planning report PDU/2819/01 14 December 2011 Riverwalk House in the City of planning application no. 11/09680/FULL

Strategic planning application stage 1 referral (new powers) 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 building and construction of a new residential building comprising 121 residential units with two elements of 17 and 7 storeys, linked by a central podium; retail and gallery space at ground floor. The proposal also includes refurbishment of existing office building for affordable housing in an offsite location on Bridge Road.

The applicant The applicant is Derwent London and the architect is Stanton Williams Architects (Riverwalk House) and Buckley Gray Yeoman Architects (Vauxhall Bridge Road).

Strategic issues The principle of residential development is likely to be acceptable, provided is content with the loss of office space.

Further information is required on the level of affordable housing, including the viability assessment and an independent appraisal will be required. There are a number of detailed matters relating to children’s playspace, urban design, heritage, access and inclusion, transport and sustainable development which require resolution.

Recommendation

That Westminster City Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 112 of this report; but that the possible remedies set out in paragraph 113.

Context

1 On 17 October 2011 the Mayor of London received documents from Westminster City Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Further information was received on 28 October 2011 to complete the referral. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor has until 14 December 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

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

 Category 1C: Development which comprises or includes the erection of a building of one or more of the following descriptions — (a) the building is more than 25 metres high and is adjacent to the ; (c) the building is more than 30 metres high and is outside the City of London.  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— (b) in Central London (other than the City of London) and with a total floorspace of more than 20,000 square metres. 3 Once Westminster City 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

Riverwalk House (main site)

5 The site is 0.28 hectares and is located at the junction of and Vauxhall Bridge Road in Westminster and is currently occupied by a 12-storey 1960’s office building recently vacated by Government Office for London. The site fronts onto the A3212 to the north of the site, part of the Road Network. The west of the site is bounded by Vauxhall Bridge Road (A202) also part of the Transport for London Road Network.

6 The River Thames marks the south of the site whilst the Thames Path and Riverside Walk Gardens form the eastern boundary. Beyond the major infrastructure that bounds the site the land use is predominantly residential to the north and west. Further east is a strong educational, cultural and state character with the Chelsea College of Art, and various Government Buildings including the Security Services (Thames House) and Houses of Parliament. As such there are also a number of heritage assets in the immediate vicinity and designated conservation areas. The public transport accessibility level (PTAL) of this site is 6a (from a scale of 1 – 6 where 1 is poor and 6 is high). This equates to an excellent level of accessibility to public transport.

7 The site fronts onto the A3212 to the north of the site which forms part of the Transport for London Road Network (TLRN). The west of the site is bordered by the TLRN Vauxhall Bridge Road (A202). A total of 8 bus routes serve the site with several additional routes available from that is approximately a 7 minute walk south of this site. The nearest station is on the , located approximately 450 metres north west of the site. London Underground services and regional rail services are also available from , located approximately 500 metres south of the site. National Rail and coach services are available from Victoria station which is approximately a 20 minute walk north of the site.

page 2 232-242 Vauxhall Bridge Road (affordable housing site)

8 This site is linked to the main site as the proposed location for the delivery of affordable housing. It is an existing 6 storey office building, located 1 kilometre north from the main site, on A202 Vauxhall Bridge Road. It is 300 metres from Victoria Station and is well served by public transport. The surrounding scale of buildings is a mixture of five and six storey residential mansion blocks, and significant commercial buildings further north towards Victoria.

Details of the proposal

9 The application seeks full planning permission for:

‘Demolition of the existing building and erection of two new buildings of 17 and 7 storeys linked by a central podium to comprise of 121 residential units (Use class C3); ground floor café/gallery (Use class A1/A3/A4/D1); three levels of basement including car parking and plant area; creation of replacement staircase and other associated public landscape improvements, works of hard and soft landscaping and other works incidental to the application.’

10 There is another proposal on the Vauxhall Bridge Road site which although not referable in its own right, is linked to this application as it is to deliver the affordable housing requirements. This application will be expected to meet the same policy strategic policy requirements as the principal scheme. Case history

11 A pre-application meeting was held at City Hall on 22 July 2011 which concluded that the principle of a tall building for residential use required further work regarding the impact on CAZ functions through the reduction in office space and regarding the heritage and townscape impacts locally. It was noted that an off site arrangement for affordable housing would need to be justified through with evidence regarding the financial implications for onsite delivery. It was noted that a number of other matters regarding design quality, circulation layouts and access, climate change and transport also needed to be addressed. Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

 Mix of uses London Plan  Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft  Affordable housing London Plan; PPS3; Housing SPG, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft  Density London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing SPG draft  Urban design London Plan; PPS1  Tall buildings/views London Plan; RPG3A, Revised View Management Framework SPG  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; Diversity and Equality in Planning: A good practice guide (ODPM)

page 3  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  Transport London Plan; the Mayor’s Transport Strategy; PPG13  Parking London Plan; the Mayor’s Transport Strategy; PPG13

13 The development plan in force for the area is the 2007 Westminster Unitary Development Plan, the 2011 Westminster Core Strategy (adopted 26 January 2011) and the London Plan 2011.

Principle of development

14 The application sites fall within the Central Activities Zone (CAZ), as identified in the London Plan. 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 flexibility ”and “seek increases in current stock where there is authoritative, strategic and local evidence of sustained demand for office based activities“. Policy 2.10 Central Activities Zone – strategic priorities also seeks to, “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”.

