PLANNING STATEMENT
DP9 LTD August 2016
Planning Statement Elephant & Castle Town Centre
CONTENTS PAGE NO.
1.0 INTRODUCTION 2
2.0 SITE DESCRIPTION 6
3.0 PROPOSED DEVELOPMENT 12
4.0 PRE-APPLICATION CONSULTATION 19
5.0 REGENERATION AND COMMUNITY BENEFITS 23
6.0 PLANNING POLICY ASSESSMENT 25
7.0 PRINCIPLE OF DEVELOPMENT 28
8.0 EXISTING USES 36
9.0 COMMERCIAL USES 39
10.0 LEISURE AND EDUCATIONAL USES 43
11.0 RESIDENTIAL USE 46
12.0 DESIGN MATTERS 51
13.0 TRANSPORT AND ACCESS 57
14.0 ENVIRONMENTAL CONSIDERATIONS 65
15.0 DRAFT SECTION 106 HEADS OF TERMS 76
16.0 CONCLUSION 77
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1.0 INTRODUCTION
1.1 This Planning Statement has been prepared by DP9 Ltd to accompany the application for planning permission submitted on behalf of Elephant and Castle Properties Co. Limited (hereafter referred to as the ‘Applicant’) for the proposed Elephant & Castle Town Centre development (hereafter referred to as the ‘Proposed Development’).
The Application
1.2 Detailed planning permission is sought for the phased mixed use redevelopment of Elephant and Castle Shopping Centre site (hereafter referred to as the ‘East Site’) and the London College of Communication (LCC) site (hereafter referred to as the ‘West Site’). The East and West Sites comprise the overall ‘Application Site’. The Application Site is 3.56ha and is located within the London Borough of Southwark (LBS).
1.3 The Description of Development proposed is as follows:
“Phased mixed use redevelopment of the existing Elephant and Castle Shopping Centre and London College of Communication sites comprising the demolition of all existing buildings and structures and redevelopment to include buildings ranging in height from single storey to 34 storeys (with a maximum building height of 124.5 m AOD) above basement (and additional space at mezzanine level within basements) to provide a range of uses including residential units (Use Class C3), retail (Use Class A1-A4), office (Use Class B1), education (Use Class D1), assembly and leisure (Use Class D2), and a new Station Entrance and Station Box for use as a London Underground operational railway station. The proposed development will also include new means of access, highway works, public realm and landscaping works, parking and cycle provision, plant and servicing, and a range of other associated and ancillary works and structures.”
1.4 Alongside the detailed planning application, an associated listed building consent application is submitted in relation to minor works proposed to the Grade II listed London Metropolitan Tabernacle associated with the redevelopment of the West Site.
1.5 This Statement assesses the planning considerations associated with the Proposed Development and considers the Development in the context of national, regional and local planning policy and guidance. Section 6 of this Statement provides an overview of the key policy and guidance relevant to the determination of the Proposed Development, whilst the text throughout the Statement refers to the relevant policy and guidance where necessary.
Application Structure
1.6 This Statement should be read in conjunction with the documents, plans and technical studies submitted to accompany the planning application, as set out below. The format of the planning application has been discussed and agreed with the London Borough of Southwark (the “Council”) as part of the pre-application discussions, and a Planning Performance Agreement, which are outlined in Section 4 of this Statement.
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Planning Application Documents
Planning Application Form, including the Ownership Certificate, prepared by DP9; Community Infrastructure Levy (CIL) Form prepared by DP9; Drawings (Plans, Sections and Elevations) prepared by Allies & Morrison; Landscape Drawings, prepared by Townshend; Design and Access Statement prepared by Allies & Morrison; Planning Statement including Draft Section 106 Heads of Terms, prepared by DP9; Retail Impact Assessment prepared by DP9; Regeneration Statement prepared by Regeneris; Statement of Community Involvement (SCI) prepared by Carvil Ventures; Transport Assessment prepared by WSP | Parsons Brinckerhoff; Draft Interim Framework Travel Plan prepared by WSP | Parsons Brinckerhoff; Delivery and Servicing Plan prepared by WSP | Parsons Brinckerhoff; Construction Management Plan prepared by MACE; Waste Management Strategy prepared by WSP | Parsons Brinckerhoff; Arboricultural Impact Assessment prepared by Waterman; Affordable Housing Statement prepared by DS2; Energy Statement prepared by Hoare Lea; Sustainability Strategy including BREEAM Pre-assessment prepared by Hoare Lea; Equalities Statement prepared by Quod; Rapid Health Impact Assessment prepared by Ricardo; Internal Daylight and Sunlight Report prepared by Hoare Lea; and, Environmental Statement coordinated by Waterman.
1.7 The planning application is accompanied by an Environmental Statement (‘ES’). This document has been prepared and coordinated by Waterman, with input from WSP | Parsons Brinckerhoff, MOLA, Hoare Lea, RWDI and Regeneris to assess the environmental implications of the Development. It comprises of the following:
Non-Technical Summary Volume 1: Main Text Volume 2: Figures Volume 3: Townscape, Visual and Built Heritage Assessment (prepared by Tavernor) Volume 4: Appendices. 1.8 A Financial Viability Assessment prepared by DS2 has been submitted under separate cover to the Council on a private and confidential basis.
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Listed Building Consent Documents
1.9 The Listed Building Consent Description of Development proposed is as follows:
'Minor alterations to the northern elevation of the Grade II listed Metropolitan Tabernacle building, by virtue of the demolition of the immediately adjacent/abutting London College of Communications building (subject to separate planning application).'
1.10 The following plans and documents are submitted as part of the Listed Building Consent:
Site Location Plan – Proposed ref. 935_00_07_002 Existing West Site - Roof Plan ref. 935_02_07_050 Existing West Site - East Elevation ref. 935_02_07_020 West Site - Ground Floor Plan ref. 935_02_07_100 West Site - Newington Butts Elevation ref. 935_02_07_210 West Site - South Elevation ref. 935_02_07_212
1.11 The submitted Design and Access Statement and Volume 3 of the ES (Townscape, Visual and Built Heritage Assessment) should be read in conjunction with the Listed Building Consent application.
Structure of the Statement
1.12 This document provides an overview of the Application Site and the Proposed Development and sets out a justification for the development. The Planning Statement takes the following form:
Section 2 provides a description of the Application Site and surrounding context; Section 3 sets out a summary of the Proposed Development; Section 4 summarises the consultation process; Section 5 sets out a summary of the main regeneration and community benefits; Section 6 summarises the relevant national, regional and local planning policy; Section 7 considers the principle of development; Section 8 assesses the loss or re-provision of the existing uses against applicable planning policy; Section 9 assesses the commercial elements against applicable planning policy; Section 10 assesses the leisure and educational elements against applicable planning policy; Section 11 assesses the residential elements against applicable planning policy; Section 12 considers proposed design against relevant planning policy; Section 13 summarises transport issues the against applicable policy; Section 14 summarises other relevant environmental considerations;
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Section 15 sets out the Draft Section 106 Heads of Terms; Section 16 sets out the overall conclusions.
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2.0 SITE DESCRIPTION
2.1 This section of the Planning Statement provides details of the Application Site in its existing condition, as well as its immediate surroundings.
The Application Site
2.2 The Application Site is located within the geographical area of the London Borough of Southwark (“LBS”), who are the Local Planning Authority (“the Council”). The 3.56ha Application Site is located at the heart of Elephant and Castle Town Centre, bisected by Newington Butts (A3) on a north-south axis. The Application Site occupies two individual sites in prominent positions immediately southwest and southeast of the Elephant and Castle roundabout.
2.3 The ‘East Site’ comprises the existing Elephant and Castle Shopping Centre, to its northeast the London Coronet Theatre, Charlie Chaplin public house, market stalls, newsagent and dental surgery, as well as the London Underground Northern Line station entrance and Northern Line ticket hall. The Elephant and Castle Rail Station is located to immediately to the east, accessed through the shopping centre and Elephant Road. Elements of the railway viaduct and arches are within the Application boundary. The East Site is bounded by:
New Kent Road (A201) to the north; A recently improved former roundabout (hereafter referred to as the ‘peninsula’) to the northwest; Elephant and Castle Rail Station, viaduct, arches and Elephant Road to the east; Walworth Road (A215) to the south; The ‘Southern Junction’ to the southeast; and Newington Butts to the west (A3).
2.4 The West Site comprises the existing UAL London College of Communication (UAL:LCC). The West Site is bounded by:
St George’s Road (A302) to the north; Newington Butts (A3) to the east; The London Metropolitan Tabernacle to the southeast Brook Drive and Pastor Street to the southwest; and, Oswin Street to the west.
2.5 The Application Site boundary is defined as follows:
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Figure 1: Existing Buildings and Site Boundary
2.6 When considering the East Site in further detail, in particular its key constituent parts, quantum of floorspace, height and massing:
The Elephant and Castle Shopping Centre is split across three storeys (plus basement) and approx. 65 occupiers. An external market is located to the north, between the shopping centre and New Kent Road. The London Coronet Theatre is a three storey building fronting New Kent Road, north of the shopping centre. Together, the retail and leisure uses comprises 27,204sq.m (GIA) floorspace. The existing bowling, bingo and cinema operations account for 12,071sq.m (GIA). In addition, Hannibal House, a 1960s 16 storey office block sits above comprising 10,669sq.m (GIA) floorspace. The buildings take up a significant area of land, with localised areas of public realm at the north-western and south-western corners. The railway viaduct comprises four arches within the East Site boundary. 2.7 When considering the West Site and its key constituent parts, quantum of floorspace, height and massing:
The existing UAL:LCC comprises a four storey building with central 16 storey administrative element. Overall, the UAL:LCC buildings comprise 31,553sq.m (GIA) floorspace. A small area of car parking is located to the north, adjacent to St George’s Road. 2.8 The table below summarises the quantum of existing floorspace on the Application Site as a whole.
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USE LAND USE GIA m2 GEA m2 CLASS EAST SITE Elephant & Castle Shopping Centre A1-A4, D2 27,204 28,284 Hannibal House B1 10,669 11,130 London Underground Limited 3,965 - Total 41,838 - WEST SITE UAL:LCC D1 31,553 32,886 Total 31,553 32,886 TOTAL 73,391 - Table 2.1 – Quantum of Existing Development
2.9 The Application Site forms part of the wider Elephant and Castle Opportunity Area within LBS. The Council aspires to regenerate the Opportunity Area to realise its potential and create a better town centre and high density new mixed-use neighbourhood, incorporating a cluster of tall buildings. Given the site’s prominence within the Opportunity Area, it represents a strategically important location for development. The Opportunity Area spans 122 ha. with a main objective of delivering 5,000 new jobs, 4,000 new homes and 45,000sqm of new shopping and leisure floorspace.
2.10 From a purely aesthetic perspective, the existing buildings on both East and West Sites are of poor quality and do not engage with the surrounding area in any meaningful way. This is in part due to their original design and age, but is clearly amplified by their relationship with the newly upgraded street scene and various neighbouring developments in and around Elephant and Castle.
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Figure 2: The Site in Context (Looking South)
2.11 The Application Site is classified within Elephant and Castle Major Town Centre. It is highly accessible by Public Transport with a Public Transport Accessibility Level (PTAL) of 6B, which represents the highest level of accessibility and defined by TfL as ‘Best’.
2.12 The Application Site benefits from access to two London Underground lines (Northern via Bank, and Bakerloo), with access to these services located within the East Site. Furthermore, Elephant and Castle National Rail station is located immediately east of the East Site, which offers Thameslink services to north and south London, as well as beyond, whilst South Eastern services also utilise this station. There are also a large number of bus stops situated on the surrounding highway network, as well as cycle superhighway CS7 which runs perpendicular to the West Site boundary, along Elliot’s Row.
2.13 The Application Site is located within an Air Quality Management Area (AQMA) and Flood Zone 3, as defined by the Environment Agency (it does, however, benefit from Thames River flood defences).
The Surrounding Area
2.14 The surrounding area consists of a mix of predominately post-war housing and more recent contemporary additions associated with the wider regeneration of Elephant and Castle.
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2.15 To the north is the former Elephant and Castle roundabout, now known as the ‘peninsula’ which has recently undergone significant improvement works by TfL to rationalise the road network and enhance the public realm, aiming to improve permeability and pedestrian experience. The Michael Faraday Memorial (Grade II listed) sits within the new pedestrian peninsula.
2.16 A London Underground entrance and Skipton House are located on the north side of the peninsula on the opposite side of the highway, whilst the LSBU campus is further to the northwest. Eileen House (now known as Two Fifty One) is located to the north east – it is a development project which obtained planning permission in January 2014 and when completed will deliver 335 dwellings, 4,785sqm of office floorspace, and 287sqm retail floorspace in a building of 41 storeys (128.7m AOD).
2.17 In addition to the various regeneration schemes in close proximity to the Application Site, the wider Elephant and Castle area is being transformed following its designation as an Opportunity Area, with the Strata tower at 147m being one of the first symbols of its rejuvenation. In recent years a number of planning permissions have been granted for major developments, including tall buildings. Of these, a number are currently on-site, at pre-construction stage, or completed. These schemes, which will further assist in transform this area of Southwark, and central London, include:
Elephant Park – the comprehensive redevelopment of the former Heygate Estate is being delivered by Lend Lease, with outline planning permission granted for a phased development consisting of circa 2,500 homes, 15,000 sqm of retail, 5,000 sqm of office, 10,000 sqm of community and leisure, a new energy centre and district heating network, and a new park. Construction is underway on the first phase with the whole development anticipated to be complete in 2025; One The Elephant – Lend Lease is also delivering this 37 storey (127m) residential tower comprising 284 residential units, with ancillary retail at ground floor; The New Elephant and Castle Leisure Centre – is being delivered by the Council and opened in May 2016; 360 London – proposals for a 44 storey (152.8m AOD) residential-led tall building are under construction; Elephant One – proposals for a 25 storey (87.5m AOD) building by Oakmayne and Delancey, comprising 373 rented homes, 272 student residences, a supermarket, cinema and new retail units; The Signal Building, 89-93 Newington Causeway – Neobrand is delivering a 22 storey (69.8m) residential-led development, which is nearing completion; and 128-150 Blackfriars Road – Barratt London obtained planning permission for a 27 storey (96.5m AOD) residential-led tower, which is now under construction. Skipton House – subject to a resolution to grant planning permission in July 2016; comprehensive redevelopment scheme comprising over 400 residential units and commercial floorspace, a large proportion for office use (approx. 49,000sq.m).
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2.18 Further details of the Application Site and the surrounding area can be found in the Design and Access Statement submitted to accompany the planning application.
Heritage
2.19 The Application Site is not located within a conservation area, nor are any of the buildings on the Application Site listed.
2.20 There are two listed buildings in close proximity to the Site, including:
Grade II Michael Faraday Memorial and electricity substation (1960-61) - located within the Elephant and Castle peninsula to the north of the Site; Grade II London Metropolitan Tabernacle on Newington Butts – located to the south of the Application Site. This comprises a Baptist church, originally dating from 1859-61, 1898 (facade), and extensively rebuilt in c.1959. The building is listed due to its façade only. 2.21 A separate but related Listed Building Consent application is submitted for party wall works required to the north elevation of the London Metropolitan Tabernacle, required as a result of the Proposed Development.
2.22 The nearest conservation areas are the Elliot’s Row and West Square Conservation Areas, both situated further west of the West Site.
2.23 Part of the Application Site is located within the Kennington Road and Elephant and Castle Archaeological Priority Zone.
Planning History
2.24 The Application Site has been subject to various planning applications, albeit, these have sought minor development and are not relevant to this development proposal given its scale.
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3.0 PROPOSED DEVELOPMENT
3.1 This section details what is being applied for in the full planning application for the Proposed Development.
Description of Development
3.2 This section should be read in conjunction with the Design and Access Statement, which is submitted to accompany the planning application and further describes the principal components of the Proposed Development.
3.3 The planning application seeks full planning permission for:
“Phased mixed use redevelopment of the existing Elephant and Castle Shopping Centre and London College of Communication sites comprising the demolition of all existing buildings and structures and redevelopment to include buildings ranging in height from single storey to 34 storeys (with a maximum building height of 124.5 m AOD) above basement (and additional space at mezzanine level within basements) to provide a range of uses including residential units (Use Class C3), retail (Use Class A1-A4), office (Use Class B1), education (Use Class D1), assembly and leisure (Use Class D2), and a new Station Entrance and Station Box for use as a London Underground operational railway station. The proposed development will also include new means of access, highway works, public realm and landscaping works, parking and cycle provision, plant and servicing, and a range of other associated and ancillary works and structures.”
The Proposed Development
3.4 The Proposed Development is a truly mixed-used scheme. The Proposed Development seeks to deliver a new and revitalised shopping centre for Elephant & Castle town centre, plus new leisure, food and beverage options, alongside a new home for UAL:LCC, notwithstanding significant residential provision.
