planning report PDU/2738/01 18 August 2011 Sea Containers House, Southbank in the London Borough of Southwark planning application no. 11/AP/1955

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 Part refurbishment and redevelopment of Sea Containers House to provide office, retail, hotel (358 bedrooms) and gym. The proposals include 29 vehicle parking space, 22 motorcycle parking spaces and 176 bicycle parking spaces. The applicant The applicant is Archlane Limited and the architect is tp Bennett.

Strategic issues The key strategic issues relate to the impact on Central Activities Zone functions through a reduction in office floor space, urban design including heritage and townscape views, access, climate change and transport, including the requirement for a crossrail contribution.

Recommendation That Southwark be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 63 of this report; but that the possible remedies set out in paragraph 65 of this report could address these deficiencies.

Context

1 On 8 July 2011, the Mayor of London received documents from Southwark 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 18 August 2011 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 Category 1C of the Schedule to the Order 2008:

“Development which comprises or includes the erection of a building of one or more of the following descriptions—

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(a) the building is more than 25 metres high and is adjacent to the River Thames.”

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

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

5 The application site relates to the existing Sea Containers House, located on the south bank of the River Thames in the Borough, Bankside and London Bridge Opportunity Area and within the Central Activities Zone (CAZ). The building was originally constructed as a hotel in the 1970’s but was subsequently converted to provide 36,898 sq.m. office space in the early 1980’s. The building comprises two basement levels, ground floor plus fourteen upper floors. The building is T-shaped with 120 metres of River Thames frontage.

6 The site context is mixed commercial and residential in character. The most significant landmarks include the River Thames to the north, the Oxo Tower to the west and the Kings Reach Tower to the south. Blackfriars Bridge is located to the east. The site abuts the Old Barge House Alley Conservation Area to the west, which forms the setting of the Oxo Tower and Barge House. The Riverside Walk provides potential for direct access into the building from the river frontage. Currently, whilst there is surveillance at ground level there are no active uses along this frontage with the main office entrance to the rear of the building from Upper Ground, a local access road.

7 The site is approximately 500 metres from Southwark London Underground station. Blackfriars (with a new Southbank entrance) and Waterloo Stations are also within walking distance, providing access to Northern, Jubilee, Bakerloo, Waterloo & City, District, Circle and National Rail services. Thameslink improvements will result in new additional national rail services from Blackfriars from 2018.

8 The site is served by bus routes 381, RV1, 63, 100 and 45, with many additional services available at Waterloo. River bus services are available from Bankside Pier located 400m away where services operate towards the London Eye Millennium Pier and North Greenwich Pier. The site has a public transport accessibility level (PTAL) of 6b, on a scale of 1 to 6 where 6 is the most accessible. The nearest Transport for London Road Network (TLRN) is the A201 Blackfriars Road and the A3200 Stamford Street.

Details of the proposal

9 The proposals are for the part refurbishment and redevelopment of Sea Containers House to provide office, retail, hotel and gym uses. The proposals include new construction to the rear of the site above the existing basement car park. The new mix of uses will be as follows:

page 2 Table 1 land use mix use sq.m. (net internal area)

Office B1 existing building 21,914

Office B1 new build 5,959

Retail (A1, A3, A4) 1,176

Hotel C1 16,817

Figure 1 proposed ground floor (source: tp bennett Design and Access Statement)

Case history

10 Initial pre-application advice was issued by the GLA on 2 February 2011 with follow-up advice on design, access and energy provided following a meeting on 2 June 2011. The strategic issues raised included the potential for comprehensive development, impact on CAZ functions through the reduction in office floor space, impact of localised concentration of hotel uses, design, layout and access; impact on strategic and local views, climate change and district heating and power networks; and transport matters including the need for a Crossrail contribution. Strategic planning issues and relevant policies and guidance

