Item No. Classification: Date: Meeting Name: 2 Open 18 December 2014 Planning Committee

Report title: Development Management planning application: Application 14/AP/1862 for: Full Planning Permission

Address: 128-150 BLACKFRIARS ROAD, LONDON SE1

Proposal: Demolition of existing buildings and development of a mixed use scheme comprised of 5 buildings ranging between 5 and 27 storeys high (maximum height of 96.5m AOD to top of roof plant), comprising 336 residential units (Class C3), 2,502sqm of office (Class B1), 1,200sqm of retail (Class A1- A4), 528sqm of office or retail (Class B1 or Class A1-A4) and 154sqm of ancillary residential floorspace (residents gym), 79 basement car parking spaces together with access, hard and soft landscaping and other associated works incidental to the development.

The application is accompanied by an Environmental Statement submitted pursuant to the Town and Country Planning (Environmental Impact Assessment) 2011.

Ward(s) or Cathedrals groups affected: From: Head of Development Management

Application Start Date 01/07/2014 Application Expiry Date 21/10/2014 Earliest Decision Date 22/11/2014

RECOMMENDATIONS

1 a) That planning permission is granted subject to conditions and the applicant entering into an appropriate legal agreement by no later than 28 February 2015, and subject to referral to the Mayor of London;

b) If it is resolved to grant planning permission, that it is confirmed that the environmental information has been taken into account as r equired by Regulation 3(4) of the Town and Country Planning (Environmental Impact Assessments) Regulations 2011;

c) That it is confirmed that, following issue of the decision, the Head of Development Management should place a stateme nt on the Statutory Register pursuant to Regulation 24 of the Town and Country Planning (Environmental Impact Assessments) Regulations 2011 which contains the information required by Regulation 21 and that for the purposes of Regulation 24(1)(c) the main r easons and considerations on which the planning committee's decision is based are as set out as in this report;

d) In the event that the requirements of (1a) are not met by 28 February 2015 the Head of Development Management be authorised to refuse plan ning permission for the reasons set out under paragraph 402 of this report.

BACKGROUND INFORMATION

Site location and description

2 The application site is approximately 1.02ha is size and located at the southern end of Blackfriars Road at its junction with St. Georges Circus. The site is bounded by Blackfriars Road to the west, Tadworth House to the north, Bazeley House and Milcote S treet to the east, Muro Court to the south east and Borough Road to the south.

3 The site is currently occupied by three buildings of up to nine stories in height dating from the 1960s, these being Hill House, Milcote House and Erlang House. Hill House has been vacant since 2009, Milcote House is currently let for use as three artist studios, whilst Erlang House is currently occupied by the Artists Studio Company and is used as studios for approximately 105 artists. The buildings originally provided 13, 348sqm of B1 office floorspace. To the south of Erlang House the site comprises a disused car park.

4 The area is characterised by a mix of uses and building types, including residential, commercial, education uses and student accommodation. The surrou nding buildings vary in design and height of between four and 12 storeys. The predominant height of buildings along Blackfriars Road is eight storeys.

5 There are no listed buildings or structures within the application site, however at the southern-mos t end of the application site, the portion of the site that is currently fenced off to the south of Erlang House and extends from Blackfriars Road around the edge of the Circus and just into Library Street, falls within the St George's Circus Conservation Area. Several Listed Buildings (Grade II) are located in the vicinity, the closest being:

- The Obelisk at the centre of St George's Circus (Grade II*) - St George the Martyr Library - The Duke of Clarence Public House - Nos. 109-112 Borough Road, former Presbyterian Chapel - Nos. 113-119 Borough Road - The Peabody Estate.

6 The site has a high public transport accessibility level (PTAL) of 6b. There are mainline stations and underground stations within the vicinity of the site, including Elephant an d Castle which is approximately 500m away. Numerous bus routes serve the site along Blackfriars Road and Borough Road and the nearest Transport for London (TfL) road is the A201 Blackfriars Road.

Details of proposal

7 The proposed development involves the erection of five blocks comprising the following:

Use Area (m2) Residential 34,518 Office (B1) 2,502 Retail (A1, A2, A3 and A4) 1,200 Office or Retail 528 Total (including basement) 39,467

Block A 8 A nine storey building to the north of the site fronting Blackfriars Road. This provides retail and office use at ground floor, residential accommodation above with a communal amenity space at roof level.

Block B 9 Comprised of two parts being a 10 st orey building (Block B1) fronting Blackfriars Road, with upper floor set back, and a 27 storey tower being 96.5m in height (Block B2). Block B accommodates office units at ground and first floor, retail units at ground floor and residential accommodation above with a communal amenity space at roof level.

Block B3/4 10 Set to the east of Blocks B1/2 and comprising a five storey building accommodating a restaurant/cafe use at ground floor, office uses at basement, ground and first floor, and residential accommodation above with a communal amenity space at roof level.

Block C 11 An eight storey building, with upper floor set back, at the St George's Circus junction of Blackfriars Road and Borough Road. The building would provide retail and office use at ground floor and residential accommodation above.

12 A single le vel basement would be provided beneath Blocks A, B1/2 and C and partially beneath Block B3/4. The basement would provide 78 car parking spaces, 662 secure cycle parking spaces (with a further 92 provided at ground floor level), 8 motorcycle parking spaces , an energy centre and plant rooms, ancillary residential storage and office space (under Block B3/4).

13 The residential accommodation comprises 336 residential units providing a mixture of one, two and three bedroom units.

Unit type Quantity Studio 10 1 bedroom 102 2 bedroom 173 3 bedroom 51 Total 336

14 The development proposes 91 affordable homes representing 30% of total habitable rooms and comprisin g affordable rent and shared ownership units. These are provided within Blocks A and B1. A further in-lieu affordable housing payment has been offered.

15 Amendments have been received during the course of the application as follows: − Alteration to mi x and layout of units resulting in increased number of affordable habitable rooms. − Alteration to window arrangement on blocks A and C to accommodate change of layout of units. − Removal of servicing route through the site. − Segregation of cyclists at top of basement access ramp. − Reallocation of basement parking spaces for service vehicles. − Minor changes to detailing and material use within tower.

