2.42 To be effective, is the term ‘predominantly commercial areas’ in Part A sufficiently precise? Should it be defined to include the City Fringe Opportunity Area?

2.42.1 The Council considers that the term ‘predominantly commercial areas’ used in BC1 Part A is sufficiently precise, given then range and complexity of built form and land use context across the AAP area, and with a view to not unnecessarily constraining development of Culture, retail, and leisure uses.

2.42.2 The policy directs cultural, retail, and leisure uses to the Local Shopping Areas and predominantly commercial areas. The use of the term predominantly commercial areas has been included to ensure that appropriate sites are not unnecessarily excluded from development. The Bunhill and Clerkenwell AAP area extends over a large area of Islington’s Central Activities Zone. The pattern of development across this area is dense with a rich variety of different land uses. A project to identify sites suitable for these uses undertaken at a strategic level, in addition to the Local Shopping Areas already identified, would likely suffer from being either too permissive, or too restrictive. A development that may be acceptable on one side a street may not be acceptable on the other side. The Council considers that it is appropriate to allow the determination of the suitability for a site for cultural, retail, or leisure use to be allowed to take place on a site by site basis, to allow for this complexity.

London Borough of Islington Matter 2 – Area Spatial Strategies

Proposed modification

Amend text as follows: The Clerkenwell/Farringdon Cultural Quarter is the focus for cultural uses. Such uses may also be suitable in other predominantly commercial areas subject to compliance with other relevant policies, pending assessment of sequentially preferable sites within the cultural quarter.

2.18 Proposals for cultural use outside the cultural quarter will need to be sequentially justified; applicants must provide detailed evidence to demonstrate that there are no sequentially preferable locations within the cultural quarter that could accommodate the proposal. Relevant guidance on the application of the sequential test must be used to inform any evidence provided, particularly national Planning Practice Guidance (PPG).

2.19 Where a cultural/creative use is proposed outside the cultural quarter, the Council must be satisfied that suitable and available sites within the cultural quarter have been considered first. This will ensure that there are no preferable sites available here which would contribute to the further enhancement of the cultural quarter. The sequential consideration of preferable sites must assess both availability of sites and suitability of sites for the intended cultural use. The sequential consideration should be proportionate to the scale and type of cultural use. If it can be demonstrated there are no suitable and available sites within the cultural quarter, cultural use is acceptable in principle across the AAP area, although suitability will be assessed against relevant policy – such as policies to protect residential amenity and promote office development – on a case-by-case basis.

Please also refer to question 8.42.

Policy BC3

2.43 To be effective, are the terms ‘substantial amount of affordable workspace’ and ‘necessary social infrastructure’ within Part B sufficiently clear? Have such requirements been subject to robust viability assessment?

2.43.1 Yes, these terms ‘substantial amount of affordable workspace’ and ‘necessary social infrastructure’ within Part B are sufficiently clear as this policy criterion and expectations for the site should also be understood with regard to Development Management Policy B4 which states that major office developments should provide 10% affordable workspace as a proportion of proposed office floorspace for at least 20 years at peppercorn rent. In addition, Moorfields Eye Hospital has a site allocation within the plan (reference BC38) which sets out the requirements for this site, however specific floorspace targets for social infrastructure are not stipulated in the site allocation.

2.44 Is Part G justified in precluding any development in the centre of the Old Street roundabout?

2.44.1 Yes, policy BC3 Part G is justified in precluding development in the centre of the Old Street Roundabout. While the Council acknowledges the benefits of development in the wider Old Street area the Council priority for this key location of Old Street roundabout, is to maintain its critical role as a transport hub handling a very high volume of journeys. It is important to 19

London Borough of Islington Matter 2 – Area Spatial Strategies

improve public realm, public open space, and improved access to the station to facilitate this role. This allocation is justified by the strategic location of the Old Street roundabout as the central public space of the East London Tech City Area and entrance to a major national rail link. An attractive efficient public realm is key to the success of the area. The policy and allocation allows some small scale retail development. The redevelopment of this area is well underway at time of writing.

Policy BC4

2.45 For clarity (and effectiveness), does the policy need to stipulate the circumstances, if any, where residential use might be appropriate?