11 The relevant issues and corresponding policies are as follows:

page 3  Urban design London Plan; PPS1  Mix of uses London Plan  Regeneration London Plan; the Mayor’s Economic Development Strategy  Transport London Plan; the Mayor’s Transport Strategy; PPG13  Crossrail London Plan Alteration; Crossrail SPG  Parking London Plan; the Mayor’s Transport Strategy; PPG13  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)  Equal opportunities London Plan; Planning for Equality and Diversity in Meeting the spatial needs of London’s diverse communities SPG; Diversity and Equality in Planning: A good practice guide (ODPM)  Tall buildings/views London Plan; RPG3A, Draft Revised View Management Framework SPG  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  River Thames/flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B  Historic Environment London Plan; PPS5

12 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 Southwark Plan (as saved) Southwark Core Strategy (2011) and the London Plan (2011). The draft Bankside, Borough and London Bridge SPD is also a material consideration. Principle of development

Central Activities Zone/Opportunity Area

13 The application site falls within the Central Activities Zone (CAZ) and within the London Bridge, Borough and Bankside Opportunity Area as identified in the London Plan (Map 2.3, Map 2.4 and Annex one Table A1.1 ref 18). Southwark Council consulted on the draft Bankside, Borough and London Bridge SPD in February 2010, and recently finished a further round of consultation on the same document. It is, however, the Council’s intention to revisit the SPD in collaboration with various stakeholders, including the GLA, TfL and local residents. Therefore, the planning policy framework for this area and its form (SPD/OAPF/other policy document) may change. Currently the emerging local site specific policy for the site is set out in section 5.12 of the draft SPD. Here, a mixed use approach is supported which includes an increase in office provision, a mix of retail, leisure, entertainment and cultural uses at lower levels and opportunity for residential provision. In the wider context the SPD identifies Blackfriars Road North for commercial intensification including provision of hotel uses and significant public realm improvements.

14 Annex one of the London Plan sets out the strategic policy direction for the opportunity area, specifically that “There is scope to develop the strengths of the area for strategic office provision as well as housing, especially in the hinterland between Blackfriars and London bridges.”

15 London Plan Policy 4.2 A c) and d) Offices states that boroughs should “encourage the renewal and modernisation of the existing office stock in viable locations to improve its quality and

page 4 flexibility ”and “seek increases in current stock where there is authoritative, strategic and local evidence of sustained demand for office based activities“.

16 Policy 2.10 Central Activities Zone – strategic priorities also seeks, “in appropriate parts of the CAZ… ensure that development of office provision is not strategically constrained and that provision is made for a range of occupiers especially the strategically important financial and business services”. Policy 2.11 Strategic functions also seeks to ensure that development complements and supports the cluster of other strategically important specialised CAZ uses.

17 The site comprises an existing office building of 36,898 sq.m. (net internal area). At present the proposals would result in a net loss in office provision of approximately 9,025 sq.m. As set out above, CAZ is prioritised for this type of land use and the London Plan promotes the area for strategic office supply. The London Plan does not seek to protect existing office uses nonetheless transfer to other land uses must be carefully considered. The policy consideration in this instance is the extent to which the loss of office undermines the strategic office function of the CAZ both locally and in terms of the implications to wider CAZ functions through the defined clusters as set out in the London Plan, in particular the London Bridge, Borough and Bankside Opportunity Area, and the extent to which an increase on this site in this location is viable.

18 It is however important that the strategic priorities for office accommodation in the CAZ are considered as part of the overall approach to redevelopment. The applicant needs to evidence the market conditions regarding office release locally and marketing evidence undertaken regarding demand for office provision in this location. An evidence-based approach is needed to ensure the defined function is not undermined.

