planning report 2289/01 29 October, 2009 Canada Water- Site A, Road in the Borough of planning application no. 09-AP-1870

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

The proposal

A detailed application for the erection of a 26-storey tower and 9 other buildings (ranging from 4 to 8 storeys in height) for a mixed-use development comprising 668 residential units, retail space (958 sq.m.), a community facility (268 sq.m.), the creation of open space; and the construction of new access roads; pedestrian and cycle routes; and associated car parking, servicing and landscaping space.

The applicant The applicants are Barratt Homes and British Land (Canada Quays) Ltd, and the architects are Glenn Howells and Hawkins Brown.

Strategic issues The detailed proposal is for a residential-led mixed-use regeneration within the Canada Water masterplan area. The key issues for consideration are the mix of residential, retail and community uses; appropriateness of a tall building, urban design/architectural quality; the size, mix, tenure and level of affordable housing, climate change and energy issues; and the transport and access implications of development

Recommendation That Southwark Council be advised that while the application is generally acceptable in strategic planning terms it does not fully comply with the London Plan, for the reasons set out in paragraph 99 of this report; but the possible remedies set out in paragraph 100 of this report could address these deficiencies.

Context

1 On 25 September 2009, 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 5 November 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

page 1 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 and 1C of the Schedule to the Order 2008:

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

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

3 When Southwark Council has made a resolution as to which way it intends to determine the application, it is required to refer the case back to the Mayor for his decision on 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 application relates to an irregular-shaped site, 2.13 hectares in size, situated on the Peninsular, to the immediate north of Canada Water underground rail and bus station (marked by a circle on the location map below) and the north-west side of Surrey Quays Road.

Map 1: Site location plan- courtesy of Glenn Howells Architects.

page 2 7 Site A encompasses three of five development sites (A1, A2, A3, B1 and B2) for which outline planning permission has been granted as part of an overall Canada Water masterplan. It is bounded on the north-east by Needleman Street, on the south-east by Surrey Quays Road, and along its north-western and western boundaries by the Council-built Albion Estate. It is shown edged in red on the location map above, with site B (comprising B1 and B2) edged in blue.

8 In terms of local connections, the site is approximately 400m from the A200 Jamaica Road/Rotherhithe Approach, part of the Transport for London Road Network. The A200 Lower Road, part of the Strategic Road Network, is approximately 250m from the site. The site is well connected to the cycle network, as National Cycle Route 4 runs along the of the within 350m of the site and a network of off-street cycle paths covers the Rotherhithe peninsula.

9 The site has a public transport accessibility level of 6 on a scale of 1 to 6, where 6 is most accessible. It is adjacent to the underground rail and bus stations at Canada Water, providing access to Jubilee line tube services and, from 2010, London over-ground services on the extended line. Numerous bus routes serve the bus station and Surrey Quays Road, with additional services available on Lower Road and Redriff Road within walking distance.

10 At present, the site comprises a temporary sales and marketing suite for neighbouring new homes, a temporary car park and scrubland.

11 The surrounding area comprises a mix of uses, with a predominance of residential accommodation and retail uses in the Surrey Quays Shopping Centre. Details of the proposal

12 The application is for a residential-led mixed–use development consisting of a 26-storey courtyard tower (A4) located at the southern tip of the site, and three courtyard developments (A1, A2 and A3) made up of individual buildings of varying (4-8 storeys) height.

13 The development would comprise 668 residential units, of which 170 units would be affordable; 958 sq.m. of ground floor retail space fronting onto Surrey Quays Road, a 268 sq.m. community facility and associated infrastructure.

14 Vehicular access would be from Needleman Street into Swan Road through the northern portion of the site, and from Surrey Quays Road into Clack Street through the southern portion of the site. The two new roads would provide direct access to basement parking at sites A1, A2 and A3, with a combined total of 174 car spaces and 1,030 bicycle spaces.