15 Policy 2.11 Strategic functions also seeks to ensure that development complements and supports the cluster of other strategically important specialised CAZ uses. Map 2.3 indicates that the main site (Riverwalk House) falls to the south of the ‘mixed uses with a strong state character’ zone of the CAZ. The Vauxhall Bridge Road site is similarly located within the context of the CAZ, the Victoria Street CAZ Frontage and Victoria Opportunity Area. Policy 2.12 Central Activities Zone – predominantly local activities also underlines the need to “protect and enhance predominantly residential neighbourhoods within the CAZ and develop sensitive mixed use policies to ensure housing does not compromise CAZ strategic functions elsewhere in the zone”.

16 Both the Riverwalk House and Vauxhall Bridge Road sites currently comprise existing office buildings. As set out above, CAZ is prioritised for this type of land use and as such, transfer to other land uses must be carefully considered. The London Plan identifies a strong State character to the north of the main site although it is acknowledged that the immediate setting is largely residential to the south and west with cultural (Tate Britain) and educational (Chelsea College of Art and Design) to the north. At the pre-application stage it was noted that the policy test in this instance would be 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.

17 The planning application is accompanied by an Office Market Report which has been prepared by Jones Lang LaSalle. This report identifies that the existing Riverwalk House building no longer makes a positive contribution to the office stock within the Victoria area and that a significant office development pipeline exists. The report also concludes that the continued use of the Riverwalk House building for office use is not an appropriate future use of the building, when considered against the context of the Victoria office submarket. However, it does not consider how an office or mixed use redevelopment on this site might contribute to the local and strategic office markets and the applicant should demonstrate that this option has also been considered.

18 The applicant has also claimed that the loss of limited quality office space within this location would not compromise the strategic function of the CAZ and has cited Westminster’s

page 4 strategic priority for housing as a driver for the change of land use on this site. Westminster City Council should therefore ensure that the loss of office space in this location is acceptable in local office market terms.

19 In terms of the Vauxhall Bridge Road site, policy 2.10 is particularly relevant in that “provision is made for a range of occupiers” including smaller business. Annex 2 of the London Plan provides strategic guidance and future growth potential indications at paragraph A2.6. Victoria Street CAZ Frontage expects high growth and “includes town centres likely to experience strategically significant levels of growth with strong demand and or large scale retail, leisure or office development in the pipeline and with existing or potential public transport capacity to accommodate it (typically PTAL 5-6)”. Westminster City Council should also ensure that the loss of office space in this location is acceptable in local office market terms.

20 Provided the applicant can demonstrate that a redevelopment including new office spaces on the site is not feasible, there is no strategic planning concern with the conversion of office space to residential uses on either the main or the affordable housing sites. Housing

21 London Plan policy 3.3 seeks to increase London’s supply of housing and sets a London- wide target of 32,210 additional homes per year between 2007/8 and 2016/17. Table 3.1 sets borough housing targets, of which Westminster’s is 770 additional homes per year between 2011 and 2021. Policy 3.4 of the London Plan seek to ensure that development proposals achieve the optimum housing output for different types of location within the relevant density range shown in Table 3.2. A distinction in the Mayor’s new approach to the issue of density is the move from maximise to optimise site capacity. This proposal intends to deliver a total of 146 residential units which will make an important contribution to Westminster’s housing targets.

22 London Plan Policy 3.12 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 3.11 sets an affordable housing target of 13,200 homes per year and states that borough targets should take account of matters including current and future housing requirements, the strategic targets and priority accorded to family housing, the need to promote mixed and balanced communities, and the viability of future development, and that within those targets 60% of affordable housing should be for social rent, and 40% for intermediate rent or sale.

23 At local level UDP policy H4 seeks affordable housing contributions on sites over 0.3 hectares or on sites with 10 or more dwellings. Policy CS16 of the adopted Core Strategy also sets out that within the CAZ a maximum of 30% affordable housing will be sought.

24 The applicant is seeking to deliver 22 affordable housing units as part of an offsite solution on Vauxhall Bridge Road, with a further (as yet unconfirmed) cash payment in lieu also proposed. The submitted planning statement sets out that this level of affordable housing is equivalent to 14% of the total residential gross external area of both schemes and 21% of the overall units. As above, London Plan policy 3.12 sets the need to maximise the provision of affordable housing on individual sites having regard to a range of relevant factors. Paragraph 3.74 of the Plan also notes that “Affordable housing provision is normally required on site. In exceptional circumstances it may be provided off-site or through a cash in lieu contribution ring fenced and if appropriate ‘pooled’, to secure efficient delivery of new affordable housing on identified sites elsewhere. These exceptional circumstances include those where having secured an alternative site, it would be possible to:

page 5  Secured a higher level of provision  Better address priority needs, especially for family housing  Secure a more balanced community  Better sustain strategically important clusters of economic activities, especially in parts of the CAZ” (housing swaps/credits)

25 The plan also sets out that in such circumstances boroughs should consider whether it is appropriate to put in place provisions for re-appraising the viability of schemes prior to implementation.

26 As stated as part of the pre-application process, the applicant will need to make the case in terms of the delivery of units on-site and off-site having regard to the full financial disclosure and this material would need to be fully and independently scrutinised. Although an affordable housing report has been submitted to support the application which concludes that an off-site solution with a commuted payment is the solution which allows the greatest contribution towards affordable housing, the detailed viability information has not yet been provided to officers. As such, it is not possible to determine whether an off-site solution is enabling a higher level of provision as required by strategic planning policy and the guidance set out in the Mayor’s draft Housing SPG.

