planning report GLA/4120/01

17 December 2018 154-172 Powis Street & 125–129 High Street

in the Royal Borough of

planning application no. 18/3068/F

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

The proposal Demolition of existing buildings and the erection of 3 buildings between 3 storeys and 23 storeys, with basement, containing 296 residential units, 1,158 sq.m. of retail, co-working and community floorspace; and cycle parking, car parking, playspace, landscaping and public realm improvements.

The applicant The applicant is Artisan Woolwich Ltd, and the architect is Conran + Partners.

Strategic issues summary Principle of development: The proposed residential-led mixed use redevelopment of the site would contribute to the vitality of the Town Centre and the wider objectives of the Opportunity Area and is supported in strategic terms (paragraph 15). Affordable housing: The scheme proposes 22% by habitable room (60 affordable rented units), which is unacceptable. GLA officers will robustly interrogate the applicant’s viability assessment and the Council’s independent review to ensure that the maximum level of affordable housing is delivered. If after interrogation affordable provision remains below 35%, both an early and a near end review mechanism will be required. The proposed rents must also be secured as genuinely affordable (paragraphs 18-21). Heritage and urban design: The development would cause less than substantial harm to the setting of the Grade II* listed former Granada Cinema; the acceptability of this will be subject to the scheme delivering appropriate public benefits, most noticeably affordable housing. Further consideration should also be given to reducing the height of Block B (paragraphs 23-32). Climate change: The applicant should explore additional measures aimed at achieving further carbon reductions. Further revisions and information relating to energy efficiency modelling, cooling, ASHP, district heating and heat network are required; and any outstanding regulated CO2 emissions must be met through a contribution to the borough’s offset fund. The surface water drainage strategy should be reviewed giving consideration to the practicality of rainwater harvesting and reuse (paragraphs 33-36). Transport: A detailed DSMP, full CLP and car park design and management plan should be secured by condition. Clarification on whether there is a formalised area for vehicles to load/unload is required and 20% active charging points must be provided from the outset with all the remaining spaces provided with passive provision in line with draft London Plan standards (paragraphs 37-46).

Recommendation That Greenwich Council be advised that the application does not comply with the London Plan and draft London Plan for the reasons set out in paragraph 50 of this report. However, the resolution of these issues could lead to the application becoming compliant with the London Plan and draft London Plan.

page 1 Context

1 On 4 October 2018, the Mayor of London received documents from Greenwich Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor must provide the Council with a statement setting out whether he considers that the application complies with the London Plan and draft 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 Categories 1A, 1B and 1C of the Mayor of London Order 2008:

• Category 1A: “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.”

• Category 1B: “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings—outside Central London and with a total floorspace of more than 15,000 square metres.”

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

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

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 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 site is approximately 0.4 hectares and is located within Woolwich Town Centre, which forms part of the area identified as the Woolwich Opportunity Area in the London Plan and draft London Plan. It is included in the Former Gala Bingo and Mortgramit Square site (Site 11) identified for redevelopment in the Woolwich Town Centre Masterplan.

7 Approximately 190 metres south of the , the site is bounded by the A206, Mortgramit Square and the Grade II* listed former Granada Cinema. Other listed buildings nearby include Cooperative Society Headquarters Building (Grade II), Church of St. Magdalene (Grade II*), New Wine Church (Grade II) and Thomas Cribb Monument (Grade II) as well as a locally listed building, which now accommodates the Emporium housing development, is next to the site. The Royal Arsenal Conservation Area is approximately 250 metres north east of the site. The site is occupied by a garage (4-5 storeys) and workshops and small 2-3 storey buildings that are unoccupied or used for commercial/retail activity.

8 The A206 Woolwich Road forms part of the Strategic Road Network (SRN) for which TfL has a duty to ensure that any development does not have an adverse impact without appropriate

page 2 mitigation. The nearest part of the Transport for London Road Network (TLRN), the A205, is located approximately 100 metres to the west of the site.