Structural constraints

19 GLA officers attended site visit and tour of the existing building at pre application. As reported at pre-application stage it is evident that the hotel model of the existing building appears a significant physical constraint on the current office floorplates. It is evident that to improve the quality of the space for higher-grade office accommodation that internal walls would need to be remodelled. The floor to ceiling heights are a further constraint in achieving the desired quality of space for higher end office tenants. Annex 3 of the planning statement is the applicant’s response to pre-application requests for further information regarding the structural constraints of the building. The information does not provide sufficient justification regarding which elements of the building are structural load-bearing elements. Given there is a current net loss proposed, further structural survey evidence which identifies specific areas on plan will need to be provided in order to demonstrate that all opportunities to maximise office provision have been considered, in particular for the south wing, which is where the majority of the loss is attributed through the conversion to hotel use.

20 In the context of London Plan policy therefore, the reduction in office floorspace still needs to be justified both in terms of the technical matters arising from the physical form of the building, the opportunities and constraints in terms of securing suitable tenants in terms of a viable office market in the current climate.

Other uses

21 The emerging wider designation within the draft SPD seeks to locate hotel uses in London Bridge and Blackfriars north, where public transport accessibility is at its highest. As set out in London Plan policy 4.5 “within the CAZ strategically important hotel provision should be focussed on opportunity areas”. In principle, therefore, at strategic level the provision of hotel use is supported and will contribute to the target set by the Mayor. The other mix of uses including

page 5 retail, restaurant is supported and consistent with the opportunity area objectives set out in Table A1.1 of Annex one (ref 18). Urban design

22 Good design is central to the objectives of the London Plan and is specifically promoted by the policies contained within Chapter 7, which encompass both general design principles and specific design issues.

Strategic views and historic assets

23 London Plan policies 7.8 to 7.12 set out the strategic approach to the protection and enhancement of London’s rich built heritage including strategic views defined in the draft London View Management Framework 2011 (LVMF).

24 In terms of strategic views the applicant has provided images of the proposal from Gabriel’s Wharf viewing platform 16B.1, Blackfriars Bridge 14A.1, Hungerford Bridge 17.B1, Victoria Embankment 20B.1 and Waterloo Bridge 15.B 1 & 2. This analysis suggests that the proposal would not significantly impact on the river prospect.

25 In terms of more localised townscape analysis and impact analysis on heritage assets the work undertaken is set out in Section 5 of the Heritage, Townscape & Visual Impact Assessment. It provides a description of the impacts, rather than images. This work needs to be substantiated with visual material identifying the key receptors on plan and testing the impact through visual analysis. It is difficult to make any judgments regarding the impact on the character and appearance of the relevant conservation area or regarding the setting of a listed building without the visual material to make such a judgment.

Layouts and circulation

26 A number of layout concerns were raised at pre-application stage. Some of these have been resolved however at this stage the arrangements of building layouts and circulation around the building still need further work as set out below.

 As has been consistently raised through pre-application discussion the redevelopment has the potential to create a new space between Oxo Wharf and the new office building to further enhance the back of the Oxo Tower and the newly refurbished Sea Containers House as a destination. Its success is dependent on the removal of the boundary wall that currently separates the two spaces and the introduction of a linked area of public realm and the introduction of active uses along the length of the west elevation of Sea Containers House. The design team has still failed to recognise or embrace this potential. Instead the western elevation is more of an access route with a planting buffer. This fails to embrace the potential of the space. Active uses should be considered for this elevation to ensure the potential for a linked space can be realised.

 The removal of railings on riverside walk to widen the public walkway remains a positive introduction to the scheme, however, it is important that the proposals provide a management strategy to ensure, for example, that the location of tables and chairs along the riverside walk would not result in new obstructions, particularly to the western pinch point. This should be conditioned by Southwark Council.

page 6  The pedestrian route on the east side of the building still requires further refinement to manage out the need for stepped access. This was previously shown in earlier iterations of the scheme as gently ramped.

 The main entrance into the hotel from Upper Ground brings the level change into the building. This provides a cleaner approach to the public realm in front of the hotel entrance by removing the tapering steps. Internally, however, for the hotel, the solution remains a mix of steps and ramps. The applicant should consider an enclosed lift to deal with the level change in this instance; particularly given the route up the ramp is a double switchback ramp. The revolving doors should be removed, particularly given the conflict between general users with luggage and the need to provide separate disabled access doors.