27 The viability information should be provided to officers as a matter of urgency and the GLA would wish to jointly commission an independent assessment of the viability case with Westminster City Council. GLA officers would welcome further discussion regarding the brief for an agreed valuer. With regard to the proposed cash in lieu payment, if this is accepted, the GLA will also expect the section 106 agreement to ensure the money is spent on additional affordable housing provision. Any permission should be conditioned such that the contribution can only be spent in accordance with the recently agreed memorandum of understanding. The use of a review mechanism within the section 106 agreement should also be considered to ensure the policy regarding the maximum reasonable amount is deliverable and is tested closer to delivery as set out above.

28 The proposed unit mix on the Riverwalk House and Vauxhall Bridge Roads sites is set out in tables 1 and 2 below:

Table 1 Riverwalk House

1 bed 2 bed 3 bed 4 bed Total

Private 37 47 31 46 121

Total % 31 39 26 5 100

Table 2 Vauxhall Bridge Road

1 bed 2 bed 3 bed Total

social rent 7 8 10 22

Total % 28 32 40 100

page 6 Tenure split

29 The 121 residential units to be delivered on the Riverwalk House site are proposed to be 100% private sale. The tenure of the proposed 22 affordable units is not fixed, although it is suggested that it will be affordable rent, with the option to include an element of intermediate if Westminster City Council prefer. Notwithstanding the need to justify the land use principles, the tenure split should be fixed to allow an assessment of the proposals against strategic planning policy.

Mix of units

30 London Plan Policy 3.8 encourages a full range of housing choice. This is supported by the London Plan Housing Supplementary Planning Guidance, which seeks to secure family accommodation within residential schemes, particularly within the social rented sector, and sets strategic guidance for councils in assessing their local needs. Policy 3.11 of the London Plan states that within affordable housing provision, priority should be accorded to family housing. Recent guidance is also set out in the draft revised interim Housing Supplementary Housing Guidance (October 2009).

31 Notwithstanding the need to justify the land use principles, a mix of family housing is provided in the Vauxhall Bridge Road site but this will need to be tested in terms of the priorities for on-site delivery. As noted as part of the pre-application advice, given the nature of the location it is important that the units will be affordable and are consistent with the GLA’s affordability criteria.

Density

32 Table 3.2 of the London Plan provides guidelines on density in support of policies 3.4. As mentioned above, Policy 3.4 of the Plan moves away from maximising site capacity to optimising development potential with a stronger focus on local context in particular.

33 A total of 121 residential units are proposed equating to a density of 275 residential units per hectare. Within the 121 units, a total of 387 habitable rooms will be provided which equates to a density of 880 habitable rooms per hectare.

34 The proposed development falls within the central area as outlined in Table 3.2 of the London Plan where an appropriate density range of 650-1,100 habitable rooms per hectare is indicated. At 880 habitable rooms per hectare, the proposal falls within the range identified in Table 3.2. In relation to the number of units per hectare, an appropriate range is identified as 175- 355 units per hectare for proposals with an average of 3.1-3.7 habitable rooms per unit. The units provided have an average of 3.2 habitable rooms per unit, as the overall development has a density of 275 residential units per hectare, the proposal falls within the range identified.

35 As such, the proposal accords with Policy 3.4 of the London Plan which seeks to optimise housing output taking account of local context, character, design principles and transport capacity. Note should also be taken of the design comments below.

Residential quality

36 London Plan policy 3.5 of the London Plan introduces a new policy on the quality and design of housing developments. Policy 3.4 extends this to focus specifically on minimum residential space standards as set out in Table 3.3.

page 7 37 The Mayor’s Interim Housing Design Guide and Draft Housing SPG, which is currently out to consultation, provide further detailed guidance on design and layout matters. The current layouts need further work. Whilst the space standards exceed the requirement set out in table 3.3 and all units have been designed to benefit from balcony access there remains nine units accessed off the core on level 2-5 which exceeds the guidance of a maximum of eight. This was raised at pre-application stage and should be reconsidered.

38 No information has been made available on the Vauxhall Bridge Road application, but this will also be expected to comply with strategic planning policy and the applicant should demonstrate that it will meet the standards set out in the guidance noted above. Children’s play space and landscaping

39 Policy 3.6 of the London Plan sets out that “Development proposals that include housing should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs”. The Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ sets a benchmark of 10 sq.m. of useable child playspace to be provided per child, with under-5 child playspace provided on-site.

40 The proposal generates a child population of approximately 17 children. It is essential that adequate facilities are provided in the development, based on the expected child population of the development. On this basis an area of approximately 170 sq.m. is required to meet the needs of the arising child population. The planning statement suggests this is met through space on the River walk outside the cafe terrace. The plans show a bench and a tree and not formal or defined space.

41 This is unacceptable and needs to be reconsidered in order to comply with London Plan policy 3.6. The applicant should also provide information to demonstrate that the affordable housing site (Vauxhall Bridge Road)

Urban design

42 The comments in this section relate to the Riverwalk House site as no detail has been provided on the Vauxhall Bridge Road site. Further details on the proposed affordable housing site should be provided for information.

43 Good design is central to all objectives of the London Plan (2011) and is specifically promoted by the policies contained within chapter seven which address both general design principles and specific design issues. London Plan Policy 7.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere 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 World Heritage Sites, views, the public realm and the Blue Ribbon Network. New development is also required to have regard to its context, and make a positive contribution to local character within its neighbourhood (policy 7.4).

