ADDRESS: Railway Bridge Upper Marsh London Application Number: 19/00071/FUL Case Officer: Emily Leighton Ward: Bishops Date Received: 10.01.2019 Proposal: Refurbishment and change of use of 9 arches at Upper Marsh and Westminster Bridge Road to provide 3,542sqm of office space (Use Class B1) arranged over ground and new mezzanine floor level; installation of glazed facade to the arches; public realm and landscaping improvements; ancillary waste storage and cycle parking facilities; and other associated works. Applicant: Agent: Urbanest UK Lambeth North Limited Henry Farrar Partnership Gerald Eve 72 Welbeck Street London W1G 0AY

RECOMMENDATION

1. Resolve to grant planning permission subject to the conditions as set out in the report and subject to the completion of an agreement under Section 106 of the Town and Country Planning Act 1990 to secure the planning obligations listed in this report.

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; and b. Negotiate, agree and finalise the planning obligations as set out in this report pursuant to Section 106 of the Town and Country Planning Act.

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 proposed planning obligations set out in the 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 six 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

Relevant site designations: Flood Risk Area Flood Zone 3 Archaeological Priority Area North Lambeth Archaeological Priority Area Local View NNE from Norwood Park to the City, and from Battersea Park to The Gherkin and Canary Wharf Other Central Activities Zone (CAZ) Waterloo Opportunity Area Thames Policy Area Area of Open Space Deficiency Tunnel Safeguarding Lines Adjacent Site Designations: Conservation Areas South Bank Conservation Area Lower Marsh Conservation Area Albert Embankment Conservation Area

LAND USE DETAILS

Site area (ha): 4257.07sqm (0.4257Ha)

NON-RESIDENTIAL DETAILS Use Class Use Description Floorspace (m2) (Gross Internal Area) Existing Sui Railway arches 2,180sqm Generis/Ancillary Disabled car parking, D1 cycle parking and refuse storage for Urbanest Proposed B1(a) Office space 3,699sqm (including the mezzanine)

PARKING DETAILS

Car Parking Spaces Car Parking Spaces % of Bike Spaces Motor- (General) (Disabled) EVCP cycle Spaces Commercial Commercial Existing 0 0 0 0 0 (3 existing disabled spaces (250 associated associated with Urbanest) with Urbanest) Proposed 0 2 0 58 long-stay 0 10 short-stay

(648 associated with Urbanest)

LEGAL SERVICES CLEARANCE

AUDIT TRAIL Consultation Name/Position Lambeth Date Sent Date Report Comments in department Received Cleared para: Susan Boucher Legal Services 05.06.2020 05.06.2020 09/06/2020 Throughout Lawyer

EXECUTIVE SUMMARY

The application site comprises 9 railway arches beneath Waterloo Station located adjacent to the Urbanest site, a mixed use development serving student accommodation, a college and business uses. Access to the application site is from both Westminster Bridge Road and Upper Marsh.

The application proposes the change of use of the 9 arches from Sui Generis use (vacant arches) and associated with D1 Use of Urbanest for the cycle parking (two arches closest to Westminster Bridge Road), disabled car parking and waste/refuse storage to create 3,699sqm (GIA) of B1 floor space. The proposal would present an opportunity for the redevelopment of under-utilised arches into a productive, employment- generating office use consistent with development plan policies, which support such uses located within the Central Activities Zone (CAZ), the London Plan Waterloo Opportunity Area and the Southbank and Waterloo Neighbourhood area.

The application proposes that the B1 floorspace would be leased to Sustainable Workspaces (an affordable workspace operator) at a significant reduction to market rent levels. The application further proposes that should the preferred lessee not take up the B1 space, a planning obligation would be entered into to secure affordable workspace in line with emerging policy ED2 of the Draft Revised Lambeth Local Plan (2018).

The design of the proposal includes a new glazed curtain wall façade on the western elevation of the arches which would read as a cohesive design and would respect the railway arches. It would also animate an inactive edge and increase passive surveillance. The proposed development allows an opportunity to open up a service road that was secured under an earlier Section 106 agreement completed in respect of the adjacent Urbanest development. The earlier agreement identifies the service road as being for private vehicular access. It is currently gated at either end. The proposal is for the gates to be removed in their entirety should development on the Royal Street site come forward in the future and develop the lowline (the area of land that runs adjacent to the railway viaduct) to Archbishops Park, with the gates opened between 7am and 10pm from the implementation of the first phase of any of the Royal Street planning permissions. In the event that the Royal Street site does not come forward for development, a ‘backstop’ date has been agreed to open the service road in mid-2023.The opening of the gates would allow permeability to the arches and the low-line and achieves greater pedestrian access within this part of the Borough. It is proposed to impose a ‘Grampian’ condition that would prevent the development being able to be occupied until a satisfactory planning obligation is entered into in relation to the operation of and future arrangements for the gates, and the facilitating of pedestrian use of the service road.

Officers have given due consideration to any potential amenity impacts that may arise from the change of use of the arches, in particular to the adjacent use of Urbanest serving student accommodation. Subject to conditions, the proposed development would not result in any unacceptable amenity impacts, namely noise and disturbance.

The Council’s transport officer has confirmed that the proposal would not result in any unacceptable transport impacts and advised that the cycle parking, disabled bay parking and servicing proposed for the office use and adjacent Urbanest site is acceptable. A non-material amendment has been granted (application reference: 20/00906/NMC) in respect of the existing planning permission for the adjacent Urbanest development in respect of reconfigured cycle parking, disabled parking and refuse storage for the existing development. The resulting amendments would enable the proposed development to be accommodated without adversely affecting cycle parking, disabled parking and refuse storage for the adjacent Urbanest development. The proposal would be car free, to be secured by a planning obligation.

Benefits would arise from the proposal in terms of employment and skills contributions which would allow for the further training of local residents and an Employment and Skills Plan relating to the end-use occupation of the building, which includes advertising any job vacancies with Lambeth Council. This is proposed to be secured by way of planning obligation.

In relation to planning obligations other than that proposed in relation to the opening up of the service road, it is proposed that planning permission be granted subject to completion of a S106 agreement. Although the applicant itself has only a leasehold interest in the application site land, the applicant has indicated that agreement in principle of other relevant parties to the completion of a S106 agreement, including Network Rail, Secretary of State for Transport and Guys’ and St. Thomas’ Charitable Foundation.

The development would be acceptable, subject to conditions in terms of environmental matters such as sustainability, flood risk, air quality and land decontamination.

Officers consider that the development would comply with the development plan for the Borough and there are no material considerations of sufficient weight that would dictate that the application should otherwise be refused. Officers are therefore recommending approval of the scheme, subject to conditions and planning obligations in accordance with the presumption in favour of sustainable development conferred upon local planning authorities by the National Planning Policy Framework (NPPF).

OFFICER REPORT

Reason for referral to PAC: The application is reported to the Planning Applications Committee in accordance with (1)(ii) of the Committee’s terms of reference as it relates to a major application for the change of use of floor space exceeding 1,000sqm.

1 THE APPLICATION SITE

1.1 The application site comprises nine railway arches located between Westminster Bridge Road and Upper Marsh with an adjoining ‘service road’. The arches are currently used for cycle parking, disabled car parking, and refuse and recycling storage for the adjacent Urbanest development or are otherwise empty.

1.2 The site does not contain any listed buildings nor is it adjacent to any listed buildings.

1.3 The proposal is for the change of use to Class B1 office use and refurbishment of nine arches east of the existing adjacent ‘Urbanest’ development on Westminster Bridge Road. The site is identified within the Lambeth Local Plan (2015) as being located within the Waterloo Railway Character Area.

2 THE SURROUNDING AREA 2.1 The surrounding area has a mixture of uses. The application site is directly adjacent to the existing development that provides a mix of student housing accommodation, a college and business uses (known as ‘Urbanest’) approved in 2013 under application reference 12/04421/FUL. Other uses surrounding the site are offices, hotel and residential uses.

2.2 The site has excellent access to public transport with a public transport accessibility rating (PTAL) of 6(b) because of its access to Waterloo railway station, the London Underground and numerous bus routes. The application site is situated approximately 200m from Waterloo Station.

2.3 The application site is located outside of the South Bank Conservation Area (CA38) which lies to the north of the site. The Lower Marsh Conservation Area (CA40) is also located nearby to the east of the arches/railway line and Albert Embankment Conservation Area (CA57) is located west of the site, beyond Urbanest and Becket House. There are no listed buildings/structures or locally listed buildings that would be affected by the proposal.

3 SITE PHOTOGRAPHS

Figure 1: Looking from Upper Marsh towards the vacant arches.

Figure 2: Looking at toward the application site and the amenity space of Urbanest.

Figure 3: Internal view of the arches looking towards the southern end of the site.

Figure 4: View of southern gate adjacent Upper Marsh entranceway.

Figure 5: Underside of (former) Eurostar platform canopy and supporting structure.

Figure 6: View of northern gates adjacent Westminster Bridge Road.

Figure 7: View toward the arches from Upper Marsh with the Urbanest amenity space to the left and the arches to the right.

4 PROPOSAL

4.1 The application proposes the refurbishment and change of use of 9 arches at Upper Marsh and Westminster Bridge Road from cycle parking, disabled parking and waste/refuse storage associated with Urbanest to provide 3,699sqm of office space (Use Class B1(a)) arranged over ground and a new mezzanine floor level; installation of glazed facade to the arches; public realm and landscaping improvements; ancillary waste storage and cycle parking facilities; and other associated works.

4.2 The proposal would result in 7 of the 9 arches being developed for the B1 office use. The remaining 2 arches closest to Westminster Bridge Road would serve as the cycle parking for the Urbanest scheme.

4.3 The office space would be set out over the ground floor and a mezzanine floor area with a Gross Internal Area (GIA) of 3,699sqm of B1 office space. The Net Internal Area (NIA) of the ground floor is 1,248sqm and the mezzanine floor is 1,587sqm totalling 2,358sqm.

Figure 8: Proposed ground floor layout of the arches.

Figure 9: Proposed mezzanine floor of arches.

4.4 The majority of the façade will be glazed with large format glazed curtain walling with a dark grey/black aluminium cover caps externally and glu-lam (glue laminated) transoms and mullions internally. These are matched with dark grey/black louvres used on the high level vents and also as cladding over back of house areas such as cycle storage and loading bays.

4.5 The Section 106 agreement associated with the adjacent Urbanest development permitted in 2013 under application ref: 12/04421/FUL contained an obligation relating to a strip of land described in the agreement as the ‘Safeguarded Land’. The ‘Safeguarded Land’ is the service road that runs along the front of the arches between Upper Marsh and Westminster Bridge Road (see Figure 10). The existing obligation requires the maintenance and repair of the Safeguarded Land as private vehicular access to the Urbanest development. The agreement contemplated that the Safeguarded Land might be reconfigured at a future date, including in the event of increased pedestrian use of that land. Currently gates are situated at either end of the service road. It is proposed that the service road is to be opened and the gates removed in line with the following triggers:

Planning permission granted for the Royal Street site In the event that a planning application for the Royal Street site (Strategic Site 1) is approved by no later than 1 January 2023, the service road gates must be opened between the hours of 7am-10pm daily on implementation of the first phase of any of planning permission for Strategic Site 1 and in any event by no later than 1 July 2023. The gates are then to be removed in their entirety when the Royal Street ‘low line’ is implemented (opening up pedestrian access adjacent the railway viaduct) and in any event by no later than 1 January 2024.

Backstop In the event that a planning application for the Royal Street site (Strategic Site 1) is not approved by 1 January 2023 the following fall-back is proposed: the service road gates would be retained with no opening hours until 1 July 2023, from which date the gates would need to be open between the hours of 7am to 10pm daily. The gates would then need to be removed in their entirety by 1 January 2024.

4.6 It is noted that there may be a period during which the B1 floorspace is occupied by a tenant but the service road would remain closed. The applicant’s reasoning for this delay is due to concerns about opening the service road too early, which may affect Urbanest and their tenants’ current and further operational requirements, particularly in the event that the Royal Street site (Strategic Site 1) did not come forward and the service road was opened ‘in isolation’. The concerns relate principally to the following matters:  Urbanest’s obligations to its tenants (Build Studios and DLD College), whose premises are situated directly adjacent to the service road, and ensuring they can continue to occupy their premises securely and without detrimental impact to their operations.  Impacts on vehicle servicing of Urbanest’s existing building, in light of increased pedestrian flows along the service road;  Security implications for the existing College (and its external areas) at ground floor level, and the necessary enhancements to the building and systems necessary to address this;  Monitoring and maintenance of the pedestrian road on a day-to-day basis and how this will be managed;  How and whether improvements to pedestrian crossings, surfacing, kerbsides etc. in the adjoining roads would be delivered to cope with increased pedestrian flow.

