Chester, Salisbury, Norfolk, Worcester, Winchester, Hereford, And Gloucester House ADDRESS: London, SW9 6EJ Application Number: 19/04478/FUL Case Officer: Michael Cassidy

Ward: Vassall Date Received: 02/12/2019

Proposal: Demolition of Salisbury House, Norfolk House, Worcester House, Winchester House, Hereford House and Gloucester House within Kennington Park Business Centre and the erection of three buildings, ranging from three to five storeys with part basement, to provide flexible business floorspace comprising light industrial and office floorspace (Class B1 a-c), light industrial floorspace (Class B1c and B8), a flexible commercial unit (Class A1/A2/A3/A4/B1), wheelchair accessible car parking, cycle parking and associated public realm and detailed landscape enhancements and the removal of two storey addition on the north facade of Chester House. Applicant: Workspace Management Limited Agent: Rolfe Judd

Drawing Numbers and Supporting Documents: Refer to Appendix 4

Supporting Documents: Appendix 1 – List of conditions and informatives Appendix 2 - List of Consultees (Statutory and Other Consultees) Appendix 3 - List of relevant policies in London Plan, Lambeth Local Plan. Reference to SPGs, SPD and other relevant guidance Appendix 4 – List of drawing numbers and supporting documents

RECOMMENDATION:

1. Resolve to grant conditional planning permission subject to the completion of an agreement under Section 106 of the Town and Country Planning Act 1990 (as amended) containing the planning obligations listed in this report and any direction as may be received following further referral to the Mayor of London.

2. Agree to delegate authority to the Director of Planning, Transport and Sustainability to:

a. Finalise the recommended conditions as set out in this report, addendums and/or PAC minutes; and b. Negotiate, agree and finalise the planning obligations as set out in this report, addendums and/or PAC minutes pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended).

3. In the event that the committee resolves to refuse planning permission and there is a subsequent appeal, delegated authority is given to the Director of Planning, Transport and Sustainability, having regard to the heads of terms set out in this report, addendums and/or PAC minutes, to negotiate and complete a document containing obligations pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended) in order to meet the requirement of the Planning Inspector.

4. In the event that the Section 106 Agreement is not completed within 6 months of committee, delegated authority is given to the Director of Planning, Transport and Sustainability to refuse planning permission for failure to enter into a section 106 agreement for the mitigating contributions identified in this report, addendums and/or the PAC minutes.

SITE DESIGNATIONS

Designation: Description: Policy Kennington Business Park Key Industrial Business Area (KIBA) Listed Building No (the site is locally listed) Conservation Area (CA) No (the site adjoins St Marks Conservation Area to the north west and Vassal Road to the east) Protected views/vistas Yes - Primrose Hill to the Palace of Westminster (View 4A.2) Local Views Yes – Local Views 19 Brixton Panoramic and 22 Norwood Park and Millbank to Vauxhall Bridge Archaeological Priority Area Yes - part of the site, the frontage to Brixton Road, is within an archaeological priority area. Flood Risk Area Yes - The north-east of the site is in tidal Flood Zone 3 Creative Enterprise Zone No Air Quality Management Area Yes

LAND USE DETAILS

Site area (ha): 1.58 Hectares

NON-RESIDENTIAL DETAILS

Use Class Use Description Floorspace (m2) (Gross Internal Area) Existing Flexible B1 (a-c) Business 1,596sqm B1 c Light Industrial / Workspace 3,042sqm B8 Storage & Distribution 2,366sqm Flexible B1/D1 Offices / Education & Training 1,455sqm Total 8,459sqm

Proposed Flexible B1 (a-c) Business 17,479sqm B1 c Light Industrial / Workspace 5,408sqm Flexible B1/D1 Offices / Education & Training 1,455sqm A1/A2/A3/A4/B1 Flexible Commercial Unit 330sqm Total 24,672sqm

PARKING DETAILS

Car Parking Spaces Car Parking Spaces % of Bike Motor- (General) (Disabled) EVCP Spaces cycle Spaces Commercial Visitor Commercial Visitor Existing 189 0 7 0 0 119 0 Proposed 0 0 6 0 0 414 0

LEGAL SERVICES CLEARANCE

AUDIT TRAIL Consultation Name/Position Lambeth Date Sent Date Report Comments in department Received Cleared para: Peter Flockhart On behalf of Legal 08/05/21 08/05/21 10/05/21 Various Services

EXECUTIVE SUMMARY

The proposed development would provide new high-quality business/workspace buildings, providing a significant uplift and enhancement in employment floorspace (an increase of 16,213sqm in floorspace and an uplift of 192% on the existing) on the site. The uplift is anticipated to provide an additional 344-1351 new jobs for the borough (calculated using the HCA Employment Density Guide).

The proposal would provide up to 219 flexible business units (former Use Class B1a-c), complementing the existing flexible business use of the Kennington Park Business Centre, and would fully reprovide the existing industrial floorspace (former Use Class B1c and B8), to be located within Block C, which has been specifically designed to be used for a range of industrial uses, in accordance with the New London Plan.

The employment use proposed would permit a range of office, research and development and light industrial uses falling under former Use Class B1a, B1b and B1c and provides flexible workspace suitable for occupation by a range of business sizes, which is welcomed. The design and layout of the proposal has been specifically tailored to be suitable for micro, small and medium sized creative enterprises engaged in light industrial manufacturing and design activities.

The group of buildings proposed are of an appropriate scale and height and have been carefully considered in terms of their architectural language. Overall, the design and appearance of proposed blocks are considered to be acceptable and will contribute positively to the streetscene and local context. The proposal would cause no harm to strategic, local views or heritage assets and would preserve and enhance the appearance of the character of the St Marks and Vassall Conservation Areas.

Given the distance and orientation to the nearest residential properties, and the inclusion of appropriate mitigation measures, the proposal would not result in any significant material impact in terms of overlooking, loss of privacy or sunlight/daylight or undue noise and disturbance to neighbouring residential properties.

The development would have a sustainable construction, meeting all of the relevant sustainability standards. The scheme has been designed to significantly improve the environment and amenity across the site, in order to create a more welcoming, usable and biodiverse place of work. scheme provides significant landscaping and ecological enhancement is to improve the legibility, permeability and external amenity space across the site for the enjoyment of existing future employees of the KIBA.

As such, the proposal is considered to be acceptable when judged against national, London wide and local plan policy and guidance and all relevant material considerations and is recommended for approval.

OFFICER REPORT

Reason for referral to PAC: The application is reported to the Planning Applications Committee in accordance with (1A) (a) (ii) of the Committee’s terms of reference as it relates to a major application for the provision of a building of more than 3,500 square metres.

1. THE APPLICATION SITE AND SURROUNDING AREA

1.1 Kennington Park Business Centre is 2.5 hectares in size and bounded by Camberwell New Road to the north, Brixton Road to the east, Cranmer Road to the south and Foxley Road to the east. It comprises 11 buildings, between two and four commercial storeys in height, with the tallest being Cranmer House, located on the corner of Brixton Road and Cranmer Road and Lincoln House, located towards to the north of the Business Park fronting Camberwell New Road. Canterbury Court, in the centre of the site, is three storeys in height. The building towards the east of the site, Gloucester House, is a single storey 1950’s warehouse style brick building with pitched roof. The buildings on the southern part of the site are two storeys in height.

1.2 The application site itself is 1.58 hectares and comprises 6 of the 11 buildings within the business centre: Worcester House, Norfolk House, Salisbury House, Winchester House, Hereford House, and

Gloucester House. Also within the site is the northern façade of Chest House, the central courtyard, the external area to the front of Canterbury Court and the section of car parking between Canterbury Court and Camberwell New Road as shown in Figure 1 below.

Figure 1 – Site and Surroundings

1.3 The business centre is an Edwardian commercial development in Queen Anne style comprising several attractive stock brick buildings with red brick and stone dressings. The complex also includes a 1950’s single storey brick building (Gloucester House) along Camberwell New Road and Foxley Road. The site was originally used for residential purposes but the buildings, which were constructed in 1905, were built by the General Motor Cab Company to provide garaging, servicing and administrative back-up for motor taxis serving London. There have been several additions and changes to the estate over the years; however, the main form of the 3 key redbrick buildings of Canterbury Court, Lincoln House and Chester House/Chichester House/Cranmer House remaining the same. An aerial view of the site is shown in Figure 2 below.

1.4 There are no statutory listed buildings on the site. The existing buildings are, however, locally listed and therefore considered a non-designated heritage asset. The site is also sandwiched between two conservation areas; St Marks (CA11) that lies north of the site and Vassal Road (CA7) directly east of the site along Foxley Road. Kennington Park, a Grade II Registered Park is north of the site. There are also several statutory and locally listed buildings in the vicinity of the site.

1.5 The site is a designated Key Industrial and Business Area (KIBA) and part of it, the frontage to Brixton Road, is within an archaeological priority area. It is located within a mixed-use area, comprising retail, residential, leisure and sports uses and open space. The surrounding context is varied with a Victorian shopping parade along the western stretch of Brixton Road, the low-rise Holland Town Estate to the south and the 19th century terraces of the Vassall Road Conservation Area to the south east of the site. To the north are the landscaped gardens and sports facilities of Kennington Park, whilst the Grade II* listed St Mark’s Church and its grounds are situated just north west of the site.

1.6 Both Brixton Road and Camberwell New Road form part of the Transport for London Road Network (TLRN). The nearest London Underground Station is Oval, situated 200m to the north east of the site and served by the Northern Line. There are a number of bus stops in close proximity of the site

serving several routes. Based on these public transport connections, the site achieves a Public Transport Accessibility Level (PTAL) of 6a, where 0 represents the lowest accessibility level and 6b the highest.

Figure 2 – Aerial View of Site

2 PROPOSAL

2.1 The application proposes the demolition of 6 existing buildings on-site (Salisbury House, Norfolk House, Worchester House, Winchester House, Hereford House and Gloucester House) and the erection of 3 replacement buildings (Buildings A, B and C as shown in Figure 3 below), ranging from 3 to 5 storeys with part basement, to provide flexible business floorspace comprising light industrial and office floorspace (Class B1 a-c), light industrial floorspace (Class B1c) and a flexible commercial unit (Class A1/A2/A3/A4/B1). The remaining 5 buildings on the site (known as Canterbury Court, Lincoln House and Chester House) would remain unchanged.

Figure 3 – Proposed Site Plan

2.2 The breakdown of floorspace proposed, as shown in Table 1 below, is as follows:

Uses Existing Proposed Uplift (reference is to former Use Classes) Floorspa Floorspace ce (sqm) (sqm) GIA GIA Flexible Business (Class B1 (a-c) 1,596sqm 19,146sqm 15,883sqm

Light Industrial / Workspace (Class B1 3,042sqm 5,408sqm Full re-provision of c) existing Storage & Distribution (Class B8) 2,366sqm

Offices / Education & Training (Flexible 1,455sqm 1,455sqm Full re-provision of B1/D1) existing, proposed as flexible B1/D1 Flexible commercial unit (Class A1/A2/ 0sqm 330sqm 330sqm A3/A4/B1) Total 8,459sqm 24,955sqm 16,213sqm Table 1 – Existing & Proposed Floorspace

Figure 4 – Proposed Aerial View of Site

2.3 The proposed buildings, as shown in Figure 4 above, will comprise the following:

• Building A comprises a range of business units with a total GIA of 9,899sqm of business floorspace. Building A has a height of five storeys and has a central courtyard to provide light and ventilation to all units. A lobby area within the courtyard identifies the entrance to the building, where there are informal ‘break out’ areas for tenants and visitors to utilise. Formal meeting rooms are located at ground floor level and can be booked for use.

• Building B comprises a range of business units with total GIA of 8,494sqm of business floorspace. Building B is part three, part four, and part five storey building and comprises a longer façade which is architecturally articulated, giving the appearance of three differing buildings.

• Building C comprises a range of business units with a total GIA of 6,562sqm of business floorspace. Building C has a height of four storeys with the fourth storey set back on the corner of Camberwell New Road. Building C has been designed to be specially occupied by light industrial uses (former Use Class B1c). The ground floor can be adapted to provide double height units and all units are provided with a dedicated riser and the ability to install extraction

facilities. A dedicated loading bay and goods lift has been allocated for the building, so all servicing can be undertaken on site. The ground floor units can be altered to provide either a glaze shopfront or a roller shutter, dependent on the tenants needs.

2.4 Each building has bookable meeting rooms for more formal meetings, there are also break out areas internally and external seating areas for more informal meetings, networking opportunities and event spaces. A flexible/alternative commercial unit (former Use Class A1/A2/A3/A4/B1) is proposed within Building C, primarily to be used by tenants and visitors of the KIBA, to provide for the estimated uplift of between 351-1370 employees on site over the existing situation.

2.5 The application also proposes the removal of 2 storey addition on north facade of Chester House; the provision of 414 cycle parking spaces; 6 disabled car parking spaces (an increase of 5 spaces on the 7 existing) and the removal of all of the 189 general car parking spaces to help facilitate the following enhancements to pedestrian access and landscaping on the site:

• ‘Canterbury Yard’- primarily a pedestrian access point to Kennington Park, proposing a flexible yard space with a planted ramp terrace, titled lawns and tree planting. Improving the accessible step free route from the main pedestrian access down to the rest of the courtyard and site and providing additional green amenity space;

• ‘Walled Garden’- replacing the car parking spaces between Canterbury Court and Camberwell New Road with a woodland inspired rain garden. Glass pod meeting rooms are situated within the woodland area and movable external furniture is provided for amenity;

• ‘Central Yard’ – located between Block A and B comprises a series of terraces incorporating play/game elements, seating and lawns with cycle parking amongst the spaces;

• ‘Games Yard & Rubble Garden’- located to the east of the site, adjacent to Building C is a flexible space which is designed to host events and outdoor games such as boules and table tennis; and

• 1,457sqm of green space and the planting of 116 trees, providing a net gain of 84 trees across Kennington Park.

3 PLANNING PERFORMANCE AGREEMENT

3.1 The applications are subject to a Planning Performance Agreement agreed on the 18 April 2019 and remaining in force until the determination of the planning application.

3.2 During the pre-application stage the proposal was presented to the Council’s Strategic Panel on 22nd May 2019.

4 AMENDMENTS

4.1 During the course of the application, the following amendments were made:

Transport amendments • Reduction in disabled car parking from 12 spaces to 6, at the request of TfL and to be in line with the New London Plan (draft at the time). This also allows for a better-quality layout and public realm within the scheme; • Slight change to the cycle parking figures to 363 long-stay and 38 short-stay cycle parking spaces, to reflect slight changes to floorspace figures; • Confirmation of the proposed works to the highway (S278);

Changes to Block C (29th May 2020) • A Mezzanine floor across first floor level, which will allow the units at ground floor to be double storey if required and can accommodate tenants with larger machinery; • Refined layout to incorporate more Class B1c units within Block C; • A large goods lift proposed at ground floor immediately adjacent to one of the loading bays, all corridors are wide enough to transport goods around the building; • Each unit is flexible and capable of being amalgamated to create bigger units or sub divided to allow for a range of business sizes and types; • Each unit is fitted with risers/ducts which can be connected into and will discharge at roof level; • The frontage of the ground floor units can be altered to a roller shutter style door or can remain as glazing; • Minor change to the basement layout, pulling this back from the site boundary;

Changes to Block A and Cranmer Road entrance (12th (August 2020) • New ramp layout simplified and shortened at entrance- entrance is exclusively for service, maintenance, and cycles; • Changes to the material of the yard to clearly separate the pedestrian path from the vehicle route; • Disabled parking bays rotated for better access; • Green buffer introduced to soften the transition between the ramp and Block A;

Further changes to Block C (December 2020) • Change to brick colour of Block C to show a browner tone; • Change to boundary fence to show a more detailed corrugated fence with the potential for landscaping against this, boundary details to be conditioned; • Fritted glazing incorporated into the lower part of the windows of Block C above ground floor, to be conditioned;

Energy Strategy • A number of revisions to the GLA spreadsheet were made confirming the agreed strategy with the GLA; and • Clarification provided to sustainability questions raised by Blew Burton.

4.2 Given the relatively minor nature of the above amendments, with no changes made to the height, scale, massing and general design of the proposal, it was not considered necessary to formally re- consult on these changes.

5 RELEVANT PLANNING HISTORY

5.1 The relevant planning history for the site includes the following applications:

• 15/06124/FUL - Removal of existing garage door, roller shutter, timber shutter and external lighting and installation of a new entrance door, glazed panel and sliding security door. Bricking up the pedestrian door opening – Refused on 12th February 2016.

• 10/04188/FUL - Redevelopment works to Kennington Park Business Centre comprising of the following: Change of use to the ground floor of Canterbury Court to provide 2,085sqm (GIA) either Retail, Financial Services and Restaurant floorspace (either use classes A1/A2/A3,), 2,015 sqm (GIA) leisure floorspace (use class D2) and 365sqm (GIA) commercial (use class B1) floorspace with associated external alterations to include the installation of shop fronts to the Camberwell New Road frontage and associated elevational changes, change of use to the first floor of Canterbury Court to provide 2,382sqm (GIA) commercial (use class B1) floorspace and alterations to the main entrance to Canterbury Court from the existing courtyard. Change of use to the ground floor of Chester House to provide 115sqm (GIA) of either Retail, Financial Services and Restaurant floorspace (either use classes A1/A2/A3) and the erection of a new

single storey extension to Chester House to provide 47sqm (GIA) Retail, Financial Services and Restaurant floorspace (either use classes A1/A2/A3) and third floor roof extension to Chichester House to provide 866sqm (GIA) commercial (use class B1) floorspace and associated alterations. Demolition of existing entrance block to Chichester House and Chester House and the erection of a new 4 storey entrance extension, provision of an external metal staircase, alterations and enlargement of existing fenestration. Provision of a new landscaped public realm accessed from Brixton Road, new boundary treatment and reduction of 56 car parking spaces and provision of cycle parking – Granted on 21st April 2011.

• 10/02689/FUL - Demolition of existing entrance block and the erection of a new 4 storey entrance extension, provision of an external metal staircase, alterations and enlargement of existing fenestration along with alterations to existing car parking spaces involving the loss of 13 spaces, provision of hard landscaping and associated alterations – Granted 29th October 2010.

• 10/00381/FUL - Change of use of the ground floor to Vocational training centre (Use Class D1) or Business/General Industrial/Storage & Distribution (Use Classes B1/B2/B8) – Granted 8th April 2010.

• 10/02283/FUL - Application for variation of a condition 4 (The proposed new use hereby permitted shall only be open to students between the hours of 0830-2000 Monday-Friday) of planning permission ref:10/00381/FUL (Change of use of the ground floor to Vocational training centre (Use Class D1) or Business/General Industrial/Storage & Distribution (Use Classes B1/B2/B8) granted 08/04/2010. The variation is to allow the training centre to be open on Saturdays between the hours of 0830 and 1600 – Granted 27th August 2010.

• 09/03485/FUL - Change of use of first floor to an employment training centre (Use Class D1) – Granted 15th February 2010.

6 CONSULTATIONS

6.1 A list of all those consulted is provided in Appendix 2. The following were consulted on the application and the responses received are summarised below:

6.2 Statutory and External Consultees

5.2.1 The Greater London Authority (GLA) (Stage 1 received 15 June 2020) The GLA have made the following comments on the application:

• Principle of development: For the principle of development to be acceptable in land use terms, the existing quantum of industrial floorspace should be re-provided in full and should be fully fit for purpose. The existing quantum of D1 floorspace should also be confirmed and fully replaced within the scheme. The provision of affordable workspace offer should be confirmed and secured within the s106 agreement. The provision of offices and a flexible commercial unit is acceptable.

