planning report PDU/2422/01 29 April 2009 566 Cable Street, in the London Borough of Tower Hamlets planning application no. PA/09/00338

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

The proposal Redevelopment of Cable Street Studios to provide 3,486 sq.m. of artists studios, 214 residential units, 475 sq.m. of commercial floorspace, 12 live/work units and retail/café uses. The proposal also includes 82 car parking spaces and 298 cycle spaces.

The applicant The applicant is Sudbury Properties, and the architect is Studio One.

Strategic issues The proposal is to refurbish an existing building for artist studios and live-work accommodation and a new residential building. Commercial uses are provided at ground floor. The scheme has a very high density, the design is not the highest quality and will impact on the setting of the conservation area and the retained historic buildings. The proposal represents overdevelopment of the site.

Recommendation That Tower Hamlets Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 86 of this report; but that the possible remedies set out in paragraph 88 of this report could address these deficiencies.

Context

1 On 19 March 2009 the Mayor of London received documents from Tower Hamlets Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 29 April 2009 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under the following categories 1B, 1C and 3E of the Schedule to the Order 2008:

page 1 • 1B ”Development which comprises or includes the erection of a building or buildings – (b) in Central London (other than the ) and which a total floorspace of more than 20,000 sq.m.”.

• 1C “Development which comprises or includes the erection of a building…(c) ..more than 30 metres high and is outside the City of London.”

• 3E “Development comprises or includes the provision of more than 2,500 sq.m. of floorspace for a use falling within any of the following use classes in the Use Classes Order (vi) class B1 (business).”

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

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken into account in the consideration of this case.

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

6 The 0.37 hectare site is located on the corner of Cable Street and Butcher Row near in Limehouse. The main existing building is Thames House, a relatively attractive four- storey Victorian building. Within Thames House is the Cable Street Studios, a group of artist studios, which is a locally significant venue for artists. At present the facility is occupied by approximately 50 artists.

7 Thames House has an attractive corner entrance on the junction of Butcher Row and Cable Street, although there are several more modern buildings along the southern boundary of the site, which is shared by an operational cement works. It is understood that the cement works has recently been modernised. The modern buildings on the subject site have little architectural merit.

8 The site has an irregular pan handle shape. To the north along Cable Street is a mixture of modern and estate housing, while there are two rows of Victorian residential cottages on Bere and Cranford Street, which abut the site to the south and west. This housing is only two storeys high and is thought to be the original workers cottages for the retained former warehouse building. Further to the west is The Highway business park which contains a mixture of light industrial units.

9 The site is within the York Square Conservation Area. St James Garden, a small park containing gardens and some seating is located on the opposite side of Butcher Row, within these gardens is the Grade II listed building ‘The Royal Foundation of St Katherine’.

10 The site is in an accessible location with a public transport accessibility level of 5 where 1 represents the lowest accessibility level and 6 the highest. Limehouse DLR and overland rail station is within walking distance of the site. The nearest bus stops are situated on Butcher Row and . Four bus routes serve these stops; D3, 15, 115 and 135. The site is adjacent to Butcher Row which is part of the TLRN linking the A13 Commercial Road with A1203 The Highway to the south. An off carriageway cycle route extends along Cable Street.

page 2

(Source: Design and Access statement, Studio One Architecture)

Details of the proposal

11 The proposal is effectively split into two parts, the refurbishment and the new build.

The refurbishment

12 The proposal involves the retention of the Victorian building (Thames House) and its refurbishment to provide 100 artist studios and twelve live/work units. The artist studios will be located in the four storeys along the Cable Street frontage, with retail uses on ground floor of the corner units. Above this retail accommodation, will be three levels of live-work units. In this part of the development there will be twelve live-work units, all of which are double aspect facing outward to the road and inward into an internal courtyard.

New build

13 In the southern part of the site, the existing, more modern, buildings will be demolished to accommodate a mixture of cafe (44 sq.m) and restaurant (147 sq.m) uses and a series of four commercial (B1) units ranging in size from 67 sq.m. to 151 sq.m.

14 The internal courtyard has been called ‘Place des Artistes’ and will include public art, planting and an area of seating for the ground floor restaurant. This courtyard also provides access to some of the residential units and the artists studios within the retained Thames House.