Figure 3: Diagram Illustrating Proposed Plots
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3.5 The Proposed Development will play an important role at both the strategic and local level; the regeneration of the Application Site will deliver a significantly improved shopping centre comprising shops, cafes, bars and restaurants (Class A1-A4), office provision (Class B1), a new modern education facility for UAL:LCC (Class D1), a new music venue and multi-screen cinema (Class D2), and 979 residential units (Class C3), in a high quality development that will contribute towards fulfilling the vision for Elephant & Castle. A new station box will provide an upgraded ticket hall and entrance to the Northern Line.
3.6 The Proposed Development includes provision of 35% affordable housing (calculated by habitable rooms) which equates to 342 affordable homes with a mix of 1, 2 and 3 bed accommodation. The affordable homes will be located across the site and mixed with the open market accommodation, in a tenure blind development, with all residents benefitting from the same amenities. It is intended that all affordable homes will be delivered on Assured Shorthold Tenancies of up to three years with tenant only break options.
3.7 The affordable housing will be made available to a wide range of income levels at a range of discounts to market rent and inclusive of service charge. The affordable housing offer is designed to meet the needs of a significantly greater number of households than would be met by a traditional affordable housing offer and the overall percentage has been maximised by taking this approach, in line with emerging planning policy on such matters.
3.8 The Proposed Development comprises the phased demolition of all existing buildings on the Application Site, and will be followed by comprehensive phased redevelopment.
East Site Summary
3.9 The East Site is split into four distinct plots (E1 to E4), set around a new public square. Further areas of public realm are proposed at the north-western and south- western corners onto the peninsula and Newington Butts respectively. In addition, the East Site comprises a new station box and proposals for the railway viaduct arches comprising new pedestrian routes, shops, cafes, bars and restaurants. The East Site also comprises a basement and basement mezzanine – this will be used to service the shopping centre and provide disabled car parking, cycle parking and ancillary facilities as well as provide the new UAL:LCC building with below ground space for teaching facilities such as studios and area to service their building. Vehicular access to the basement is from a ramp off New Kent Road (north).
3.10 Plot E1 comprises:
A new educational facility for UAL:LCC (Class D1); 12-storeys above ground, rising to 55.2m AOD; Retail use at ground floor (Class A1/A2/A3/A4); Commercial/workspace at first and second floor (Class A1/A2/A3/B1); New station box, ticket hall and Northern Line entrance.
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3.11 Plot E2 comprises: A retail and leisure building, plus residential tower element; Tower 1 reaches 32-storeys above ground, rising to 124.45m AOD; Shops, cafes, bars and restaurants (Class A1/A2/A3/A4), and a Multi-Screen Cinema (Class D2); The residential element comprises Homes for Rent (Class C3) and ancillary amenity space; 3.12 Plot E3 comprises: A retail and leisure building with two residential tower elements; Tower 2 reaches 21-storeys above ground, rising to 80.025m AOD; Tower 3 reaches 23-storeys above ground and rises to 86.425m AOD; Shops, cafes, bars and restaurants (Class A1/A2/A3/A4); The residential element comprises Homes for Rent (Class C3), ancillary amenity space and a dedicated cycle lift and lobby. 3.13 Plot E4 comprises: A retail and leisure building; 4 storeys, rising to 24.9m AOD Shops, cafes, bars and restaurants (Class A1/A2/A3/A4); New opening through two railway arches, and use of one arch for A1-A4 purposes. West Site Summary
3.14 The West Site is split into three distinct plots (W1 to W3). W1 sits at the north- western corner alongside a smaller pavilion, whilst W2 is located between the extended Pastor Street and Newington Butts, with the London Metropolitan Tabernacle to its south. Plot W3 runs perpendicular between both Oswin Street and Pastor Street. In addition to Pastor Street, a new area of public realm is provided at the northern end of the West Site, adjacent to St George’s Road.
3.15 Plot W1 comprises:
A retail and commercial building with a residential tower above; Tower 1 reaches 20-storeys above ground, rising to 71.9m AOD; Shops, cafes, restaurants and commercial/workspace A1/A2/A3/A4/B1; A single storey Retail Pavilion (9.35m AOD) to parapet height. 3.16 Plot W2 comprises:
A retail and leisure building with two residential towers above; Tower 2 reaches 24-storeys above ground, rising to 84.7m AOD; Tower 3 reaches 35-storeys above ground, rising to 119.76m AOD;
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A new Music Venue (D2); Shops, cafes, bars and restaurants A1/A2/A3/A4 The residential element comprises Homes for Rent (Class C3). 3.17 Plot W3 comprises:
A mansion block, split into 3 individual residential buildings, plus office and retail use at ground and upper ground; Residential buildings 1, 2 and 3 reach 8-storeys above ground, rising to 24.8m AOD at parapet height; The residential elements front Oswin Street and comprise Homes for Rent (Class C3); Workspace (B1), and Shops, cafes and restaurants (A1/A2/A3) front the pedestrianised Pastor Street. 3.18 The CGI below illustrates the massing and layout of the Proposed Development:
Figure 4: Illustrative CGI of the Development
3.19 The proposals seek to contribute to the aspiration of the Council for the regeneration of Elephant & Castle, focusing on the Opportunity Area, by providing a much improved retail, leisure and cultural destination including a multi-screen cinema and music venue, complemented by high quality workspace, and 979 residential units. At ground floor level, uses will consist mainly of retail/commercial and transport infrastructure that will activate the various frontages and streetscene.
3.20 When taken as a whole, new and improved pedestrianised areas and appropriate landscaping will complement the active ground floor uses and add to the public realm
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improvements delivered by Transport for London at the peninsula. It will also significantly enhance permeability throughout the town centre, to and from London Underground and Rail Stations, and through the railway viaduct arches to the east.
3.21 The proposals seek to achieve the highest standards of architectural design and will add a series of complementary yet striking new buildings to Elephant & Castle. All residential units are designed to meet exemplary standards in line with LB Southwark and London Plan policy, including almost 100% of units exceeding minimum space standards, a predominance of dual aspect units, and plentiful private and communal amenity spaces.
3.22 The Proposed Development will be car free, meaning that there are zero car parking spaces (with the exception of 47 disabled residential parking spaces). This is a clear sustainability benefit given the Application Site’s exceptional public transport connectivity. 1,988 long stay cycle parking spaces are provided, and 285 short stay spaces located within the public realm areas.
3.23 A more detailed description of the proposed development can be found in the Design and Access Statement.
Uses and Amount
3.24 In total, the Development seeks planning permission for a total of 219,924 sqm (GEA) of floorspace, across the Proposed Development, comprising: retail, cafes and restaurants, workspace, UAL:LCC, music venue, cinema, and 979 residential units, as well as cycle storage, disabled parking, servicing, plant areas, new landscaping, new public realm, and other associated works.
3.25 Table 3.1 below defines the residential units and floorspace figures for the proposed Development.
USE LAND USE GIA m2 GEA m2 CLASS EAST SITE Residential C3 50,428 58,167 Retail A1-A4 22,825 28,138 Leisure (Cinema) D2 2,895 3,045 UAL:LCC D1 41,405 52,612 London Underground Limited SG 3,965 4,707 Total 121,518 146,669 WEST SITE Residential C3 56,043 65,065 Retail A1-A4 1,102 1,232 Leisure (Music Venue) D2 2,848 3,851 Flexible Use A1-A4, B1 2,860 3,107 Total 62,853 73,255 TOTAL 184,371 219,924 Table 3.1 – Quantum of Proposed Development
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Phasing
3.26 This subsection sets out the proposed phasing of the Proposed Development as currently envisaged by the Applicant. The phasing maybe subject to minor change during the course of the construction period, however, the following represents the current thinking. It is anticipated that the Proposed Development will be constructed over a number of years as this:
Reduces disruption to adjacent neighbouring businesses and residents, as well as highway, pedestrian and public transport considerations;
Continuity of LUL Station to maintain access to the Northern Line throughout construction;
Movement of UAL:LCC from their existing facilities to new building on the East Site;
Has viability and funding benefits, including the phasing of CIL;
3.27 The indicative programme of works for the Proposed Development is set out in Figure 5 below.
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Figure 5: Indicative Programme of Works
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4.0 PRE-APPLICATION CONSULTATION
4.1 This section should be read in conjunction with the Statement of Community Involvement (SCI), which is submitted as a separate document to accompany the planning application.
4.2 The Statement of Community Involvement explains all public consultation carried out during the pre-application stage. This section is primarily focussed on providing an overview of the formal pre-application process with the Local Planning Authority, other statutory bodies, as well as the public consultation.
EIA Scoping Request
4.3 A formal Scoping Request for the Proposed Development was submitted to LBS in 2015, with the Opinion received on 24th November 2015 (ref. 15/AP/4122). The Application Site exceeds the suggested 0.5ha threshold for 'urban development projects' within Schedule 2 of the EIA Regulations, and owing to the nature of the Proposed Development and the surrounding environs, it is accepted by the Applicant that the Proposed Development falls within Category 10b (urban development projects). Therefore, the Applicant has commissioned an EIA to be undertaken, in accord with the Scoping Opinion and subsequent clarifications and agreement reached with LBS.
Mayoral Referral
4.4 The application is referable to the Greater London Authority (GLA) as it exceeds the relevant thresholds set out in the Town and Country Planning (Mayor of London) Order 2008 (as amended). Accordingly, the GLA has been involved in a number of pre-application discussions with the Applicant.
Pre-Application Discussions
4.5 Formal pre-application discussions have been held with the Council on the evolving scheme since late 2013. The meetings have focussed a range of topics, including the following: The principle of development and land uses; Design and massing, townscape, strategic and local views; Employment and regeneration; The retailer and leisure offer; Housing mix, layout, and residential quality; Transport and accessibility, including servicing; Public realm and landscaping; Environmental considerations; Demolition, construction management and phasing;
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Affordable housing; Viability and Section 106. 4.6 The proposals were also presented to the Council’s Design Review Panel (DRP) in September 2015 and May 2016 respectively. The feedback from the pre-application discussions with the Council has been broadly positive and the scheme has developed and evolved as a consequence.
4.7 A formal Planning Performance Agreement (PPA) was entered into between the Applicant and Council. The PPA captures all pre-application meetings and sets out planning application document requirements, timescales for decision and guarantees availability of officer time.
Statutory Consultee Consultation
4.8 In addition to regular pre-application meetings with the Council, contact has been made with key statutory consultees in respect of various aspects of the Proposed Development, including:
Transport for London (TfL);
Historic England (formerly English Heritage);
Thames Water;
Environment Agency; and
The Met Police Architectural Liaison Officer.
Public Consultation
4.9 Public consultation is described in detail in the Statement of Community Involvement that accompanies this planning application. In summary, an extensive process of consultation was undertaken to initiate a dialogue between the Applicant and the key stakeholders and local community in order to understand their objectives, aspirations and expectations, which have helped inform the evolution of the Proposed Development.
4.10 In summary, the following consultation was undertaken in order to understand the views of the local community and key stakeholders;
Held meetings with Latin Elephant, Walworth Society, Plaza Latina / Carnival del Pubelo, Southwark Cyclists, Walworth Garden Farm, Southwark Disablement Society, Church of England – Diocese of Southwark: Southwark & Newington Deanery, Southwark Pensioners Society and Southwark Living Streets.
Held meetings with Perronet House TRA, Strata Residents, Metro Central Heights residents, Meadow Row TRA, Lawson Estate TRA, Hayles TRA, Albert Barnes House TRA, Draper TRA and Newington TRA, Oswin Street residents, Rockingham Community Association and West Square RA.
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Held meetings with Elephant Partnership, British School of Osteopathy, London Metropolitan Tabernacle, Hotel Elephant, Tiendos Del Sur, Imperial War Museum, Lend Lease, Neobrand, Ministry of Sound and Salvation Army.
Held meetings with elected representatives, including Peter John (Leader of the Council), Cllr Mark Williams (Cabinet Member for Regeneration), Cllr Barrie Hargrove (Cabinet Member for Public Health), Simon Hughes MP, Andrew Gilligan (Cycling Commissioner for London), LB Southwark Overview & Scrutiny Committee, Elephant & Castle Strategy Forum, Borough Bankside & Walworth Community Council, East Walworth Ward Councillors, Cathedrals Ward Councillors, Chaucer Ward Councillors, Newington Ward Councillors, Bishop’s Ward and Prince’s Ward Councillors.
Held a series of Drop-In Sessions from June to September 2014 attended by 296 people at the existing shopping centre and other venues to allow users of the existing centre and interested parties to provide feedback through a questionnaire about what people like and dislike about the existing shopping centre,
1st Public Exhibition (July 2015) was held over 3 days and previews were arranged for existing shopping centre traders, locally elected representatives, local community groups, amenity organisations and local businesses and landowners. 835 people attended the first exhibition.
Holding a series of Public Workshops in November 2015 with the elected political representatives, local community groups, amenity organisations, local businesses and landowners located around the Proposed Development, including breakout groups chaired by independent facilitators.
A 2nd Public Exhibition was held in May 2016 over 3 days, again with previews arranged for the above groups. 773 people attended the second exhibition.
A website was created with more information on the proposals. This can be seen at: www.elephantandcastletowncentre.co.uk
Key Themes from the Consultation Process
4.11 A wide range of themes have emerged through the consultation process, including:
Overall design, style and appearance;
Form and arrangement of the buildings, including height and massing;
The provision of cultural space;
Public realm and landscape proposals;
Impact of the proposals on the existing Shopping Centre retail officer, meanwhile uses and alternative service provision during demolition and construction;
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The residential model and amount of affordable housing.
4.12 Since the initial public consultation and engagement the scheme has evolved in line with the comments from the Council, statutory consultees and the public. Section 5.6 of the Statement of Community Involvement and Section 3.2 of the Design and Access Statement set out the key areas where the design has changed, which include:
East Site permeability and evolution of the Court’s design and function as a destination in its own right;
LUL Underground station entrance and visibility between this and the existing Bakerloo Line entrance on the other side of the peninsula;
Relocation of cinema given height requirements and associated impact on overshadowing to public areas;
West Site pedestrian routes and reinstatement of historic layout between St George’s Road and Brooke Drive;
Form and typology of the Mansion Blocks and their relationship with surrounding terraces; and
Inclusion of a music venue
4.13 Overall there was strong support for the principles of the scheme from the public consultation. The 2nd public exhibition in May 2016 resulted in considerable support for the scheme, with 83.4% of respondents registering their support.
4.14 Following the submission of the planning application the Applicant remains committed to consulting and engaging with local residents, businesses and other stakeholders. The intention is to maintain the dialogue with those individuals and organisations who have expressed an interest in the scheme and to keep people up to date with the project through the website, newsletters, and meetings as required.
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5.0 REGENERATION AND COMMUNITY BENEFITS
5.1 A Regeneration Statement prepared by Regeneris Consulting has been prepared to accompany the planning application. An associated socio-economic chapter of the ES has also been prepared. The report sets out the socio-economic context, an estimation of economic benefits and the Proposed Development’s contribution to regeneration and competitiveness, including an assessment against relevant policy.
5.2 The proposal will deliver the following economic benefits:
12,300 person years of construction employment, equating to c1,230 construction workers per year over 10 years; New Homes Bonus (NHB) revenues of £9 million over 6 years of which approximately two thirds will go to London Borough of Southwark and the remaining third to the GLA; £1.5m Council Tax revenue annually; Approximate CIL of £14.8 million An additional 1,850 residents in the locality with an estimated 70% of working age, and 50% economically active residents employed in higher value skilled occupations (higher managerial and professional occupations), contributing to the local policy objectives of improving the area’s skills profile, and increasing locally available expenditure; 2,375 FTE gross jobs onsite, a gross increase of 732 jobs following completion of the Proposed Development. It is estimated that total expenditure generated from the Proposed Development would equate to c. £1.6 million per annum in the Elephant & Castle Opportunity Area and £3.6m per annum within the Borough.
5.3 The proposal will deliver the following wider regeneration benefits:
A cluster of new additions to the Elephant & Castle skyline, designed by award- winning architects Allies and Morrison who have been involved with a number of high quality additions to London’s built environment over recent years, including Wood Wharf, Two Pancras Square, and Stratford for London 2012; A significantly improved shopping centre, new leisure and office space that will contribute towards completing the vision for the Opportunity Area; A more diverse range of jobs in retail, leisure, education and employment space which better meets the needs of the modern London businesses; An enhanced educational offer in a landmark state of the art home for UAL:LCC, which in turn will benefit and inspire its students and staff; A new exhibition space within the UAL:LCC building which could be used for the benefit of the local community; 979 new homes, contributing to the need for new housing in LB Southwark and London as whole;
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An exciting new music venue at the heart of the scheme, which in conjunction with other venues in the area, will put Elephant and Castle firmly back on the map as a cultural centre for London. An offer that complements the ongoing improvement and aspirations for Walworth Road; New, high quality public realm, including new pedestrian routes, opened railway viaduct arches and a new public square; A new entrance to the London Underground Northern Line, and at grade access to the Elephant & Castle Rail Station; Achieving development in a sustainable location, with easy access to pedestrian routes, local facilities and amenities, and close to public transport including rail, underground and bus routes.
