planning report D&P/4231a/01 8 October 2018 Graphite Square, Vauxhall in the Borough of Lambeth planning application no. 18/03773/FUL

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

The proposal Demolition of existing buildings and redevelopment with a residential led mixed-use development comprising two buildings of 14 storeys and one 11 storey building, linked by a four storey podium, containing 178 residential units, 6,972 sq.m. of office space, 84 sq.m. of flexible retail/cafe/office, a 247 sq.m. replacement church, and new public realm.

The applicant The applicant is BMOR, and the architect is Architects.

Strategic issues summary Principle of development: The redevelopment of this under-used site for residential-led mixed use purposes is strongly supported. The applicant should provide details on the relocation plans and assistance for all current occupiers, and affordable workspace provision should be considered. Affordable housing: The proposed 35% (by habitable room) affordable housing is strongly supported as a starting point; however, the applicant must fully investigate the provision of grant funding and any other available public subsidy. The low cost rent tenures should be confirmed. An early stage viability review is also required. Urban design, strategic views and historic environment: The design and residential quality of the proposals is generally of a high quality. The daylight and sunlight impacts given as the only ground for refusal of the previous scheme have been significantly reduced as a result of amendments to the massing and height of the proposals. The loss of daylight and sunlight to adjoining properties is minimal, and given the urban context and highly accessible location in central London, an appropriate balance has been struck. Transport: Further information is required on highway impacts and cycle parking. Climate change: The application does not yet comply with London Plan and draft London Plan policies on energy, flood risk, sustainable drainage, and water infrastructure.

Recommendation That Lambeth Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 71 of this report; however, the possible remedies set out in that paragraph could address these deficiencies.

page 1 Context

1 On 5 September 2018, the Mayor of London received documents from Lambeth Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008, the Mayor has until 16 October 2018 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 Categories 1A, 1B and 1C of the Mayor of London Order 2008: • 1A “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.” • 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 (c) outside Central London and with a total floorspace of more than 15,000 square metres.” • 1C “Development which comprises or includes the erection of a building of (c) more than 30 metres high and is outside the City of London.”

3 Once Lambeth 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 0.43 hectare site is currently occupied by a range of low quality buildings of between one and four storeys, and areas of hardstanding used primarily for car-parking. The buildings have been in various uses, including 3,975 sq.m. of office space, 1,156 sq.m. of storage space, and 369 sq.m. of church space, although a number are now vacant and semi-derelict. The site is bounded by Jonathan Street to the north, with two 13-storey residential blocks beyond; Worgan Street to the east, with 5-storey residential blocks beyond; two 5-storey residential blocks to the south, and an associated parking courtyard; and Victorian buildings in commercial use to the west, which front onto Vauxhall Walk. The wider area includes a mixture of uses; primarily residential to the east, and increasingly mixed to the west. Buildings are generally of up to 5-storeys, with two blocks of 14 storeys to the north, and taller blocks to the west along Albert Embankment.

6 The majority of the site lies within the Albert Embankment Conservation Area, and it borders the Vauxhall Gardens Conservation Area to the south and east. The site lies just outside the border of the Vauxhall Nine Elms (VNEB) Opportunity Area, and just within the border of the Central Activities Zone (CAZ).

7 The nearest section of the Transport for London Road Network (TLRN) is the A3036 Albert Embankment, 200 metres west of the site. Four bus routes operate within an acceptable walking distance of the site. The nearest station is Vauxhall, 500 metres south, with National Rail, London Underground Victoria line services and additional bus services. Cycle Hire docking stations are located 200 metres south on Vauxhall Walk, and 400 metres north-east on Black Prince Road. As a result, the site has a public transport accessibility level (PTAL) of 6a, on a scale of 0-6b, where 6b is the highest.

page 2 Details of the proposal

8 The proposal is to demolish the existing office, warehouse and church buildings, and redevelop the site to provide a residential led mixed-use development with a podium building of 4 storeys (fronting onto Worgan Street), two buildings of 14 storeys (fronting onto Worgan Street), and an 11 storey building (at the junction of Worgan Street and Jonathan Street). This will provide 178 residential units, 6,972 sq.m. of office space (Use Class B1), an 84 sq.m. ground-floor flexible retail/cafe/office (flexible Use Class /A3/B1), a 247 sq.m. replacement church (Use Class D1), and provision of a single level basement, together with servicing, car and cycle parking, and provision of new public realm and associated works.