15 Above these commercial uses at ground floor level, is the bulk of the residential accommodation. In total 214 units are proposed within two towers, Tower A with a height of 24- storeys (i.e. 24-storeys above ground, therefore 25-storeys in total), tower B at 14-storeys and a link block of six storeys high.

16 The towers are located at the western and eastern parts of the site, with the linking block between. The tallest element of 25 storeys is located on the Butcher Row frontage.

17 The proposal does not provide any affordable housing.

18 82 car parking spaces are provided within a two level basement.

page 3

(Source: Design and Access statement, Studio One Architecture) Case history

19 There is no relevant history. Strategic planning issues and relevant policies and guidance

20 The relevant issues and corresponding policies are as follows:

• Mix of uses London Plan • Employment London Plan; PPG4; draft PPS4; Industrial Capacity SPG • Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG • Affordable housing London Plan; PPS3; Housing SPG • Density London Plan; PPS3; Housing SPG • Urban design London Plan; PPS1 • Tall buildings/views London Plan; View Management Framework SPG • Regeneration London Plan; the Mayor’s Economic Development Strategy • Transport London Plan; the Mayor’s Transport Strategy; PPG13 • Parking London Plan; the Mayor’s Transport Strategy; PPG13 • Sustainable development London Plan; PPS1, PPS Planning and Climate Change Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy • Ambient noise London Plan; the Mayor’s Ambient Noise Strategy; PPG24 • Air quality London Plan; the Mayor’s Air Quality Strategy; The Control of dust and emissions from construction and demolition BPG; PPS23 • Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Wheelchair Accessible Housing BPG Planning and Access for Disabled People: a good practice guide (ODPM)

page 4 21 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the 1998 Tower Hamlets Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004).

22 In October 2007, the Secretary of State directed Tower Hamlets to withdraw the submitted Tower Hamlets Core Strategy and Development Control development plan documents and the associated Area Action Plans. The Council has since adopted the withdrawn documents as ‘Interim planning guidance for the purposes of development control’. The Council has also recently produced a ‘Core Strategy – Options and Alternatives for Places’ document which is currently undergoing public consultation. These documents, though of limited weight, are relevant material considerations in the decision making process. Mix of uses

23 London Plan policy 3B.5 ‘Industrial locations’, seeks to manage Locally Significant and other, smaller industrial sites having regard to “integrated strategic and local assessments of industrial demand promote, manage and where necessary protect the varied industrial offer”. The re-provision of the artist studios within the refurbished building is strongly supported as it will improve the employment offer of the site and provide a valuable type of workspace for the area. This use is appropriate in line with policy 3B.5 and 3D.4 ‘Development and promotion of arts and culture’. Existing tenants will be given priority in occupying the new spaces.

24 The artist studios will be managed by Acme, a London-based charity supporting visual arts practice by providing artists with affordable studio and living space. In this instance, it is proposed that the studios will be rented out at appropriately £9.20 per square foot, which, according to Acme, is approximately a third of the price of comparable rented accommodation on the open market. The rent sounds reasonable, but should be verified by an independent valuation expert and the affordability should be secured through any future S.106. At present the draft heads of terms does not include the on-going provision of the affordable artist accommodation. It is noted within the financial appraisals, a different rent value for the artist studios is provided, this discrepancy should be clarified.

25 The provision of the live-work accommodation within the refurbished building is not opposed, although it is not clear within the information submitted, how these spaces will be allocated or managed to ensure they are utilised as genuine live-work space. It is unclear if the live- work element is a requirement of the local authority or whether this is a developer-led initiative, but these units, which are double aspect and large given the dimensions/layout of the existing building, could provide the perfect opportunity to larger family accommodation, which is lacking in the proposal.

26 The principle of the other commercial uses on the site, including general office employment (B1); cafe, restaurant and small-scale retail uses are also supported in line policy 3.D3 ‘Maintaining and improving retail facilities’. All of the proposed units are small (i.e. will not create any significant out-of-centre development), will provide important facilities for local people in an area which lacks this type of café/retail environment, will introduce life and vitality into the ground floor and will complement the art based land use.