44 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.

page 8 Principle of a tall building

45 The London Plan moves away from active encouragement of tall buildings to careful management in defined areas. London Plan policy 7.7C sets out criteria for assessing the appropriateness of tall and large scale buildings including, location, impact on character of surrounding area, relationship to surrounding form, impact on skyline, architecture, groundfloor relationship, urban realm and permeability, access and regeneration. Issues regarding microclimate, strategic views and heritage are also covered in 7.7 D and E and further underpinned by Policies 7.11 and 7.12 and the draft London View Management Framework 2011.

46 There is an existing large scale 12 storey building on site which will be demolished and replaced by a 17 and 7 storey tower linked at ground floor level. While there is also a tower to the west of the site which is 21 storeys, there is no clearly defined cluster or civic landmark function on this site and the Core Strategy does not allocate the site in its list of strategic sites.

47 The City Council’s Core Strategy is cautious with regards to tall buildings noting that in most instances tall buildings will be inappropriate within the borough. Some specific guidance is given in each opportunity area and in policy CS25 Views, however further guidance will be provided in the City Management Plan.

48 Whilst this is the case London Plan policy 7.7 Part C d) refers to “improving the legibility of an area by emphasising a point of…. visual significance”. The Vauxhall Bridge lands immediately adjacent to the site and forms the south western boundary. The bridge represents an entrance and exit point from into and out of the borough. It is already established as a point of visual significance on account of the scale of buildings that already exist on site and the Panoramic Tower (residential) adjacent which frame the bridge on either side. The proposed taller tower reinforces this principle by coming closer to the bridge providing a stronger emphasis on the space between the new tower and the Panoramic. The role of the smaller tower in defining this significance is however not entirely robust and results in new heritage impacts from various views surrounding the site and from the South side of the River. The principle of the taller tower is fairly established therefore and contributes to the landmark visual significance at the landing point of the bridge. The smaller tower however does not contribute to this relationship and requires further consideration particularly given it raises other heritage matters discussed further below.

Strategic heritage impacts

49 In this particular case, the principal consideration in determining the acceptability of the proposal in design terms is its bearing on the historic assets in the vicinity and specifically whether or not it would preserve or enhance the character or appearance of the conservation area, the setting of listed buildings and protect the ability to appreciate the outstanding universal values of the Westminster World Heritage Site (WHS).

50 Development within the setting of the WHS is managed in the same way as all other development, through development plan policy. It is however, also informed by any relevant World Heritage Site Management Plan. In this case the and including St Margaret’s Church World Heritage Site Management Plan (May 2007) provides further detailed guidance and builds on the policies in the London Plan, LVMF and the public consultation draft London World Heritage sites – guidance on settings SPG (October 2011).

51 Specifically the Management Plan draws on the strategic planning polices at paragraph 5.1.2.9 and provides a series of 28 Objectives, many of which are relevant but specifically 7-9 and 14, which seek to manage new development in the setting of the WHS and to safeguard the Outstanding Universal Value of the World Heritage Site.

page 9 52 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 London View Management Framework 2011 (LVMF). Policy 7.10 refers specifically to World Heritages Sites. As above the Mayor has also published the public consultation draft London World Heritage sites – guidance on settings SPG (October 2011). Implementation Point 15 of the SPG provides a framework for assessing the effect of development proposals in WHS and their settings.

Strategic views and setting of World Heritage site

53 Implementation Point 15 of the draft London World Heritage Site – Guidance on Setting SPG (Oct 2011) provides a framework for assessing the effect of development proposals in World Heritage Sites and their settings. As part of the townscape assessment, the applicant should follow this approach to demonstrate a clear understanding of the Outstanding Universal Value of the World Heritage Site and how its setting contributes to this appreciation of its Outstanding Universal Value. Based on this understanding, the potential effects of the proposal should be assessed against the impact on OUV as wells other impacts on other heritage assets identified.

54 A key part of the assessment will include visual analysis using the LVMF as well as other local views important to the World Heritage Site, if appropriate. For the strategic views, the applicant has submitted a townscape analysis which considers the proposals from a number of strategic views including those from (15.A), Hungerford Bridge (17.A) and (18.A).

Waterloo Bridge (15.A)

55 As set out in the LVMF the character of the upstream view is dominated by the considerable length and breadth of the River Thames in the foreground. Two Assessment Points (15A.1 and 15A.2) are located on the upstream side of the bridge where these characteristics are best appreciated in relation to the townscape. A Protected Silhouette of the Palace of Westminster is applied between the formal Assessment Points.

56 The material submitted by the applicant suggests the proposals would not be visible when viewed from Assessment Point 15A.1. It would however appear in the background view behind Thames House from Assessment Point 15A.2. The LVMF sets out guidance regarding development in the background of this particular view at paragraph 250. Here it states “New building to the right of should not detract from the dominance of the Palace of Westminster in the view, should preserve the dominance of the trees in this part of the view, and contribute to the horizontal emphasis of the buildings on Millbank.” The impact of the proposal in the case of the Palace needs to be further tested and whilst the proposed building does not appear behind the Protected Silhouette, it does fall in the setting above Thames House. The approach may therefore impact on the horizontal emphasis of Millbank in the kinetic view between the two Assessment Points and may impact on the Outstanding Universal Value of the World Heritage Site.