9 There are a number of bus routes available within 400 metres on a number of surrounding streets, including Powis Street, Hare Street and Woolwich High Street. Woolwich Arsenal and are within 800 metres; and Docklands Light Railway (DLR) services are available at Woolwich Arsenal. The Elizabeth Line will also serve Woolwich. The ferry at Woolwich Pier South runs to Woolwich Pier North (north side of the river) and the nearest London Underground station is at North Greenwich 3.1 miles to the west of the site. The site therefore records a PTAL 6a, which is an excellent level of accessibility to public transport services. The closest cycle route to the site is the signed/marked cycle route along John Wilson Street/South Circular Road. Details of the proposal

10 Full planning permission is sought for the demolition of the existing buildings on site and the erection of three buildings ranging in height from 3 to 23 storeys, comprising:

• 296 residential units (including 143 PRS units); • 603 sq.m. of flexible co-working and community use space; • 237 sq.m. of flexible community and internal play space; • 240 sq.m. of retail floorspace; • 28 Blue Badge parking spaces; and, • 473 cycle parking spaces;

Case history

11 GLA officers held pre-application discussions with the applicant in November 2016 and November 2017. The principle of a residential-led mixed use development was supported in strategic planning policy terms given its potential contribution towards housing delivery, placemaking and public realm improvements within the Woolwich Opportunity Area; however, issues regarding loss of/re-provision of social infrastructure/community use, affordable housing, and design needed to be addressed to ensure compliance with the London Plan and draft London Plan. Strategic planning issues and relevant policies and guidance

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 Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014); and the London Plan 2016 (The Spatial Development Strategy for London Consolidated with Alterations since 2011). 13 The relevant issues and corresponding policies are as follows: • Opportunity Areas London Plan; • Town centres London Plan; Town Centres SPG; • Housing London Plan; Housing SPG; Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context SPG; • Affordable housing London Plan; Housing SPG; Housing Strategy; Mayor’s Affordable Housing and Viability SPG;

page 3 • Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG; • Heritage London Plan; • Inclusive design London Plan; Accessible London: Achieving an Inclusive Environment SPG; • Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Environment Strategy; • Transport London Plan; Mayor’s Transport Strategy;

14 The following are relevant material considerations:

• National Planning Policy Framework and National Planning Practice Guidance; • Draft London Plan (consultation draft December 2017 incorporating early suggested changes published August 2018); • Royal Greenwich Local Plan: Site Allocations, Issues and Options Consultation, Feb 2016. Principle of development

15 The optimisation of residential output and densities in Opportunity Areas is supported under Policy 2.13 of the London Plan. Policies GG” and SD1 emphasise the maximisation of affordable housing delivery and creation of mixed and inclusive communities in Opportunity Areas. As indicated at paragraph 6, the site is within the Woolwich Opportunity Area, which is identified in the London Plan as having capacity to deliver 5,000 jobs and a minimum of 5,000 new homes. The proposed residential-led mixed use redevelopment of the site would contribute to the vitality of the Town Centre and the wider objectives of the Opportunity Area and is supported in strategic terms. Re-provision of social infrastructure

16 London Plan Policy 3.16 and draft London Plan Policy S1 seek to protect social infrastructure. The site previously contained a 692 sq.m. day nursery, which has been re-located within Woolwich Town Centre. The application proposes the re-provision of 237 sq.m. of flexible floorspace for community use. Noting that the nursery has been successfully relocated, the proposed net reduction in on-site community use space is acceptable in strategic planning terms. Housing

17 London Plan Policy 3.3, in seeking to increase the supply of housing in London sets borough housing targets and in Table 3.1 puts the minimum annual monitoring target for the Royal Borough of Greenwich at 2,685 additional homes per year between 2015 and 2025. Draft London Plan Policy H1 sets a higher target of 3,204 per year for the period 2019 to 2028. The applicant proposes to provide 278 new homes at this site and this provision is strongly supported in strategic planning terms in accordance with London Plan Policy 3.3. The scheme would deliver 293 new homes, which would contribute positively to this target. The proposed unit and tenure mix is set out below in Table 1.

Table 1: Proposed residential schedule

tenure studio 1-Bed 2-Bed 3-Bed total/u total/hr hr % private sale - 24 61 8 93 263 34%

page 4 private rented 17 56 62 8 143 347 44%

affordable rent - 22 27 11 60 169 22% total 17 102 150 27 296 779 100%

Affordable housing

18 London Plan Policy 3.12 seeks the maximum reasonable amount of affordable housing. Policy H5 of the draft London Plan sets a strategic target of 50%, and Policy H7 provides a flexibly prescribed tenure mix of: a minimum of 30% social rent/London Affordable Rent; 30% intermediate products (with London Living Rent (LLR) and shared ownership being the default tenures); and, 40% to be determined by the relevant borough based on identified need and consistency with the definition of affordable housing.