• Urban design: Overall the scheme is of good quality. However, the design of the courtyard is cluttered and would benefit from rationalisation. It also appears that there is increased opportunity for pedestrian and vehicular conflict as a result of the intensification of the site, this should also be addressed fully. The impact of the development on the LVMF view from Primrose Hill to the Palace of Westminster background assessment area should be assessed.

• Heritage: It is not possible to undertake a full assessment of impact until the verified views are updated. However, it is likely that the demolition of the locally listed buildings on Cranmer Street would give rise to some harm albeit to the lower end of the scale which would need to be weighed against the public benefits of the scheme.

• Inclusive access: The Design and Access Statement does not currently set out how the development would promote accessibility for disabled people and should be updated to provide this detail. The Fire Strategy should be revised to meet the necessary information requirements of Policy D12 of the London Plan. Confirmation is required that fire evacuation lifts would be provided throughout the scheme as necessary.

• Energy: The energy strategy for the scheme is broadly acceptable however, the applicant must provide the following additional information and revisions in order to confirm compliance with relevant London Plan, ItP London Plan policies and current GLA Energy Assessment Guidance including: submitting the GLA’s carbon emissions excel spreadsheet; providing further information on the site’s connection to a district heating network; details of the route network and location of the energy centre; further information required on PV potential; and further information is required regarding the proposed heat pumps and how the energy generation has been maximised from this source.

• Air quality: The applicant should demonstrate that building emissions would be air quality neutral and an assessment of the gas boilers should be required prior to occupation to ensure no adverse impacts on existing air quality. Both should be secured by condition.

• Flood risk and drainage: The Flood Risk Assessment provided complies with London Plan Policy. However, the surface water drainage strategy would need to be revised. The applicant should also consider water harvesting and reuse to reduce consumption of wholesome water across the entire development site. This can be integrated with the surface water drainage system to provide a dual benefit.

• Urban greening: The scheme should aim to achieve a UGF of 0.3.

• Transport: Contributions will be sought towards Road Safety schemes, bus capacity enhancements and cycle hire. Further detail is required to ensure that the cycle parking is designed and laid out in accordance the London Cycling Design Standards (LCDS).

Officer comment: the application has been amended to re-provide the existing quantum of industrial floorspace and further information has been provided to address the matters raised in relation to affordable workspace requirement, heritage, energy and transport as set out in the ‘Assessment’ section of the report below. Appropriately worded conditions along with s106 Heads of Terms (HoTs) are recommended to address the issues raised. The amendments made will be considered by the GLA in their Stage II response.

Environment Agency 5.2.2 No response received.

Historic England (Archaeology) 5.2.3 No response received.

Transport for London (TfL) (received 25th June 2020) 5.2.4 TfL requests that further information is provided before we can fully assess and be supportive of the proposed development. Specific mitigation measures and further work are summarised below:

1. A contribution of £450k (£90k pa for five years) towards bus services, £15k towards TfL’s road safety scheme and £50k towards the expansion of the Cranmer Road cycle hire docking station to be secured through s106. 2. The applicant needs to confirm how cycle storage will be accessed, particularly in Block B, and demonstrate that routes to cycle storage are free of obstacles and well located. 3. Car Parking Management Plan to be secured by condition. 4. Travel Plan, Construction Logistics Plan and Delivery and Servicing Plan to be secured by condition.

Officer comment: appropriately worded conditions and s106 Heads of Term are recommended as set out in the ‘Planning Obligations and CIL’ section below.

London Ecology Unit 5.2.5 No response received.

London Fire Brigade 5.2.6 No response received.

Thames Water 5.2.7 No response received.

6.3 Internal Consultees

LBL Building Control (Basement Impact Assessment) (received 16th June 2020) 5.3.1 No objection. The Basement Impact Assessment submitted is satisfactory.

LBL Building Control (Fire Safety) (received 15th June 2020) 5.3.2 No objection. The outline fire strategy appears satisfactory given the early design stage, covering key design issues. A more detailed strategy to accompany the design would usually be submitted as part of the Building Regulations application to the chosen Building Control Body (BCB). It is that BCB who will consider compliance of the scheme including any proposed deviations, relaxations, compensatory measures etc.

Officer comment: were permission to be granted, a condition would be applied requiring a detailed Fire Statement to be produced by an independent third party. The submitted details would be assessed by the Council’s Building Control department.

LBL Conservation & Urban Design (received 23rd April 2021) 5.3.3 No objection to the proposal. The layout, scale and mass relate positively to the existing context and as such would not appear dominant in the streetscene or context. Overall, the proposal would preserve and enhance the appearance of the character of the St Marks and Vassal Road Conservation Areas and would have no adverse impact on the setting of locally listed buildings. The impact of the proposal on the setting of statutory listed buildings has been carefully considered and no harm has been identified to these designated heritage assets. Overall, the design and appearance of proposed blocks are considered to be acceptable and will contribute positively to the streetscene and context.

Conditions requiring detailed drawings (at a scale of 1:10) showing all external construction detailing and design features; refuse and cycle stores; wayfinding and signage; landscaping and details of the re-instatement of the original sandstone plaques on Worcester House should be attached to any permission granted.

Officer comment: appropriately worded conditions are recommended as set out in the ‘Design and Conservation’ and ‘Conditions’ sections below.

LBL EHST Noise Pollution (received 22nd May 2020) 5.3.4 No objection subject to conditions securing a construction and environmental management plan; flues and extraction plant details; noise and vibration attenuation of ventilation plant; noise from light industrial activity; maintenance details; operating hours; customer management plan; delivery and servicing management plan; and external lighting being secured by condition.

Officer comment: appropriately worded conditions recommended if the committee is minded to approve the application.

LBL Enterprise, Employment and Skills (received 28th February 2020) 5.3.5 No objection to the proposal subject to Employment and Skills obligations in line with the Council’s Employment and Skills SPD being secured by s106.

Officer comment: appropriately worded conditions and s106 Heads of Terms recommended if the committee is minded to approve the application.

LBL Flooding 5.3.6 No response received.

LBL Highways Team (received 20th April 2020) 5.3.7 No objection subject to s278 highway works to upgrade the footway around the site, which is in a poor state, being secured by s106 legal agreement.

Officer comment: were permission to be granted, the highway works would be secured by s106 legal agreement.

LBL Parks & Open Spaces (received 19th March 2020) 5.3.8 Support for the application. The proposals for a number of landscaping and ecological enhancements are welcome.

Officer comment: appropriately worded conditions are recommended as set out in the ‘Ecology, Trees and Landscaping’ section below.

LBL Planning Policy (received 27th February and 5th November 2020) 5.3.9 No objection to the proposal subject to the existing quantum of industrial floorspace being re- provided. Given the flexible nature of the existing permission (B1/D1) relating to the community floorspace on site, this replacement community space can be provided in the form of a flexible B1/D1 permission. This aspect of the proposal should seek to re-provide the existing quantum of flexible floorspace.

As the site does not lie within a town centre, the proposed flexible ancillary retail/commercial unit should be assessed against the sequential test and impact assessment. Notwithstanding the results of this, on balance, the proposed flexible unit intended primarily to serve the needs of those working in and visiting the KIBA is acceptable in principle if the aforementioned industrial floorspace capacity requirements are met.

Officer comment: The scheme has since been amended to fully re-provide the existing B1c and B8 floorspace (within Block c) and will be secured as flexible B1c/B8 (industrial) floorspace. The re- provision of industrial floorspace and proposed land uses are considered in detail in the ‘Land uses’ section below.

LBL Sustainability Team on Air Quality (received 17th March 2020) 5.3.10 No objection subject to conditions relating to an Air Quality and Dust Management Plan; Air Quality Neutral Assessment emissions; final CHP Plant and gas boiler system details; Method of Demolition and Construction Statement and emissions from Non-road Mobile Machinery (NRMM) being attached to any permission granted and a s106 requirement for a Carbon Offset Payment to be made.

Officer comment: were permission to be granted, conditions and informatives would be included.

LBL Transport (received 3rd April 2020) 5.3.11 No objection to the proposal subject to conditions relating to Delivery and Servicing Plan, Cycle Parking, disabled car parking, Car Club, Travel Plan, Construction Environmental Management Plan being attached to any permission granted and a commitment being provided to enter into a s106 and S278 agreement for pedestrian and cyclist improvements within the vicinity of the site and mitigation

measures as set out in the ‘Transport Section’ below.

Officer comment: appropriately worded conditions and s106 Heads of Terms recommended if the committee is minded to approve the application.

Blew Burton 5.3.12 No objection subject to further information being confirmed in relation to BREEAM, water use, and the final energy strategy.

Officer comment: further information has been provided by the applicant in relation to the above matters. Appropriately worded conditions and s106 Heads of Terms recommended if the committee is minded to approve the application.

Design Out Crime Officer (Metropolitan Police) (received 3rd March 2020) 5.3.13 No objection subject to ‘Secured by Design’ conditions being attached to any permission granted.

Officer comment: appropriately worded conditions are recommended if the committee is minded to approve the application.

Veolia Waste (received 9th March 2020) 5.3.14 Support waste collection plans as outlined in delivery and service plan.

Ward Councillors 5.3.15 No response received.

5.4 Other

Brixton Society (received 29th April 2020) 5.4.1 Objection. The Brixton Society’s main concerns are as follows:

• Lack of Design & Access Statement: despite over 80 documents being provided with the application, no Design and Access Statement has been provided. This has made it very difficult to obtain an overview of the applicant’s intentions and priorities. The application should not have been validated in the absence of such a basic requirement.

• Conservation & Townscape: The Heritage & Townscape Report includes some interesting material, but rather underplays the site’s historic significance as the first major development of the former Brixton Estate Company. More critically, we expected to see more detail about the streetscape and the relationship with the Vassall Road Conservation Area. The existing roofline on the Cranmer Road frontage has some original features of particular interest. If all this is to be lost, we would prefer to see some interest or variety added to highlight the entrances to the repetitive street frontage presently proposed for blocks A and B.

• Accommodating existing businesses: the Brixton Society is sympathetic to the provision of new business floorspace, because so much has been displaced by high-density residential development in recent years. However, it needs to match the needs of a range of local business types, including some uses or processes which will generate noise or fumes, or require the storage or recycling of special waste products. Providing undifferentiated desk- space for start-ups is insufficient for a development of this scale. Too many growing enterprises have had to move away from the Lambeth area because of a lack of suitable local premises to expand into, reducing local employment opportunities. To allow existing tenants to relocate within the larger site, the development should be carried out in phases.

• Noise Impact on nearby dwellings: Operating hours and vehicle access arrangements need to respect the amenity of nearby residential property in Cranmer Road and Foxley Road.

• Extract Ventilation: The design of extract ventilation is often a critical factor in how acceptable industrial processes will be in proximity to residential accommodation. External ducts should be sited in relatively unobtrusive positions. On the Cranmer and Foxley Road frontages, they should only discharge above the main roof level. Flues should include odour filters and soundproofing.

Officer comment: A Design and Access Statement has been submitted with the application and is available to view on the Council’s website. The concerns raised are addressed in the ‘Design and Conservation’ and ‘Amenity of neighbouring occupiers’ section below.

5.5 Adjoining owners/occupiers

5.5.1 Public consultation was undertaken in accordance with statutory and council requirements, including 551 individual letters sent to neighbouring properties within the vicinity of the site, publication of a press advert and site notices being displayed on 6th March 2020. The public consultation period formally ended on 6th April 2020 although representations continue to be accepted up until the time of determination.

5.5.2 In total, 1 individual objection has been received as summarised in Table 2 below:

Summary of objections Response Amenity • Likelihood of undue noise and Refer to ‘Amenity of neighbouring occupiers’ fumes section below • Loss of sunlight/daylight Refer to ‘Amenity of neighbouring occupiers’ section below • Loss of privacy Refer to ‘Amenity of neighbouring occupiers’ section below

Table 2 – Summary of objections

6 POLICIES

6.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires planning decisions to be made in accordance with the development plan unless material considerations indicate otherwise. Section 72 of the Planning (Listed Buildings and Conservation Area) Act 1990 as amended advises that the Council has a duty to respect any building or land in conservation areas in exercise of planning functions and advises that special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area.

6.2 The development plan in Lambeth is the new London Plan (2021) and the Lambeth Local Plan (September 2015). Following the successful completion of the Examination process and formal consent to publish by the Secretary of State, on 2 March 2021 the Mayor of London formally published the new London Plan which now has full weight in planning decisions. The Lambeth Local Plan (LLP) is currently under partial review to ensure it complies with amendments to the National Planning Policy Framework (NPPF) and the new London Plan.

6.3 The Draft Revised Lambeth Local Plan (DRLLP) underwent public consultation under Regulation 19 of the Town and Country Planning (Local Plans) (England) Regulations 2012 between 31 January and 13 March 2020 and was submitted to the Secretary of State for examination on 22 May 2020. The examination hearing took place between the 27 October and 13 November 2020. The Inspector’s proposed main modifications were made available for public consultation between 15 February and 29 March 2021. Those draft policies that are unaffected by proposed main modifications can be considered to have significant weight at this point, with moderate weight

afforded to those policies that are subject to proposed main modifications.

6.4 The latest NPPF was published in 2018 and updated in 2019. This document sets out the Government’s planning policies for England including the presumption in favour of sustainable development and is a material consideration in the determination of all applications.

6.5 The current planning application has been considered against all relevant national, regional and local planning policies as well as any relevant guidance. A full list of relevant policies and guidance has been set out in Appendix 3 of this report.

7 ASSESSMENT

7.1 Land uses

7.1.1 The proposal would provide 24,672sqm (GIA) of flexible industrial and employment floorspace (former Use Class B1a-c and B8) with an increase of 16,213sqm (192% uplift) proposed on site. The principle of the proposed uses is discussed in full below.

Industrial and employment floorspace

7.1.2 The application site lies within the Kennington Oval area, where, through Policy PN8 of the LLP and DRLLP, the council will support its role as an important residential and employment area. Policy PN8 notes that there are opportunities to increase the vitality and attractiveness of the Brixton Road centre through the provision of active frontages in the Kennington Park. The Local Plan considers that appropriate proposals that achieve these objectives and result in no net loss of employment floorspace will be supported.

7.1.3 The site also lies within the designated Kennington Business Park Key Industrial and Business Area (KIBA), which is referenced as a Locally Significant Industrial Site (LSIS) within Policy E6 of the London Plan. The application site comprises 1.58ha of the overall 2.5ha Business Centre containing 8,459 sqm of floorspace in former Use Class B1a-c use.

7.1.4 Policies E4 and E7 of the London Plan seek to ensure there is sufficient industrial capacity across the capital to meet current and future demand. Policy E4 states that the provision of industrial capacity should be retained and enhanced in locations such as this, which provide capacity for micro, small and medium sized enterprises. Policy E7 also states that the redevelopment of Locally Significant Industrial Sites such as this can be supported where industrial floorspace is re-provided as part of an industrial intensification, co-location and substitution scheme.

7.1.5 Policy ED1 of the LLP further advises that development in KIBA’s will only be permitted for ‘business, industrial, storage and waste management uses, including green industries and other compatible industrial and commercial uses (excluding large scale retail) ancillary to, or providing for, the needs of the KIBA’. Policy ED3, part b) of the DRLLP encourages the intensification of industrial uses in former Use Classes B1b, B1c, B2 and B8 and industrial sui generis use, in accordance with Policy E7, Section A of the London Plan. Development proposals of this type should have regard to operational requirements (including servicing) and mitigate impacts on the transport network where necessary.

7.1.6 As set out in Table 1 above, the proposal would re-provide the full existing quantum of former Use Class B1c light industrial floorspace, including the former Use Class B8 floorspace (5,408sq.m), which is supported. This would be secured by condition in any permission granted. The proposed floorspace would not compromise any surrounding industrial uses, in terms of their function, operation and access, and has been designed to be fully fit for purpose in accordance with Policy E2 of the London Plan and the GLA’s minimum specifications for industrial uses.

7.1.7 The proposed former Use Class B1c floorspace units within Building C would be flexible, with the ability to be made larger or smaller to suit the occupier (these range from circa 30-100sqm) with a

range of floor to ceiling heights with the ground floor units having a floor to ceiling height of 3.6m under the part mezzanine floor, the remainder of the ground floor (double height section without the mezzanine floor) having a floor to ceiling height of circa 7m. The part mezzanine floors within the ground floor units give the occupier the option of installing larger machinery in part of the unit and an ancillary storage or office space within the mezzanine, if desired. The other floors within the Block are circa 3.1m in height. The corridors would have a minimum width of 1800mm, and a goods lift is proposed within Block C. All units would have a lockable door and a minimum opening width of 0.9m. The yard space is also appropriate for the building and the number of units. The detailed specification and functionality of the light industrial / workspace, in terms of fit out, layout, access and servicing would be secured by condition were permission to be granted.

7.1.8 The development also proposes a significant uplift in business floorspace with an increase of 16,213sqm (192% uplift) proposed on site. The employment use proposed would permit a range of office, research and development and light industrial uses falling under former Use Class B1a, B1b and B1c and provides flexible workspace suitable for occupation by a range of business sizes, which is welcomed.. The design and layout of the proposal has been specifically tailored to be suitable for micro, small and medium sized creative enterprises engaged in light industrial manufacturing and design activities. Policy E1 of the London Plan supports increases in office provision in certain locations, in outer and inner London, this includes focusing office development in town centres and existing office clusters. In this regard, the site is an established business park with a large proportion of existing office floorspace. On this basis, the provision of business uses on site is acceptable in principle,

Affordable workspace

7.1.9 Policy E3 of the London Plan encourages the provision of affordable workspace, the specifics of which should be defined in local development plans. In this regard, Policy ED2 of the DRLLP states that the council will apply requirements for affordable workspace in (i) Waterloo/Southbank and Vauxhall, (ii) Oval, Kennington and Clapham and in the (iii) Brixton Creative Enterprise Zone. The supporting text to the policy explains that the areas referred to in Policy ED2, part a) i) and ii) correspond to CIL charging zones A (Waterloo/ Southbank and Vauxhall) and B (Kennington, Oval and Clapham). The application site lies in Charging Zone C and therefore this policy does not apply to this site and the proposal is not required to provide a percentage of Affordable Workspace.

7.1.10 Notwithstanding this, this site will continue to operate as per the applicant’s existing business model which provides floorspace for SME, including access to onsite facilities providing support for micro and small businesses at an affordable rent and flexible leasing agreements which can be adapted as businesses grow.

Flexible retail / commercial unit

7.1.11 The scheme proposes one unit (330sqm) as a flexible/alternative commercial use, comprising either former Use Classes A1/A2/A3/A4 or B1 floorspace. This unit is proposed to be located within the north east corner of the site, within the ground floor of Building C. This flexible unit is described as an ‘ancillary facility to the KIBA, to cater for the significant uplift in employees on the site’. The applicant’s aspiration for this unit is to provide a facility which is related to the use of the KIBA, such as a small-scale café or a bar/taproom. The applicant states that whilst they expect the facility would primarily serve those working and visiting Kennington Park, both future and existing, it would also be open to the general public. The principle frontage of the unit will face internally to the courtyard and KIBA but would also be accessible from the corner of Foxley Road. The proposed unit will have direct access to the external amenity space proposed within the courtyard, where seating and a games area are proposed as part of the landscaping strategy. The applicant estimates that the whole of the development proposal when complete will be occupied by between an additional 351-1370 employees.

7.1.12 The site is not within a designated town centre. However, a local centre lies immediately to the west of the site along Brixton Road. The proposals are for 330sqm of flexible former Use Classes A1/A2/A3/ A4 or B1 uses which is to be located in a unit to the north east of the site, furthest from the local centre and therefore in an out of centre location. Policy SD7 of the London Plan and Policy ED6 of the LLP and DRLLP require the sequential test to be applied to applications for main town centre uses, requiring them to be located in town centres in the first instance. Out of centre sites should only be considered if it demonstrated that no suitable sites are available within the town centre or edge of centre locations and applications that fail to demonstrate this should be refused. Notwithstanding this, given the relatively small size of the unit and the fact that it would serve as a complementary function to the business park, the provision of a small flexible retail unit is considered acceptable on balance.