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6.0 PLANNING POLICY ASSESSMENT
6.1 The purpose of this section is to identify the key national, regional and local planning policy and guidance relevant to the determination of the application for the Proposed Development, and against which the proposals have been considered during design development. An analysis of the key policies and tests relating to the principle of the Proposed Development is therefore included in the relevant sections of this Planning Statement. An analysis of the relevant policies concerning environmental matters is contained in the relevant chapters of the Environmental Statement.
6.2 Section 38(6) of the Planning and Compulsory Purchase Act 2004 (as amended) and Section 70(2) of the Town and Country Planning Act 1990 state that the determination of planning applications should be made in accordance with the Development Plan unless material considerations indicate otherwise. This requirement is reiterated in the National Planning Policy Framework (NPPF).
Development Plan
6.3 The Development Plan for the Site comprises the following:
The London Plan: Spatial Development Strategy for Greater London – Consolidated with Alterations Since 2011 (March 2016);
The Southwark Council Core Strategy (April 2011); and
Saved polices of the Southwark Plan (July 2007).
6.4 Also of relevance is the Elephant and Castle Supplementary Planning Document / Opportunity Area Planning Framework (adopted in March 2012), and the emerging New Southwark Plan, for which public consultation on the ‘Preferred Option’ stage concluded on Friday 12th February 2016.
6.5 In addition to the Development Plan, regard has been had to the following:
National Planning Policy Framework and Guidance (NPPF and NPPG)
6.6 The NPPF establishes overarching principles of the planning system, including the requirement of the system to “drive and support development”. There is also a “presumption in favour of sustainable development… should be seen as a golden thread running through both plan-making and decision-taking”.
6.7 Both the NPPF and NPPG are material considerations in the determination of a planning application, but do not form part of the Development Plan.
Supplementary Planning Documents and Guidance
Regional
6.8 The GLA has also produced a number of guidance documents, which amplify London Plan policy and are relevant to the Development. These documents are material
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considerations but do not form part of the Development Plan. These documents include:
Accessible London: Achieving an Inclusive Environment SPG (October 2014);
Housing SPG (2016);
Sustainable Design and Construction SPG (April 2014);
Planning for Equality and Diversity in London SPG (October 2007);
London View Management Framework SPG (July 2012);
All London Green Grid (March 2012);
London World Heritage Sites – Guidance on Settings SPG (March 2012);
Shaping Neighbourhoods: Play and Informal Recreation SPG (September 2012);
Cultural Strategy for London Cultural Metropolis (15 November 2010) (and as updated 2014);
The Control of Dust and Emissions During Construction and Demolition (July 2014);
Character and Context (June 2014);
London Planning Statement (May 2014);
Social Infrastructure (May 2015);
Town Centres (July 2014); and
Central Activities Zone (CAZ) SPG (March 2016)
Local
6.9 The Council has also prepared a number of supplementary documents to provide guidance on adopted planning policies. These documents form material considerations but do not form part of the Development Plan. Of relevance to the Development are the following supplementary planning documents (SPD):
Sustainability Assessment (2009);
Sustainable Design and Construction (2009);
Sustainable Transport (2010);
Technical Update to Residential Design Standards SPD (2015);
Affordable Housing (2008) and Draft Affordable Housing (2011);
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Section 106 Planning Obligations / CIL (2015); and
Development Viability SPD (2016).
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7.0 PRINCIPLE OF DEVELOPMENT
7.1 This Section summarises the overriding priorities and strategic policy objectives which promote development in the area. It then goes on to assess the principle of the Development.
Overarching Priorities for Sustainable Development
7.2 The overarching message at national level is embodied in the NPPF (March 2012) which states that “At the heart of the planning system is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan making and decision taking…” (Para. 14). It goes on to state “All plans should be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption will be applied locally.” (Para. 15).
7.3 The NPPF sets out key themes for achieving sustainable development, which include:
Building a strong, competitive economy;
Delivering a wide choice of high quality homes;
Requiring good design; and
Promoting healthy communities.
7.4 The NPPF states that planning should proactively drive and support sustainable economic development to deliver the homes, business, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth.
7.5 Paragraph 70 of the NPPF goes on to state that in order to deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should: plan positively for the provision and use of shared space, community facilities (such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities and residential environments.
7.6 The Budget 2015 further reiterated some of these key national priorities and sets out a comprehensive package of measures that builds on existing reforms to create a dynamic, balanced economy and to support future productivity growth. Some of the measures included “securing a truly national recovery by investing in infrastructure, housing, science and innovation across the whole of the UK” and “creating a dynamic economy that is the best place in the world to start, invest in, and grow a business”. The Budget also referenced the Government’s further devolution of powers to the Mayor of London, including over planning, to accelerate the provision of new homes.
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Regional Objectives for Growth
7.7 The London Plan sets out a number of objectives for development throughout its policies, these are summarised below and seek to:
Optimise residential and non-residential output and densities, provide necessary social and other infrastructure to sustain growth and… support wider regeneration in Opportunity Areas such as Elephant and Castle (Policy 2.13);
Increase housing supply as the mayor recognises the pressing need for more homes in London… and realise the potential brownfield housing capacity through intensification, mixed use development and town centre renewal, especially in centres with good public transport accessibility (Policy 3.3 & 3.4)
Ensure that development to increase office floorspace within the CAZ include a mix of uses including housing (Policy 2.11)
Encourage large residential development in areas of high public transport accessibility (Policy 3.7) and improve housing choice for Londoners (Policy 3.8);
Promote mixed and balanced communities (Policy 3.9);
Promote and enable the continued development of a strong, sustainable and increasingly diverse economy across all parts of London (Policy 4.1);
Support the management and mixed use development and redevelopment of office provision to improve London’s competitiveness (Policy 4.2);
Support a strong, partnership approach to bringing forward capacity for retail, commercial, culture and leisure development in town centres (Policy 4.7)
Sustain and manage the attractions of Central Activities Zone (CAZ) as the world’s leading visitor destination (Policy 2.10); and
Support the continued success of London’s diverse range of arts, cultural, professional sporting and entertainment enterprises and the cultural, social and economic benefits that they offer to its residents, workers and visitors (Policy 4.6).
7.8 In relation to housing supply, the London Plan states that an average of 42,000 net additional homes should be delivered across London annually. For Southwark specifically, the London Plan sets out a minimum ten year target of 27,362 new homes between 2015-2025 – this equates to 2,736 homes per year. Southwark’s housing target is the second highest in London.
7.9 London Plan Table A1.1 Opportunity Areas identifies Elephant and Castle as an opportunity area (Ref. 11), with and indicative employment capacity of 5,000 and sets the minimum number of new homes to be delivered within the Opportunity Area at
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5,000 (up from the previous target in the 2011 London Plan). The accompanying text states that:
“The Area is undergoing major transformation with significant investment in housing and potential for new retail provision integrated with a more efficient and attractive transport interchange. There is scope to create a series of connected public open spaces complemented by environmental and traffic management improvements. Resolution of these and rail related issues are crucial to the successful redevelopment of this southern gateway to central London.”
7.10 Opportunity Areas are London’s principal opportunities for accommodating large scale development to provide substantial new employment and housing, with a mixed and intensive use of land and assisted by good public transport accessibility.
7.11 Policy 2.13 of the London Plan specifically relates to Opportunity and Intensification Areas. It states that development proposals within opportunity areas and intensification areas should: “seek to optimise residential and non-residential output and densities, provide necessary social and other infrastructure to sustain growth, and, where appropriate, contain a mix of uses; and contribute towards meeting (or where appropriate, exceeding) the minimum guidelines for housing and/or indicative estimates for employment capacity.”
Local Objectives for Growth
Elephant and Castle
7.12 Elephant and Castle has long been identified as a significant opportunity for development by both regional and local strategic plans and there has been an adopted policy position setting out a detailed strategy for growth since 2004.
7.13 The Council’s adopted Core Strategy identifies Elephant and Castle as an Opportunity Area and Growth Area, acknowledging that it is one of the best available areas to accommodate major growth in jobs and housing.
7.14 Objective 5A of the Core Strategy prioritises development in the Opportunity Area and seeks to improve it as a place to live and work in, and to enable a better quality of life for Southwark’s residents. Strategic Targets Policy 2 seeks the provision of 4,000 net new homes (this is lower than the London Plan 2015 target of 5,000); 5,000 net new jobs; and around 45,000 sqm of additional shopping and leisure space.
7.15 In addition, the Elephant and Castle SPD / OAPF sets out the Council’s vision for the Elephant and Castle Opportunity Area and provides a framework which will guide development over the next 15 years and ensure that regeneration is coordinated and sustainable. Relevant extracts from the vision are included below for reference:
‘Elephant and Castle has potential for redevelopment into an attractive central London destination. We will facilitate regeneration of the Elephant and Castle into a more desirable place for both existing and new residents. There will be excellent shopping, leisure facilities and cultural activities. London South Bank University and London University of the Arts will develop further as important centres of learning. Elephant and Castle will continue to be highly accessible from other places in Southwark and London.’
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‘We are using our land at the heart of the area to stimulate 440,000 sqm of new development with of up to 45,000 sqm new shopping and leisure floor space and 25,000-30,000 sqm of business floorspace. We will meet our target of 4000 new homes and a minimum of 1,400 affordable housing units by working with the local community, registered providers and private developers to deliver new homes. We will also meet the London plan target of 5,000 new jobs by encouraging more offices, hotels, small businesses and developing the evening economy and cultural activities. There could be tall buildings on some sites in the core area where this helps stimulate regeneration and creates a distinctive place.’
‘The regeneration of the opportunity area will create a highly integrated and efficient public transport hub. This will include an improved Northern line station with a new ticket hall and improved access to platforms; while additional lifts would provide sufficient capacity, there is an aspiration that access should be via escalators. There will be enhanced conditions for bus and rail users and an improved interchange between the various modes. All development will be phased to ensure that the funding is available so that the necessary transport capacity and improvements can be delivered in time to accommodate the new residents, businesses and leisure activities in the opportunity area.’
7.16 The East and West Sites both sit within the Central Area defined by the SPD / OAPF, which set out aspirations to:
Central Area:
Support the objective of consolidating the Elephant and Castle as a major town centre.
Improve the retail offer by providing a range of types of retail, including comparison goods floorspace.
Provide a range of unit sizes and affordable retail units which are made available to existing occupiers displaced by development.
Increase the number of employment opportunities on the site and ensure that there is no net loss of non-residential floorspace.
Provide a range of arts, cultural, leisure and entertainment uses, including food and drink uses which make a positive contribution to the evening economy.
Introduce residential use as part of mixed-use development where feasible.
Retail
7.17 The Proposed Development will replace the existing dated, poor quality shopping centre, with a more flexible, current retail offer which caters to modern, evolving customer needs. The Proposed Development will improve the quality of the retail offering, shopping environment and townscape, increase the footfall within the Town Centre to create a livelier streetscene, thereby improving the long term viability of the town centre, local and borough wide economy.
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7.18 The accompanying Retail Assessment has demonstrated that the Proposed Development at Elephant & Castle Town Centre will clearly satisfy all of the relevant national, regional and local planning policy requirements. Furthermore, the retail and leisure elements represent a timely and significant strategic opportunity to realise the long standing, long awaited regeneration goals of both local and regional government, to elevate the Elephant & Castle Opportunity Area and Town Centre to a prime retail and leisure destination as befits its Zone One London location.
Employment
7.19 In terms of jobs and businesses, the Council’s Economic Wellbeing strategy (2012- 2020) promotes the creation of new jobs and business growth opportunities through regeneration, development and better use, management and improvement of employment land.
7.20 Strategic Policy 10 (Jobs and Businesses) of the Core Strategy sets out the Council’s approach to increase the number of jobs in Southwark and create an environment in which businesses can thrive. It will also try to ensure that local people and businesses benefit from opportunities which are generated from development.
Education
7.21 Southwark Core Strategy Strategic Objective 1B ‘Achieving education potential’ seeks Southwark schools, universities, pre-schools and colleges to be places where children and young people can achieve and gain the knowledge and skills to get a job. Southwark will be a place that creates positive futures by building, redeveloping and improving educational facilities with good access for everyone. Improving Southwark will help to attract good teachers to work in the borough. Strategic Policy 4 seeks to achieve these aims by building new schools and improving existing schools to provide improved education opportunities.
7.22 Saved Southwark Plan Policy 2.3 seeks the enhancement of educational establishments. The Elephant & Castle SPD also supports proposals for provision of space used for higher education (SPD 8).
7.23 At regional level, the London Plan states that the Mayor will support provision of childcare, primary and secondary school, and further and higher education facilities adequate to meet the demands of a growing and changing population and to enable greater educational choice.
7.24 In doing this, Policy 3.18 development proposals which enhance education and skills provision will be supported, including new build, expansion of existing or change of use to educational purposes. It goes on to state that development proposals that encourage co-location of services between schools and colleges and other provision should be encouraged in order to maximise land use, reduce costs and develop the extended school or college’s offer.
7.25 Cultural / Leisure
7.26 Southwark’s Cultural Strategy: 2013 - 2018 states that Southwark’s reputation as a cultural destination brings new business, money and investment into the borough, creating jobs and opportunities. It states that culture also has a role to play in the
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regeneration of local areas, engaging and bringing together local communities in periods of change, attracting visitors to all areas of the borough, and increasing footfall for local business, attracting more spend in these areas. The Strategy states that the scope for further engagement in Elephant and Castle, amongst other places, over the coming years will be significant.
7.27 Strategic Objective 1D of the Core Strategy seeks to provide a wide range of arts and cultural facilities for Southwark’s multicultural and very diverse community, whilst Strategic Policy 4 aims to facilitating a network of community facilities that meet the needs of local communities, and ensuring development provides flexible community spaces that can be shared by many groups, where there is a local need and an identified occupier for the space.
7.28 Policy SPD 6 of the Elephant and Castle SPD / OAPF also states that proposals involving arts, cultural, leisure and entertainment uses which contribute towards consolidating Elephant and Castle and Walworth Road as a major town centre will be supported.
7.29 The emerging draft New Southwark Plan Preferred Options document continues to seek cultural uses via draft Policy DM39, outlining how such uses are essential for the regeneration of areas that make a positive contribution and a vibrant cultural ‘scene’ bring employment and provide opportunities for training and learning.
Residential
7.30 Strategic Policy 5 (Providing New Homes) of the Core Strategy (2011) states that the Council will meet the housing needs of people who want to live in Southwark and London by providing 24,450 net new homes between 2011 and 2026. The Policy further sets out a density of 650 – 1,100 habitable rooms per hectare (hr/ha) in the Central Activities Zone, within which the Site falls.
7.31 As set out above, the London Plan sets a target of delivering 2,736 homes per year in Southwark, which the draft New Southwark Plan Preferred Options document states that the Council will seek to meet by requiring development to optimise the use of land, and allowing higher densities in Regeneration Areas, which benefit from high levels of accessibility and provide opportunities to build supporting infrastructure.
Regeneration
7.32 The accompanying Regeneration Statement assesses how the Proposed Development will contribute to the regeneration of the Application Site and wider Elephant & Castle area.
7.33 The benefits of the scheme are clear and wide ranging, including positive economic impacts such as new construction employment and jobs in the completed development, new homes, increased local expenditure to support local businesses, an enhanced educational facility, Underground station entrance, public realm and landscape improvements.
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Evaluation of the Development
7.34 The principle of the Development accords with current and emerging planning policy and guidance. National policy, the London Plan, the Core Strategy and the emerging New Southwark Plan all seek to ensure that development achieves the highest possible intensity of use compatible with the local context in order to deliver a scale of development which makes the most effective and efficient use of land.
7.35 The London Plan and the Southwark Core Strategy recognise Elephant and Castle as an Opportunity Area and as one of the most suitable locations for accommodating major development and growth. The strategic targets for delivering significant new jobs, housing, retail and cultural facilities are closely linked to realising the development potential of Opportunity Areas. Opportunity Areas, and sites such as the Application Site, are therefore fundamental to the growth of London and key to achieving physical, social and economic regeneration, and will help Southwark achieve its vision for the Elephant and Castle Opportunity Area.
7.36 The Proposed Development, in terms of its mix of uses and architectural quality, will perform a key role in the wider regeneration of Elephant and Castle through the delivery of a cluster of new buildings and a significantly improved retail, employment and cultural offer. The Development will also set an excellent benchmark for future high-density mixed-use developments within Southwark’s Regeneration Areas and other Opportunity Areas in London.
7.37 A much improved, flexible high quality retail offer forms an integral part of the Proposed Development. The principle of redeveloping the existing shopping centre to provide a new town centre is inherently acceptable given the location. The proposed retail, café, restaurant and bar offer will provide a new offer to local residents and visitors alike, complement the wider mix of use, and contribute towards putting Elephant & Cattle back on the map as a Zone One destination in London.