57 To establish the scale of the impact on the strategic view and the Outstanding Universal Value of the World Heritage Site the applicant should follow the guidance set out in Implementation Point 15 of the SPG. This should include fully rendered images of the proposed building and a reassessment of the view at the Assessment Points and also as a series of views along the bridge to test the impact of the kinetic viewing experience along the bridge from between the Assessment Points. The scope of this testing should be agreed with GLA officers. The current wire line views do not allow a full and robust assessment of the likely impact.

page 10 Hungerford Bridge (17.A)

58 As with Waterloo Bridge the character is dominated by the River foreground. The LVMF confirms that “in most views from the bridge the complete silhouette of the Palace can be seen against sky. Where buildings are glimpsed in the background of the landmark, the viewing experience is diminished.” Guidance set out in paragraph 286 of the LVMF states that “Development proposed behind the other river frontage buildings must respond to the character and appearance of existing buildings and landscape and should not encroach on, or form backdrop to, the Palace of Westminster or Westminster Abbey in this view…Incrementally change to development in the background of the river frontage is acceptable provided each addition to the view contributes positively to the overtly horizontal composition”. Furthermore, paragraph 289 sets out that “The protected Silhouette should not be altered by development appearing in its background at or between Assessment Points 17A.1 and 17A.2.”

59 The images provided are taken from the relevant points at each end of the bridge which suggests that the proposal would be visible behind Thames House Assessment Point 17A.1 but completely obscured from Assessment Point 17A.2. As with the tests required for Waterloo Bridge, this view also includes the Protected Silhouette of the Palace of Westminster status. To demonstrate the full impact on the Protected silhouette of the Palace and the Outstanding Universal Value of the World Heritage Site the applicant needs to undertake the same appraisal referred to above (Implementation Point 15 of the SPG) and fully render the proposed building and re-assess the view at the Assessment Points and also as a series of views along the bridge to test the impact of the kinetic viewing experience along the bridge from between the Assessment Points. As with the Waterloo Bridge view the scope of this testing should be agreed with GLA officers but it will need to demonstrate that at no stage between the Assessment Points does the scheme appear in the background Protected Silhouette of the Palace.

Westminster Bridge (18.A)

60 The viewpoint from Westminster Bridge has been tested at Assessment Point 18A.1. The modelling suggests that the building would be completely obscured from view and has no effect on the view.

Other heritage impacts

61 The application site is not in the conservation area but is located adjacent to Millbank Conservation Area (north) and Pimlico Conservation Area (south). The site is also in the setting of a number of listed buildings including 58 Milbank (Morpeth Arms public house), 46-57 Millbank, former Royal Army Medical College - Chelsea College of Art and Design, Tate Britain and Vauxhall Bridge. Many of these are prominent features in the townscape, particularly when viewed from along Millbank, from Vauxhall Bridge and the south side of the River Thames.

62 The townscape analysis provides various views from Vauxhall Bridge, the south side of the River Thames and to the north of the site in the surrounding streets and from the steps of the Tate Britain. In many instances the presence of Riverwalk House in its current form as a 1960 office building detracts from the setting of surrounding heritage assets along Millbank and on the character and appearance of the conservation areas. Its removal and replacement with a contemporary building is in principle an opportunity to improve the current setting.

63 The taller tower is being located much closer to Vauxhall Bridge than the current building. As previously noted, it strengthens the relationship of the bridge as a gateway, it also has the potential to improve and increase views along Millbank from the south and Vauxhall Bridge

page 11 through its relocation further south – this is however reduced through the introduction of the smaller tower as discussed below.

64 The taller element will impact on the surrounding streets including when viewed in the context of Ponsonby Place from John Islip Street and from the courtyard of Chelsea College and Tate Britain. The existing tower does however already establish an impact as does the Panoramic tower on the other side of Vauxhall Bridge Road. The impact of the taller tower therefore does not harm the setting of nearby listed buildings on account of the existing context and presence of taller structures in these local views. Similarly the proposals would preserve the character and appearance of the conservation area on the basis that the scale of the riverside buildings is already established as a presence in the character of the conservation area.

65 The smaller tower however creates a new building, which obscures part of the listed buildings viewed from the Vauxhall Bridge and views of the campanile of when viewed from Vauxhall Bridge. The impact appears greatest from Vauxhall Bridge where it obscures 60-63 Millbank and part of Morpeth Arms pub. 60-63 Millbank is not a listed terrace but forms part of the setting to the listed pub and is identified as a group of heritage buildings of merit. The introduction of the smaller tower in this context is therefore unfortunate and negates some of the benefits of relocating the taller tower closer to Vauxhall Bridge, which would open up views of Millbank from Vauxhall Bridge and other view points. This approach is therefore unfortunate and needs to be carefully considered in terms of the impacts arising on heritage assets locally. Further discussion with the applicant, the Council and English Heritage is therefore required regarding the impacts of the smaller tower.

Layouts and circulation

66 At pre-application stage a number of areas required further work. The design team has responded to the comments with amendments to the layout arrangements which address some of the previous concerns, however there is still a number of areas which need further work as set out below:

 Definition of public and private space – the design team have looked carefully at the public areas and the interface between the private spaces around the building. The proposals are significantly improved on the west and southwest elevation which deals with the relationship to the landing of Vauxhall Bridge. The plans suggest the pavement will now abut the west side and gently slope to Millbank pavement level. This removes the route that was previously shown between the side of the bridge and the new tower – a route which was enclosed and poorly surveyed. This approach allows a new ‘viewing terrace’ adjacent to the new public lift which will mange the level change from the Riverwalk up to Vauxhall Bridge. The amendments are a significant improvement, however it is important that the applicant provides some visualisation of the space and considers the treatment of the wall of the viewing terrace and its integration into the base of the tower carefully. Further detail should therefore be provided.

