planning report D&P/3444/01 10 December 2014 Stockley House, 130 Wilton Road, SW1V 1LQ in the City of Westminster

planning application no. 14/08299/FULL

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

The proposal Demolition of existing office building (Class B1) and redevelopment to provide a 15-storey building plus three basement levels comprising 107 residential units, retail floorspace (Class A1/A3/A4), 60 car parking spaces, plant enclosure at roof level and public realm works.

The applicant The applicant is Victoria Gardens Development Ltd and the architect is Squire and Partners.

Strategic issues The principle of a residential-led mixed use development on this site within the Central Activities Zone and the Victoria Opportunity Area is strongly supported. Whilst the density, design, ground floor layout, massing and height are supported, further work is required on the internal layout in order to resolve a number of issues relating to residential quality. Further information is also required on the children’s playspace strategy. Matters of inclusive access are broadly supported. The indicative affordable housing offer raises strategic concern and further discussion is required on this, together with an independent assessment of the applicant’s viability appraisal. The energy strategy needs further attention as the London Plan target is not being reached, and there are a number of strategic transport matters that require attention, including the car parking provision and construction logistics including the stopping up of the highway and servicing issues. Conditions and section 106 obligations are required to secure a number of transport matters. Recommendation That Westminster City Council be advised that the application broadly complies with the London Plan but that the issues set out in paragraph 99 of this report should be addressed before the scheme is referred back to the Mayor.

Context

1 On 20 October 2014 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. Under the provisions of The Town & Country Planning (Mayor of

page 1 London) Order 2008 the Mayor has until 28 November 2014 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Category 1C of the Schedule to the Order 2008:

Category 1C: “Development which comprises or includes the erection of a building of more than 30 metres high outside the .”

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

5 The application site is located adjacent to Victoria station on its south-eastern side and currently comprises a seven storey office building on a roughly triangular shaped plot bound by Wilton Road to the east, Hudson’s Place to the north-west (owned by Network Rail) and Bridge Place to the south which the building bridges over as the road runs through from Neathouse Place from the east.

6 The surrounding area is defined by a mix of uses, building styles and heights. Wilton Road contains mainly retail uses at ground level with office or residential above together with some hotel uses, in buildings of generally 5-10 storeys. To the north on Wilton Road is also the Apollo Theatre which is Grade II* Listed. Victoria station is Grade II Listed. There is an entrance to Victoria station opposite the site on Hudson’s Place, which also provides a service access to the station.

7 The site lies within the Central Activities Zone (CAZ) and within the Victoria Opportunity Area (VOA), which London Plan Policy 2.13 and Annex 1 state has the potential for significant mixed-use regeneration given the proximity to the transport interchange, with potential to provide up to 1000 new homes and 4,000 new jobs.

8 The site is served by nineteen bus routes within walking distance, together with National Rail and services on the Victoria, District and Circle lines at Victoria station adjacent to the site. An upgrade is currently taking place at Victoria underground station, known as Victoria Station Upgrade (VSU), which is due to complete in late 2018.

9 Both Wilton Road and Bridge Place are part of the Road Network (TLRN), and access to Wilton Road is restricted to buses, taxis and bicycles. Bridge Place is part of London’s inner and is a key link in the Victoria one way system. As noted in paragraph five above, Bridge Place passes directly under Stockley House, in a one-way westbound direction, and has a weight limit of 18 tonnes. The existing office building oversails Bridge Place with ground floor frontages on both sides. The proposed building would also oversail the highway. The public transport accessibility level (PTAL) is 6b and is therefore classifiable as excellent. Case history

10 A pre-application meeting was held on 7 July 2014 to discuss the scheme now the subject of this planning application. At the applicant’s request, an advice report was not issued.

page 2 Details of the proposal

11 Full planning permission is sought for a development proposing the demolition of the existing office buildings (currently providing 9,869 sq.m GIA) on the site and redevelopment to provide a residential-led mixed-use development comprising a building of 15 stories providing:

 107 residential units;

 Two flexible retail units (Classes A1/A3/A4) at lower ground, ground and mezzanine level;

 Provision of three basement levels utilising an existing car lift off Hudson’s Place providing access to 60 car parking spaces, seven of which will be accessible. Strategic planning issues and relevant policies and guidance

12 The relevant issues and corresponding policies are as follows:

 Land use principles London Plan;  Central Activities Zone London Plan;  Housing London Plan; Housing SPG; Draft Revised Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG;  Affordable housing London Plan; Housing SPG, Draft Revised Housing Strategy;  Density London Plan; Housing SPG;  Urban design London Plan; Shaping Neighbourhoods: Character and Context Draft SPG; Heritage London Plan; Inclusive access London Plan; Accessible London SPG;  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change and Energy Strategy; Mayor’s Water Strategy;  Transport and parking London Plan; the Mayor’s Transport Strategy;  London Plan; Mayoral Community Infrastructure Levy.