9 The scheme differs to the previously refused scheme (see ‘Case history’) as follows: • Block C at the northern end of the site has been reduced from thirteen to eleven storeys, with the introduction of a stepped massing at upper levels, reduced width of western elevation, and re-orientation of all units to face east/west. • The massing of Block B amended and the width of the podium bridge link to Block C reduced. • The double height pedestrian link between Blocks B and C reduced to a single storey. • Along Worgan Street, the proposed building line moved back by one metre and stepped massing introduced at podium roof level. • Block A at the southern end of the site increased from nine to fourteen storeys. Case history

10 An application (GLA Ref: D&P/4231; LPA ref: 17/02936/FUL) was submitted in July 2016 for demolition of the existing buildings, and redevelopment to provide a residential led mixed-use development of up to 14 storeys, providing 160 residential units, 8,694 sq.m. of office space, 84 sq.m. of flexible retail/cafe/office space, a 213 sq.m. replacement church, servicing, parking, new public realm and associated works. In February 2018, Lambeth Council resolved to refuse planning permission (against officer recommendation), on a single ground, that by reason of its scale and massing and proximity to neighbouring residential properties, the pproposal would adversely impact on amenity due to the sunlight and daylight received by residential occupiers in Arne House Worgan Street, and 79 Vauxhall Walk. This was considered by the Mayor of London on 5 March 2018, who advised Lambeth Council that he was content for it to determine the case itself, subject to any action that the Secretary of State may take.

Strategic planning issues and relevant policies and guidance

11 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 Lambeth Local Plan (2015) and the 2016 London Plan (Consolidated with alterations since 2011).

12 The following are also relevant material considerations: • The National Planning Policy Framework 2018 and National Planning Practice Guidance. • The draft London Plan 2017 and the Mayor’s Minor Suggested Changes, which should be taken into account on the basis explained in the NPPF. • In August 2017, the Mayor published his Affordable Housing and Viability Supplementary Planning Guidance. This must now be read subject to the decision in R(McCarthy & Stone) v. Mayor of London.

page 3 13 The relevant issues and corresponding policies are as follows: • Employment space London Plan; draft London Plan • Affordable housing London Plan; draft London Plan; Housing SPG; Housing Strategy; Affordable Housing and Viability SPG • Housing London Plan; draft London Plan; Housing SPG; Housing Strategy; Providing for Children and Young People’s Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context SPG • Urban design London Plan; draft London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG, London View Management Framework SPG • Historic Environment London Plan; draft London Plan • Inclusive design London Plan; draft London Plan; Accessible London: achieving an inclusive environment SPG • Transport London Plan; draft London Plan; the Mayor’s Transport Strategy • Climate change London Plan; draft London Plan; Sustainable Design and Construction SPG; the Mayor’s Environment Strategy Principle of development

14 London Plan Policy 3.3 ‘Increasing Housing Supply’ recognises the pressing need for more homes and sets an annual target for Lambeth of 1,559 new homes per year between 2015 and 2025. Policy H1 and Table 4.1 of the draft London Plan sets Lambeth an increased annualised average housing completion target of 1,589 between 2019/20 and 2028/29. The redevelopment of this under-used site for residential-led mixed use purposes would contribute to London Plan and draft London Plan housing targets and is strongly supported.

15 London Plan Policy 7.18 supports the creation of new open space and the creation of 1,800 sq.m. of new public realm, representing over 40% of the site area, is strongly supported.