While these concerns are capable of being addressed and mitigated, it is important that there is sufficient time to do so and for Urbanest to undertake necessary discussions and arrangements with their tenants, investors (and other stakeholders), such that the service road opens in an organised and coordinated way. It is therefore proposed that there is a period after occupation of the arches being established, to review and consider the operational management, servicing, and access of the offices and how this will relate to the service road once opened. As noted above, this will also allow for further discussion and arrangements to be made with Urbanest’s tenants and other local stakeholders, to ensure there is awareness and consensus on the approach to the service road opening. Accordingly, Urbanest have accepted a backstop date of 1 July 2023 for the opening of the service road.

4.7 The Royal Street site is identified in the Lambeth Local Plan as Site 1 under Policy S2 of the Lambeth Local Plan (see Figure 12). The Royal Street site is owned by the Trustees of the Guy’s and St Thomas’ Charity and other related charities and provides the opportunity to be developed as an expansion for St Thomas’ hospital to provide clinical and ancillary hospital uses. It would be necessary to secure the proposed arrangement in relation to the gates, and pedestrian use of the service road, by way of a replacement planning obligation. The area of the Safeguarded Land is included within the ‘red line’ for the current proposal (see Figure 11). However, because the relevant obligation relates to the adjacent Urbanest development, consideration would need to be given to any impact on that development of any changes to that obligation. Accordingly, it is recommended to impose a ‘Grampian condition’ (condition 3) preventing occupation of the scheme currently under consideration until the existing Safeguarded Land obligation can be suitably amended. This would be most likely to be done through a freestanding application to vary the relevant obligation. The amended obligation in relation to the Safeguarded Land would be able to be ‘mirrored’ in the S106 agreement attaching to the proposed development if this is considered necessary.

Figure 10: ‘Safeguarded Land’ outlined in Blue as defined in the Section 106 agreement for 12/04421/FUL and shown on Plan 5.

Figure 11: The figure shows how the current application site ‘overlaps’ the application site for 12/04421/FUL. The ‘red line’ boundary for 12/04421/FUL is shown in green, with the red line being the ‘red line boundary’ for the current application. The yellow area shown is the ‘safeguarded land’ referred to in Schedule 6 of the S106 agreement for 12/04421/FUL. This is located within the area of ‘overlap’ of the application site boundaries for the extant permission 12/04421/FUL and the current permission.

Figure 12: Location of Royal Street (Strategic Site 1) in relation to the application site (pink dot).

4.8 It should be noted as regards the remaining planning obligations proposed in this report in connection with the application site itself, the applicant has a leasehold interest in the land. The applicant submitted an amended Certificate B form on 19.03.2020 advising that the owner/agricultural tenants of the application site ‘red line’ are:  Secretary of State for Transport;  Guys’ and St Thomas Charity;  Network Rail Infrastructure.

4.9 Cycle parking and refuse storage is proposed at ground floor level with access from the arch closest to Upper Marsh. The applicant is proposing to retain the existing fire escape staircase to Waterloo Station within the arch located closest to Upper Marsh. A ‘no build’ area is proposed to the front of the emergency stairs and access to the cycle and refuse store is gated either side of the staircase.

Figure 13: Proposed front elevation of the arches.

Figure 14: Proposed CGI of the front elevation of the arches.

4.10 The applicant is proposing 58 cycle parking spaces and 10 short-stay spaces for visitors. Changing rooms and showers are provided at ground floor level.

4.11 A non-material amendment application (application reference: 20/00906/NMC) was submitted to the Council on 06.03.2020 to reconfigure the cycle parking, waste and refuse storage and disabled car parking associated with Urbanest. The applicant is proposing to move and reconfigure these facilities as they are currently located within arch 1 and 2, the area proposed for B1 office space under the current application. The NMC application was permitted on 03.04.2020.

5 Amendment(s) 5.1 Amended floor plans were submitted on 04.03.2020 which showed the updated provision of cycle parking for the existing Urbanest scheme within Arch 1 and 2 (adjacent Westminster Bridge Road).

5.2 To accommodate the cycle parking within Arch 1 and 2, the applicant has revised the B1 floor space of the scheme. The overall B1 floor space (GIA) is 3,699sqm as advertised. The NIA of B1 floor space has decreased from 2,475sqm to 2,358sqm.

5.3 The applicant originally proposed to subdivide the external amenity space associated with Urbanest. The applicant has amended the plans to remove this from the scheme.

6 RELEVANT PLANNING HISTORY

6.1 18/01680/PREAPP - Change of use of the railway arches to Class B1 office use. Advice given 27.06.2018.

6.2 18/04762/PREAPP - Refurbishment of railway under archers for Class B1 use. Advice given 14.01.2019.

Urbanest Applications – 203 York Road 6.3 12/04421/FUL - Demolition of York House and the Florence Nightingale Public House and the redevelopment of the site comprising the erection of a 19 storey building (plus basement) to accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm and public realm improvements.

The development is EIA Development for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011. The application is accompanied by an Environmental Statement). The application was permitted 29.01.2013.

6.4 14/06123/DET - Approval of details pursuant to condition 32 (Cycle parking) of planning permission ref: 12/04421/FUL (Demolition of York House and the Florence Nightingale Public House and the redevelopment of the site comprising the erection of a 19 storey building (plus basement) to accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm and public realm improvements) granted on 06/03/2013. Application permitted 18.03.2015.

6.5 15/05919/DET - Approval of details, pursuant to condition 32 (cycle parking) of planning permission 12/04421/FUL (Demolition of York House and the Florence Nightingale Public House and the redevelopment of the site comprising the erection of a 19 storey building (plus basement) to accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm and public realm improvements). Granted on 06.03.2013. Application permitted 24.11.2015.

Under this discharge of condition application, a lesser number of cycle parking spaces were approved within the Urbanest amenity space area for a temporary period to allow for Network Rail to utilise 4 arches whilst undertaking construction works.

6.6 15/05972/NMC - Application for a Non-Material Amendment following a grant of planning permission Non-material amendment 12/04421/FUL (Demolition of York House and the Florence Nightingale Public House and the redevelopment of the site comprising the erection of a 19 storey building (plus basement) to accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm and public realm improvements.) Granted on 06.03.2013. Application permitted 16.11.2015.

Under this application, the plans were varied in order to show the temporary location of the cycle parking approved under the application 15/05919/DET.

6.7 16/00063/DET - Partial approval of details pursuant to condition 32 (cycle parking) of planning permission 12/04421/FUL (Demolition of York House and the Florence Nightingale Public House and the redevelopment of the site comprising the erection of a 19 storey building (plus basement) to accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm and public realm improvements) granted on 06.03.2013. Application permitted 05.02.2016.

Under this application, the applicant discharged their obligation to provide cycle hire docking stations and an associated pay station.

6.8 19/04233/VOC - Variation of condition 32 (Cycle Parking) and 37 (Waste Management Strategy) of planning permission 12/04421/FUL (Demolition of York House and the Florence Nightingale Public House and the redevelopment of the site comprising the erection of a 19 storey building (plus basement) to accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm and public realm improvements) granted on 06.03.2013.

(Re-consultation due to corrected description)

Variation sought:

Amend wording of Condition 32 to 'Cycle Parking must be provided and maintained in accordance with the details shown on plans 18107_(00)_P099 18107_(00)_P100 and 18107_(00)_P01. The cycle parking shall thereafter be retained solely for its designated use unless otherwise approved with the local planning authority'.

Amend wording of Condition 37 to: 'The management and storage of waste shall be carried out in accordance with the [Waste Management Statement] (November 2019). The facilities shall be operated in accordance with the plan and retained for the duration of the permitted use, unless otherwise agreed with the Local Planning Authority'.

Insert new condition as proposed: '3no. disabled car parking spaces for the student accommodation must be provided in accordance with details shown in the Disabled Parking Statement (November 2019) and thereafter retained for the duration of the permitted use, unless otherwise agreed with the Local Planning Authority'.

This application was withdrawn on 28.02.2020 on the advice of Officers as the proposed changes were not considered material. The applicant submitted an NMC application addressing the changes to the cycle parking, disabled car parking and the refuse and recycling storage serving the Urbanest development on 05.03.2020. Officers have provided the applicant with informal pre-application advice noting that the proposed changes would constitute a non-material change to the parent permission. However at the time of writing this report a formal decision has not be issued and will be reported to Members by way of an addendum.

6.9 20/00906/NMC – Application for a non-material amendment following a grant of planning permission ref : 12/04421/FUL (Demolition of York House and the Florence Nightingale Public House and the redevelopment of the site comprising the erection of a 19 storey building (plus basement) to accommodate student accommodation and ancillary facilities (Use Class Sui Generis; 35,926 sqm GEA; 1,093 bed spaces), a college (Use Class D1; 6,340 sqm GEA) and affordable workspace (Use Class B1; 382 sqm GEA) and associated servicing arrangements, landscaping, new public realm and public realm improvements) granted 06.03.2013

Amendment sought to wording of conditions 32 and 37 to reflect reconfiguration of cycle parking provision, and waste management/storage for the building, as a consequence of the proposed change of use of adjacent Railway Arches to provide new office floorspace. Proposed additional condition to reflect disabled parking re-provision. Application permitted 03.04.2020.

7 CONSULTATIONS

7.1 Statutory External Consultees

Environment Agency – Received 18.02.2019. Advised that there is no objection to the proposal subject to conditions on contamination measures, piling methods and sustainable drainage systems. The EA have advised that the submitted Flood Risk Assessment (FRA) provides an accurate assessment of the tidal and fluvial flood risks associated with the proposed development. (refer to conditions 25-29).

TFL Road Network Development – Received 13.02.2019. No objection to the proposal subject to conditions ensuring the proposal being car-free, compliance with the London Plan cycle parking standards, Delivery and Servicing Plan and Construction and Logistics Plan. (refer to conditions 5-8).

Veolia Waste Lambeth – Received 12.02.2019. No objection to proposal – noted that Veolia had met with the applicants during pre-application meetings to discuss the submitted Operational Waste Management Strategy. (refer to condition 8).

Design Out Crime Officer – Received 28.01.2019. No objection subject to conditions: pre- commencement condition to incorporate security measures and pre-occupation condition to ensure a secured by design inspection is undertaken. (refer to conditions 30 & 31).

Bioregional – Received 05.02.2019. No objection to proposal subject to conditions on connecting to a decentralized network, BREEAM design stage and post construction certificates, design stage and as-built calculations and a cash in lieu contribution to offset the remaining carbon contributions. Following the initial comments, the applicant provided further information on 19.03.2019 which addressed Bioregionals’ concerns on connecting to decentralised systems, BREEAM ratings and carbon offsetting contribution. Bioregional advised on 22.03.2019 that conditions requiring the scheme to connect to a decentralized network would not be required and that a ‘Very Good’ rating of 60% would be acceptable. (refer to conditions 19-22).

EHST Land Contamination – Received 17.02.2019. No objection to the proposal subject to conditions on contamination, a delivery and servicing plan, and post-installation noise conditions. (refer to conditions 6, 23 and 24)

Thames Water – Received 28.01.2019. No objection to the proposal, however note that the development is close to water main pipes. Informatives are suggested.

Network Rail – no comments received at the time of writing this report. Any comments will be reported by way of an addendum.

Historic England (archaeology) - no comments received at the time of writing this report. Any comments will be reported by way of an addendum.

7.2 Internal Consultees LBL Noise Pollution – Received 13.02.2019. No objection to the proposal.

Flooding – SUDS – Received 12.02.2019. No objection with the proposal due as the applicants are proposing to utilise an existing Sustainable Drainage System which has been designed to accept flows from this development.

Conservation & Urban Design – Received 06.02.2019. Note that whilst supportive of the scheme which would animate an inactive edge and increase passive surveillance, there are concerns with the proposed curtain wall of the proposal and with the retention of the gates which fail to allow permeability and connectivity of the site. (refer to conditions 11-17).

Planning Policy – Received 07.02.2019. No objection to the introduction of office space in the arches. Officers advise that flexible/affordable workspace should be provided with the scheme.

Transport Lambeth – Received 29.01.2019. No objection to the proposal subject to conditions securing details of refuse/recycling, design/layout of cycle parking, Method of Construction Statement, Service and Delivery Plan and Travel Plan. Car free development and financial contributions for disabled car parking is also requested to be secured through a Section 106 agreement. (refer to conditions 5-10).

Sustainability Team On Air Quality – Received 08.02.2019. The site is classed as being at Medium Risk. No objection to the proposal subject to conditions on NRMM and including more details in the Construction Management Plan. (refer to conditions 4 & 6).

Employment And Skills – Received 18.02.2019. Advised that the proposal would trigger the requirements to provide a financial contribution for local employment and training which would be secured through a Section 106 agreement.