13 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 Westminster City Plan: Strategic Policies, adopted November 2013; the saved policies of the 1997 Unitary Development Plan, and; the London Plan 2011 (with 2013 Alterations).

14 The following are also relevant material considerations:  Westminster City Council’s Victoria Area Planning Brief (adopted July 2011).  The Further Alterations to the London Plan (January 2014 consultation draft)  The National Planning Policy Framework and Technical Guide to the National Planning Policy Framework. Land use principles

15 As set out in paragraph seven, the site is located within the Central Activities Zone (CAZ) and within the Victoria Opportunity Area as designated on London Plan Map 2.4 and Annex 1. London Plan Policy 2.10 sets out the strategic priorities for the CAZ, which encourages opportunities for high density development capacity to support the mixed character clusters in

page 3 the CAZ. Whilst this Policy and Policy 4.2 encourage the renewal and modernisation of existing office floorspace in the CAZ, neither the London Plan nor the Policies in Westminster’s City Plan seek to protect existing office space and indeed promote mixed uses, including housing, within the CAZ area. The loss of office floorspace therefore raises no strategic concern, although the Council should satisfy itself that this loss does not undermine the wider employment capacity in the borough.

16 London Plan Policy 2.13 states that development in opportunity areas is expected to optimise residential and non-residential densities and to contain a mix of uses. Annex One of the London Plan indicates that the Victoria Opportunity Area has the potential for significant mixed use intensification, capitalising on the enhancements to the public transport interchange and improvements to accessibility and capacity, and suggests that the area has the potential for up to 1,000 new homes and 4,000 new jobs over the plan period to 2031. The proposals will provide a mix of residential accommodation on the upper floors with flexible Class A retail type uses at ground level, which is fully supported in strategic land use terms within this CAZ location adjacent to a major transport interchange.

17 London Plan Policy 3.3 seeks to increase London’s supply of housing and in doing so sets borough housing targets. The Further Alterations to the London Plan (consultation draft, January 2014) proposes to set Westminster’s target at 1,068 additional homes per year between 2015 and 2025, which the proposals will contribute to and is strongly supported. Housing

18 The proposals include the provision of 107 residential units with the following breakdown of unit types and tenures:

Unit type TOTAL Studio 13 (12%) One bed 16 (15%) Two bed 36 (33.5%) Three bed 38 (35.5%) Four bed 2 (2%) Five bed 2 (2%) TOTAL 107 Table 1: Unit schedule

Affordable housing

19 London Plan policies 3.11 and 3.12 require the maximum reasonable amount of affordable housing to be delivered in all residential developments above ten units, taking into account; the need to encourage rather than restrain development; the housing needs in particular locations; mixed and balanced communities, and; the specific circumstances of individual sites. The tenure split suggested by the London Plan is 60% social/affordable rent and 40% shared ownership. The NPPF, the Mayor’s Housing SPG and the London Plan clearly state that to maximise affordable housing in London and provide a more diverse offer for the range of people requiring an affordable home, the affordable rent product should be utilised in the affordable housing offer in residential developments.

page 4 20 Due to scarce land availability and significant land values in the City of Westminster, there is an acute difficulty in providing enough affordable homes to serve the population in need of such a home. In order to address this, the affordable housing policy in Westminster’s City Plan: Strategic Policies, sets both a unit and floorspace threshold for new developments, and requires new residential development to exceed the target of 30% new affordable homes by floorspace. Westminster’s interim guidance note on affordable housing, however, recognises that in CAZ locations, this affordable floorspace target is reduced to 25%, and recognises that the approach to affordable housing should be informed by viability.