 The new office entrance at Upper Ground remains accessed via steps and ramp. The level change is a significant challenge. There are very limited images of the landscaping arrangement to this part of the public realm and therefore it is difficult to determine how successful the layout will be. Further images should be provided.

 The triple height glass box office entrance is a positive addition to the scheme and will create a publically accessible space with cafe uses internally. Given this approach to creating a publically accessible atrium, and as previously reported, the applicant is encouraged to consider the provision of a 'Changing Places' WC in this location. This could be accommodated through minor redesign of the existing WC facilities behind the reception desk and ‘back of house’.

 The provision of windows to the southeast cafe unit should be included to provide some further surveillance to the space between Sea Containers House and River Court.

 Given the significant improvements proposed to the river walk, the applicant should continue to explore the Paralympic Inclusive Environment (PIE) programme which aims to improve access for disabled people along the south bank from Jubilee Gardens to Potters Field Park to enable visitors to the Olympic and Paralympic Games to experience London's riverside walk.

Architecture and massing

27 London Plan Chapter 7 covers, amongst others, details of inclusive design, designing out crime, public realm, architecture and architectural quality and at policy 7.7 focuses on the impact on character by scale, mass or built form of a tall building and that they should relate well to form, proportion, scale and character of surrounding buildings, urban grain and public realm.

28 The bulk and massing of the building increases at the rear with the introduction of the new office building. The river elevation massing is also altered with the introduction of the new rooftop restaurant and the removal of the western stair core (pepper pot). From the river prospect the new building will integrate fairly comfortably with the existing scale of built form. Similarly the rear will be viewed mostly in the context of the existing building.

29 The existing building is an iconic structure with gold stair core pepper pots that bookend the building and bold detailing to the top and lower frontage which defines the building character. Most of this will be retained, with the exception of the lower level gold detailing. At the lower level, floor to ceiling glazing will be introduced, providing a lighter appearance than the existing recessed balconies. Reducing the recesses throughout the rest of the elevation is broadly successful in creating a lighter external fabric which will also help with internal lighting conditions.

page 7 30 In terms of the rear of the building, there remains a slightly awkward junction between the existing Sea Containers House (western end) and the new office which results in the top of the new stair and lift core overrunning by two floors above the office block. It is however shown as a fairly lightweight and distinctive element of the building. The other elements of the architecture remain broadly successful with the exception of the ground floor treatment to the stair and lift core on the western elevation which now includes a series of steps and lacks any sort of animation with the public realm. As above, this space fails to embrace the potential of a linked space with Oxo Wharf and needs to be reconsidered. Details of materials need to be provided for both the refurbishment of the elevations and the new office block.

Figure 2 existing building (source: tp bennett Design and Access Statement)

page 8 Figure 3 proposed treatment (source: tp bennett Design and Access Statement)

Figure 4 part of the south and western elevation (source: tp bennett Design and Access Statement)

page 9 Access and inclusive design

31 The aim of Policy 7.2 is that proposals aim for the highest standards of accessibility and inclusion (not just the minimum) and that the design process has from the outset considered how everyone, including disabled and deaf people, older people, children and young people, will be able to use the places and spaces that are proposed safely, easily and with dignity.

32 The design of the landscaping and the public realm is crucial to how inclusive the development is to many people. As set out above the pedestrian routes to the buildings should be designed to ensure full and easy access for all users, the eastern route around the building should be a gentle slope and steps removed. The lighting design is particularly important to create safe and well and evenly lit routes through and into the site, particularly for people at night, this should be conditioned by Southwark Council to include all areas, but in particular the eastern route.

33 The biggest challenge has been dealing with the level change from north to south without introducing stepped access. Taking the level change into the hotel lobby is supported, however there should be a lift option which could be located on the western side of the stairway. The entrance to the office is more challenging, and as described above it is difficult to determine the success without further detailed images.