Planning history

16 13/AP/1766 Application type: Scoping Opinion (EIA) (SCP) Request for an EIA Scopining Opinion in relation to the redevelopment of the site to provide a mixed use development up to 27 storeys high comprising 384 residential units (Class C3), retail (Classes A1 and A3) and office (Class B1) uses with underground car parking, a landscaped public area and other ancillary works

Decision date 13/08/2013 Decision: Scoping Opinion - EIA Regs (SCP)

Planning history of adjoining sites

17 08-AP-2427 LAND ADJOINING LIBRARY STREET DAVIDGE STREET KING JAMES STREET AND MILCOTE STREET SE1 0RN Erection of a part three, part four, part five, part six storey block (22.69m AOD) comprising 34 residential flats with private terraces/balconies, communal courtyard and roof garden with pergola and cycle parking; erection of 6 three storey 4 bedroom townhouses with private gardens and provision of a community allotment garden. Part of the Elephant and Castle Early Housing Scheme. Decision date 17/12/2008 Decision: Granted with Legal Agreement

KEY ISSUES FOR CONSIDERATION

Summary of main issues

18 The main issues to be considered in respect of this application are:

a) Principle of the proposed development in terms of land use and conformity with strategic policies; b) Environmental impact assessment; c) Density; d) Dwelling mix; e) Affordable housing; f) Quality of residential accommodation; g) Impact on the amenities of occupiers of adjoining properties; h) Impact of adjoining uses on occupiers of proposed development; i) Transport issues; j) Design issues, including layout, height and massing; k) Impact on strategic and local views and sett ing of adjacent listed buildings and conservation areas; l) Ecology and biodiversity; m) Landscaping and Impact on trees; n) Wind; o) Archaeology; p) Land contamination; q) Water resources and flood risk; r) Socio-economic implications; s) Equalities; t) Planning obligations; and Energy and sustainability. Statutory Duties

19 The following main duties apply:

a) In dealing with the application the Council is under a duty to have regard to the provisions of the development plan, so far as material to the application, to local finance considerations so far as material to the application, and to any other material considerations (Section70(2) Town & Country Planning Act 1990);

b) The Council is to determine the application in accordance with the development plan unless other material considerations indicate otherwise (Section 38(6) of the Planning and Compulsory Purchase Act 2004);

c) In considering whether to grant planning pe rmission for development which affects a listed building or its setting, to have special regard to the desirability of preserving the building or its settings or any features of special architectural or historic interest which it possesses. (S66 (1) Planni ng (Listed Building and Conservation Areas) Act 1990). Part of the site lies within a conservation area and therefore the duty imposed by section 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 applies. Accordin gly, with respect to any buildings or other land in the conservation area, special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area.

d) The effect of sections 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 is to create a strong presumption against the grant of planning permission in the event of a finding that a proposed development would cause harm to the setting of a listed building or t o a conservation area. If it is found that the proposal would harm the setting of a listed building or the character and appearance of the conservation area, that harm must be given considerable importance and weight.

Planning policy

20 The statutory development plan for the borough comprises the London Plan 2011, the Southwark Core Strategy 2011, and saved policies of the Southwark Plan (2007).

21 The site is within the Central Activities Zone (CAZ), and Air Quality Management Area (AQ MA). The northern half of the site (Hill House and Milcote House) is within the Bankside, Borough and London Bridge Opportunity Area and the Bankside and Borough District Town Centre. The southern part of the site (Erlang House and car park) is within the Elephant and Castle Opportunity Area and the Elephant and Castle Major Town Centre.

22 The site in its entirety is within an area defined by Southwark's Blackfriars Road SPD. Within the SPD, the site is designated a 'Potential Development Site' (Nos. 4 1 and 42). The SPD replaces the guidance set out in the Elephant and Castle SPD/OAPF for the area around the southern end of Blackfriars Road (including the application site) which forms part of the Elephant and Castle Opportunity Area.

National Planning Policy Framework (the Framework) Section 1: Building a strong, competitive economy Section 2: Ensuring the vitality of town centres Section 4: Promoting sustainable development Section 6: Delivering a wide choice of high quality homes Section 7: Requiring good design Section 8: Promoting healthy communities Section 10: Meeting the challenge of climate change, flooding and coastal change Section 11: Conserving and enhancing the natural environment Section 12: Conserving and enhancing the historic environment

London Plan July 2011 consolidated with revised early minor alterations October 2013 Policy 2.5 Sub-regions Policy 2.9 Inner London Policy 2.10 Central Activities Zone - strategic priorities Policy 2.11 Central Activities Zone - strategic functions Policy 2.12 Central Activities Zone - predominantly local activities Policy 2.13 Opportunity Areas and Intensification Areas Policy 2.15 Town Centres Policy 3.1 Ensuring equal life chances for all Policy 3.3 Increasing housing supply Policy 3.4 Optimising housing potential Policy 3.5 Quality and design of housing developments Policy 3.6 Children and young people's play and informal recreation facilities Policy 3.8 Housing choice Policy 3.10 Mixed and balanced communities Policy 3.11 Definition of affordable housing Policy 3.12 Affordable housing targets Policy 3.13 Negotiating affordable housing on individual private residential and mixed use schemes Policy 3.14 Affordable housing thresholds Policy 4.1 Developing London's economy Policy 4.7 Retail and town centre development Policy 4.8 Supporting a successful and diverse retail sector Policy 4.12 Improving opportunities for all Policy 5.1 Climate change mitigation Policy 5.2 Minimising carbon dioxide emissions Policy 5.3 Sustainable design and construction Policy 5.5 Decentralised energy networks Policy 5.6 Decentralised energy in development proposals Policy 5.7 Renewable energy Policy 5.9 Overheating and cooling Policy 5.10 Urban greening Policy 5.11 Green roofs and development site environs Policy 5.12 Flood risk management Policy 5.13 Sustainable drainage Policy 5.15 Water use and supplies Policy 5.18 Construction, excavation and demolition waste Policy 5.21 Contaminated land Policy 6.1 Strategic approach (Transport) Policy 6.3 Assessing transport capacity Policy 6.5 Funding Crossrail and other strategically important transport infrastructure Policy 6.9 Cycling Policy 6.10 Walking Policy 6.11 Smoothing traffic flow and tackling congestion Policy 6.12 Road network capacity Policy 6.13 Parking Policy 7.1 Building London's neighbourhoods and communities Policy 7.2 An inclusive environment Policy 7.3 Secured by design Policy 7.4 Local character Policy 7.5 Public realm Policy 7.6 Architecture Policy 7.7 Location and design of tall and large buildings Policy 7.8 Heritage assets and archaeology Policy 7.11 London View Management Framework Policy 7.14 Improving air quality Policy 7.15 Reducing noise and enhancing soundscapes Policy 7.18 Protecting local natural space and addressing local deficiency Policy 7.19 Biodiversity and access to nature Policy 8.2 Planning obligations Policy 8.3 Community infrastructure levy

Core Strategy 2011 Strategic Targets Policy 1 - Achieving growth Strategic Targets Policy 2 - Improving places Strategic Policy 1 - Sustainable development Strategic Policy 2 - Sustainable transport Strategic Policy 3 - Shopping, leisure and entertainment Strategic Policy 5 - Providing new homes Strategic Policy 6 - Homes for people on different incomes Strategic Policy 7 - Family homes Strategic Policy 10 - Jobs and businesses Strategic Policy 11 - Open spaces and wildlife Strategic Policy 12 - Design and conservation Strategic Policy 13 - High environmental standards Strategic Policy 14 - Implementation and Delivery

Southwark Plan 2007 (July) - saved policies The Council's cabinet on 19 March 2013, as required by para 215 of the NPPF, considered the issue of compliance of Southwark Planning Policy with the National Planning Policy Framework. All policies and proposa ls were reviewed and the Council satisfied itself that the polices and proposals in use were in conformity with the NPPF. The resolution was that with the exception of Policy 1.8 (location of retail outside town centres) in the Southwark Plan all Southwark Plan policies are saved. Therefore due weight should be given to relevant policies in existing plans in accordance to their degree of consistency with the NPPF.