21 The planning statement submitted with the application states that the affordable housing viability report prepared for the applicant by Savills demonstrates that it is not possible to provide any affordable housing. It also states that regardless of the findings of the viability assessment, the applicant is cognisant of the need to deliver affordable homes in London and committed to securing a planning permission for the site, and therefore is prepared to make a financial contribution to the delivery of affordable housing off-site which can be discussed further with the Council.

22 This position raises strategic concern. Whilst GLA officers have not yet had the benefit of seeing the applicant’s viability appraisal or the Council/its consultant’s independent assessment of it, the inability of the development to provide any affordable housing seems implausible, given the likely residential values that will be achieved in this location, and the apparent lack of any abnormal site costs that could impact on surplus (such as contaminated land).

23 Policy 3.12 of the London Plan expects affordable housing to be provided on-site, and the Mayor’s Housing SPG reiterates this point, noting that on-site provision generally gives the greatest certainty of actual provision as well as meeting the Plan’s policies on mixed and balanced communities.

24 In order to maximise affordable housing delivery however, it is recognised that in exceptional circumstances and where it would have demonstrable benefits, 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.

25 The Policy lists a number of exceptional circumstances, where off-site options may be able to:

 Secure 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 (land swap/housing credit).

26 It is acknowledged that site’s central location, with high property values and rent levels, and the current layout of the floor plans with one service core, could potentially make the scheme an unattractive investment for local registered providers due to management costs. It is also recognised that the high values would mean it is not possible to provide intermediate homes within the GLA’s income thresholds. It is acknowledged therefore, that a higher number of larger, family homes could be provided off-site. However, it must first be demonstrated that a suitable quantum and mix of affordable housing cannot reasonably be provided on-site before considering off-site solutions, and the applicant should consider the full range of affordable products, including discounted market sale/rent (DMS/DMR) which do not require the investment of a registered provider.

page 5 27 GLA officers will need to see the applicant’s viability appraisal in order to assess whether the maximum reasonable amount of affordable housing is being delivered, and whether the affordable offer is the optimum that can be achieved through any on/off site mix or commuted sum. The appraisal should include details of rent levels and a range of scenario tests (including a policy compliant scenario test) to demonstrate how the offer has been maximised.

28 In addition, GLA officers will also require further details on the scheme for any donor site, including plans showing the layout and mix of the affordable units, and further detail on timescales for delivery in the context of the phasing for the development on the application site. The London Plan expects applications for donor sites to come forward concurrently with the substantive planning application for the development site.

29 GLA officers expect the Council or their independent consultant, to scrutinise the development finances to understand the constraints inputted into the toolkit and how this has impacted on affordable housing provision. The Council should also confirm that any affordable offer, tenures and rent levels, meet local housing needs. Both reports will need to be supplied to the GLA.

30 Given the indicative position outlined in the planning statement and depending on the on- going negotiations on this matter, GLA officers may insist on a review mechanism being included in the section 106 agreement. This should require a viability re-appraisal at a suitable point before/during implementation, given the uncertainty over values to be achieved or the length of time that may pass from initial toolkit appraisal to actual build out. This should be designed to allow any additional financial surplus to be captured prior to implementation, that may be generated by uplift in residential sales values or more accurate inputs. Such a mechanism would need to be designed to ensure that any financial surplus is allocated to the Council, and ring- fenced for the delivery of additional affordable housing units. In this instance, GLA officers would welcome further information from the Council on its affordable housing investment or delivery programme.

Mixed and balanced communities

31 London Plan Policies 3.8, 3.9 and 3.11 and the Mayor’s Housing SPG all accord priority to affordable family housing in new residential development, promote housing choice and seek a balanced mix of unit sizes and tenures in new developments in order to promote mixed and balanced communities, which can be achieved by providing a mix of tenures across the development and ensuring that the scheme is tenure blind.

32 The scheme includes a generous proportion of family units (those with three or more bedrooms), at just less than 40% (42 units). It is however disappointing that all of these units are for private sale, and as noted earlier in this report, GLA officers need further evidence and scenario testing to demonstrate that providing affordable family homes on-site is not reasonable.

33 It is noted that the top two floors of the building contain a number of super-size four and five bedroom duplex units. Whilst GLA officers recognise that there is a market in London for this type of unit, London Plan Policy 3.4 and paragraph 1.3.20 of the Mayor’s Housing SPG both recognise that such units are not conducive to optimising housing outputs. This needs to be taken into account when negotiating the affordable housing offer.

