planning report PDU/2009a/01 22 July 2009 Deals Gateway (Phase 2), 6-42 Blackheath Road in the Borough of planning application no. 09/1158/F

Strategic planning application stage 1 referral (new powers) Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and 2007; Town & Country Planning (Mayor of London) Order 2008

The proposal A mixed-use development comprising a 230 room hotel with ancillary bar/restaurant, 72 residential flats (6 studio, 57 one-bed, 6 two-bed, 3 three-bed), 20 live-work units and 574 sq.m ground of floor retail uses.

The applicant The applicant is St James Group Ltd, and the architect is Fraser Brown MacKenna.

Strategic issues The principle of this mixed-use development containing residential, hotel and retail uses is supported on this site within the Creek / Greenwich Riverside Opportunity Area.

The design is of a high standard and the proposed housing mix and level of affordable housing are acceptable.

There are outstanding detailed issues relating to ambient noise and climate change adaptation.

Recommendation

That Greenwich Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 57 of this report; but that the possible remedies set out in paragraph 59 of this report could address these deficiencies.

Context

1 On 17 June 2009 the Mayor of London received documents from Greenwich Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 28 July 2009 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

page 1 2 The application is referable under Paragraph 2 of the Schedule of the Order 2008, being an application that forms part of a more substantial proposed development on the same land that is referable under Category 1A of the Schedule of the Order 2008: “Development which comprises or includes the provision of more than 150 units (houses and/or flats)”.

3 Once Greenwich Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

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

Site description

5 The vacant site, which previously consisted of a 3-storey office building and six industrial sheds, is 0.5 hectares in area and located to at the intersection of two roads; Blackheath Road to the north and Deals Gateway to the west. The rear southwest edge of the site abuts the boundary of the London Borough of , which contains the majority of the ‘One SE8’ major development, of which this site forms part, to which Deals Gateway is the main access road. The site also forms part of the Deptford Creek / Greenwich Riverside Opportunity Area as per London Plan policy 2A.5, and is designated as mixed-use area ‘W3’ within Greenwich Council’s UDP.

6 East of the site is the Greenwich Academy; a Grade II listed former school building, which has been converted into residential properties. Opposite the site, to the north of Blackheath Road, is a Grade II Listed Magistrates Court and further to the east there is a row of Grade II Listed houses. This area north of Blackheath Road is predominantly residential in character and forms part of the Ashburnham Triangle Conservation Area. To the west of the site is the Deptford Bridge (DLR) station. The station and railway line are elevated on a viaduct and cross Blackheath Road via a bridge. Further west, just beyond the railway tracks, is the Seager Distillery site that will be redeveloped to include a 27-storey tower and a 5-11 storey crescent building. Ravensbourne River flows adjacent the DLR railway track in a southerly direction, past the public open spaces of Broadway Fields and Brookmill Park, which are within a short walking distance of the site.

7 Blackheath Road forms part of Transport for London Road Network (TLRN), and connects to the Deals Gateway and Deptford Bridge junction at its western end. TfL have identified transport improvement measures along the western part of Blackheath Road and the junction, which include pedestrian and cycle accessibility enhancements, as well as bus priority measures. Several bus routes serve the site with the nearest bus stops located along Blackheath Road and Greenwich High Road. The nearest rail station is Deptford DLR, approximately 70 metres northwest of the site. As a result, the site has an ‘excellent’ public transport accessibility level (PTAL) of 6.

Case history

8 The Mayor considered a similar proposal in December 2008 (ref: PDU/2009), which was subsequently withdrawn to provide more time to resolve energy and transport issues.

9 The site currently has an extant permission, which was granted on 26 July 2004 for a mixed-use scheme of 108 residential units, 30 live work units, commercial floorspace with 65 car parking spaces and 60 cycle parking spaces. Phase 1 of this scheme has already been built out and this provides 12 private residential units, 10 live work units, 32 affordable units and 465 sq.m of B1 employment space, which is occupied by Kwik Fit.

page 2 10 Prior to the consented scheme a planning application for redevelopment of the site to provide 134 one, two and three bedroom flats, 3,220 sq.m of B1 floorspace and 81 car parking spaces was appealed under non-determination (the Appeal Scheme). Significantly, Block A was a 10 storey building. The Council contested the appeal on the grounds of loss of employment land, height, scale and bulk, air pollution and noise levels, overlooking and sense of enclosure. The appeal was heard at a Public Inquiry on 30 October 2001. The Appeal Scheme was dismissed for the reasons of loss of employment land, impact on the conservation area and effects of pollution on the occupants of the development. These matters have all been addressed in the consideration of the new proposals.