7.38 The Proposed Development will bring about a significant increase in jobs and employment density on the Site, with an estimated total number of jobs increase from approximately 1,418 FTE (full-time equivalent) jobs up to 1,990 FTE jobs associated with the completed Development (assuming the flexible space is used for office purposes) – an increase of up to 572 FTE jobs. This equates to approx. 11.4% of the target for the Elephant and Castle Opportunity Area in the Core Strategy and London Plan, excluding the estimated 1,230 construction worker jobs created per year through the construction period.
7.39 The Development will also deliver an exciting new music venue, comprising up to 2,895sq.m (GIA) of space. In line with the aspirations of Southwark’s Cultural Strategy and the vision for Elephant and Castle the ambition is to increase the footfall in the area and, in conjunction with other venues in the area, put Elephant and Castle firmly back on the map as a cultural centre for London.
7.40 Redevelopment of this Application Site would also significantly contribute to meeting housing targets by adding 979 high quality new residential units to the existing housing stock – which equates to approximately 36% of LBS’s annual housing target, as set out in the London Plan, and 20% of the housing target for the Elephant and Castle Opportunity Area in the SPD / OAPF. Alongside a Homes for Rent offer these
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homes will promote opportunity and choice for residents in ways that meet their needs and the strategic objectives for London and the Council.
7.41 For the reasons outlined above, the principle of the Development is consistent with the broad objectives of planning policy and in accordance with the Government’s overarching objectives for sustainable growth. The proposed Development is acceptable in principle and should be supported in this location.
7.42 The Development constitutes sustainable development and therefore should be approved pursuant to paragraph 14 of the NPPF.
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8.0 EXISTING USES
8.1 This Section assesses the loss or re-provision of the existing uses from the Application Site as a result of the construction of the Proposed Development.
8.2 The Application Site is currently occupied by Elephant & Castle Shopping Centre and Market, The Coronet and UAL:LCC which are described in more detail below.
8.3 Architecturally the existing buildings are of a low quality which do not engage with the surrounding area in a meaningful way, in part due to their original design, but also given their relationship with the changing nature of Elephant and Castle. As established in Section 7 of this Statement the principle of a comprehensive high density, mixed-use redevelopment of the Application Site is supported by planning policies, however, justification for the loss or re-provision of the existing land uses on the Site is set out below.
Elephant & Castle Shopping Centre
8.4 The existing shopping centre is clearly in decline, comprises low quality space and is in need of urgent investment so that a new modern offer can be provided, befitting of Elephant & Castle’s regeneration and existing/future demographic.
8.5 There are around 65 retail occupiers currently leasing space in the Elephant & Castle shopping centre. This includes 9 restaurants, 5 leisure occupiers, 6 community organisations and 18 businesses leasing office space. The occupiers have been made aware of the redevelopment proposals, have been offered briefings and were invited to the public exhibition.
8.6 There is no specific policy protection in respect of the existing bingo or bowling operations. Their loss is offset by the benefits of the town centre regeneration scheme, including significant high quality flexible retail and leisure space, including new cinema, music venue and exhibition space in the new UAL:LCC building.
8.7 Retaining local and specialist retailers as part of a more diverse offer in the wider Elephant & Castle area is one of the building blocks to establish a diverse, yet cohesive retail and service offer for the wider Elephant & Castle area. However, it is recognised that some existing retailers in the area are benefitting from disproportionately low levels of rent for such a central London location, and it may not be financially viable for them to survive in the wider area over the longer term. Notwithstanding this, the Applicant intends to develop a relocation strategy following the grant of planning permission. This strategy will include an aspiration to retain local retailers and businesses where possible, and in particular those delivering important social, community and economic functions that would benefit from access to alternative space in the wider area.
8.8 Businesses that provide important local functions will be identified by the Applicant in conjunction with the Council and these tenants should be consulted regarding their business aspirations as part of the relocation strategy. Where businesses are intending to move, support will be offered in terms of independent business advice and planning, as well as where to find specialist legal and property representation alongside a list of all retail property that is available in the area.
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8.9 The redevelopment of the existing shopping centre is a key opportunity to significantly increase the importance of Elephant & Castle as a retail and leisure destination in London, and to ensure that the retail space being delivered by other neighbouring landowners, such as the Applicant’s own Elephant One scheme or those by Lend Lease, is complemented by the Proposed Development. In our view, unless the existing shopping centre is redeveloped and repositioned, the other regeneration schemes in the immediate area will not reach their potential.
8.10 There are a significant number of convenience and comparison retailers along with restaurant and leisure operators that have shown interest in being represented at Elephant & Castle. The tenant mix of the Proposed Development will be heavily represented by convenience retailers, supported and completed by modern fashion and comparison retailers. A significant proportion of cafes and restaurants, that are likely to be from the smaller London operators, will support and underpin the retail and leisure function (in particular the cinema and music venue), and provide a destination in their own right for local residents and pass-by commuters.
8.11 There is no in-principle reason to oppose the redevelopment and re-provision of a shopping centre in a town centre location. The format, layout and mix of unit sizes, as well as anticipated occupiers are driven by market and commercial requirements, however conscious efforts are being made to support existing retailers through a period of change, and best complement other redevelopment schemes in the locality. The new shopping centre will realise clear qualitative improvements to the offer.
Hannibal House
8.12 Much of the existing Hannibal House office space is of poor quality and dated. The building does not suit current modern occupier space or layout requirements, and therefore without significant upgrading to modern standards, the number of jobs the Application Site could support will continue to suffer.
8.13 Given that the Application Site seeks to deliver shopping and leisure facilities befitting of a town centre, as well as the relocation of educational uses which are together driven by Opportunity Area and Applicant’s aspirations, there is little rationale for significant levels of new office floorspace provision. There is no in-principle policy restricting the loss of office floorspace. In addition, other neighbouring sites are bringing forward substantial office provision that will cater for the town centres needs, including the Skipton House scheme which benefits from a resolution to grant planning permission.
8.14 In the order of 2,860sq.m employment floorspace may be re-provided on the Application Site, split across both East and West Sites as part of a the flexible use package. The space is intended to best serve current and future employment space requirements in the London market, and will in some instances provide active frontages and add to the mixed-use nature of the scheme. In terms of job creation, the reduction in office floorspace is offset by the net increase of up to 572 FTE jobs once the Proposed Development is completed.
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The Coronet
8.15 The Coronet, originally a theatre, now effectively functions as a nightclub or venue ‘for hire’. The existing operation is therefore not a community use and provides very little benefit to local residents or businesses. Furthermore, the existing operation does not contribute or tally with the regeneration aspirations of the Elephant & Castle Opportunity Area. The Coronet is not listed, nor protected by planning policy in any other way.
8.16 In our view the loss of The Coronet is far outweighed by the wider benefits of the Proposed Development, including the provision of a new modern leisure offer in the form of a cinema and music venue, which during daytime could provide public access and gallery / exhibition space. In terms of floorspace, the demolition of The Coronet is offset by a combined 5,743sq.m (GIA) of new leisure floorspace.
UAL:LCC
8.17 The existing UAL:LCC buildings on the West Site are to be demolished and effectively upgraded and re-provided on the East Site. The transition and upgrade is very much a positive element of the scheme in that it provides UAL:LCC with a new start of the art educational facility that will future proof its operation over the coming years. In terms of floorspace comparison, the new facility will provide a net increase of 9,852sq.m – a clearly positive aspect of the Proposed Development.
8.18 The Proposed Development is strongly supported by UAL:LCC and will allow them to decant staff from other sites, equating to the addition of up to 500 jobs that would otherwise not be in Elephant & Castle. There are no policy grounds to oppose the demolition and re-provision of educational floorspace on the same Application Site for a named occupier.
Summary
8.19 Overall, the existing retail/leisure and educational uses are offset by a largely like-for- like replacement, albeit of much increased quality, flexibility and fit for modern requirements. The net loss of office space is inherently reflected in the nature of the scheme, which focusses on providing the town centre with a new retail, leisure and educational hub, with other neighbouring developments such as Skipton House delivering the Opportunity Area’s required office space provision.
8.20 The approach to existing uses through comprehensive phased redevelopment is fully justified in planning policy terms, and will realise significant regeneration and public benefits.
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9.0 COMMERCIAL USES
9.1 This section assesses the Proposed Development against planning policy and guidance, specifically in relation to the proposed commercial elements, notably the retail and office uses located above grade. The Proposed Development proposes a significant amount of high quality modern retail floorspace (Use Classes A1, A2, A3 and A4), as well as complementary office floorspace (Use Class B1) which may come forward as part of the flexible use element.
9.2 The table below sets out the proposed floorspace and estimated jobs for the commercial elements of the scheme.
Proposed GROSS FTE Jobs NET FTE Jobs Use Class Floorspace (sqm, Created in Created in GIA) Development Development Retail (A1-A4) & 29,670 733 +423 Leisure (D2) Offices Up to 2,860 Up to 307 -331 (B1)*
Total 32,062 1,040 +92 Table 9.1 – Commercial Floorspace Schedule and Jobs *Offices may form part of the flexible Class A1-A4/B1 element on the West Site Retail (Class A1, A2, A3 and A4 Uses)
9.3 The Proposed Development comprises of 29,670s.qm (GIA) of flexible retail (Use Classes A1, A2, A3 and A4) and leisure space in the form of the cinema and music venue (Use Class D2). The majority of floorspace is provided in the new town centre on the East Site, with smaller elements in the West Site to improve overall vitality and sustainability, as well as active frontages within the new areas of public realm.
9.4 The proposals have been developed to provide an increase in the quality of retail and leisure floorspace, in order to attract a range of retailers. This approach seeks to address the range of needs of the increasing population forecasts for Elephant & Castle and Southwark, outlined in the Southwark Retail Study (2015).
9.5 The retail frontage of the existing shopping centre fronts Newington Butts and the eastern side of the Elephant & Castle Roundabout. The proposals would replace and upgrade the existing poor quality frontage, floorspace, public realm and access to public transport. This will increase footfall within the new town centre, and across the Elephant & Castle Town Centre Opportunity Area as a whole.
9.6 The Southwark Retail Study notes the continued growth of new forms of retailing (multi-channel shopping) as an alternative to more traditional shopping, and that trends within this sector are likely to have implications for retailing within Southwark. The retail proposals have been designed with the requirements of a range of retailers in
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mind. This includes retail floorspace accommodating the needs of click and collect as well as traditional store retailers.
9.7 The Southwark Retail Study also notes the preference of high street multiple comparison retailers seeking larger modern shop units (over 200 sq.m) within town centres. It notes the trend of smaller vacant units becoming less attractive for new multiple occupiers, with retailers increasingly looking to relocate into larger units in higher order centres. The proposals for the new shopping and leisure centre seek to accommodate the needs of these types of retailers, which are considered the appropriate type of retailers for the scale of Major Town Centre the Elephant & Castle regeneration hopes to achieve.
9.8 Through these types of retailers, the proposals would deliver an uplift in the quality of the retail offering and environment over what is currently present onsite, capturing a higher spend per visit, and increasing the vitality and viability of the centre.
9.9 The Application Site will continue to serve the existing local ward catchment area, however the redevelopment of the existing shopping centre is a key opportunity to significantly increase the importance of Elephant & Castle as a retail and leisure destination for the Borough and across London.
9.10 Unless the existing shopping centre is redeveloped and repositioned the other current and proposed regeneration in the area will not be so successful. There is a significant number of convenience and comparison retailers along with restaurant and leisure operators that have a requirement for Elephant & Castle. The tenant mix of the town centre needs to be convenience based, backed up by the fashion and comparison retailers that work well in London, together with a significant proportion of cafes and restaurants that are likely to be from smaller London operators. The anchor multi- screen cinema will also underpin this food offer and ensure that the development will become the focal point for the area. The increased footfall as well as the mainstream retail and leisure offer will help to underpin the wider area’s leasing aspirations, and allow for the inclusion of independent and local operators.
9.11 Centres with comparable transport accessibility that successfully represent this type of convenience, leisure and food market positioning (with supporting fashion and comparison retailers), include Angel Central Shopping Centre, Fulham Broadway and Ealing Broadway. Market research and consultation with interested retailers has indicated that this would be the most appropriate type of retail offer for the Application Site. It is this type of offer that would best complement and enhance the retail offerings of other planned and consented developments in the Town Centre Opportunity Area, including at Walworth Road.
9.12 The Application Site is the only location within the town centre which is able to accommodate these specific retailer and customer requirements at this time.
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9.13 In addition to reinvigorating the Elephant and Castle town centre, the proposals will encourage movement between it and the shops at Walworth Road, an objective of LBS set out in its Local Plan. It is envisaged that the new town centre retail and leisure element could create approximately 733 jobs (FTE).
9.14 Altogether, the development proposals (and corresponding TFL works) will replace the existing dated, poor quality shopping centre, with a more modern retail offer which caters to modern, evolving customer needs. The Proposals will improve the quality of the retail offering, shopping environment and townscape, increase the footfall within the Town Centre to create a livelier streetscene, thereby improving the long term viability of the town centre and local economy.
9.15 The national impact and sequential tests are not relevant given the town centre location and development plan support for redevelopment, whilst a consideration of scale is included in the accompanying Retail Assessment.
9.16 Planning policies at all levels support the provision of new retail floorspace in existing town centres, such as Elephant & Castle.
Offices (Class B1)
9.17 The proposed office floorspace (part of the flexible A1-A4, B1 element) will be apportioned across the West Site. A small amount of office space is also included within the UAL:LCC building, ancillary to the educational use. The Application Site is located within the Central Activities Zone (CAZ), the Elephant and Castle Opportunity Area and Elephant and Castle Town Centre.
9.18 Strategic Policy 10 of the Core Strategy sets out Southwark’s approach to employment. The policy seeks to protect existing employment floorspace and support the provision of employment space, specifically on sites within the CAZ, Opportunity Areas and Town Centres. In addition, Draft Policy DM 21 of the New Southwark Plan also states that new office (Class B1) floorspace will be permitted in a number of locations, including Opportunity Areas, such as Elephant & Castle.
9.19 The vision for the Elephant and Castle Opportunity Area includes a target for 5,000 net new jobs. It is estimated that the total number of gross jobs resulting from the office use in this Proposed Development will be 307 FTE jobs, a net reduction given the size of the existing Hannibal House building. A large proportion of emerging office floorspace within the Opportunity Area is proposed as part of the Skipton House scheme.
9.20 The net reduction in office space and associate jobs is inherently reflected in the nature of the scheme, which focusses on providing the town centre with a new retail, leisure and educational hub, with other neighbouring developments such as Skipton House delivering the Opportunity Area’s required office space provision. On this basis, the
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principle of B1 Use Class floorspace is fully policy compliant and should be supported.
Summary
9.21 The new town centre and introduction of high quality flexible retail, café, bar, restaurant and leisure floorspace will greatly improve Elephant & Castle’s offer and attractiveness. The existing shopping centre is in dire need of upgrading, which is most viably brought forward through comprehensive redevelopment, as part of a phased mixed use scheme.
9.22 No sequential or impact considerations are relevant, whilst the appropriateness of scale is addressed in the accompanying Retail Assessment.
9.23 The proposed office space is strongly supported by local and regional policies, including Core Strategy Strategic Policy 10 and Policies 2.11 and 4.1 of the London Plan. Notwithstanding the net loss of office floorspace and jobs, the overall Proposed Development results in a net uplift in job creation, whilst other nearby developments are proposing more significant levels of office floorspace to serve the town centre.
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10.0 LEISURE AND EDUCATIONAL USES
10.1 This section assesses the Proposed Development against planning policy and guidance, specifically in relation to the proposed leisure and educational elements.
10.2 One of the driving principles of the Proposed Development is to create a truly mixed- used development approach. The proposal houses a diversity of complementary uses in order to create a day and night living environment. These uses include the new shopping centre, a high quality educational facility for UAL:LCC, a new music venue and cinema, and significant food and beverage offers.
The New Cinema
10.3 The proposals for the Town Centre also include a multi-screen cinema, situated on the East Site and integrated with the retail, café, bar and restaurant offer. The cinema will provide a modern leisure offer for local residents, shoppers and visitors to Elephant & Castle, and is an appropriate use for a town centre location.
10.4 As reported in the Socio-Economic ES Chapter, FSP research shows that there is significant demand for a 12-15 screen cinema within the catchment area of the Proposed Development. FSP survey data shows that there is potential demand for c. 680,000 cinema visits.
10.5 The new multi-screen cinema is a positive aspect of the Proposed Development, will increase the centre’s offer and attractiveness, and inherently an acceptable land use in this location.
The Music Venue
10.6 The inclusion of a music venue as part of the Proposed Development responds to the ambition to create a cultural hub in Elephant & Castle, once known as the Piccadilly of the South. It is not intended as a direct replacement for The Coronet, which no longer truly acts as a theatre, more of a ‘venue for hire. Other cultural schemes in the vicinity include an auditorium in the proposals for Skipton House and a theatre for Highpoint in Newington Butts, currently under construction.