Employment space

16 London Plan Policy 4.2 ‘Offices’ supports mixed use development with office provision to improve London’s competitiveness, while draft London Plan Policy E1 emphasises the need for a range of office space to suit micro, small, medium, and larger businesses. London Plan and draft London Plan policies also support office provision within the Central Activities Zone (CAZ), whilst recognising that the CAZ is a place where people live and that proposals should provide a mix of uses including housing.

17 The existing buildings include 3,975 sq.m. of office space, and 1,156 sq.m. of storage space, although a number of the buildings are vacant and semi-derelict. The applicant should provide further details on the remaining business occupiers on the site, together with relocation plans and full details of assistance that will be provided.

18 The proposals comprise a total of 6,972 sq.m. of office floorspace (Use Class B1) provided across basement, ground and levels 1-3. The employment floorspace would comprise a mixture of larger office floorplates aimed at traditional single or multiple office occupiers at upper levels; and more flexible space that can be sub-divided, at basement and ground floor level, aimed at small businesses and start-ups. One of the ground floor workspace units (84 sq.m.) facing the proposed courtyard, is proposed as flexible retail/cafe/office space. Overall, this represents an increase of 2,997 sq.m. on the existing employment space.

page 4

19 No local or strategic protections are in place for the current use. The proposals would deliver significant qualitative and quantitative improvement in commercial space; replacing low grade and derelict space with high quality space designed to appeal to a range of prospective end users, which is strongly supported. Although the Council has no specific requirement in this area, consideration should be given to secured affordable workspace provision.

Social infrastructure

20 London Plan Policy 3.16 ‘Social Infrastructure’ seeks to ensure there is sufficient high quality social infrastructure to support London’s growth and resists the loss of existing social infrastructure facilities, which is reflected in draft London Plan Policy S1.

21 The existing site includes 369 sq.m. of church space; however, the space has been in use for storage and other miscellaneous uses by the Methodist Church, rather than worship. The proposals include 247 sq.m. of church space on the ground floor to the rear of Block A, with direct access from the newly created public realm within the site. Although the replacement church is smaller than the existing space, the new facility has been designed in consultation with the Church, and is of a size and format that enables the space to be used flexibly for a range of different functions and activities, as encouraged by Policies 3.16 and S1.

22 The replacement social infrastructure is strongly supported and must be secured in any planning permission. In line with draft London Plan Policy D12 ‘Agent of Change’, it must be ensured that the continued operation of the church is unfettered by the proximity of the proposed residential uses. The building envelope must be designed to incorporate adequate sound insulation between noise generating and noise sensitive uses. As it is not yet known how the Church is to use the new facility, it is proposed that a Community Use Management Plan will be secured by planning condition, which is supported. This should provide further details on the operation and uses within the building, including any further controls that may be required to ensure that surrounding residential amenity is not affected by its operation.

Housing

Affordable housing

23 The proposal includes 178 units, with tenure and mix as set out below:

Unit Affordable Intermediate Market Total size rent (shared ownership) 1 bed 7 8 64 79 (44%) 2 bed 14 10 48 72 (40%) 3 bed 16 0 10 26 (15%) 4 bed 1 0 0 1 Total 38 18 122 178 35% (hab room)

24 London Plan Policy 3.12 ‘Negotiating Affordable Housing’ seeks to secure the maximum reasonable amount of affordable housing. Policy H5 ‘Delivering affordable housing’ of the draft London Plan and the Mayor’s Affordable Housing and Viability SPG set a strategic target of 50% affordable housing. Policy H6 ‘Threshold approach to applications’ identifies a minimum

page 5 threshold of 35% (by habitable room) affordable housing, whereby applications providing that level of affordable housing, with an appropriate tenure split, without public subsidy, meeting other relevant policy requirements and obligations to the satisfaction of the borough and the Mayor, as well as investigating grant funding, can follow the ‘fast track route’ set out in the SPG. This means that they are not required to submit a viability assessment or be subject to a late stage viability review. Policy H7 of the draft London Plan and the Mayor’s Affordable Housing and Viability SPG sets out a preferred tenure split of at least 30% low cost rent, with London Affordable Rent as the default level of rent, at least 30% intermediate (with London Living Rent and shared ownership being the default tenures), and the remaining 40% to be determined in partnership with the local planning authority and the GLA.