34 Regarding the hotel, London Plan policy 4.5 requires that at least 10 per cent of rooms should be wheelchair accessible, this needs to be shown on plan. Details of how the gym will be fully accessible to disabled people should also be provided.

35 The blue badge parking bays need to have transfer space both sides of each bay and at the rear of the bay (see BS 8300 for guidance on design of blue badge bays). The parking management plan should include a mechanism to ensure that the supply and demand of the blue badge bays are regularly monitored and provision reviewed to take into account changes in future demand and ensure that future disabled users are able to occupy a blue badge bay, and that the bays are effectively enforced. Climate change mitigation

36 The London Plan climate change policies as set out in chapter 5 collectively require developments to make the fullest contribution to tackling climate change by minimising carbon dioxide emissions, adopting sustainable design and construction measures, prioritising decentralised energy supply, and incorporating renewable energy technologies on-site. The policies set out ways in which developers must address mitigation of, and adaptation to, the effects of climate change.

37 The applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole. Further clarification is however required before the proposals can be considered acceptable and the carbon dioxide savings verified.

Energy efficiency standards

38 A range of passive design features and demand reduction measures are proposed to reduce the carbon dioxide emissions of the proposed development. Both air permeability and heat loss parameter will be improved beyond the minimum backstop values required by building regulations. Other features include energy efficient lighting and controls. As a whole, and based on the information provided, the proposed development does not achieve any carbon savings from energy efficiency alone compared to a 2010 Building Regulations compliant development. It is acknowledged, however, that this is partly to do with the fact that there are existing limitations to

page 10 the savings that can be obtained from the refurbishment of the existing offices. However, the applicant should explore further opportunities to bring the overall development in alignment with 2010 building regulations compliance with the use of demand reduction measures alone, such as strengthening the measures proposed for new build elements.

District heating

39 There are no existing district heating networks within the vicinity of the proposed development. The applicant should however engage in discussions with the owners of the Kings Reach Tower regarding future plans for the refurbishment of the tower.

40 The applicant has provided a commitment to ensure that the development is designed to allow future connection to a district heating network should one become available. A site heat network served from a single energy centre is proposed for the development. The network will provide heat to all buildings on-site. The applicant should, however, provide further information on the footprint and precise location of the energy centre as part of the energy strategy. The commitment to the single energy centre and site wide heat network should be secured by condition by Southwark Council.

Combined Heat and Power

41 The applicant is proposing to install a gas fired combined heat and power unit of 500 kW electrical capacity as the lead heat source for the development. A reduction in regulated carbon dioxide emissions of 566 tonnes per annum (28%) will be achieved through this second part of the energy hierarchy.

Cooling

42 Cooling requirements on-site will be provided using a cooling network which would distribute cold water to the buildings on-site. Such a heat network would be supplied with cooling using high efficiency electrical chillers.

Renewable energy technologies

43 The applicant is proposing to install photovoltaic panels (PV) on the roof of the hotel. In total, 130 sq.m. would provide a renewable contribution for the proposed development. A drawing showing the indicative PV array placement has been provided. A reduction in regulated carbon dioxide emissions of 8 tonnes per annum 0.55% will be achieved through this third element of the energy hierarchy. This should be conditioned by Southwark Council.

Summary

44 The estimated regulated carbon emissions of the development are 1,422 tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures, combined heat and power and renewable energy has been taken into account. This equates to a reduction of 556 tonnes per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 28%. Climate change adaptation

45 The London Plan policies 5.9 – 5.15 promotes the key principles of climate change adaptation including overheating and cooling, urban greening, green roofs and water management.

page 11 46 Policy 5.9 seeks to deal with the issue of overheating and sets out a cooling hierarchy. Policy 5.10 promotes urban greening. Policy 5.11 seek major developments to incorporate living roofs and walls where feasible. Policy 5.13 seeks to ensure that surface water run-off is managed as close to its source as possible and sets out a hierarchy of preferred measures to achieve this. Policy 5.15 seek to ensure that new development has proper regard to the impacts on water demand and existing capacity by minimising the use of treated water and maximising rainwater harvesting.