Policy 1.1 Access to employment opportunities Policy 1.4 Employment sites outside the Pref erred Office Locations and Preferred Industrial Locations Policy 1.7 Development within town and local centres Policy 2.5 Planning obligations Policy 3.1 Environmental effects Policy 3.2 Protection of amenity Policy 3.3 Sustainability assessment Policy 3.4 Energy efficiency Policy 3.6 Air quality Policy 3.7 Waste reduction Policy 3.9 Water Policy 3.11 Efficient use of land Policy 3.12 Quality in design Policy 3.13 Urban design Policy 3.14 Designing out crime Policy 3.18 Setting of listed buildings, conservation areas and world heritage sites Policy 3.19 Archaeology Policy 3:20 Tall buildings Policy 3.28 Biodiversity Policy 4.2 Quality of residential accommodation Policy 4.3 Mix of dwellings Policy 4.4 Affordable housing Policy 5.1 Locating developments Policy 5.2 Transport impacts Policy 5.3 Walking and cycling Policy 5.6 Car parking Policy 5.7 Parking standards for disabled people and the mobility impaired

Regional Supplementary Planning Documents (SPDs) and Guidance London View Management Framework (2012) Providing for Children and Young People's Play and Informal Recreation (2012) Sustainable Design and Construction (2006) The Mayor's Energy Strategy (2010) The Mayor's Transport Strategy (2010) World Heritage Sites (2012) The Mayor's Economic Development Strategy (2010) Housing (2012) Planning for Equality & Diversity in London (2007) The Mayor's Climate Change Mitigation and Energy Strategy (2011)

Southwark Supplementary Planning Documents (SPDs) Sustainability Assessment (2009) Design and Access Statements (2007) Section 106 Planning Obligations (2007) Residential Design Standards (2011) Affordable Housing (2008) Sustainable Transport (2008) Sustainable Design and Construction (2009) Elephant and Castle SPD / Opportunity Area Planning Framework (OAPF) 2012 Draft Affordable Housing 2011 Draft S106 Planning Obligations / CIL SPD 2013

Other guidance documents CABE and EH Guidance on tall buildings (2007) Seeing History in the View (2011) The Setting of Heritage Assets (2011) Understanding Place: Conservation Area Designation, Appraisal and Management (2010)

These establish: That when local authorities are preparing an evidence base to identify appropriate, inappropriate and sensitive lo cations for tall buildings that as a matter of good practice a detailed urban design study should be conducted. This includes analysis of the historic context of the wider area, local character, opportunities and identification of mistakes of the past.

The series of criteria for evaluating tall building proposals including: - Relationship to context - Effect on the historic context - Effect on World Heritage Sites - Relationship to transport infrastructure - Contribution to public space and facilities - Effect on the local environment - Contribution to permeability.

Best practice guidance, including examples, to assist in preparation of heritage area assessments, designation and management of conservation areas, identifying and assessing views, and understanding the character of an area and setting of heritage assets.

Principle of development

23 At the heart of the NPPF is the presumption in favour of sustainable development. Amongst the key themes in achieving sustainable development are ensuring the vitality of town centres, promoting sustainable transport, delivering a wide choice of high quality homes and delivering good design.

Policy context 24 The application site is located within the Central Activities Zone (CAZ), Bankside, Borough and London Bridge Opportunity Area, Elephant and Castle Opportunity Area, Borough and Bankside District Town Centre and Elephant and Castle Major Town Centre. The site is designated in the Blackfriars Road SPD as a ‘Potential Development Site’ (Nos. 41 and 42 – Figure 6).

25 The London Plan considers Opportunity Areas to be “the capital’ s major reservoir of brownfield land with significant capacity to accommodate new housing, commercial and other developments linked to existing or potential improvements to public transport.” (Para. 2.58). Within Opportunity Areas, Policy 2.13 seeks to op timise residential and non-residential output and densities, provide social and other infrastructure to sustain growth, and, where appropriate contain a mix of uses. Development proposals should contribute towards meeting (or where appropriate, exceeding) the minimum guidelines for housing and/or indicative estimates for employment capacity including supporting wider regeneration (including in particular improvements to environmental quality) and integration of developments to the surrounding area.

26 Ta ble A1.1 (Annex 1) of the London Plan provides an indicative employment capacity of 25,000 new jobs and a minimum of 1,900 new homes to be delivered over the plan period (up to 2031) within the Bankside, Borough and London Bridge OA. Within the Elephant an d Castle OA, the target requirement is 5,000 new jobs and a minimum 4,000 new homes.

27 Southwark’s Core Strategy reinforces the London Plan aspirations for development in the CAZ to support London as a world class city. The CAZ and Opportunity Areas a re targeted as growth areas in the borough where development will be prioritised. The council will allow more intense development for a mix of uses in the growth areas and make sure development makes the most of a site’s potential and protects open space (Strategic Policy 1). Strategic Targets Policy 2 reflects the above London Plan targets for the opportunity areas but further seeks around 45,000 sqm of additional shopping and leisure space within the Elephant and Castle OA.

28 The adopted Blackfriars R oad SPD sets out (Para. 2.2.3) the emerging vision for Blackfriars Road which is:

“Blackfriars Road will be transformed into a vibrant place where people will want to work, live and visit. Running south from the river at Bankside to historic St. George’s Circus, Blackfriars Road is a gateway north into Central London, and south to the Elephant and Castle. The historic, wide boulevard will provide a range of different activities, regenerating the area from the river along Blackfriars Road and stimulating change at the Elephant and Castle. Much of the character and historic value of the surrounding residential areas, particularly the conservation areas and listed buildings will continue to be protected and enhanced.”

29 The existing buildings on the site are either vacant or under-utilised and do not maximise the efficient use of this central urban location. Furthermore, they make a very poor contribution to the local streetscape and detract from the quality of the urban environment. The proposed scheme would deliver a high density residential-led development with new landscaping and public realm which fully accords with the principle of prioritising new development within the CAZ and Opportunity Areas. Redevelopment of the site would make an important cont ribution towards the regeneration of the southern end of Blackfriars Road and towards achieving the emerging vision for the area as a destination. The principle of redevelopment is therefore strongly supported.

Land use assessment 30 The Blackfriars R oad SPD aspiration for the area is to have a mix of shops, offices and services. Opportunities to increase the amount and type of development will be maximised, especially opportunities for flexible innovative business space. New homes will be provided, pr imarily on the upper floors of commercial developments, offering a range of housing types and sizes. Existing and new residents would benefit from the increased range of town centre and business uses to help make Blackfriars Road a destination.

31 The proposed development would comprise residential use located at upper floor levels with flexible retail (Classes A1 to A4) and business space located on the ground floors and additional business space on the first floors of Blocks B1 and B3/4 and in the bas ement. The business space would be targeted towards SMEs with the intention of creating a new employment SME quarter for the area. The proposed uses are considered below.

Housing 32 The delivery of a wide choice of high quality homes and the creation o f sustainable, inclusive and mixed communities is a key objective of the NPPF and to this extent the NPPF advices that housing applications should be considered in the context of the presumption in favour of sustainable development.