25 The scheme proposes 35% affordable housing in the form of 68% affordable rent, 32% shared ownership units. The affordable rented homes will be provided at rents at Local Housing Allowance Levels for one and two bed homes, and London Affordable Rents for the family units. The applicant should clarify the tenure of these units as it is understood that all of the affordable rent units were offered at London Affordable Rent levels for the refused scheme. The shared ownership units will be available to households on a range of incomes, in accordance with the Mayor’s qualifying income levels, as set out in the Mayor’s Affordable Housing and Viability SPG, and the London Plan Annual Monitoring Report, which should be secured in the section 106 agreement.

26 The 35% offer, with a tenure split in line with the draft London Plan and the Affordable Housing and Viability SPG, meets the requirements of the ‘Fast Track Route’, subject to the resolution of other issues stated in this report. Whilst this offer is supported as a starting point, the applicant must fully investigate the potential for Mayoral grant funding (and any other available public subsidy) with a view to further increasing affordable housing delivery within the scheme.

27 The requirement for an early stage viability review will be triggered if an agreed level of progress on implementation is not made within two years of any permission being granted, in accordance with Policy H6 of the draft London Plan and the Mayor’s Affordable Housing and Viability SPG.

28 A draft of the section 106 agreement must be agreed with GLA officers prior to any Stage II referral.

Housing choice

29 London Plan Policy 3.8 ‘Housing Choice’ encourages a choice of housing based on local needs, while affordable family housing is stated as a strategic priority. Policy H12 ‘Housing size mix’ of the draft London Plan states that boroughs should not set prescriptive dwelling size mix requirements for market and intermediate homes; and for low cost rent, boroughs should provide guidance on the size of units required to ensure housing meets identified needs.

30 The proportion of family sized units within the affordable rented tenure have been agreed with Council officers in response to its most recent Strategic Housing Market Assessment (October 2017), which identifies an increased demand for two-bed units. The proposed mix provides a good range of units and is therefore supported.

Children’s play space

31 London Plan Policy 3.6 and Policy S4 of the draft London Plan seek to ensure that development proposals include suitable provision for play and recreation, and incorporate good-

page 6 quality, accessible play provision for all ages, of at least 10 sq.m. per child, with further detail in the Mayor’s ‘Shaping Neighbourhoods: Play and Informal Recreation’ SPG.

32 The GLA child yield calculator provides an estimate of 61, requiring 610 sq.m. of play space. A total of 180 sq.m. of under-fives external play space is proposed at podium level, with illustrative proposals included in the application materials. The proposal includes a similarly sized area of external residential amenity space at podium level, as well as generous areas of new public open space at ground floor level. The application also includes a detailed play space assessment, which identifies considerable play provision within easy access of the site, with Pedlars Park, Glasshouse Walk Playground, Black Prince Road and Playground, and Vauxhall Pleasure Gardens all less than a minute’s walk away. Furthermore, a financial contribution towards children’s playspace, in line with the Council’s Planning Obligations SPD, will be secured via the section 106 agreement to address the shortfall in on-site provision. The provision of play space on the site is therefore acceptable.

Urban design, strategic views, and historic environment

Site layout

33 The design principles underpinning the application, including new public pedestrian routes through the site, new areas of public realm, much improved definition to the urban block, and the widening of the currently narrow footway on Worgan Street (further widened since the refused application), are strongly supported.

34 The inclusion of a basement level containing most of the site servicing allows the proposals to achieve very good levels of active frontage on surrounding streets and the proposed public courtyard spaces, with three residential entrance cores located at the base of each block. Splayed openings provide high visibility to the courtyards from surrounding streets, encouraging pedestrians to enter the site. The existing narrow cut through (to the west) from Vauxhall Walk is to be gated at night for security purposes. Following consultation feedback from local residents, the other three entrances into the site are not proposed to be gated; however, the applicant states that gates can be designed into the scheme should the Council consider these are required. Subject to the Council’s views, access arrangements to the site should be appropriately secured.