Case history

15 Southwark Council’s approved a masterplan vision for the Canada Water area in October 2005.

16 A temporary five-year permission was granted in October 2008 for a two-storey marketing suite and six off-street parking spaces that now occupy the site.

17 On 6 November 2008, a pre-application meeting was held with GLA officers to discuss a proposal for redevelopment of Site A comprising 757 new homes and approximately 2,000 sq.m. of non-residential (mostly retail and community) space, including a 27-storey tower adjacent to Canada Water station and a series of courtyard blocks varying between five and seven storeys Strategic planning issues and relevant policies and guidance

page 3 18 The relevant issues and corresponding policies are as follows:

• Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, draft Housing Strategy • Affordable housing London Plan; PPS3; Housing SPG, draft Housing Strategy • Density London Plan; PPS3; Housing SPG • Retail London Plan; PPS6; PPG13 • Mix of uses London Plan • Urban design London Plan; PPS1 • Tall buildings/views London Plan; View Management Framework SPG, draft Revised View Management Framework SPG • Transport/parking London Plan; the Mayor’s Transport Strategy; PPG13; • 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) • 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) • Sustainable development London Plan; PPS1, PPS Planning and Climate Change Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy Strategy; Sustainable Design and Construction SPG • Biodiversity London Plan; the Mayor’s Biodiversity Strategy; Improving Londoner’s Access to Nature: Implementation Report; PPS9 • River Thames/flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B

19 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 Unitary Development Plan and the London Plan (Consolidated with Alterations since 2004).

20 The following are also relevant material considerations: • The Consultation Draft Replacement London Plan • The Southwark Core Strategy (Pre-Submission Stage). • The Canada Water Area Action Plan, which is at preferred options consultation stage.

Land use policy and the principle of a mixed-use development

21 The London Plan identifies Canada Water/Surrey Quays as a 47-hectare ‘Area for Intensification’, of which the application site forms a small part. Policy 2A.6 aims to maximise the benefits of good public transport accessibility in such areas and the potential to increase residential, employment and other uses, through the provision of higher densities and more mixed and intensive uses. This is supported further by policy 5D.3, which seeks to accommodate growth in South East London by promoting higher density redevelopment in town centres and at key transport nodes with good capacity and accessibility, and to achieve higher levels of provision, especially housing, wherever possible.

22 The intensification of Canada Water/Surrey Quays is thus focused on the transport interchange and district shopping centre, with significant potential for the development of infill

page 4 and the intensification of existing commercial sites. More specifically, the London Plan envisages a capacity for 2,000 jobs and 2,000 new homes in the Canada Water/Surrey Quays area by 2026 (Table 5D.1). This is taken forward to table A1.2 in the draft replacement London Plan.

23 It is evident from the foregoing that the principle of a mixed-use development on the application site supported from a strategic policy perspective. It is also in line with the Southwark UDP site allocation and the subsequent grants of planning permission issued in respect of sites within the Canada Water masterplan area.

24 The opportunity for a regeneration of the application site and the adjoining area has been enhanced by disuse of the former docks and construction of the relatively new Canada Water and Surrey Quays transport interchanges in close proximity to an urban brownfield site with excellent accessibility. Housing issues

25 The residential-led development would include 668 new homes of varying size and tenure. It would include a range of studio, one, two and three-bedroom flats and 5 four-bedroom town houses. This is a significant proportion of the London Plan annual target of 1630 homes for Southwark over the ten-year period from 2007/8 to 2016/17. (2005 homes in the draft replacement London Plan).

26 A breakdown of the proposed housing is provided in the following table: tenure dwelling size total % by tenure studio 1-bed 2-bed 3-bed 4-bed - market 29 234 211 24 0 498 75 social rented 0 26 43 49 5 123 18 shared ownership 0 27 20 0 0 47 7 affordable total 0 53 63 49 5 170 25 overall total 29 287 274 73 5 668 100 % by mix 4 43 41 11 1 100 -

27 London Plan policies 3A.3 and 4B.1 highlight the need for development proposals to achieve the maximum intensity of use compatible with local context, the design principles of the compact city, and public transport accessibility. Table 3A.2 of the London Plan provides guidelines on density in support of policies 4B.1 and 3A.3.