2.45.1 No, the Council considers that Policy BC4 does not need to stipulate the circumstances where additional residential development might be appropriate, as residential development will be appropriate throughout the spatial strategy areas provided that it meets Policy BC1, or if the site is specifically allocated for residential development as part of a site allocation.

2.46 Is the strategy for residential moorings, set out within Part G justified?

2.46.1 Yes, the approach to residential moorings set out in Policy BC4 Part G is justified as it balances the competing interests in use and enjoyment of the canal waterspace and corridor, including the use for boaters and navigation, as an open space, and a green space and biodiversity habitat. The Council supports development of new residential moorings where appropriate, including where they do not impact on leisure provision, and where there is no detrimental impact on the canal with regard to character, nature conservation, and air quality. Refer to question 3.57 for information on how the identified needs of boat dwellers will be met by the Local Plan.

2.47 Will the redevelopment of Finsbury Leisure Centre be consistent with national policy, namely NPPF paragraphs 96 and 97?

2.47.1 Yes, any development of the Finsbury Leisure Centre will be consistent with national policy, including NPPF paragraphs 96 and 97. Paragraph 67 requires that planning policies should be based on robust and up to date evidence with regard to open space, sport and physical activity. Paragraph 67 of the NPPF states that existing open space, sport and recreational buildings should not be built on unless an assessment shows that the space is surplus to requirements, the loss is offset by equivalent or better provision, or the development is for alternative sports and recreation provision where the benefits clearly outweigh the loss of the current or former use.

2.47.2 The Finsbury Leisure Centre is allocated in the Bunhill and Clerkenwell AAP as site BC4. The site is allocated for “redevelopment of the existing site to provide new high quality leisure facilities and meet increased demand, as well as a nursery, energy centre, housing (including a significant amount of genuinely affordable housing) and public open space.” The Council has also produced a planning brief for the site and ran a competition for redevelopment of the site with the winning scheme awarded to Pollard Edward Thomas. No planning application has been submitted.

London Borough of Islington Matter 2 – Area Spatial Strategies

2.47.3 The Finsbury Leisure Centre is protected by policy SC1 which states that the Council will not permit any loss of social and community infrastructure uses unless a replacement facility of equal or better quality is provided on-site or the existing use is not required on site, demonstrated through either a marketing exercise or a Community Needs Assessment. The Council will only permit development that is in accordance with the NPPF and Policy SC1.

Policy BC5

2.48 Is there text missing from the first sentence of Parts F & G?

Yes, please see suggested modifications below.

Proposed modifications:

F: Development in this area should, where appropriate, Measures to facilitate ease of movement and modal interchange, including secure cycle parking, cycle hire docking stations, cycle lanes along Charterhouse Street, taxi ranks, improved bus provision, pedestrian signage, and restrictions on delivery and servicing during daytime hours. Servicing must be located to remove conflicts and maximise efficiency of space and use. Shared service bays, basements and access/egress with neighbouring buildings must achieve the most efficient use of space and must not be located in a prominent location which affects promotion of sustainable travel modes. G. Development in this area should provide Aan improved public realm which promotes pedestrian circulation and which results in a series of integrated, linked and high quality public spaces, including neighbouring spaces such as Clerkenwell Green.

2.49 Is the Spatial Strategy area correctly outlined on Figure 3.4?

2.49.1 No, the boundary of the spatial strategy area for Farringdon is missing from Figure 3.4. We will prepare an amended map with this corrected.

2.50 For clarity (and effectiveness), does the policy need to stipulate the circumstances, if any, where residential use might be appropriate?

2.50.1 No, the Council considers that Policy BC5 does not need to stipulate the circumstances where additional residential development might be appropriate, as residential development will be appropriate throughout the spatial strategy areas provided that it meets Policy BC1, or if the site is specifically allocated for residential development as part of a site allocation.

2.51 Is Part G comprehensive in terms of its reference to transport matters? To be effective, are there any specific initiatives worth mentioning?

2.51.1 The policy sets out the priorities for transport improvements in the area, including Part F which states that measures should facilitate ease of movement and modal interchange 21

London Borough of Islington Matter 2 – Area Spatial Strategies

however specific schemes are not set out as these are programmed and coordinated in detail in the Transport Local Implementation Plan where the priority, funding, and construction capacity can be managed. In addition, as developments come forward in this area they may also be required to improve the transport and servicing connections and facilities on and immediately around the development site.