35 The landscape drawings suggest a high quality and consistent sequence of new public spaces, including planting, seating and amenity areas. Shared external residential amenity space is provided at fourth floor podium level, including play space, with access from all three cores.

Residential quality

36 The massing arrangement of three distinct residential blocks above a 4-storey podium creates efficient core to unit ratios with no more than 6 units per core, and a good proportion of dual aspect units. Single aspect units are limited to one and two-bed units and are south facing, with 2.5 metres floor to ceiling heights, full length glazing to maximise daylight, and recessed balconies with sliding glass screens to minimise overheating. The application includes a full analysis of compliance with Housing SPG standards, which demonstrates that a very high standard of residential quality will be achieved. The affordable rented homes are significantly larger than the minimum standards set out in the Mayor’s Housing SPG, for example the three bed homes range from 95 sq.m. to 118 sq.m. against a minimum requirement of 86 sq.m., which is strongly supported.

page 7 37 A separation distance of 18 metres is achieved between the 3 blocks, which will allow for privacy in line with standards in the Mayor’s Housing SPG. Directional glass is specified to prevent overlooking between the proposed office and residential uses, as well as existing residential/commercial uses. Block C is a minimum distance of approximately 12 metres from east-facing windows of habitable rooms in the third and fourth storeys of the existing 79 Vauxhall Walk residential building. The separation distance has been increased compared to the refused application (previously 6.5-8.5 metres), and residential units are laid out so that their primary aspects are directed away from 79 Vauxhall Walk, which achieves acceptable levels of privacy and restricts overlooking.

Daylight/sunlight

38 The previous application was refused against officer’s advice on grounds of adverse impact on amenity due to the daylight/sunlight received by residential occupiers in Arne House, Worgan Street and 79 Vauxhall Walk. Since then, the applicant has worked with Council officers to address these concerns. Block C at the northern end of the site, adjacent to 79 Vauxhall Walk, has been reduced in height from thirteen to eleven storeys, with the introduction of a stepped massing at upper levels, reduced width of the western elevation, and re-orientation of all units to face east/west. The podium link between Blocks B and C has also been pulled back from 79 Vauxhall Walk. On Worgan Street, opposite Arne House, the building frontage has been pushed back by one metre, with stepped massing introduced at podium roof level. Internal inspections have also been undertaken to Arne House, identifying that all of the living rooms and the majority of primary bedrooms are located on the east elevation facing away from the site. This represents a significant change in circumstances from the previous daylight and sunlight assessment, which informed the Council’s decision to refuse the previous application.

39 The daylight and sunlight analysis assesses the impact on 79 Vauxhall Walk of the revised massing and height of Block C. This concludes that there would now be only a single living room that could be considered to have a major impact, delivering a substantial improvement in technical results against BRE Guidelines compared to the previous planning application.

40 Block A at the southern end of the site has been increased from nine to fourteen storeys compared to the refused application. The applicant’s daylight and sunlight analysis finds that impacts on neighbouring Kennedy House and Jameson House, the reduction in daylight is immaterial, with no reduction in sunlight, which reflects the position of the site to the north of these buildings.

41 In relation to the previous scheme, GLA officers were of the view that the proposed design was of high quality, well-conceived and related positively to the existing context, and the conservation areas. The limited extent of losses of daylight and sunlight to adjoining properties was acknowledged; however, given the urban context and highly accessible location in central London, it was noted that an appropriate balance needs to be struck with the benefits provided, as acknowledged in the Housing SPG and BRE guidance. The delivery of enhanced and new employment uses; new housing; 35% affordable housing, with policy compliant tenure; and new public realm, was considered to outweigh this issue. The design was considered to accord with London Plan Policies 7.4, 7.6 and 7.8, as well as draft London Plan Policies D1, D2 and HC1 and was supported. Taking account of the amendments to the scheme as now proposed, and reduction in daylight and sunlight impacts, GLA officers are more strongly of this view.