33 The Core Strategy identifies a target of 24,450 new homes to be delivered in Southwark between 2011 and 2026 and, as noted earlier, minimum housing targets have been set for each opportunity area. The existing buildings on the site do not contain housing and therefore the p roposal would deliver 336 net new homes. The site lies on the boundary of the Borough, Bankside and London Bridge OA which has a housing target of 1,900 and the Elephant and Castle OA which has a housing target of 4,000. This represents 5.7% of the 5,900 c ombined housing targets for the two opportunity areas. As such, the proposal would make a significant contribution to housing supply in the borough. The uplift in new homes will maximise the use of the site and fully accords with land use policy objectives for the site.

Retail 34 The NPPF recognises town centres as the heart of communities and proposals to support their viability and vitality should be encouraged. Competitive town centres that provide customer choice and a diverse retail offer should be promoted and which reflect the individuality of town centres. London Plan Policy 2.11 promotes the enhancement and expansion of retail capacity in the CAZ to meet strategic and local need.

35 Saved Policy 1.7 of the Southwark Plan requires most new developments for retail and other town centre uses to be accommodated within the existing town centres. Accordingly, the application site is located within a town centre. Policy SPD 2 of the Blackfriars Road SPD encourages the provision of a mix of town ce ntre uses within a range of unit sizes to help enhance the commercial attractiveness of Blackfriars Road, and to increase activity and strengthen the appeal of the area. There is currently limited retail provision at the southern end of Blackfriars Road. The provision is retail use on the site is therefore highly appropriate. 36 1,200 sqm (GIA) of dedicated flexible retail (Classes A1-A4) floorspace is proposed within five units of varying sizes along the Blackfriars Road and St. George's Circus frontage s, and at the entrance to the employment courtyard (the "Creative Courtyard") at the rear. A further 528 sqm of either flexible retail or business (Class B1) use is proposed within an additional four units to give a maximum potential retail floorspace of 1,728 sqm (within nine units) for the scheme.

37 The proposed retail strategy is to provide high street type uses along the Blackfriars Road frontage, including the potential for a Metro-sized food retailer. The units fronting the Circus are considered suited to food and drink uses (Class A3 / A4) with a cafe located at the entrance to the Creative Courtyard. Small independent retailers could flank the new public square ("Library Square"). However, at this stage the retail uses are flexible in order to encourage take-up of the units.

38 The proposed scale of the retail offer is appropriate to major and district size town centres and the potential mix of uses would activate the street frontage, thereby contributing to the vitality and viability of the a rea. The majority of buildings along Blackfriars Road, including those on the application site, present blank frontages to the street and do little to contribute to the vibrancy of the area. The new retail units would be designed to have large open frontag es to provide clear views into and from inside to give a much more open and lively feel to the area to ensure better integration with the street environment. The provision of high quality active frontages represents a significant improvement as compared with the existing condition.

Business provision 39 A key objective towards achieving sustainable development is building a strong, competitive economy through securing economic growth. Policies 4.1 and 4.2 of the London Plan promotes the contribution ma de by central London to London's economic success and seeks to meet the needs of the central London office market.

40 At the local level, Strategic Policy 10 of the Core Strategy aims to protect existing business space and support the provision of up to 500,000 sqm of additional business floorspace and 25,000 new jobs in the Bankside, Borough and London Bridge OA. Existing business floorspace will also be protected in the wider CAZ and town centre locations where up to 30,000 sqm of new business space will be encouraged.

41 Specifically to Blackfriars Road, guidance SPD 1 of the SPD encourages new jobs and businesses along Blackfriars Road area to help consolidate and expand the existing business cluster and reinforce the area as a strategic office and employment location. New business floorspace will be encouraged and existing business floorspace is required to be retained or replaced, unless an exception can be demonstrated in accordance with borough employment policies. In this respect, Saved Policy 1.4 of the Southwark Plan sets out the circumstances where a net loss of Class B floorspace may be permitted on sites which have an established Class B use within the CAZ or front onto to a classified road:

a) the applicant can demonstrate that convincin g attempts to dispose of the premises, either for continued B Class use, or for mixed uses involving B class, including redevelopment, over a period of 24 months, have been unsuccessful; or b) the site or buildings would be unsuitable for re-use or redevelopment for B Class use or mixed uses including B Class use, having regard to physical or environmental constraints; or c) the site is located within the town or local centre, in which case in accordance with policy 1.7 suitable Class A or other town centre uses will be permitted in place of Class B uses. Where an increase in floorspace is proposed, the additional floorspace may be used for suitable mixed or residential use. 42 The existing bu ildings on site total 13,348sqm (GIA) of Class B1 office floorspace, albeit vacant or under-used space. At least 2,502sqm (GIA) of dedicated replacement business floorspace would be re-provided within the new development but this could increase to a maximu m of 3,030sqm if the entire 528sqm of flexible retail / business floorspace space is given over to business use. In addition, the scheme includes 1,200sqm of dedicated retail space which can be included as part of the replacement business floorspace provis ion in accordance with Saved Policy 1.4(c). A total 4,230sqm (GIA) of replacement employment floorspace would therefore be provided within the new development which would result in an overall net loss of 9,118sqm (GIA) of Class B employment floorspace. Thi s is a significant loss which needs to be considered very carefully in light of the strong policy direction towards retention and expansion of business floorspace in the CAZ.

43 An Employment Review Report accompanies the application which provides infor mation on the marketing undertaken, occupation and condition of the existing buildings, as well as the local office market.

Marketing 44 The submitted marketing evidence confirms that the existing buildings were actively marketed for re-let from the last quarter of 2008 through 2009 to 2012. The marketing was carried out by mailing and telephone work. Officers consider it somewhat disappoin ting that the marketing campaign didn’t include advertising or publication on websites. However, the report advises that due to the condition of the buildings it was considered that photographs of the buildings on a website would probably deter potential o ccupiers. The marketing resulted in expressions of interest, but no commitments with the exception of an art based organisation who since 2010 has secured short term lets at nominal rents in Erlang House and more recently in Milcote House.

Re-use or redevelopment potential 45 The report advises that Hill House has been vacant since 2009 and is in a very poor, dilapidated condition with signs of vandalism and a back-log of maintenance. The building is not in an occupiable condition and is de-rated (as of April 2012). Although Erlang and Milcote Houses are both occupied as artist studios, the buildings are reported as being functionally obsolete, having been poorly maintained over the years. Milcote House further suffers in terms of commercial viability from being a low-rise building in a “back-of site” location.

46 Officers accept that in their current physical state, the buildings would require significant investment to bring them up to a condition suitable to meet modern day requirements, and essentially they have come to the end of their economic life.

47 A financial appraisal has been undertaken to assess whether refurbishment would be viable. The appraisal compares the existing capital value (£ 16.486 million) as compared with their residual value following refurbishment (£5.131 million). Clearly if the net residual value of the refurbished buildings is less than the value of the existing buildings then refurbishment is not viable.

48 The viabi lity of continued use of the site for Class B purposes through redevelopment has also been considered for two scenarios: wholesale office redevelopment with the same level of floorspace reprovided; and redevelopment as currently proposed.