Social Infrastructure

7.1.13 The existing site currently contains an element of former Use Class D1 floorspace comprising educational and training floorspace according to the applicant’s submission. This has been defined as existing flexible office/ educational floorspace (1,455sq.m) which it is understood is currently occupied by the University of Wales as offices and teaching/ training facilities in Winchester House.

7.1.14 Uses involving teaching and training cannot lawfully be accommodated under former Use Class B1 use. Policy S3 of the London Plan and Policy S1 of the LLP and DRLLP seek to ensure development proposals result in no net loss of education or childcare facilities, unless it can be demonstrated that there is no on-going or future need.

7.1.15 The planning permission (ref. 09/03485/FUL) for the first floor approved the change of use of 1,637sqm to former Use Class D1 use. It is acknowledged, however, that a condition attached to this particular permission states that should this use cease, it is required to be reinstated to Class B1. However, if it is still in active use, this floorspace should be re-provided under the provisions of the policies. The proposals would re-provide this use in its entirety which would satisfy the requirements of Policy S3 of the London Plan and Policy S1 of the LLP and DRLLP.

7.1.16 Given the flexible nature of this permission and requirement to reinstate the use back to Business use, it is not deemed appropriate to secure a solely Storage or Distribution use within the proposal, this use would also not be an appropriate use within a KIBA under policy. As such, 1,455sqm would be secured as flexible Class D1/B1 use were permission to be granted.

7.2 Design and conservation

7.2.1 Good design is central to all objectives of the London Plan and LLP and DRLLP planning policies. Policies D1 to D4 of the London Plan place greater emphasis on a design-led approach to ensure development makes the best use of land, with consideration given to site context, public transport, walking and cycling accessibility and the capacity of surrounding infrastructure. The higher the density of a development the greater the level of scrutiny there should be of the proposed built form, massing, site layout, external spaces, internal design, and ongoing management.

7.2.2 Policies Q5 and Q7 of the LLP and DRLLP seek to create high quality urban environments and state that proposals will be supported where the design of development is a response to positive aspects of the local context and historic character.

7.2.3 The Business Centre is locally listed and therefore considered a non-designated heritage asset. The site is also sandwiched between two conservation areas; St Marks (CA11) that lies north of the site and Vassal Road (CA7) directly east of the site along Foxley Road. Kennington Park, a Grade II Registered Park is north of the site. There are also a number of statutory and locally listed buildings in the vicinity of the site.

7.2.4 This section of the report considers design and conservation (heritage) matters arising from the proposed development and incorporates the Council’s Design and Conservation Team’s comments on

the proposals. It is set out under the following sub-headings:

• Scale, massing, layout and appearance • Strategic and Local Views • Impact on heritage assets

7.2.5 The Council’s Design and Conservation Team’s comments have been incorporated into this section of the report.

Scale, massing, layout and appearance

7.2.6 The scale of development in the surrounding context is relatively modest ranging between two and four storeys in height. The retained buildings on the site (Lincoln House, Canterbury Court, Chichester House and Chester House) are substantial occupying a large footprint and standing at four storeys making an impression within the streetscene. The proposal is for three buildings - Block A (five storeys along Cranmer Road), Block B (part three, four and five storeys along Cranmer Road) and Block C (four storeys on Foxley and Camberwell New Road). The proposed blocks would be of a comparable scale and mass to existing blocks on site and as such would not appear dominant or out of place within the surrounding context. The scale of development is considered to be in keeping with the established character of the commercial complex.

7.2.7 The proposal would increase in height and mass noticeably along Cranmer Road. However, at a maximum of four storeys fronting Cranmer Road, as shown in Figure 5 below, the proposal would not overbear the street and the generous gaps between Block A, B and C ensures that development will not appear as a continuous canyon like development.

Figure 5 – Proposed view looking northwest from Foxley Road and east along Cranmer Road

7.2.8 In addition to appropriate scale, the proposed Block building lines respond positively to the established building lines of retained buildings Cranmer House and Canterbury Court which assist in the proposal fitting into the streetscene successfully. The layout, scale and mass would relate positively to the existing context and as such would not appear dominant in the streetscene or context.

7.2.9 The architectural approach is based on a contemporary warehouse aesthetic. Officers consider this an appropriate design approach as it resonates strongly with the character of the retained locally listed commercial/warehouse buildings. Each of the proposed buildings have robust brick elevations with regular punched window openings.

7.2.10 The group of buildings proposed has been carefully considered in terms of their architectural language. The architectural detailing provides individuality to each block whilst the consistent use of brick creates a clear and coherent visual appearance that unifies the complex. Brick detailing and the use of contrasting and complimentary materials also adds another layer of interest and texture. The material palette is also well considered with brick the predominate material which relates positively to the other buildings within the complex and the surrounding context and gives the buildings a robust

quality. Overall, the design and appearance of proposed blocks are considered to be acceptable and will contribute positively to the streetscene and context.

7.2.11 Whilst officers are supportive of the principle and style of boundaries along Cranmer Road, there is concern in relation to the potential height of these railings, which should be lowered where possible. As such, a condition requiring details of boundary to be agreed is considered to be appropriate.

Strategic and Local Views

7.2.12 The site is within the strategic view of Primrose Hill to the Palace of Westminster background assessment area (view 4A.2) and also within local views, including Local Views 19 Brixton Panoramic and 22 Norwood Park and Millbank to Vauxhall Bridge Given the relatively low scale of the development, the Townscape and Heritage assessment undertaken and officers, conclude that there will be no impact or harm to either strategic or local views.

Impact on Heritage Assets

Locally Listed Buildings

i) Kennington Business Centre; Demolition of Salisbury House, Worcester House, Winchester House, Hereford House and Gloucester House

7.2.13 The business complex is locally listed for its architecture, history and townscape. Policy Q23, part (c) of the LLP and DRLLP advise that the council will: ‘i) resist the destruction of assets on the local heritage list (or harm their settings) and expect applicants to retain, preserve, protect, safeguard and where desirable, enhance them when developing proposals that affect them; ii) require proper investigation and recording of archaeological remains and publication and archiving of results to advance understanding.; and iii) apply London Plan policy HC1D’.

7.2.14 Paragraph 197 of the NPPF further states that ‘the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application’. In weighing applications that directly or indirectly affect non-designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.

7.2.15 The significance of the locally listed complex lies within the architectural, historical and townscape value of blocks fronting onto Brixton Road (Lincoln House, Canterbury Court, Chichester House, Chester Court and Cranmer House). These Edwardian blocks are striking in their appearance and scale, comprising highly ornamental and detailed brick and sandstone elevations. In contrast to these decorative buildings, the remaining blocks to be demolished, although having competent facades, are lower in scale and grandeur with a more utilitarian appearance and modest embellishment. In the case of Winchester House and Gloucester House they were of later construction; the façade of Winchester House was substantially rebuilt in 1992 and Gloucester House was built in circ.1950 therefore they do not have any heritage value. Similarly, there is evidence that suggests that Hereford House façade was also constructed at the same time as Gloucester House as the current façade is not apparent in a 1934 aerial photograph.

7.2.16 As detailed within the Design and Access Statement, there is also evidence that a number of the buildings are experiencing leakage in the roofs, internal water damage creating mould and unknown substances beginning to surface within the ground floor levels, likely as a result of historic uses of the site. Internally, the buildings have cramped and challenging layouts which have been altered over time in an attempt to cater and accommodate the changing and differing needs of businesses.

7.2.17 For these reasons, no objection is raised to the loss of Salisbury House, Norfolk House, Worcester House, Winchester House, Hereford House and Gloucester House. Furthermore, the replacement buildings will be of high architectural quality that sympathetically responds to the retained locally listed buildings and reinforces the character of the complex.

7.2.18 Overall, whilst officers recognise that parts of the locally listed complex will be lost this would not affect the significance of the complex as its value derives from the retained buildings on site. Officers are also of the view that the proposed Blocks will enhance the setting of the locally listed complex particularly in views from Camberwell New Road, Cranmer Road and Foxley Road.

ii) No 60 Camberwell New Road

7.2.19 The Kennington is a three-storey public house built in circa1900 in the Queen Anne style and located along Camberwell New Road at the junction with Foxley Road. The pub marks the corner, boasting Dutch gables with copper dome and its elevations are faced in red brick with stone dressings. Currently, the site/Gloucester House are seen within the setting of The Kennington Pub from various vantage points along Camberwell New Road and Foxley Road. Gloucester House is located directly opposite The Kennington and is considered to be an unremarkable utilitarian 1950’s commercial block which has a neutral impact on the setting of the locally listed pub. However, Block C which is proposed to replace Gloucester House would stand at a comparable height to The Kennington, be faced in brick and would have attractive appearance which would enhance the setting of the pub.

Figure 6 – Proposed view looking northwest along Camberwell New Road

7.2.20 Overall, it is considered the replacement high quality Block C would improve the setting of the pub.

Conservation Areas

i) Vassall Road Conservation Area (CA07)

7.2.21 The conservation area is located to the east and south-east of the site and is characterised by formal terraces and semi-detached villas built for the burgeoning middle classes when this area was made accessible following the construction of the Vauxhall Bridge after 1816. The site fronts onto Foxley Road which lies within the conservation area. The 2016 conservation character appraisal describes Foxley Road as a:

‘…relatively broad road has a quiet residential character. Detached and semi-detached villas and a grand terrace are supplemented by sympathetic 1970s infill development. The use of stock brick and stucco unifies the street, as does repeated use of 6/6 sash windows and flat gauged arch heads. The

presence of large trees and mature hedges gives it a leafy domestic atmosphere. Looking south the view terminates in the commanding spire of St John the Divine. There are excellent views of the rear elevations of terraced houses at nos 95 – 113 Vassall Road, which make an important contribution to the area’s historic character.

On the west side, tall villas (three storeys over a semi-basement) with overhanging eaves create a strong rhythm; these have narrow gardens and a close relationship to the street. Across from these is a smart terrace with tall flanking and central pavilions creating a symmetrical composition. The front gardens are now landscaped communally, re-graded to form a gentle slope to the basement area; they are no longer enclosed. These alterations cumulatively weaken their historic integrity. A large, well-planted open space near the junction with Vassall Road contributes to the street’s leafy quality. The pair of 1970s infill bungalows may at first seem incongruous with these surroundings, but their low scale allows for a sense of spaciousness.’

7.2.22 Foxley Road also contains a number of statutory listed properties the impact on these listed properties is assessed later on in my comments. The impact of Block C on Vassal Road Conservation Area is considered to be a positive and beneficial one. Its proposed height of four storeys provides appropriate enclosure and definition to the street a key character of Foxley Road whilst its quality detailed design relates to listed villas on the street. Block C is considered a marked improvement to the current Gloucester House which does not have any architectural or townscape value.

7.2.23 Overall, the proposal would enhance the appearance and character of Vassal Road Conservation Area.

ii) St Marks Conservation Area (CA11)

7.2.24 The St Mark's Conservation Area (CA) is characterised by smart terraced housing dating from the early 19th century onwards. Of particular note is Hanover Square. The imposing St Mark's Church is its principal landmark and is grade II* listed. The impact on St Marks church is assessed separately in the ‘Statutory Listed Building’ section.

7.2.25 Although St Marks CA is located close to the site on the west side of Brixton Road the impact of the proposal on the conservation area is limited as Blocks A, B and C are located within the southern portion of the site some distance from the CA. In views from St Marks CA towards the site, the retained blocks from Brixton Road would screen proposed Blocks A, B and C and where they are glimpsed, they would not appear dominate or distracting. Similarly, where Block C can be seen in views looking north west along Camberwell New Road towards St Marks CA it would moderate in scale and not detract of harm the appearance or character of the conservation area.

7.2.26 Overall, the proposal would preserve and enhance the appearance of the character of the St Marks Conservation Area.

Statutory Listed Buildings

i) Kennington Park (Registered Historic Park and Garden)

7.2.27 The impact on Kennington Park would be similar to St Marks. Block C would be seen in the setting of the park (eastern boundary) in the view looking northwest along New Camberwell Road. The moderate scale of Block C would not detract from the setting of the registered park. In officer’s view there would be an improvement to the parks setting.

ii) St Marks Church

7.2.28 St Marks’ is a grade II* listed church located along Kennington Park Road. Built 1822-24 to the design of A B Clayton with frontages onto Clapham Road, Brixton Road and Prima Road. The church is in Greek revival style with sandstone elevations and Portland stone tetrastyle Doric porch in antis with pediment and a square tower bearing octagonal drum and open round ionic stage with cupola above.

Nos 22 & 24 Brixton Road is a pair of houses dating from the early C19 in brown stock brick and is also listed (grade II). Both St Marks church and Nos 22 & 24 are located along Brixton Road and directly opposite the site.

7.2.29 The site lies within the backdrop of St Marks Church when looking south east from Clapham Road. The siting of Blocks A, B and C in the southern part of the site and being a similar height to retained buildings means that they would be mostly screened by retained blocks and where they may be visible taking into account seasonal changes their proposed height being similar to retained blocks means that they would not appear dominant. The church would the focal point in the view. In the view from Brixton Road looking north west towards the church, the proposal would not be seen in the setting of the church and as such there would be no impact. There would also be no impact on the setting of Nos 22 & 24 which when viewed from Brixton Road.

iii) Foxley Road and Camberwell New Road

7.2.30 Block C has frontages onto Camberwell New Road and Foxley Road which both contain a number of listed buildings close to the site, which are as follows:

Listed Buildings along Camberwell New Road and Foxley Road: • No.64-76 Camberwell New Road (Grade II) • No.78-82 Camberwell New Road (Grade II) • No.84-90 Camberwell New Road (Grade II) • No.15-19 Foxley Road (Grade II) • No.32-48 Foxley Road (Grade II) • No.21-37 Foxley Road (Grade II)

7.2.31 As such, Block C would be seen in the streetscene and within their settings in views along Camberwell New Road and Foxley Road. Unlike Gloucester House which has no architectural value, Block C has pleasing proportions that take inspiration from the rhythms and patterns of listed villas along Foxley Road. As a result, the scale, mass and detailed design relates positively to the listed buildings and character of the street. Where Block C turns the corner onto Camberwell New Road its defined brick parapet and setback upper storey responds to the massing and form of Canterbury House and therefore fits into the streetscene successfully.

7.2.32 Overall, Block C would be a positive addition to the street which would enhance the setting of listed buildings along Foxley Road and Camberwell New Road. The proposal would have a similar beneficial impact in the view looking south along Foxley Road where St John the Divine Church (Grade I listed and built 1870-74 to the designs of G E Street) which spire terminates the vista and the church is located on Vassal Road. The high-quality appearance of Block C would improve the appearance of the street and the foreground of the view.

Conclusion

7.2.33 To conclude, officers have carefully considered the impact of the proposal on the setting of statutory listed buildings and no harm has been identified harm to these designated heritage assets. The proposal would therefore comply with Policy Q20 of the LLP and DRLLP.

7.3 Inclusive Design

7.3.1 Policy D5 of the London Plan requires that all new developments achieve the highest standards of accessible and inclusive design and can be used safely, easily and with dignity by all; are convenient and welcoming with no disabling barriers; are flexible and response; and realistic. This requirement is reiterated in Policy Q1 of the LLP and DRLLP.

7.3.2 Blocks A and B are accessed from the internal courtyard/landscaped area and Block C has a direct entrance from the road and from the rear courtyard. The proposed buildings all have step free access. All entrances to the buildings will be step free, fully accessible and clearly distinguishable from the rest

of the façade. All entrance doors will have clear openings greater than 800mm in order to facilitate wheelchair access.

7.3.3 There are 6 disabled parking bays proposed on site, all of which will have electrical charge points. The areas dedicated to disabled car parking and loading bays are located off the main vehicle route. These will be identified by the use of graphics painted on the concrete paving.

7.3.4 Internally, lift access is available to all floors which will accommodate wheelchair users with room for standing passengers.

7.3.5 As such, the proposal would provide a high standard of accessible and inclusive design that can be used safely and easily by all in accordance with Policy D5 of the London Plan and Policy Q1 of the LLP and DRLLP.

7.4 Fire safety

7.4.1 Policy D12 of the London Plan states that major applications should be accompanied by a fire statement, prepared by a suitably qualified third-party assessor, demonstrating how the development proposals would achieve the highest standards of fire safety, including details of construction methods and materials, means of escape, fire safety features and means of access for fire service personnel. Policy D5 further seeks to ensure that developments incorporate safe and dignified emergency evacuation for all building users. In all developments where lifts are installed, as a minimum, at least one lift per core (or more subject to capacity assessments) should be a suitably sized fire evacuation lift suitable to be used to evacuate people who require level access from the buildings.

7.4.2 An outline Fire Strategy has been submitted with the application which sets out the overall approach to fire safety. This has been reviewed by the Council’s Building Control section and is considered to be satisfactory given the early design stage, covering the key design issues. A more detailed strategy to accompany the design would usually be submitted as part of the Building Regulations application to the chosen Building Control Body (BCB). It is that BCB who will consider compliance of the scheme including any proposed deviations, relaxations, compensatory measures etc.

7.4.3 A condition would be applied to any permission granted requiring a detailed Fire Statement to be produced by an independent third party. The submitted details would be assessed by the Council’s Building Control department and the proposal would therefore meet policy.

7.5 Amenity for neighbouring occupiers

7.5.1 One of the core planning principles (paragraph 17) in the NPPF is that decisions should “always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings”.

7.5.2 Policy Q2 of the LLP and DRLLP only supports development if visual amenity from adjoining sites and from the public realm is not unacceptably compromised, acceptable standards of privacy are provided, adequate outlook is provided, while undue sense of enclosure and overlooking is avoided, and daylight and sunlight levels to both the host property and surrounding properties are not compromised.

Daylight, sunlight and overshadowing

7.5.3 In accordance with Policy Q2 of the LLP and DRLLP, the application is accompanied by a Daylight and Sunlight Assessment prepared by Waldrams. This provides an assessment of the potential impact of the development on sunlight, daylight and overshadowing to neighbouring residential properties and open spaces based on the approach set out in the Building Research Establishment’s (BRE) ‘Site Layout Planning for Daylight and Sunlight: A Good Practice Guide’. This includes an assessment of impacts on the site’s residential neighbours.

7.5.4 The BRE guidelines are not mandatory; they do however act as a guide to help understand the impact

of a development upon properties and other spaces, while acknowledging that in some circumstances, such as that of an urban environment or where the existing site is only previously partially developed some impact may be unavoidable. It should be further noted that the BRE guide considers level of daylight, sunlight and overshadowing tests based on an expectation of reasonable levels of light within a suburban context and this should be kept in mind when considering a central London context as is the case for the application site.

7.5.5 The nearest residential properties to the site are located in Cranmer Road, Bowhill Close and Minerva Close to the south; Camberwell New Road and Foxley Road to the east; and Camberwell New Road to the north as shown in Figure 2 above.

7.5.6 The Council has sought an independent review of the report findings in respect of possible impacts of the new development on surrounding sites and within the development itself. This review was undertaken by Schroeders Begg. Their assessment review considers several tests:

• The 25-degree line: Properties will very likely retain good levels of daylight and sunlight if new development does fall below a 25-degree line to the horizontal drawn from the centre of the lowest window; • Vertical Sky Component (VSC): A measure of the amount of skylight available at the centre of a habitable room window (ratio compared to horizontal plane) to serve a habitable room. The BRE guide states that daylighting may be affected if the VSC calculation is less than 27% and less than 0.8 times its former value; • Annual Probable Sunlight Hours (APSH): Is a measure of the average number of hours per year in which direct sunlight is received by a window. The BRE guide states that rooms may be affected if they receive less than 25% APSH for the year and 5% APSH for the winter; and less than 0.8 times former value; • Daylight Distribution / No skyline test (NSL): A measure that calculates the amount of area (at the working plane) of a habitable room which receives direct skylight and how much does not. The BRE guide highlights if less than 0.8 times former value, reductions will be noticeable; and • Shadowing: The BRE guide recommends that at least half the area of an amenity space should receive at least 2hrs of sunlight on the Spring Equinox (21 March).