Regeneration Team Bishop Ward – Received 04.03.2019. No objection to the proposal. The proposal would reactivate an area with potential for linkages to strategic sites. The service road alongside the arches should be for pedestrian and cyclists only. The service road alongside the arches should be opened and if required, a condition for the opening hours of any gates could be added to the decision notice with a requirement in any S106 agreement for full opening should any strategic sites come forward in the future. Officer comment: The proposed ‘Grampian’ condition requires a planning obligation to be entered into providing for the removal of the gates if and when the Royal Street Site is developed, and securing daily opening times of the gates, as well as securing the service road as a pedestrian road adjacent railway lines, thereby increasing the permeability of the proposed arch redevelopment as per Policies PN1 and ED5 of the Lambeth Local Plan. The opening up of this road would accord with the current requirements of Policy ED5(d) which requires applications affecting railway arches to improve the immediate environment around the arches, including the public realm. This is to include accessibility, safety, servicing and lighting appropriate to the location.

7.3 Other Consultees

WeAreWaterloo – Received 18.02.2019. No objection to the proposal. Supportive of the creation of additional office space within the Waterloo BID area as this meets the objectives of supporting the growth of a mixed economy. The following requests and suggestions were outlined in the comments:  Request that there is a provision for affordable workspace – the applicant could consult with WeAreWaterloo and the Council to determine whether a part of the office development may be able to be offered at below market rates for start-up companies;  Request that the noise from the proposal would not impact on Build Studios which is located within the lower levels of the Urbanest – hours of operation should be conditioned;  Request that the developer funds reasonable costs for installing artwork on the hoardings to be erected whilst construction is undertaken. This request is common and has been undertaken on applications along Lower Marsh – helps to brighten the area and provides an opportunity to showcase local independent artists;  Support increased public access to linear car free pathways alongside elevated railway infrastructure. Note that the Design and Access Statement submitted with the proposal does not suggest that this element will be opened up and requested that the developer look into this issue;  Suggest that the treatment of the Westminster Bridge Road (WBR) elevation is looked at – note that there is limited opportunities to create entrances on this elevation however WBR is a key access point for tenants, most of all those who would use ‘EXIT 1’ of Waterloo Station. WeAreWaterloo would be happy to work with the developer to improve the streetscape on this elevation;  Furthermore, the air quality in the WBR underpass is some of the worst in the capital - the WSP Air Quality Assessment fails to note the data collected as part of the Love Lambeth Air project facilitated by WeAreWaterloo in 2016/17. With plant from the development expelling exhaust air into the underpass, no assessment is made of how this will affect air quality in that space;  Section 2.3. of the draft Construction Management Plan does not include Build Studios as one of the sensitive tenants which Urbanest is consulting with over operations requirements. Given that the facility offers 24 hour access to tenants, we would advise immediate consultation is entered into with the management of Build Studios. WeAreWaterloo as a tenant of this space would be glad to facilitate this. Furthermore the construction management plan mentions that deliveries will be made alternately between Upper Marsh and Westminster Bridge Road. As a red route featuring a segregated cycle lane, there is no potential to make any deliveries by vehicle from the Westminster Bridge Road entrance.  The Construction Coordination Group is not a stakeholder consultation mechanism - most of the stakeholders concerned with the development (Becket House, Build Studios, Canterbury and Stangate House etc) have no involvement with this group and it will be contingent on the developer to ensure those adjacent to the site are kept fully informed, with a site manager available by phone at all times of operation.  The Construction Management Plan does not enter into sufficient detail regarding rodent controls. The railway viaducts contain a significant population of rodents which are likely to be displaced as a result of the construction works, as was noted during the Wessex Capacity works to Waterloo Station in 2017. Given the proximity of a food market at Lower Marsh, it is contingent on the developer to ensure that every effort is being made to manage this issue, including but not limited to the funding of rodent control measures for those neighbours experiencing an increase during the construction.  WeAreWaterloo and Build Studios would hope that the developers could broker a meeting with the new tenants as soon as possible to develop partnerships aimed at strengthening the network of co-working spaces in the area. Reciprocal arrangements on meeting rooms, social value programmes and events would be beneficial to both operators, and as future levy payers the BID will help the operator develop local supply chain arrangements to serve the local economy.

Officer Response: The majority of the comments raised by WeAreWaterloo are matters that require the parties to undertake their own discussions and cannot be conditioned under this application. A condition has been added to the proposed decision notice to secure a hoarding strategy with public art (refer condition 5).

LCR (London and Continental Railways) – received 31.03.2020. LCR have advised that they have a leasehold interest at the former Waterloo International Terminal and landlord of the Leake Street Arches.

LCR is supportive of the scheme as proposed. It will be a further step to securing comprehensive regeneration in the wider Waterloo area.

For the reasons set out above, LCR’s main comment on the scheme would be that the proposal to retain the existing gates at both ends of the public realm in front of the Urbanest development would cause an interruption to the pedestrian realm in this area, going against the aspiration of the 2014 Masterplan and LB Lambeth proposals to implement the Spine Route.

We understand from Urbanest however that the gates would only be closed at night and that, once the Guy’s and St. Thomas’ Charity Royal Street development is completed, the gates would be removed/left open.

To that end we would request that London Borough of Lambeth utilises its vires as the local planning authority to ensure that this is the case by securing this through Planning Condition. Subject to London Borough of Lambeth securing the removal of the gates once the Royal Street development is brought online, LCR has no objection to this scheme.

Officer Response: The treatment of the Safeguarded Land is dealt with through the proposed ‘Grampian’ condition as explained in section 4.5 of this report.

7.4 Adjoining owners/occupiers

7.4.1 Three site notices were displayed from 01.02.2019 and the application was advertised in the local paper on 01.02.2019. The formal consultation period ended on 22.02.2019.

7.4.2 The applicant advised on 11.03.2020 that Certificate B had been served incorrectly, that is, not all those parties with an interest in the land in the application site had been correctly notified about the application. The applicant provided an updated Certificate B. Site notices were posted on 01.04.2020 and a press notice was published on 27.03.2020. The expiry date of this round of consultation ended on 22.04.2020.

7.4.3 At the time of writing this report, no objections to the proposal have been received. Should objections be made prior to the Committee date, these will be reported in the form of an addendum.

7.4.4 A comment in support of the application was received from Alpha Plus Group Ltd who run the college use within the adjacent Urbanest Building as follows:

These proposals will transform prime opportunity space into regenerating life style working spaces adding buzz to the area. Also as a result of this other excellent hard and soft landscaping designs can be brought forward that will further enhance the immediate environment for all (incl our students) and additionally safeguarding and security measures that are much needed will be sensitively and attractively completed.

8 POLICIES

8.1 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. The development plan in Lambeth is the London Plan (2016, consolidated with alterations since 2011), the Lambeth Local Plan (September 2015) and the South Bank and Waterloo neighbourhood development plan (‘the SoWNDP’) (October 2019).

8.2 In December 2019 the London Plan (Intend to Publish version) was published by the Mayor of London. This followed the Examination in Public on the Draft London Plan (published in December 2017), which was held between January and May 2019. On 21 October 2019 the Panel of Inspectors appointed by the Secretary of State issued their report and recommendations. Many of these recommendations (although not all) were incorporated into the Intend to Publish version. The Draft London Plan has a significant amount of weight in planning decisions, although it will not be given full weight until the final version is published.

8.3 On 13 March 2020 the Secretary of State formally directed the Mayor to make a number of detailed modifications to the wording of various policies in the Intend to Publish version released in December 2019. Under the Greater London Authority Act 1999, whilst such a direction remains in force, the Mayor must not proceed to publish the London Plan (in its final form) without modifying the Intend to Publish version so as to comply with the direction. From the Mayor’s reply to the Secretary of State on 24 April 2020 as published on the GLA website, it appears that there may be further dialogue between the Mayor and the Secretary of State about the modifications. However, the outcome of this process is not known at present. Officers have therefore needed to take into account the effect of the Secretary of State’s direction on emerging London Plan policies.

8.4 It is not considered that the Secretary of State’s modifications to the Intend to Publish version alter the assessment of the application. This is because the emerging London Plan policies that are affected by the direction are not considered relevant to the current proposal. The degree of weight to be attached to the draft London Plan as a whole is noted above.

8.5 The LLP is currently under partial review to ensure it complies with amendments to changes in the National Planning Policy Framework (NPPF) and London Plan. The Draft Revised Lambeth Local Plan underwent public consultation from October to December 2018 under Regulation 18 of the Town and Country Planning (Local Plans) (England) Regulations 2012. Pre-submission publication (Regulation 19) of the Draft Revised Lambeth Local Plan Proposed Submission Version occurred between 31 January and 13 March 2020. The Council submitted the draft plan for examination on 22 May 2020. Officers consider that this should be afforded very limited weight at this stage.

8.6 The site falls within the Southbank and Waterloo neighbourhood area. The adopted Southbank and Waterloo Neighbourhood Plan 2017-2032 is in place for this neighbourhood area (referred to in this report as the SOWN Neighbourhood Plan).

8.7 The latest National Planning Policy Framework 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.

8.8 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 to this report.

ASSESSMENT

9 LAND USE

9.1 Appropriateness of an office use on the site

9.1.1 Policy ED3(a) of the Lambeth Local Plan (LLP) 2015 states that proposals for offices greater than 1,000sqm will be supported in the Central Activities Zone, Vauxhall and Waterloo London Plan Opportunity Areas and Brixton and Streatham major town centres.

9.1.2 Policy ED5(a) of the Lambeth Local Plan (LLP) 2015 states that the use of railway arches for B1 use will be supported within the London Plan Opportunity Area.

9.1.3 Office use is supported in the CAZ under London Plan Policy 2.11 and within the Waterloo Opportunity Area under Policy 2.13. The additional floorspace would contribute towards the strategic aim of supporting 15,000 jobs in the Opportunity Area with the potential to provide approximately 206 jobs. LP Policy 4.2 supports new office development in viable locations with good public transport where there is evidence to show sustained demand for office based activities. The London Plan identifies a demand for 2.71-3.07 million sqm of new office space in the CAZ and north of the Isle of Dogs. The latest figures in the draft London Plan show an increased forecast demand of 3.5 million sqm for the period 2016 and 2041. The proposed development would help achieve this target by providing 3,699sqm (GIA) of high quality office space. This space would be flexible so that it could support small, medium and larger enterprises in compliance with Policy 4.2 and Policy E1 under the draft LP.

9.1.4 Policy 2.11(a) and 4.3 of the London Plan states that proposals to increase office floorspace in the CAZ should include housing. There is no housing on the site and no housing is proposed under this application. The Mayor’s CAZ SPG and Policy SD5 of the draft London Plan identifies that offices and other CAZ strategic functions should be given greater weight relative to new residential use in the Waterloo Opportunity Area. Policy 2.11 of the London Plan requires proposals for office space within the CAZ to provide a mixed use unless such a mix would demonstrably conflict with other policies set out in the London Plan and Local Plan. The applicant has submitted a Planning Statement which states that a mixed-use scheme has not been proposed in line LP Policy 2.11 as the site is heavily constrained due to its location beneath the Waterloo Station railway bridge, resulting in significant structural and design constraints, including the need for Network Rail to access the site regularly for maintenance works. Noting the location and the constraints of the site, it would not be suitable to provide a mixed-use scheme at the site which would include a residential element. As such, a wholly commercial scheme is considered to be acceptable in this location.

9.1.5 Policy P12 of the SOWN Neighbourhood Plan states that schemes will be encouraged which provide office or workspace.

19.1.6 The application site is within the Central Activities Zone and is therefore an appropriate location for an office use. The proposal would present an opportunity for the re-development of underused arches into a productive, employment-generating office use. The proposed B1 use is acceptable for the site and is welcomed and would accord with the principles of Policies 2.11 and 2.13 of the London Plan, Policy ED3 and ED5 of the Lambeth Local Plan (2015) and Policy P12 of the SOWN (2018).

9.2 Provision of Affordable Workspace

9.2.1 The Intend to Publish London Plan (2019) seeks to ensure that new commercial developments creating more than 2500sqm of business space provide low-cost business space (Policy E2) and also affordable workspace (Policy E3). Policy E3 further notes that particular consideration of affordable workspace should be provided in the CAZ. The policy advises boroughs to consider detailed affordable workspace policies in light of local evidence of need and viability. Accordingly, in Lambeth’s draft new Local Plan, Policy ED2 requires major developments that include B1 floorspace to provide a portion of affordable workspace depending on its location. In Waterloo, the draft requirement is that 10 per cent of B1 floorspace shall be discounted at 50 per cent of market rents for a period of 15 years.