49 Similarly to the refurbishment option, wholesale office redevelopment was also considered unviable with a net residual value (£4.05 million) less than the existing value. The Borough Valuer has considered the appraisal and agrees that redevelopment with a similar repr ovision of office floorspace would not be viable. Indeed, he considers the assumed rent levels in this scenario to be far too optimistic and as such any positive value would quickly disappear, resulting in a negative residual value.

50 With regards to th e viability of the proposed scheme, the findings show a good residual value for the retail element but a near nil residual value for the office area. In effect, the proposed commercial element would be subsidised by the residential element of the scheme.

51 Officers note that an option for redevelopment of the site with a greater quantum of office floorspace has not been considered. Whilst the expansion of business floorspace in the CAZ is strongly encouraged, the policy requires no net loss of business f loorspace. As such, there is no policy basis to require an increased level of employment floorspace on the site. Furthermore, the Borough Valuer has advised that it is highly unlikely that a developer would provide more offices than they really needed to given the current residential sale values in this location.

Market conditions 52 The report provides commentary on the future demand for office floorspace within the area. It considers that most of the new office supply coming forward is Grade A SE1 market office floorspace, north of Webber Street whereas the application site is in a fringe location with the area more suited to the local office market as opposed to Grade A SE1 office market demand specifications. The report therefore cons iders that the site would be more likely to appeal to SME companies. As such, it is concluded that there is no real prospect of attracting refurbishment or redevelopment interest for Grade A prime office development.

Small and Medium Enterprises 53 SME s play an important role in Southwark’s economy. Whilst the overarching aim in terms of business space for the Blackfriars Road is to reinforce the Blackfriars Road area as a strategic office and employment location (SPD 1), the SPD acknowledges that small office / studio / workshop space would be more appropriate located in the southern part of the area (Para. 3.5). In this respect the proposed provision of small flexible business units is supported and conforms to the council’s aspirations for the area. T he council’s Local Economy Team advise that the type of commercial space proposed is appropriate for the area and local office market.

54 The proposed business units would be clustered around a central courtyard (“Creative Courtyard”) to form a new comme rcial hub. Approximately 24 units could be accommodated, ranging in size from 67 sqm to 164 sqm although these could be amalgamated or subdivided, as required. A particularly positive aspect of the scheme, is its clustering potential with the London South Bank University (LSBU) new business incubator complex (Clarence Centre for Enterprise and Innovation) located at the southern side of the Circus. It is known there is a growing concentration of technology, media, and telecommunications (TMT) businesses in the locality and the provision of new flexible, small business space is welcomed to support this growing sector.

55 Although the proposed clustering of the units around an internal courtyard would create an attractive business location, it does mean that the units have little street frontage. Officers therefore strongly encourage the applicant to utilise the 528 sqm of flexible retail / business spaces which are more prominently located along the site frontages. Not only would this maximise the amount of Class B floorspace within the development, it would also create a more prominent entrance to the units and give the site a stronger identity and presence as a business location.

56 The applicant has advised that they intend to seek a commercial operator to manage the business space which is welcome. Obligations will need to be included within the legal agreement to require details of the management of this space to help towards establishing a successful new business quarter.

Conclusion on land use matters 57 It is acknowledged that the development would result in a large loss of existing employment floorspace which is regrettable. However, the buildings have been marketed for a long period of time, much longer than the 24 month marketing period requi red by Saved Policy 1.4. The buildings are evidently in a poor state of repair and are only partially occupied for short term lets. This does not represent an efficient use of land in this sustainable location. Whilst office use is appropriate for the site , it has been demonstrated that either refurbishment or wholesale redevelopment with replacement quantum provision is not viable. In addition, the refurbishment option would not deliver the other regenerative benefits associated with the scheme such as pro vision of much needed new housing, including affordable homes, attractive active ground floor retail frontages, and high quality landscaped open space and public realm.

58 The proposed new flexible SME workspace is highly appropriate type of business use in the area and fully accords with the council’s aspirations for Blackfriars Road. The proposed 4,230 sqm employment floorspace would generate approximately 252 office workers and 66 retail workers (calculated on the basis of GLA Employment Density) as co mpared with circa 105 artists currently accommodated on site. The uplift in employment opportunities is welcome and to that extent meets the Core Strategy objective towards increasing the number of jobs in Southwark. Taking all matters into consideration, officers are satisfied that the proposal meets the exceptions test set out in Saved Policy 1.4 and the loss of employment space is on balance acceptable.

59 In reaching this conclusion, officers have taken account of the comments submitted by the council ’s Local Economy Team who, whilst supportive of the type of commercial space proposed, consider the overall reduction of employment floorspace unacceptable. The team also refer to the council’s draft S106 Planning Obligations and Community Infrastructure L evy SPD (December 2013) which seeks a financial contribution to mitigate the loss of employment floorspace from developers who cannot meet the criteria (exceptions test) set out in Saved Policy 1.4. Based on the charge set out in the draft SPD, this would amount to circa £354,000 for the quantum of floorspace to be lost.

60 Officers are mindful that the SPD is draft at this stage and as such only limited weight can be attached to it. In any event, it is considered that the developer has met the exception s test set out in Policy 1.4 for the reasons set out above. It therefore wouldn’t be reasonable or justified to seek further planning obligations under these particular circumstances. This by no means sets a precedent for not requesting obligations on futu re development schemes where there is a loss of employment floorspace provision. Each application is considered on its own planning merits and it would be for developers to put forward robust justification based on the particular circumstances of each case.

Environmental impact assessment

61 Applications where an environmental impact assessment (EIA) is required will either be mandatory or discretionary, depending on whether the proposal constitutes Schedule 1 (mandatory) or Schedule 2 (discretionary) development of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011. In this case the proposed development falls within Schedule 2, Category 10(b) ‘Urban Development Project’ of the EIA Regulations where the applicable threshold for such projects is when the area of the development exceeds 0.5 hectare. The application site area is approximately 1.02 hectare in size and is therefore well above the threshold for this type of project. 62 Notwithstanding this, an EIA is only requir ed if the proposal is likely to have significant effects on the environment by virtue of factors such as its nature, size or location and is therefore EIA development. In determining whether Schedule 2 development is EIA development the Council is require d to take into account such of the selection criteria set out in Schedule 3 of the EIA Regulations as are relevant to the development. Those criteria include:

• the characteristics of the development; • the environmental sensitivity of the location; and • the characteristics of the potential impact .

63 Based upon a review of the Schedule 3 criteria, it is considered that the proposed development is likely to generate significant environmental effects and therefore an EIA is required. Accordingly, an Environmental Statement (ES) accompanies the planning application.

64 Prior to the submission of the planning application, the applicant requested a formal scoping opinion under Regulation 13 of the EIA Regulations to ascertain what information the Loc al Planning Authority considered should be included within the ES (application reference 13-AP-1766).

65 Regulation 3 of the EIA Regulations precludes the granting of planning permission unless the council has first taken the “environmental information” into consideration. The “environmental information” means the ES, including any further information and any other information, any representations made by consultation bodies, and any other person about the environmental effects of the development.

66 The ES should identify and assess the likely environmental impacts at each stage of the development programme, including impacts arising from the demolition and construction phases as well those arising from the completed and operational development.