28 The density of development would be 323 units (or 867 habitable rooms) per hectare, based on a net residential area of 2.07ha. This is above the upper end (260 u/ha or 700 hr/ha) of the indicative range for a site in an urban setting with the maximum public transport accessibility level of six. Whilst this density is inflated by the proposed 26-storey tower block, it is acceptable in strategic planning terms given the close proximity of the development to a choice of public transport facilities.

29 With regard to the mix of housing, only (78) 11.6% of the 668 units would have three or more bedroom units. Though more than half (56%) of those would be for social renting rather than market sale, the overall proportion of large family units falls well short of the Mayor’s Housing SPG target, which aims to secure 30% of all new homes as family units. With 36% of the total 123 units allocated for social renting, the proposal also falls short of the Housing SPG and the Draft Housing Strategy target, which seeks 42% of all social rented units as family units. It is evident from this,

page 5 that the development would provide a high proportion of one and two-bed units and a correspondingly low number of family-sized units. As such consideration should be given to increasing the number of family-sized units within the scheme.

Affordable housing

30 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, 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.

31 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. This approach is taken forward in policy 3.13 of the draft replacement London Plan.

32 The 2007 Southwark UDP set a target of 35% affordable housing in Canada Water, split on a ratio of 70:30 social rented to intermediate housing. It is evident from the above breakdown, however, that the applicants’ proposal of 25% affordable housing by unit (30% by habitable room) falls significantly short of this target. A toolkit appraisal has not been submitted to allow verification that the affordable housing contribution is indeed the maximum reasonable amount that is financially viable for this scheme, despite GLA officers’ written advice following two pre- application meetings. As such the proposal does not comply with policy 3A.10 of the London Plan. Children’s play space

33 Policy 3D.13 of the London Plan sets out that “the Mayor will and the boroughs should ensure developments that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.” This approach is taken forward in policy 3.6 of the draft replacement London Plan. 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 208 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 2,080 sq.m. of playspace.

34 The development would provide 8,914 sq.m. of private amenity space, including children’s play space. The provision comprises three courtyards, private terraces, balconies and roof gardens. Specially designated informal play areas would be incorporated within the communal private courtyards as follows:

page 6 Courtyard Size (sq.m.) Informal play Play area as a area (sq.m.) % of courtyard A1 676 111 16 A2 1,046 208 20 A3 876 122 14 Total 2,598 441 -

35 An additional 838 sq.m. of landscaped open space is available in nearby Needleman Gardens. It is clear from this that the aggregate of spaces provide adequate scope to meet the Mayor’s SPG requirement in respect of children’s play space. Urban design and architectural quality

36 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 include specific design requirements relating to maximising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage, and views. The draft replacement Plan includes further detailed design policy in chapter 7.

Relationship to context

37 The scale and massing of the courtyard blocks (A1 to A3) respond appropriately to the surrounding building heights, the street network and general location of the site. With heights varying from 5 to 8 storeys, the lower four and five-storey blocks would be sited along the internal streets like Swan Road and Clack Street; whilst the higher eight-storey blocks with active retail frontage would be sited along the larger busier Surrey Quays Road. Between these are a series of six to eight storey blocks that are noticeably stepped down towards the northern end of the site in relationship to existing residential development.

38 The progressive increase in height at the southern end of the site culminates in a bold, freestanding, 26-storey landmark tower, sited to add legibility to the transport hub and proposed public plaza (Deal Porter’s Plaza/Canada Water Square) that will form a gateway to Canada Water as a whole.

Figure 2: Model showing proposed scale and massing of the buildings. (Source: Glenn Howells Architects

page 7

Site layout

39 The layout is designed to incorporate the existing and new routes to cater for pedestrian, cycle and vehicular modes of movement throughout the development. Each of the courtyard buildings would have a direct but highly visible access to the principal adjacent street or pedestrian route, and a separate entrance to the well-lit courtyards and amenity spaces; thereby striking an appropriate balance between permeability, security and the efficient use of a highly accessible site.