11 On 23 February 2001 London Borough of Lewisham granted full planning permission for the redevelopment of the Deals Gateway site (now known as One SE8) for a mixed use scheme comprising 457 residential units, 40 live/work units, B1, A1, A2 and A3 uses, with ancillary gym together with associated car parking and landscaping. This application was not referable to the Mayor because, under the previous Order, the total number of units on site was less than 500.

12 St James has subsequently submitted various additional and separate full planning applications to enhance phases of the development. This includes applications for Block A and Block B, which were granted permission on 8 April 2004 and 5 January 2004 respectively. Blocks A and B are located adjacent to Phase 2 of the consented scheme and share a basement car park. The planning consent for Block B includes in its description ‘access through the basement to Block B to serve 6-42 Blackheath Road’ (i.e. this site).

13 A further planning permission has subsequently been granted for a ‘link block’ within the adjacent One SE8 development, which physically adjoins Phase 1 of the consented scheme on the application site. The link block crosses the borough boundary between Greenwich and Lewisham. The link block has introduced a further 18 units to the development.

Details of the proposal

14 The amount and type of commercial use already approved for Phase 2, granted on 26 July 2004, and the prohibitive costs of constructing the basement have prevented St James delivering this part of the consent. The level of demand for both office space and parking is insufficient to drive a value that covers the development costs. Following an attempt to sell the site it is evident that third parties also regard the current consent for Phase 2 as an unviable prospect.

15 Consequently the consent on Phase 2 has been reviewed in order to find a solution that will enable St James to bring the site forward. This opportunity has been taken to propose alternative commercial uses, including the hotel, which can be delivered and will generate sufficient jobs while still encompassing the live-work and residential uses.

16 Following pre-application meetings with the GLA, a mixed-use development comprising a 230 room hotel with ancillary bar/restaurant, 72 residential flats (6 studio, 57 one-bed, 6 two- bed, 3 three-bed), 20 live-work units and 574 sq.m ground of floor retail uses, is now proposed for Phase 2. The building would have a perimeter block layout and would rise from seven storeys, opposite the listed Magistrates Court on Blackheath Road, to ten storeys at the corner next to Deals Gateway. Strategic planning issues and relevant policies and guidance

17 The relevant issues and corresponding policies are as follows:

page 3 • Land use principle London Plan • Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG • Ambient noise London Plan; the Mayor’s Ambient Noise Strategy; PPG24 • Urban design London Plan; PPS1 • Inclusive design London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Wheelchair Accessible Housing BPG; Planning and Access for Disabled People: a good practice guide (ODPM) • Climate change London Plan; PPS1, PPS Planning and Climate Change Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG • Transport London Plan; the Mayor’s Transport Strategy;

18 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 2006 Greenwich Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004). The Greenwich Core Strategy 2008 (preferred options stage) is also a relevant material consideration.

Land use principle

19 The principle of a mixed-use development comprising residential and commercial uses on this site has already been established through the consented permission on the site.

20 The inclusion of a hotel and ground floor ancillary retail within the redevelopment is supported by Policy 3D.7 of the London Plan, which identifies a requirement for 40,000 net additional hotel bedrooms by 2026; 1,750 rooms alone, are expected within the London Borough of Greenwich. London Plan policy 3D.7 also sets out that capacity for new hotel accommodation should be in locations such as Opportunity Areas with good public transport access to central London; both criteria that this site meets.

21 Given the site is just outside a designated town centre, a Hotel Assessment in accordance with PPS6 ‘Planning for Town Centres’ has been provided. The sequential test within the assessment demonstrates that there are no available or suitable sites for a hotel within nearby town centre boundaries, and that the proposed hotel would not materially harm the continued vitality or viability of these town centres in accordance with strategic policy 2A.8.