7.5.7 In terms of daylight analysis, applicable reductions to habitable rooms in both VSC and daylight distribution / NSL meets BRE target criteria for the following properties and therefore, the review does not comment further on these;

• Nos 3-13 (odds) Foxley Road • Nos 39-57 Camberwell New Road • Clarson House, 59-61 Camberwell New Road

7.5.8 The review undertaken concludes that the proposal would result in some very limited reductions to a window or room which is considered as effectively / very close to meeting target and this is summarised as follows;

No 2 Bowhill Close

7.5.9 This bungalow property has 2 No rooms with windows facing north / opposite the development site; a conservatory and dual aspect living room which have daylight VSC reductions to some isolated windows with reductions exceeding BRE Guide default target criteria. For the conservatory, there are 2 No isolated windows with a VSC reduction each of 22%; however, given the numerous windows within the conservatory, in consideration of the average VSC reduction for this room, BRE Guide target criteria would be readily met. Similarly, for the dual aspect living room, this is served by a window and glazed door facing site and rear window / not facing site; in considering an average VSC reduction for this living room, the reduction would equate to 18% thus within BRE Guide target criteria. A third room has also been analysed (bedroom) albeit windows are perpendicular to site and for the small reductions applicable in daylight VSC, these meet target criteria. For any reductions in daylight

distribution to all 3 No rooms considered, these readily meet BRE Guide target criteria. Thus, in terms of daylight reductions, in considering the analysis in context of dual aspect arrangements, there is considered to be no adverse effect overall to this property.

The Kennington, 60 Camberwell New Road

7.5.10 The likely residential upper parts of this property have been analysed. All reductions in daylight VSC and daylight distribution meet target criteria with the isolated exception of a window to a 1st floor window (window W7 potentially serving a kitchen having a VSC reduction of 29%); however, given that this window forms part of a bay arrangement and is not the central window (often the main / primary window considered) and equally, the average VSC reduction for the room would readily meet BRE Guide default target criteria, we consider that there is no adverse effect overall. In addition, there is also a 1st floor room (ref R3, potentially a dining room) which is served by 2 No windows and whilst reductions will exceed BRE Guide target criteria, the retained VSC value to both of these windows is 26.3 thus very close to a VSC threshold value of 27 (VSC reductions not being considered until falling below a VSC value of 27). In summary, it is considered there is effectively no / negligible adverse impact on daylight to this property for the anticipated residential habitable rooms.

7.5.11 In respect of the remaining properties, there are reductions in daylight VSC and / or daylight distribution there are a number of windows (and / or in some isolated instances, greater reductions) not meeting BRE Guide default target criteria and we upon these as follows:

Swift House (Nos 25-38 inclusive), Cranmer Road

7.5.12 This property comprises flats / maisonettes and based upon indicative layout details, it appears that typically, bedrooms and small / medium size kitchens have windows in the north elevation / facing the site (living rooms, typically appearing to rear of the property facing south, away from the proposal).

7.5.13 For the western half of this property (Nos 25–32 Swift House), for any applicable reductions in daylight VSC and / or daylight distribution, these meet BRE Guide default target criteria.

7.5.14 For the eastern half of this property (Nos 33- 38 Swift House), from the analysis, there are typically ‘minor adverse’ reductions in VSC (2 No windows having reductions at 30% reduction thus borderline of ‘minor / moderate’ adverse reductions). However, in all instances, retained VSC values for these particular windows range 19.4 to 26.6 thus considered a reasonable VSC for an urban context.

7.5.15 In terms of daylight distribution, all reductions meet BRE Guide default target criteria with the isolated exception of 4 No rooms; 2 No rooms with ‘minor adverse’ reductions and 2 No rooms having ‘moderate adverse’ reductions; these rooms being at the eastern end. However, in respect of the retained daylight distribution value, these are; 61%, 66%, 74% & 75% respectively, which again are considered reasonable for an urban context.

7.5.16 In summary, the majority of rooms have reductions in daylight distribution meeting target criteria and for daylight VSC, circa half of windows applicable for review have reductions meeting target criteria and for the remaining eastern half, reductions are typically, ‘minor adverse’ and relating to bedrooms or kitchens and in consideration of retained levels, these are considered reasonable for an urban context.

Nos 6-30 (evens) Cranmer Road

7.5.17 For these townhouses, based upon indicative layout details, it appears that typically bedrooms have windows in the north elevation / facing site (living rooms, typically to the rear of these townhouses with windows facing south, away from the proposal).

7.5.18 For Nos, 6, 8 & 10 Cranmer Road, effectively reductions in daylight VSC and daylight distribution meet BRE Guide default target criteria.

7.5.19 For Nos 12, 14, 16, 18, 20, 22, 24, 26, 28 & 30 Cranmer Road, in terms of windows facing site that are serving habitable rooms (in this instance considered typically bedrooms), all windows have ‘minor adverse’ reductions in VSC. The applicable retained VSC values are ranging 16.5 to 26 (average retained VSC for this particular range being 22.2) which again, could be considered reasonable for an urban context and in consideration that typically the habitable rooms appear bedrooms which the BRE Guide recognises for which daylight as being less important (when compared to say a living room / similar). For the same property range, in terms of daylight distribution, typically, it is the lower ground floor rooms with reductions not meeting BRE Guide default target criteria and to such rooms, reductions are typically ‘major adverse’.

7.5.20 However, it is noted that all rooms as existing scenario, effectively have 100% daylight distribution to these rooms and for the given reductions, these rooms would still retain a daylight distribution of 59% or above (with the isolated instance of one room with a proposed daylight distribution of 55% and 1 No room at 58%). To highlight, these reductions in daylight distribution relate to the lower ground floor rooms and almost all reductions in daylight distribution at upper ground and 1st floor meets BRE Guide default target criteria.

7.5.21 On balance, in consideration of the extent and adversity, retained values and room uses affected (typically bedrooms), general dual-aspect arrangement of these residential properties etc, it is considered that such an impact to daylight should be considered reasonable for an urban context.

Nos 36-50 (evens) Cranmer Road

7.5.22 These townhouses appear of similar arrangement to Nos 6-30 (evens) Cranmer Road, namely, typically bedrooms having windows in the north elevation / facing site (living rooms, typically to the rear of these townhouses with windows facing south, away from the proposal).

7.5.23 In terms of windows facing site serving habitable rooms, windows have typically ‘moderate adverse’ reductions in VSC (part opposite the slightly higher part of proposed Block B). Consideration of the applicable retained VSC values are ranging 15.2 to 26.8 (average retained VSC for this particular range being 21.4); indeed, given this retained average, it is highlighted that there are a limited 9 No windows (out of 23 No for this range) with a VSC below 20.

7.5.24 For the same property range, in terms of daylight distribution, typically, it is the lower ground floor rooms with reductions not meeting BRE Guide default target criteria and to such rooms, reductions are typically ‘major adverse’.

7.5.25 However, it is noted that almost all rooms as existing scenario, effectively have 100% daylight distribution to these rooms and for the given reductions, these rooms would still retain a daylight distribution of 59% or above (with the isolated instances of 4 No rooms in the proposed scenario with respective retained daylight distribution values of 50%, 52%, 55% & 57%). To highlight, this relates to the lower ground floor and almost all reductions in daylight distribution at upper ground and 1st floor meets BRE Guide default target criteria.

7.5.26 On balance, in consideration of the extent and adversity, retained values and room uses affected (typically bedrooms), general dual-aspect arrangement of these residential properties etc, it is considered that such an impact to daylight should be considered reasonable for an urban context.

No 6 Minerva Close

7.5.27 This bungalow property has 3 No bedrooms with windows facing north / opposite the development site (includes a larger bedroom appearing dual aspect with a small window in the rear elevation). In addition, there is a front living room albeit the windows appear perpendicular to the proposal / not directly facing and not analysed (there would be minimal reduction to these particular windows from the proposal).

7.5.28 In consideration of the 3 No bedrooms, in terms of daylight VSC, the reductions exceed BRE Guide

default target criteria with reductions considered as close to the threshold of ‘minor/moderate adverse’ reductions. In terms of daylight distribution, reductions are limited and readily meet BRE Guide target criteria. Such reductions in VSC for this urban context should be considered acceptable, especially, that these relate to bedrooms.

Nos 54-62 (evens) Cranmer Road

7.5.29 These residential properties are arranged at 2nd and 3rd floor above the Oval Ambulance Station and comprise 5 No maisonettes accessed from the deck-access walkway at 2nd floor. It appears that a kitchen at 2nd floor and a bedroom at 3rd floor are the habitable rooms with windows in the north elevation / facing site (living rooms appearing to the rear of the property with windows facing south / away from the proposal).

7.5.30 In terms of windows facing site serving these habitable rooms, all reductions in both daylight VSC and daylight distribution meet the BRE Guide default target criteria with the exception of VSC reductions to the 5 No kitchen windows at 2nd floor level.

7.5.31 In terms of these kitchen windows, they are recessed within the deck-access since the bedroom at 3rd floor projects out above these kitchen windows thus forming a soffit above these kitchen windows which inherently obstructs daylight. In such instances, sometimes a theoretical analysis of ‘without balconies / soffits’ is undertaken to assist in consideration of the sensitivity of this inherent arrangement to changes in obstruction / the proposed massing.

7.5.32 However, given that the actual shift in VSC loss is limited (in value terms, as opposed to percentage terms), then this is less benefit for consideration of ‘without balconies / soffit’ analysis and equally, it can be readily seen that the windows on the immediately floor above (which whilst benefitting from being slightly higher, do project further forward / closer to the proposal), have quite limited reductions of just up to 9% reduction. These kitchen windows, whilst having a percentage reduction ranging from 21% at the east and 46% at the west end, actually have a limited VSC shift loss, equating to a VSC loss of 2.1 at the east and 4.6 at the west end, which can be considered as quite limited losses in real terms.

7.5.33 In summary, daylight reduction to these properties meets target criteria with the exception to the recessed 2nd floor kitchen windows facing the proposal in terms of daylight VSC. It is considered that a ‘without balconies / soffit’ analysis for these windows would more likely indicate that it is the inherent projecting soffit above the window resulting in the sensitivity, rather than an adverse proposal, especially based upon the limited VSC reductions to the windows immediately above on the 3rd floor.

Nos 1 & 1a Foxley Road

7.5.34 For these semi-detached properties, 6 out of 10 windows would have reductions greater than BRE Guide target criteria ranging 21% to 28% / ‘minor adverse’. However, in all instances the retained VSC value is not less than 23.6 which is considered a good VSC for an urban context.

7.5.35 In terms of daylight distribution, all reductions meet BRE Guide target criteria with the isolated exception of one ground floor room with a reduction still very close to BRE Guide target criteria at a 22 % reduction.

Nos 62-72 (evens) Camberwell New Road

7.5.36 The rear elevation of these terraced properties have windows serving rooms that are oblique to site. In terms of daylight VSC, all reductions meet BRE Guide default target criteria.

7.5.37 In terms of daylight distribution, all reductions meet BRE Guide target criteria with the isolated exception of one lower ground floor room (potentially bedroom) with a 31% reduction / ‘moderate adverse’ daylight distribution reduction (retained daylight distribution of circa 57%).

7.5.38 In summary, consideration of the daylight analysis of the reductions to both VSC and / or NSL/ daylight distribution, the majority of reductions meet or are close to default BRE Guide target criteria and in those instances that reductions are beyond target criteria, then such reductions could be considered as more typically ‘minor adverse’ (plus a relatively smaller number of greater impacts / reductions of ‘moderate adverse’ / ‘major adverse’).

7.5.39 On balance, in consideration of the extent and adversity, retained values and rooms, uses affected (typically bedrooms which the BRE Guide recognises as daylight being less important), dual-aspect arrangement of many of these residential properties etc, it is considered that such impact to daylight should, overall be considered reasonable for an urban context / arrangement.

7.5.40 In relation to the review undertaken of the impact of the proposal on sunlight to neighbouring windows / rooms, a significant proportion of these properties are not applicable for sunlight review to windows since the windows are ‘north facing’ (not facing within 90 degrees of south); this is primarily applicable to the properties south of the site along Cranmer Road etc.

7.5.41 For the remaining properties that do have windows serving habitable rooms facing within 90 degrees of south, in consider of the analysis results for both Annual Probable Sunlight Hours (APSH) and winter sunlight, the reductions effectively all meet BRE Guide default criteria / there is no adverse impact and should be considered acceptable.

7.5.42 In relation to sunlight to neighbouring amenity / rear garden areas, it is noted that there is no submitted assessment of sunlight reduction to neighbouring amenity areas which primarily would relate to rear garden areas for assessment. However, similar to sunlight to windows, given that a significant proportion of these properties have gardens that are south of the proposal along Cranmer Road etc, there would be a limited number of properties for consideration.

7.5.43 For those properties for initial consideration, the rear gardens are to the rear of the neighbouring property in question thus not facing site and for this massing, there could only be limited affect as the actual neighbouring property / immediate surrounding properties would be driving the availability of sunlight / associated shadowing to the amenity area. The only properties which do have gardens facing / open to the proposal relate primarily to the rear gardens of Nos 62 – 66 (evens) Camberwell New Road; however, in consideration of the orientation of site to these particular gardens (site is south-west / west of these gardens), any applicable increased shadowing would not be for the morning and restricted for part afternoon / early evening sunlight, resulting from proposed Block C. Even though some increased shadowing is anticipated to the rear garden to these particular properties, given the availability of sunlight in the earlier part of the day (which could not be affected by the proposal), it is anticipated that these gardens would still readily meet the 2-hour BRE Guide amenity test (at the 21st March equinox standard review).

7.5.44 For the majority of neighbouring amenity areas there would be either no or extremely limited affect. For the isolated closest amenity areas with context for potential reductions, it is anticipated that for such reductions, these would still readily meet the 2-hour BRE Guide amenity test (at the 21st March equinox standard review).

7.5.45 In summary, it is considered that the proposed development would have a limited effect on the daylight and sunlight amenity received to neighbouring properties. The majority of living areas tested will comply with BRE guidelines and where they are exceeded, the majority of these windows would retain levels of daylight that are consistent for the local area and an inner urban location.

Outlook, privacy and overlooking

7.5.46 Policy Q2 of the LLP and DRLLP requires development to provide adequate outlooks avoiding where possible any undue sense of enclosure or unacceptable levels of overlooking (or perceived overlooking).

7.5.47 The application site already comprises commercial buildings with windows facing outwards from the

site towards the neighbouring residential uses on Cranmer Road, Foxley Road and Camberwell New Road. No additional windows are proposed on the Cranmer Road, Foxley Road and Camberwell New Road elevations and the building line will be no closer in proximity to the existing surrounding residential properties when compared with the existing situation.

7.5.48 The distance between the proposed building on Foxley Road and the façade of the nearest residential properties would be circa 21metres and the distance between the proposed buildings and the façades of the properties along Cranmer Road would be circa 17 metres, with Cranmer Road running between the buildings.

7.5.49 The proposal is also appropriately designed and positioned to ensure no undue overlooking or loss of privacy to the nearest residential properties on Cranmer Road, Foxley Road and Camberwell New Road. Given the separation distances proposed and positioning of the proposed windows, communal and terrace areas, the proposed development would not result in any undue overlooking or loss of privacy to neighbouring residential occupiers. As such. the proposal would be contrary to Policy Q2 of the LLP and DRLLP.

Noise and vibration

7.5.50 Policy D14 of the London Plan seeks to reduce, manage and mitigate noise. This is reiterated in Policy Q2 of the LLP and DRLLP.

7.5.51 A Noise Assessment report, prepared by Max Fordham LLP, has been submitted with the application which details the environmental noise issues at the site and makes appropriate recommendations regarding noise impacts from building services and light industrial activity. Using the background noise level taken within the long-term environmental noise survey, the noise emissions from the plant equipment required will be 5dB below the representative background level when measured outside the window of the nearest noise sensitive premises. The report concludes that is it unlikely that noise from plant or activity on the site would have an adverse impact to the surrounding neighbouring amenity.

7.5.52 No objection has been raised by the Council’s Environmental Health Section to the proposal. Conditions are proposed in relation to noise and vibration attenuation to ensure the appropriate mitigation and control measures proposed in the Noise Assessment report are implemented. Subject to these conditions, the proposal would not have any undue impact on neighbouring residential occupiers in accordance with Policy D14 of the London Plan and Policy Q2 of the LLP and DRLLP.

7.6 Designing Out Crime

7.6.1 Policy Q3 of the LLP requires developments to be designed in a manner that does not engender opportunities for crime or anti-social behaviour or create a hostile environment that would produce fear of crime.

7.6.2 For a development of this nature, the main considerations would relate to counter terrorism, access to the building and the areas of public realm around the building. No objection has been raised by the Designing out Crime Officer to the proposed development which would incorporate principles of Secured by Design. Conditions securing Secured by Design accreditation would be attached to any permission granted.

7.7 Ecology, trees and landscaping

7.7.1 Policies EN1 and Q9 of the LLP and DRLLP promote opportunities for greening, as well as protection and enhancement of existing biodiversity, and support the use of landscaping to provide strong boundary treatments, together with access routes and parking areas compliant with safety standards and minimum parking standards.

7.7.2 A Preliminary Ecological Appraisal, including a Phase 1 Habitat Survey of the site, produced by Ashgrove Ecology, has been provided with the application. This confirms that the site is not covered

by any statutory or non-statutory nature conservation designations. The appraisal finds that it is unlikely that the site would be used by anything other than a low number of birds and foraging bats and the proposed new areas of soft landscaping could provide opportunities for bird and bats. The impacts of the scheme on ecology are therefore predicted to be negligible and non-significant.

7.7.3 The appraisal makes a number of recommendations for the proposed scheme. Biodiverse roofs are proposed on all new buildings where this is possible. A rain garden is proposed within the centre of the site and within the landscaped pathway along Camberwell New Road. As well as providing areas for wildlife to drink, the rain gardens provide a sustainable way of conserving water, filtering pollutants from runoff and create a habitat for further wildlife.

7.7.4 The appraisal recommends the installation of two nest boxes suitable for black redstarts under the eaves of the new buildings and the suggestion of four bat boxes. The Landscaping Strategy proposes bird/bat/bug habitats across the site and boxes on the walls and under the eaves of the new buildings, including the provision of two nest boxes suitable for Black Redstarts, as suggested within the appraisal.

7.7.5 The Council’s Parks and Open Spaces Section support the proposals and the areas of 'green roof' on the roofs for Block A and Block B are welcomed as these will contribute significantly to the biodiversity value of the site and address any potential adverse ecological impacts from any proposed building demolition/disturbance. They strongly advocate for these roofs to be biodiverse 'living green roofs', designed with a high ecological value. This is especially important given the potential for local use by protected species like black redstart and foraging bats, as such a green roof type will provide appropriate nesting and foraging opportunity. Further details on the proposed green roofs, including a planting and maintenance plan, would be secured by condition in any permission granted.

7.7.6 A full landscaping strategy has been prepared by Spacehub, which details the proposed landscaping, lighting strategy and ecology strategy for the development. The existing site is dominated by car parking and as a result comprises predominantly hard standing, with very little amenity or green spaces. The scheme has been designed to significantly improve the environment and amenity across the site, in order to create a more welcoming, usable and biodiverse place of work.