27 The provision of residential accommodation on the site adjacent to the cement works is not opposed in principle, subject to the comments later in this report relating to design, noise and air quality, as the delivery of housing in this area will help achieve the aspirations London Plan policy 3A.1 ‘Increasing London’s supply of housing’ which seeks an annual monitoring target of 3,150 homes per year in Tower Hamlets.

page 5 Housing

28 London Plan Policy 3A.10 requires borough councils to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mix-use schemes. In doing so, each council should have regard to its own overall target for the amount of affordable housing provision. Policy 3A.9 states that such targets should be based on an assessment of regional and local housing need and a realistic assessment of supply, and should take account of the London Plan strategic target that 35% of housing should be social and 15% intermediate provision, and of the promotion of mixed and balanced communities. In addition, Policy 3A.10 encourages councils to have regard to the need to encourage rather than restrain residential development, and to the individual circumstances of the site. Targets should be applied flexibly, taking account of individual site costs, the availability of public subsidy and other scheme requirements.

29 Policy 3A.10 is supported by paragraph 3.52, which urges borough councils to take account of economic viability when estimating the appropriate amount of affordable provision. The ‘Three Dragons’ development control toolkit is recommended for this purpose. The results of a toolkit appraisal might need to be independently verified.

30 The proposed scheme provides 214 residential units, with no affordable housing.

31 The proposed dwelling mix is as follows: -

• 20 x studios • 24 x 3 bedroom units

• 89 x 1 bedroom units • 3 x 4 bedroom

• 90 x 2 bedroom units

32 The provision of housing does help contribute to aspirations of policy 3A.1 ‘Increasing London’s supply of housing’, but unfortunately does not provide any affordable housing. The borough wide target is 50%, of which this application goes no way to meeting.

33 The proposal has been supported by a financial appraisal to justify this level by ‘three dragons appraisal’, a developers ‘circle appraisal’ and a commentary that the provision of low cost artist studios to Acme has the impact that the developer will “suffer a substantially lower land value compared to providing affordable housing in a development without the artists studios”.

34 The developer is effectively providing affordable artist accommodation at the expense of affordable housing.

35 At this stage, the financial appraisal has not been subject to vigorous scrutiny to test the assumptions and figures used within the appraisals, however, there are several queries relating to the way in which the appraisal has been approached, particularly relating to the alternative hypothetical scheme which is potentially unrealistic, given the large amount of demolition that would be required within the conservation area.

36 Currently, the application does not comply with policy 3A.10 that seeks to maximise affordable housing outputs. Any further update on the appropriateness of this level of affordable housing will be reported back to the Mayor in due course.

page 6 37 London Plan policy 3A.5 ‘Housing choice’ seeks developments that offer a range of housing choices. The proposed unit types do not adequately comply with this policy or the mix promoted by the Mayor’s Housing Supplementary Planning Guidance. This seeks an overall provision of 30% 4 bedroom units, 38% 2/3 bedroom and 32% 1-beds. The unit mix should be altered to better reflect this guidance, in particular, more family should be introduced and the studio units should be deleted. Density

38 The density of the scheme is 610 units per hectare. The London Plan policy 3A.3 ‘Maximising the potential of sites’ outlines broad guidelines on housing density, which for central London locations with high public transport accessibility, a density of between 215 and 405 units per hectare, is promoted. The proposed density is significantly higher than the guidelines.

39 High-density development can be appropriate, however, in this instance, the high density is not sufficiently justified. Some of the problems with the high density are expressed within the design, a matter that will be addressed later in this report, but the other issues with the high density include the lack of amenity space for residents and a paucity of local services such as shops. The planning application does not include any information on local services such as schools and doctor’s surgeries, although this is a matter that may be covered by Tower Hamlets Council in its consideration of the scheme.

40 Despite the good level of public transport accessibility, the density of the proposal too high and there do not appear to be any justification for a density so far in excess of the in relation to London Plan guidelines. Urban design

41 Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within Chapter 4B which address both general design principles and specific design issues. London Plan Policy 4B.1 sets out a series of overarching design principles for development in London. In addition to Chapter 4B, London Plan policies relating to density (3A.3) and sustainable design and construction (4A.3) are also relevant. Design polices in the London Plan also include specific design requirements relating to maximising the potential of sites, the quality of new housing provision and tall and large-scale buildings.