Internal layouts

40 The internal planning of the units has been designed to meet the Lifetime Homes, Housing Quality Indicators and the Homes and Communities Agency (Housing Corporation) standards. The following table provides a crude comparison between the average net unit sizes of the development and the Mayor’s emerging minimum standards (expressed in gross internal areas), as set out in his consultation draft replacement London Plan.

Unit size Mayor’s Site A Standard (sq.m.) (sq.m.) Studio - 33.2 1 bed 50 50.2 2 bed 61 69.2 3 bed 74 85.2 4 bed 100 143

41 In terms of orientation and natural lighting, 65% of the proposed units would have dual- aspect, though the remaining (35%) single-aspect units are orientated and designed to receive maximum sunlight. None of the single–aspect units would be north-facing.

Architectural expression

42 The tower building is intended to add to an existing cluster of tall buildings (that include the 22-storey Columbia Point and Regina Point) around Porter’s Deal Square, and to complement and enhance the skyline within the vicinity of the site.

Figure 3: Computer-generated image of the proposed 26-storey tower (Source: Glenn Howells Architects)

page 8 43 Designed on a triangular base, the elevations of the tower form three equal planes comprising a series of vertically stacked elements made up of bronze-coloured anodised aluminium panels and full height clear glass panels split on a ratio of one third to two thirds.

44 The ground floor would be allocated to retail use to provide an active link with the hard- surfaced public realm around its base, including Canada Water station and a proposed new public library. However, its architectural form is essentially residential, with its extensively glazed facades offering welcome views towards and the City of London. The tower would be linked to the new low-rise buildings by a single-storey glazed podium.

45 The courtyard buildings provide a variety of typologies to reflect the diversity of architectural styles within the locality.

Figure 4: View of residential typology along Needleman Street. (Source: Glenn Howells Architects)

46 On the whole, the proposals are a positive response to the challenge of optimising the development density of a highly accessible site, whilst maximising the provision of amenity space, the public realm and general security. Access/social inclusion

47 For internal circulation, all residential units are intended to meet the Lifetime Homes standard, with over 10% of the total either adapted or adaptable to wheelchair accessible standards. A total of 69 wheelchair-housing units would be provided, of which 39 would be fully adapted prior to first occupation. The blocks containing wheelchair-adapted units would be served by two lifts, with all other low-rise blocks served by at least one. The wheelchair units would be distributed across the various types, sizes and tenure of accommodation, taking into account the phasing of the development.

48 The residential tower would be equipped with two lifts. For emergency evacuation, the passenger lifts in the tower would serve as fire fighting lifts available for use by people with impaired mobility in the event of an emergency.

49 Externally, the topography of the site is characterised by a level change of approximately 1.5 metres over a distance of 250 metres. As such, the principal entrances for occupants and visitors to the residential units would have level thresholds located at street level around the perimeter (including Swan Road and Clack Street) of the courtyard blocks and base of the tower building. Ramped vehicle and cycle access to the basement car and cycle parking, refuse and plant storage areas.

page 9 50 Given its high level of public transport accessibility, the development is designed to minimise use of the private car. Nonetheless, over 20% of the total provision of parking bays would be wheelchair accessible and sited in close proximity to the lift cores. Car and taxi pickup and drop- off bays would be provided on Surrey Quays Road, Swan Road and Clack Street. Transport for London’s comments

Transport assessment

51 TfL questions the residential modal split used, particularly in relation to the car driver, ‘tube’, train, and bus figures. Further details of the underlying assumptions are required.