10.7 The proposed music venue is located in a prominent location, fronting the new peninsula, at the northern end of Newington Butts, directly opposite the new Northern Line entrance. The music venue will improve the vitality of the town centre in the evening, complementing the proposed retail and leisure offer. The venue also includes a lounge and exhibition space on the ground floor and ancillary bar on the first floor, conceived to operate during the day with income producing activities.
10.8 The music venue is of a ‘Medium’ size, as defined in “London’s Grassroots Music Venue Rescue Plan” produced by The Mayor of London’s Music Venues Taskforce. It has capacity for a five hundred standing audience over two floors, allowing it to run commercial concerts with limited dependence on subsidies. The music venue has been
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developed following industry standard design conventions, allowing sufficient flexibility to accommodate specific requirements from an operator.
10.9 The music venue is considered a positive part of the Proposed Development and a contributory to meeting strategic objectives for the town centre. The operation of the music venue will be managed to ensure it has no adverse impact on amenity – we envisage that this will be via a management plan, secured by way of planning condition or part of a legal agreement.
UAL:LCC
10.10 The new UAL:LCC building is a key element of the Proposed Development. The Applicant and design team have worked closely with UAL:LCC for some time to realise their ambitions for a new, modern and flexible education facility in Elephant & Castle that enables them to continue to teach, train and employ a significant proportion of local people. Key aspects of the brief were to be:
More open and accessible to the local community;
Flexible for hosting exhibitions and events throughout the year;
Create space for UAL’s core university service relocating over 500 jobs from other sites;
Relocating its world renowned international language centre, its training and conferencing facilities and its Student Union facilities; and
Providing a home for its renowned archive collection including the Stanley Kubrick archive.
10.11 A three-storey exhibition space is proposed within the building which will provide benefits to the local community (e.g. community lets), as well as enabling UAL:LCC to showcase student work and exhibit some of their ‘special collections’, which includes Stanley Kubrick’s archive.
10.12 The new facility sits adjacent to the new town centre offer, and above the new Northern Line ticket hall and entrance. The building itself spans 12 storeys, including basement, with typical 4m floor to ceiling heights.
10.13 The detailed design rationale is explained in the accompanying Design & Access Statement.
Summary 10.14 The cinema and music venue will provide important new leisure offers for the town centre, underpinned by the town centre’s food and drink offer, whilst the new state of the art UAL:LCC facility will secure their long term future in the Borough.
10.15 In summary, the proposed leisure and educational space is a fundamental component of the Proposed Development and accords with planning policy, the Cultural
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Strategies of both the Mayor and Southwark, and help to complete the vision for the Elephant and Castle Opportunity Area.
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11.0 RESIDENTIAL USE
11.1 This section assesses the Proposed Development against planning policy and guidance specific to residential development.
11.2 The proceeding paragraphs should be read in conjunction with the Design and Access Statement, and Affordable Housing Statement, which assesses the residential component of the Proposed Development and sets out the financial context within which the proposals have come forward.
11.3 Redevelopment of these two brownfield sites would significantly contribute to meeting housing targets by adding 979 new residential units to the existing housing stock – this equates to approximately 36% of Southwark Council’s annual housing target, as set out in the London Plan, and 20% of the indicative housing target for the Elephant and Castle Opportunity Area. Alongside an affordable housing offer these homes will promote opportunity and choice for residents in ways that meet their needs and the strategic objectives for London and the Council. It its pre-application response to the Development the GLA stated that “the proposed delivery of these new homes is strongly supported.”
11.4 The provision of 979 new homes would accommodate a new residential population of approximately 1,850 people, which would generate approximately £1.7m annually in household spending within the Opportunity Area, and £3.7m across the Borough. A significant proportion of this spending will be undertaken locally which results in a number of associated benefits (as outlined in the Chapter 7: Socio-Economics of the Environmental Statement).
Density
11.5 The London Plan and Southwark Core Strategy Policy 5 sets out a density range of 650 to 1,100 habitable rooms per hectare (hr/ha) within the CAZ within which the Application Site currently falls.
11.6 The current adopted methodology for calculating residential density in Southwark is set out in the Residential Design Standards Supplementary Planning Document (2011 and as updated 2015).
11.7 The Proposed Development comprises 2,712 habitable rooms which results in a residential density of 762 hr/ha, comfortably at the lower end of the range for this location. When taking into account retail, leisure, flexible and educational floorspace using LBS’s mixed-use methodology, the density when combined with the residential element rises to 1,512 hr/ha. We note that the majority of this mixed-use floorspace is re-provision of existing facilities rather than new build per se.
11.8 It is acknowledged that the higher mixed-use density for the Development is beyond that set out in Core Strategy Policy 5 within the CAZ. It is however acknowledged in both the Core Strategy and the emerging New Southwark Plan that density ranges can be exceeded in Opportunity and Regeneration Areas where the development demonstrates exemplary standards of design.
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11.9 The Design and Access Statement clearly demonstrates that this Development has been developed to achieve exemplary design standards. Indeed the emerging New Southwark Plan states at in the supporting text to draft policy DM8 that:
“Allowing higher densities in Regeneration Areas, which benefit from high levels of accessibility and provide opportunities to building supporting infrastructure, will ensure [the Council] makes efficient use of our land by providing as much housing as possible whilst reducing out impact on the nature environment.”
11.10 Furthermore, whilst this is in excess of the guidance in the London Plan, this is not uncommon, particularly in Opportunity Areas, and the London Plan Annual Monitoring report (2015) outlines that 56% of residential schemes approved in 2013/2014 were above the optimal density matrix in the London Plan. Indeed, the Mayor of London’s Housing SPG (2016) provides further commentary on density, its application to residential-led mixed use schemes and town centre development, as well as its relevant in the context of a much wider range of amenity, transport and social policies to manage development in ways to secure sufficient numbers and types of home in a high quality environment while taking account of local character.
11.11 Thus, the London Plan includes a density matrix as only one part of a wider policy to optimise development on sites in different settings, with different levels of public transport and accommodating homes of different sizes. It goes on to state that the density ranges are sufficiently wide to accommodate the spectrum of policy considerations which must be taken into account when optimising development at a particular location, notwithstanding the Plan as a whole seeks to deliver as many new homes as possible.
Residential Design Standards
11.12 All residential units have been designed to comply with, and where possible exceed, the London Mayor’s Housing SPG 2016, and Southwark’s Residential Design Standards SPD (2015) to deliver a Proposed Development with a high standard of design. The proposed residential units also comply with the new Technical Housing Standards – Nationally Prescribed Space Standard (CLG, March 2015) in the vast majority of cases. A series of design principles have been achieved for the residential units, including:
Vast majority of the residential units exceed the minimum space standards outlined within the Southwark Residential Design Standards SPD and the London Housing Design Guide (LHDG). A schedule demonstrating compliance is provided as an appendix to the Design and Access Statement.
The residential units are predominantly dual aspect.
Sufficient space for storage is provided in each unit with space for bulk storage also provided in the basement area.
All habitable rooms provide adequate minimum floor to ceiling heights.
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All residential units will be provided with private open space in the form of a balcony, winter garden or terrace, and all residents benefit from access to the communal residential terraces.
The Development seeks to minimise corridor lengths to reduce the number of residential units being access via each core.
All residential units will be designed and constructed to meet relevant sustainability standards.
All residential accommodation exceeds amenity space standards.
All kitchens receive natural daylight and ventilation.
Residential Mix
11.13 The Development will deliver a variety of residential typologies - with a varied mix of unit sizes throughout the residential components of the buildings.
11.14 Table 11.1 below sets out the accommodation schedule:
Mix Units % Studio 16 1.6 1-bed 316 32.3 2-bed 528 54 3-bed 117 12 4-bed 2 0.1 Total 979 100 Table 11.1 – Proposed Residential Mix
11.15 The proposed mix meets the planning policy targets for the Elephant and Castle Opportunity Area that require the provision of a minimum of 10% 3 or more bedrooms, and limiting the provision of studio units to a maximum of 5%. The Development provides over 60% of units with 2 or more bedrooms, in line with policy.
11.16 Furthermore, of the 528 2-bed units, 527 are designed as 2-bed 4-person dwellings.
Wheelchair Accessible Units
11.17 In line with the London Plan, as stated in the Housing Standards Policy Transition Statement published by the Mayor of London in March 2015, 90% of the dwellings are designed to meet Approved Document M4(2) – accessible and adaptable dwellings so that they can be easily adapted to suit the individual needs of the households that live in them.
11.18 Ten per cent of the residential units provided (by total) have been designed for wheelchair housing to meet Approved Document M4(3) – wheelchair adaptable dwellings, and in compliance with the principles of the South East London Housing Partnership Wheelchair Housing Design Guide (SELHPWHDG) so that they can be easily adapted to meet the needs of a wheelchair user.
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11.19 Further details on the wheelchair accessible units, and accessibility more generally, can be found in the Access Statement submitted with the planning application.
Affordable Housing
11.20 The Proposed Development includes provision of 35% affordable housing (calculated by habitable rooms) which equates to 342 affordable homes with a mix of 1, 2 and 3 bed accommodation. The affordable homes will be located across the site and mixed with the open market accommodation, in a tenure blind development, with all residents benefitting from the same amenities. It is intended that all affordable homes will be delivered on Assured Shorthold Tenancies of up to three years with tenant only break options.
11.21 The affordable housing will be made available to a wide range of income levels at a range of discounts to market rent and inclusive of service charge. The affordable housing offer is designed to meet the needs of a significantly greater number of households than would be met by a traditional affordable housing offer and the overall percentage has been maximised by taking this approach, in line with emerging planning policy on such matters. Table 11.2 below summarises the affordable housing element of the scheme:
Mix East Site West Site Total Units Hab Rooms Studio 1 2 3 3 1-bed 63 32 95 190 2-bed 86 131 217 651 3-bed 22 5 27 108 Total 172 170 342 952 Table 11.2 – Proposed Affordable Housing Mix 11.22 We continue to work with the Council and their viability advisers to confirm this position. This affordable housing offer will be concluded as part of the formal planning application process and subsequent Section 106 Agreement.
11.23 Please refer to the Affordable Housing Statement for further details of the affordable housing proposals in the Development.
Summary
11.24 In summary, the proposed residential accommodation is a fundamental component of the Development and accords with planning policy for the following reasons:
It provides a substantial level of new housing that makes a significant contribution to meeting the Council’s targets for housing delivery. It therefore accords with London Plan Policies 3.3 and 3.4 and Core Strategy Strategic Policies 5 and 6.
The Development provides new housing at the Application Site which accords with London Plan Policies 2.13 and 3.14 and contributes towards achieving the Council’s objectives and visions for the Elephant and Castle Opportunity Area.
The approach taken in seeking to deliver the maximum amount of affordable housing on the Site, subject to viability and other material considerations,
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accords with London Plan Policy 3.11 and 3.12 and Core Strategy Strategic Policy 6.
The residential units have been designed to exceed the minimum standards of the Nationally Prescribed Housing Standard, Mayor’s Housing SPG 2016, and the updated 2015 Southwark Residential Design Standards.
Ten per cent of the dwellings will be designed to comply with the principles of the SELHPWHDG and comply with the Wheelchair Housing Design Guide, in accordance with the Southwark Residential Design Standards and London Plan Policy 3.8.
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12.0 DESIGN MATTERS
12.1 This section should be read in conjunction with a number of other application documents, of which the principle documents are listed below:
Application plans Design and Access Statement Environmental Statement Volume II: Townscape, Built Heritage, and Visual Impact Assessment Design Principles
12.2 Sections 3 and 4 of the accompanying Design & Access Statement set out the design objectives, and masterplan design principles in respect of the Proposed Development.
12.3 The brief for the Proposed Development can be grouped together into the following categories:
Public realm
Public transport
Mix of uses
Transport hub
Retail centre
Education
Residential
Cultural
12.4 The vision for the development is to build a vibrant town centre for Elephant & Castle and the wider area, with a strong focus on public realm, public transport and mix of uses.
Scale, Massing and Appearance
12.5 The development plots generated by the new routes through the Application Site are developed with a range of typologies, including building blocks, tall buildings, podiums, mansion blocks and pavilions. Some of these typologies are grouped in ‘families’ while others stand with a singular character.
12.6 The towers on the East Site are arranged in accordance with the principles of the Elephant Park masterplan. The tallest tower on the East Site forms a focal point on the longitudinal axis of the park while the two lower towers follow the footprint, orientation and sequence of tall buildings facing the park.
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12.7 The towers on the West site on the other hand reconcile the street alignment of the conservation area with the strong axis of Newington Butts, offering parallel facades on both orientations. The graphic below denotes the proposed heights and storeys for each of the development plots.
Figure 6: Proposed Building Heights
12.8 The tall buildings in the East and West Site are clustered in families, participating of the same footprint geometry, massing and facade language. This townscape approach resonates with a number of existing and projected buildings around the Peninsula that are also designed as ‘families’: Metro Central Heights, Skipton House and Elephant One. The mansion blocks are also conceived as a family, complementing to the repetitive rhythm of the existing terraces.
12.9 Surrounded by ‘families’ of buildings, the new UAL:LCC facility stands out as a landmark building with a singular massing, composition and cladding. At a smaller scale, the retail building in Block E4 and the Cultural venue in Block W2 are also conceived as singular buildings with distinct characters.
12.10 The Design & Access Statement provides further background rationale and analysis of the proposed scale and massing of the Proposed Development, whilst assessment against relevant policy in terms of views and townscape can be found in the accompanying Townscape, Built Heritage & Visual Assessment (which forms part of the ES).
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Townscape and Heritage
12.11 A Townscape, Built Heritage and Visual Assessment (TBHVA) has been prepared by Professor Robert Tavernor Consultancy, as part of the Environmental Statement.
12.12 The TBHVA assesses the potential effects of the Proposed Development on the character and quality of the surrounding townscape, distant, mid-distance and local views and on the setting and significance of built heritage assets close to the Application Site. It has been prepared based on architectural drawings and the Design and Access Statement (DAS) prepared by Allies and Morrison, which also form part of the planning application, and verified views with Computer Generated Images (CGIs) of the Proposed Development prepared by GMJ which are included in the Views Assessment.
12.13 The TBHVA considers relevant national planning policy and guidance, Historic England advice notes, the London Plan and London View Management Framework, as well as guidance on settings of London’s World Heritage Sites and LBS policy and guidance. The assessment carefully considered impacts on Conservation Areas and Listed Buildings, and splits the local environs into a number of character areas. A total of 40 different viewing positions have been used for assessment purposes.
12.14 In respect of The Coronet, in October 2015 the Secretary of State for Culture, Media and Sport followed the recommendation made by Historic England and decided not to add the Coronet to the List of Buildings of Special Architectural or Historic Interest. The significance of the Coronet is low. This is an unlisted building that does not contribute to a designated conservation area, although its demolition is assessed and justified as an undesignated ‘heritage asset’ in the TBHVA.
12.15 It is relevant to note that Historic England considered the emerging development proposals in February 2016. HE confirmed it would be a statutory consultee on a subsequent planning application, but that it was not necessary for them to participate in detailed pre-application discussions unless there were material changes to the proposals that would affect the historic environment.
12.16 The Built Heritage Assessment assessed the likely long-term significant effects of the Proposed Development on the settings of listed structures and identified undesignated heritage assets in the local area, and Grade I and II* assets within the wider area, where it is judged that through their location or setting they may be sensitive to the impact of the Proposed Development. The likely effects on those elements of setting that contribute to the significance of the listed structures in the local area would be negligible.
12.17 In the Townscape assessment, the likely effects on the townscape character and quality of central Elephant and Castle, within which both the East and West Sites are located, and on the settings of surrounding townscape character areas, has been assessed. The Proposed Development would have a major beneficial effect on the character and quality of Character Area 1: Central Elephant and Castle. The likely effects on surrounding character areas would range from negligible in areas more distant from the Application Site to moderate or major, beneficial closer to the East or West Sites.
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12.18 In the Visual Assessment, the suitability of the design of the Proposed Development in its spatial location has been assessed using 40 different viewing positions and a kinetic sequence of views of the Westminster WHS, which were selected in consultation with the Council. These views permit the Proposed Development to be assessed in the round and its effect on visual amenity to be tested allowing the likely effects of the Proposed Development sought for approval to be understood. As the assessment demonstrates, the Proposed Development, where visible, would have no effect, negligible or minor, beneficial likely effects on regional and sub-regional designated LVMF SGP (Ref 1-6) views. The likely effects on district views would range from no effect to moderate, beneficial. The likely effect on local views would range from negligible to major in magnitude and would be neutral or beneficial. Taking into account the sensitivity to change of the view and the high design quality of the Proposed Development sought for approval none of the likely significant effects are judged to be adverse.