Retained building

42 The retention of the impressive Victorian building is supported, particularly in light of the conservation area setting. The refurbishment will ensure the preservation of the building into the future. Any scheme that involved the demolition of these buildings would be unlikely to be supported.

43 It is noted that, that the entrances to the commercial unit and the artist studios on Cable Street are all located off the central courtyard, rather than from the street. The rationale for this perhaps includes a desire to avoid puncturing new entrances into the historic elevations which is logical, however, there is nothing on the plans to illustrate how these units will be recognisable as retail units and accordingly the marketability of the units may suffer, details of the elevations of these units should be provided. If these units were to remain vacant, the central courtyard (where several residential entrance are located) may suffer form lack of passive surveillance and could raise personal safety issues. It is unclear if the courtyard will be locked at night.

44 The entrances to the proposed development from both the Butcher Row frontage and the internal courtyard, are accessed via ramps. The need for these ramps is unclear and they should be

page 7 deleted, if possible, to provide level access to the building from the street. If there is a problem is the floor level, this might be able to be overcome when the basement carparking area is built.

45 Several of the live-work units are not accessible by the lifts. To ensure compliance with the London Plan 3A.5 ‘Housing choice’ this arrangement should be amended. The layout arrangements of the live-work units on the fourth floor fronting Butcher Row also appear unnecessarily complicated.

New build

46 London Plan policy 4B.10 ‘Large-scale buildings – design and impact’ require the all tall buildings to be of the highest design quality and to take account of views, the local and wider context, to be attractive from all angles, provide high quality spaces and be sensitive in their impacts.

47 The new buildings are within the southern portion of the site. It includes three main elements, two towers of 25 and 15 storeys respectively and a 7-storey link between the towers.

48 The scale and bulk of the proposed buildings are very large within the context of the adjoining two-storey cottages, the four-storey retained studios and the listed building on the opposite side of Butcher Row. As mentioned, the retention of the existing buildings is supported, however, within the illustrative material provided, the new buildings dominate the historic buildings to such an extent as the development would negatively affect their character and setting, and that of the conservation area. The context of the surrounding area does not seem to have been given appropriate weight in the design of the scheme and should be reconsidered.

49 The provision of a tall building on the site is not necessarily opposed, however, the combined height and bulk of all of the three buildings is overwhelming in this setting and, combined with the density of the development, represents overdevelopment of the site. The scheme would be improved by reducing the height of the linking block to that of the retained building, while it also seems necessary to remove one the tower elements and work hard on the remaining tower to ensure it is streamlined and elegant. While it is appreciated the site is heavily constrained in terms of the surrounding buildings and the presence of cement works, the rationale for the current arrangement is not accepted and the resulting arrangement is confused, overly dominant and creates an untidy building form.

50 Lowering the linking block and reducing the scheme to one tower element will let more light into the courtyard and allow better recognition of the surrounding historic elements.

51 The level of information justifying the tall building is insufficient. The townscape and visual assessment does not include any accurate visual representations and the rationale behind the views that have been included within the wire-line assessment has not been provided. It is unclear if there are any important local views within Tower Hamlet policy guidance that should be modelled. Several views of the site that have been modelled, illustrate the large scale of the proposal and the uncomfortable relationship the proposal has with the local context.

52 It is unclear whether there has been any check as to whether any strategic views within the Mayor’s London View Management Framework will be impacted on by the development. This should be clarified and amended if necessary to ensure compliance with London Plan policy 4B.16 ‘London’s View Management Framework’.

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Computer generated image of the proposed development (Source: Design and Access statement, Studio One Architecture)

53 Further details on the elevational treatments should be supplied. This should include details on the materials and the fenestration, balconies and winter gardens. At present, the illustrative materials within the design and access statement and within the application drawings are not sufficiently detailed to allow comment on the quality of the elevations.

54 On the drawings, the differentiation between units that have winter gardens and those with normal balconies is unclear. Further detail on the operation and design of the winter gardens is necessary, given the important noise and air quality function that these gardens will perform, please refer to the noise and air quality sections of this report also. Details of the mechanical ventilation and glazing of the winter gardens is also required.

55 Similarly, further information is also required on the proposed screen between the site and the cement works. It is not clear how large the screen is and whether it is free standing or part of the building.