Density

42 London Plan Policy 3.4 and draft London Plan Policy D6 ‘Optimising housing density’ seek to optimise the potential of sites, having regard to local context, design principles, public

page 8 transport accessibility, and capacity of existing and future transport services. The higher the density of a development, the greater the level of design scrutiny that is required, particularly qualitative aspects of the development design, as described in draft London Plan Policies D4 ‘Housing quality and standards’ and D2 ‘Delivering good design’.

43 The density is 1,100 habitable rooms, or 404 units, per hectare, based on the net residential site area as per the Mayor’s Housing SPG for mixed use developments. This is within the guidance ranges in Table 3.2 of the London Plan (based on the site’s PTAL of 6a in a ‘central’ setting) and the thresholds set out in Policy D6 of the draft London Plan. Considering the generous provision of new public open space and residents’ amenity space, and the high residential and design quality, the density of the scheme is supported.

Height, massing and appearance

44 The form and massing strategy is supported and introduces a defined shoulder height of four storeys, which is broadly consistent with the scale of immediate surrounding development. The height of the proposed blocks steps up from 11 storeys at the north end of the site, to 14 storeys to the south. The massing of Block C at upper levels is somewhat compromised compared to the refused scheme; however, it is appreciated that this is a response to the need to minimise daylight and sunlight impacts on 79 Vauxhall Walk. In the wider context, the scheme mediates between lower rise areas to the east, the immediate area, which includes 14 storey buildings to the north, and the emerging cluster of tall buildings of over 20 storeys to the west along Albert Embankment. The architectural response draws on the character, proportions, and materials of the industrial heritage of the area, resulting in a distinctive appearance, which is supported.

Strategic views

45 London Plan Policy 7.12 and Policy HC4 of the draft London Plan state that development should not harm strategic views, with further detail provided in the Mayor’s London View Management Framework (LVMF) SPG.

46 A townscape, heritage, and visual impact assessment (THVIA) has been provided, with 24 views as agreed with the Council. This includes the strategic views ‘London Panorama 2: Parliament Hill’ from Assessment Points 2A.2 and 2B.1, as identified in the LVMF SPG (2012).

47 The proposals are only 1.8 metres above the background threshold height identified for London Panorama 2 in the LVMF SPG. The proposal would be largely concealed by existing development, with a small part of the central block ‘technically visible’; however, it would not be visually perceptible to the naked eye. As required by the LVMF SPG, the proposal “is incremental, carefully designed, and of a small scale”, would not affect the viewer’s ability to recognise and appreciate the Palace of Westminster, and complies with the London Plan and the draft London Plan.

Historic environment

48 The Planning (Listed Buildings and Conservation Areas) Act 1990 sets out the statutory duties for dealing with heritage assets in planning decisions. In relation to conservation areas, special attention must be paid to “the desirability of preserving or enhancing the character or appearance of that area”. London Plan Policy 7.8 ‘Heritage Assets and Archaeology’ states that development should identify, value, conserve, restore, re-use and incorporate heritage assets where appropriate, which is reflected in Policy HC1 ‘Heritage conservation and growth’ of the draft London Plan. The NPPF states that when considering the impact of a proposal on the

page 9 significance of a designated heritage asset, great weight should be given to the asset’s conservation, and the more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting.

49 The proposal will have an impact on designated heritage assets. The majority of the site lies within the Albert Embankment Conservation Area, and it borders the Vauxhall Gardens Conservation Area to the south and east. An assessment of the impact is contained within the applicant’s THVIA.

50 The application involves the demolition of buildings within the Albert Embankment Conservation Area; however, the Council’s Conservation Area Character Appraisal (May 2017) states that these buildings are of little interest. The demolition of these buildings would therefore preserve the character and appearance of both Conservation Areas. The new buildings will impact on the Albert Embankment Conservation Area, within which most of site is situated, as well as the setting of the Vauxhall Gardens Conservation Area. The proposed buildings and open spaces would be of far greater quality than those existing, and although the buildings would be of a greater scale than those existing, they would fit within the context of surrounding development and are of lesser height than those existing and under construction to the west. GLA officers consider that the proposals would preserve the character and appearance of both Conservation Areas.