9.2.2 Furthermore, Policy ED2 of the Draft Revised Lambeth Local Plan (October 2018) states that all major developments proposing B1 floorspace are to provide a proportion of affordable workspace within the Waterloo Opportunity Area. Emerging policy ED2 is further supported by Lambeth’s Draft Affordable Workspace SPD (Feb 2020) – this document has been through one round of consultation with another expected late 2020. The SPD carries very limited weight.

9.2.3 Policy P12 of the SOWN Neighbourhood Plan states that schemes will be encouraged which provide office or workspace with the following characteristics: i) are able to be subdivided to encourage flexible use and co-working and/or; ii) include a range of unit sizes including offices of under 1000sqm and/or; iii) are able to provide accommodation for a range of jobs which are accessible to local people and/or; iv) commit to working with third party employment support providers and local schools to provide work placements, apprenticeships and training support for unemployed people.

9.2.4 Whilst it is noted that the draft London Plan policies do not currently have full weight, but do have significant weight, the proposal would result in the creation of affordable workspace which the applicant proposes would be operated by Sustainable Workspaces (an affordable workspace operator).

9.2.5 In the applicant’s ‘Consultation Response Schedule’ dated 19.03.2019 (reiterated in an email dated 28.02.2020), they advise that they expect Sustainable Workspaces will lease all of the B1 space at a rent of £30/sqft, which would be at a significant discount (£1,194,480 for an GIA of 39,816sqft) to open market rent (approximately around £50-60/sq ft which would equate to £1,990,800 - £2,388,960 for an GIA of 39,816sqft). The website for Sustainable Workspaces states that the business is ‘the largest ecosystem of sustainable start-ups and corporates in the UK and Europe’. The business brings together startups, corporates, government and NGOs into their workspaces which are uniquely focused on sustainable development (buildings, food, energy, transport, circular economy and clean air). Strictly applying emerging Policy ED2 would require the provision of 369sqm (3972sqft) of affordable space. The letting of the whole unit to Sustainable Workspaces is sequentially preferable to applying emerging Policy ED2 in the first instance, as the former would enable the larger area to be taken on by Sustainable Workspaces. It is noted that the applicant has not provided details of how long Sustainable Workspaces would be leasing the floorspace – in the absence of this information it is considered that any obligation should relate to a period of 15 years to align with provision of affordable workspace set out in emerging policy ED2. Any affordable workspace terms would need to be secured by way of a planning obligation.

9.2.6 Lambeth’s Economy and Inward Investment Team have set out the proposed Affordable Workspace obligations that they wish to secure through a Section 106 agreement as follows:  To let all the proposed B1 floorspace to Sustainable Workspaces (the applicant’s preferred provider) for the discounted rent of £30/sqft;  Approval of an Affordable Workspace Management Plan with Lambeth Council to produce annual report detailing and quantifying social impact, as well as setting out matters such as the basis on which the space will be let to end use occupiers as set out in Section 5 of the Draft Affordable Workspace SPD;  In the event that Sustainable Workspaces do not lease all of the proposed B1 floorspace, the following cascade mechanism is proposed: i. Sustainable Workspaces to lease all the B1 floorspace and agree an Affordable Workspace Management Plan with the Council; ii. If (i) does not occur or if Sustainable Workspaces vacate the B1 floorspace before the end of 15 years, 10% of the floorspace is to be provided at 50% market rent for 15 years and leased to a suitable organisation on the Council’s emerging Approved Workspace Provider List or Charitable/Not-for profit Register. The workspace should have a sectoral focus on the low carbon and/or life sciences sectors, building on multi-stakeholder efforts locally (for example within the Guys & St Thomas’ Charity Estate which adjoins the site to support the growth of low carbon focussed and life science enterprise in South Bank, Waterloo and the wider SE1 economic geography. Should this focus not be possible, a wider focus of supporting the creative and cultural economy should be sought for the occupation of the arches; iii. In the event that both i) and ii) are unable to be secured, a financial contribution as calculated in Appendix 10 of the Draft Revised Lambeth Local Plan will be sought.  A review mechanism will be required in the Section 106 agreement should Sustainable Workspaces vacate the site before the end of the 15 year period. The mechanism would require that a new affordable workspace operator will need to be sought to manage the workspace and be subject to an Affordable Workspace Management Plan.

9.2.7 Regeneration Officers and the Economy and Inward Investment Team have requested that Officers include an obligation that directs the occupation of the affordable workspace element towards a sectoral focus on the low carbon and/or life sciences sectors. Planning Policy Officers have advised that the emerging policy ED2 allows for affordable workspace to be taken up by a specific sector in line with what the Economy and Inward Investment Team have requested. It is noted that the applicant has agreed that in the event that Sustainable Workspaces do not take the affordable workspace, the floorspace would then be leased to a new affordable workspace provider with a preference for a provider that has a sectoral focus on the low carbon and/or life sciences. Officers have therefore added this preference into the proposed cascade mechanism. It is recommended that the affordable workspace obligation provides for the following:

 Securing of the B1 floorspace as affordable workspace subject to the following cascade mechanism: i) Sustainable Workspaces to lease the B1 space, which is to be managed in accordance with an approved Affordable Workspace Management Plan (including requirements for annual report detailing and quantifying social impact); ii) If (i) does not occur or if Sustainable Workspaces vacate the B1 space before the end of 15 years, 10% of the floorspace to be provided at 50% of market rent for the balance of the 15 year period running from the date of original occupation by Sustainable Workspaces and such floorspace to be leased to a suitable organisation on the Council’s emerging Approved Workspace Provider List or Charitable / Not-for-profit Register (with reasonable endeavours to be used to secure a provider with a low carbon/life sciences sectoral focus) and a replacement Affordable Workspace Management Plan entered into; iii) In the event that both i) and ii) are unable to be secured, a financial contribution as calculated in Appendix 10 of the Draft Revised Lambeth Local Plan (Proposed Submission Version January 2020).

There is no requirement for a separate ‘review mechanism’ as requested by the Economy and Inward Investment Team, as this is able to be covered by what is proposed at (ii) above.

9.2.8 Officers welcome the proposed affordable workspace and note this reflects emerging London Plan policy and emerging borough level policy, albeit that neither of these has full weight and the emerging borough policy is at a relatively early stage of preparation. In this instance, Officers agree that the affordable workspace is secured through a ‘cascade’ mechanism whereby should Sustainable Workspaces not lease the unit for discounted market rent or vacate the unit before the end of their 15 year period, that 369sqm (3972sqft) affordable workspace can be secured for 10% of the floorspace at 50% of the market rent for a period of 15 years from the first occupation of the B1 floorspace to accord with the emerging policy. In the event that occupation by Sustainable Workspaces is unable to be secured or they vacate the premises within the 15 year period, the cascade mechanism will apply and the applicant will need to provide an amount of affordable workspace in accordance with emerging policy. If this is also unable to be secured, a financial contribution following the formula set out in Appendix 10 of the Draft Revised Lambeth Local Plan (2018) will be secured. Should a financial contribution be secured, emerging policy provides that this can be spent on the provision of affordable workspace anywhere within the Borough. The cascade mechanism is proposed because of the potential difficulty of letting an area of 369 sqm (3972sqft) in the event that Sustainable Workspaces does not take on the whole of the B1 floorspace.

9.2.9 The proposed provision of affordable workspace reflects the aims of emerging Policy ED2 and draft London Plan Policy E3. This element of the proposal is supported.

10 Design and Conservation

10.1 The beginning of the Agenda Pack contains a summary of the legislative and national policy context for the assessment of the impact of a development proposal on the historic environment and its heritage assets. This is in addition to Lambeth Local Plan and London Plan policies.

10.2 Turning to consider the application of the legislative and policy requirements referred to above, the first step is for the decision-maker to consider each of the designated heritage assets (referred to hereafter simply as “heritage assets”) which would be affected by the proposed development in turn and assess whether the proposed development would result in any harm to the heritage asset.

10.3 The decision of the Court of Appeal in Barnwell Manor confirms that the assessment of the degree of harm to the heritage asset is a matter for the planning judgement of the decision-maker.

10.4 However, where the decision-maker concludes that there would be some harm to the heritage asset, in deciding whether that harm would be outweighed by the advantages of the proposed development (in the course of undertaking the analysis required by s.38(6) PCPA 2004) the decision-maker is not free to give the harm such weight as the decision-maker thinks appropriate. Rather, Barnwell Manor establishes that a finding of harm to a heritage asset is a consideration to which the decision-maker must give considerable importance and weight in carrying out the balancing exercise.

10.5 There is therefore a “strong presumption” against granting planning permission for development which would harm a heritage asset. In the Forge Field case the High Court explained that the presumption is a statutory one. It is not irrebuttable. It can be outweighed by material considerations powerful enough to do so. But a local planning authority can only properly strike the balance between harm to a heritage asset on the one hand and planning benefits on the other if it is conscious of the statutory presumption in favour of preservation and if it demonstrably applies that presumption to the proposal it is considering.

10.6 The case-law also establishes that even where the harm identified is less than substantial (i.e. falls within paragraph 196 of the NPPF), that harm must still be given considerable importance and weight.

10.7 Where more than one heritage asset would be harmed by the proposed development, the decision- maker also needs to ensure that when the balancing exercise in undertaken, the cumulative effect of those several harms to individual assets is properly considered. Considerable importance and weight must be attached to each of the harms identified and to their cumulative effect.

10.8 What follows is an officer assessment of the extent of harm which would result from the proposed development to the scoped heritage assets provided by the applicant as part of its submission. This includes adjacent Conservation Areas.

10.9 Impact on heritage assets: Conservation Areas

10.10 The Council’s Conservation and Design Officer has considered the impact of the development on the following heritage assets:

 South Bank Conservation Area  Albert Embankment Conservation Area  Lower Marsh Conservation Area

Figure 15: Location of Conservation Areas near the application site (shown in pink).

10.11 Noting the location of the proposal within the railway arches and adjacent to the existing Urbanest development, there would be limited views of the proposed development from the surrounding Conservation Areas.

South Bank Conservation Area 10.12 From Addington Street (within the South Bank Conservation Area), there would be restricted views looking southeast towards the proposal. In this view the proposal would appear modest compared to its larger neighbour Urbanest. As such, the proposal would not harm the setting or views in and out of the South Bank Conservation Area.

Albert Embankment Conservation Area 10.13 From Lambeth Palace Road (Albert Embankment Conservation Area) there would be restricted views looking eastward toward the application site. The proposal is screened by Urbanest and Becket House, again the proposal would compare modest next to both these buildings. As such, the proposal would not harm the setting or views in and out of the Albert Embankment Conservation Area.

Lower Marsh Conservation Area 10.14 The proposal is not visible from within the Lower Marsh Conservation Area. As such, the proposal would not harm views in or out of the Lower Marsh Conservation Area.

Impact upon Heritage Assets: Summary

10.15 The proposal is not considered to cause harm to the significance of any heritage assets. It would preserve the character and appearance of the adjacent conservation areas. The proposal would therefore accord with the LLP Policy Q22, the requirements of the NPPF and the statutory duty placed on the local planning authority.

Assessment of Harm versus Benefits 10.16 No assessment is required in terms of harm to heritage assets versus the public benefits of the proposal given that officers have identified no harm to heritage assets.

10.17 Local views 10.18 Whilst it is noted that the application site is located within Local Views (NNE from Norwood Park to the City, and from Battersea Park to The Gherkin and Canary Wharf), due to the location of the proposal within the existing arch space beneath the Waterloo railway bridge, the proposal would not impact on local views. As such, the proposal would accord with LLP Policy Q25.

10.19 Impact on heritage assets: Archaeological Priority Area 10.20 The application site is located within the North Lambeth Archaeological Priority Area. Historic England Archaeology (GLAAS) were consulted on the application but no comments were received. It is noted that the application is not proposing significant ground works to accommodate the change of use at the site.

10.21 Scale, massing, layout and appearance 10.22 The proposal is for a glazed façade with expressed frame along the western elevation of the railway viaduct. The façade treatment takes inspiration from S.R. Crown Hall by Mies van der Rohe (Chicago) and would provide a lightweight visually permeable contrast to the heavy concrete structure of the viaduct. Whilst there is in-principle support for a glazed infill approach which achieves a ‘clean, clear and crisp expression’, Design Officers have previously raised concerns about its detailing during pre- application advice. The glass façade would project beyond the viaduct by 1.4m and would rise above the viaduct fascia by 0.8m. Design Officers are concerned that the combined forward and upward projection would envelope the viaduct fascia and as a result the purity of the viaduct form and structure would be lost and dominated by the glass façade. It is worthwhile noting that these concerns are exacerbated by the increase in forward projection compared to the pre-application position, where officers were told the projected was 300mm. Design Officers consider that their concerns have not been considered in this regard.