12.19 Overall, the Proposed Development has been conceived as an integral part of the townscape of the locality. It would have a distinctive character and sense of place, drawn from analysis of the specific location of the Application Site. The legibility of the Proposed Development, the high quality of the architectural and urban design, enhanced permeability and connectivity and the creation of well defined, active street frontages and new public realm would significantly enhance the local townscape. The Proposed Development would not harm strategic or local townscape or visual amenity or the settings of designated heritage assets in the local area.
Public Realm, Trees, Landscaping and Amenity Space
12.20 Section 6 of the accompanying Design & Access Statement, prepared by Townshend, sets out the approach to public realm and landscaping.
12.21 The Section is split into two sections - the first section describes and analyses in detail the public realm and podiums for the East site. The second section will go onto describe the public realm and podiums for the West site. The public realm on both sites have been an important factor in linking the two sites together.
Arboricultural Implications
12.22 An Arboricultural Survey and Implications Assessment has been carried out by Waterman to assess the extent and quality of existing trees on the Application Site, and identify trees to be removed and retained to facilitate development.
12.23 The removal of some existing trees will be required to facilitate the Proposed Development due to both a direct conflict with the proposed built form and indirect requirements relating to construction access. Existing trees to be removed comprise individual trees T3 to T11, T13, T16, T17, G24, T25, T27 and T28 growing within the Application Site boundary. This will comprises 6 No. trees graded as ‘B’ Category trees being of medium quality, 5 No. trees graded as ‘C’ Category being of low quality 1 No. tree group graded as ‘C’ Category being of low quality and 4 No. trees graded as ‘U’ Category being unsuitable for retention. No grade ‘A’ trees require removal.
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12.24 Trees to be retained include trees T2, T12, T14, T15, T18 to T23 and T26 growing within the Application Site boundary. Protection measures and recommendations are set out in respect of trees to be retained.
12.25 New tree planting will be provided as an integrated part of the Proposed Development and will reinforce the existing trees to be retained and provide visual amenity and long term environmental benefits. The proposed tree planting includes new street trees flanking the adjacent highway network and feature trees located internally within the East and West Sites. New tree planting is identified on the submitted Townshend drawings.
Public Realm & Landscape Design Principles
12.26 A ground floor analysis has been undertaken that considers both East and West Site’s in terms of pedestrian routes, key entrances and traffic flows.
12.27 This analysis has informed the design evolution and layout of the Proposed Development, culminating in the new areas of public realm and streetscape, pedestrian connectivity and entrances, surface treatments, furniture and material palette, as well as trees and soft landscaping.
12.28 The East Site at surface level is split into a number of spaces, with a focus on pedestrian usability. The Court forms the central civic space, a new public square at the focal point of the new town centre. The Court is connected by routes at all of its four corners, linking to the peninsula to the northwest, Newington Butts to the southwest, two links through the railway arches to the east. The Court and four ‘Retail Streets’ will all have active frontages and improve permeability. Tree planting is proposed on the west, southwest and north boundaries of the East Site, as well as within The Court. The upper podium levels provide substantial areas of lawns and decking/terraces, play space and planting.
12.29 The public realm proposals comprise a variety of high quality surface materials such as yorkstone paving and natural stone, street trees and planters, as well as seating cycle parking.
12.30 The West Site at surface level comprises the extension of Pastor Street to the north into area of public realm, and a high quality upgrade of Oswin Street, the west side of Newington Butts and St George’s Road. Again, the proposal comprise high quality areas of yorkstone paving and stone finishes, tree planting, pocket gardens (Oswin Street) and street furniture. Podiums and terraces provide lawn areas and further planting above all three building plots.
Residential Amenity Space
12.31 All 1-bed, 2-bed & 3-bed residential apartments have a private balcony contributing to meet the requirements of relevant policy. In the majority of cases, private amenity space meets relevant size requirements. Communal amenity space at roof garden and podium level, plus the new areas of park space adjacent to East Site (via the new arches route) will boost the overall amenity space levels for this town centre location.
12.32 The development as a whole, aims to provide a significant area and range of external amenity and play spaces across the communal gardens and terraces.
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12.33 The Roof Gardens provide shared access for each of the residential towers 1, 2 & 3 and significantly over delivers in external amenity and play space. Additional external amenity space is provided at the Roof Terrace (level 25).
Children’s Play Space
12.34 Informal play space will be provided for the younger age groups in close proximity to the front door of their house. In the West Site substantial amenity space and 0-4 age group space is provided, with space for age groups 5-11 and 12+ located off site. On the East Site play for all age groups will be provided on the Podiums of Buildings E2 and E3.
12.35 Overall, the West Site delivers approx. 846sq.m of playspace, and the East Site 463sq.m. As above, substantial areas of communal amenity space are provided at roof garden and podium level, notwithstanding the new park east of the East Site.
12.36 Notwithstanding the element of offsite playspace proposed for age groups 5-11 and 12+, the level of playspace provision is policy compliant.
Summary
12.37 The proposals for the Development have developed over an intensive period of design evolution in direct response to planning policy, local context, and consultation. The Development will comply with national, regional and local policies relating to the design, specifically the NPPF, London Plan Policies 7.8, 7.9, and 7.12, Core Strategy Strategic Policy 12.
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13.0 TRANSPORT AND ACCESS
Introduction
13.1 This Section should be read in conjunction with the Transport Assessment (TA) and Travel Plan (prepared by WSP | Parsons Brinckerhoff) which are submitted to accompany this planning application. These documents, which also inform the relevant Chapter of the Environmental Statement, provide a comprehensive review of the Proposed Development and a robust assessment of the transportation impacts. The documents also identify any mitigation measures to ensure safe access to and from the Application Site, and circulation within it.
13.2 The submitted Travel Plan provides a framework for encouraging and delivering sustainable travel in and around the Application Site, and identifies the potential measures that may be introduced to promote alternative means of travel other than private car e.g. walking, cycling and public transport. The Travel Plan is also intended to provide a mechanism to monitor performance once the Proposed Development is complete and occupied.
13.3 The proposed Development is well located for access to London Underground (Bakerloo and Northern Lines), National Rail, and local bus services, with a Public Transport Accessibility Level (PTAL) of 6B, which represents the highest level of accessibility and defined by TfL as “Excellent”.
13.4 The Transport Assessment and Travel Plan address a number of fundamental issues, including:
Relevant planning policy and guidance;
Existing local pedestrian, cycle and public transport connectivity, including baseline assessment;
Local highway conditions, baseline and future baseline;
The proposed development and anticipated changes in travel demand, including existing/proposed trip generation;
Servicing arrangements, waste and vehicular access, car and cycle parking; and
Road network and public transport assessment.
Pedestrian Permeability
13.5 The Application Site’s inner London location means that most essential amenities are available in the local vicinity and can be accessed on foot. Notwithstanding this, there are varying levels of provision for pedestrians. Along certain routes such as New Kent Road, Walworth Road and Newington Butts, the footways are of an adequate width with good access to bus stops and London Underground, however there is poor provision on Elephant Road and limited connectivity to new developments east of the arches.
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13.6 Recent works at the Elephant & Castle southern roundabout have seen significant improvements delivered to the public realm and pedestrian space, including the provision of signalised pedestrian crossings.
13.7 The pedestrian environment in the vicinity of the Elephant & Castle northern roundabout is generally of a poor quality in terms of navigation around or across the roundabout. In particular, given the volume of traffic using the roundabout, the existing at-grade pedestrian crossing facilities are limited with signalised crossings on the London Road and New Kent Road approaches to the roundabout only including into the centre of the roundabout.
13.8 The Proposed Development results in clear benefits for pedestrian permeability and quality of the public realm. The new shopping centre, UAL:LCC building and reconfigured Underground access on the East Site provide a series of open streets, strong links and sightlines to the Peninsula and a new east-west link through the railway arches to connect with the Heygate Estate masterplan. Footway widths, comfort levels and bus stop locations have been carefully assessed and are re- provided.
13.9 The West Site is also subject to the creation of new streets and pedestrianised areas. Oswin Street’s eastern footway will be widened, Pastor Street will be pedestrianised and generous areas of public realm created on the Newington Butts (east) and St George’s Road (north) frontages respectively.
Cycle Connectivity and Cycle Parking
13.10 Cycling is a popular and accessible mode of transport in London and has the potential to substitute for short car trips, particularly those less than 5 km. The Application Site provides good access to cycle routes with onward connections to a variety of destinations, as shown in the TA, which demonstrates that it is possible to reach all of central London within a 30 minute cycle journey.
13.11 There is a dedicated off-carriageway cycle lane on the southern side of New Kent Road. Two adjacent lanes are provided for travel in each direction. To the east of Rodney Place, this cycle lane continues as far as Balfour Street while to the west, the cycle lane ends approximately 70m before Elephant Road. There is a dedicated cycle lane on Elephant Road, the lane is off-carriageway and is currently interrupted by the ongoing construction of Elephant & Castle Regeneration project. North of the station entrance on Elephant Road the cycle lane is hoarded in its entirety. There are no dedicated cycle lane facilities on Walworth Road. However, Advanced Stop Lines (ASLs) are provided on the Walworth Road approach to the Southern Junction.
13.12 The key routes in the vicinity of the Proposed Development include the Cycle Superhighway from Merton to the City (CS7) along Newington Butts, Churchyard Row, Elliott’s Row, Princess Street and Southwark Bridge Road, by-passing the southern junction and the northern roundabout. To the south, it connects with Kennington, Oval, Stockwell, Clapham until Colliers Wood on an approximately journey of 40 minutes.
13.13 The North South Cycle Superhighway started its construction at St George's Circus in March 2015 and will be completed by spring 2016. The cycleway will run for
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approximately 4km to the north of the Application Site from St. George Road towards Blackfriars, New Bridge Street, Farringdon Street until Judd Street only 300 meters from Kings Cross station.
13.14 Publicly accessible cycle parking is available at a number of locations surrounding the site as follows:
Two Sheffield stands (four cycle parking spaces) are available on New Kent Road, just east of the junction of New Kent Road with Rodney Place;
Four Sheffield stands (parking for eight bicycles) are provided on Larcom Street close to its junction with Content Street;
Four Sheffield stands (parking for eight bicycles) available for cycle parking on Wansey Street, close to the junction of Wansey Street with Walworth Road; and
Five Sheffield stands (parking for ten bicycles) are provided on Elephant Road outside of Elephant & Castle station.
13.15 There are seven London Cycle Hire docking stations in the vicinity of the proposed Development located as follows:
Walworth Road adjacent to Elephant & Castle Shopping Centre / Southern Junction: 29 spaces; Walworth Road adjacent to Strata: 21 spaces; Wansey Street: 16 spaces; Rodney Road: 24 spaces; New Kent Road: 32 spaces; Newington Butts: 21 spaces; and Ontario Street: 14 spaces. 13.16 In terms of the proposed scheme, 2,273 cycle parking spaces are proposed across the Application Site. The cycle parking provision is compliant with London Plan requirements. 1,626 long stay and 25 short stay spaces are proposed to serve the new residential units, all of which are located in secure storage areas with access from ground level via ramp/lift as appropriate. 291 long stay and 193 short stay spaces are proposed to serve the new UAL:LCC building, the long stay spaces located at secure locations. A further 24 long stay spaces are situated on the East Site to serve the retail and leisure element, with 42 short stay spaces. The West Site comprises 47 long stay spaces for the flexible use, retail and cultural (music) venue, with 25 short stay spaces.
Public Transport Accessibility
13.17 Transport for London (TfL) utilise the Public Transport Accessibility Level (PTAL) model to provide an indication of a site’s accessibility to the public transport network. The PTAL methodology takes into account the time taken to access the public
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transport network. The PTAL methodology considers all rail stations and bus stops located within a 12 minute walk (960m) and eight minute walk (640) of the site respectively. An access Index is calculated for each mode and then aggregated into a PTAL ranging between 0 (poor) to 6b (excellent). The TfL online PTAL online model indicates the Application Site currently has a PTAL of 6b.
13.18 Elephant & Castle is a key node on the London bus network. The majority of passengers are observed to board or alight in the vicinity of London Road, St George’s Road and Newington Butts outside the shopping centre where there is the highest concentration of stops. A total of 28 bus routes serving the area result in a cumulative service frequency of over 200 buses per hour during the busiest peak periods. All services currently stop twice in the vicinity of the shopping centre as they route through Elephant & Castle.
13.19 Elephant & Castle Rail Station is situated on Elephant Road to the east of the shopping centre and is built on two arched viaducts. Rail services are provided by Thameslink and South Eastern Trains and comprise a range of services and destinations per hour during the busy peak periods (14 trains an hour AM, and 10 trains per hour PM). Pedestrian access is either via Elephant Road or, during opening times directly through the shopping centre. The station has poor accessibility from its surrounding environs and is not DDA compliant.
13.20 Elephant & Castle underground station is a key interchange on the network and one of only six interchange stations south of the River Thames. The station is served by the Bakerloo Line, for which Elephant & Castle represents the southern terminus (until the Bakerloo Line extension comes forward), and the Northern Line. The cumulative service frequency is approximately 48 trains per hour during the peak periods. There are therefore very good direct links to Central London and across the capital.
13.21 The station is comprised of separate ticket halls for both Bakerloo and Northern lines. The Bakerloo Line Ticket Hall is located on London Road on the north side of the northern roundabout. The Northern Line Ticket Hall is located adjacent to the shopping centre on the south side of the northern roundabout. The two ticket halls are connected track-side by sub surface passageways as well as at surface through the northern roundabout. Connections to the platforms from the ticket halls are via lifts and emergency stairs only, with a capacity of two lifts at the Northern Line Ticket Hall and three lifts at the Bakerloo Line Ticket Hall.
Car Parking
13.22 Considering the Application Site’s location and excellent PTAL it is proposed to provide only three blue badge car parking spaces for LCC employees and 13 blue badge car parking spaces for disabled residents of the East Site, located at basement level on the East Site, with 34 blue badge spaces for residents at the West Site. Twenty percent of the spaces will have active electric charging points from first occupation. No general parking for the public, residents or employees will be provided. This limited number of car parking spaces will generate very few traffic movements and is consistent with policy at all levels that seeks to encourage sustainable transport patterns. Swept path analysis has been carried out to show how safe vehicle access can be made to and from the car parking areas at the East and West Sites.
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Travel Demand and Impact on the Highway Network
13.23 The TA comprises a detailed existing and proposed trip generation assessment. The assessment takes into account existing education, office, retail and leisure trips, car park and servicing movements for both East and West Sites. A corresponding assessment of proposed trips has been undertaken for both East and West Sites, taking into account the new residential use, educational, office, retail, leisure and servicing trips. Servicing specifically is addressed in the next subsection.
13.24 A summary of the net change in daily trips as a result of the Proposed Development can be found below.
AM Peak (0800- PM Peak (1700- Daily 0900) 1800) Arr. Dep. Total Arr. Dep. Total Arr. Dep. Total Vehicles -13 7 -7 -2 -20 -23 -113 -102 -215 Vehicle -1 5 4 -2 -3 -4 -16 6 -8 Passengers Cyclists 13 47 60 9 17 26 185 167 352
n o i t
a Pedestrians 34 204 238 50 101 150 845 817 1663 r e n e
G Bus/Tram 28 156 184 73 18 93 544 601 1145
p i r Rail 5 48 52 17 2 19 125 140 264 T Underground 27 153 180 78 16 93 532 589 1120 Coach 0 0 0 0 0 0 0 0 0 Total 93 620 713 227 133 360 2102 2219 4321 HGV -3 -2 -4 -1 -1 -2 6 6 13
g n
i LGV -4 -3 -6 -1 -1 -1 32 32 65 c i v r
e Car 0 0 0 0 -1 -1 0 0 1 S Total -6 -4 -9 -1 -2 -4 39 40 79 Overall 87 616 704 226 130 356 2142 2259 4400 Total Table 13.1: Net Change in Trip Generation
13.25 As shown above, the Proposed Development results in a net reduction in daily vehicle trips and vehicle passengers, as well a negligible impact on coach trips. The increases in trips are solely within the pedestrian, cycling and public transport modes i.e. sustainable means of travel.
13.26 The net reduction in vehicular trips is anticipated partially as a result of the removal of the existing 140 space public car park, and provision of only 35 disabled resident bays on the West site and 13 disabled resident bays and 3 disabled LCC employee bays on the East Site. The scheme will therefore be beneficial to the operation of the local highway network.
13.27 The additional pedestrian and cycle movements can be accommodated within the existing (and recently upgraded) highway network together with new areas of public realm provided as part of the Proposed Development.
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13.28 The additional public transport trips made via overground rail, bus and underground modes have been considered from a baseline and future cumulative scenario. The trip generation analysis concludes that impacts on rail and bus capacity will be negligible. On the Bakerloo and Northern Lines it has been demonstrated that there will be no significant decreases in space capacity on the line as a result of the proposed Development.