19 Policy H6 of the draft London Plan and the Mayor’s Affordable Housing and Viability SPG set out his preferred approach to the delivery of affordable housing, introducing a Fast Track Route for applications that deliver at least 35% affordable housing (by habitable room) on site, without public subsidy, subject to tenure and increasing this further with grant funding. The document also sets out detailed guidance to the form, content and transparency of viability assessments and the requirements for review mechanisms. Schemes involving Build to Rent units should provide at least 30% of the units at London Living Rent Level, with the remainder being at a range of discounts below market rent to be agreed with the borough or the Mayor.

20 The scheme would deliver 60 affordable rented units, which equates to 22% affordable housing by habitable rooms. Whilst the prioritisation of this tenure is strongly supported, the overall provision of affordable housing is unacceptable at this stage, pending rigorous viability interrogation. The applicant has submitted a financial viability assessment with the application and on receipt of the Council’s independent review, GLA officers will robustly interrogate both assessments to ensure that the maximum level of affordable housing is delivered. If after interrogation the maximum level of affordable provision remains below 35%, both an early and a near end review mechanism will be required as set out in the Mayor’s Affordable Housing and Viability SPG and draft London Plan. An early review mechanism will be required if the 35% threshold is met. The Council has published the financial viability assessment in accordance with the Mayor's Affordable Housing and Viability SPG and draft London Plan to ensure transparency of information. The applicant is engaging with a Registered Provider and the use of grant to increase the provision of affordable housing should be explored as part of the discussion.

21 The proposed weekly rents, which are set out in Table 2 below, are in excess of London Affordable Rent levels. The applicant must commit to delivering genuinely affordable housing and is strongly encouraged to provide these units at London Affordable Rent levels. As an absolute minimum, the affordable rent levels must be demonstrated as affordable to those on local housing allowance.

Table 2: Proposed rent levels unit Market rents (derived from London Affordable Rent Proposed rent London Rents Map) 1-Bed £219.25 £144.26 £159.81 2-Bed £288.46 £152.73 £220.85 3-Bed £321.92 £161.22 £279.00

page 5 Children’s play space

22 In accordance with London Plan Policy 3.6 and draft London Plan Policy S4, development proposals that include housing should provide playspace for children based on the short and long- term needs of the expected child population generated by the scheme. Further detail in the Mayor’s supplementary planning guidance ‘Shaping Neighbourhoods: Play and Informal Recreation’ sets a benchmark of 10 sq.m. of useable child play space to be provided per child, with under-fives play space provided on-site as a minimum. A total of 724 sq.m. (including 400 sq.m. for Under 5s) of on-site playspace is required for this scheme based on the expected child yield. Internal play space would be provided within the 237 sq.m. of community use space on the ground floor of Block AB and further play areas would be available within the public square and at roof level on blocks C and B. The proposed play space would be diverse and allow for passive surveillance and would meet the requirement for on-site provision for Under 5s. The Council should ensure that the rooftop play areas are safe and the applicant should engage with the Council regarding any required contributions toward off-site provision. Heritage and urban design

23 The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the tests for dealing with heritage assets in planning decisions. In relation to conservation areas, for all planning decisions “special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area”. Regarding listed buildings, all planning decisions should “have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses”. The NPPF states that when considering the impact of the proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation and the more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting.

24 As indicated in paragraph 7 of this report, the site sits next to the Grade II* listed former Granada Cinema and there are other heritage assets in proximity. The applicant has submitted a Heritage, Townscape and Visual Impact Assessment (HTVIA) as part of Volume II of the Environmental Statement. In View 8 of the HTVIA, the proposed tall buildings would be visible above the existing roof profile of Cinema and fill most of the clear sky back drop to the cinema when viewed from South Circular opposite Powis Street. However, the design and massing of the tower contrasts with the curvilinear facade of the listed asset, and this feature of the building remains prominent. It is also noted that in analysing this asset, Historic focuses on the interior concluding that it is “one of the finest and most important cinema interiors in Britain, being one of the only two with convincing Gothic decoration”.