Residential quality

34 London Plan policy 3.5, Table 3.3 and Annex One of the Housing SPG set out requirements for the quality and design of housing developments, including minimum space standards for new development. The application documents demonstrate that the majority of these standards would

page 6 be met which is welcomed. The design and access statement also demonstrates compliance with the ‘Lifetime Homes’ standard. However, there are some areas that require further work as outlined below.

35 The Mayor’s Housing SPG states that new residential development should generally not provide more than eight units per core, in order to promote a sense of community and ownership over one’s home. In addition, in order to achieve a quality internal environment in terms of light and cross-ventilation, the SPG states that dual aspect units should be maximised and single aspect units facing north should be avoided altogether.

36 The first and second floor layouts, which include the smaller studio and one bedroom units, have nine and ten units per floor/core respectively, which exceeds the Mayor’s standard. As noted in paragraph 31 above, the top floors on the contrary, contain very large duplex units, which is part contributes to the issue on the lower floors. In order to promote mixed and balanced communities and meet the Mayor’s standards for housing quality, the mix and balance of units throughout the floors should be revisited.

37 Aside from the units located on the corners of the triangular shaped building, all units in the scheme will be single aspect, and because of the shape and orientation of the site and the choice in building layout, a large proportion of the units would face north-west. This raises strategic concern, and is a symptom of the choice in layout, where the building maximises its site envelope and only contains one core.

38 GLA officers recognise that in some cases it is not possible to eliminate single aspect north- facing units altogether, and in such cases, the architect should seek to optimise the quality of these units for example by maximising floor to ceiling heights to at least 2.6m, maximising glazing and ensuring the units are not too deep. In this instance, GLA officers are not fully convinced at this stage that this matter has been explored in enough detail.

39 It appears form the plans that the vast majority of the units include private balconies, of varying sizes depending on the unit size. The studio units do not have balconies, but in a high density development in central locations such as this, this is generally accepted.

Density

40 London Plan policy 3.4 requires development to optimise housing output for different locations taking into account local context and character, design principles set out in London Plan Chapter 7 and public transport capacity. Table 3.2 provides the density matrix in support of this policy. Based on the characteristics of the location set out in paragraphs 5-7, the site can be regarded as having a ‘central’ setting within a very high PTAL rating. For this setting, the matrix suggests a residential density in the region of 650-1,100 habitable rooms per hectare.

41 The planning statement confirms that the density of the scheme is 2,166 habitable rooms per hectare. The density is high and exceeds the highest range of the density matrix in London Plan Policy 3.4. However, the Mayor’s Housing SPG makes it clear that the matrix should not be applied prescriptively as other factors such as design, residential quality, townscape and public realm will also determine whether a schemes density is appropriate. In this case, whilst it is recognised that the location is wholly appropriate for high density development which may exceed the range in the matrix, as suggested elsewhere in this report, there are a number of areas the architect needs to revisit to ensure that the residential quality does not suffer, for example the number of units per core, the number of north-facing single aspect units and the strategy for children’s playspace.

page 7 42 The applicant should also confirm that the density figure quoted has been generated using the appropriate calculation based on the net residential site area in accordance with paragraph 1.3.47 of the Mayor’s Housing SPG. As with all high density development, the applicant should take note of paragraph 1.3.41 of the Mayor’s Housing SPG regarding the impacts of high densities on local services and infrastructure.

Children’s play space

43 Children and young people need free, inclusive, accessible and safe spaces offering high- quality play and informal recreation opportunities in child-friendly neighbourhood environments. Policy 3.6 of the London Plan states 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. Applying the methodology within the Mayor’s Play and Informal Recreation SPG (2012), and based on the unit types and tenures, the development will generate a child yield of 16, requiring 164 sq.m of playspace (this is based on a wholly private development, and the methodology will need to be reapplied if the tenure mix is altered as a result of affordable housing discussions).

44 GLA officers acknowledge that given the sites location and constraints, it is impractical to provide extensive children’s playspace on site. However, the application documents do not explain how the need for children’s playspace will be met, and this will be required before the application is referred back at stage two. The Council should also consider whether the section 106 agreement will include a financial contribution for local parks reflecting the quantum provided on site. Urban design

45 The scheme is generally well thought out and the ground floor layout responds successfully to the surrounding context with good levels of active street frontages, and efficient use and activation of the existing underpass, which is welcome.