51 The nearest listed building is approximately 200 metres from the site and any impacts would be negligible.

52 In coming to these conclusions, GLA officers have taken account of the strong presumption against granting permission that would harm the character or appearance of the conservation areas, and placed considerable importance and weight to any harm caused to listed buildings. Overall, the application is therefore consistent with London Plan Policy 7.8 and draft London Plan Policy HC1.

Inclusive design

53 London Plan Policy 7.2 and Policy D3 of the draft London Plan seek to ensure that proposals achieve the highest standards of accessible and inclusive design (not just the minimum). Policy 3.8 of the London Plan and Policy D5 require that at least 10% of new build dwellings meet Building Regulation requirement M4(3) ‘wheelchair user dwellings’ (designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users); and all other new build dwellings must meet Building Regulation requirement M4(2) ‘accessible and adaptable dwellings’.

54 The application materials demonstrate that the proposals will meet these requirements. Plans of wheelchair accessible units are provided for a range of unit sizes. The Council should secure M4(2) and M4(3) requirements by condition as part of any permission. Transport

55 The majority of trips will be by public transport or on foot, and as such, the impact of the scheme on the highway network can be accommodated. The impact on the public transport network is acceptable; however, the applicant should provide a further assessment based on the church operating at maximum capacity, with typical hours of use.

56 The site currently has multiple access points from Worgan Street and Jonathan Street. The proposal to provide a single access on Jonathan Street will reduce vehicular conflicts with

page 10 pedestrians and is supported. The proposal for pedestrian access through the site is consistent with London Plan Policy 6.10 ‘Walking’ and draft London Plan Policy T2 ‘Healthy Streets’ and is supported. The applicant has submitted a pedestrian audit, which recognises that the footways surrounding the site are of a sub-standard width. The application will widen the footway on Worgan Street to between 4.85-6 metres, which is consistent with the London Plan and draft London Plan and is supported.

57 The proposal is car free, with the exception of 10 disabled parking spaces, and 6 spaces (Blue Badge sized) leased to an adjacent occupier, to replace 6 spaces currently existing on the site. Whilst the London Plan and draft London Plan does not advocate general commercial parking in areas with high accessibility levels, the approach is reasonable given the existing provision. Notwithstanding this, a single Blue Badge space should be allocated to the other commercial uses at the site. A car park management plan should be secured by condition. The electric vehicle charging provision should be London Plan and draft London Plan compliant at 20% active, with the remainder passive, and this should be secured by condition.

58 The provision of 366 cycle parking spaces is consistent with the London Plan. Since the previous application was submitted, the draft London Plan has increased the level of cycle parking expected in Lambeth. As such, the applicant should investigate how the draft London Plan standards can be met. The short-stay spaces must be located entirely outside of the highway boundary.

59 Servicing is primarily proposed from the basement, with dedicated bays; and a bay is proposed on Worgan Street for larger vehicles, which is supported.

60 A framework travel plan has been submitted, which is satisfactory. In order to encourage sustainable travel and increase cycle mode share, 3 year membership of the Cycle Hire scheme per household and for 10% for the office staff should be funded by the applicant and secured through the section 106 agreement. Funding, monitoring and review of the travel plan should also be secured in the section 106 agreement. An outline construction logistics plan (CLP), in line with TfL’s 2017 guidance, should be submitted prior to determination by the Council. A full CLP should be secured by condition prior to commencement, and discharged in consultation with TfL.