7.7.7 ‘Canterbury Yard’ is the primary pedestrian entrance to the site and currently comprises predominantly hardstanding. The landscaping strategy proposes two lawns and movable seating to provide amenity space immediately outside the entrance to Canterbury Court. The current ramp down to the car park is step and uneven, a new more gradually sloping ramp is proposed with terraced planting and seats built into steps alongside this, improving the accessibility of the site and areas to relax in.

7.7.8 The frontage of Canterbury Court alongside Camberwell new Road is a dark and narrow space used for a number of car parking spaces. The landscaping strategy seeks to make this space usable by proposing glass ‘pod’ meeting rooms within a walled garden, comprising woodland, movable furniture and a raingarden. Between Buildings A and B is a ‘Central Yard’ comprising seating, wheelchair accessible car parking spaces, a rain garden and amenity spaces with games/play elements. Towards the east of the site, the scheme, as shown in Figure 7 below, proposes a ‘rubble garden’ and games yard, both of which are flexible spaces which can be used for outdoor games such as boules and ping pong, with outdoor seating. This space can be used by users of the ancillary facilities within Building C, for occupants of workspace and to host events.

7.7.9 Policy Q10 of the LLP and DRLLP seek to protect existing trees and will not permit development that would result in the loss of trees of significant amenity, historic and conservation value or give rise to the wellbeing of such trees.

7.7.10 An Arboricultural Impact Assessment has been prepared by Tamla Trees in support of the application. The site is not located within a conservation area and there are no Tree Protection Orders on site. In order to develop the site, 32 trees are required to be removed, these trees are internal to the site and are mostly car park trees. These trees are considered to be low quality and of minimal wider amenity value given their size and location and are classed as Category C and Category U trees within the AIA

which are lower quality and trees which are in such a condition that they would be lost within 10 years.

Figure 7 – Proposed Landscape Masterplan

7.7.11 The proposal also requires the crown reduction to four street trees, located on Cranmer Road, in order to facilitate the redevelopment of these buildings. 128 trees are proposed to be planted, resulting in a net gain of 96 trees. The species of trees to be planted have been informed by the Ecology Appraisal and include the planting of native shrubs to further attract wildlife. The proposal therefore provides a significant net gain in trees, amenity value of the site and biodiversity value to the site.

7.7.12 The Council’s Parks and Open Spaces Section welcome the landscaping proposals, including ground level planting of trees, shrubs and planters, and the installation of bat and bird boxes are recommended in the planning statement, ecological appraisal and as indicated on submitted plans. Conditions securing the hard and soft landscape planting and installation of bat and bird boxes would be attached to any permission granted to ensure the quality and suitability of such enhancements is secured.

7.7.13 In accordance with Policies EN1 and Q9 of the LLP and DRLLP, the scheme has maximised the opportunities for greening, providing improved boundary treatment, a significant increase in planting and amenity areas, enhancing the appearance of the site.

7.8 Transport

7.8.1 Policies T1, T3 T4 of the London Plan seeks to ensure that the impacts of development in transport capacity and the transport network are fully assessed. Policies T3, T6, T7 and T8 of the LLP and Policies T3, T7 and T8 of the DRLLP seek to ensure that proposals for development will have a limited impact on the performance and safety of the highway network and that sufficient and appropriate car parking and cycle storage is provided whilst meeting objectives to encourage sustainable transport and to reduce dependence on the private car. If development will have an unacceptable transport impact, it should be refused in the absence of mitigation measures to make the development acceptable.

Site context

7.8.2 The site is bound by Brixton Road to the west, Camberwell New Road to the north, Foxley Road to the east and Cranmer Road to the south. Brixton Road and Camberwell New Road are part of the Transport for London Road Network (TLRN), for which TfL is the Highway Authority.

7.8.3 The site is well placed for public transport, being within a 3–5-minute walking distance of seven bus routes and a 6-minute walking distance of the Oval London Underground station. As a result, the site has an excellent Public Transport Access Level (PTAL) of 6a, on a scale from 0 to 6b where 6b is the highest.

7.8.4 The site is also well connected to the cycle network with Cycle Superhighway 7 running along Clapham Road, east of the site. In addition, two new cycleways are proposed nearby; Cycle Future Route 14 on Camberwell New Road and Cycle Future Route 15 on Brixton Road.

Access

7.8.5 At present, the site is accessible to pedestrians, cyclists and vehicles via a number of access points from Brixton Road, Camberwell New Road, and Cranmer Road.

7.8.6 The proposal seeks to reorganise the internal courtyard to prioritise pedestrians and cyclists over the private vehicle with the removal of all general car parking and this element of the proposal is very much welcomed. The proposal also recognises the need to accommodate all servicing off-street (i.e., within the red line boundary) and as such to position loading locations in logical and clearly apparent areas which is supported. The proposal has been designed to reduce car dominance within the public realm, minimise pedestrian and cyclist conflict with their comfort prioritised and offering a more attractive, accessible area for employees, visitors and local residents.

7.8.7 Brixton Road is located along the Site’s western frontage and provides the main access point into the Site. There are three access points to the Site from Brixton Road; two of which form vehicular crossovers. The northern vehicular access is limited to pedestrians, cyclists and emergency vehicles whilst the southern vehicular access allows egress only via an automated gate. A gated pedestrian access is in between, provided offering the main access into the Site for those travelling to/from Oval Station.

7.8.8 Camberwell New Road is located along the Site’s northern frontage and operates westbound to Brixton Road / Harleyford Street junction and eastbound to Camberwell. Opposite the Site there is a gated access to Kennington Park. A single vehicular crossover into the Site is provided from Camberwell New Road, located within the Site’s north-eastern corner. A second vehicular access point into the Site from Camberwell New Road is located to the north-west of the Site, however this is currently unused.

7.8.9 Cranmer Road bounds the Site to the South. Cranmer Road accommodates 4 vehicular crossovers associated with the Site. The most easterly access provides entry / exit solely into a warehouse building and its forecourt. Two vehicular crossovers provide entry / exit into the Site’s car park area, and finally there is a crossover for the sub-station, located central to the Site’s frontage on Cranmer Road.

7.8.10 Finally, Foxley Road bounds the Site to the east. One vehicle access is provided to Foxley Road into the Site, this is currently operating as exit only for the taxi service building.

7.8.11 Pedestrians are well provided for in the vicinity of the development site with footways along both sides of all roads. Pedestrian specific way-finding signage is present and offers directions to local public transport services and sites of interest.

7.8.12 The nearest controlled crossing point is located on the Site frontage to Brixton Road. This crossing is two-stage with dropped kerbs, tactile paving and rotating cones for visually impaired pedestrians,

offering a route to Oval Station.

Sustainable travel and cycle parking

7.8.13 Based on the uplift in floorspace proposed, the Transport Assessment provided predicts the development will generate an uplift of 80 and 76 bus trips in the AM and PM peak hours respectively. According to TfL and the GLA in their Stage 1 response, several bus routes are already at capacity in the vicinity of the site. As such, a contribution of £450k (£90k pa x 5 years) has been requested towards bus services. This would be secured by s106 in any planning permission granted.

7.8.14 A total of 414 cycling parking spaces, including 358 long and 56 short-stay cycle parking spaces, are proposed which accords with standards of the London plan (2021). The long stay cycle stores would be located within or close to each new building and would be secure and covered. The short stay cycle spaces would be located within the landscaped areas around the buildings and comprise easily accessible Sheffield stands. Changing and shower facilities would also be provided within each new building. The Cycle parking is required to be designed and laid out in accordance with the guidance contained in Chapter 8 of the London Cycling Design Standards (LCDS). This would be secured by condition.

7.8.15 The nearest cycle hire docking station is on Cranmer Road, located on the south west corner of the site. Given the car-free nature of the proposed development and TfL’s objectives to increase sustainable and active travel, it is considered that the cycle hire docking station on Cranmer Road will need to be expanded. TfL have requested that a contribution of £50k towards the expansion of the existing docking station is secured through the s106 agreement, along with 3 years of free cycle hire membership for employees of the business units being secured.

Trip Generation and Impacts

7.8.16 A robust multi-modal trip generation exercise has been provided within the Transport Assessment submitted which concludes that the proposal will result in an increase in trip generation when compared to the existing use of the site, including increases in bus, rail and active mode trips which reflects the increase commercial floorspace. A further shift towards sustainable modes of transport will be promoted through the implementation of dedicated Travel Plans.

7.8.17 However, it is also acknowledged that there were 125 private cars/vehicles parked on-site on the day of the parking survey and that this application will see the removal of all casual (i.e., employee) car parking spaces, which will be further controlled by a Business Car Parking Permit Free agreement secured by s106 legal agreement.

7.8.18 The overall upgrade to the public realm and removal of general parking is expected to result in a mode shift for the entire site and therefore, the overall 24,672sqm of employment space has been assessed. It can be concluded that the vast majority of additional trips resulting from the proposed development will be by public transport. The net change in car driver trips is forecast to reduce significantly with circa 495 less vehicle trips (not accounting for the 39 arrival and 39 departure increase in servicing vehicle movements). Net increases in cycle trips of circa 16 two-way movements are forecast for the AM peak hour, 30 in the PM peak hour, with a corresponding 272 additional daily cycle movements.

7.8.19 To summarise, the trip generation assessment indicates that the uplift in commercial floorspace as part of the development will result in 324 additional trips during the AM peak and 341 additional trips during the PM peak with the vast majority making use of the site’s excellent accessibility to public transport. This is counteracted by a significant reduction in vehicle trips following the removal of the car park (excluding 12 disabled spaces, 9 loading areas and a car club bay). As a result, those working and visiting the site will no longer be able to travel by car (other than those with a blue badge) and will instead be required to adopt more sustainable modes.

7.8.20 The trip generation exercise predicts 491 fewer vehicle trips and 84 fewer motorcycle trips per day travelling to and from the site. The proposal would therefore result in a significant reduction in

vehicular traffic that will be removed from the surrounding streets and strategic network which is welcomed and is seen as a major benefit of the scheme from a transport and highways perspective and aligns with LLP and London Plan objectives.

Pedestrian Environment Review System (PERS)

7.8.21 A Pedestrian Environment Review System (PERS) audit has been submitted which studies a large area from an accident/collision history perspective, and whilst this is welcomed, it presents challenges with respect to identifying themes/clusters. The study assessed a five-year period, working back from September 2018. With respect to the most vulnerable road users. Reflecting this large collision study area, it is noted that a total of 1,536 accidents were recorded with 268 involving pedestrians and 547 involving cyclists.

7.8.22 The majority of accidents involving vulnerable road users took place across large junctions, generally at crossings, or just outside crossings, and in cycle lanes. The causes of recorded incidents are predominantly linked to pedestrians, cyclists and vehicle users not looking properly, or obeying traffic signals or traffic regulations according to the audit. Having reviewed the locations referenced in the recorded collision study, the Council’s Transport Section are unable to identify anything that might be linked to an obstructed sightline, for example, something which would be potentially directly linked to recorded collisions/incidents.

7.8.23 The ‘Active Travel Audit’ and ‘PERS Audit’ undertaken indicate that walking and cycling links in the vicinity of the site are good to excellent with wide and well-lit footways, pedestrian crossings and cycle lanes present in the vicinity of the site. Furthermore, there are a range of local amenities within a short distance of the site, ensuring a range of day-to-day facilities can be easily reached by either walking or cycling. This is helpful as regards the identification of (potential) mitigation and incorporated a detailed analysis of the ‘local’ roads in line with the PERS Assessment criteria, this is in order to identify and improve specific issues local to the site, benefitting both the local community and users of the Site.

7.8.24 The assessment area considered the primary walking routes from the application site to local public transport services and amenities including Oval Station, Vauxhall Station and bus services along Brixton Road, Clapham Road, Camberwell New Road and Kennington Park Road. The scope of the survey was agreed with the council prior to it being undertaken. Due to the convenient location of Oval Station, it is likely most public transport users will utilise this station. However, Vauxhall Station is located within the 20-minute Active Travel Zone and provides step-free access from the street to the train for the Victoria line and rail links, provides step-free access from street to train; and has therefore, been included within the PERS audit area.

7.8.25 The findings of the PERS Audit found all crossings to be at a ‘good’ level (green), other than the crossing from Foxley Road to Cranmer Road (C3), which was rated ‘poor’ (red). The average score for crossings was 50 (43%), with only C3 scoring (significantly) below this. The Cranmer Road / Foxley Road crossing has limitations relating to legibility for sensory impaired people, dropped kerbs and maintenance. Deficiencies in public footways were also identified.

7.8.26 The development itself, which proposes to improve remove all general car parking, will significantly increase cycle parking and enhance the pedestrian environment on site by landscaping the courtyard would contribute to an improved environment for pedestrians. A number of redundant crossovers will be removed as well as improvements to the footways in the immediate vicinity of the site as part of the proposal. This will include all existing footway crossovers to be stopped up; all areas of adjacent /local footway improved; and other pedestrian improvements, to be secured/delivered on the back of the PERS/Healthy Streets Audit.

7.8.27 It is considered appropriate that the applicant enter into a s278 Agreement with the council to undertake the necessary highway work / footway improvements along Cranmer Road and Foxley Road identified. This would be secure by s106 legal agreement in any permission granted.

Car Parking

7.8.28 The proposed development is car-free with the exception of 6 disabled parking spaces, having been reduced down from 12. This quantum is now considered acceptable and should facilitate improvements to the quality and layout of the public realm within the scheme. Disabled persons’ parking should also include infrastructure for electric or other Ultra-Low Emission Vehicles. A Car Park Management Plan would need to be secured by condition. The applicant will be required to enter into a section 278 Agreement under the Highways Act 1980, for the works on TfL’s highway associated with the scheme.

Car Clubs

7.8.29 There are several existing car club vehicles in the vicinity of the Site; the closest 3 vehicles are operated by Zipcar and are located within an 800m walk from the Site.

7.8.30 The applicant has engaged car club operators and is willing to fund the provision of a car club vehicle (most likely a van) within the site that can be used by employees at the site, along with providing access to the wider general public. The provision of a car club will support the car parking strategy, which seeks to reduce the need for car ownership through car parking restraint, and thus limit the traffic and associated air quality effects of the scheme. An “outline/framework Car Club agreement” (with free corporate car club membership for all on site businesses - for a minimum of three years) would be secured by s106 legal agreement.

Servicing, including Refuse and Recycling

7.8.31 A draft Delivery and Servicing Plan (DSP) has been provided which identifies that all servicing will be undertaken off-street within the car park area which is welcomed. Currently, there are no dedicated servicing bays with vehicles stopping informally within car parking spaces. The proposal will provide dedicated bays for deliveries and servicing suitably located throughout the site. This will increase the safety and efficiency of servicing vehicles.

7.8.32 The proposal is for a shared space approach, which will assist in reducing driver speed and increasing driver awareness of pedestrians whilst the proposed one-way arrangement will reduce mean that need for reversing within the site (which can occur at present) is negated. The delivery arrangement seeks to improve the safety and efficiency of servicing and deliveries within the site and as per the existing situation, all servicing (including deliveries and refuse collection) will be undertaken within the site i.e., not on the public highway. This approach is welcomed. The majority of delivery vehicles will make use of a one-way servicing route going from the eastern crossover to the western crossover on Cranmer Road. Any other delivery vehicles will enter and egress the site on Brixton Road, or enter on Cranmer Road and egress on Camberwell New Road in forward gear. It is welcomed that a ‘Goods-In Manager’ will be appointed to ensure that vehicles load and unload in line with the proposed delivery arrangements. Consolidation of freight should be considered to reduce the number of vehicular trips generated by delivery and servicing and a final Delivery and Service Plan would be secured by condition in any permission granted.

7.8.33 No objection has been raised by Veolia Waste to the proposal and the intended refuse store arrangements, with three refuse collection points, marked (a), (b) and (c), being provided on site are considered to be acceptable. The Council has published and adopted a guide on the design of refuse and recycling storage and the final waste and recycling arrangement should comply with the council’s “Waste & Recycling Storage & Collection Requirements – Technical Specification for Architects & Developers” (October 2013) supported by Policy Q12 of the LLP and DRLLP. Conditions relating to final waste and recycling storage and a Waste Management Strategy would be secured by condition in any permission granted.

Healthy Streets

7.8.34 The Healthy Streets Approach seeks to inform design, management and use of public spaces in order to place people and people’s health at the forefront of development decisions. The following assessment is based on the document ‘Guide to the Healthy Streets Indicators – Delivering the Healthy Streets Approach, November 2017’.

7.8.35 The approach is set out within the Mayor’s Transport Strategy (2018) and puts human health and experience at the centre of planning. The aims of the strategy are to encourage all Londoners to do at least 20 minutes of active travel each day by 2041. To this end, TfL have defined 20-minute walking and cycling distances as an Active Travel Zone (ATZ).

7.8.36 Pedestrians are well provided for near to the site with footways along both sides of all roads. Pedestrian specific way-finding signage is present and offers directions to local public transport services and sites of interest. The nearest controlled crossing point (Pelican crossing) is located on the Site frontage to Brixton Road. This crossing is two-stage with dropped kerbs, tactile paving and rotating cones for visually impaired pedestrians, offering a route to Oval Station.

7.8.37 The proposed re-development will see an increase in pedestrian and cycle trips to/ from the site and the local area. Whilst the redevelopment includes the removal of 189 existing car parking spaces on site and the provision of improved public realm and cycle parking, no improvements are proposed beyond the site. TfL are currently developing two Road Safety schemes within close proximity of the site and would seek a contribution towards these schemes. A contribution of £15,000 towards developing a road safety scheme at the junction between Camberwell New Road and Foxley Road to improve cycling and pedestrian safety has been requested by TfL and GLA in their Stage 1 response. Such a contribution would be secured by s106 legal agreement.

Construction

7.8.38 Policy T8 of the LLP and DRLLP requires planning applications to be accompanied by a construction and logistics plan, demonstrating arrangements for construction traffic and how environmental, traffic and amenity impacts would be minimised.

7.8.39 An outline Construction Management and Logistics Plan (CMLP) has been provided which outlines that vehicles associated with the construction will enter the site via the western crossover on Cranmer Road and either exit through the eastern crossover on Cranmer Road or Camberwell New Road in forward gear. A delivery management system will be used to schedule deliveries and that an early doors agreement will be put in place to have construction vehicles arrive on site before morning peak hours which is welcomed. However, the CMLP should also include measures on how construction vehicles will avoid afternoon peak hours between 16:00 and 18:30.

7.8.40 Final Delivery and Servicing Management Plan and Construction and Environmental Management Plan would be secured by way of conditions and both should focus on pedestrian and cycle safety and the free movement of all road users along the four key adjoining roads - throughout future associated construction works – and minimising impacts on air quality, for example by requiring use of FORS silver-registered haulage contractors, using HGVs with 2-star or greater Direct Vision Standard (DVS) and maximising deliveries by bike and electric vehicles. To mitigate the impacts of numerous construction works in the area, the applicant should seek to co-ordinate works with other sites by consolidating deliveries, where possible.

Travel Plan

7.8.41 A draft Employee Travel Plan (TP) has been submitted with the application, which sets out targets for increasing cycling and walking to and from the site. The measures included within the TP should be appropriate to deliver the Mayor’s strategic mode shift target. A final Travel Plan would be secured by condition and subsequent monitoring by s106 legal agreement in any planning permission granted.

Mitigation

7.8.42 The following mitigation measures will be delivered as part of the development:

• Construction, Environmental Management Plan; • Delivery and Service Management Plan; • Travel Plan and monitoring • Car Park Management plan; • Enter into s278 agreement for highways works and improvements within the vicinity of the site; • Travel plan and monitoring fee of £5,000; • Parking permit free development for employees; • Securing of blue badge car parking spaces; • Healthy Route Network contribution of £15,000 towards developing a road safety scheme at the junction between Camberwell New Road and Foxley Road to improve cycling and pedestrian safety; • Bus Capacity Enhancements contribution of £450,000 (£90,000 per annum for up to five years); • Cycle Hire docking station contribution of £50,000 to expand the existing station on Cranmer Road; • 3yrs free cycle hire membership for employees of the business units; • Provision of 1 Car club bay on-street within the vicinity of the site (£10,000);

7.8.43 No objection has been raised by the Council’s Transport and Highways Sections to the proposals. Subject to the above mitigation measures, the proposals would be in accordance with Policies T1, T2, T3, T4, T5 and T6 of the London Plan and Policies T3, T6, T7 and T8 of the LLP and Policies T3, T7 and T8 of the DRLLP.