Housing and affordable housing

22 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 70% of housing should be social and 30% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements.

page 4 23 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose.

24 The consented scheme for Phase 2 includes 64 private residential units comprising 49 one-bed and 15 two-bed units. Consented Phase 2 also includes 20 live-work units, with all the affordable housing (32 units) and 10 live-work units having already been delivered in Phase 1, now occupied. The new proposal for Phase 2 includes an additional eight residential units and the local authority have requested that the equivalent of 50% of these additional eight units would be provided as affordable housing. Out of the additional eight units proposed, six of the units (3 two- bed and 3 one-bed) would be affordable which equates to 75% of the additional units being affordable.

25 The already completed Phase 1 and newly proposed Phase 2 of the development would therefore provide a total of 116 residential units and 30 live work units. Of these residential units, a total of 38 would be affordable which equates to 33% affordable housing (excluding the live work units from the calculation).

26 In this instance no viability information has been provided contrary to strategic policy 3A.10. However, given the local authority has reached an agreement with the applicant to provide the additional affordable housing based on uplift over the existing consent, which would be 75%, the proposed affordable housing offer is acceptable. This offer is further justified given that the 32 affordable housing units built within Phase 1 have now been delivered and occupied for some time. GLA case officers are therefore content that no economic viability information is necessary in this instance and the maximum reasonable amount of affordable housing for both Phases 1 and 2 has been achieved.

27 The proposed six affordable units would be for intermediate rent. This is acceptable given that the social rented housing has already been delivered in Phase 1 of the development.

Housing mix

28 Three of the additional eight residential units are proposed to be 3-bedroom units. This is welcomed, but the percentage of family housing in the Phase 2 scheme alone falls well below the 30% target set out in the London Plan Housing SPG. However, given that this is the final phase of a larger development and that there is already a Phase 2 consented scheme with no 3-bedroom units included, the level of family housing is on balance acceptable and compliant with strategic policy 3A.5.

Density

29 London Plan Policy 3A.3 outlines the need for all development proposals to achieve the highest possible intensity of use compatible with local context, the design principles of the compact city (4B.1), and with public transport accessibility. Table 3A.2 of the London Plan provides guidelines on density in support of policy 3A.3. This table provides a guidance range of 650-1100 habitable rooms per hectare for central sites with a PTAL rating of six. The proposal has a density of 1049 habitable per hectare, and therefore sits comfortably within the density range of the London Plan.

Quality of accommodation

30 The flats are appropriately arranged around cluster cores with a maximum of seven units per floor; a layout that would help create a cohesive sense of community, ownership and identity for residents and to improve the overall quality of the residential accommodation. A high number

page 5 of single aspect residential units are proposed, but given the constraints of the site this is considered acceptable. Furthermore, none of the single aspect units would face directly north and would therefore receive adequate levels of natural sun/day light at certain times of the day, and all units are afforded with good outlook either into the communal courtyard or to the open street.

31 There is no significant differentiation in accommodation floor area size between the private and affordable housing units, which is welcomed. Furthermore, all the units are adequately sized and generally accord with unit sizes set out in the Draft London Housing Design Guide 2009. All the units would be regular in shape to help achieve practical layouts and would include their own storage space.

32 All of the units, apart from the those at first, second and third floor levels facing the internal courtyard, would be served by private amenity space in the form of outdoor balconies, which is welcomed. Those with no balconies would have easy access to the residential communal amenity area provided in the internal courtyard, which benefits from a southwesterly aspect allowing plenty of sunlight to reach the space. The scheme is therefore in accordance with policies 3A.6 and 4B.10.

Ambient noise

33 Policy 4A.20 states that “the Mayor will and boroughs should reduce noise by separating new noise sensitive development from major noise sources wherever practicable.” Given that part of the site’s boundary abuts Blackheath Road to the north and Deals Gateway to the west, the applicant has provided a noise survey report in accordance with PPG 24. The report identifies that the proposed northern facade would fall within the highest Noise Exposure Category (NEC) D and the western facade within NEC C. The advice for NEC D is that planning permission for residential development should normally be refused. Given this, the applicant has located the hotel facade on Blackheath Road and partially around the corner into Deals Gateway. This approach is acceptable, as hotel uses are not considered noise sensitive. The noise sensitive residential windows facing Deals Gateway are exposed to NEC C, which is acceptable subject to appropriate conditions.