10.23 Whilst the Design Officer has raised concerns with height and projection of the proposal, this has been considered alongside the positive aspects of the scheme such as activating the arches, improved semi-public realm and overall pleasing design. Officers consider that the design of the proposal to include a new glazed curtain wall façade on the western elevation of the arches would read as a cohesive design and would respect the railway arch. It would also animate an inactive edge and increase passive surveillance. As such, it is considered that the design of the structure would be in accordance with the principles of LLP Policies Q5, Q6, Q7, Q8 and Q11.

10.24 Public Realm 10.25 One of the key general aspirations for the Waterloo Area as set out in the Local Plan (Policy PN1) and Waterloo SPD is to address existing problems of severance by increasing permeability throughout the area. The Waterloo SPD outlines the Railway Character Area and advises that this area is dominated by Waterloo Station and viaducts. The SPD seeks that development within this area should enhance pedestrian routes and the public realm. This goes hand in hand with activating arches and improved public realm. The Waterloo Opportunity Area Policy Framework (2007) supports this position and the executive summary begins with statement ‘To give Waterloo a new ‘City Square’ to create a radically improved public space; to improve permeability to and within the area and provide new development principally in the area around and above Waterloo Station’. Appendix 4 further outlines that improvements to pedestrian links along Upper Marsh were a priority. The proposal would upgrade surfaces in front of the new development which is currently tarmac, improving the immediate environment around the arches which complies with Policy ED5.

10.26 Design Officers however have raised concerns that the proposal retains gates at each end of the site; along Westminster Bridge Road and Upper Marsh and consider that gating this area is not within the spirit of the policy and does not seek to secure the wider ambitions for the area. They have commented that opening up this road to the general public would provide increased permeability; improving linkages between future major development coming forward to Waterloo Station in line with the Waterloo SPD and Waterloo Opportunity Area Policy Framework (2007). The activity and animation created by the proposed change of use will help with natural surveillance of the road and therefore the need for gates would not be necessary. Officers note that the applicant has previously expressed concerns regarding the safety of the students’ amenity area should the road become publicly accessible. Design Officers believe this could be resolved by securing the communal amenity area with a boundary.

10.27 The opening up of the service road which includes the ‘Safeguarded Land’ identified in the S106 agreement for application 12/04421/FUL would further meet the current requirements of Policy ED5(d) which requires applications affecting railway arches to improve the immediate environment around the arches, including the public realm. This is to include accessibility, safety, servicing and lighting appropriate to the location.

10.28 Officers agree with the Design Officers’ comments and note that agreement has been reached between the applicant and parties that have an interest in the land to enter into a section 106 obligation to provide for the opening up the service road and removal of the gates as outlined in paragraph 4.5 of this report. The imposition of a ‘Grampian’ condition is therefore recommended to prevent the application site development being occupied until the necessary planning obligation has been entered into in respect of the service road (as shown in Figure 11). This is proposed as Condition 3.

10.29 Furthermore, as one of the triggers to opening the service road (which sits within the ‘Safeguarded Land’) ties in with the potential adjacent Royal Street development (Strategic Site 1) (see Figure 12), the applicant has proposed that an Estate Coordination Management Plan be developed between parties who have an interest in the ‘Safeguarded Land’. Officers are therefore recommending provision for an Estate Coordination Management Plan between relevant landowning parties to be submitted to the Council for approval which will outline how the ‘Safeguarded Land’ will be managed and maintained by relevant landowners, including how anti-social behaviour will be monitored along the ‘Safeguarded Land’. The applicant has suggested that the Estate Coordination Management Plan covers a number of issues relating to the ongoing use of the service road. Officers do not consider that these issues are able properly to be addressed at this stage or that it is necessary to do so. They are recommending that a planning obligation is entered into that will require adherence to an approved Estate Coordination Management Plan and that the obligation will need to set out the agreed principles which any such Plan will need to address in respect of matters including the future use of the service road.

10.29 The proposed ground floor plan initially showed a division of the Urbanest amenity space area. Amended plans were received on 03.03.2020 with this fence removed. This is considered acceptable and would ensure that the landscaped area is useable and functional.

10.30 A relatively large refuse holding area is proposed close to the Lower Marsh and would be sited over an existing swale within the Urbanest amenity area. Further details would be secured by condition 11 to include how the area will be treated, its relationship with the swale and screening.

11 Amenity for Neighbouring Occupiers

11.1 Privacy and Outlook 11.2 The proposed office space would look towards Urbanest located 6.9m from the arches at the closest point. The approved floor plans of Urbanest (application ref: 12/04421/FUL) show that the approved floor space at ground and first floor facing the arches are in affordable workspace and college use. As such, there would be no loss of privacy or outlook to the residential element of the Urbanest scheme.

11.3 Noise and Vibration 11.4 An Environmental Noise Survey prepared by RBA Acoustics has been submitted and reviewed by the Council’s Environmental Health Consultants. The Consultants have advised that the Noise Survey identified that the development site will be impacted by high levels of environmental noise and vibration. Consultants have recommended conditions with respect to the internal noise environment of the proposed offices and building services plant and a condition is proposed to ensure these recommendations are implemented. Officers agree with the suggested condition and these have been added to the proposed decision notice as Condition 23.

11.5 Given the commercial nature of the surrounding location it is considered that the use of a B1 office is appropriate and would not be out of character or result in undue noise or disturbance impacts.

12 Designing Out Crime

12.1 London Plan 2015 Policy 7.3 states that development should amongst other things, reduce opportunities for crime and contribute to a sense of security in particular, well maintained routes, clear indication of spaces being private, semi-private or public and natural surveillance, encourage activity appropriate to the location, promote a sense of ownership of spaces, places and buildings, integrate security features into the design. Policy Q3 (Community safety) 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.

12.2 The application was referred to the Metropolitan Police Design out Crime advisor who raised no concerns regarding the proposed development. This is subject to a recommended conditions requiring the development to adhere to the principles of secured by design and advised that the application should benefit from the same standards, measures and principles applied to the Leake Street Tunnel Development.

12.3 The applicant advised in their consultation response of 19.03.2019 that they did not consider that a full secure-by design certification would be appropriate for the proposed development and noted that the Leake Street redevelopment involved a greater area and is a publicly accessible development incorporating thoroughfare and premises that are open late into the evening. The applicant argues that the proposed development is more modest and involves the refurbishment of the arches for office use within a private and access controlled site rather than a public thoroughfare.

12.4 Since the consultation response, the applicant has proposed the ‘opening up’ of the adjacent service road with the gates being open between the hours of 7am and 10pm as set out at paragraph 6.4 of the report. Once the Royal Street site has been developed, the applicant has proposed that these gates would be removed in their entirety. The southern-most arch adjacent Upper Marsh is partially used as an emergency escape route from Waterloo Station. The applicants are proposing to retain the emergency access and have specified a ‘no build zone’ adjacent the base of the staircase to ensure that there is no obstruction should an emergency arise. The ‘no build area’ will be secured by a planning obligation to ensure that emergency access is not obstructed. Noting this, the scheme would be publicly accessible due to the opening up of the adjacent service road, increasing the permeability of the arches, improving pedestrian linkages and the proposed conditions are considered to be acceptable, affording the scheme with security through design. On this basis, it is considered that the proposed development in consistent with the Council’s policies about community safety in Local Plan Policy Q3 and Officers have retained the suggested conditions 33 and 34 from the MET Police.

13 Transport

13.1 Site context 13.2 The application site is in close proximity to Waterloo Station and has a PTAL (Public Transport Accessibility Level) score of 6(b), which is considered excellent on a scale of 0-6, where 0 is considered ‘very poor’ and 6a/b is classified as ‘excellent’. Office users at the proposed development site would benefit from excellent access to local public/passenger transport services.

13.3 No new or amended pedestrian or vehicular access is proposed in the application, hence access arrangements remain as present from the service lane adjacent the arches. Access to the service lane is gained from Upper Marsh. To the west of the application site, the road divides into two branches; one branch linking directly onto Lambeth Palace Road to the west (restricted access) and the other providing access to Royal Street to the south. Upper Marsh also provides access to Westminster Bridge Road to the west of the Development, although vehicles are not permitted to turn into Upper Marsh from Westminster Bridge Road.

13.4 Trip Generation 13.5 Lambeth advises/uses a 12sqm per employee employment density which sets out the suggested space required in an office to support each employee as set out in the Employment and Skills SPD (2018). This suggests that approximately 196.5 employees will be working within the proposed B1 use, resulting in approximately 66 arrivals/departures in the morning and evening peaks, respectively. In a centrally and well-connected location such as this, particularly mindful of the highest possible PTAL rating, Transport Officers advise that the local highway/footway network will readily absorb any associated/projected increase of this level.

13.6 Car parking & servicing 13.7 A Controlled Parking Zone (CPZ) spans the Waterloo area within Lambeth. The CPZ for the area within which the Development is located is Waterloo ‘W’, which operates between 08:30 to 18:00 Monday to Friday and 08:30 to 13:00 on Saturdays. The nearest on-street pay and display and permit holder parking bays are located on Royal Street, to the south of the application site. Given the local high quality public transport links/provision and the need to reduce dependence on private car use in line with development plan policies the proposal will be secured as car-free. A car parking permit free agreement restricting employees from applying for on-street business parking permits would be secured by way of a planning obligation.

13.8 Whilst the development is required to be car-free (Draft London Plan Policy T6.2) adequate provision for disabled people/parking (Lambeth Local Plan Policy T7) should be made. The applicant has shown on the revised plans submitted on 17.01.2020 that 2 disabled car parking spaces are to be provided for the proposal. These are to be located along the adjacent service road. It is noted that the number of disabled car parking spaces would accord with the requirements of the current London Plan which requires a minimum of 2 spaces as per Table 6.2 of Policy 6.13 of the London Plan.

Figure 16: Table 6.2 of the London Plan setting out the disabled parking requirements for an office use.

13.9 The proposed 2 disabled parking spaces also meets the requirements of the Draft New London Plan (Figure 16) which requires that office uses provide a disabled parking spaces that equate to 5% of the overall parking provision. Noting that the application is car-free, the requirement for 2 disabled car parking spaces would meet the requirement (1 designated bay and 1 enlarged bay).

Figure 17: Table outlining the provision of disabled car parking spaces for office use under the Draft New London Plan.

13.10 Cycle Parking 13.11 The applicant is proposing to provide 58 long-stay cycle parking spaces and 10 short-stay cycle parking spaces for the office use. The cycle parking is to be located at ground floor level. The proposed cycle parking meets the London Plan requirements for B1 use as set out in Figure 18.

Figure 18: Current London Plan cycle parking requirements.

13.12 London Cycling Design Standards (LCDS) state that where cycle parking is inside a building, it should have step-free access, wide doorways and spacious corridors. Accessing the parking area should involve passing through no more than two sets of doors, with a recommended minimum external door width of 2 metres. Lifts or shallow gradient ramps should be provided to any basement cycle parking.

13.13 LCDS further states that cycle parking must be well located: close to the entrance of the property and avoiding obstacles such as stairs, multiple doors, narrow doorways (less than 1.2 metres wide) and tight corners. To accommodate all types of cycle, any lifts proposed lifts should have minimum dimensions of 1.2 by 2.3 metres, with a minimum door opening of 1000mm, and any door to a cycle parking area should be automated –push button or pressure pad operated.

13.14 The cycle parking will be provided via a variety of cycle stand types, including cradles, wishbones and hoops, to ensure a suitable provision of cycle parking is available on-site to cater for all types of cycles, including adapted cycles for disabled cyclists. Lambeth Transport Planning welcomes this. Additionally, the office will include showers, with changing facilities and lockers for use by employees.

13.15 The proposed cycle parking spaces for the office use meet the requirements for cycle parking set out in the draft new London Plan (Figure 19) which requires 1 long-stay space per every 70sqm of floor space (requires 33 cycle spaces) and 1 short-stay space for every 500sqm of floorspace up to 5000sqm (requires 4.95 cycle spaces).

Figure 19: Draft New London Plan cycle parking requirements for B1 Business uses.

13.16 Overall, the proposed cycle parking for the B1 office use meets the requirements of both the current and draft new London Plan and that of Policy T3 and Q13 of the Lambeth Local Plan (2015). TFL Road Network have no objection to the levels of cycle parking proposed for the office use.

13.17 Service and Delivery 13.18 Deliveries and refuse collection will be undertaken on-site, with deliveries by vehicles up to and including a 7.5T Box Van being accommodated on-site and allowing access and egress in forward gear. A Servicing & Delivery Plan is submitted in support of the application and this reflects discussion Lambeth Transport Planning has had with the applicant during pre-application stages. This is welcomed and presents there most appropriate fork of servicing for this site. Transport Officers have reviewed the supporting swept-path (vehicular tracking) drawings and the proposed manoeuvres associated with arriving/departing vehicles appear to be acceptable.