25 Having regard to the statutory duty in respect of listed building and conservation areas in the Planning (Listed Buildings and Conservation Areas) Act 1990, and the relevant paragraphs in the NPPF, GLA officers consider that the proposed development would cause less than substantial harm to the setting of the nearby Grade II* listed former Granada Cinema and would not cause harm to the other nearby assets. The NPPF at paragraph 196 makes clear that where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use. The acceptance of this less than substantial harm will be subject to the scheme delivering the maximum level of affordable housing as determined by GLA officers after a robust assessment of the applicant and Council’s financial appraisals.

page 6 Density

26 London Plan Policy 3.4 and draft London Plan Policy D6 seek to optimise the potential of sites, having regard to local context, design principles, public transport accessibility, and capacity of existing and future transport services. The higher the density of a development, the greater the level of design scrutiny that is required, particularly qualitative aspects of the development design, as described in draft London Plan Policies D4 and D2.

27 The net residential density for the proposed development is 1,997 habitable rooms per hectare, which with a PTAL of 6a and a central character setting, exceeds the guidance ranges in Table 3.2 of the London Plan and the thresholds for increased scrutiny of design quality set out in the draft London Plan. Given the location of the site within the Opportunity Area and town centre and high PTAL and optimisation of land use, the increased density on this site could be supported provided the design is of the highest quality and the provision of affordable housing increased. In line with Policy D6, a management plan detailing day-to-day servicing and delivery arrangements and long-term maintenance implications, as detailed in paragraph 3.6.8 of the draft London Plan will also be required. The agreed maintenance plan should be secured by condition as part of any permission.

Site layout

28 The layout is broadly supported, and blocks are positioned to create a legible sequence of public realm flanked with commercial frontage and generously sized residential lobbies. The proposed scheme consists of three blocks, with two perimeter Blocks D and C and Block AB forming a simple podium block with a residents’ courtyard within. The amount of active frontage has been maximised, with significant improvements to Mortgramit Square and Woolwich High Street, as well as the establishment of a continuous building line along this corner of the high street. The site’s permeability would also be significantly improved with pedestrian access from Woolwich High Street. There are however concerns about the pedestrian environment and this is detailed later in this report under Transport.

Residential quality and inclusive design

29 All units would meet the London Plan, draft London Plan and Mayor’s Housing SPG internal space standards. In terms of private outdoor amenity, all units would have access to balconies, terraces or winter gardens that comply with the Housing SPG standards. None of the units are north facing single aspect and there is a large number of dual aspect units. For the most part, there would be efficient cores in line with the Mayor’s Housing SPG. In Block AB, however, there would be 12 units per core; but with the inclusion of a deck access that would allow light into the corridor this is considered acceptable. Nevertheless, the applicant should still consider separating the two lifts and re-providing along the southwestern section of the corridor. There also instances in Block C where there are 9 units per core, given the approach to the internal corridor this is considered acceptable. The applicant should confirm that the floor to ceiling height is at least 2.5 metres.

30 The proposal responds positively to London Plan Policy 3.8, as 90% of all units would meet Building Regulation requirement M4 (2) ‘accessible and adaptable dwellings’, and 10% would meet Building Regulation requirement M4 (3) ‘wheelchair user dwellings’.

Form and height

31 The design steps the massing down across the site from Woolwich High Street to Powis Street. The height of the tallest element would appear prominent in both immediate and longer- range views and its efficient footprint gives potential to form a distinctive landmark in the context of the emerging skyline, as well as acting as a landmark to the western end of Powis Street to assist page 7 in local way finding and the street facing blocks complete the urban block and broadly respond to both the existing and emerging wider context. The removal of the cranked portion of block B and the resulting increase in the separation distance between the towers is welcomed; however, consideration should still be given to reducing the scale of block B to create clear height distinction between A and B.

Appearance

32 The use of brick is welcomed, as it is consistent with the material evident on the nearby buildings, and as such responds positively to its setting. The Council’s planning officers should seek to secure key details including facing materials, window reveals, balconies and rooflines to ensure an exemplary quality of architecture is delivered. In accordance with Policy D11 of the draft London Plan, the Council should include an informative prescribing the submission of a fire statement, produced by a suitably qualified third-party assessor. Climate change

Energy strategy

33 The applicant has submitted an energy assessment in accordance with London Plan Policy 5.2 and draft London Plan Policy SI2. An on-site reduction of 135 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected for the domestic element, equivalent to an overall saving of 41%; and for the non-domestic element, a reduction of 26 tonnes of CO2 per year and an overall saving of 28% is expected. In both instances, the expected carbon savings fall short of London Plan and draft London Plan targets; therefore, the applicant should explore additional measures aimed at achieving further carbon reductions. Further revisions and information relating to energy efficiency modelling, cooling, ASHP, district heating and heat network are required. Any outstanding regulated CO2 emissions must be met through a contribution to the borough’s offset fund. Full details of the outstanding issues relating to energy have been provided directly to the applicant and Council.