 Links to Riverwalk Gardens (continuation of the open space) – Whilst the west side of the building has been considerably improved the design team has not embraced the suggestion to improve the east side of the proposals. Consideration should be given to creating a seamless link to Riverwalk Gardens and providing non residential uses at ground floor level to face onto the open space. This will help to reduce the lack of privacy currently experienced by the two ground floor units in the lower tower and provide a more defined destination with a mix of ground floor uses to enhance the Thames path and open space to the east.

page 12  Front door onto the river – It is important that the design team remove the level change from north to south and provide a level access arrangement along the Thames path that can run through the building. At present the ground floor plan suggests that there is a 1 metre level difference to the south which is managed by stepped access up to a private terrace for residents and steps and ramp access up to a new cafe/gallery space. This results in a poor relationship with the public realm of the Thames Path and creates segregation in terms of inclusive environment for users of the cafe and no level access into the private terrace from the Thames path.

Noise

67 The lower units, in particular those that face the bridge and are single aspect, will be exposed to poor air quality and noise. The Mayor’s Housing Design Guide provides clear guidance on the need to minimise single aspect dwellings that are north facing, exposed to noise category C or D or contain three or more bedrooms (5.2.1). The proposal is not accompanied by an environmental statement, however there is a supporting noise and vibration report which identifies that the site falls within Noise Exposure Category C - daytime and C/D- night time. The report suggests this can be mitigated through high performance glazing. The report also concludes that mechanical (whole house) ventilation systems will be adopted, to eliminate the need for ventilation openings. This also means there will be no reliance on operable windows for ventilation purposes, although it is intended that windows will be operable in order to give tenants choice over the living conditions. The methodology used is not entirely consistent with the guidance in PPS24 and therefore GLA officers will scrutinise the proposals in further detail and may provide further comment in due course.

Architecture and massing

68 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.

69 Whilst the architecture is broadly supported, including the use of high quality limestone materials, there are elements which need to be carefully considered. Specifically the bulk and massing of the towers needs careful townscape analysis in terms of the transition between the scale of development to the north and the overshadowing of existing residential buildings and gardens. The existing building already casts shadow and has a presence in terms of scale. GLA officers are in the process of scrutinising the sunlight daylight report. Further discussion may therefore be required jointly with Westminster City Council.

70 As such, there are a number of matters which require further consideration to ensure the application complies with London Plan policies relating to urban design, heritage and views. Access and inclusive design

71 The comments in this section relate to the Riverwalk House site as no detail has been provided on the Vauxhall Bridge Road site. Further details on the proposed affordable housing site should be provided for information.

page 13 72 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. Policy 3.8 requires all new housing to be built to Lifetime Homes standards and that ten percent of new housing is designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users.

73 As above, London Plan policy 3.8 c and d sets out the need to meet Lifetime Homes Standards and that 10 per cent of new housing is designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users. It is important that the applicant identify which are accessible or easily adaptable and demonstrate what measures are required to adapt units to meeting the necessary standards. Flat layouts have been provided to illustrate wheelchair accessible units 12 of which are located in block A, equivalent to 10%

74 An access audit of the surrounding streets has not been provided and therefore it is unclear what pedestrian links and step free routes for disabled people exist to the site or if these require upgrading. A lighting strategy for the Riverwalk should be provided, this can be secured by condition.

75 At present the level change north to south and the interface with the south entrance to the cafe and gallery space is poorly resolved. This was raised at pre-application stage and needs to be reconsidered. The introduction of a new lift up to Vauxhall Bridge is fully supported. 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). At present this is not shown on the basement plan arrangements.

76 Further work is therefore required on a number of matters to ensure compliance with London Plan policy 7.2 relating to inclusive design. Transport

77 The comments below relate to the main Riverwalk House site.

Site Access

78 The existing vehicular access is from the Transport for London (TfL) road network route along Millbank on a left turn in and left turn out only basis. The developer proposes to move the site access to a more central point on the site to allow access to the basement car park. This requires the shortening and relocation further east of the existing westbound bus stop which may have an impact on bus journey times and the cycle superhighway 8. Therefore, TfL require further discussions with the developer to resolve these concerns before any designs relating to access are finalised.

Car Parking

79 A total of 115 car parking spaces are proposed for the 121 residential units which equates to a ratio of 0.95 spaces per unit. TfL requires this figure to be significantly reduced given the high PTAL of the site and so as not to undermine the use of public transport. Blue badge parking should be provided in line with the number of wheelchair accessible units in addition to blue badge parking for staff of the proposed cafe/art gallery area. This will ensure compliance with London Plan policy 6.13 Parking.

page 14 80 TfL welcomes the developers proposal to provide 20% of all car parking spaces with an active electric vehicle charging point (EVCP) and fit all remaining spaces with passive provision. This will help to encourage the uptake of electric vehicles and is therefore compliant with policy 6.13 of the London Plan.

81 There are several car clubs currently operating within the vicinity of the site. TfL requests that the developer engages with the providers of these car clubs to investigate existing usage patterns and identify the possible demand for expansion.

Cycle Parking

82 TfL welcomes the provision of 217 cycle parking spaces for residents located in the basement and 6 cycle parking spaces for visitors located in the public realm. All cycle parking must be convenient, covered and secure with good lighting and CCTV. This will ensure compliance with London Plan Policy 6.9 Cycling. Barclays Cycle Hire scheme operates in the area and there are currently no plans to extend the existing docking stations. However, to encourage the use of this facility, the Travel Plan should include robust measures including free membership and location plans in order to support the use of this facility.

Walking

83 TfL requests that the applicant undertakes a pedestrian environmental review system assessment (PERS) to highlight improvements that could be made for pedestrians, cyclists and wheelchair users on routes to and from the site. This should be secured as a condition and undertaken prior to the commencement of any works.