7.9 Sustainable design and construction

7.9.1 Policy SI 2 of the London Plan states that development proposals should be net zero-carbon. Policy EN3 of the LLP and DRLLP further require development to utilise decentralized heating, cooling or power networks in the vicinity of the site, or future proof for planned energy networks.

7.9.2 Policy SI2 of the London Plan introduces a requirement to calculate the whole life-cycle emissions of the development through a nationally recognised Whole Life-Cycle Carbon Assessment. Whole Life- Cycle carbon assessment includes not only the regulated emissions considered under current energy assessments but also the following:

• Unregulated emissions, i.e., those associated with cooking and small appliances • Embodied emissions, i.e., those associated with raw material extraction, • manufacture and transport of building materials and construction • Emissions associated with maintenance, repair and replacement as well as dismantling, demolition and eventual material disposal

7.9.3 The Mayor intends to publish guidance on the approach to whole life-cycle carbon emissions assessments, including when they should take place, what they should contain and how information should be reported. The application pre-dated this policy requirement so a whole life-cycle assessment has not been undertaken and the GLA has not requested this in this case.

7.9.4 At the time of submission of the application (November 2019), the application was not required to be supported by a Circular Economy Statement or a Life Cycle Carbon Analysis, which is only now a requirement under the recently adopted New London Plan. As stated within the Whole Lifecycle Carbon Assessment Draft Guidance (October 2020), these reports are required at pre-application stage, as the proposal was designed and submitted a year prior to this guidance, these reports were not required to accompany the pre-application discussions or the application submission. These reports were also not required by the GLA at Stage one and the GLA have now confirmed acceptability of the energy strategy.

7.9.5 However, the application was supported by a sustainability statement which details how sustainability has been a key part of the design of the scheme. As part of the Sustainability Statement and BREEAM pre-assessment, a Circular Economy Strategy and Life Cycle Assessment were undertaken in order to meet the relevant BREEAM credits. Page 11 of the attached details how the scheme was designed to reduce the embodied carbon of the design, implementing the best performing superstructure and substructures and landscaping materials. This has resulted in the scheme achieving an ‘Excellent’ BREAAM rating (77.5%).

7.9.6 In accordance with Policy SI2 of the London Plan, the applicant has submitted an Energy Statement which is compliant with the London Plan and Energy Assessment Guidance (2018) energy Hierarchy. Based on the Energy Strategy, the proposal would achieve a 37% site wide reduction in CO2 emissions compared to Building Regulations Part L on the non-domestic element. This would be achieved through the use of renewable energy technology in the form of Water Source Heat Pumps and photovoltaic panels alongside a range of energy efficiency and demand reduction measures. This overall strategy is supported by both the Council and GLA.

7.9.7 Whilst the site is not within an area currently served by a District Heat Network (DHN), the scheme should be designed to facilitate connection of the buildings to a future DHN. The remaining shortfall in reductions in CO2 emissions on the residential element should be secured via a carbon offset payment to be secured by s106 legal agreement.

7.9.8 The sustainability statement shows a 25% reduction in water consumption will be achieved over baseline water consumption. This exceeds the London Plan requirement of 12.5%. Details of the proposed capacities and flowrates have been provided. This would be secured by condition in any permission granted.

7.10 Other Environmental Matters

Flood risk and drainage

7.10.1 Policies SI.12 and SI.13 of the London Plan and Policy EN5 of the LLP and DRLLP expect development in Flood Zones 2, 3a and 3b to contribute positively to reducing the flood risk. In accordance with Policy EN5, a Flood Risk Assessment (FRA) and Sustainable Urban Drainage Strategy (SUDS), prepared by GTA, accompanies the application.

7.10.2 The north-east of the site is in tidal Flood Zone 3 but benefits from existing flood defences and is considered by the Environment Agency to have an extremely low residual risk. The FRA concludes that the proposed office buildings do not change the existing vulnerability classification which remains Less Vulnerable, and no further mitigation is necessary.

7.10.3 The drainage strategy for the site preserves the existing site catchments and outfalls to the public sewer, attenuation storage will be provided in the form of underground tanks, permeable paving and surface ponding in extreme events. The FRA and SUDS states that a betterment of 67% has been achieved compared to the existing scenario.

7.11 The FRA provided complies with Policy SI.12 of the London Plan and Policy EN5 of the LLP and DRLLP. In their Stage 1 response, the GLA advised that the proposed development did not fully comply with Policy SI.13 of the London Plan, as it did not give appropriate regard to the drainage hierarchy and greenfield runoff rate. Further details on how Suds measures at the top of the drainage hierarchy will be included in the development and an updated greenfield runoff calculation have now been provided and will be considered further by the GLA at the Stage 2 stage.

7.12 The development generally meets the requirements of London Plan. The GLA, in their Stage 1 response, also requested that the applicant consider water harvesting and reuse to reduce consumption of wholesome water across the entire development site. This information has now been provided and can be integrated with the surface water drainage system to provide a dual benefit.

7.13 Overall, taking into account the site circumstances and constraint and subject to the further information provided being agreed by the GLA, the proposal would comply with the drainage hierarchy and would be in accordance with London Plan, LLP and DRLLP policies.

Air quality

7.14 The site falls within an Air Quality Management Area in relation to a breach of nitrogen dioxide and particulate matters objectives as specified in the Air Quality Regulations 2000. Policy SI 1 of the London Plan and Policy T1 of the LLP and DRLLP require development to support measures that reduce levels of local air pollution and improve air quality.

7.15 An Air Quality Assessment, prepared by Waterman, has been submitted with the application which provides an assessment of the air quality impacts associated with the proposal. The scheme is predicted to have a net reduction in car traffic flows on the highway due to the removal of all general car parking across the site. The effect of operational traffic is predicted to be not significant on local air quality at relevant receptors. The development is considered to include measures which will benefit local air quality, including the cycle parking provision, limiting car access and car parking.

7.16 The Air Quality Assessment states that based on the detailed dispersion modelling the effect of the development will have no significant effects at all existing sensitive receptors considered. The main likely effects on air quality during construction relates to dust however a range of mitigation measures would be implemented to reduce the effects from dust emission to be not significant.

7.17 During the construction works, a range of best practice mitigation measures would be implemented to reduce dust emissions and the overall effect would be ‘not significant’; appropriate measures have been set out in the report and these would be included in the final Air Quality and Dust Management Plan for the works that would be secured by condition.

7.18 Overall, the construction and operational air quality effects of the proposal are judged to be ‘not significant’. The proposal has also been shown to meet the London Plan’s requirement that new developments are at least ‘air quality neutral’.

7.19 No objection has been raised by the Council’s Sustainability Section to the proposals. A condition would therefore be attached to any permission granted requiring the implementation of appropriate mitigation measures to ensure the proposal is air quality neutral. The residual effects of the proposed development are considered to be negligible for NO2 and particulate matter and the overall effect of the proposed development on local air quality is not considered to be significant.

7.20 Policy T8 of the Local Plan requires planning applications to be accompanied by a construction and logistic plan, demonstrating arrangements for construction traffic and how environmental, traffic and amenity impacts would be minimised. An outline of the principles of a construction management plan are set out in the submitted documents.

7.21 A final management plan will be required setting out full details of the demolition and construction programme to fully protect the locality from the transport and environmental impacts of construction. These further details would be secured by condition. A condition is also recommended to ensure any Non-Road Mobile Machinery (NRMM) used during construction and demolition in order to minimise detrimental impact on air quality.

Ground conditions and contamination

7.22 Whilst the LLP and DRLLP do not contain specific policies on land contamination, the supporting text to Policy EN4 notes that a remediation strategy should be submitted prior to commencement of development in instances where contamination exists. No objection has been raised by either the Council’s Building Control or Environmental Health Section to the proposal.

7.23 A Land Contamination Assessment, prepared by Furnis Group, has been undertaken for the site to

inform the proposal. The Assessment finds that there are potential sources of contamination on site. It is recommended by the assessment that a Phase II Intrusive investigation should be undertaken and that a pre-demolition and refurbishment asbestos survey will be required. This was would be secured by condition in any permission granted.

Archaeology

7.24 Part of the site, the frontage to Brixton Road, is located within an Archaeological Priority Area. Policy Q23 of the LLP and DRLLP require the investigation and recording of archaeological remains and publication of results to assist understanding. In accordance with the priorities of this policy, the application is supported by an Archaeological Assessment, prepared by MOLA. The report concludes that there is uncertain but probably low potential for remains of prehistoric, Roman, medieval or early post-medieval date on this site.

7.25 Subject to a pre-commencement condition requiring the submission and approval of a written scheme of investigation being attached to any permission granted, the proposal is considered to be in accordance with Policy Q23 of the LLP and DRLLP.

Employment and training

7.26 The completed development is estimated to support an additional 344-1351 jobs (calculated using the HCA Employment Density Guide).

7.27 The council seeks to maximise local employment opportunities and help address skills deficits in the local population. Accordingly, the s106 legal agreement would secure an Employment and Skills Plan (ESP) developed in accordance with the Employment and Skills SPD (Feb 2018) with the following key requirements:

• Reasonable endeavours to secure 25 per cent of jobs and training opportunities created by the development during construction and the first 2 years of end-use occupation for local residents; and • Engagement with local school and colleges to promote the skills and qualifications needed for employment in the commercial sectors of the end-use occupiers in place during the first two years of the development.

7.28 The Employment and Skills SPD also seeks a monetary contribution to help support those sections of the Lambeth workforce that are furthest from employment, having been out of work for a long period of time and/or having low levels of skills. The financial contributions will be used by the council to fund training and support to enable access to newly created employment opportunities arising from development. For this development the financial contribution would be based on the formula set out in the SPD. This would be secured by s106 legal agreement.

7.29 Subject to this agreement, the development would be compliant with Policy E11 of the London Plan and Policy ED4 of the LLP and DRLLP.

Planning obligations and CIL

7.30 Policy D4 of the Local Plan and Annex 10 sets out the Council’s policy in relation to seeking planning obligations and the charging approaches for various types of obligation. For contributions that are not covered by Annex 10, the Council’s approach to calculating contributions is guided by the Council’s Development Viability SPD (adopted 2017) and the Employment and Skills SPD (adopted 2018).

7.31 The planning obligations that are proposed are considered necessary to make the development acceptable in planning terms, are directly related to the development and are fairly and reasonably related in kind and in scale to the development. They are therefore compliant with the requirements of Regulation 122 of the Community Infrastructure Levy Regulations 2010.

7.32 The proposed obligations to be secured through the s106 agreement have now all been confirmed with the applicant and are as follows:

• Employment and training contribution (tbc); • Employment and skills plan; • Enter into s278 agreement for highways works and improvements within the vicinity of the site; • Travel plan and monitoring fee of £5,000; • Parking permit free development for employees; • Securing of blue badge car parking spaces; • Healthy Route Network contribution of £15,000 towards developing a road safety scheme at the junction between Camberwell New Road and Foxley Road to improve cycling and pedestrian safety; • Bus Capacity Enhancements contribution of £450,000 (£90,000 per annum for up to five years); • Cycle Hire docking station contribution of £50,000 to expand the existing station on Cranmer Road including free membership for business employees for 3 years; • Final Energy statement for future energy network connection, and identify value of any carbon off- setting contribution (estimated currently to be £484,500); • 3yrs free cycle hire membership for employees of the business units; • Provision of 1 Car club bay on-street within the vicinity of the site (£10,000); and • Administration and implementation fee (tbc)

7.33 If the application is approved and the development is implemented, a liability to pay the Mayoral and Lambeth Community Infrastructure Levies (CIL) will arise. On the basis of the information supplied with the applications, the Mayoral CIL is estimated to be £972,780. The Lambeth CIL contribution is estimated to be nil. Expenditure of the majority of a future CIL receipt will be applied towards Borough infrastructure needs in accordance with the applicable policies and procedures relating to expenditure decisions.

7.34 Allocation of CIL monies to particular infrastructure projects is not a matter for consideration in the determination of planning applications. Separate governance arrangements are being put in place for Borough Infrastructure needs.

8 CONCLUSION

8.1 The proposed development would provide new high-quality business/workspace buildings, providing a significant uplift and enhancement in employment floorspace on the site. The uplift is anticipated to provide an additional 344-1351 new jobs for the borough (calculated using the HCA Employment Density Guide).

8.2 The proposal would complement the existing flexible business use of the Kennington Park Business Centre and would fully reprovide the existing industrial floorspace on the site. The employment use proposed would permit a range of office, research and development and light industrial uses and provides flexible workspace suitable for occupation by a range of business sizes, which is welcomed. The design and layout of the proposal has been specifically tailored to be suitable for micro, small and medium sized creative enterprises engaged in light industrial manufacturing and design activities.

8.3 The group of buildings proposed are of an appropriate scale and height and have been carefully considered in terms of their architectural language. Overall, the design and appearance of proposed blocks are considered to be acceptable and will contribute positively to the streetscene and local context. The proposal would cause no harm to strategic, local views or heritage assets and would preserve and enhance the appearance of the character of the St Marks and Vassall Conservation Areas.

8.4 Given the distance and orientation to the nearest residential properties, and the inclusion of appropriate mitigation measures, the proposal would not result in any significant material impact in terms of overlooking, loss of privacy or sunlight/daylight or undue noise and disturbance to neighbouring residential properties.

8.5 The development would have a sustainable construction, meeting all of the relevant sustainability standards. It has been designed to significantly improve the environment and amenity across the site, in order to create a more welcoming, usable and biodiverse place of work, and would provide significant ecological, landscape and pedestrian/cycle enhancements.

8.6 As such, the proposal is considered to be acceptable when judged against national, London wide and local plan policy and guidance and all relevant material considerations and is recommended for approval.

9 PROCEDURAL MATTERS

9.1 The application is referable to the Mayor under the provisions of the Town and Country Planning (Mayor of London) Order 2008. The application has been referred to the Mayor at ‘Stage 1’. Before Lambeth can issue a decision on this application it will need to refer the application again to the Mayor at Stage 2; at which point the Mayor will have the opportunity to elect to become determining authority, direct refusal, or allow Lambeth to proceed and issue the decision in line with its resolution.

10 EQUALITY DUTY AND HUMAN RIGHTS

10.1 In line with the Public Sector Equality Duty the council must have due regard to the need to eliminate discrimination and advance equality of opportunity, as set out in section 149 of the Equality Act 2010. In making this recommendation, regard has been given to the Public Sector Equality Duty and the relevant protected characteristics (age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation).

10.2 In line with the Human Rights Act 1998, it is unlawful for a public authority to act in a way which is incompatible with a Convention right, as per the European Convention on Human Rights. The human rights impact has been considered, with particular reference to Article 1 of the First Protocol (Protection of property), Article 8 (Right to respect for private and family life) and Article 14 (Prohibition of discrimination) of the Convention.

10.3 The Human Rights Act 1998 does not impair the right of the state to make decisions and enforce laws as deemed necessary in the public interest. The recommendation is considered appropriate in upholding the council's adopted and emerging policies and is not outweighed by any engaged rights.

11 RECOMMENDATION

1 Resolve to grant conditional planning permission subject to the completion of an agreement under Section 106 of the Town and Country Planning Act 1990 (as amended) containing the planning obligations listed in this report and any direction as may be received following further referral to the Mayor of London.

2 Agree to delegate authority to the Director of Planning, Transport and Sustainability to:

2.1 Finalise the recommended conditions as set out in this report, addendums and/or PAC minutes; and 2.2 Negotiate, agree and finalise the planning obligations as set out in this report, addendums and/or PAC minutes pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended).

3 In the event that the committee resolves to refuse planning permission and there is a subsequent appeal, delegated authority is given to the Director of Planning, Transport and Sustainability, having regard to the heads of terms set out in this report, addendums and/or PAC minutes, to negotiate and complete a document containing obligations pursuant to Section 106 of the Town and Country Planning Act 1990 (as amended) in

order to meet the requirement of the Planning Inspector.

4 In the event that the Section 106 Agreement is not completed within 6 months of committee, delegated authority is given to the Director of Planning, Transport and Sustainability to refuse planning permission for failure to enter into a section 106 agreement for the matters identified in this report, addendums and/or the PAC minutes.

APPENDICES

Appendix 1: List of Conditions and Informatives

Standard Conditions

Time period 1. The development to which this permission relates must be begun no later than three years from the date of this decision notice.

Reason: To comply with the provisions of Section 91 of the Town and Country Planning Act 1990.

In accordance with approved plans 2. The development hereby permitted shall be carried out in complete accordance with the approved plans and drawings listed in this decision notice, other than where those details are altered pursuant to the conditions of this planning permission.

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

Pre-commencement Conditions

Drainage scheme 3. No development shall commence on site until the detailed design for the surface water drainage system and associated pipework referred to in the Flood Risk Assessment and Sustainable Urban Drainage Strategy, prepared by GTA, has been submitted to and approved in writing by the local planning authority. The approved for the surface water drainage scheme shall be carried out in accordance with the approved details before the development is first put into use/occupied and thereafter maintained for the lifetime of the development.

Reason: To ensure the development is provided with a satisfactory means of drainage and in the interests of securing a more sustainable development and to reduce the impact of flooding both to and from the development and third parties in accordance with Policy SI 13 of the London Plan (2021) and Policy EN6 of the Lambeth Local Plan (September 2015).

Contamination 4. Notwithstanding demolition and site clearance on site, no development shall take place until the following components of a scheme to deal with the risks associated with contamination of the site have been submitted to and approved in writing by the local planning authority:

(i) A site investigation scheme, based on previous findings to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site; (ii) The site investigation results and the detailed risk assessment resulting from (i); (iii) An options appraisal and remediation strategy giving full details of the remediation measures required and how they are to be undertaken; and (iv) A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in iii) are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action.

The development shall thereafter be implemented in accordance with the details and measures approved.

Reason: For the protection of controlled waters and the site is located over a Secondary Aquifer and it is understood that the site may be affected by historic contamination. (Policy EN4 of the Lambeth Local Plan 2015).

Basement Construction Method statement 5. Notwithstanding demolition and site clearance on site, no development shall commence until full details of the proposed basement construction methodology, in the form of a Construction Method Statement, is submitted to and approved in writing by the local planning authority. The Construction Method Statement shall be written by a suitably qualified person and shall include details of:

a) The basement excavation methods of demolition and construction; b) Measures to prevent mud and debris on the public highway; c) Details of the phasing of construction; d) Details of other measures including movement monitoring and reporting for nearby premises or structures that may be affected by the excavation and e) Measures to ensure ground stability and avoid adverse impacts on nearby premises or structures

The development shall thereafter be implemented in accordance with the details and measures approved.

Reason: Development must not commence before this condition is discharged to avoid hazard and obstruction being caused to users of the public highway and to ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and of the area generally and avoid hazard and obstruction to the public highway. (Policies T1, T6, T7, Q2 of the Lambeth Local Plan (2015)).

Piling Method Statement 6. No impact piling or other penetrative foundation work shall take place until a Piling Method Statement has been submitted to and approved in writing by the Local Planning Authority. The Piling Method Statement shall include details of: a) The depth and type of piling to be undertaken; b) The methodology by which such piling will be carried out; c) Measures to prevent and minimise the potential for damage to subsurface water infrastructure; d) Measures to ensure there is no resultant unacceptable risk to groundwater as a result of the work; and e) The programme for the works.