Servicing, Vehicular Access and Waste
13.29 Currently the East site has a basement service yard and two-level public car park, both of which are accessed from Elephant Road - the Proposed Development seeks to re- provide a new basement service yard and a small amount of parking for disabled residents of the scheme. UAL:LCC servicing is currently undertaken from two areas; the dedicated service yard in the centre of the West Site accessed via Pastor Street, and the car park to the north, accessed from Oswin Street. Delivery and servicing movement surveys were undertaken for the Application Sirte in October and November 2015. The survey results are summarised in the accompanying TA.
13.30 The proposed East Site will provide a new basement service yard accessed through a dedicated servicing access from New Kent Road. This service yard will provide 4 retail loading bays, 6 compactor bays and 1 loading bay for LCC (as well as the 3 blue badge car parking spaces for LCC employees and 13 blue badge car parking spaces for residents). The proposed servicing of the office and residential land uses on the West Site will be mainly undertaken within a dedicated service yard consisting of 3 delivery bays and 3 compactor bays, accessed via Pastor Street. One retail loading bay is also proposed on Oswin Street.
13.31 The existing servicing movements attributed to the East and West Sites were used in part to delineate an associated servicing trip rate for the proposed land uses on both East and West Sites. The servicing trips estimated to occur during the morning and even peak hours have been redistributed outside of the peak hours to reflect the peak hour servicing restriction that will be managed on the Application Site through a Delivery and Servicing Strategy.
13.32 A marginal increase in daily servicing trip generation is anticipated. This is expected to have an overall negligible impact on the local highway network, and through the servicing management strategy will be properly managed to minimise any potential impacts.
13.33 A Waste Management Strategy has been prepared by WSP to accompany the planning application. The report identifies relevant waste legislation policy and guidance, and goes on to assess waste generation requirements and strategies, facilities management and collection processes for both East and West Sites.
13.34 In terms of household waste, residential units will incorporate sufficient internal waste storage containers to promote the separation of recyclable materials at source. Container numbers have been quantified using residential waste generation metrics detailed within LBS’s Waste Management Guidance Notes for Residential Developments guidance document. All household waste storage areas will be clearly labelled to ensure cross contamination of refuse and recycling is minimised.
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13.35 In terms of commercial waste, tenants will be responsible for designing and providing sufficient internal waste storage space within their unit as part of fit out. This will be the first point of waste disposal for waste generated within the units. Sufficient space within the main waste store has been provided to accommodate the required number of bins; the required quantum of bins has been quantified using commercial waste generation metrics detailed within BS 5906:2005. The main commercial waste store will be built to BS 5906:2005 specifications. Commercial tenants’ staff will be responsible for transporting waste from their respective unit to the main commercial waste store. All commercial waste storage areas will be clearly labelled to ensure cross contamination of refuse and recycling is minimised. The cost of the waste collection services will be allocated to each of the commercial unit operators and recovered through appropriate service charges as stated in the Tenancy Agreements. The commercial waste collection contract will be in place pre-occupation of all commercial units.
13.36 Overall, the Waste Management Strategy has taken into account the need to lessen the overall impact of waste generation through recycling of materials from the operational phase of the Application Site. The proposals set out in the Strategy meet the requirements of relevant waste policy and follow applicable guidance.
13.37 A Framework Delivery and Servicing Plan (DSP) has been prepared to accompany the planning application. The DSP is applicable to the Application Site and will form the basis of subsequent detailed DSP documents which will be developed once the end users, on-site strategies and service contracts are agreed. The submitted DSP summarises the Proposed Development in the context of relevant London Plan policy and other best practice guidance including TfL’s ‘Managing Freight Effectively: Delivery and Servicing Plans’.
13.38 The DSP goes on to outline the proposed servicing and refuse collection proposals, and how the Proposed Development will function in terms of:
Design (e.g. off-street servicing, risk assessment of service areas, service vehicle size restrictions, traffic management, security measures and secure drop-off);
Procurement Strategy (e.g. freight operator recognition scheme and consolidation of suppliers);
Operational Efficiency (e.g. delivery restrictions and enforcement, promotion of freight information portal, communication of delivery procedures, workplace servicing booking / management strategy, our of house deliveries, staff training requirements and responsibilities);
Waste Management (as informed by the Waste Management Strategy); and
Road Trip Reduction (e.g. delivery and collection frequencies, encouraging deliveries by sustainable modes).
13.39 It is envisaged that a nominated Site Manager will be responsible for monitoring and review of the DSP, with post-completion surveys to be completed and shared with Southwark and TfL in the form of a review and amendment process where necessary.
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Construction Traffic Management
13.40 To accompany the planning application, MACE has prepared a draft Construction Management Plan Pro-forma and a Project Access Review. Clearly, with the recent remodelling of the surrounding highway network, and prospect of a phased scheme, there are sensitivities relating to maintaining transport and pedestrian links during construction, as well as managing construction traffic. All access proposals need to consider how pedestrians are managed and how the transport links interface. In many cases bus stops may need temporarily relocated, or cycle and pedestrian routes may need adapting to accommodate construction access points.
13.41 The submitted draft Construction Management Plan Pro-forma and Project Access Review seek to provide the Council with an initial proposal for transport and traffic management during construction, as well as monitoring, compliance, reporting and consultation. These documents should also be read alongside any subsequent Demolition / Construction Environmental Management Plan, as advocated by the accompanying ES, to be secured by planning condition. The accompanying TA also comprises a dedicated chapter in respect of construction and its impact on the highway network, specifically addressing logistics, construction hours and traffic routing, servicing movements, temporary traffic measures and arrangements for construction personnel.
Summary
13.42 The Proposed Development complies with current transport policies and offers future users the opportunity to access the Development by a variety of different travel modes. The effect of the transport aspects of the Proposed Development on the surrounding highway and public transport network have been assessed for the construction and operational effects. The TA demonstrates that the trips generated by the Proposed Development can be accommodated within the local transport network with no significant adverse effects.
13.43 The Development fully accords with London Plan Policy 6.3 which requires proposals to be fully assessed to ensure there is sufficient road network capacity. The Proposed Development is also car free in line with the Council’s policies and maximises the provision of cycle parking in line with London Plan standards. The Development accords with Core Strategy Strategic Policy 2: Sustainable Transport which requires applications to demonstrate that any impacts are minimised, cycle parking is maximised and a range of sustainable transport options are provided.
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14.0 ENVIRONMENTAL CONSIDERATIONS
Introduction
14.1 The purpose of this Section is to summarise the findings of the main Chapters of the Environmental Statement (ES), and other reports accompanying the application, against relevant planning policy. A full assessment of the impacts of the Proposed Development is included in the ES, which also recommends any mitigation measures that may be required as a result of the Proposed Development.
Energy and Sustainability
14.2 Energy efficiency and sustainability considerations have been an important element of the planning and design process for the Proposed Development. It will continue to underpin any details reserved by condition for subsequent approval, as well as during the construction and operational periods of the Proposed Development.
14.3 An Energy Strategy (prepared by Hoare Lea) is submitted with the planning application which demonstrates how the Proposed Development will comply with relevant carbon reduction and planning policy, with a high-level summary provided below:
Be Lean - The use of energy efficient measures results in a saving of 4% (271 tonnes of CO2 per annum) over Part L 2013 emissions.
Be Clean - On site CHP proposed for the Application Site will result in 22% (748 tonnes of CO2 per annum) reduction in CO2 emissions over Part L 2013 emissions.
Be Green - The use of solar photovoltaic panels results in a 1% (94 tonnes of CO2 per annum) over Part L 2013 emissions.
14.4 As a result of the proposed concept design strategy the Application Site’s total emissions reduction will be 1,113 tonnes of CO2 per annum and an overall 27% improvement is achieved over the Building Regulations 2013 baseline.
14.5 Since the Proposed Development falls short of the London Plan target (35% CO2 reduction) by 8%, a carbon offset payment of £476,000 may be payable to the Council. The offset payment is based on £60/tonne of CO2 for 30 years will only be made payable subject to it being in compliance with all legal requirements, including the CIL Regulations 2010 (as amended).
14.6 A number of BREEAM pre-assessments have been undertaken and accompany the planning application. The assessments show that the majority of the Proposed Development is capable of targeting a BREEAM ‘Excellent’ rating for non-residential buildings / uses. The retail elements of the East and West Sites and the Music Venue will target BREEAM ‘Very Good’ with an aspiration for ‘Excellent’.
14.7 A Sustainability Statement and Checklist (also prepared by Hoare Lea) is submitted to demonstrate how the Proposed Development delivers against general sustainability
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criteria and best practice. The Statement and Checklist assesses the Proposed Development against the following criteria:
Resource Management, Site Layout and Building Design, Energy and Carbon Dioxide Emissions, Carbon Dioxide Offsetting and Retrofitting
Monitoring Energy Use, Supporting a Resilient Energy Supply, Water Efficiency, Materials and Waste
Nature Conservation and Biodiversity, Climate Change Adaptation, Increasing Green Cover and Trees
Flooding, Pollution Management, Air Quality, Noise, Light Pollution, Water Pollution and Wastewater Treatment.
14.8 It is considered that the Development accords with London Plan Policies 5.2, 5.5, 5.6 and 5.7, Core Strategy Strategic Policy 13 and saved Southwark Plan Policies 3.3 and 3.4.
Noise and Vibration
14.9 ES Chapter 9, prepared by Waterman, presents an assessment of the suitability of the Application Site for the Proposed Development considered from a noise and vibration perspective. The chapter also considered effects from demolition and construction activities, and traffic.
14.10 The noise and vibration effects of the Proposed Development have been established in accordance with published guidelines and best-practice. The assessment has used comprehensive baseline noise monitoring surveys undertaken by Waterman in 2014, 2015 and 2016 together with vibration monitoring undertaken by Hoare Lea the acoustic design consultants in 2014. Local receptors to the Proposed Development which would be sensitive to noise and vibration have been identified. The dominant noise sources at the Application Site are that of road traffic associated with the surrounding local highway network and the elevated railway line located to the east. In addition to this London Underground lines are located under and proximate to the Application Site.
14.11 Demolition and construction works are likely to include activities that are predicted to result in a temporary increase in noise and vibration levels within areas within and immediately adjacent to the Proposed Development. In particular, when activities are occurring closest to the sensitive receptors, this could result in temporary short-term impacts on nearby occupants, particularly residents on Oswin Street. Changes to the number of vehicles on the road network, with a higher proportion of lorries and vans during the demolition and construction phase has been assessed and quantified. Due to the relatively high flows on the existing road network, this is predicted to give rise to insignificant effects with adverse effects of minor significance on Brook Drive during peak construction flows.
14.12 A number of measures would be taken to minimise the amount of noise and vibration arising from the Application Site such as:
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the careful selection of modern and quiet plant and machinery;
the erection of suitable hoardings;
the setting of noise and vibration limit levels which would be previously agreed with LBS; and
the selection of specific construction techniques which would minimise levels of vibration.
14.13 These measures would be included in a Construction Environmental Management Plan, to be secured by condition. With these measures in place, residual noise effects are considered to be predominantly insignificant to adverse effects of moderate significance, when works are being undertaken in close proximity to sensitive receptors.
14.14 In terms of vibration, piling will be undertaken as part of the Proposed Development and at this stage it is anticipated this will consist of the most benign methods of CFA and rotary bored. However due to the relatively close proximity of works to sensitive receptors this may give rise to temporary disturbance. Monitoring during work undertaken near Oswin Street and the Metropolitan Tabernacle is therefore recommended. With mitigation measures in place and adherence to agreed vibration limits, insignificant to adverse effects of minor significance are predicted.
14.15 With regards to the suitability of the Application Site for residential and education use, inherent design measures, developed by the scheme’s acoustic consultant’s Hoare Lea, ensures that the required internal ambient noise levels would be achieved. Inherent design measures are also included to provide suitable external amenity areas.
14.16 The Proposed Development is considered acceptable from a noise and vibration perspective, and therefore complies with planning policy, in particular the relevant national guidance, London Plan Policy 7.15, Core Strategy Policy 13 and Southwark Plan Policies 3.2 and 4.2
Air Quality
14.17 ES Chapter 10, prepared by Waterman, addresses air quality in respect of the Proposed Development and assesses its potential effects on human health and the environment. Air quality is considered both in terms of demolition and construction, as well as the completed and operational stage.
14.18 The main potential effects on local air quality during the demolition and construction works of the Proposed Development relate to dust. A range of measures to minimise or prevent dust would be implemented through the Construction Environmental Management Plan (CEMP) so that no significant dust effects would result.
14.19 Any emissions from equipment and machinery operating on the Application Site during the construction works would be small in comparison to the emissions from the volume of vehicles travelling on roads surrounding the Application Site, and would need to adhere to the emissions set out in the London Plan. Such emissions would not significantly affect air quality.
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14.20 Accounting for the implementation of a Construction Logistics Plan (CLP), it is anticipated that the effect of construction vehicles entering and egressing the Application Site would not be significant, again when considered against existing traffic volumes in the vicinity.
14.21 Computer modelling has been carried out to predict the contribution of heating plant emissions and future traffic related emissions arising from the operation of the completed Development, and the likely resultant changes that this would bring about to local air quality. The likely effect of the Proposed Development on local air quality has been predicted for a number of existing sensitive locations surrounding the Application Site, and at future sensitive residential locations within the Proposed Development.
14.22 The results of the computer modelling demonstrate that with the Proposed Development in place, their operation would not to give rise to a significant air quality effect that would adversely affect the occupants of existing sensitive locations surrounding the Application Site.
14.23 Taking into account the design of the Proposed Development (residential receptors located away from the more heavily trafficked roads and above ground level, as well as utilising mechanical ventilation where necessary), it is considered that the Application Site is suitable for residential use.
14.24 The Proposed Development is considered acceptable from an air quality perspective, and therefore complies with planning policy, in particular the relevant NPPF tests and guidance, London Plan Policy 7.14 and Southwark Plan Policy 3.6.
Ground Conditions and Contamination
14.25 ES Chapter 11, prepared by Waterman, addresses ground conditions and contamination in respect of the Proposed Development and assesses its potential effects on human health and the environment.
14.26 Two desk based Preliminary Geo-Environmental Risk Assessments were carried out by WSP Ltd in July 2014 and August 2015 and then updated in 2016 to reflect the 2016 planning application scheme to highlight the geotechnical and environmental considerations, predominantly with respect to ground, ground gas and groundwater conditions, which may potentially arise as issues associated with the redevelopment of the Application Site. These reports are appended to the ES and informed the preparation of a Conceptual Site Model, in order to evaluate the potential and likely residual contamination risks associated with the Application Site.
14.27 Potentially contaminative historical Application Site uses were identified, predominantly relating to industrial land use. These included works, workshops, warehouses, a timber yard, oil works and oil-fired boilers with tanks.
14.28 Geology and hydrogeology for the Application Site was inferred using information from the British Geological Survey and Environment Agency. The Application Site is indicated to be underlain by Made Ground, then Alluvium and River Terrace Gravel Formation containing shallow groundwater. Beneath this is London Clay Formation, followed by Lambeth Group and Thanet Sands Formation which also contain deep
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groundwater. The bedrock is Chalk Group, which contains a regionally significant source of groundwater. A culverted river, the River Neckinger was identified running beneath the Site.
14.29 Potential sources of contamination identified beneath the Application Site include Made Ground associated with the historical land uses, historical leakage from the oil works and oil-fired boiler. Ground gas and vapours arising from contamination in Made Ground, and contamination in groundwater within Alluvium and River Terrace Gravel Formation underlying the Application Site are also potential sources, along with storage of potentially contaminative materials on-Site during construction. There is also the potential for unexploded bombs beneath the Application Site (medium risk at the East Site and high risk at the West Site).
14.30 Future receptors for potential contamination include construction workers, Proposed Development users, current and future off-Site users, vegetation at private gardens at the Proposed Development, the shallow and deep groundwaters, future sub-surface structures and services, both at the Application Site and off-Site.
14.31 An intrusive ground investigation would inform the necessary measures to protect future Site users and off-Site users, shallow groundwater and deep groundwater, and the culverted River Neckinger. These would be implemented via a Remediation Strategy, and through appropriate design of the Proposed Development structures, sub-surface structures and services, and piled foundations. The use of clean topsoil at the private gardens would protect vegetation in these areas. Construction workers should be protected though use of correct safety equipment, and carrying out construction work in-line with appropriate regulations and best practice.
14.32 We expect that ground conditions and contamination mitigation measures, including in respect of unexploded ordnance, can be secured by way of appropriate planning condition, attached to a prospective planning permission decision notice.
Water Resources and Flood Risk
14.33 ES Chapter 12, prepared by Waterman, addresses water resources and flood risk in respect of the Proposed Development and assesses its potential effects on flood risk, surface water drainage, and capacity of foul and potable water supply infrastructure.
14.34 During demolition and construction, changes in Application Site conditions have the potential to result in a temporary risk of surface water flooding. However, measures would be put in place to control surface water runoff from the Application Site in line with industry standards. Where appropriate, cut-off drainage would be provided around the Application Site during the construction phase when there is no on-Site drainage network in place.
14.35 Localised groundwater flooding could also occur during the excavation works required to construct the basements within the Proposed Development. Appropriate building practices with regard to the basement construction should be employed to prevent groundwater ingress.