13.19 It is also noted that industry standard data (TRAVL/TRICS) assumes 0.25 deliveries per 100sqm (GEA), therefore, the proposed 3,921sqm (GEA) office development will generate approximately 9 – 10 deliveries per day, all of which will be undertaken on-site. It is concluded this will not have a severe (or notable even) impact on the free flow of traffic on the surrounding road network. TFL Road Network have advised that the Service and Delivery Plan (prepared by Caneparo Associates – February 2020). TFL have suggested that should the application be permitted, that a full Delivery and Servicing Plan be secured by condition in accordance with draft London Plan Policy T7 and Policy T6 and T8 of the Lambeth Local Plan (2015). Officers agree that a full, updated Service and Delivery Plan should be submitted and this has been secured as Condition 7.

13.20 Refuse and Recycling 13.21 The applicant has proposed a dedicated refuse and recycling store within the office at ground floor level. Waste is proposed to be consolidated in 1,100 wheeled bins. Waste will be collected from the office units daily or multiple times a day (as required) and taken to the dedicated waste storage area. The submitted Operational Waste Strategy (December 2018) document outlines that the store will be designed to BS5906:2005 Waste Management in Buildings – Code of Practice. Full details of servicing, delivery and waste management have been requested as Condition 7 of the draft decision notices.

13.22 The Operational Waste Strategy (December 2018) estimates that the office use would generate 8,323L of waste per week (5,576L of refuse and 2,747L of recycling). Based on this, the waste store would require 3x 1,100L refuse bins and 2x 1,100L recycling bins – 5 bins total.

13.23 The bins will be delivered to the waste collection point (see Figure 20) on the nominated collection days and collected by waste collection operatives.

Figure 20: Location of waste collection point adjacent Upper Marsh.

13.24 Veolia Waste and Lambeth Transport Officers both have raised no objections to the proposed refuse and recycling servicing. Full details of the proposed waste collection point will be required to be submitted to ensure that the store meets the requirements of “Waste & Recycling Storage & Collection Requirements – Technical Specification for Architects & Developers (October 2013)” and accords with the principles of Policies T6, T8 and Q12 of the Lambeth Local Plan (2015).

Figure 21: Swept path assessment of refuse vehicles servicing the waste collection point.

13.25 Construction and Logistics Plan 13.26 Local Plan Policy T8(d) 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.

13.27 TFL Road Network have reviewed the Draft Construction Management Plan (19th December 2018) and requested that a full Construction Logistics Plan be secured by condition and that this should be prepared in line with TfLs latest guidance, and should include details of construction vehicle routing, alongside the expected number, frequency and types of vehicles that will be entering the site during construction works. This is considered acceptable and has been added to the draft decision notice as Condition 5.

13.28 It is noted that the Air Quality Officer has requested that Section 6.1 of the submitted Air Quality Assessment (December 2018) titled ‘Construction’ should be incorporated into the CLP. This is acceptable and has been added into the details of Condition 5.

14 Sustainable Design and Construction 14.1 Carbon Reductions and BREEAM

14.2 Non-residential developments should also be accompanied by a pre-assessment, demonstrating how the following BREEAM standards, or any future replacement standards, will be met. Policy EN4(b) (i) states that all new non-residential development and non-self-contained residential accommodation, should meet at least BREEAM ‘Excellent’ unless it is demonstrated that it is not technically feasible or viable to do so, in which case proposals should demonstrate a ‘Very Good’ rating with a minimum score of 63 per cent.

14.3 London Plan Policy 5.2 requires that major development should provide a detailed energy assessment to demonstrate that the targets for carbon dioxide emissions reduction of 35% over Part L of the Building regulations for non-residential buildings can be met. The policy further notes that should the carbon reduction targets not be met onsite, any shortfall may be provided off-site or through a cash in lieu contribution to be ring fenced to secure the delivery of carbon dioxide savings elsewhere.

14.4 The Council’s Sustainability Consultant advised the application fails to meet the minimum 35% reduction in CO2 emissions over Part L of the Building Regulations (2013), only meeting a target of 17.5%. However, the consultant has noted that whilst the proposal does not meet the policy requirement reduction of 35%, the applicant has done everything possible to maximise the carbon reduction of the scheme (providing high levels of thermal insulation, selecting glass that will provide adequate levels of solar control and light transmittance, AHSP systems, energy efficient light fittings and external lighting systems that are controlled by a timer). Noting this, the Sustainability Consultant has recommended that in the event of a permission, that design stage and as-built calculations are submitted to ensure that the development has achieved the 17.5% reduction as outlined in the Energy and Sustainability Statement. This is acceptable and would accord with the principles of Policies 5.2 and 5.7 of the London Plan (2015).

14.5 Noting that the proposal does not meet the requirement of 35% reduction in carbon emissions, the applicants are required to provide a cash in lieu payment for carbon off-setting. The Council’s Sustainability Consultant advised that this was not addressed in the submitted Energy and Sustainability Statement. The applicant provided a ‘Consultation Response Schedule’ on 19.03.2019 which advised that the rate for carbon offsetting tax as recommended by the Sustainable Design and Construction SPG to the London Plan is £60 per tCO2 per year over a period of 30 years and should be calculated in comparison to a building achieving 35% carbon reduction. Using these rates, the total estimated cash in lieu payment for the development would be £29,800. The financial contribution would accord with the requirements of Policy 5.2 of the London Plan and will be secured through a Section 106 agreement.

14.6 Local Plan Policy EN3 states that all major development will be expected to connect to, and where appropriate extend, existing decentralised heating, cooling or power networks in the vicinity of the site, unless a feasibility assessment demonstrates that connection is not reasonably possible. Major development proposals that cannot immediately connect to an existing heating or cooling network should evaluate the feasibility of combined heat and power (CHP) systems and where appropriate, examine the feasibility of extending the system beyond the site boundary.

14.7 The submitted Energy and Sustainability Statement has been reviewed by the Council’s Sustainability Consultants who have noted that the applicants have made provisions to connect to a decentralised network if it becomes operational in the future. The Consultant requested further information on how the development will have the capability to connect to a future planned decentralized network and has suggested that this could be addressed through a pre-commencement condition. Further information has been provided by the applicant on 19.03.2019 with an amended plan (00)_P100 rev P01 outlining where the potential connections to the network could be undertaken. The plan shows the site location and distance to the potential district heating network, a floor plan identifying the space allowance for future capped-off connection and valved pipework and a more detailed LTHW schematic. The Sustainability Consultant has advised that the applicant had specifically responded to the request for additional information on the proposed connection to the SPEG network by providing plans of the proposed technology and as such, this element of the scheme was satisfactory and no condition was required.

15 Other Environmental Matters

15.1 Flood Risk 15.1.1 The site is in Flood Zone 3 and is located within an area benefitting from flood defences. Whilst the site is protected by the River Thames tidal flood defences up to a 1 in 1000 (0.1%) chance in any year, the Environment Agency (EA) have commented that their most recent flood modelling (December 2017) shows that the site is at risk if there was to be a breach in the defences.

15.1.2 The EA have reviewed the submitted Flood Risk Assessment (FRA) by WSP (dated January 2019 with reference 70052923 DI-001) provides an accurate assessment of the tidal and fluvial flood risks associated with the proposed development.

15.1.3 The EA advise that the site is located over a Secondary Aquifer. The EA note that the submitted ‘preliminary environmental risk assessment desk study’ document by WSP (dated December 2018 with reference 70052923GEO) has indicated the potential for historic ground contamination to be present and has recommended an intrusive investigation to assess this situation. The EA have recommended 5 conditions relating to the protection of the secondary aquifer and ensuring that there is no contamination of groundwater. These conditions are considered acceptable and have been added to the decision notice as Conditions 25-29.

15.1.4 Lambeth’s Flood Risk Officers have advised that there is no objection to the proposal noting that the proposal will utilise and existing Sustainable Drainage System that has been designed to accept flows from this development.

15.1.5 Overall, the proposal would accord with Policies EN5 and EN6 of the Lambeth Local Plan (2015) and Policies 5.3 and 5.12 of the London Plan.

15.2 Air Quality 15.2.1 The application has been supported by an air quality assessment as required for all major developments in the borough. The proposed development is a major development located within a borough-wide Air Quality Management Area (AQMA), within 400m of a GLA-designated Air Quality Focus Area (area of high pollution combined with high exposure) of Waterloo Road and in Central Activities Zone for the purpose of Non-Road Mobile Machinery Low Emission Zone requirements. It is located in an area where Air Quality Objectives for nitrogen dioxide NO2 are exceeded (both annual mean and predicted hourly mean) and in the immediate vicinity of St. Thomas’ Hospital and a number of residential properties, all classed as sensitive receptors to air pollutants.

15.2.2 The development is proposed to be car-free, with limited number of daily servicing and delivery trips. The development does not include static combustion plant. Instead, electric air source heat pumps will provide building heating and cooling. Officers commend this approach and welcome the proposal from the air quality perspective.

Air Quality Impacts from Demolition and Construction 15.2.3 The Air Quality Assessment’s conclusion that the site is Medium Risk in respect of demolition and Low Risk in respect of earthwork, construction and trackout is accepted. As the classification falls between two categories Officers accept that the site is Medium Risk overall.

15.2.4 Construction impacts mitigation measures proposed in the AQA, which are based on the Control of Dust and Emissions during Construction and Demolition SPG 2014, are accepted.

15.2.5 Air Quality Officers have reviewed the draft Construction Management Plan (CMP) and have found limited air quality and dust mitigation measures in section 4.2 Air Pollution, Dust and Dirt Control. Officers request that mitigation measures listed in the AQA section 6.1 Construction are included in the final CMP. As the measures in AQA area based on the Control of Dust and Emissions during Construction and Demolition SPG 2014, Officers would refer the Applicant to Appendix 7 of the SPG which contains a list of recommended and desirable measures. The site is classified as Medium Risk overall.

15.2.6 Due to the presence of sensitive receptors in the vicinity of the area, the Applicant is encouraged to install green hoardings/walls and other vegetation around the construction site to minimise the impact of dust and pollution and also to improve the local environment during construction.

Air Quality Impacts During Operation, including Air Quality Neutral Assessments

15.2.7 As the development is car-free and the TEB calculations related to servicing and delivery trips are accepted, the site is Air Quality Neutral in terms of Transport.

15.2.8 As the proposed development will be heated and cooled using electric air source heat pumps and there will be no on-site static combustion plant, the conclusion that the air quality neutrality in terms of building emissions is not relevant to this development is accepted and it may be concluded that the development is therefore Air Quality Neutral in terms of Building emissions. In addition, air intakes are proposed on the western façade - avoiding Westminster Bridge Road where air pollutant, particularly concentrations are likely to be highest.

15.2.9 No other air quality impacts of the development and on the development have been identified. Emissions from the nearby railway lines are considered negligible given the development’s location, design and the proposed office use. Officers are therefore satisfied that the scheme would accord with the aims of Policy 7.14 of the London Plan.

16 Employment and Training 16.1 Policy ED14 of the Lambeth Local Plan states that planning obligations should be used to secure employment opportunities and apprenticeships arising from major developments, so that local residents are given access to the right skills training so that they can take advantage of opportunities created by new development. The SPD on Employment and Skills (2018) sets out a ‘headline’ target of 25% of jobs generated by developments as being for local residents. The SPD envisages that an applicant will be asked to work towards delivery of that target through the carrying out of an approved employment and skills plan, which would be designed so as to include the intended target numbers and types of job opportunities. The SPD envisages an element of flexibility in how the applicant may agree to work towards delivery of employment and skills obligations, for example as regards the target mix of jobs, apprenticeships and/or bespoke employment training and support arrangements. The employment and skills plan should also set out how the applicant will aim to deliver young people’s training and careers initiatives. The SPD also envisages the possibility in individual cases of an applicant making a payment in lieu rather than seeking to deliver employment and skills obligations ‘in kind’ and the SPD sets out the broad basis on which such payment would be calculated.

16.2 The application has been reviewed by the Employment and Skills Team who have requested that an Employment and Skills Plan is produced for both the construction and end phase of the development and a financial contribution towards local employment and training be secured. Based on the applicant’s figures, the following contribution is to be secured through a planning obligation:

2,358 sqm(NIA) / 12 sqm per job for B1 office = 196.5 jobs

(2,358/12) x 25% x 17.8% x £6,500 = £56,838.

16.3 LLP Policy ED14 (c) states that the Council will work with local training providers and aim to ensure that local residents are given access to the right skills training so that they can take advantage of opportunities create by new development. The financial contribution of £56,838 is directly linked to this part of Policy ED14 and would ensure that the training referred to in the policy is able to be funded.