67 It is not necessarily the case that planning permission should be refused if a development has the potential to have significant adverse effects; it has to be decided whether any of the identified adverse impacts are capable of being mitigated or at least reduced to a level where the residual impact would not be so significant or adverse as to warrant a refusal of permission, or would be outweighed by other factors.

68 The submitted ES comprises Volume I: Environmental Impact Assessment (Main text and f igures); Volume II: Townscape, Visual and Built Heritage Assessment; Volume III: Technical Appendices; and Non-Technical Summary. The ES details the results of the EIA carried out and provides a detailed verification of the potential beneficial and adverse environmental impacts arising from the proposed development, including the following areas of impact (in the order they appear in the ES):

• Demolition and Construction • Waste and Recycling • Socio-economics • Traffic and Transportation • Air Quality • Noise and Vibration • Wind Microclimate • Daylight, Sunlight, Overshadowing, Light Pollution and Solar Glare • Water Resources, Drainage and Flood Risk, • Ground Conditions • Archaeology • Ecology • Electronic Interference • Impact Interactions and Cumulative Impact Assessment • Residual Impacts • Townscape, Visual and Built Heritage (ES Volume II).

69 In assessing the likely environmental effects of a scheme, the ES must identify the existing (base line) environmental conditions prevailing at the site, and the likely environmental impacts (including magnitude, duration, and significance) taking account of potential sensitive receptors. It further identifies measures to mitigate any adverse impacts, a nd provides a summary of potential positive and negative residual effects remaining after mitigation measures in order to assess their significance and acceptability. (The ES also discusses alternatives, including the ‘no development scenario’ and this is detailed below).

70 In order to provide a consistent approach within the ES thereby enabling comparison between the impacts, the ES uses the following terminology to define impacts:

• Adverse – detrimental or negative impacts to an environmental resou rce or receptor; • Negligible – Imperceptible impacts to an environmental resource or receptor; • Beneficial – Advantageous or positive impact to an environmental resource or receptor.

71 Where adverse or beneficial impacts have been identified these have been assessed against the following scale:

• Minor – Slight, very short or highly localised impact of no significant consequence • Moderate – Limited impact (by extent, duration or magn itude), which may be considered significant • Major – Considerable impact (by extent, duration or magnitude) of more than local significance or in breach of recognised acceptability legislation, policy or standards.

72 Reference to cumulative effects includes two types of cumulative impact:

• The combined effect of individual impacts, for example noise, airborne dust or traffic on a single receptor; and • The combined effects of several development schemes which may, on an individual basis be insignificant but, cumulatively have a significant impact.

73 Additional environmental information or ‘Further Information’ to support the ES was received during th e course of the application (22 September 2014) and in accordance with Regulation 22 of the EIA Regulations, all consultees and neighbours were re- consulted and a press notice re-advertised. The further information included revisions to the planning applic ation. A summary of the conclusions of the assessment contained in the ES (including Further Information) and the conclusions reached regarding the environmental effects of the proposed development as well as mitigation measures (where required) are set out in the report.

Alternatives 74 Under the EIA regulations, an ES is required to provide “... an outline of the main alternatives studied by the ap plicant or appellant and an indication of the main reasons for his choice, taking into account the environmental effects.” Accordingly, the ES considers three alternative options.

75 The ‘No Development’ alternative would leave the application site in its current state. This scenario is considered by the applicant to have a negative impact in that it would result in missed opportunities to regenerate a brownfield site which is in a strategically important location; to contribute positively to the regeneration of St. George’s Circus and Blackfriars Road; and to formalise the existing pedestrian routes within the wider public realm.

76 No other alternative sites have been considered i n the ES as the site has been designated as a redevelopment site within the Blackfriars Road SPD and hence the ES concludes that the proposed development site is deemed as a suitable location for high quality, residential led mixed use development.

77 The ES also describes the design evolution of the scheme which includes eight different block massing options, of which one shows a 34 storey tower on the Circus with lower rise buildings to the east and north (Option 3 – August 2012). The design has taken account of the existing site context, including heritage, and has been influenced by environmental opportunities and constraints such as daylight and sunlight matters with massing studies undertaken at various stages to identify which part(s) of the scheme caused the most significant impacts to surrounding properties. As such, the final design of the scheme is the result of the development of a series of alternatives, and has responded to issues raised by key stakeholders during the process.

78 Officers consider that the ES satisfactorily demonstrates that other alternatives would not be viable or supported in planning terms, particularly given that the site has been identified as a potential development site where proposed housing, office and re tail uses would be highly appropriate and consistent with the London Plan, Core Strategy and the council’s emerging vision for Blackfriars Road. Alternative quantums and building heights have been considered but these were not considered by the applicant to be a deliverable option. Officers consider that that the applicant has adequately addressed this aspect of the EIA Regulations.

Cumulative impacts 79 The ES has taken into account the potential cumulative impacts of the proposed development alongsid e 18 other committed developments (i.e. those that have been granted planning permission, those with a resolution to grant permission, or those under construction) which produce an uplift of at least 10,000 sqm (GEA) of floorspace and are sited within a 1k m radius of the application site. 14 of the schemes are in Southwark and four are in Lambeth borough. The closest construction site would be Eileen House (granted permission 7 January 2014), which is 400m due south east of the application site.

80 Duri ng demolition and construction of the proposed development, the localised impacts caused by similar works on other development sites are not close enough in proximity to one another to cause any likely significant impact. Furthermore, any construction cumu lative impacts (such as increased traffic, noise, and emissions) would be temporary in nature and can be minimised through the implementation of mitigation measures set out in a Construction Management Plan for the development.

81 The key cumulative impacts of the proposed development with other development schemes once completed and operational are described in the ES. The following potential combined cumulative impacts have been identified and are summarised as:

− Contribution to the provision of new retail, office, and leisure floorspace to meet the needs of future occupiers as well as enhancing opportunities for existing surrounding neighbourhoods in terms of employment opportunities and increased local spending. − New residential housing, the reby contributing to housing targets in terms of dwelling mix, type, and tenures. − Minor beneficial impact to the existing sewer infrastructure in terms of reducing flood risk, assuming all schemes incorporate sustainable urban drainage systems – SuDS. − Beneficial impact on ground conditions (including groundwater) assuming remediation of sites involving the removal of contaminated land. − Minor beneficial impact in terms of biodiversity enhancement through the creation of a range of new habitats in th e area from landscaping planting incorporated into development schemes which will provide a net gain in foraging areas for wildlife. − Minor adverse cumulative impact in relation to the combined increased pressure on water supply.

82 In terms of the combined effect of individual impacts from the proposed development on a single sensitive receptor (which may be neighbouring properties, passers by, or future residents on site), the cumulative impacts arising during the demolition and con struction phase, and the magnitude of the impacts, would vary across the site depending on the different stages of the works. Such impacts are likely to arise from construction traffic, noise, vibration, air quality, daylight and sunlight and visual amenit y. However, the combined impacts would be temporary and transient in nature and although adverse in nature mitigation measures would be in place to ensure these impacts were minimised to ensure they wouldn’t have a significant local impact.