Walking and cycling

52 TfL welcomes the new pedestrian and cycle links that would be created by this proposal, which will improve permeability in the area and improve access to public transport. The site should have greater integration with TfL’s Strategic Walk Network (SWN), which runs around the peninsula; potential connections and improved signage within the site should be further investigated and funded by the developer. TfL seeks a contribution of £8,000 for improvements to the SWN in the vicinity of the site, which would help ensure compliance with London Plan policy 3C.21 Improving conditions for walking.

53 In line with TfL’s cycle parking standards, a total of 1,088 covered cycle parking spaces are proposed for the residential element and would be provided in clusters around the basement cores. Clarification is required regarding the provisions for securing these spaces and the means of access to the surface for cyclists. A total of 80 spaces would be distributed throughout the public realm for site visitors and the retail element of the scheme. TfL notes that a minimum of 19 spaces would be required to meet TfL’s cycle parking standards for the retail element and should be secure, internal spaces for staff cyclists. Furthermore, the applicant should demonstrate that a number of the visitor spaces would be convenient to the community space.

54 Overall, TfL requires the level of staff cycle parking to be increased and suitably provided, in order to comply with London Plan policy 3C.22 Improving conditions for cycling. Additional details regarding the location, access routes, and security arrangements are required.

Public cycle facility

55 As part of the outline application for Sites A, B, and the public plaza, provision of a secure, covered public cycle facility with a minimum capacity for 60 cycles and storage facilities for cycling gear were required to address the shortage of cycle parking in the area. Several discussions have taken place between TfL, Southwark transport planners and the applicant, to agree the location and details of the public cycle facility. Aside from the features required at outline stage, TfL and Southwark considered that the facility should be located in a highly visible location near the entrance to Canada Water station which did not obstruct the footway or encourage cyclists to ride through the bus station and should provide private changing cubicles. The preferred location was within block A4 facing the side of the bus station.

56 In contrast to the advice provided as part of these discussions, a cycle facility has been proposed on the west side of block A4, directly adjacent to a plot of land at the rear of Canada Water bus station. This location is unacceptable to TfL as it would block the emergency egress route from the underground station and would also block pedestrian access into the northern end of the bus station. Furthermore, the proposal does not appear to provide the required storage for cycling gear, and the vertical timber lattice design does not provide shelter from the elements.

page 10 57 Overall, the location is unacceptable on safety grounds, and it is TfL’s view that the proposed facility does not meet the other requirements set out as part of the outline planning permission. TfL considers that the present proposals for the cycle facility not only fail to comply with London Plan policy 3C.22 Improving conditions for cycling but are also contrary to policies 3C.4 Land for transport, 3C.10 Public transport security, and 3C.20 Improving conditions for buses. TfL would welcome further discussion with the developer and Southwark Council at the earliest opportunity.

Car parking

58 A total of 174 car parking spaces are proposed for the residential element of the proposal, of which 36 are disabled spaces; this equates to 0.26 spaces per unit. These would be spread across 3 proposed ‘doughnut’ basement car parks, which follow the footprint of the buildings above ground. TfL welcomes the relatively low level of parking, although a further reduction in car parking is encouraged given the site’s excellent public transport links and the likely impact on the already-congested local roads. In addition, TfL requires the provision of a number of electric vehicle charging points, in line with the consultation draft replacement London Plan. This states that 20% of all residential spaces must be able to charge electric vehicles, with an additional 20% passive provision whereby additional spaces or points can be provided at the time of implementation or at some time in the future.

59 Two car club spaces would be provided on Needleman Street and the retail and community/leisure uses are proposed to be car-free, which is welcomed in line with London Plan policies 3C.23 Parking strategy and 3C.24 Parking in town centres. However, policy 3C.23 requires the provision of adequate parking for disabled persons in new developments, which would include staff and users of the retail and community uses. As no parking is proposed for the non-residential uses, TfL requires further information about how disabled users of the development will be adequately accommodated before the proposal can be considered compliant with this policy.