Flood risk, sustainable drainage and water efficiency

34 The site is located within Flood Zone 1, and the flood risk assessment (FRA) submitted with the application considers the risk of flooding from a range of sources. When mitigation measures are considered, the residual flood risk to the site is low. The approach to flood risk management for the proposed development complies with London Plan Policy 5.12 and draft London Plan Policy SI12.

35 The surface water drainage strategy partly addresses the London Plan and draft London Plan drainage hierarchy. No consideration of the practicality of rainwater harvesting and reuse has been made and attenuation tanks and green roofs are proposed as the main SuDS measure. This approach does not satisfy the requirements of London Plan Policy 5.13 and draft London Plan SI13. Further details are therefore required on how SuDS measures at the top of the drainage hierarchy would be included in the development; and additional attenuation storage volume calculations should also be provided.

36 Regarding water efficiency, the proposed development generally meets the requirements of London Plan policy 5.15 and draft London Plan policy SI5. The applicant should, however, consider water harvesting and reuse to reduce consumption of wholesome water across the entire development site, which can be integrated with the surface water drainage system to provide a dual benefit.

page 8 Transport

Bus stop

37 The proposed reconfiguration of the shelter at the bus stop on Woolwich High Street is supported; however, the bus stop must not to be moved and all costs must be met by the developer.

Healthy streets

38 As previously mentioned, the site would benefit from a more permeable and improved pedestrian/cycle access from Woolwich High Street, which would help to make the site more permeable and accessible on foot and by bicycle. The main residential access for Block C is via the central square and there is no access from the high street, other than through the community space making the area dependent on community areas (therefore the access is not open 24 hours as it depends on the community space being open). This increases reliance on the Hare Street / Mortgramit Square link for pedestrian access to the block C lobby, which is undesirable due to the distance for people to walk and the narrow Hare Street link, which is also used for servicing. A pedestrian access directly into the block C lobby from Woolwich High Street should be considered.

39 Given that the site is only providing disabled persons car parking spaces and is expected to generate only a limited number of vehicular trips, the Powis Street access design should include clear pedestrian priority along Powis Street through its paving, creating a more pedestrian friendly environment. The Hare Street / Mortgramit Square access would be used for deliveries and servicing; however, no footway is provided along the south side of Mortgramit Square, which could result in pedestrian/HGV conflicts. This should be reviewed. A footway should also be provided here to in the interest of pedestrian safety.

Car parking

40 The car-free approach, apart from 28 Blue Badge spaces, is supported. The proposed Blue Badge parking provision accords with London Plan and draft London Plan. However, the proposed parking provision does not allow for 1.2 metres safety zones on both sides of each disabled parking space. Whilst the space constraints on site are understood, all options should be explored to increase the number of spaces that have the safety zones on both sides. It should also be noted that the draft London Plan offers greater flexibility for implementing Blue Badge spaces at new residential developments as outlined in Policy T6.1. Moreover, the Blue Badge spaces in the north west of the car park within Block AB car park appear to be partially obstructed and unable to achieve the required dimensions for a disabled parking space. Further swept path analysis should therefore be undertaken, and the car park redesigned where necessary.

41 The aisle width at the car park entrance is considered too narrow to allow for two-way movement in and out of the car park. The applicant should provide swept path analysis to demonstrate that this is possible; or provide a design solution such as widening the site access or providing traffic signals to manage access and egress. If a signalised arrangement is proposed, an assessment should be provided showing the impact during the AM and PM peak in terms of the time vehicles spend waiting within the site boundary.