83 Officers acknowledge that there will be adverse impacts resulting from the demolition and construction of the proposed scheme, and this also needs to be considered alongside the construction of other schemes in the area. However, such impacts will be reduced as far as possible and any short-term or temporary nuisance arising has to be balanced with the long-term significant regenerative benefits that the scheme would deliver to the site and the wider Blackfriars Road area. Officers consider that the cu mulative impacts arising from the proposed development as detailed in the ES have been adequately considered and that, with mitigation measures in place, would not result in such significant adverse effects upon people or the environment that would warrant planning permission being refused.

Conclusion on Environmental Impact Assessment 84 The ES concludes (Chapter 19 – Residual Impacts) that in relation to the majority of environmental impacts, the residual impacts of the proposed development during e ach development phase (demolition, construction and operation) following mitigation would be insignificant or negligible. However, there are likely to be some adverse impacts particularly during the demolition and construction phases as well long term adve rse impacts on daylight and sunlight from the completed development. Adverse residual impacts of minor to moderate significance of varying duration have been identified in relation to:

• Impacts on air quality from demolition and construction dust (short term) • Impacts from construction noise (short term) • Daylight and sunlight to existing residential units (long term) • Permanent and transient overshadowing (long term)

85 Whilst it is acknowledged that there would be some significant adverse environmental effects experienced during the demolition and construction phase and operation of the development, this has to be balanced with the fact that the proposed scheme would have a number of major long-term beneficial impacts of varying significance. These have been identified in relation to: • Provision of 336 new homes, including affordable housing • Provision of small and medium sized retail and office facilities • Increased spending in local and regional economy • New open spaces and public realm, including play provision • Enhanced biodiversity (including new tree planting, habitats and species) • Improved permeability and usability through the site • Regeneration of a vacant / underused site • Employment generation – circa 224 net construction related jobs on average per year / circa 223 additional jobs in the completed development • Impact upon the setting of the St. George’s Conservation Area, local heritag e assets, listed structures, regional and local views.

86 A detailed assessment of the likely potential and residual impacts of the proposed development is provided in the relevant sections of this report, taking into account the ES and the relevant pla nning policy considerations. Overall, officers are satisfied that the ES is adequate to enable a fully informed assessment of the environmental effects of the proposal.

Dwelling mix and density

87 Strategic Policy 7 'Family homes' of the Core Strategy 2011 prioritises the development of family homes. The policy sets out differing requirements for provision of family sized units depending upon the geographical area in which developments of ten or mor e units are located. Developments of 10 or more units in the CAZ must provide at least 60% of units with 2 or more bedrooms. The application site straddles the Elephant and Castle OA and the London Bridge and Bankside OA with approx imately 46% and 54% of the site area split respectively. The requirement set out in Strategic Policy differs for the two OAs. In the Elephant Castle OA the policy requires that at least 10% of units have 3,4 or 5 bedrooms, whereas in the Urban Zone (as de fined on Figure 29 of the Core Strategy) at least 20% of units are to be 3, 4 or 5 bedrooms. Policy SP7 also requires that any studio provision should not be higher than 5% (and only be for private housing).

88 The proposed development is made up of the following mix of units:

Unit type Quantity Percentage Studio 10 3% 1 bedroom 102 30.3% 2 bedroom 173 51.5% 3 bedroom 51 15.2% Total 336 100%

89 From the above, it is demonstrated that the proposed residential accommodation makes an appropriate provision of 2+ bedroomed units at 66% and restricts the level of studio units to just 3%. The 3+ bedroomed split has been calculated on the basis of the site straddling the differing zones and thus provides 15%. The development is therefore considered to provide a good mix of units and to comply with Core Strategy SP7.

90 The Core Strategy Strategic Policy 5 states that residential development within the CAZ should be the density range of 650-1,1 00 habitable rooms per hectare. Where development exceeds the density range within the opportunity areas development will be required to be of an exemplary design standard – Section 2.2 of the Residential Design Standards SPD sets out the criteria to be a pplied when considering whether an exemplary standard of design has been achieved.

91 The proposed development has a density of 1,232hr/h which is in excess of the range provided by the Core Strategy. However, the design of the scheme, including its t all tower, does not appear as an over-development of the site, responds appropriately to its context, and does not have significant adverse impacts on neighbouring occupiers. Taking all other matters into consideration, it is considered that this is an ap propriate scale of development for this site in a densely built up area of the Central Activities Zone. While developments that exceed the density guidelines are required to demonstrate exemplary design standards (discussed below) this should be considered in proportion to the appropriateness of the development generally and the extent to which it exceeds the guidelines. In this case the density is not significantly over the range set out in the Core and it is not considered that the high density raises an y issues that would justify withholding planning permission.

Wheelchair Accommodation 92 The London Plan sets out that in major residential developments, 10% of new homes should be accessible for wheelchair users. The wheelchair units and communal ar eas should be designed to meet the criteria set out in the South East London Housing Partnership Wheelchair Housing Design Guidelines (Appendix 1 of the Residential Design Standards SPD). The units should be distributed proportionally across all tenures.

93 The development makes provision for 34 wheelchair units, amounting to 128 habitable rooms and 10.1%. Of these units 6 would be shared ownership affordable units all of which would be fitted out from the outset.

94 Due to uncertainty over the dema nd for wheelchair units in the private sector it is agreed that the remaining 28 units could be designed to be adaptable in that they will be fitted out to a ‘base specification’ and adaptations made to meet individual wheelchair user’s requirements (at no additional fit-out cost to the wheelchair user). The wheelchair accommodation will be secured by legal agreement.

Affordable housing

Policy context 95 The NPPF states that local planning authorities should set policies for affordable housing need on site, unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified and the agreed approach contributes to the objective of creating mixed and balanced communities. Such policies should be sufficiently flexible to take account of changing market conditions over time.

96 London Plan Policy 3.8 requires new developments to offer a range of housing choices, including the provision of affordable housing. Policy 3.12 requires the maximum reasonable amount of affo rdable housing should be sought having regard to a number of factors, including: the need to encourage rather than restrain development; the need to promote mixed and balanced communities; and the specific circumstances of the site.

97 The supporting text in Paragraph 3.74 sets out that:

“Affordable housing should normally be provided on-site. In exceptional cases (where it can be demonstrated that this is not appropriate in terms of the policies in the plan), it may be provided off-site. A cash in-lieu contribution should only be accepted where this would have demonstrable benefits in furthering the affordable housing and other policies in the plan...”

98 Core Strategy Strategic Policy 6 requires major developments to provide as much affordable hous ing as is reasonably possible. It sets a target of 8,558 net affordable housing units between 2011 and 2026, including a minimum 665 affordable homes in the Bankside, Borough and London Bridge OA and 1,400 affordable units in the Elephant and Castle OA. In order to achieve this, the policy requires a minimum 35% affordable housing on major developments.

99 Saved Southwark Plan Policy 4.4 is used alongside the overarching Strategic Policy 6. In terms of tenure, affordable housing within the Elephant and C astle OA should be delivered at 50% intermediate and 50% social rented and for Bankside, Borough and London Bridge OA the tenure split is 70% social rented and 30% intermediate units.