46 The spatial quality and pedestrian environment of Bridge Place will be significantly improved through the introduction of a light well which runs up the full height of the building, providing daylight and ventilation to residential floors above and a more open and welcoming pedestrian environment along Bridge Place. Refuse and servicing frontages are contained along the southern edge of Bridge Place, enabling residential entrance areas and commercial frontages to be optimised while also enabling the future delivery of Hudson’s Place as a pedestrian/shared space zone.

47 It is understood that discussions are on-going with Network Rail with the aim of securing Hudson’s Place as part of a wider strategy to improve the public realm around the peripheries of Victoria Station and it is understood that this is reliant on the logistics of relocating taxi ranks to the northern edge of the station. Part of the future success of this scheme is dependent on the ability to upgrade Hudson’s Place, and GLA officers would welcome further discussion on the delivery of these upgrade works, including the potential new connection to the station, to ensure that this proposal can be a catalyst for local public realm upgrades.

48 As discussed at the pre-application meeting, the applicant was encouraged to explore means of introducing a second core to be located at the south-east corner of the site and accessed from Wilton Road. This would alleviate concerns relating to a high unit per core ratio and enable the inclusion of on-site affordable units that can be suitably managed by a registered provider. It is disappointing that this has not been included, or any acknowledgement of the potential for this to be accommodated.

page 8 49 Visuals have been included with the application documents that demonstrate how the scale of the proposed commercial unit at the south-east corner is sufficient to provide a usable amount of commercial floorspace while contributing positively to the ground floor activities of the building. Indicative visuals have been submitted demonstrating how the arrangement of corridors around the atrium provides good daylight penetration to communal circulation areas and the opportunity for passive ventilation which is welcomed. Notwithstanding this, and as noted earlier in this report, there remain a number of floors that exceed the Mayor’s Housing SPG guidance of eight units per core and the number of single aspect units, and the applicant is advised again to look at ways of addressing this.

50 The form and massing response to the site is strongly supported, and the building’s 15 storey height sits comfortably within the surrounding context, raising no strategic issues. The submitted visuals demonstrate how the architectural approach has drawn on the proportions and detailing of neighbouring development and successfully balances a traditional and formal language with a clean-lined, modern aesthetic. As discussed at pre-application stage, and based on the indicative high quality of design, GLA officers would support additional height to the building as this would provide a better proportioned and more elegant form in relation to the built footprint and the prominent location of the site.

51 The materials strategy indicates a high quality of traditional facing materials including stone cladding, and anodized bronze which will contribute to forming a high quality appearance and a domestic environment for residential units. Inclusive design

52 The aim of London Plan Policy 7.2 is to ensure that proposals achieve the highest standards of accessibility and inclusion. Inclusive design principles if embedded into the development and design process from the outset help to ensure that all of us, including older people, disabled and deaf people, children and young people, can use the places and spaces proposed comfortably, safely and with dignity.

Residential units

53 The design and access statement demonstrates that all residential units have been designed to the Lifetime Homes standard, and 10% of the units have been designed to be wheelchair accessible or adaptable. This is welcomed and in line with London Plan Policy 3.8. The design and access statement should be amended to include typical floorplans showing how the design of the residential units meets the sixteen Lifetime Home standards and showing the layout of the wheelchair accessible homes. The plans also show where the wheelchair accessible homes are located, which are close to service cores to minimise travel distance for these residents.

Marketing

54 The future marketing of the private wheelchair accessible homes should ensure that prospective purchasers are aware of the accessibility and adaptability of these units. Specific marketing to the disabled community and to older people’s organisations can help to ensure that the people who will benefit from their accessible design are made aware of their existence.

Commercial and public realm

55 Extending the Lifetime Homes concept to the public realm can help to ensure that the parking areas, the routes to the site and links to adjacent public transport and local services and facilities are also designed to be accessible, safe and convenient for everyone, particularly disabled and older people.

page 9 56 The design and access statement includes details showing how disabled people access each of the entrances safely, and includes details of levels, gradients, widths and surface materials of the paths and how they are segregated from traffic and turning vehicles etc, and how any level changes on the routes will be addressed. These features should be secured by condition by the Council.

Parking

57 The design and access statement confirms that seven accessible parking bays will be provided and shows that they will be provided close to the service cores in the basement.