47 A sustainability statement supports the application and demonstrates general compliance with the relevant London Plan policies on sustainable design and construction and climate change adaptation. The building will achieve BREEAM rating ‘very good’. The Council should secure the proposed measures by condition.

Transport for London’s comments

Crossrail

48 The site falls within the Crossrail charging zone. The mechanism for contributions towards Crossrail has been set out in the Mayor’s Supplementary Planning Guidance (SPG) ‘Use of planning obligations in the funding of Crossrail’ (July 2010) and the London Plan policy alteration. The applicant has provided a detailed breakdown regarding floorspace (G1115 note on areas (2)) which sets out the existing notional charge arising from the current office building. It suggests that no charge is due on the basis that this notional charge exceeds the charge arising from the proposed land uses. Whilst the principle is consistent with the guidance in the SPG, the calculation undertaken by the applicant regarding proposed floorspace seems to apportion an amount of basement space and subtract it from the proposed floorspace per land use. The calculation should simply not include any basement space or service yard. The approach needs to be amended to reflect actual land uses proposed, excluding those elements set out in paragraph 4.26 of the SPG. A plan showing the areas calculated regarding basement and service area for existing and proposed should be provided to ensure an accurate approach has been adopted.

Vehicle parking

49 The submission documents include a total of 29 car parking spaces for operational use only within the basement area, this includes three accessible disabled parking bays. A further two new disabled parking spaces are proposed at-grade on Upper Ground. However following discussion the applicant has agreed to increase the provision to seven spaces.

50 TfL understands that Southwark Council is seeking for all proposed car parking to be designed in accordance with DfT disabled parking guidelines to facilitate disabled parking demand. Any remaining unused bays can be allocated towards operational car parking and controlled with a car parking management plan.

51 This desire is supported by TfL to ensure conformity with London Plan policy 6.13 Parking as the proposed level of car parking conflicts with London Plan policy objectives which seek to ensure that on-site car parking at new developments is the minimum necessary and that there is no over-provision that could undermine the use of more sustainable non-car modes. Electric vehicle charging points have been proposed in line with London Plan standards. This should be conditioned by Southwark Council.

page 12 Pedestrians

52 In order to ensure conformity with London Plan policy 6.10 Walking a robust assessment of pedestrian levels of service around the site should be conducted by the applicant, this is required to determine whether any pedestrian improvements within the vicinity of the site are needed. TfL’s Pedestrian Comfort Guidance tool should be used.

Cycle parking

53 A total of 176 cycle spaces are proposed within the basement for the use by staff and guests in line with the minimum standards of the London Plan. However following discussion with Southwark Council TfL has a better understanding of the demands for cycle parking in this area related to the proposed land uses. As a result TfL recommends that the level of cycle parking provision is increased, both in terms of on-site and off-site provision (i.e. visitor parking).

54 In addition to this TfL requests the safeguarding of land and a contribution of at least £195,000 towards the installation, operation and maintenance of a Mayor’s Cycle Hire docking station at this location. This must be secured to ensure accordance with the Mayor’s objectives to increase the cycle mode share to 5% in accordance with London Plan policy 6.9 Cycling.

Blackfriars Road

55 In partnership with Southwark Council, TfL is developing a public realm enhancement scheme for Blackfriars Road. This is aimed at improving the overall quality of the environment along Blackfriars Road including junction re-design at Blackfriars Road/Southwark Street, pedestrian and cycling improvements, tree planting and materials. In order to ensure consistency with London Plan policies 6.9 Cycling and 6.10 Walking and in line with other recent proposals in the area, there needs to be a consideration of the cumulative impacts of all development on Blackfriars Road, this is not only in terms of increased pedestrian use but additional taxi/vehicle, public transport, servicing, coach and cycle trips. As will all the other sites within the area both TfL and Southwark Council expect this development to make an appropriate contribution towards this scheme.