56 The south facing elevation of the tall tower includes the only windows for the living accommodation in this part of the block. These windows have an outlook into a small winter garden, which is directly adjacent to the boundary with the cement works facility. This limited outlook, the potential for nuisance from the cement works and the impact that this current proposal will have on the ability of the cement works site to come forward for redevelopment, are far from ideal. This arrangement should be reconsidered and the redevelopment potential of the neighbouring site should be taken into account. Windows/winter gardens on the boundary should be avoided.

57 Many of the units have balconies, several of which are quite large for this central London location. The provision of balconies is supported, however, it is noted that many of these balconies

page 9 are small, enclosed by adjoining walls and often (particularly on the 1st, 2nd and 3rd floors) have a very uncomfortable relationship with other balconies. These balconies and sometimes the associated living space, will suffer from a lack of privacy and a sense of enclosure. These problems should be addressed.

58 The proposal also includes two areas of roof garden, one above the ground floor commercial uses and another at 7th floor level. Neither of these roof gardens appear to be accessible, either to the units adjacent or to the wider development. Careful consideration should be given to the use of these areas as they could provide vital amenity space, which is currently lacking outdoor space. However, given the small size of these spaces and the presence of windows and private balconies on to these spaces, the solution will have to be sensitively treated.

59 The ground floor courtyard should be a lively addition to the area and is welcomed, particularly if the height of the link block is reduced to allow for more light into the space. There is also a parking forecourt type area on the street frontage that is included within the red line boundary of the scheme. No information has been provided as to how this space will be landscaped and how it can be incorporated into the development. The strategy for this space should be provided.

60 The tall existing trees on the Butcher Row frontage are an attractive feature of the area. While the submitted plans illustrate that the trees are to be retained, to ensure the trees are not damaged or destroyed during the construction period, conditions should be placed on any future permission ensuring the protection of the trees. Such measures will ensure compliance with London Plan policy 3D.15 ‘Trees and woodland’.

61 In relation to design, the proposal does not comply with London Plan policies 4B.10, 4B.16 and 4B.1. Children’s play space

62 Policy 3D.13 ‘Children’s and young people’s play and informal recreation strategies’ sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” Using the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ it is anticipated that there will be approximately 24 children within the development. The guidance sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site. As such the development should make provision for 240 sq.m. of playspace.

63 This development does not include any children’s playspace, although it has been highlighted that there is children’s playspace in the gardens across the street. The policy particularly relates to on-site provision, and at present the proposal does not comply with the requirements. This should be amended. Given the small size of the site, if there are difficulties delivering a policy compliant amount of playspace, it would be useful to understand if there are any improvements or s.106 contributions that could be made to the existing nearby facilities.

Transport

64 In order to understand the transport impact of the development details of the survey data used for the trip generation assessment should be provided. Furthermore, the details of the sites used to calculate the average trip rate is required. Trip generation should not be indicated for public transport as a whole but as details of person based trip generation by mode. In the absense

page 10 of this information, the transport impact of the development can not be determined and accordingly the scheme is not in accordance with London Plan policy 3C.2 ‘Matching development to transport capacity’.

65 The development includes 82 parking spaces in an underground car park. Except for disabled provision, this level of parking is not supported in light of the high public transport accessibility level of the site. In order to encourage more sustainable travel, particularly cycling and walking, a reduction would be encouraged. Occupiers of the development should be excluded from access to a parking permit through a section 106 agreement.

66 The provision of 298 cycle spaces is supported as it accords with Trasnport for London standards and London Plan policy 3C.22 ‘Improving conditions for cycling’. All cycle parking should be safe and secure in addition to be covered. Cycle parking for visitors should be conveniently located and marked accordingly to encourage use. As the cycle route along Cable Street will be rerouted outside the front of the development, the space should be designed to minimise conflicts between pedestrians, cyclists and vehicles.

67 The applicant should provide a map showing key walking routes including to public transport nodes. This should be accompanied by an assessment of the routes and proposals for any improvements that are necessary. Walking routes to from the development are poor and there appears to be an absence of crossing facilities in the vicinity of Cable Street. The developer should consider providing a crossing as well as improving the public realm around Limehouse station via Butcher Row and Ratcliffe Lane to encourage safe routes to public transport in accordance with London Plan policy 3C.10 ‘Public transport and security’.