60 It is TfL’s understanding that the council has committed to extending the existing nearby controlled parking zone (CPZ) to cover Canada Water as part of the regeneration of the area; this is welcomed as it will support the use of more sustainable modes of travel. To support the low level of car parking proposed for Site A, all users of the development should be ineligible for on-street parking permits. This should be secured as part of any planning permission to ensure compliance with London Plan policy 3C.23 Parking strategy.

Buses

61 Additional capacity and new bus links will be required on the bus network in the Canada Water area as a result of this and other forthcoming developments in the area. TfL considers that at least one additional return journey between Canada Water and the City in the AM peak will be required as a result of this development. To provide this additional capacity, TfL will require a Section 106 contribution of £90,000 per year for 3 years (total of £270,000). In addition, TfL requests a minimum contribution of £48,000 towards improvements to the bus station which will be needed in order to accommodate the additional bus services needed as a result of this and other local developments. This will help ensure compliance with London Plan policy 3C.20 Improving conditions for buses.

Servicing and construction management

62 TfL welcomes the developer’s intention to prepare a delivery and servicing plan (DSP) for the site. However, TfL has concerns regarding the inset service road adjacent to block A3 as the design appears to inadequate for larger vehicles which would be forced onto the footway, thus increasing the potential for conflicts with pedestrians and conflicting with London Plan policies

page 11 3C.21 Improving conditions for walking and 3C.25 Freight strategy. This should be satisfactorily addressed prior to the council determining the application.

63 TfL also remains concerned about the potential for conflict between pedestrians and servicing vehicles in the pedestrian/cycle link adjacent to Needleman Gardens, which would reasonably be considered to be protected pedestrian realm. Further information about the design and width of this space is necessary in order to determine whether the proposals are compliant with London Plan policies 3C.21 Improving conditions for walking and 3C.25 Freight strategy.

64 The developer’s agreement to securing a construction logistics plan (CLP) is also welcomed; this should be prepared in line with the London Freight Plan and approved in consultation with TfL prior to the commencement of works on site. The use of waterways, particularly Greenland Dock, to move demolition and construction materials should be considered. The CLP should also take the likely cumulative construction movements of other nearby developments into consideration. London Buses Network Operations should be consulted at the earliest opportunity to ensure unnecessary disruption is avoided.

65 Given the proximity of the bus station and local TLRN/SRN roads, TfL will require the DSP and CLP to be approved in consultation with TfL and secured by planning obligation in order to ensure compliance with London Plan policies 3C.17 Tackling congestion and reducing traffic and 3C.25 Freight strategy.

Travel plan

66 A travel plan (TP) covering both the residential and commercial elements has been submitted with this application. The submitted travel plan is generally of good quality and shows a commitment to encouraging sustainable travel. However, further work is needed on funding and mode shift targets in order to be considered to be compliant with London Plan policy 3C.3 Sustainable transport in London; TfL would welcome these details to be incorporated into the travel plan prior to the council determining the application. The travel plan should be iTRACE and TRAVL compliant and secured, enforced, monitored and reviewed as part of the Section 106 agreement.

Section 106 contributions

67 In order to mitigate the impacts of this development on the transport network, TfL will require the following Section 106 contributions:

• £90,000 per year for 3 years towards an additional bus journey in the morning peak (total of £270,000) • £48,000 towards improvements at Canada Water bus station • £8,000 towards improvements to TfL’s Strategic Walk Network.

68 This is in addition to any separate transport requirements the council may have.

Summary

69 In summary, TfL has several key concerns relating to the development proposals and requires further work and information before this application could be considered acceptable in London Plan policy terms. The issues surrounding the public cycle facility must be satisfactorily addressed. Further work is needed on staff cycle parking, the inset service road, and the travel plan. Additional information about residential cycle parking, disabled parking for the retail and community elements, and servicing is needed. Finally, a contribution to mitigate the impacts of

page 12 this development of £326,000 is required for improvements to bus services/facilities and the Strategic Walk Network. Climate change mitigation

70 The London Plan climate change policies as set out in chapter 4A 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 with a target of 20% carbon reductions from on-site renewable energy. The policies set out ways in which developers must address mitigation of and adaptation to the effects of climate change. Chapter 5 of the draft replacement plan sets out the approach to climate change and requires developments to make the fullest contribution to minimizing carbon dioxide emissions.