17 Accessibility 17.1 Access to the site is gained from the service road adjacent the arches. Lifts are proposed in the reception area to give access to the raised ground floor and another lift is proposed to enable access from the ground floor to the mezzanine floor. Both the ground floor and mezzanine floor contain a bathroom that would allow for wheelchair access. As such, the proposal accords with Policy Q1 of the Lambeth Local Plan (2015).

18 Planning Obligations and CIL

Planning Obligations 18.1 The LLP Policy D4 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 Development Viability SPD (adopted 2017) and the Employment and Skills SPD (adopted 2018).

18.2 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.

18.3 The proposed obligations to be secured are as follows:

Item Details Carbon offsetting  Payment of £29,800 to achieve zero carbon Employment and Skills  Employment and Skills Plan for both the construction and end phase;  Financial contribution of £56,838. Service road (to be addressed via amendment to  Provision for opening up of the service road to existing S106 obligation relating to the adjoining provide for pedestrian use of the service road development and through any necessary and to limit vehicular access accordingly as set ‘mirroring’ of that amended obligation in relation to out in paragraph 4.5. the proposed development) Affordable Workspace  Secure the B1 floorspace as affordable workspace subject to the cascade mechanism as set out in paragraph 9.2.7.

Transport  Parking permit free designation for business/employees

To be included in relation to the Estate  Obligation that requires adherence to terms of Coordination Management Plan via amendment an approved Estate Coordination Management to existing S106 obligation relating to the Plan for the Safeguarded Land and sets out the adjoining development and through any agreed principles which any such Plan will need necessary ‘mirroring’ of that amended obligation to address in respect of matters including the in relation to the proposed development future use of the service road Other  Ensure ‘no build zone’ remains clear to ensure no obstruction in an emergency from Waterloo Station  Monitoring fee of up to 5% of the total financial obligations

CIL 18.4 If the application is approved and the development is implemented, a liability to pay the Lambeth Community Infrastructure Levy (CIL) will arise.

18.5 The Lambeth CIL contribution is estimated, on the basis of information supplied with the planning application to be £646,164.23. This figure is subject to indexation which will be charged at the date of the decision. 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.

18.6 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.

18.7 The Mayoral CIL2 contribution is estimated, on the basis of the information provided with the planning application, to be approximately £686,370.00.

19 CONCLUSION 19.1 The application would activate arches to provide much needed office space within the Waterloo Opportunity Area and CAZ, including affordable workspace in line with emerging Local Plan policy. The proposal would result in improved pedestrian access linkages within Waterloo. The proposal would not result in significant amenity or transport impacts to surrounding sensitive properties or road networks. Furthermore, the proposal accords with design, flooding, air quality, contamination and sustainability matters.

19.2 The conditions and informatives recommended by officers are set out in the Draft Decision Notice (Appendix 1). The proposed conditions are considered necessary to make the application acceptable in planning terms.

19.3 Officers consider that the development would comply with the development plan for the Borough and there are no material considerations of sufficient weight that would dictate that the application should otherwise be refused. Officers are therefore recommending approval of the scheme, subject to conditions in accordance with the presumption in favour of sustainable development conferred upon local planning authorities by the NPPF.

20 EQUALITY DUTY AND HUMAN RIGHTS

20.1 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).

20.2 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 have 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.

20.3 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.

21 RECOMMENDATION 21.1 Resolve to grant planning permission subject to the conditions as set out in the report and subject to the completion of an agreement under Section 106 of the Town and Country Planning Act 1990 to secure the planning obligations listed in this report.

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

a. Finalise the recommended conditions as set out in this report; and b. Negotiate, agree and finalise the planning obligations as set out in this report pursuant to Section 106 of the Town and Country Planning Act.

21.3 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 proposed planning obligations set out in the 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.

21.4 In the event that the Section 106 Agreement is not completed within six 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.

APPENDICES

Appendix 1: Draft Decision Notice

Appendix 2: List of consultees (statutory and Other Consultees)

Conservation & Urban Design

Planning Policy

TFL Road Network Development (non-referable)

Transport Lambeth

Veolia Waste Lambeth Planning App

Ward Councillors

Regeneration Team Bishop Ward

Network Rail

Design Out Crime Officer

Building Control

Enterprise, Employment And Skills

Highway Team Lambeth

Parks & Open Spaces Bioregional

Flooding - SUDS

Environment Agency

Historic England - Archaeology

London Ecology Unit

Development Control Department Thames Water

Sewers Major Development (20+) Thames Water

LBL Noise Pollution

South Bank And Waterloo Neighbours

L.F.C.D Authority

Association of Waterloo Groups

Lambeth Estates Residents Association

South Bank Employers Group

Waterloo Community Development Group

Kennington Association Planning Forum

Friends Of Hatfield Green

Friends Of Archbishop's Park

Kennington Oval & Vauxhall Forum

Kennington Park Road Residents' Association

We Are Waterloo

Sustainability Team On Air Quality

Friends Of Lambeth High Street Rec

Friends Of St John's Churchyard

Southbank & Waterloo Forum

Neighbourhood Regeneration Project Manager

Westminster Square Residents' Association

EHST Land Contamination

Cleaver Square, Cleaver Street , Bowden St

Friends Of Jubilee Gardens

List of Neighbours Consulted

Flat 312 203 Westminster Bridge Road London SE1 7FR

Flat 307 203 Westminster Bridge Road London SE1 7FR

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Residential Accommodation The Walrus Social 172 Westminster Bridge Road London SE1 7RW

First Floor 142 Lower Marsh London SE1 7AE

Build Studios 203 Westminster Bridge Road London SE1 7FR

DLD College London 199 Westminster Bridge Road London SE1 7FX

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Flat 311 203 Westminster Bridge Road London SE1 7FR

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Arches 216 To 218 Upper Marsh London SE1 7EL

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Flat 1102 203 Westminster Bridge Road London SE1 7FS

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Flat 717 203 Westminster Bridge Road London SE1 7FR

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Flat 1820 203 Westminster Bridge Road London SE1 7FU

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Flat 512 203 Westminster Bridge Road London SE1 7FR

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Flat 317 203 Westminster Bridge Road London SE1 7FR

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Flat 310 203 Westminster Bridge Road London SE1 7FR

1 Carlisle Lane London SE1 7LH

141 Westminster Bridge Road London SE1 7HR

Tenth Floor Becket House 1 Lambeth Palace Road London SE1 7EU

Sixth - Eighth Floors Becket House 1 Lambeth Palace Road London SE1 7EU

Eleventh Floor Becket House 1 Lambeth Palace Road London SE1 7EU

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Flat 705 203 Westminster Bridge Road London SE1 7FR

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Flat 1832 203 Westminster Bridge Road London SE1 7FU

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Flat 516 203 Westminster Bridge Road London SE1 7FR

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Flat 1804 203 Westminster Bridge Road London SE1 7FU

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Flat 318 203 Westminster Bridge Road London SE1 7FR

Flat 315 203 Westminster Bridge Road London SE1 7FR

Flat 309 203 Westminster Bridge Road London SE1 7FR

Flat 305 203 Westminster Bridge Road London SE1 7FR

Arches 219 To 220 Upper Marsh London SE1 7EL

141 Lower Marsh London SE1 7AE

Second Floor Becket House 1 Lambeth Palace Road London SE1 7EU

Fifth Floor Becket House 1 Lambeth Palace Road London SE1 7EU

Third Floor Becket House 1 Lambeth Palace Road London SE1 7EU

Flat 1607 203 Westminster Bridge Road London SE1 7FU

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Flat 1118 203 Westminster Bridge Road London SE1 7FS

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Flat 716 203 Westminster Bridge Road London SE1 7FR

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Flat 1810 203 Westminster Bridge Road London SE1 7FU

Flat 606 203 Westminster Bridge Road London SE1 7FR

Flat 514 203 Westminster Bridge Road London SE1 7FR

Flat 410 203 Westminster Bridge Road London SE1 7FR

Flat 1715 203 Westminster Bridge Road London SE1 7FU

Flat 306 203 Westminster Bridge Road London SE1 7FR

The Walrus Social 172 Westminster Bridge Road London SE1 7RW

Arches 222A B And C Upper Marsh London SE1 7EL

Flat 1608 203 Westminster Bridge Road London SE1 7FU

Flat 1515 203 Westminster Bridge Road London SE1 7FT

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Flat 604 203 Westminster Bridge Road London SE1 7FR

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Flat 314 203 Westminster Bridge Road London SE1 7FR

Flat 303 203 Westminster Bridge Road London SE1 7FR

Third Floor 142 Lower Marsh London SE1 7AE

Arches 206 To 207 Carlisle Lane London SE1 7LH

Arch 205 Carlisle Lane London SE1 7LH

Ground Floor Becket House 1 Lambeth Palace Road London SE1 7EU

Flat 1612 203 Westminster Bridge Road London SE1 7FU

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Flat 714 203 Westminster Bridge Road London SE1 7FR

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Flat 1827 203 Westminster Bridge Road London SE1 7FU

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Flat 605 203 Westminster Bridge Road London SE1 7FR

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Flat 405 203 Westminster Bridge Road London SE1 7FR

Flat 403 203 Westminster Bridge Road London SE1 7FR

Flat 313 203 Westminster Bridge Road London SE1 7FR

Ninth Floor Becket House 1 Lambeth Palace Road London SE1 7EU

First Floor Becket House 1 Lambeth Palace Road London SE1 7EU

Flat 1422 203 Westminster Bridge Road London SE1 7FT

Flat 1609 203 Westminster Bridge Road London SE1 7FU

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Flat 1521 203 Westminster Bridge Road London SE1 7FT

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Flat 602 203 Westminster Bridge Road London SE1 7FR

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Second Floor 142 Lower Marsh London SE1 7AE