58 The provision and future management of the blue badge parking bays for the residents should be in line with the advice in the Lifetime Homes standards and the Wheelchair Housing Design Guide. A parking management plan should identify how bays will be allocated to residents of the wheelchair accessible units and should include a mechanism to ensure that the supply and demand of the blue badge bays are regularly monitored and the provision reviewed. This ensures that the provision going forward equates to the demand from disabled residents and visitors, and also ensures that the bays are effectively enforced. Climate change mitigation and adaptation

59 The applicant has broadly followed the energy hierarchy and sufficient information has been provided to understand the proposals, although further information and some revisions are required to verify the carbon dioxide savings claimed and in order for the proposals to comply with London Plan energy policies.

Energy efficiency standards

60 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development, such as improving air permeability and heat loss parameters beyond the minimum backstop values required by building regulations, mechanical ventilation with heat recovery and triple glazing. The development includes a centralised cooling plant to serve both the retail and the domestic uses, and evidence is required to demonstrate that the cooling demand has been minimised through passive design measures in line with London Plan Policy 5.9.

61 The development is estimated to achieve a reduction of 34 tonnes per annum (19%) in regulated carbon dioxide emissions compared to a 2013 Building Regulations compliant development. As these savings appear very high, further modelling outputs including full DER and TER sheets for sample units should be provided to support the savings claimed. Further information is also required on how air permeability of 2.49 will be achieved for the retail unit.

District heating

62 The district heating network is within the vicinity of the development and may present an opportunity for connection in the future. Connection to the network should be prioritised and evidence of correspondence with the network operator should be provided including information on timescales for connection and any design issues.

63 The applicant is proposing to install a building heat network, which is supported, although GLA officers require confirmation that all apartments and non-domestic uses will be connected to the network. The site heat network will be supplied from a single energy centre, which will be approximately 100 sq.m in size and located in basement level one. Plans for the plant room have

page 10 been provided showing the proposed location for connection to the Pimlico district heating network in basement level two.

Combined heat and power (CHP)

64 The applicant is proposing to install a gas fired CHP unit as the lead heat source for the site heat network. This approach is not supported at this stage, as connection to the Pimlico district heating network must be pursued as the priority. If this is not possible and CHP is proposed as a back-up option, a feasibility assessment (including installed capacity, running hours, load profiles etc) will be required to support any carbon savings claimed. Information would also be required on the management arrangements for the system.

65 A reduction in regulated carbon dioxide emissions of 14 tonnes per annum (10%) is claimed through this part of the energy hierarchy.

Renewable energy technologies

66 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install 12kWp of solar PV on the roof of the building, and a roof plan has been provided showing the proposed installation. Further information is required on the location of the lift gantry and height of the satellite dish to demonstrate that the PV installation will not be excessively overshadowed.

67 A reduction in regulated carbon dioxide emissions of 3 tonnes per annum (2%) will be achieved through this third element of the energy hierarchy.

Overall carbon savings

68 A reduction of 51 tonnes of carbon dioxide per year in regulated emissions compared to a 2013 Building Regulations compliant development is claimed, equivalent to an overall saving of 28%, which falls short of the targets in London Plan Policy 5.2. The applicant should address the comments above before compliance with other London Plan energy policy can be verified.

69 The applicant should note that a cash in lieu contribution for any shortfall in carbon savings on site should be agreed with the Council, as it has established a cost per tonne of carbon to be used within the borough. Transport for London

Trip generation/modal split

70 Trip generation figures have been supplied in the transport assessment and are satisfactory, so TfL accepts that the development’s trip generation would be unlikely to have a significant impact on the public transport network

Deliveries and servicing

71 A temporary feeder taxi rank is operating on the northern side of Bridge Place during the VSU works, which are operational until 2018, and the proposals include a loading bay which would replace the rank. Appropriate planning obligations will be required to safeguard the feeder taxi rank until the completion of the VSU works.

72 Servicing for the residential and retail uses is proposed to take place on-street from the new loading bay. Servicing/loading should preferably take place on-site and further justification is

page 11 requested by TfL on this matter. Notwithstanding this requirement, restrictions on use would need to be put in place and the design and operation agreed with TfL by use of planning conditions.

73 A delivery and servicing plan will be required and should be secured by condition, in accordance with TfL’s best practice guidance (see https://www.tfl.gov.uk/info- for/freight/planning/delivery-and-servicing-plans). The final plan should be approved by both TfL and the Council.