84 TfL requests a contribution, in connection with the Vauxhall Bridge Road application, towards the provision of the Legible London wayfinding scheme to help pedestrians navigate around the local area. This will ensure conformity with London Plan policy 6.10 Walking.

Public Transport

85 TfL requests that the modal split information is amended to ensure the split is made by each individual public transport mode and includes a directional split. This will then correctly inform the trip generation data that will highlight any increases in demand in the peaks that may require mitigation measures.

Travel Plan

86 TfL requests the submission of the Travel Plan to be secured in the s106 agreement. This should include but not be limited to travel information for staff and residents, car club membership, subsidised Oyster cards, Cycle Hire membership and the provision of shower and locker facilities for staff. Securing of these travel plan measures within the section 106 agreement will ensure conformity with London Plan (2011) policy 6.3 Assessing effects of development on transport capacity.

Construction, Servicing and Deliveries

87 TfL requests the submission of a delivery servicing plan (DSP) and construction management plan (CMP). It is requested that these are secured in the section 106 agreement or by planning condition to ensure conformity with London Plan policy 6.14 Freight. The DSP must now form part of the travel plan as set out in TfL guidance.

Olympic Route Network

page 15 88 Millbank and Vauxhall Bridge Road are part of the Olympic Route Network (ORN). Therefore, the applicant should be aware that the operation of the highway will be altered during the time the ORN is in operation. Any works planned during this period that will affect the ORN must be stated in the CMP.

89 The ORN and Paralympic Route Network (PRN) will operate during the Olympic and Paralympic Games period, between June and September 2012. During this period, there will be an impact on construction works, utility works and highway licensed activities (for example, skips and building materials) if they affect the roads designated as a part of the ORN/PRN and some of the surrounding streets. Other routes might also be affected and will also be required to be clear of any kinds of obstruction.

90 Given the above, highway works and licences could therefore be affected on occasions during the Games period. Requests to utility providers to provide any additional water, gas, electricity or telecommunications connections should also be made sufficiently well in advance of this period.

91 The applicant should note that this information is provided without prejudice to the legal rights of the ODA or any other relevant authority whether under the London Olympic Games and Paralympic Games Act 2006, planning, traffic or highway legislation or otherwise. Further information and the latest news on the ORN and PRN can be found on the London 2012 website at http://www.london2012.com/olympic-route-network/home.html.

Summary

92 Overall, several issues need to be resolved or clarified in order for the application to comply with the London Plan. Further discussions are required between the applicant and TfL with regards to the movement of the bus stop, car parking levels need to be significantly reduced, the viability of a new car club space needs to be explored, a PERS assessment need to be undertaken, contributions are required towards totems for the ‘Legible London’ scheme, the modal split information needs to be re-calculated and a DSP, CMP and robust travel plan must be secured by condition. Sustainable development

93 The comments below relate to the principle site.

94 The London Plan climate change policies set out in Chapter 5 collectively require developments to make the fullest contribution to the mitigation of, and adaptation to, climate change, and to minimise carbon dioxide emissions. London Plan Policy 5.2 ‘minimising carbon dioxide emissions’ set out an energy hierarchy for assessing applications, London Plan Policy 5.3 ‘Sustainable design and construction’ ensures future developments meet the highest standards of sustainable design and construction, and London Plan Policies 5.9-5.15 promote and support effective adaptation to climate change. Further detailed policies on climate change mitigation and adaptation are found throughout Chapter 5 and supplementary guidance is also given in the London Plan sustainable design and construction SPG.

Climate change mitigation

95 The applicant has broadly followed the energy hierarchy. Sufficient information has been provided to understand the proposals as a whole. The proposals are broadly acceptable; however, further information is required before the carbon savings can be verified.

BE LEAN

page 16 Energy efficiency standards

96 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include energy efficient lighting and mechanical ventilation with heat recovery. The demand for cooling will be minimised through the use of solar control glass and balconies. The development is estimated to achieve a reduction of 26 tonnes per annum (11%) in regulated carbon dioxide emissions compared to a 2010 Building Regulations compliant development.

BE CLEAN

District heating

97 The applicant has identified that the Pimlico District Heating Undertaking (PDHU) network is within the vicinity of the development. However, the applicant’s discussions with the operators of PDHU suggest that the nearest connection point is approximately 700 metres away and it would not be feasible to extend the network at this time based on supplying this single development. However, the energy assessment confirms that provision will be made within the design of the development to allow future connection.

98 The applicant is proposing to install a site heat network linking both buildings served via a single energy centre. A scale drawing showing the size of the energy centre within the basement has been provided.

Combined Heat and Power

99 The applicant is proposing to install a 51 kWe gas fired combined heat and power unit (CHP) as the lead heat source for the site heat network. The CHP is sized to provide the domestic hot water load, as well as a proportion of the space heating. A reduction in regulated carbon dioxide emissions of 35 tonnes per annum (17%) is envisaged through this second part of the energy hierarchy.

100 Given the relatively small size of this residential led development and the complexities of ensuring the successful long term operation of on-site CHP in these circumstances, the applicant should provide further information on the proposed arrangements for managing the operation of the CHP including those relating to the sale of CHP electricity.

BE GREEN

Renewable energy technologies

101 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 80 sq.m. roof mounted photovoltaic cells (PV). A reduction in regulated carbon dioxide emissions of 4 tonnes per annum (3%) will be achieved through this third element of the energy hierarchy.