31 Stangate Royal Street London SE1 7EQ

53 Canterbury House Royal Street London SE1 7LW

24 Stangate Royal Street London SE1 7EQ

52 Canterbury House Royal Street London SE1 7LW

44 Stangate Royal Street London SE1 7EQ

16 Stangate Royal Street London SE1 7EQ

42 Stangate Royal Street London SE1 7EQ

72 Canterbury House Royal Street London SE1 7LW

23 Canterbury House Royal Street London SE1 7LN

56 Canterbury House Royal Street London SE1 7LW

47 Canterbury House Royal Street London SE1 7LW

58 Canterbury House Royal Street London SE1 7LW

57 Canterbury House Royal Street London SE1 7LW

14 Canterbury House Royal Street London SE1 7LN

20 Stangate Royal Street London SE1 7EQ

69 Canterbury House Royal Street London SE1 7LW

67 Canterbury House Royal Street London SE1 7LW

54 Canterbury House Royal Street London SE1 7LW

48 Stangate Royal Street London SE1 7EQ

46 Stangate Royal Street London SE1 7EQ

36 Canterbury House Royal Street London SE1 7LN

29 Stangate Royal Street London SE1 7EQ

50 Canterbury House Royal Street London SE1 7LW

Day Nursery Canterbury House Royal Street London SE1 7LN

11 Stangate Royal Street London SE1 7EQ

22 Canterbury House Royal Street London SE1 7LN

1 Stangate Royal Street London SE1 7EQ

40 Canterbury House Royal Street London SE1 7LN

71 Canterbury House Royal Street London SE1 7LW

22 Stangate Royal Street London SE1 7EQ

52 Stangate Royal Street London SE1 7EQ

8 Stangate Royal Street London SE1 7EQ

6 Stangate Royal Street London SE1 7EQ

5 Stangate Royal Street London SE1 7EQ

49 Canterbury House Royal Street London SE1 7LW

38 Stangate Royal Street London SE1 7EQ

34 Canterbury House Royal Street London SE1 7LN

66 Canterbury House Royal Street London SE1 7LW

35 Canterbury House Royal Street London SE1 7LN

12 Canterbury House Royal Street London SE1 7LN

21 Canterbury House Royal Street London SE1 7LN

45 Stangate Royal Street London SE1 7EQ

4 Canterbury House Royal Street London SE1 7LN

37 Stangate Royal Street London SE1 7EQ

18 Stangate Royal Street London SE1 7EQ

73 Canterbury House Royal Street London SE1 7LW

65 Canterbury House Royal Street London SE1 7LW

47 Stangate Royal Street London SE1 7EQ

8 Canterbury House Royal Street London SE1 7LN

9 Stangate Royal Street London SE1 7EQ

41 Canterbury House Royal Street London SE1 7LW

11 Canterbury House Royal Street London SE1 7LN

5 Canterbury House Royal Street London SE1 7LN

38 Canterbury House Royal Street London SE1 7LN

13 Canterbury House Royal Street London SE1 7LN

33 Stangate Royal Street London SE1 7EQ

6 Canterbury House Royal Street London SE1 7LN

24 Canterbury House Royal Street London SE1 7LN

32 Stangate Royal Street London SE1 7EQ

51 Stangate Royal Street London SE1 7EQ

41 Stangate Royal Street London SE1 7EQ

35 Stangate Royal Street London SE1 7EQ

43 Stangate Royal Street London SE1 7EQ

17 Stangate Royal Street London SE1 7EQ

12 Stangate Royal Street London SE1 7EQ

63 Canterbury House Royal Street London SE1 7LW

60 Canterbury House Royal Street London SE1 7LW

29 Canterbury House Royal Street London SE1 7LN

18 Canterbury House Royal Street London SE1 7LN

16 Canterbury House Royal Street London SE1 7LN

28 Stangate Royal Street London SE1 7EQ

2 Stangate Royal Street London SE1 7EQ

25 Canterbury House Royal Street London SE1 7LN

30 Stangate Royal Street London SE1 7EQ

4 Stangate Royal Street London SE1 7EQ

1 Royal Street London SE1 7LL

34 Stangate Royal Street London SE1 7EQ

10 Stangate Royal Street London SE1 7EQ

21 Stangate Royal Street London SE1 7EQ

76 Canterbury House Royal Street London SE1 7LW

74 Canterbury House Royal Street London SE1 7LW

2 Canterbury House Royal Street London SE1 7LN

9 Canterbury House Royal Street London SE1 7LN

7 Canterbury House Royal Street London SE1 7LN

45 Canterbury House Royal Street London SE1 7LW

19 Canterbury House Royal Street London SE1 7LN

15 Canterbury House Royal Street London SE1 7LN

36 Stangate Royal Street London SE1 7EQ

3 Stangate Royal Street London SE1 7EQ

46 Canterbury House Royal Street London SE1 7LW

48 Canterbury House Royal Street London SE1 7LW

27 Stangate Royal Street London SE1 7EQ

13 Stangate Royal Street London SE1 7EQ

23 Stangate Royal Street London SE1 7EQ

43 Canterbury House Royal Street London SE1 7LW

51 Canterbury House Royal Street London SE1 7LW

10 Canterbury House Royal Street London SE1 7LN

42 Canterbury House Royal Street London SE1 7LW

20 Canterbury House Royal Street London SE1 7LN

40 Stangate Royal Street London SE1 7EQ

14 Stangate Royal Street London SE1 7EQ

1 Canterbury House Royal Street London SE1 7LN

68 Canterbury House Royal Street London SE1 7LW

39 Canterbury House Royal Street London SE1 7LN

19 Stangate Royal Street London SE1 7EQ

33 Canterbury House Royal Street London SE1 7LN

44 Canterbury House Royal Street London SE1 7LW

62 Canterbury House Royal Street London SE1 7LW

15 Stangate Royal Street London SE1 7EQ

50 Stangate Royal Street London SE1 7EQ

7 Stangate Royal Street London SE1 7EQ

39 Stangate Royal Street London SE1 7EQ

27 Canterbury House Royal Street London SE1 7LN

17 Canterbury House Royal Street London SE1 7LN

28 Canterbury House Royal Street London SE1 7LN

32 Canterbury House Royal Street London SE1 7LN

49 Stangate Royal Street London SE1 7EQ

3 Canterbury House Royal Street London SE1 7LN

61 Canterbury House Royal Street London SE1 7LW

55 Canterbury House Royal Street London SE1 7LW

25 Stangate Royal Street London SE1 7EQ

77 Canterbury House Royal Street London SE1 7LW

59 Canterbury House Royal Street London SE1 7LW

75 Canterbury House Royal Street London SE1 7LW

37 Canterbury House Royal Street London SE1 7LN

26 Stangate Royal Street London SE1 7EQ

26 Canterbury House Royal Street London SE1 7LN

70 Canterbury House Royal Street London SE1 7LW

64 Canterbury House Royal Street London SE1 7LW

31 Canterbury House Royal Street London SE1 7LN

30 Canterbury House Royal Street London SE1 7LN

Fourth Floor Becket House 1 Lambeth Palace Road London SE1 7EU

Flat 1601 203 Westminster Bridge Road London SE1 7FU

Flat 1505 203 Westminster Bridge Road London SE1 7FT

Flat 1502 203 Westminster Bridge Road London SE1 7FT

Flat 1418 203 Westminster Bridge Road London SE1 7FT

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Flat 1120 203 Westminster Bridge Road London SE1 7FS

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Flat 911 203 Westminster Bridge Road London SE1 7FS

Flat 907 203 Westminster Bridge Road London SE1 7FS

Flat 816 203 Westminster Bridge Road London SE1 7FS

Flat 710 203 Westminster Bridge Road London SE1 7FR

Flat 707 203 Westminster Bridge Road London SE1 7FR

Flat 617 203 Westminster Bridge Road London SE1 7FR

Flat 612 203 Westminster Bridge Road London SE1 7FR

Flat 1834 203 Westminster Bridge Road London SE1 7FU

Flat 1831 203 Westminster Bridge Road London SE1 7FU

Flat 1822 203 Westminster Bridge Road London SE1 7FU

Flat 1806 203 Westminster Bridge Road London SE1 7FU

Flat 601 203 Westminster Bridge Road London SE1 7FR

Flat 411 203 Westminster Bridge Road London SE1 7FR

Flat 1805 203 Westminster Bridge Road London SE1 7FU

Flat 1802 203 Westminster Bridge Road London SE1 7FU

Arches 228 To 232 Waterloo Station Approach London SE1 7LY

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

NPPF 2019

Lambeth Local Plan (2015) policies: D1 Delivery and monitoring D2 Presumption in favour of sustainable development D3 Infrastructure D4 Planning obligations D5 Enforcement H1 Maximising housing growth H2 Delivering affordable housing H3 Safeguarding existing housing H4 Housing mix in new developments H5 Housing standards H6 Residential conversions H7 Student housing H8 Housing to meet specific community needs H9 Hostels and houses in multiple occupation H10 Gypsy and traveller needs ED1 Key Industrial and Business Areas (KIBAs) ED2 Business, industrial and storage uses outside KIBAs ED3 Large offices (greater than 1,000 m2) ED4 Work-live development ED5 Railway arches ED6 Town centres ED8 Public houses ED9 A2 uses ED10 Local centres and dispersed local shops ED11 Visitor attractions, leisure, arts and culture uses ED12 Hotels and other visitor accommodation ED13 Markets ED14 Employment and training S1 Safeguarding existing community premises S2 New or improved community premises S3 Schools T1 Sustainable travel T2 Walking T3 Cycling T4 Public transport infrastructure T5 River transport T6 Assessing impacts of development on transport capacity T7 Parking T8 Servicing T9 Minicabs, taxis and private hire vehicles T10 Telecommunications EN1 Open space and biodiversity EN2 Local food growing and production EN3 Decentralised energy EN4 Sustainable design and construction EN5 Flood risk 106 EN6 Sustainable drainage systems and water management EN7 Sustainable waste management Q1 Inclusive environments Q2 Amenity Q3 Community safety Q4 Public art Q5 Local distinctiveness Q6 Urban design: public realm Q7 Urban design: new development Q8 Design quality: construction detailing Q9 Landscaping Q10 Trees Q11 Building alterations and extensions Q12 Refuse/recycling storage Q13 Cycle storage Q14 Development in gardens and on backland sites Q15 Boundary treatments Q16 Shop fronts Q17 Advertisements and signage Q18 Historic environment strategy Q19 Westminster World Heritage Site Q20 Statutory listed buildings Q21 Registered parks and gardens Q22 Conservation areas Q23 Undesignated heritage assets: local heritage list Q24 River Thames Q25 Views PN1 Waterloo

Draft Revised Lambeth Local Plan (2018) policies: Policy D1 Delivery and monitoring Policy D2 Presumption in favour of sustainable development Policy D4 Planning Obligations Policy ED1 Offices (B1a) Policy ED2 Affordable Workspace Policy ED6 Railway Arches Policy ED7 Town centres Policy ED15 Employment and training Policy T1 Sustainable travel Policy T3 Cycling Policy T7 Parking Policy T8 Servicing Policy T10 Digital connectivity infrastructure Policy EN3 Decentralised energy Policy EN4 Sustainable design and construction Policy EN5 Flood risk Policy EN6 Sustainable drainage systems and water management Policy EN7 Sustainable waste management Policy Q1 Inclusive environments Policy Q2 Amenity Policy Q3 Safety, crime prevention and counter terrorism Policy Q4 Public Art Policy Q5 Local distinctiveness Policy Q6 Urban design: public realm Policy Q7 Urban design: new development Policy Q9 Landscaping Policy Q12 Refuse/recycling storage Policy Q13 Cycle storage Policy Q15 Boundary Treatments Policy Q17 Advertisements and signage Policy Q22 Conservation Areas Policy Q3 Non-designated heritage assets: local heritage list Policy Q25 Local views Policy PN1 Waterloo and South Bank

South Bank and Waterloo Neighbourhood Plan (2019) policies: Policy P2 – Publically accessible open space Policy P4 – Amenity in public space Policy P5 – Air Quality Policy P12 – Office or workspace schemes

London Plan (2016) Policy 1.1 Delivering the strategic vision and objectives for London Policy 2.10 Central Activities Zone – Strategic priorities Policy 2.11 Central Activities Zone – Strategic functions Policy 2.12 Central Activities Zone – predominately local activities Policy 2.13 Opportunity Areas and Intensification Areas Policy 2.15 Town Centres Policy 4.2 Offices Policy 4.3 Mixed use development and offices Policy 5.1 Climate change mitigation Policy 5.2 Minimising carbon dioxide emissions Policy 5.3 Sustainable design and construction Policy 5.5 Decentralised energy networks Policy 5.6 Decentralised energy in development proposals Policy 5.9 Overheating and cooling Policy 5.12 Flood risk management Policy 5.13 Sustainable drainage Policy 5.14 Water quality and wastewater infrastructure Policy 5.15 Water use and supplies Policy 5.21 Contaminated land Policy 6.3 Assessing effects of development on transport capacity Policy 6.9 Cycling Policy 6.10 Walking Policy 6.13 Parking Policy 7.2 An inclusive environment Policy 7.3 Designing out crime Policy 7.4 Local character Policy 7.5 Public realm Policy 7.6 Architecture Policy 7.8 Heritage assets and archaeology Policy 7.11 London View Management Framework Policy 7.14 Improving air quality Policy 7.15 Reducing and managing noise, improving and enhancing the acoustic environment and promoting appropriate soundscapes

Draft New London Plan (2017) Policy SD1 Opportunity Areas Policy SD4 The Central Activities Zone Policy SD5 Offices, other strategic functions and residential development in the CAZ Policy SD6 Town centres Policy D2 Delivering good design Policy D3 Inclusive design Policy D7 Public Realm Policy D13 Noise Policy E1 Offices Policy E2 Low-cost business space Policy E3 Affordable Workspace Policy HC1 Heritage conservation and growth Policy HC4 London View Management Framework Policy HC5 Supporting London’s culture and creative industries Policy G1 Green Infrastructure Policy SI1 Improving air quality Policy SI2 Minimising greenhouse gas emissions Policy SI3 Energy Infrastructure Policy SI6 Digital connectivity infrastructure Policy SI7 Reducing Waste and supporting the circular economy Policy SI8 Waste capacity and net waste self-sufficiency Policy SI12 Flood Risk management Policy SI13 Sustainable drainage Policy T1 Strategic approach to transport Policy T4 Assessing and mitigating transport impacts Policy T5 Cycling Policy T6 Car parking Policy T6.2 Office parking Policy T6.5 Non-residential disabled persons parking Policy T7 Freight and servicing

Supplementary Planning Documents (SPDs) & Other Relevant Documents:

Lambeth Waterloo SPD Advertising & Signage Guidance Refuse & Recycling Storage Design Guide Waste Storage and Collection Requirements - Technical Specification Air Quality Planning Guidance Notes Lambeth Employment and Skills SPD (2018) Draft Supplementary Planning Document: Affordable Workspace (Feb 2020)

London Plan Supplementary Planning Guidance (SPG) Central Activities Zone (March 2016) Social Infrastructure (May 2015) Accessible London: Achieving an Inclusive Environment (October 2014) The control of dust and emissions during construction and demolition (July 2014) Town Centres (July 2014) Character and Context (June 2014) Sustainable Design and Construction (April 2014) London View Management Framework (March 2012) Waterloo Opportunity Area Planning Framework (2007) Appendix 4: Other relevant Plans and Photos

Existing Site Plan

Existing GF Plan

Existing Roof Plan

Existing West Elevation

Existing North Elevation

Existing Sections

Proposed Site Location Plan

Proposed Site Plan

Proposed Roof Plan

Proposed West Elevation

Proposed North Elevation

Proposed Sections

Area Schedule