42 A total of 6 wheelchair accessible parking spaces on site would be equipped with active electric vehicle charging points and the applicant has confirmed that a further 6 could be provided. The applicant should provide 20% active charging points from the outset with all the remaining spaces provided with passive provision in line with draft London Plan standards. A car park design and management plan should be secured by condition.

page 9 Cycle parking

43 The proposed cycle parking, which includes 473 residential cycle parking spaces for the residential units (with 7 visitor cycle spaces) in four cycle stands and 12 spaces on Powis Street for the commercial element, accords with London Plan requirements but not draft London Plan standards. The number of parking spaces should therefore be increased to meet draft London Plan requirements, in doing so the schedule of studio and one-bedroom units must be clarified to ensure the correct level of parking is provided. Cycle parking should be designed to make it easy, safe and convenient for cyclist and a plan showing routes from the public highway to each of the proposed cycle parking locations should be provided. Access to the parking area should be via a maximum of two doors, with a recommended minimum external door width of 2 metres.

44 Showers, changing rooms and storage facilities must be provided for the non-residential uses proposed. The access corridors leading to cycle parking should be at least 3m wide and access should be directly from the core and parking at podium level in block AB and at basement level in Block C should be provided with a dedicated lift or access via a service lift. Finally, residential or commercial visitor cycle parking located in the public realm should avoid any fly-parking around the site.

Supporting plans: deliveries and servicing, construction and travel

45 A delivery and servicing management plan (DSMP) is included in the TA and the plan’s broad details, including rationalising trips and minimising deliveries in peak hours, is welcomed. A detailed DSMP should be secured by condition. The proposed servicing arrangements are very compact, with the servicing and refuse vehicles overhanging and over-running the pedestrianised areas of the site. This would be a safety concern. In addition, there could be vehicle conflict into the swept path of cars accessing the car park and the applicant must clarify whether there is a formalised area for these vehicles to load/unload. Further details should be provided to show how service vehicles would safely access the site and where they will unload

46 A full construction logistics plan (CLP), detailing the proposed access to the site for construction vehicles, the length of the construction programme and plans and diagrams showing the expected routes construction vehicles would use, must be secured. The CLP must also identify efficient and sustainable measures that would be undertaken during construction of the development such as: trip consolidation; secure, off-street loading and drop-off facilities; and using operators committed to best practice such as members of TfL’s Freight Operator Recognition Scheme or similar. Local planning authority’s position

47 Greenwich Council planning officers have engaged in pre-application discussions with the applicant and it is understood that officers are supportive of the principle of development but have concerns in relation to the height. It is also understood that the application will go to Committee in January/February 2019. Legal considerations

48 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

page 10 direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the 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

49 There are no financial considerations at this stage. Conclusion

50 London Plan and draft London Plan policies on Opportunity Areas, Town Centres, housing, affordable housing, social infrastructure, heritage, urban and inclusive design, climate change and transport are relevant to this application. The application does not comply with the London Plan and draft London Plan. The following changes might, however, lead to the application becoming compliant with the London Plan and draft London Plan:

• Principle of development: The proposed residential-led mixed use redevelopment of the site would contribute to the vitality of the Town Centre and the wider objectives of the Opportunity Area and is supported in strategic terms. • Affordable housing: The scheme proposes 22% by habitable room (60 affordable rented units), which is unacceptable. GLA officers will robustly interrogate the applicant’s viability assessment and the Council’s independent review to ensure that the maximum level of affordable housing is delivered. If after interrogation affordable provision remains below 35%, both an early and a near end review mechanism will be required. The proposed rents must also be secured as genuinely affordable. • Heritage and urban design: The development would cause less than substantial harm to the setting of the Grade II* listed former Granada Cinema; the acceptability of this will be subject to the scheme delivering appropriate public benefits, most noticeably affordable housing. Further consideration should also be given to reducing the height of Block B. • Climate change: The applicant should explore additional measures aimed at achieving further carbon reductions. Further revisions and information relating to energy efficiency modelling, cooling, ASHP, district heating and heat network are required; and any outstanding regulated CO2 emissions must be met through a contribution to the borough’s offset fund. The surface water drainage strategy should be reviewed giving consideration to the practicality of rainwater harvesting and reuse. • Transport: A detailed DSMP, full CLP and car park design and management plan should be secured by condition. Clarification on whether there is a formalised area for vehicles to load/unload is required, and 20% active charging points must be provided from the outset with all the remaining spaces provided with passive provision in line with draft London Plan standards.

For further information, contact the GLA Planning Team (Development Management): Juliemma McLoughlin, Chief Planner 020 7983 4271 email [email protected] John Finlayson, Head of Development Management 020 7084 2632 email [email protected] Graham Clements, Team Leader 020 7983 4265 email [email protected] Andrew Payne, Case Officer 020 7983 4650 email [email protected] page 11