34 For the residential windows on Deals Gateway it may be unavoidable that windows will need to be kept closed at certain times to provide acceptable internal noise levels. Therefore alternative means of acoustically treated ventilation must be provided. This should be able to provide a rapid flow of air, as opposed to trickle vents, for example. Ideally, systems able to provide this without incurring additional energy usage, such as a whole building ‘passive stack’, should be utilised. Failing this, mechanical ventilation or air conditioning should be provided. This should be appropriately conditioned. Furthermore, the noise assessment provided was originally done in July 2007 based on the consented building footprint. This should be revised to match the now proposed footprint for Phase 2; a condition should secure this. Only once this revision is provided, can the proposed window systems, meeting at least the BS 8233 good criteria, be specified. Urban design

35 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage and views.

36 The redesign of the Phase 2 scheme has resulted in the creation of a perimeter block that would connect to the existing Washington and California buildings, which form part of the

page 6 One SE8 development to the rear of the site. This layout would create an inner courtyard that would form a grassed amenity area. Access to non-residential uses would be located off the principle frontages at ground floor level, creating an active street scene along Blackheath Road and Deals Gateway with passive surveillance. Locating the residential uses in the wings of the building reduces the effects of noise and air pollution caused by the proximity to Blackheath Road. The points of access and egress for the different uses have been separated to avoid conflict, which is positive in design terms and accord with policy 4B.6.

37 The height and scale of the development seeks to mediate the transition between the recent development at Deals Gateway and the buildings along Blackheath Road. The building heights also serve to reinforce the hierarchy of frontages, with the building rising to 10-storeys at the intersection of Blackheath Road and Greenwich High Road. The upper three storeys of the 10-storey element would set back and constructed of differing material to the lower storeys, which will add visual interest to the prominent corner. A number of taller higher density developments have been consented in the area, which includes part of the OneSE8 development that has 10-storey buildings, and the Seager site, which has approval for a 26-storey tower. In this regard the height and scale of the proposed scheme would therefore sit comfortably within the surrounding context and responds appropriately to the emerging townscape in compliance with strategic polices 4B.1 and 4B.10.

38 The site sits opposite the Ashburnham Triangle Conservation Area and the Grade II Listed Greenwich Magistrates Court. There are several large scale buildings already within or adjacent to the conservation area and the precedent for modern, contemporary development fronting the conservation area has been set by the consented scheme and other local developments. In order to respect the character of the conservation area a simple palette of materials has been used which seeks to provide a transition between the vibrant approach of the main part of the OneSE8 scheme and the conservation area. This approach is supported by London Plan policies 4B.8 and 4B.12.

Children’s play space

39 Policy 3D .13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately seven children within the development. The guidance sets a benchmark of 10 sq.m of useable child playspace to be provided per child, with under-five child playspace provided on-site. As such the development should make provision for 70 sq.m of playspace.

40 Although this development includes a small internal courtyard it does not provide any dedicated child playspace. Consideration should be given to providing some playable elements within this courtyard for the under-fives. For older children, given that the development is located close to a large public park, the proposal is acceptable.

Inclusive design

41 In accordance with London Plan policies 3A.5 and 4B.5 the design and access statement accompanying the application states that all flats will be built to Lifetime Homes standards and that all flats will be fully wheelchair adaptable, which exceeds the 10% requirement. These flats are clearly indicated on the proposed floor plans and typical flat layouts are provided. Additionally, all the balconies and terraces will have a level threshold, which is welcomed.

page 7 42 In accordance with strategic policy 3D.7, the proposed 230-room hotel option would include eight wheelchair accessible rooms together with ten rooms designed for ambulant disabled people, which would equate to 8%, which exceeds the 5% of rooms required under Building Regulations.

Climate change

43 The London Plan climate change policies as set out in chapter 4A collectively require developments to make the fullest contribution to the mitigation of and adaptation to climate change and to minimise carbon dioxide emissions.