2.52 Is Part H justified and what evidence underpins the statement that the railway cuttings have heritage value?

2.52.1 The heritage value of the cuttings themselves has not been established by a specific evidence document, however they are likely to contain fabric and features which may have heritage value and this should be assessed as part of any redevelopment. The railway cuttings in this location are the earlier ‘cut and cover’ type and are some of the earliest underground lines in London, completed in the late 1800s. The cuttings are not listed or locally listed however Farringdon Station is Grade II listed.

Policy BC6

2.53 Part B states that the mix of uses within Exmouth Market Local Shopping Area must be managed to support the vitality and viability of the centre, while not harming local character or amenity. Will this be effective, and does it provide sufficient certainty to guide applicants?

2.53.1 Yes, BC6 Part B will be effective and provide certainty to applicants on development in this area. Exmouth Market is a Local Shopping Area under the Local Plan, and under Policy BC2 the Council encourages development of retail and leisure uses in these areas, as well as requiring that active frontages are provided. The policy should be read in conjunction with Policy R4 for Local Shopping Areas in the Development Management Policies. Under Development Management Policy R4 all development in Local Shopping Areas must maintain and enhance the retail and service function of these areas, and proposals for change of use from Class E to non Class E Main Town Centres Uses is restricted, as is development of residential.

2.54 Is Policy BC6 comprehensive as regards transport initiatives, for example to be effective does it need to cross refer to the Clean Air Walking route along Amwell St to Farringdon?

2.54.1 The policy sets out the priorities for transport and public realm improvements in the area however specific schemes are not set out as these are programmed and coordinated in detail in the Transport Local Implementation Plan where the priority, funding, and construction capacity can be managed. In addition, as developments come forward in this area they may also be required to improve the transport and servicing connections and facilities on and immediately around the development site. The Council does not consider it necessary to add reference to the Clean Air Walking Route specifically as the area action plan does not include reference to initiatives such as this however the importance of the

London Borough of Islington Matter 2 – Area Spatial Strategies

route for walking and cycling and its lower level of air pollution are understood and valued by the Council.

2.55 What is the status of the Mount Pleasant Sorting Office site? How far has the permitted development progressed?

2.55.1 Development at the Mount Pleasant Sorting Office (planning application P2013/1423/FUL) has commenced but has not completed yet, with completion anticipated for 2025. A further application has been received (P2021/1479/S73) for a change the internal arrangement to provide an additional 34 homes.

Policy BC7

2.56 Will the redevelopment of Finsbury Leisure Centre be consistent with national policy, namely NPPF paragraphs 96 and 97? (See similar question in relation to Allocation BC4)

2.56.1 Please refer to the answer for question 2.47, above.

2.57 Respondents have referred to the Bunhill and Clerkenwell Urban Design Study 2010, page 45 of which, allegedly states that additional housing is not required. Is this document relevant and if not why not? (Please can the Council supply relevant extracts)

2.57.1 The Bunhill and Clerkenwell Urban Design Study 2010 was commission by Islington Council as an evidence document for the Finsbury Local Plan (2013). The document set development quantum for the Bunhill and Clerkenwell Area, including 2,750 homes, which is stated on page 45. Given the age of the document, most aspects, including planning for housing have since been superseded by more recent documents and evidence, and in particular in the evidence base for the Local Plan. The document is therefore of little relevance to the matter of redevelopment of the Finsbury Leisure Centre. Nevertheless, there is no indication in this document that there should be a limit placed on residential development in this area or on this site. The Finsbury Leisure Centre site (Site 2 in the document) is identified as a site with potential for long term development for community led mixed use.

2.58 Are paragraphs 3.60 to 3.64 setting out policy? If so, for effectiveness, should it be incorporated into the policy?

2.58.1 It is agreed that paragraphs 3.60 to 3.63 should be moved to the policy box above. Paragraph 3.64 does not contain policy, but rather sets out that the Council will implement public realm improvements in the area.

London Borough of Islington Matter 2 – Area Spatial Strategies

Proposed modifications:

BC7 New Part I: Development along Central Street should improve the relationship between buildings and spaces along Central Street.