Climate change

Energy

61 Based on the energy assessment submitted, compared to a 2013 Building Regulations compliant development, an on-site reduction equivalent to an overall saving of 41% of CO2 per year in regulated emissions is expected for the domestic element; and 37% for the non-domestic element. Further information has been requested on cooling/overheating, passive design/ energy efficiency, worksheet calculations, the district energy network, the site heat network, and combined heat and power, which must be provided before the proposals can be considered acceptable in accordance with Policy 5.2 of the London Plan and Policy SI2 of the draft London Plan, and the carbon dioxide savings verified. Full details have been provided to the applicant and the Council.

Water

62 The Flood Risk Assessment provided does not fully comply with London Plan Policy 5.12 and draft London Plan Policy SI.12, as it does not give appropriate regard to residual flood risks, and the need for resilience and emergency planning measures. A full review of flood risk should

page 11 be included, including residual risks, from all sources of flooding should be provided, and flood resilience and emergency planning measures to manage these risks.

63 The surface water drainage strategy does not fully comply with London Plan Policy 5.13 and draft London Plan Policy SI.13, as it does not give appropriate regard to the drainage hierarchy and greenfield runoff rate. Further details should be provided on how SuDS measures at the top of the drainage hierarchy will be included, and how greenfield run-off rate will be achieved. An updated outline drainage plan should also be provided.

64 The proposed development does not fully meet the requirements of London Plan Policy 5.15 and draft London Plan Policy SI.5, as it does not meet the water consumption targets of these policies. The proposals should be amended to meet these targets.

65 Full details on these requirements have been provided to the applicant and the Council.

Equalities

66 The 2010 Equality Act places a duty on public bodies, including the GLA, in the exercise of their functions, to have due regard to the need to advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it. This requirement includes removing or minimising disadvantages suffered by persons who share a relevant protected characteristic that are connected to that characteristic and taking steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it. The Act defines protected characteristics and in this case religion is of particular relevance. The GLA in the discharge of its planning function must engage this duty, in so far as it is applicable to a particular case. In this case, the application includes space in use by a religious community. As set out under ‘principle of development’ above, the proposals involve the replacement of this space and officers have set out further information required to ensure compliance with the Act.

Local planning authority’s position

67 The applicant has been engaged in pre-application discussions with Council officers to consider amendments to the scheme to address the single reason for refusal of the previous scheme and it is understood that officers are generally supportive of the proposals. The application is expected to be considered at Committee on 13 November 2018. Legal considerations

68 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 LPA 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.

69 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.

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70 There are no financial considerations at this stage. Conclusion

71 London Plan policies on employment; social infrastructure; housing; affordable housing; urban design, strategic views, and historic environment; inclusive design; transport; and climate change are relevant to this application. The application does not comply with the London Plan for the reasons set out below; however, the possible remedies stated could address these deficiencies: • Principle of development: The redevelopment of this under-used site for residential- led mixed use purposes is strongly supported. The applicant should provide details on the relocation plans and assistance for all current occupiers, and affordable workspace provision should be considered. • Affordable housing: The proposed 35% (by habitable room) affordable housing is strongly supported as a starting point; however, the applicant must fully investigate the provision of grant funding and any other available public subsidy. The low cost rent tenures should be confirmed. An early stage viability review is also required. • Urban design, strategic views and historic environment: The design and residential quality of the proposals is generally of a high quality. The daylight and sunlight impacts given as the only ground for refusal of the previous scheme have been significantly reduced as a result of amendments to the massing and height of the proposals. The loss of daylight and sunlight to adjoining properties is minimal, and given the urban context and highly accessible location in central London, an appropriate balance has been struck. • Transport: Further information is required on highway impacts and cycle parking. • Climate change: The application does not yet comply with London Plan and draft London Plan policies on energy, flood risk, sustainable drainage, and water infrastructure.

for further information, contact the GLA Planning Team: Juliemma McLoughlin, Chief Planner 020 7983 4271 email [email protected] John Finlayson, Head of Development Management 020 7084 2632 email [email protected] Graham Clements, Team Leader, Development Management 020 7983 4265 email [email protected] Martin Jones, Principal Strategic Planner, Case Officer 020 7983 6567 email [email protected]

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