Energy

71 Policies 4A.1 to 4A.8 of the London Plan focus on how to mitigate climate change, and the carbon dioxide reduction targets that are necessary across London to achieve it.

72 The applicant applied the energy hierarchy in Policy 4A.1

Be Lean

(Policy 4A.4)

73 The baseline emissions for the development have been estimated to be 2,500 tonnes CO2 per annum. The baseline emissions for the development have been adequately calculated using a combination of modelling for the residential element and existing benchmarks for the smaller non- domestic element. The applicant needs to confirm whether all energy usages in the development, i.e. regulated and unregulated have been taken into account when calculating the baseline emissions.

(Policy 4A.3) Energy efficiency standards

74 The applicant has proposed a series of demand reduction measures that intend to reduce carbon emissions beyond the baseline emissions. Measures proposed include lighting controls for the common areas and at least 75% of all internal lighting to be low energy. Additionally, slightly improved insulation standards than those required by current building regulations are proposed.

75 The measures proposed by the applicant to reduce the demand for energy are welcomed, but tighter and stronger commitments are expected that contribute to reduce the demand for heating and electricity further. Additionally, it is expected that the applicant provides the strategy through which carbon emissions due to non regulated energy usages would be reduced, for instance, commitment to the provision of A or A+ rated appliances.

76 Once the demand reduction measures proposed by the applicant are reviewed, building regulations approved modelling needs to be used to estimate the carbon savings that the proposed measures would achieve.

Be Clean

page 13 (Policies 4A.5 and 4A.6) District heating

77 Canada Water sites A and B are located within the Canada Water AAP. The energy strategy should have due regard to the energy proposals for adjacent sites C and E and, in discussions with the Council, to explore the possibilities for developing a joint energy strategy looking at the whole masterplan area.

78 The energy strategy should also reflect the plans that exist for the South East London Combined Heat and Power (SELCHP) waste incineration plant to export heat. Due to the proximity of this scheme to SELCHP, the energy strategy should explore whether connection to SELCHP is feasible or otherwise to demonstrate that the proposed heating strategy would allow Sites A and B to connect to an external heat network in the future.

79 In relation to the heating infrastructure proposed for the current scheme, the applicants should revise the energy strategy and to develop a heating supply strategy that results in the installation of a district heating network supplying sites A and B with heat and hot water, using heat generating plant installed in a single energy centre. The applicants need to describe how the proposed heat network would grow in relation to the development phasing.

80 Finally, the applicants should be aware that the size of the proposed combined heat and power plant should be reviewed within the context above and omitting the proposals for biomass boilers, i.e. the CHP needs to be optimised and sized assuming that no other renewable heat generating technologies are installed.

(Policy 4A.6) Combined Heat and Power

81 As described in paragraphs 78-80 above.

(Policies 4A.6) Cooling

82 The energy strategy is not robust enough in addressing the potential risk of overheating. The use of external shading devices and other strategies should be maximised in order to reduce the risk of overheating as far as possible, and further detail should be provided as to the type of devices and how they will be integrated into the design of the buildings.

83 Where a requirement for active cooling exists the applicant should explain how this occurs and how the requirements would be met within the development.

Be Green

(Policy 4A.7) Renewable energy technologies

84 The proposed scheme is located in an Air Quality Management Area. As stated within the Mayor’s draft Air Quality Strategy small biomass boilers below 500kWth in AQMAs are considered unsuitable unless they can demonstrate that they have no adverse effects on local air quality when compared with conventional gas-fired boilers.