Car parking

74 Sixty residential parking spaces are proposed including seven wheelchair accessible spaces, which equates to a ratio of 0.56 per unit. Given the highly accessible location close to Victoria station and adjoining the TLRN, the development should be car-free except for accessible spaces to comply with London Plan Policy 6.13, and further discussion is required on this.

75 The applicant also proposes to include in the section 106 agreement a 50% contribution per household towards the cost of leasing a parking space in the local area, once available spaces within the development have been sold. This subsidy mechanism effectively constitutes a proposal for 1:1 parking, which TfL objects to. TfL is concerned about establishing this precedent for dealing with high demand for parking in central Westminster and has requires further discussion with the Council and the applicant on this matter. Except for disabled spaces, TfL would prefer for car parking spaces to be unallocated and governed by a permit system open to all residents on a first come first serve basis.

76 The applicant needs to confirm the location of electric vehicle charging points in the development, which should be in accordance with London Plan Policy 6.13, and secured by condition.

Impact on the highway

77 The proposal includes extension of the existing building footprint out into the TLRN and the applicant has requested for TfL highway land to be stopped up and become part of the new development.

78 Due to the status of Bridge Place as a key part of the inner ring road, TfL in principle opposes the stopping up proposed by the applicant, which could potentially undermine TfL’s ability to deliver additional or improved network capacity in the future as required by London Plan Policy 6.12. It would also result in reduction of the footway to less than two metres wide on the southern side of Bridge Place, contravening TfL’s 2009 Streetscape Guidance.

79 In accordance with London Plan Policy 8.2, TfL has asked the applicant to investigate the feasibility of a highway improvement scheme for the junction of Neathouse Place, Wilton Road and Bridge Place east of the application site with improved crossing facilities. This may include works to be funded by the applicant through a section 106 agreement. The scheme has since been discussed at meetings, and there is a general acceptance that the scheme could improve pedestrian legibility and amenity around the site. However the proposed amendments to the kerb line on the northern side of Bridge Place would preclude future traffic capacity upgrade works (for example extra lanes), and a large section of Wilton Road’s footway would also be lost. Any temporary or permanent stopping up of the highway will require agreements under sections 247 and 248 of the Town and Country Planning Act 1990, and would require approval by both TfL and City of Westminster Council.

page 12 Cycling and cycle parking

80 The existing environment is unwelcoming to cyclists, and the overall design strategy for cycling in the proposals is underdeveloped. For example, drawings submitted include access diagrams which make no reference to cycling, and the applicant has not put forward any measures or features to encourage or ease cycling in the vicinity of the site, which is unacceptable and conflict with London Plan Policy 6.9.

81 TfL has requested an analysis of cycling to and from the site and in the surrounding area to inform discussions between TfL, the applicant and the Council around stopping up the highway and implementing highway improvements. The analysis and discussions may lead TfL to seek a section 106 contribution for cycle connectivity and wayfinding.

82 The applicant has offered to negotiate a section 106 contribution towards cycling, which is welcomed, and could help fund the Central London Grid or Cycle Superhighway 5. TfL will negotiate this further with the applicant when the proposals are more developed.

83 Whilst the cycle parking proposed is in accordance with London Plan standards, the applicant is advised to accord with cycle parking standards in the Revised Early Minor Alterations (REMA) to the London Plan (October 2013, Table 6.3), and minimum standards for provision of visitor and staff cycle parking and changing facilities with showers. All cycle parking and associated facilities should be secured by condition.

Structure

84 As noted earlier in this report, Stockley House oversails the TLRN, and the proposed building would also oversail the TLRN. The headroom clearance proposed between the road surface of Bridge Place and the oversailing element of the new building is 5.775 metres, and the lateral clearance from the kerb face to the supporting columns of the building must be at least 600mm. This issue remains unresolved as the exact positions/dimensions proposed for the columns cannot be interpreted from the drawings. The basement excavation and construction must be subject to technical approval by TfL.

85 TfL will need to agree the wording of a number of planning conditions with the Council before the application is determined.

Public realm

86 The application documents include indicative designs for improvements to Hudson’s Place, which are supported by TfL. TfL should be consulted on any further details or approvals relating to public realm works or materials in respect of Hudson’s Place. Further discussions are required including in relation to the VSU works.

87 Hudson’s Place is also used annually as a temporary bus stop during the Chelsea Flower Show with Network Rail’s co-operation and support. TfL seeks assurances that this could continue before, during and after any works.