OVERALL CARBON SAVINGS

102 The estimated regulated carbon emissions of the development are 163 tonnes of carbon dioxide per year after the cumulative effect of energy efficiency measures, CHP and renewable energy has been taken into account. This equates to a reduction of 65 tonnes of carbon dioxide per year in regulated emissions compared to a 2010 Building Regulations compliant development, equivalent to an overall saving of 29%.

page 17 103 The carbon dioxide savings exceed the targets set within Policy 5.2 of the London Plan.

Climate change mitigation

104 London Plan policies 5.1 to 5.9 require development proposals to minimise carbon dioxide emissions in accordance with the energy hierarchy, demonstrate that sustainable design and construction standards have been employed, along with the use of decentralised energy networks, renewable and innovative energy approaches.

105 The application has been supported by the submission of a sustainability assessment which sets out that the proposal will achieve Code for Sustainable Homes Level 4 and BREEAM excellent level for the non-residential uses. The report also sets out how the proposal meets the standards set out in the Mayor’s Sustainable Design and Construction SPG relating to the re-use of land; conservation of energy, materials water and other resources; use of natural systems; reducing noise, pollution, flooding and micro-climatic effects; comfort and security and biodiversity. In addition, the proposal includes green roofs.

106 The proposal complies with London Plan policies 5.1 to 5.9 relating to climate change adaptation but there are a number of matters which require further resolution to ensure compliance with London Plan policies relating to climate change mitigation. Community Infrastructure Levy

107 In accordance with London Plan policy 8.3, the Mayor of London proposes to introduce a London-wide Community Infrastructure Levy (CIL) that will be paid by most new development in Greater London. Following consultation on both a Preliminary Draft, and then a Draft Charging Schedule, the Mayor has formally submitted the charging schedule and supporting evidence to the examiner in advance of an examination in public. Subject to the legal process, the Mayor intends to start charging on 1 April 2012. Any development that receives planning permission after that date will have to pay, including:

 Cases where a planning application was submitted before 1 April 2012, but not approved by then.  Cases where a borough makes a resolution to grant planning permission before 1 April 2012 but does not formally issue the decision notice until after that date (to allow a section 106 agreement to be signed or referral to the Secretary of State or the Mayor, for example).

108 The Mayor is proposing to arrange boroughs into three charging bands with rates of £50 / £35 / £20 per square metre of net increase in floor space respectively (see table, below). The proposed development is within the where the proposed Mayoral charge is £50 per square metre. More details are available via the GLA website http://london.gov.uk/ .

109 Within London both the Mayor and boroughs are able to introduce CIL charges and therefore two distinct CIL charges may be applied to development in future. At the present time, borough CIL charges for Redbridge and Wandsworth are the most advanced. The Mayor’s CIL will contribute towards the funding of Crossrail.

Mayoral CIL London boroughs Rates charging zones (£/sq. m.) Zone

page 18 1 Camden, City of London, City of Westminster, Hammersmith £50 and Fulham, Islington, Kensington and Chelsea, Richmond- upon-Thames, Wandsworth

2 Barnet, Brent, Bromley, Ealing, , Hackney, £35 Haringey, Harrow, Hillingdon, Hounslow, Kingston upon Thames, , Lewisham, Merton, Redbridge, Southwark, Tower Hamlets

3 Barking and Dagenham, Bexley, Croydon, Enfield, Havering, £20 Newham, Sutton, Waltham Forest Local planning authority’s position

110 Westminster City Council is in the process of reviewing the application. Legal considerations

111 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

112 There are no financial considerations at this stage. Conclusion

113 London Plan policies on CAZ, office, retail, housing, children’s playspace, urban design, views, heritage, access and inclusion, transport and sustainable development are relevant to this application. In general, the application complies with these policies, for the following reasons:  Principle of development: there is no strategic concern with the conversion from office to residential uses on either site, as it will not damage the strategic function of the CAZ in line with London Plan policies 2.10 and 2.11.

 Affordable housing: no detailed viability information has been provided to support the proposed off-site solution and it has not been possible to determine whether the proposals provide the ‘maximum reasonable amount’ in line with London Plan policy 3.12.

 Children’s playspace: the proposals do not comply with London Plan policy 3.6.

 Urban design: there are a number of detailed matters which were raised at the pre- application stage but still require further attention to ensure the proposal complies with the policies in chapter 7 of the London Plan.

page 19  Views: the proposals comply with London Plan policy 7.11.

 Access and inclusion: the proposals do not fully comply with London Plan policies 7.1 and 7.2 relating to inclusive access.

 Transport: the proposals do not fully comply with London Plan policies 6.3, 6.13, 6.9, 6.10, and 6.14.

 Sustainable development: the proposals generally comply with London Plan policy 5.5 and 5.6 relating to decentralised energy and heat networks although some further information is required. They also comply with policies relating to sustainable design and construction.

114 On balance, the application does not comply with the London Plan. The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:

 Affordable housing: the detailed viability information should be submitted and independent review should be commissioned.

 Urban design: the issues raised at the pre-application stage should be addressed and the matters relating to the impact of the proposal on the World Heritage Site need to be addressed.

 Children’s playspace: improved provision is required.

 Access and inclusion: further information is required in relation to the wheelchair units and blue badge provision. A full access audit is also required.

 Transport: further negotiation and information is required.

 Sustainable development: further information is required.

115 In addition, given the relationship between the two applications, further information should be provided on the Vauxhall Bridge Road application for information purposes and to allow a comprehensive assessment.

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] Shelley Gould, Case Officer 020 7983 4803 email [email protected]

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