68 The development should be accompanied by a delivery and servicing plan. It should indentify the potential for safe drop off and collection area within the site to minimise waste journeys and hence the impact of vehicular trips on the network. The applicant should verify that the front car park will accomodate servicing to the retail and commercial units and that vehicles can enter and leave the site in forward gear. In order to minimise the impact of construction trips on the Road Network and to comply with London Plan Policy 3C.25 ‘Freight strategy’ the applicant should a Construction Logistics Plan. Given the proximity of the River Thames the developer should investigate the transfer of construction waste and materials by water.

69 The submission of a interim travel plan for the residential uses is welcomed. Further discussion to ensure that it will be compliant with Transport for London’s travel plan guidance is welcomed. The travel plan must include targets, details of the Travel Plan Coordinator role, funding information, clarification on the number of cycle parking spaces, a parking strategy and a monitoring schedule. Energy and sustainable design and construction

70 The applicant has not followed the energy hierarchy set out in the London plan. Although some of the work undertaken is useful, the applicant needs to re-write the energy strategy to address the specific requirements of the London Plan. As an example, the applicant has established the targets in terms of energy consumption rather than in carbon emissions.

71 The energy assessment should fully address requirements in policies 4A.1 to 4A.7 in the London Plan taking account of relevant design and climate change adaptation policies in the Plan, and clearly outline the applicant’s commitments in terms of the carbon dioxide savings and measures proposed.

72 The strategy should include the following:

page 11 • A target for overall carbon dioxide reductions. • A target for carbon dioxide emissions savings through energy demand reduction measures. • Commitment to communal heating infrastructure (and CHP) if appropriate for the development. • Renewable option appraisal with the aim of reducing carbon emission by a 20%.

73 Completion of the table attached in appendix 1 is also recommended. This appendix also includes the methodology that should be used to calculate baseline emissions and the measures for carbon dioxide reduction.

74 Policy 4A.3 ‘Sustainable design and construction’ of the London Plan requires all development proposals to quantify the potential implications of the development on sustainable design and construction principles. The applicant does not appear to have submitted this statement, although it is briefly mentioned within the design and access statement. The statement should be submitted to GLA officers. This report should address the five main principles of policy 4A.9 ‘Adaptation to Climate Change’ that requires developments to be adaptable to the climate they will face over their lifetime. These principles are to minimise overheating and contribution to heat island effects, minimise solar gain in summer, contribute to flood risk reductions, including applying sustainable drainage principles, minimising water use and protecting and enhancing green infrastructure. Specific policies also cover overheating, living roofs and walls, and water. Provision of electric vehicle charging points should also be made.

75 While it is noted that green roofs, cross ventilation and heat recovery, sustainable materials might be used, the report should provide further commitment to such measures. Noise

76 A noise assessment has been submitted in support of the application. This report concludes that the noise from the adjacent cement works will cause noise disturbance to the residents unless mitigation measures are provided. These measures include mechanical ventilation for all units and noise reduction measures through the provision of the winter gardens and an acoustic screen. Although the adjacent noise would not create an ideal residential environment, it is not unusual within in the busy urban areas of London, provided it is satisfactorily mitigated.

77 However, the methodology of the noise assessment does require some clarification. The assessment states that noise assessment point was ‘located on the boundary of the proposed development some 8 metres high and both overlooking the concrete yard and Cable Street’. This location is incorrect as there is not a point on the boundary that overlooks both Cable Street and the concrete yard. The assessment points should be shown on a plan and at least one should have been located on the boundary of the concrete yard. If this was not an assessment point, the assessment should be repeated.

78 As mentioned previously, there is no clarity as the location of the noise screen, what it will look like and what it will be made of. The noise assessment states that this will be necessary to screen the residential properties and if so, the screen should be shown on the drawings.