85 The applicants should investigate the suitability of other renewable technologies. The use of photovoltaic is likely to appear as the most suitable technology to supplement CHP. For this purpose, the applicant needs to provide indicative drawings showing how much photovoltaic could be installed with suitable orientation, free of shading, and quantify the carbon savings this option could achieve.

page 14 Summary

86 The applicant has partially applied the energy hierarchy in the London Plan. However, the proposals cannot be considered acceptable until a revised energy strategy is submitted providing further clarification and information.

Climate change adaptation

87 The London Plan promotes five principles in policy 4A.9 to promote and support the most effective adaptation to climate change. These are to minimise overheating and contribute to heat island effects; minimise solar gain in summer; contribute to flood risk reduction, including applying sustainable drainage; minimising water use; and protect and enhance green infrastructure. Specific policies cover overheating, living roofs and walls and water.

88 In line with policy 4A.10 of the London Plan particular attention should be paid to use of passive design and natural ventilation. The pre-assessment report for the Code for Sustainable Homes predicts that code level 4 will be achieved.

89 Policy 4A.14 of the London Plan 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 4A.11 seeks major developments to incorporate living roofs and walls where feasible. Policy 4A.16 of the London Plan seeks to ensure that new development has proper regard to the impact on water demand and existing capacity by minimising the use of treated water and maximising rainwater harvesting opportunities. Roof runoff will be used for watering the public amenity space within the site.

90 The applicant proposes several green and brown roofs. Other provisions within the development include grey water recycling and the fitting of low flow appliances.

Flood risk

91 The site lies within flood zone 1 of the defended Thames floodplain, which would not ordinarily require a flood risk assessment. However as the site is larger than a hectare, a full flood risk assessment was carried out for the previous application, in accordance with Planning Policy Statement 25. The assessment remains valid for the present application.

92 The greatest source of potential flooding on site is tidal flooding from the River Thames. With the exception of four surveyed heights at the north-west corner of the site all levels of the site are higher than the 1 in 1000 flood level adjusted to take account of climate change. In addition ground levels in the surrounding area of Rotherhithe are higher than the modelled tidal flood water levels in the River Thames and as such the site is not expected to flood even in the event of catastrophic failure of the flood defences. In any case the building levels will be 6m above the expected flood level in the case of failure of the flood defences.

93 Groundwater flooding is not considered a significant source of potential flooding due to the ground condition in Rotherhithe as well as the extent of urbanisation in the area.

94 The development will result in an increase in permeable ground cover on site and as such a reduction in surface water runoff is expected.

95 The development complies with London Plan policy in this regard. Local planning authority’s position

page 15 96 Officers proposed to report this application to Southwark Council’s planning committee on 2 December 2009, however, it could not be verified at the time of writing if the case was still on target for that date and if so, whether a positive recommendation could be made. Legal considerations

97 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

98 There are no financial considerations at this stage. Conclusion

99 London Plan policies on mixed-use developments, housing, urban design, tall buildings, transport, climate change, energy and social inclusion are relevant to this application. In general, the application complies with some of these policies but not with others for the following reasons • Housing: The application does not comply with London Plan policy 3A.10, which requires submission of a toolkit appraisal of financial viability to justify a low proportion of affordable housing. The proportion of family-sized units in the scheme is unduly low, contrary to the Mayor’s Housing SPG. • Energy: The submitted energy strategy only partially complies with the energy hierarchy set out in the in the London Plan. • Transport: The TfL comments in paragraphs 51-69 demonstrate only a partial compliance with the policies in section 3C of the London Plan.

100 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan: • Housing: Submit a toolkit appraisal to demonstrate that the affordable housing contribution is the maximum reasonable amount viable for this development. • Raise the proportion of family-sized units closer to the strategic targets set out in the Mayor’s Housing SPG and draft Housing Strategy, as indicated in paragraph 29 of this report. • Energy: Provide the relevant information and clarifications needed to resolve the issues identified in paragraphs 73-86 of this report.

• Transport: Provide the relevant information, revisions and financial contributions identified in paragraphs 51-69 of this report.

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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] David Blankson-Hemans, Senior Strategic Planner (Case Officer) 020 7983 4268 email [email protected]

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