Mitigation

44 London Plan policies 4A.3-11 focus on mitigation of climate change and require a reduction in a development’s carbon dioxide emissions through the use of passive design, energy efficiency and renewable energy measures. The London Plan requires developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures and prioritising decentralised energy, including renewable technologies.

Be lean

45 The applicant has submitted an energy assessment in accordance with London Plan policy 4A.4 and the content of this report broadly follows the energy hierarchy as set out in policy 4A.1. The baseline emissions for the development have been estimated to be 447 tonnes carbon dioxide per annum, which has been calculated using building regulations approved software and are representative of a development that would just comply with current building regulations requirements. The applicant has taken into account the carbon emissions from non-regulated energy usages, electrical equipment, which is in line with the requirements of the London Plan.

46 The applicant has proposed a series of demand reduction measures to reduce carbon emissions beyond the baseline emissions. Measures proposed include improved envelope insulation and air tightness beyond current building regulations. This has been estimated to save carbon emissions by a 6% beyond the baseline emissions in line with policy London Plan 4A.3.

Be clean

47 Earlier phases of the One SE8 development, already built and occupied, installed electric heating. This has prevented the opportunity for linking the proposed communal heat network for this Phase 2 development into earlier phases. The proposals for Phase 2 include a centralised heat supply using heat-generating plant installed in a single energy centre. The heat network would serve both the domestic and non-domestic elements of the proposed scheme.

48 The proposed energy centre would be located at the ground floor and the information submitted by the applicant indicates that enough space has been secured that would allow for the installation of all the required heat generating plant. The proposed heat network would be partially supplied by combined heat and power (CHP) plant. A CHP capacity of 70 kilowatts would be installed which would save CO2 emissions by a further 19% in accordance with strategic policy 4A.6.

49 With regards to active cooling, the applicant has stated that this would be installed in the retail elements only. Whilst the use of natural ventilation for hotel and residential elements is welcomed, the applicant is requested to provide further information to demonstrate that the hotel

page 8 bedrooms and residential flats will not overheat in order to guarantee the comfort of the occupants.

Be green

50 In terms of renewable energy, the use of photovoltaic (PV) cells has been identified as the most suitable technology, with other technologies disregarded on acceptable arguments. The proposal would include the provision of 150 sq.m of PV panels to generate electricity, which would save carbon emissions by a further 2%, and evidence has been provided to demonstrate that 2% the maximum figure possible. The renewable energy proposals are compliant strategic policy 4A.7.

Adaptation

51 London Plan policy 4A.9 outlines five principles for ensuring effective adaptation to climate change in new developments. These are to minimise overheating and contribution to heat island effects, minimise solar gain in summer, contributing to flood risk reductions, including applying sustainable drainage principles, minimising water use and protecting and enhancing green infrastructure. Policies 4A.10 – 4A.16 cover strategic issues relating to overheating, living roofs and walls and water efficiency. Further guidance is given in the Mayor’s Supplementary Planning Guidance (SPG) ‘Sustainable Design and Construction’, which sets out the Mayor’s essential and preferred standards for sustainable design and construction.

52 The applicant has not provided a sustainability statement to demonstrate that the Mayor’s essential and preferred standards would be achieved, as set out in the SPG. The applicant is also requested to include living roofs where practical and is reminded that PV and living roofs are not mutually exclusive. With regards to water conservation the applicant is requested to maximise rainwater-harvesting opportunities, grey water recycling systems and sustainable urban drainage. Additionally, there is no commitment that the development will achieve BREEAM bespoke pre- assessment rating of ‘very good’ minimum. The BREEAM rating should be secured by condition, but the applicant is requested to provide a sustainability statement before the application returns to the Mayor. Transport

53 The previously withdrawn application raised strategic transport concerns as detailed in planning report PDU/2009/01. Prior to the resubmission, the applicant in communication with TfL addressed all those concerns. Given that this resubmission does not affect any of the transport aspects of the proposal, TfL’s latest position remains valid and that, subject to satisfactory detailed design and s106 agreement, there are no more outstanding matters with the current application. A summary of the package of measures previously agreed with the applicant to mitigate the impact of the proposals on the transport network, to be retained as part of this revised application and be secured through condition and / or s106, consist of:

i) Car parking management plan and restriction for future occupiers from eligibility from on-street parking permits within the nearby CPZ.