Any piling or other penetrative works must be undertaken in accordance with the terms of the approved Piling Method Statement, unless the written consent of the Local Planning Authority is received for any variation.

Reason: To ensure that any piling works would not unduly impact upon the local underground sewerage utility infrastructure and in order to avoid adverse environmental impact upon the community. (Policies EN5 and EN6 of Lambeth Local Plan 2015).

Construction and Environmental Management Plan 7. No development shall commence until a Construction and Environmental Management Plan (CEMP), including the method of demolition, has been submitted to and approved in writing by the local planning authority.

The CEMP shall include details of the following relevant measures:

(i) An introduction consisting of construction phase environmental management plan, definitions and abbreviations and project description and location; (ii) A description of management responsibilities. (iii) A description of the construction programme which identifies activities likely to cause high levels of noise or dust; (iv) Site working hours and a named person for residents to contact; (v) Detailed Site construction logistics arrangements;

(vi) Details regarding parking, deliveries, and storage; (vii) Details of an air quality and dust management plan; (viii) Details regarding dust and noise mitigation measures to be deployed including identification of sensitive receptors and ongoing monitoring; (ix) Details of the hours of works and other measures to mitigate the impact of construction on the amenity of the area and safety of the highway network; (x) Measures to prevent the deposit of mud and debris on the public highway; and (xi) Communication procedures with the LBL and local community regarding key construction issues.

The development shall thereafter be carried out in accordance with the details and measures approved in the CEMP for the duration of the construction period, unless the written consent of the local planning authority is received for any variation.

Reason: This is required prior to demolition and construction to avoid hazard and obstruction being caused to users of the public highway and to safeguard residential amenity during the whole of the construction period (Policies T6 and Q2 of the Lambeth Local Plan (2015)).

Air Quality and Dust Management Plan 8. No demolition or development shall commence until full details of the proposed mitigation measures for impact on air quality and dust emissions, in the form of an Air Quality and Dust Management Plan (AQDMP), have been submitted to and approved in writing by the local planning authority. In preparing the AQMDP the applicant should follow the guidance on mitigation measures for medium Risk sites set out in Appendix 7 of the Control of Dust and Emissions during Construction and Demolition SPG 2014 for demolition, earthworks and construction and high risk for track out. Both ‘highly recommended’ and ‘desirable’ measures should be included. The AQDMP shall include the following for each relevant phase of work (demolition, earthworks, construction and track out):

a) A summary of work to be carried out; b) Proposed haul routes, location of site equipment including supply of water for damping down, source of water, drainage and enclosed areas to prevent contaminated water leaving the site; c) Inventory and timetable of all dust and NOx air pollutant generating activities; d) List of all dust and emission control methods to be employed and how they relate to the Air Quality (Dust) Risk Assessment; e) Details of any fuel stored on-site; f) Details of a trained and responsible person on-site for air quality (with knowledge of pollution monitoring and control methods, and vehicle emissions); g) Summary of monitoring protocols and agreed procedure of notification to the local authority; and h) A log book for action taken in response to incidents or dust-causing episodes and the mitigation measure taken to remedy any harm caused, and measures employed to prevent a similar incident reoccurring.

Automatic continuous PM10 monitoring should be carried out on site. Baseline monitoring should commence at least three months before the commencement of the demolition phase and continue throughout all construction phases. Monitors should be used at locations in use by sensitive receptors and construction traffic for the duration of the development. Details of the equipment to be used and its exact positioning should be submitted to the Council as part of the Air Quality Dust Management Plan and approved prior to use. Data should be available for download by the local authority on request. An annual summary report of continuous monitoring data should be provided to the council for the duration of the development.

No demolition or development shall commence until all necessary pre-commencement measures described in the AQDMP have been put in place and set out on site. The demolition and development shall thereafter be carried out and monitored in accordance with the details and measures approved in the AQDMP.

Reason: Development must not commence before this condition is discharged to manage and mitigate the impact of the development on the air quality and dust emissions in the area and London as a whole, and to avoid irreversible and unacceptable damage to the environment (Policy SI 1 of the London Plan (2021) and the London Plan SPGs for Sustainable Design and Construction and Control of Dust and Emissions during Construction and Demolition).

Air Quality Neutral Assessment 8. No development shall commence until a full Air Quality Neutral Assessment in accordance with the GLA Sustainable Design and Construction Supplementary Planning Guidance has been undertaken and submitted to and approved in writing by the local planning authority. Where Air Quality Neutral benchmarks cannot be met a scheme of mitigation must be submitted which includes on site mitigation that is part of the proposed development and may also include off-site offsetting. The details as approved shall be implemented prior to occupation of the development and thereafter be permanently retained.

Reasons: To minimise increased exposure to existing poor air quality and make provision to address local problems of air quality (particularly within AQMAs) (Policy SI 1 of the London Plan 2021).

Internal water use 9. Prior to the commencement of the development, details shall be submitted to and approved in writing by the Local Planning Authority to demonstrate that the internal water consumption will achieve the 12.5% improvement over the baseline performance standard, achieving the BREEAM Excellent standard for the Wat 01 category and to demonstrate that the development has incorporated measures such as smart metering, water saving and recycling measures, including retrofitting, to help to achieve lower water consumption rates and to maximise future-proofing through the provision of post- construction BREEAM evidence used to sign off credits Wat 02 and Wat 03.

Reason: To ensure the development would achieve an acceptable standard of water efficiency (Policy SI 1 of the London Plan (2021)).

NRMM Low Emission Zone 10. No demolition or development shall commence until all non-road mobile machinery (NRMM) to be used on site has been registered at ‘https://nrmm.london/user-nrmm/register’ and that all registered NRMM is compliant with the NRMM Low Emission Zone requirements.

Reason: To ensure that air quality is not adversely affected by the development Reason: To ensure that air quality is not adversely affected by the development in line with Policy SI 1 of the London Plan (2021) and the Mayor’s SPG: The Control of Dust and Emissions during Construction and Demolition.

Method of demolition and construction statement 11. No demolition or construction shall commence until full details of the proposed demolition and construction methodology, in the form of a Method of Demolition and Construction Statement, has been submitted to and approved in writing by the Local Planning Authority. The Method of Demolition and Construction Statement shall include details of:

a) The notification of neighbours with regard to specific works; b) Advance notification of road closures; c) Details regarding parking, deliveries, and storage; d) Details regarding dust mitigation; e) Details of measures to prevent the deposit of mud and debris on the public highway; f) Details of a temporary lighting strategy, including details of temporary lighting of all public areas and buildings showing acceptable positioning and levels of glare; g) Details of the hours of works and other measures to mitigate the impact of demolition and construction

on the amenity of the area. The hours of deliveries associated with demolition and construction activity should work around the core school hours at nearby schools; h) Any measures to mitigate the impact of demolition and construction upon the function and safety of the surrounding area for cyclists; and i) Any other measures to mitigate the impact of demolition and construction upon the amenity of the area and the function and safety of the highway network.

No demolition or development shall commence until provision has been made to accommodate all site operatives', visitors' and construction vehicles loading, off-loading, parking and turning within the site or otherwise during the construction period in accordance with the approved details. The demolition and development shall thereafter be carried out in accordance with the details and measures approved in the Method of Construction Statement.

Reason: This is required prior to demolition and construction to avoid hazard and obstruction being caused to users of the public highway and to safeguard residential amenity during the whole of the demolition and construction period. (Policies T6 and Q2 of the Lambeth Local Plan 2015).

Flues and extraction plant 12. The uses hereby permitted shall not commence until details and full specifications of flues extraction and filtration equipment, and ongoing maintenance plan (including elevational drawings) have been submitted to and approved in writing by the local planning authority. The use hereby permitted shall not commence until the approved details are fully implemented. The approved flues, extraction and filtration equipment shall thereafter be retained and maintained in working order for the duration of the use in accordance with the approved details. Reason: To protect the amenities of adjoining occupiers and the surrounding area (Policy Q2 of the London Borough of Lambeth Local Plan (2015)).

Land contamination and drainage maintenance

Land Contamination 13. Prior to the occupation of any part of the development, a verification report demonstrating completion of the works set out in the approved remediation strategy and the effectiveness of the remediation shall be submitted to and approved in writing by the local planning authority.

The report shall include results of sampling and monitoring carried out in accordance with the approved verification plan to demonstrate that the site remediation criteria have been met. It shall also include any plan (a “long-term monitoring and maintenance plan”) for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action, as identified in the verification plan, and for the reporting of this to the local planning authority.

If, during development, contamination not previously identified is found to be present at the site then no further development shall be carried out until the developer has submitted and obtained written approval from the local planning authority for, an amendment to the remediation strategy detailing how this unsuspected contamination will be dealt with.

Reasons: Development must not commence before relevant parts of this condition are discharged to safeguard future users or occupiers of this site and the wider environment from irreversible risks associated with the contaminants which are present by ensuring that the contaminated land is properly treated and made safe before development. (Policies 5.21 of the London Plan (2015) and EN4 of the Lambeth Local Plan (2015)).

Drainage, Infrastructure, Management and Maintenance 14. No part of the development shall be brought into use/occupied until a Drainage Infrastructure Management and Maintenance Plan including the foul and surface water management system and associated pipework has been submitted to and approved in writing by the local planning authority.

The plan must consider the management and maintenance for the lifetime of the development which shall include the arrangements made to secure the operation of the scheme. The approved plan shall be implemented in full in accordance with the agreed terms and conditions and thereafter retained as such for the lifetime of the development.

All provisions for drainage must be undertaken in accordance with the details approved, unless the written consent of the local planning authority is received for any variation.

Reason: To ensure the development is provided with a satisfactory means of drainage and in the interests of securing a more sustainable development and to reduce the impact of flooding both to and from the development and third parties in accordance with Policy SI 13 of the London Plan (2021) and Policy EN6 of the Lambeth Local Plan (2015) and to ensure there are clear arrangements in place for ongoing maintenance over the lifetime of the development (Government ministerial statement HCWS161).

Design Details

External Materials 15. Prior to the commencement of building works above ground of the development hereby permitted, the following details of the external elevations of the building shall be submitted to and approved in writing by the local planning authority:

a) A technical specification schedule of the materials; and b) Sample panels to be made available on site (or another convenient local location), at a scale of 1:1, for inspection showing ‘typical’ façade construction and illustrating the materials and their construction detailing.

The development shall be carried out in accordance with the approved details and thereafter retained as such for the lifetime of the development.

Reason: To ensure that the external appearance of the building is satisfactory and does not detract from the character and visual amenity of the area along with setting of the nearby conservation areas (Policies Q6, Q7, Q8, and Q22 of the Lambeth Local Plan 2015).

Fine Detailing 16. Notwithstanding the details shown on the drawings hereby approved, no development shall take place until drawings (at 1:10 scale [including sections] showing all external construction detailing), for the relevant part of the development have been submitted to and approved by the Local Planning Authority in writing, unless otherwise agreed in writing by the Local Planning Authority. The drawings shall include details of:

a) Detailed elevations b) Details of windows (including technical details, elevations, reveal depths, plans and cross sections) c) Details of terraces, balustrades and privacy screens d) Details of entrances and external doors (including technical details, elevations, reveal depths, plans and sections) e) Details of roof treatments, cills and parapets f) Details of rainwater goods and pipes (including location and fixings) g) Details and location of flues and vents h) Details of works to Chichester House i) Details of wayfinding and signage

The development shall be carried out in accordance with the approved details and retained for the lifetime of the development.

Reason: To ensure that the external appearance of the building is satisfactory and does not detract from the character and visual amenity of the area along with setting of the nearby conservation areas (Policies Q6, Q7, Q8, and Q22 of the Lambeth Local Plan 2015).

Re-instatement of Sandstone plaques 17. Prior to the commencement of building works above ground of the development hereby permitted, details of the of the reinstatement of the original sandstone plaques on Worcester House shall be submitted to and approved in writing by the local planning authority:

The development shall be carried out in accordance with the approved details and retained for the lifetime of the development.

Reason: To ensure that the external appearance of the building is satisfactory and does not detract from the character and visual amenity of the area along with setting of the nearby conservation areas (Policies Q6, Q7, Q8, and Q22 of the Lambeth Local Plan 2015).

Plumbing 18. No vents, plumbing or pipes, other than those approved, shall be fixed to the external faces of the building.

Reason: To ensure an appropriate standard of design (Policies Q6 and Q8 of the Lambeth Local Plan 2015).

Amenity

Noise and Vibration attenuation of ventilation plant 18. Prior to the occupation of the uses hereby permitted, or the operation of any building services plant, an assessment of the acoustic impact arising from the operation of all internally and externally located plant shall be submitted to and approved in writing by the local planning authority.

The assessment of the acoustic impact shall be undertaken in accordance with BS 4142: 2014 (or subsequent superseding equivalent) and current best practice and shall include a scheme of attenuation measures to ensure the rating level of noise emitted from the proposed building services plant is 10dB less than background.

The uses hereby permitted, or the operation of any building services plant, shall not commence until a post-installation noise assessment has been carried out to confirm compliance with the noise criteria. The scheme of attenuation shall be implemented in accordance with the approved details and attenuation measures, and they shall be permanently retained and maintained in working order for the duration of the use and their operation.

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

Site Maintenance and Management

Fire Statement 20. Prior to the commencement of above ground works, a Fire Statement shall be submitted to and approved in writing by the local planning authority. The Fire Statement shall be produced by a suitably competent and qualified person which shall detail the building’s construction, methods, products and materials used; the means of escape for all building users including those who are disabled or require level access together with the associated management plan; access for fire service personnel and equipment; ongoing maintenance and monitoring and how provision will be made within the site to enable fire appliances to gain access to the building. The development shall be carried out in

accordance with the approved details, and to the satisfaction of current Building Regulations and the measures and means shall thereafter be retained for the lifetime of the building hereby approved.

Reason: In order to provide a safe and secure development in accordance with Policy D12 of the London Plan (2021).

Operating hours. 21. Customers are not permitted in the retail, restaurant and café and community and leisure uses hereby permitted other than within the following times:

- 08:00 Hours to 23:00 Hours – Monday through to Thursday. - 08:00 Hours to 00:00 Hours – Fridays and Saturdays. - 10:00 Hours to 23:00 hours – Sundays, Bank or Public holidays.

Reason: To ensure that no nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers or of the area generally.

Maintenance of flues and extraction plant 22. The restaurant/café uses hereby permitted shall not commence until details of an ongoing maintenance plan for the fume extraction and filtration equipment have been submitted to and approved in writing by the local planning authority. The approved fume extraction and filtration equipment shall thereafter be retained and maintained in working order for the duration of the use in accordance with the approved details.

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

Customer Management Plan 23. The restaurant/café uses hereby permitted shall not commence until a Customer Management Plan has been submitted to and approved in writing for each use by the local planning authority. This should include but not be limited to, hours of operation, management responsibilities during all operating hours, measures to control noise from live and amplified music (including the screening of sporting events and public address systems) and minimising the effects of patrons coming and going from site and demonstrating how customers leaving the building will be prevented from causing nuisance for people in the area. The uses hereby permitted shall thereafter be operated in accordance with the approved details for the lifetime of the development.

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

Waste and recycling storage 24. Prior to the occupation of the uses hereby permitted, details of waste and recycling storage (including detail on ventilation of refuse stores) for the development shall be submitted to and approved in writing by the local planning authority. The waste and recycling storage shall be provided in accordance with the approved details prior to the commencement of any of the uses hereby permitted and shall thereafter be retained solely for its designated use. The waste and recycling storage areas/facilities should comply with the Lambeth's Refuse & Recycling Storage Design Guide (2013), unless it is demonstrated in the submissions that such provision is inappropriate for this specific development.

Reason: To ensure suitable provision for the occupiers of the development, to encourage the sustainable management of waste and to safeguard the visual amenities of the area (Policies Q2 and Q12 of the London Borough of Lambeth Local Plan (2015)).

Waste Management Strategy 25. Prior to the occupation of the uses hereby permitted, a Waste Management Strategy shall be submitted to and approved in writing by the local planning authority. The development hereby permitted shall be built in accordance with the approved details and shall thereafter be retained solely for its designated use. The uses hereby permitted shall thereafter be operated in accordance with the approved Waste Management Strategy.

Reason: To ensure suitable provision for the occupiers of the development, to encourage the sustainable management of waste and to safeguard the visual amenities of the area (Policies Q2 and Q12 of the London Borough of Lambeth Local Plan (2015)).

Provide Disabled parking spaces 26. Prior to the commencement of the use hereby permitted, the parking spaces shall be laid out in accordance with the approved plans, and the disabled/accessible parking spaces shall be retained for the duration of the use. No vehicles, other than blue-badge holder vehicles and operational vehicles for the users of the site, shall park on the site. Vehicles shall only park within the designated spaces shown on the approved plans, and on no other part of the site.

Reason: To enable accessible parking to be provided, prevent excessive parking and minimise danger, obstruction and inconvenience to users of the site and surrounding area (policies T1, T6, T7, T8 and Q2 of the London Borough of Lambeth Local Plan (2015)).

Cycle Storage 27. Prior to the occupation of the development hereby permitted, details of the provision to be made for 414 cycle parking spaces on the site shall be submitted to and approved in writing by the Local Planning Authority. The cycle parking shall thereafter be implemented in full in accordance with the approved details before the uses hereby permitted commence and shall thereafter be retained solely for its designated use for the lifetime of the development.

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

Delivery and Servicing Management Plan 28. The uses hereby permitted shall not commence until a Delivery and Servicing Management Plan, including details of freight consolidation and confirming that all servicing will be undertaken off-street within the service yard, has been submitted and approved in writing by the local planning authority. The use hereby permitted shall thereafter be operated in accordance with the approved details for the lifetime of the development. The submitted details must include the following:

a) Frequency and timings of deliveries to the site; b) Frequency and timings of other servicing vehicles, such as refuse collections; c) Dimensions of delivery and servicing vehicles; d) Proposed loading and delivery locations; and e) A strategy to manage vehicles servicing the site.

Reason: To protect the amenities of adjoining occupiers and the surrounding area (Policy Q2 of the London Borough of Lambeth Local Plan (2015) and to limit the effects of the increase in travel movements (Policy T8 of the Lambeth Local Plan (2015)).

Car Parking Management Plan 29. Prior to the occupation of the development hereby approved, a Car Park Management Plan shall be submitted to and approved in writing by the local planning authority. The Plan submitted shall include details of car parking allocation for residential and commercial occupants. The development shall be carried out in accordance with the approved details.

Reason: To ensure suitable provision for the occupiers of the development and to safeguard the visual amenities of the area (policies Q2 and Q12 of the London Borough of Lambeth Local Plan (2015)).

Landscaping scheme 30. Prior to the occupation of any part of the development hereby permitted, a soft and hard landscaping scheme and ecological enhancement strategy shall be submitted to and approved in writing by the local planning authority. The specifications shall include details of the quantity, size, species, position and the proposed time of planting of all elements of the landscape design (together with details of their anticipated routine maintenance and protection) to demonstrate that the Urban Greening Factor of 0.3 has been achieved.

The development shall thereafter be carried out in accordance with the approved timetable. All tree, shrub and hedge planting included within the above specification shall accord with BS3936:1992, BS4043:1989 and BS4428:1989 (or subsequent superseding equivalent) and current Arboricultural best practice.

Reason: In order to introduce high quality soft landscaping in and around the site in the interests of the ecological value of the site and to ensure a satisfactory landscaping of the site in the interests of visual amenity (Policy Q9 of the Lambeth Local Plan (2015)).

Green roofs 31. Prior to the occupation of any part of the development hereby permitted, a detailed specification of the green roofs shall be submitted to and approved in writing by the local planning authority. The specification shall include details of the quantity, size, species, position and the proposed time of planting of all elements of the green roof, together with details of their anticipated routine maintenance and protection. The green roofs shall only be installed and thereafter maintained in accordance with the approved details for the lifetime of the development.