14.36 Although the Application Site is located within Flood Zone 3, the Application Site is protected by the Thames flood defences, and as such, the Application Site's risk of
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flooding from the River Thames is considered to be low. In the unlikely event of a breach of flood defences coupled with extreme water level, the maximum flood depth would be approximately 1.33m, based on a minimum proposed ground level of 2.28m AOD. To address this, the Proposed Development has been designed to ensure the safety of occupiers and users of the buildings.
14.37 A surface water drainage strategy for the Proposed Development has been developed, which includes measures to reduce water runoff from the Application Site and control the rate of discharge of this water to the local sewer network. These measures include the use of sustainable urban drainage (SuDS) methods and the plan also allows for the likely future increase in rainfall due to climate change. The Proposed Development would not increase flood risk on the Application Site or elsewhere beyond the Application Site boundary, which is in line with national and local policy.
14.38 There would be an overall reduction in the combined surface water and foul water discharges as a result of the Proposed Development. Therefore, there is likely to be capacity to accommodate the combined (foul and surface water) discharge flows from the Proposed Development.
14.39 There would be an increased demand for water supply resulting from the Proposed Development. However, the implementation of water efficiency measures would be incorporated into the Proposed Development to minimise the demand as far as possible.
14.40 The Proposed Development is considered acceptable from a flood risk perspective, and therefore complies with planning policy, in particular the relevant NPPF tests and guidance, London Plan Policy 5.12, Core Strategy Policy 13 and Southwark Plan Policies 3.9 and 3.31.
Archaeology
14.41 ES Chapter 13, prepared by MOLA (Museum of London Archaeology), addresses archaeology matters in respect of the Proposed Development and assesses its potential effects on buried heritage assets. The Chapter and approach has been informed following consultation and engagement with both LBS and Historic England.
14.42 There are no statutorily designated heritage assets within the Application Site. However, the centre and west of the Application Site are located within the Elephant & Castle, Kennington Road Archaeological Priority Zone as designated by Southwark Council, which incorporates the Roman and medieval settlement and the historic settlement areas of Bankside, Bermondsey and Rotherhithe, and follows the line of Roman Stane Street.
14.43 The study area is well understood archaeologically, with 28 previous investigations having taken place within 350m of the Application Site. Within the Application Site itself, roadworks were observed in 1960 on the present site of the Northern Line Station Entrance, south-east of the peninsula and a potential section of Roman road was recorded. Within the south-western extent of the Application Site, an archaeological evaluation in 2000 revealed evidence of an east-west natural channel (probably the edge of the Neckinger), a dense concentration of later medieval pits, a
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large 16th/17th century drainage ditch and extensive footings of 19th century buildings.
14.44 Based on this assessment, no buried heritage assets of very high significance are anticipated which would merit a mitigation strategy of permanent preservation in situ. It is therefore considered that the minor to substantial environmental effects of the Proposed Development could be successfully mitigated by a suitable programme of archaeological investigation before and/or during construction, to achieve preservation by record (through advancing understanding of asset significance).
14.45 Archaeological evaluation trenches are proposed to confirm the detail of the presence, nature and significance of any archaeological remains in the areas of proposed impact. Where possible a preliminary investigation could also include the archaeological monitoring of any geotechnical pits dug for engineering purposes.
14.46 The results would enable an informed decision in respect of an appropriate mitigation strategy for any significant remains. This might comprise targeted archaeological excavation in advance of construction, and/or a watching brief during ground works for remains of lesser significance. This would ensure that significant archaeological assets are not removed without record. Any archaeological work would need to be undertaken in accordance with an approved Written Scheme of Investigation (WSI) in consultation with the LBS Archaeological Advisor.
14.47 We expect that archaeological mitigation measures can be secured by way of appropriate planning condition, attached to a prospective planning permission decision notice.
14.48 The Proposed Development is considered acceptable from an archaeological perspective, and therefore complies with relevant planning policy, in particular the NPPF, London Plan Policy 7.8, Core Strategy Policy 12 and Southwark Plan Policy 3.15
Wind
14.49 ES Chapter 14, prepared by RWDI addresses wind matters in respect of the Proposed Development and assesses its potential effects. Wind tunnel testing has been undertaken, and tested in a number of configurations, including the existing Application Site (baseline), the Proposed Development, the Proposed Development with cumulative schemes taken into account, and scenarios with mitigation measures added.
14.50 In the absence of the landscaping scheme/mitigation measures, the wind microclimate is generally windier than acceptable for intended use in and around the Proposed Development during the windiest season. Similarly, in the absence landscaping scheme/mitigation measures there are isolated occurrences of strong winds in exceedance of Beaufort Force 6, Beaufort Force 7 with associated safety concerns at ground level, as well as Beaufort Force 8 at terrace level. Several thoroughfare and entrance locations to the Proposed Development observed windier than desired conditions.
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14.51 Mitigation measures will be required to be in place before the Proposed Development is completed and operational. The proposed landscaping scheme/mitigation measures for the Application Site will therefore need to be installed before the site hoarding is removed, and before the Proposed Development becomes fully operational.
14.52 All balcony locations observed acceptable sitting conditions during the summer season, and no mitigation measures are required at these locations. Most entrance locations across the Proposed Development observed conditions suitable or calmer than required for the intended standing/entrance use at these locations.
14.53 Several entrance locations (receptors 44, 59, 61, 63-64 and 323) observe conditions windier than required in the absence of the landscaping scheme/mitigation measures, and would require these measures to be implemented to create suitable wind conditions at these locations.
14.54 Most terrace locations at elevated levels observed an acceptable mixture of sitting and standing conditions during the summer season, however 4 locations (349, 362 and 368-369) observed conditions windier than desired for the intended amenity space usage without landscaping scheme/mitigation measures in place, and would require such measures to be implemented to create wind conditions suitable for the desired use at these locations.
14.55 More solid bus shelters are required near receptors 6-8, 95-96 and 328-329 to create a sheltered environment, with 2x2m side screens, in addition to the applied mitigation measures.
14.56 With the landscaping scheme/mitigation measures in place across the Application Site, no significant adverse effects on the wind microclimate would occur during the demolition or construction periods, nor on completion and operation of the Proposed Development.
14.57 The Proposed Development’s impact on wind and microclimate is considered acceptable, and therefore complies with relevant planning policy, in particular London Plan Policy 7.6.
Daylight, Sunlight, Overshadowing and Solar Glare
14.58 ES Chapter 15, prepared by GIA, addresses sunlight, daylight, overshadowing and solar glare matters in respect of the Proposed Development. A separate report prepared by Hoare Lea assesses internal daylight performance of the proposed residential units.
Demolition and Construction
14.59 Following demolition of the existing buildings, daylight and sunlight levels at the Application Site and the immediate surrounds are likely to steadily increase in magnitude as the superstructure is built. As the construction works continue, the levels of daylight, sunlight and overshadowing received by neighbours for the Application Site would trend towards those of the completed Proposed Development.
Surrounding Properties
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14.60 To assess the surrounding existing properties, the BRE Guidelines provide two main methods for assessing daylight: ‘Vertical Sky Component’ (VSC) and ‘No Sky Line’ (NSL). The VSC method measures the amount of light available on a vertical wall or window following the introduction of barriers such as buildings. The NSL method is a measure of the distribution of daylight at the ‘working plane’ within a room (i.e. a horizontal ‘desktop’ plane of 0.85 metres (m) in height). The NSL divides those areas of working plane in a room which receive direct sky light through the windows from those areas of the working plane which cannot. Where all of the windows meet the VSC and all of the rooms meet the NSL criteria within a property the effect is considered to be insignificant.
14.61 For the assessment of sunlight, the approach considers the ‘Annual Probable Sunlight Hours’ (APSH) for a reference point on a window (i.e. if a window point can receive at least 25% APSH, then the room should still receive enough sunlight). Windows are checked to see if they are facing 90° due south, with the emphasis on main living rooms and other rooms such as the kitchen and bedrooms being is less importance.
14.62 A total of 6,220 windows serving 4,092 rooms have been assessed for daylight and 3,728 windows have been assessed for sunlight within surrounding residential receptors. Out of the 6,220 windows, 3,093 (50%) windows have a baseline VSC equal or greater than the 27% recommended within the BRE Guidelines, whereas 3,436 (84%) out of the 4,092 rooms assessed have a daylight distribution to at least 80% of the total room area. With regard to sunlight, out of the 3,728 windows assessed, 2,452 (66%) meet the BRE Guidelines for sunlight in the baseline. The results of the baseline assessment therefore indicate relatively low levels of BRE compliance for daylight and sunlight, which is reflective of the urban location of the Application Site.
14.63 In the Proposed Development scenario, in regards to daylight, out of the total 6,220 windows assessed 4,751 (76%) meet the BRE criteria for VSC whereas 3,667 (90%) out of the 4,092 rooms assessed meet the BRE criteria for NSL. For sunlight, out of the total 3,728 windows assessed 3,128 (84%) meet the BRE criteria for both Winter and Annual APSH.
14.64 Despite the high levels of compliance against BRE criteria, there would be instances of adverse effects of moderate to substantial significance particularly along the Oswin Street properties and Hayles Buildings. This is a result of the close proximity of these properties to the West Site combined with the existing low level of massing on the West Site in the baseline. Whilst some substantial adverse effects would occur, these are a result of the low existing massing upon the site and the proximity of the neighbouring properties, particularly along Oswin Street whereby BRE transgressions are inevitable.
14.65 In regards to transient overshadowing, there would be an increase in the levels of shadow cast over the surrounding area and amenity spaces as a result of the Proposed Development, although this effect is considered to be minor. When considering Sun Hours on Ground, the 3 existing amenity areas assessed (Elliot’s Row Play Area, Metro Centre Courtyard and Greenspace to the south of Albert Barnes House) all meet the BRE criteria and have over 50% of the total area receiving at least 2 hours of direct sunlight.
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14.66 In terms of solar glare, the Proposed Development would result in largely insignificant effects, but some would be considered minor to moderate significance from certain viewpoints. Whilst adverse effects occur it should be noted that the assessment considers a scenario whereby the sun shines on every day of the year to consider all potential circumstances in which reflection will occur. According to the sunlight availability protractor, based on London weather data, the sun shine probability will be significantly reduced according to the month in consideration and therefore the likelihood of the instances of reflections are considerably reduced. For several of the viewpoints the sun would be directly visible and in comparison, the reflections from the Proposed Development would appear less intense.
New Residential Units
14.67 A standalone report (prepared by Hoare Lea) has been submitted with the planning application to quantify the quality of light within the new residential accommodation with the Proposed Development. Given the size and scale of the Proposed Development, the ‘sample’ report assesses Average Daylight Factor (ADF) and Probable Sunlight Hours (PSH) for one third (1,021) of the total number of rooms across East and West Sites.
14.68 The results of the daylight assessments have shown that 71% of habitable rooms tested will meet or exceed the levels of Average Daylight Factor (ADF) recommended by the BRE. If a full assessment of all rooms was carried out then the overall pass rate would be expected to be higher than 71%.
14.69 For sunlight the overall pass rate for Annual PSH was 51% and for low angle winter sun, Winter PSH, 71% of the tested apartments achieve or exceed the BR209-required 5% Winter PSH. It is Hoare Lea Daylights professional opinion that these percentage pass rates can be applied to all BR209 applicable rooms.
14.70 Overshadowing has been considered by GIA as part of ES Chapter 15. Specifically in relation to the podium/terrace amenity areas proposed for use by residents, they would fall short of the BRE’s recommendations for the 21st of March, however would receive direct sunlight on June 21st when the areas are most likely to be in use.
14.71 It is concluded that the Proposed Development‘s performance in terms of daylight and sunlight is considered good given the urban location of the Application Site in Elephant and Castle. Overall the Proposed Development can be deemed to be broadly in accordance with the criteria set out in the BRE Handbook for new residential units and, therefore, accords with London Plan Policy 3.5 and Southwark Saved Plan Policy 3.12.
Health Impacts
14.72 A Rapid Health Impact Assessment (RHIA) has been prepared by Ricardo Energy & Environment to accompany the planning application. The RHIA has been produced in accordance with the London Healthy Urban Development Unit (HUDU) Rapid Health Impact Assessment Tool developed by the National Health Service (NHS), and draws upon other assessments submitted to accompany the planning application.
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14.73 The RHIA assesses the Proposed Development’s effect on a number of topic areas and provides a conclusion on the anticipated impacts. In this case, the RHIA finds that the Proposed Development mostly positive impacts, with some uncertainty where future negotiation over relocation support and employment policies of potential contractors need to be concluded. No negative impacts have been identified by the RHIA.
14.74 A summary of the findings can be found in Table 14.1 below:
Table 14.1 – Summary of RHIA Findings
14.75 Overall the RHIA finds that the proposed mixed-use redevelopment of the Elephant & Castle town centre site is assessed to have a positive influence on health and well- being of prospective residents and the existing local community of Elephant & Castle, and more broadly in Southwark.
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15.0 DRAFT SECTION 106 HEADS OF TERMS
15.1 This section sets out a summary of the draft Heads of Terms for the Proposed Development. The draft Heads of Terms have been considered in relation to Southwark Council’s Section 106 Planning Obligations and Community Infrastructure Levy (CIL) SPD (April 2015).
15.2 It is envisaged that discussions relating to the following draft heads of terms and the Section 106 Agreement will continue with Southwark Council during the determination of the planning application.
Affordable Housing
Archaeology
Carbon Offset: Green Fund
Children’s play space
Employment and enterprise during construction
Employment and enterprise in operational development
Employment and enterprise: loss of employment floorspace
Outdoor amenity space
Public realm measures
Site-specific transport measures
Wheelchair accessible housing off-set fund
Administration charge
15.3 Other measures envisaged at this stage that could be secured through a Section 106 (or via planning conditions if appropriate) may include the following, which will be discussed further with planning officers at the Council following submission of the planning application:
Demolition / Construction Environmental Management Plan (CEMP); Travel Plan; and Delivery and Servicing Management Plan; 15.4 The Proposed Development will also be liable for substantial CIL contributions under both the Mayor of London and Southwark’s CIL Charging Schedules towards strategic and local infrastructure projects.
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16.0 CONCLUSION
16.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004, requires proposals to be determined in accordance with the Development Plan unless other materials considerations indicate otherwise.
16.2 The Planning Statement assesses the Development against the Development Plan and other relevant national, regional and local planning policy, including the Elephant & Castle SPD and emerging New Southwark Plan.
16.3 The Development is considered to accord with the aspirations of planning policy which seeks the creation of new jobs and business growth opportunities and an environment in Southwark in which businesses can thrive, as well as providing much needed new homes. The Council’s vision for the Elephant & Castle Opportunity Area includes an ambition to deliver more jobs, more homes, and provide a thriving town centre.
16.4 The Development delivers a new town centre for Elephant & Castle comprising significant retail, leisure and cultural facilities, alongside a new state of the art home for UAL:LCC. A further 979 residential units are proposed, alongside significant public realm improvements, routes through the viaduct to connect the Application Site with Elephant Park, and a new Underground entrance and ticket hall for the Northern Line.
16.5 The Development will bring about a significant increase in jobs and employment density on the Application Site through the improved quality of the new town centre floorspace. Whilst there may be an overall decrease in total employment floorspace on the Site, the total number of jobs will increase by up to 572 FTE jobs.
16.6 Redevelopment of this brownfield site would also significantly contribute to meeting housing targets by adding 979 new residential units to the existing housing stock – this equates to approximately 36% of Southwark Council’s annual housing target, as set out in the London Plan, and 20% of the indicative housing target for the Elephant & Castle Opportunity Area. These homes will promote opportunity and choice for residents in ways that meet their needs and the strategic objectives for London and the Council, with an element of affordable housing capable of being provided on-site.
16.7 The Development will result in the creation of a new town centre on two underutilised brownfield sites which will act as a catalyst for further development in the Opportunity Area, and will contribute significantly to achieving the Council’s targets in the area.
16.8 The likely impacts of the Development and a series of cumulative schemes have been fully assessed by the Environmental Statement and other application documents and any mitigation measures have been identified, where appropriate. The Development is considered to be entirely appropriate for its location.
16.9 The Development has been the subject of extensive consultation with the Council, the GLA, key stakeholders, and the public. This has resulted in changes to the Development to take into account the comments received. This process of consultation and engagement is on-going.
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16.10 The proposed Development is in compliance with the Development Plan, as well as the overarching approach and direction of travel contained within emerging policy for the area. It will deliver significant employment, residential and wider community benefits within a comprehensive masterplan approach that showcases exemplary design. The benefits of the Proposed Development clearly outweigh any perceived impacts, none of which could be categorised as significant, let alone adverse.
16.11 For the reasons outlined above, the principle of the Development is consistent with the broad objectives of planning policy and in accordance with the Government’s overarching objectives for sustainable growth. The proposed Development is acceptable in principle and should be supported in this location.
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