79 At present the proposal does not comply with London Plan policy 4A.20 ‘Reducing noise and enhancing soundscapes’.

page 12 Air quality

80 London Plan policy 4A.19 ‘Improving air quality’ requires air quality to be taken into account in the assessment of planning applications. An air quality assessment has been submitted in support of the application, however, it appears to solely focus on the traffic based pollutants. To ensure compliance with this policy, the assessment should be revised to include an assessment of the operation of the cement works that presumably could create a large amount of dust. The assessment should also include information on the impact of the proposed biomass boilers on air quality, particularly in relation to the residential windows. The drawings should be amended to clearly illustrate the location of the associated biomass stack. Inclusive design

81 In accordance with policy 4B.5 ‘Creating an inclusive environment’ the proposal commits to 100% ‘lifetime homes’ and 10% wheelchair accessible. However, this is perhaps not an entirely accurate statement given that several of the live-work units are only accessible by stairs. Additionally, some the plans show there is not enough room on the door widths to achieve the lifetime home standards. This also appears to be the case for the wheelchair units. This should be amended and the standards should be met.

82 As mentioned in the design section, the need for the access ramps to the commercial units is queried and should be deleted if possible. Local planning authority’s position

83 Unknown. Legal considerations

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

85 There are no financial considerations at this stage. Conclusion

86 London Plan policies on affordable housing, employment, design, tall buildings, noise, air quality, transport and accessare relevant to this application. The application complies with some of these policies but not with others, for the following reasons:

page 13 • Mix of uses: the reprovision of the artist studios within the existing building is supported in line with policies 3B.5 and 3D.4 , although further analysis of the viability appraisals is required and, as it currently stands the provision of the artist accommodation should not necessarily be provided at the expense of affordable housing. The provision of live/work accommodation is queried as the refurbished building may allow better opportunities for family accommodation. The small-scale commercial uses and the residential accommodation are supported in line with policies 3D.3 and 3A.1. • Housing: the provision of housing on the site, helps contribute to achieving policy 3A.1. But, as the scheme has no affordable housing and the financial appraisal has not yet been subjected to full scrutiny, the proposal conflicts with policy 3A.10 and 3A.9. As the scheme contains very little large family accommodation and many studios the proposal conflicts with policy 3A.5. The comparison of scheme against the hypothetical solely-residential scheme is not yet accepted as justification for the lack of affordable housing within this development. • Density: the density is unjustifiably high in relation to London Plan guidance led by policy 3A.3. No information has been provided on local services and the high density has design implications. The selection of the views within the views assessment should be justified. • Urban design: given the conservation area and the charm of the existing building, the retention of the artist studios is welcomed, however, the design of the new build element of the proposal is not in accordance with policies 4A.1, 4B.10 and 4B.16. • Children’s playspace: the scheme does not provide any child’s play space in conflict with policy 3D.13. • Transport: the lack of information on trip generation means the scheme cannot be assessed against policy 3C.2. Car parking levels are too high. The provision of cycle parking is welcomed in line with 3C.22, although attention to the cycle route on Cable Street is required. Further work is required to ensure compliance with policy 3C.10 and 3C.25. • Energy and sustainable design and construction: the energy strategy does not comply with policies 4A.1 to 4A.7 and as no sustainable design and construction report has been provided to the GLA, the scheme has not demonstrated compliance with policies within 4A.3 and 4A.9. • Noise: crucial information about the methodology of the noise assessment is required in line with policy 4A.20. • Air quality: the assessment fails to recognise the cement works or the proposed biomass boilers and is not in accordance with policy 4A.19. • Inclusive design: the proposal does not appear to provide 100% lifetime homes or wheelchair units contrary to policy 4B.5. 87 On balance, the application does not comply with the London Plan. 88 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan: • Mix of uses: further analysis of the viability appraisals is required and justification for the approach of a ‘hypothetical’ entirely new build scheme should be rethought. Further information on the long-term management of the live/work accommodation is required. The affordability of the artist studios should be clarified and secured by condition. • Housing: again, further analysis of the viability appraisals is required and justification for the approach of a ‘hypothetical’ entirely new build scheme should be rethought.