ii) Highway section of the Deals Gateway falling with the OneSE8 development to be subject to parking controls to be enforced by the site management company while the rest of Deals Gateway is within TfL’s full control (section of TLRN).

iii) Use of Kwik-Fit service yard for deliveries and access, and production of a Construction Management Plan and Servicing & Delivery Plan which set out the servicing

page 9 restrictions to the retail and commercial occupiers. This should be in consultation with TfL.

iv) A contribution of £15,000 to be paid to TfL towards highway works for improving the footway between the site and the DLR station or nearby bus stops.

v) Provision of DAISY boards or other real time information in the hotel lobby for DLR services.

vi) Condition prohibiting the operator from accepting pre-bookings for private coaches which are 10 metres or longer to be secured in the hotel lease, whilst mini-bus type coaches must only drop off/pick up outside the convenience store.

vii) Travel plan to be approved prior to commencement on site and be both ATTrBuTE and iTRACE (both common types of Travel Plan management software) compliant.

viii) Land dedication at the south-eastern corner of Deals Gateway/A2 junction as per drawing no. 30239/002AC rev A to be provided at no cost to TfL and which will be subject to detailed design of an over-sailing license.

ix) Resurfacing of the footway of Deals Gateway and Blackheath Road frontages.

Local planning authority’s position

54 The local planning authority has yet to come to a view on this application. Legal considerations

55 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments. Financial considerations

56 There are no financial considerations at this stage.

Conclusion

57 London Plan policies on land use; housing; affordable housing; urban design; ambient noise; inclusive design; climate change mitigation and adaptation and transport are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

page 10 • Land use: The principle of a mixed-use development on this site comprising residential and commercial uses has been established through previous consents. The inclusion of a hotel is in line with London Plan policy 3D.7. • Housing and affordable housing: The level of family housing within the Phase 2 scheme is relatively low but given there is already a scheme consented for the site with less family housing the level of family housing is acceptable. In this instance no viability information is provided, but given six of the eight additional units (75% for Phase 2 and 33% overall) would be affordable, this is acceptable. All six units would be for intermediate rent which is acceptable given the social housing has been built and already occupied within Phase 1.

• Ambient noise: The noise sensitive residential windows are appropriately located on Deals Gateway, with the non-noise sensitive hotel windows facing Blackheath Road. This approach is welcomed subject to conditions for ventilation and an updated noise assessment based on the proposed Phase 2 building footprint.

• Urban design: The design of the proposal is an appropriate response to surrounding context and this constrained site. The design is compliant with London Plan design policies.

• Children’s playspace: Consideration should be given to providing playable elements within this courtyard for the under-fives; otherwise the proposal is acceptable.

• Climate change mitigation and adaptation: Mitigation measures to provide CHP and PV cells are acceptable. However with regards to adaptation further detail is required: sustainability statement to demonstrate that the Mayor’s essential and preferred standards would be achieved, feasibility of living roofs, water conservation measures, and a BREEAM bespoke pre-assessment rating of ‘very good’ minimum.

• Transport: Since the previously withdrawn application, the applicant has liased with TfL and all concerns have been addressed subject to the agreed conditions and/or s106 legal agreement to ensure the provisions listed in paragraph 53 are achieved.

58 On balance, whilst the application conforms generally to the London Plan, its fails to secure compliance in several regards.

59 On balance, the application does not comply with the London Plan. • Ambient noise: An updated noise assessment, based on the proposed Phase 2 building footprint, must be provided and ventilation systems and window specifications conditioned. • Climate change adaptation: A sustainability statement to demonstrate that the Mayor’s essential and preferred standards would be achieved, feasibility of including living roofs, water conservation measures, and a BREEAM bespoke pre-assessment rating of ‘very good’ minimum must be provided or conditioned as appropriate.

for further information, contact Planning Decisions Unit: Giles Dolphin, Head of Planning Decisions 020 7983 4271 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Colin Wilson, Strategic Planning Manager (Planning Frameworks) 020 7983 4783 email [email protected] Conor McDonagh, Case Officer 020 7983 4310 email [email protected]

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