Reason: In order to introduce high quality soft landscaping in and around the site in the interests of the ecological value of the site and to ensure a satisfactory landscaping of the site in the interests of visual amenity (Policies EN4 and Q9 of the Lambeth Local Plan (2015) and Policy G1 of the London Plan (2021).

Landscaping Scheme and Ecological Enhancements Strategy implementation 32. Within six months of first occupation of any part of the development, evidence to demonstrate that the net biodiversity gains (secured under the Ecological Enhancements details approved as part of the discharge of Condition 30) have been achieved shall be submitted to and approved in writing by the local planning authority. In the event that these gains have not been achieved, a scheme of mitigation to achieve the shortfall shall be submitted to and approved in writing by the local planning authority. The approved scheme shall be implemented within the first planting season following the scheme being approved and shall thereafter be retained for the lifetime of the development.

Reason: In the interests of the ecological value of the site and to ensure a satisfactory landscaping of the site in the interests of visual amenity (Policies EN4 and Q9 of the Lambeth Local Plan (2015) and Policy G1 of the London Plan (2021).

Landscaping Timescales 33. All planting, seeding or turfing comprised in the approved details of soft landscaping shall be carried out in the first planting and seeding season following the occupation of the development hereby permitted. Any trees, hedgerows or shrubs forming part of the approved landscaping scheme which within a period of five years from the occupation or substantial completion of the relevant phase die, are removed or become seriously damaged or diseased shall be replaced in the next planting season

with others of similar size and species, unless the local planning authority gives written consent to any variation.

Reason: In order to introduce high quality soft landscaping in and around the site in the interests of the ecological value of the site and to ensure a satisfactory landscaping of the site in the interests of visual amenity (Policies EN4 and Q9 of the Lambeth Local Plan (2015) and Policy G1 of the London Plan (2021).

Lighting Scheme 34. Prior to occupation a lighting scheme must be submitted for the approval of the Local Planning Authority in accordance with the Institute of Lighting Professional’s Guidance notes for the reduction of obstructive light. The scheme must be designed by a suitably qualified person in accordance with the recommendations for environmental zone E3 in the ILP document “Guidance Notes for the Reduction of Obtrusive Light GN01:2011.

Before commencement of operation of the approved lighting scheme the applicant shall appoint a suitably qualified member of the institute of lighting professionals (ILP) to validate that the lighting scheme as installed conforms to the recommendations for environmental zone E3 in the ILP document “Guidance Notes for the Reduction of Obtrusive Light GN01:2011.

The development should be implemented in accordance with the approved details and retained and properly maintained thereafter for the lifetime of the development.

Reason: To ensure minimal nuisance or disturbance is caused to the detriment of the amenities of adjoining occupiers and to ensure the external appearance of the building is satisfactory and does not detract from the setting of the nearby conservation areas (Policies Q2, Q6, Q7, Q8 and Q22 of the Lambeth Local Plan (2015)).

Sustainability and Energy

BREEAM – Post Construction Certificate 35. Within six months of first occupation of any part of the development, a BREEAM Post Construction certificate and summary score sheet should be submitted to and approved in writing by the Local Planning Authority demonstrating that a rating of ‘Excellent’ has been achieved for the development. The summary score sheets for the assessment should demonstrate that the actions proposed to reduce waste during construction and water during operation are undertaken in line with the approved Sustainability Statement.

Reason: To ensure that the development has an acceptable level of sustainability (Policy EN4 of the Lambeth Local Plan (2015)).

Photovoltaic panels 36. Prior to above ground construction works commencing, plans, elevations and sections of the roof(s) showing the location of the proposed photovoltaic array(s) should be submitted for approval to the Local Planning Authority. The photovoltaic array(s) shall be implemented in accordance with the approved details and retained and properly maintained permanently thereafter.

37. Reason: To safeguard the appearance of the completed development and to ensure that the development has an acceptable level of sustainability (Policies Q2, Q7, Q8 and EN4 of the Lambeth Local Plan (2015)).

Operational impacts 38. Prior to installation, the proposed energy centre should meet the emission standards set out in the GLA’s Sustainable Design and Construction Supplementary Planning Guidance 2014 (or any superseding requirements). Full details of the final proposed CHP plant and gas boiler system should

be submitted to the Council for approval. Details of the proposed CHP should be provided using Combined Heat and Power System information request form.

Reason: To ensure that air quality is not adversely affected by the development in line with Policy SI 3 of the London Plan and the Mayor’s SPG: Sustainable Design and Construction

Travel Plan 39. Prior to the uses hereby approved commencing, a Travel Plan relating to those uses shall be submitted to and approved in writing by the local planning authority. The measures approved in the Travel Plan to be implemented before occupation shall so be implemented prior to the use commencing and shall be so maintained for the duration of the use, unless the prior written approval of the Local Planning Authority is obtained to any variation.

Reason: To ensure that the travel arrangements to the site are appropriate and to limit the effects of the increase in travel movements (Policy T4 of the London Plan (2021) and Policies T1 and T6 of the Lambeth Local Plan (2015)).

Secure by Design Measures 40. The development hereby permitted shall incorporate security measures to minimise the risk of crime and to meet the specific Security needs of the development in accordance with the principles and objectives of Secured by Design. Details of these measures shall be submitted to and approved in writing by the local planning authority prior to commencement of the development and shall be implemented in accordance with the approved details prior to occupation.

Reason: To ensure that the development maintains and enhances community safety (policy Q3 of the London Borough of Lambeth Local Plan (2015)).

Secure by Design Certification 41. Prior to occupation, a satisfactory Secured by Design inspection must take place. The resulting Secured by Design certificate shall be submitted to and approved by the local planning authority.

Reason: To ensure that the development maintains and enhances community safety (policy Q3 of the London Borough of Lambeth Local Plan (2015)).

Employment and Commercial floorspace 42. No less than 5,408sqm sqm of Class E (g) (iii) and B8 light industrial / workspace floorspace shall be provided within the development. Prior to the occupation of the Class B1 use hereby permitted, full details of the internal layout of this floorspace, including which units will be provided for Class E (g) (iii) and B8 use, shall be submitted to and approved in writing by the local planning authority.

The development shall be carried out in accordance with the approved details.

Reason: to ensure an appropriate level of light industrial floorspace is re-provided on the site in accordance with Policy ED7 of the London Plan (2021).

Informatives

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

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

3. Your attention is drawn to the provisions of The Party Wall Act 1996 in relation to the rights of adjoining owners regarding party walls etc. These rights are a matter for civil enforcement, and you may wish to consult a surveyor or architect.

4. The property numbers of all ground floor units with external doors hereby approved shall be clearly and permanently displayed at their entrance.

5. You are advised of the necessity to consult the Council's Streetcare team within the Public Protection Division with regard to the provision of refuse storage and collection facilities.

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

7. You are advised that this permission does not authorise the display of illuminated advertisements at the premises and separate consent may be required from the Local Planning Authority under the Town and Country Planning (Control of Advertisements) Regulations 1992.

8. As soon as building work starts on the development, you must contact the Street Naming and Numbering Officer if you need to do the following:

- name a new street - name a new or existing building - apply new street numbers to a new or existing building

This will ensure that any changes are agreed with Lambeth Council before use, in accordance with the London Buildings Acts (Amendment) Act 1939 and the Local Government Act 1985. Although it is not essential, we also advise you to contact the Street Naming and Numbering Officer before applying new names or numbers to internal flats or units. Contact details are listed below. Street Naming and Numbering Officer e-mail: [email protected] tel: 020 7926 2283 fax: 020 7926 9104.

9. For information on the NRMM Low Emission Zone requirements please visit ‘http://nrmm.london/nrmm’

10. Temporary structures such as cranes can be notified through the means of a Notice to Airmen (NOTAM). If above a height of 300ft (91.4m) above ground level, the developer must ensure that the crane operator contacts the CAA's Airspace Regulation (AR) section on [email protected] or 02074536599.

For cranes below this height the developer must ensure that the crane operator contacts Low Flying Operations at RAF Wittering [email protected] / 01780 146 208. However, in this case that is not necessary as no military low flying routinely takes place in this location. If the crane is to be in place for in excess of 90 days, it should be considered a permanent structure and will need to be notified as such: to that end the developer should also contact the DGC (see above). Additionally, any crane of a height of 60m or more will need to be equipped with aviation warning lighting in line with CAA guidance concerning crane operations which is again available at http://publicapps.caa.co.uk/docs/33/CAP%201096%20In%20Focus%20-%20Crane%20Ops.pdf.

11. The latest Sustainable Design and Construction SPG can be found on the GLA’s website https://www.london.gov.uk/what-we-do/planning/implementing-london-plan/supplementary-planning- guidance. The Combined Heat and Power System information request from can be found in the air quality resource section of Lambeth Air Quality webpage www.lambeth.gov.uk/AirQuality

Appendix 2: List of Consultees (Statutory and Other Consultees)

Statutory

Environment Agency Greater London Authority Historic England - Archaeology London Ecology Unit London Fire Brigade London Transport Buses Thames Water Transport for London

Internal/Consultants

Blew Burton Design Out Crime Officer LBL Arboricultural Officer LBL Building Control LBL Conservation & Urban Design LBL EHST Noise Pollution LBL Enterprise, Employment and Skills LBL Flooding LBL Highways Team LBL Parks & Open Spaces LBL Planning Policy LBL Public Protection & Regulatory Services LBL Regeneration Team LBL Sustainability Team LBL Transport Veolia Waste Ward Councillors

Other

Kennington Oval and Vauxhall Forum Kennington Association Planning Forum London Borough of Southwark Met Office & Licensing Minet Conservation Association Stockwell Park Residents Association Vassall And Coldharbour Forum

Appendix 3: List of relevant policies in London Plan, Lambeth Local Plan. Reference to SPGs, SPD and other relevant guidance

London Plan (2021) policies:

• GG1 Building strong and inclusive communities • GG2 Making the best use of land • GG3 Creating a healthy city • GG6 Increasing efficiency and resilience • D1 London’s form, character and capacity for growth • D2 Infrastructure requirements for sustainable densities • D3 Optimising site capacity through the design-led approach • D4 Delivering good design • D5 Inclusive design • D8 Public realm • D11 Safety, security and resilience to emergency • D12 Fire safety • D14 Noise • E3 Affordable workspace • E4 Land for industry, logistics and services to support London’s economic function • E6 Locally Significant Industrial Sites • E7 Industrial intensification, co-location and substitution • E11 Skills and employment for all • HC1 Heritage conservation and growth • HC3 Strategic and Local Views • HC4 London View Management Framework • HC5 Supporting London’s culture and creative industries • G1 Green infrastructure • G5 Urban greening • G6 Biodiversity and access to nature • G7 Trees and woodlands • SI 1 Improving air quality • SI 2 Minimising greenhouse gas emissions • SI 3 Energy infrastructure • SI 4 Managing heat risk • SI 5 Water infrastructure • SI 6 Digital connectivity infrastructure • SI 7 Reducing waste and supporting the circular economy • SI 8 Waste capacity and net waste self-sufficiency • SI 12 Flood risk management • SI 13 Sustainable drainage • T1 Strategic approach to transport • T2 Healthy Streets • T3 Transport capacity, connectivity and safeguarding • T4 Assessing and mitigating transport impacts • T5 Cycling • T6 Car parking • T6.5 Non-residential disabled persons parking • T7 Deliveries, servicing and construction • T9 Funding transport infrastructure through planning • DF1 Delivery of the Plan and Planning Obligations

Regional Guidance

• Social Infrastructure (May 2015) • Accessible London: Achieving an Inclusive Environment (October 2014) • The control of dust and emissions during construction and demolition (July 2014) • Character and Context (June 2014) • Sustainable Design and Construction (April 2014) • Use of planning obligations in the funding of Crossrail, and the Mayoral Community Infrastructure Levy SPG (2013) • London View Management Framework (March 2012) • London Cycle Design Guide (2014)

Lambeth Local Plan (2015) policies

• D1 Delivery and monitoring • D2 Presumption in favour of sustainable development • D3 Infrastructure • D4 Planning obligations • ED1 Key Industrial and Business Areas (KIBAs) • ED2 Economic Development, Retail and Town Centre Uses • ED3 Large Offices (greater than 1,000m2) • ED7 Evening economy and food and drink uses • ED14 Employment and training • EN1 Open space and biodiversity • EN3 Decentralised energy • EN4 Sustainable design and construction • EN5 Flood risk • EN6 Sustainable drainage systems and water management • EN7 Sustainable waste management • Q1 Inclusive environments • Q2 Amenity • Q3 Community safety • Q5 Local distinctiveness • Q6 Urban design: public realm • Q7 Urban design: new development • Q8 Design quality: construction detailing • Q9 Landscaping • Q10 Trees • Q12 Refuse/recycling storage • Q13 Cycle storage • Q15 Boundary treatments • Q18 Historic environment strategy • Q20 Statutory listed buildings • Q21 Registered parks and gardens • Q22 Conservation areas • Q23 Undesignated heritage assets: local heritage list • Q25 Views • Q27 Basement development • PN8 Kennington/Oval • S1 safeguarding existing social infrastructure • T1 Sustainable travel • T2 Walking • T3 Cycling

• T4 Public transport infrastructure • T6 Assessing impacts of development on transport capacity • T7 Parking • T8 Servicing • T10 Digital connectivity infrastructure

Draft Revised Lambeth Local Plan Proposed Submission Version (January 2020)

• D1 Delivery and monitoring ▪ D2 Presumption in favour of sustainable development ▪ D3 Infrastructure ▪ D4 Planning obligations • ED1 Offices (B1a) ▪ ED2 Affordable workspace ▪ ED3 Key Industrial and Business Areas (KIBAs) ▪ ED8 Evening economy and food and drink uses ▪ ED15 Employment and training • EN1 Open space and biodiversity • EN3 Decentralised energy • EN4 Sustainable design and construction • EN5 Flood risk • EN6 Sustainable drainage systems and water management • EN7 Sustainable waste management • Q1 Inclusive environments • Q2 Amenity • Q3 Safety, crime prevention and counter terrorism • Q5 Local distinctiveness • Q6 Urban design: public realm • Q7 Urban design: new development • Q8 Design quality: construction detailing • Q9 Landscaping • Q10 Trees • Q12 Refuse/recycling storage • Q13 Cycle storage • Q15 Boundary treatments • Q18 Historic environment strategy • Q20 Statutory listed buildings • Q21 Registered parks and gardens • Q22 Conservation areas • Q23 Non-designated heritage assets: local heritage list • Q25 Views • Q27 Basement development • PN8 Kennington/Oval • S1 safeguarding existing social infrastructure ▪ T1 Sustainable travel ▪ T2 Walking ▪ T3 Cycling ▪ T4 Public transport infrastructure ▪ T7 Parking ▪ T8 Servicing ▪ T10 Digital connectivity infrastructure

Local Guidance / Supplementary Planning Documents (SPD):

• Employment and Skills SPD • Parking Survey Guidance Notes • Refuse & Recycling Storage Design Guide • Waste Storage and Collection Requirements - Technical Specification • Air Quality Planning Guidance Notes

Appendix 4 - List of drawing numbers and supporting documents

Existing Drawings

Document Rev Title BB20201 P01 Block B Existing Elevations BB20100-B P01 Block B Existing Ground Floor Plan Part B BB20100-A P01 Block B Existing Ground Floor Plan Part A BA20202 P01 Block A Existing Elevations Sheet 2 BA20201 P01 Block A Existing Elevations Sheet 1 BA20101-B P01 Block A Existing First Floor Plan Part B BA20101-A P01 Block A Existing First Floor Plan Part A BA20100-B P01 Block A Existing Ground Floor Plan Part B BA20100-A P01 Block A Existing Ground Floor Plan Part A B91301 P01 Existing Site Sections B91201 P01 Existing Site Elevations B91100 P01 Existing Site Plan

Proposed Drawings

Document Rev Title TCH20100 P2 Chester House, Proposed Demolitions , and External Works TC20301 P2 Block C , Proposed Sections TC20201 P3 Block C , Proposed Elevations TC20104 P3 Block C, Proposed Fourth Floor Plan TC20103 P3 Block C, Proposed Third Floor Plan TC20102 P3 Block C, Proposed First Floor Plan TC20101 P3 Block C, Proposed First Floor Plan TC20100 P3 Block C, Proposed Ground Floor Plan TC20099 P3 Block C, Proposed Basement Floor Plan TB20301 P2 Block B, Proposed Sections: B1, B2, B3 & B4 TB20201 P2 Block B, Preposed Elevations: North, East, South and West TB20105 P2 Block B, Proposed Roof Plan TB20104 P2 Block B, Proposed Fourth Floor Plan TB20103 P2 Block B, Proposed Third Floor Plan TB20102 P2 Block B, Proposed Second Floor Plan TB20101 P2 Block B, Proposed First Floor Plan TB20100 P2 Block B, Proposed Ground Floor Plan TB20099 P2 Block B, Proposed Ground Floor Plan TA20302 P2 Block A , Proposed Sections A3 & A4 TA20301 P2 Block A , Proposed Sections A1 & A2 TA20202 P2 Block A , Proposed North & East Elevations TA20201 P2 Block A , Proposed South & West Elevations TA20105 P4 Block A , Proposed Roof Plan TA20104 P3 Block A , Proposed Fourth Floor Plan TA20103 P3 Block A , Proposed Third Floor Plan TA20102 P3 Block A , Proposed Second Floor Plan TA20101 P3 Block A , Proposed First Floor Plan TA20100 P4 Block A , Proposed Ground Floor Plan T92200 P3 Proposed External Cycle Stores Ground Floor Plan, Elevations & CGI View

T91301 P2 Proposed Site Sections T91201 P2 Proposed Site Elevations T91105 P2 Proposed, Fifth Floor Site Plan T91104 P3 Proposed, Fourth Floor Site Plan T91103 P3 Proposed, Third Floor Site Plan T91102 P3 Proposed, Second Floor Site Plan T91101 P3 Proposed, First Floor Site Plan T91100 P4 Proposed, Ground Floor Site Plan T91099 P3 Proposed, Basement Site Plan

Supporting Documents

• Design & Access Statement prepared by Rolfe Judd Architecture • Air Quality Assessment prepared by Waterman • Arboricultural Impact Assessment prepared by Tamla Trees • Construction Management and Logistics Plan prepared by Caneparo Associates • Daylight and Sunlight Assessment prepared by Consil • Energy Assessment prepared by Max Fordham (this document was not updated, but Appendix E- the GLA Carbon emissions reporting spreadsheet was updated a number of times following Stage 1 comments (last updated 25th Feb 2021) • Flood Risk Assessment and SUDS prepared by GTA (including Lambeth SUDs Pro Forma) • Townscape and Heritage Statement prepared by Tavenors • Historic Environment Assessment prepared by MOLA • Land Contamination Assessment prepared by Furnis Group • Landscaping and Lighting Strategy (within Design and Access Statement) prepared by Space Hub (200812 Planning Response Document was submitted by Spacehub as a further document) • Noise Impact Assessment prepared by Max Fordham • Preliminary Ecological Appraisal prepared by Ashgrove Ecology • Servicing and Delivery Management Plan prepared by Caneparo Associates • Statement of Community Involvement prepared by MPC • Sustainability Statement prepared by Max Fordham • Transport Assessment prepared by Caneparo Associates • Travel Plan- prepared by Caneparo Associates • Ventilation and Extraction information prepared by Max Fordham. • Fire Strategy prepared by JGA (dated 31st January 2020). In addition: • Fire Strategy Block A R4 Issue 2 • Fire Strategy Block B R5 Issue 2 • Fire Strategy Block C R6 Issue 2 • Basement Impact Assessment prepared by Furness Partnership (dated Feb 2020) • Planning Statement prepared by Rolfe Judd Planning