page 14 Affordable housing should be provided on the site, if viable. The unit mix should be amended. • Density: the density should be reduced in line with London Plan guidance and further evidence of the ability of the area to accommodate a large amount of new residential units should be provided. Design changes are also required. • Urban design: the design of the new build elements of the proposal should be rethought, particularly the height and bulk. More attention should be given to the contextual setting of the site and the details of the elevations should be provided. The selection of the views within the views assessment should be justified. Further detail is required on the screening to the cement works, particularly the proposed winter gardens and the screen. Amenity spaces on the roof should be accessible and landscaping at the front the site should be provided. The ramped entrances to the existing building should be removed if possible. • Children’s playspace: should be provided and consideration should be given towards improving existing local facilities. • Transport: trip generation data is required and car parking levels should be reduced. Attention to the cycle route on Cable Street is required. Further work is required on the freight strategy and pedestrian routes. The travel plan should be secured by any future S.106. • Energy and sustainable design and construction: the energy strategy should be rewritten and a sustainable design and construction report should be submitted. • Noise: information on the noise assessment points should be provided and should include a point on the boundary shared with the cement works. • Air quality: the assessment should consider the adjacent cement works and the impact of the biomass boilers on air quality. • Inclusive design: 100% lifetime homes and 10% wheelchair units should be provided.

for further information, contact Planning Decisions Unit: Giles Dolphin, Head of Planning Decisions 020 7983 4271 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Loren Brown, Case Officer 020 7983 4926 email [email protected]

page 15 Appendix 1

Tonnes CO2 per annum Carbon dioxide (%) Regulated Total Energy Regulated Total Energy Baseline emissions Savings from energy demand reduction Savings from CHP/CCHP Savings from renewable energy

Baseline emissions

Baseline emissions should be calculated on a whole energy basis which includes the energy consumed in the operation of the space heating/cooling and hot-water systems, ventilation, all internal lighting cooking and all electrical appliances.

Baseline emissions for dwellings should establish:

A Target Emissions Rate (TER) calculated through the standard Building Regulations 2006 methodology SAP 2005 Additional emissions associated with non Building Regulation elements (i.e. cooking and appliances) established by using BREDEM (BRE Domestic Energy Model).

In terms of the extent of modeling work required, the applicant should provide a representative sample of domestic properties. This is in line with the information already provided by the applicant.

Baseline emissions for non-domestic development should establish:

A Target Emissions Rate (TER) calculated through the standard Building Regulations methodology established through SBEM or other approved software Additional emissions associated with non Building Regulation elements (ie ‘whole energy’) established by using individual end use figures (for example catering and computing) from CIBSE guide baselines (eg CIBSE Guide F), ECON 19, or evidence established through previous development work.

It is technically possible to exceed Building Regulations requirements (Part L 2006) through demand reduction measures alone. Energy assessments should therefore set out the demand reduction measures specific to the scheme and demonstrate (using building regulations approved modeling) the extent to which they exceed Building Regulations. Measures typically include both architectural and building fabric measures (passive design) and energy efficiency services (active design).

All planning applications should demonstrate how their heating, cooling and power systems have been selected to minimize CO2 emissions in accordance with the order of preference in Policy 4A.6. Energy assessments will need to explicitly work through the order of preference and where an approach is not appropriate for the development, the assessment should demonstrate provide reasoned justification.

page 16 a. The applicant should investigate the potential for connecting the scheme to an existing district energy scheme. A back-up on-site strategy is also acceptable in the event that connection to a district energy scheme proves unviable. b. If no existing scheme is present, the applicant should investigate whether a network is planned in the area. Developments should demonstrate that they are designed to connect to future district energy networks where possible (established or planned schemes may have detailed technical guidance which applicants should follow).

Information related to the carbon factor associated with the heat utilised from networks should be provided.

c. Where more than one building or use is proposed, buildings should have communal heating systems and all buildings/uses within a scheme should be connected into a single site-wide communal heating network

d. The communal heating network should be supplied from a central energy centre where all energy generating equipment is located. The feasibility of CHP/CCHP should be investigated and committed to, only if feasible.

e. Schemes that will be implemented in a number of phases, and where a number of energy centres are proposed, should seek to minimise the number of energy centres and explain how the energy strategy will be implemented across the development’s phasing programme.

f. A simple schematic of the communal heating network showing all buildings/ uses connected into it, as well as the location of the single energy centre, should be provided as part of the energy assessment.

Where there is an identified demand for cooling, a low carbon cooling strategy should be outlined. This should set out the extent to which, and how cooling demand has been minimised. It should then set out:

Residual cooling demand Cooling infrastructure Details of all plant, including efficient and/or renewable cooling sources.

Finally, energy assessments should set out consideration of each renewable energy technology in Policy 4A.7 of the London Plan. All technologies listed in the London Plan 4A.7 are considered potentially technically feasible in London.

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