BC7 part H: Development should Public realm improvements should facilitate easy pedestrian and cyclist access through and within the area, in line with pedestrian and cycle desire lines and should improve and better connect green spaces in the area where feasible.

BC7 new part J: The design of new development across the area must respond to local context. Development proposals (including the redevelopment of existing buildings) must: • be based on a human scale and reflect the predominant building height; • enhance definition between public and private spaces and provide improved access and permeability; • where appropriate, provide and enhance definition, enclosure and active edges to Central Street, Central Square, Goswell Road, Moreland Street and other important pedestrian routes; and • re-establish traditional building lines.

BC7 new part K: Development proposals should contribute to an enhanced public realm, including through: • extension, retention or re-provision of existing green spaces and provision of new green and/or open spaces such as pocket parks; • incorporation of significant tree planting along key routes to reinforce their primacy in the street hierarchy; and • improvements to pedestrian and cycling connections.

Paragraph 3.62 “The design of new development across the area must respond to local context. Development proposals (including the redevelopment of existing buildings) must: • be based on a human scale and reflect the predominant building height; • enhance definition between public and private spaces and provide improved access and permeability; • where appropriate, provide and enhance definition, enclosure and active edges to Central Street, Central Square, Goswell Road, Moreland Street and other important pedestrian routes; and • re-establish traditional building lines.

Paragraph 3.63: “Development proposals should contribute to an enhanced public realm, including through:

London Borough of Islington Matter 2 – Area Spatial Strategies

• extension, retention or re-provision of existing green spaces and provision of new green and/or open spaces such as pocket parks; • incorporation of significant tree planting along key routes to reinforce their primacy in the street hierarchy; and • improvements to pedestrian and cycling connections.”

Policy BC8

2.59 For effectiveness, are amendments required to ensure that the policy and its supporting text are consistent, particularly in relation to commercial uses (paragraph 3.68) and public realm (paragraphs 3.75-3.77)?

2.59.1 Yes, the following amendments are suggested to ensure consistency:

Proposed modifications:

Paragraph 3.68: Commercial uses, particularly small scale employment uses (e.g. design and light manufacturing) are an intrinsic part of the unique character if the area. Protection of these uses is therefore important to protect local character and ensure that the areas diverse commercial role is supported and retained. Office/business uses, especially those which complement the existing commercial uses, must be maximised where development does come forward. A range of business activities (including smaller workspaces for creative and specialist industries, which are under pressure from increased land values) are encouraged as well as active ground floor uses fronting major roads and key streets, to provide diversity and interest.

Policy BC8 Part A: The Council will preserve and enhance the special historic character and appearance of the Historic Clerkenwell area, which reinforces its uniqueness, integrity and socio- cultural value. Limited Commercial development, particularly business workspaces suitable for SMEs and/or specialist industries, and small-scale retail and leisure uses, may be acceptable where it is contextual and of a high quality.

Insert a new Policy criterion BC8 Part B: The Council will protect existing employment uses. In addition, a range of business activities including smaller workspaces for creative and specialist industries are encouraged, provided they are in accordance with Policy BC1. Active ground floor uses fronting major roads and key streets are encouraged.

Paragraph 4.75 remains the as drafted, but a policy criterion is added to link to the policy text box in BC8. New Policy Criterion BC8 Part G: G: Development should provide additional public space by transferring underused roads and parking areas into pedestrian use where appropriate. Public realm and 25

London Borough of Islington Matter 2 – Area Spatial Strategies

street improvements are encouraged to improve conditions for walking and cycling, improve amenity and biodiversity.

Paragraphs 3.76 and 3.77 do not create inconsistency and should remain as drafted.

Appendix 1: Overview of land uses in the Vale Royal/Brewery Road LSIS This map is a recent edit submitted to AECOM who are preparing the London Industrial Land Supply Study 2020 for the GLA (work in progress). The information shown informs part of a strategic GLA Study prepared under a bespoke study-specific methodology, which amongst other considerations, does not attempt to provide detailed information on land uses at a very local scale.

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XX)()( SHEET UILE lndustrial l aodlJsesattheYale ___... Ro-,111 and Brewery Road LSIS 50 SHEET NUMBER FIGURE 1