Coach parking

56 The London Plan states that development should provide for one coach parking space per 50 rooms for hotels, this would equate to a minimum of 7 spaces being required. However TfL considers this level of coach parking provision would be difficult to deliver at this site and therefore it is recommended that other near-by coach facilities are identified to facilitate coach trips generated from this development. In order to ensure consistency with London Plan policy 6.8 Coaches a strategy setting out how guests will travel to and from these pick-up/drop-off bays safely and conveniently should be included as part of the delivery and servicing plan.

Highway impacts

57 TfL considers that the proposals will not have an unacceptable impact on the local highway network and public transport network. However the submitted framework travel plan has failed the ATTrBuTE assessment and further work is required to remedy this before determination. The Travel Plan must be secured, enforced, monitored, reviewed and funded through the s106 agreement. This will ensure consistency with London Plan policy 6.3 Assessing effects of development on transport capacity.

58 In order to mitigate any adverse impacts of construction and servicing traffic on the Transport for London Road Network and local road network, the submitted construction logistics

page 13 plan and delivery and servicing plan should be secured by way of planning conditions. This will ensure consistency with London Plan policy 6.14 Freight.

59 In summary a number of issues need to be resolved including the need for a Crossrail contribution, the car parking provision, pedestrian environment, coach facilities, travel plan improvements in line with TfL recommendations and a delivery and servicing plan and construction logistics plan, both which should be secured by condition.

Local planning authority’s position

60 The officer recommendation is currently unknown. Legal considerations

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

62 There are no financial considerations at this stage. Conclusion

63 London Plan policies on are CAZ, office, urban design, access, heritage, strategic views, climate change, transport including Crossrail are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Principle of development: (non-compliant) the reduction in office space in the CAZ requires further justification.  Urban design and access (non-compliant): The report identifies some detailed design matters that require further consideration, including layout of land uses along the western elevation, access and level change along the eastern elevation, introduction of an internal lift at the hotel lobby, details regarding materials and further images of the level change at Upper Ground into the refurbished office building.  Climate change mitigation (non-compliant): Further technical work is required as set out in this report including energy efficiency and details of the location for the energy centre including its size and layout.  Climate change adaptation (compliant): broadly acceptable subject to conditions set out in this report.  Transport (non-compliant): A number of issues need to be resolved including the Crossrail contribution, car parking provision, pedestrian environment, coach facilities, Travel Plan

page 14 improvements in line with TfL recommendations and a delivery and servicing plan and construction logistics plan both secured by condition. 64 On balance, the application does not comply with the London Plan 65 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan  Principle of development: Further detail regarding the marketing of the site for office tenants and structural evidence to support the proposed approach is required given the significant reduction in office floorspace.  Urban design and access: The design team need to reconsider a number of matters as set out in this report, including the land uses along the western elevation and animating the space. Level access along the eastern route, introduction of an internal lift at the hotel lobby, further images of the ramped arrangement at Upper Ground, introduction of a changing places WC in the refurbished office, plans showing the wheelchair accessible units and arrangement for wheelchair access to the gym. Furthermore, the applicant should confirm the proposed materials for all elements of the development.

 Climate change mitigation: The applicant should reconsider the energy efficiency side so as to meet Building Regulations 2010 through energy efficiency alone. The applicant should also provide a plan showing location of the energy centre including its size and layout.

 Transport: A number of issues need to be resolved including the Crossrail contribution, the car parking provision, pedestrian environment, coach facilities, travel plan improvements in line with TfL recommendations and a delivery and servicing plan and construction logistics plan both which should be secured by condition by Southwark Council.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Matthew Carpen, Case Officer 020 7983 4272 email [email protected]

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