Car club

88 There are four car club vehicles within 250 metres of the application site and 15 vehicles within one kilometre. TfL requests that the applicant offers three years of free car club membership for all residents of the development, which should be secured in the section 106 agreement, in accordance with London Plan Policies 6.13 and 8.2.

page 13 Travel planning

89 A framework travel plan has been submitted and TfL supports the measures proposed, subject to funding, monitoring and review mechanisms being secured in the section 106 agreement.

90 A car parking management plan should be secured by condition and include mechanisms to ensure additional blue badge parking provision and electric vehicle charging points can be made quickly and easily if necessary. TfL should be consulted on the discharge of the management plan condition.

91 A full travel plan should be secured by condition and include provision to offer each household a £500 voucher for bicycles and accessories and three years of free car club membership. These measures should be secured in the section 106 agreement.

Construction

92 Notwithstanding TfL’s objection to stopping up the highway for this development, a large number of issues would need to be addressed prior to construction and have been communicated directly to the applicant and Council. A construction logistics plan would need to be secured by condition and should follow TfL’s best practice guidance (see http://www.tfl.gov.uk/info- for/freight/planning/construction-logistics-plans.)

93 Contact would need to be maintained between TfL and the applicant and a timetable agreed for regular updates to be provided to TfL by the applicant at key project milestones. As the construction would take at least 170 weeks and involve numerous vehicle movements per day, the operation of entrances to the construction site and loading bays would need to be carefully managed and monitored in conjunction with TfL throughout construction.

Community Infrastructure Levy

94 The development site is located within the Central London contribution area as identified in the Crossrail Supplementary Planning Guidance. However, as the theoretical contribution required from the existing land uses is greater than that required from the proposed development, the development is not liable to contribute towards the SPG.

95 In accordance with London Plan Policy 8.3, the Mayoral CIL charge within the City of Westminster is £50 per square metre of gross internal area. Further details can be found at http://www.london.gov.uk/publication/mayoral-community-infrastructure-levy. Local planning authority’s position

96 It is understood that the applicant has had pre-application meetings with Westminster Council officers, although the Council’s position on the formal planning application is unknown at this stage.

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

page 14 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 land use principles, housing, urban design, inclusive access, sustainable development and transport are relevant to this application. The application complies with the majority of these policies and is broadly supported but some further information is needed in order to fully comply with the London Plan. The potential remedies to issues of non- compliance are set out below:

 Land use principles: There is no strategic concern to the loss of office floorspace, and the mix of land uses proposed is consistent with CAZ policy and is supported.  Housing: The indicative zero affordable housing offer raises strategic concern, and further discussion is required on this matter, including an independent appraisal of the applicant’s viability assessment. Further work is also needed on elements of the residential quality, including the playspace strategy, the number of units per core, the number of single aspect north facing units, and whether through amendments to the scheme these issues can be issued, together with the potential for a second core to make on-site affordable housing feasible. Whilst the density exceeds the maximum range in the matrix, it is acceptable in this location.  Urban design: The design of the proposal is well thought-out. The ground floor activity, relationship with the streets and improvements to Bridge Place are strongly supported, together with the massing, height and materials strategy. As noted above, further work is required on the internal layout to resolve matters of residential quality and the potential for on-site affordable housing.  Inclusive access: Overall the scheme responds well to the principles of inclusive design subject to conditions.  Climate change: A reduction of 51 tonnes of carbon dioxide per year in regulated emissions compared to a 2013 Building Regulations compliant development is claimed, equivalent to an overall saving of 28%, which falls short of the targets in London Plan Policy 5.2. The applicant should note that a cash in lieu contribution for any shortfall in carbon savings on site should be agreed with the Council, as it has established a cost per tonne of carbon to be used within the borough.

 Transport: A number of transport issues need to be resolved with TfL prior to determination by the Council. TfL opposes any stopping up of Bridge Place to extend the existing building footprint, and reduced car parking and increased provision for blue badge holders is required along with additional cycle parking spaces. A number of other matters are detailed in paragraph 96 of this report which should be addressed.

page 15 for further information, contact GLA Planning Unit (Development & Projects Team): Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email: [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email: [email protected] Natalie Gentry, Senior Strategic Planner – Case officer 020 7983 5746 email: [email protected]

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