100 The Council’s adopted Affordable Housing SPD 2008 together with th e draft Affordable Housing SPD 2011 provides further detailed guidance to supplement the policy set out in the Southwark Plan and Core Strategy policy framework and sets out the approach in relation to securing the maximum level of affordable housing from developments. The adopted Affordable Housing SPD 2008 and the draft Affordable Housing SPD 2011 both set out guidance on the sequential test.. The 2008 SPD sets out the following in section 3.6. Sections 3.7, 3.8 and 3.9 also set out further guidance.

101 The sequential approach:

1. All housing, including affordable housing should be located on the development site. 2. In exceptional circumstances it may be justified by the applicant that it is not possible to provide the affordable housing on-site or demonstrated that significant benefits will be gained by providing new units in a different location, such as to meet hou sing needs by creating more family housing. In these circumstances we will ask that affordable housing is provided on another site or sites in the local area of the proposed development. This is known as off-site provision. 3. In very exceptional circums tances where it is accepted that the affordable housing can not be provided on-site or off-site, we will require a payment towards providing affordable housing instead of the affordable housing being built as part of the development. This is known as an in-lieu payment or commuted sum.

102 The applicant should not financially benefit by providing affordable housing through off-site provision or in-lieu payments instead of on-site.”

103 The draft 2011 Affordable Housing SPD sets out the following in sec tion 6.3, “The sequential test:

6.3.1 We follow a sequential approach to make sure that we get as much affordable housing as possible. This is in accordance with the sequential approach required by national and regional policy.

6.3.2 The sequential approach is set out below. This applies to all types of housing development including small schemes and student housing developments:

1. All housing, including affordable housing should be located on the development site. 2. In exceptional circumstances we may allow the affordable housing to be provided off-site. In these circumstances we require that affordable housing is provided on another site or sites in the local area of the proposed development. 3. In exceptional circumstances we may allow a pooled contribution in lieu of on-site of offsite affordable housing. In these circumstances we require a payment towards providing affordable housing instead of the affordable housing being built as part of the proposed development.

6.3.3 Where we allow either an off-site or pooled contribution provision, at least as much affordable housing must be provided as would have been provided if the minimum 35% affordable housing policy requirement were achieved on- site.

6.3.4 Affordable housi ng should be delivered at the same time as private housing. This should be the case for on-site, off-site and a pooled contribution provision."

104 Again, further guidance is set out in the following paragraphs, providing more detail on each of the elements of the sequential test.

105 The SPDs give guidance on how to calculate the level of affordable housing a development provides. It describes the habitable room calculatio n for affordable housing purposes, which takes into account an additional habitable room where the size of a room is more than 27.5sqm. Saved Policy 4.5 of the Southwark Plan, also states that for every affordable housing unit which complies with the wheel chair design standards, one less affordable habitable room will be required.

Assessment 106 In total there are 1,085 habitable rooms across the development (those habitable rooms over 27.5sqm have been counted as two habitable rooms), 35% of which equates to 378 habitable rooms which would be the required level of on-site provision.

107 As the application site straddles the two opportunity areas (46% within Elephant and Castle and 54% within Bankside, Borough and London Bridge) the applicant has calculated the tenure split based on the amount of proposed residential floor area falling within each area. This would result in a required tenure split of 39% intermediate and 61% rented across the scheme. This is an acceptable approach as it will achieve the appropriate mix for the location at the boundary of two areas of the borough identified to have different characteristics.

108 The applicant is unable to provide the minimum 35% on-site affordable housing provision on the basis that if such provision were to be made the development would not be financially viable. In order to support this, a financial viability appraisal has been submitted which has been reviewed by the Borough Valuer. The initial affordable housing offer (79 affordable units or 26.5% calculated on a habitable room basis) was considered unacceptable and len gthy, detailed negotiations have since taken place during the course of the application.

109 In order to justify the affordable housing offer, the applicant has sought to show th at the proposed scheme generates a Residual Land Value (RLV) which is less than the Site Value Benchmark (SVB). Whilst a number of inputs into the valuation have been agreed (including commercial values, ground rents, and professional fees) an agreement ha s not been reached on two fundamental matters: methodology of calculating the benchmark value of the site; and residential sale values. As such, the applicant and the Borough Valuer have not reached an agreed position about how much affordable housing can be delivered on site.

110 Notwithstanding that viability matters have not been agreed, further negotiations with officers have taken place and the applicant has revised the affordable housing offer. The breakdown of proposed affordable units is detailed below.

Unit Shared Affordable Rent Target Rent Ownership 1-bedroom 9 8 0 2-bedroom 26 * 40 0 3-bedroom 0 0 8 TOTAL 35 48 8

* Includes 6 x 2-bedroom wheelchair units

The 56 rented units would be located within Block A. The 35 intermediate units would be provided within Block B1 which also contains private market accommodation.

111 As six of the affordable shared ownership units are proposed to be wheelchair accessibl e, the target 378 affordable habitable rooms can be reduced by six habitable rooms to 372 rooms. The proposed affordable wheelchair accommodation will need to be designed from the outset to comply with the South East London Housing Partnership Wheelchair H ousing Design Guidelines and an obligation will need to be included in the legal agreement to secure this.

112 The 91 affordable units (56 x rent and 35 shared ownership units) equates to 325 habitable rooms or 30% on-site affordable housing provision. In terms of tenure this equates to 61% affordable rent and 39% intermediate (shared ownership) which meets the blended policy requirement for the two opportunity areas.

113 The 91 affordable units (56 x rent and 35 shared ownership units) equates to 325 habitable rooms or 30% on-site affordable housing provision. In terms of tenure this equates to 61% affordable ren t and 39% intermediate (shared ownership) which meets the blended policy requirement for the two opportunity areas.

114 The one and two bedroom affordable rent units would be charged at 65% of market rent (inclusive of service charge), capped at Local Au thority Housing Allowance Levels. The 8 x 3-bedroom affordable family units would be let at target rents (i.e. social rent levels – exclusive of service charge). Officers welcome that the family units would be offered at target rents but it is noted that t he affordable housing element doesn’t contain more 3-bedroom family accommodation.

115 The income thresholds for the 35 shared ownership units would be in accordance with the GLA income levels which are currently capped at £ 66,000 for one and two bedroom properties.

116 For a 35% policy compliant scheme, an additional 47 habitable rooms would need to be affordable. The applicant proposes that the shortfall is secured by an in lieu payment. In the very exceptional circumstan ces where an in lieu payment is considered acceptable, the Affordable Housing SPD seeks £100,000 for each habitable room. Accordingly, the applicant proposes a £4.7 million in lieu payment.

117 Affordable housing policy gives a strong direction that affo rdable housing should normally be provided on site. It is only in exceptional and very exceptional circumstances that either on off-site or an in-lieu payment is deemed acceptable. The proposal therefore needs to be assessed against the affordable housing sequential test.

118 The applicant asserts that 30% on-site provision (or 91 units) is the maximum that can practicably be delivered as the scheme is designed so that all the affordable rented accommodation is provided within a single building (Block A) and the intermediate units are located off a separate core within Block B1. It would not be possible to provide more affordable housing that complies with policies on tenure mix without sharing cores which would create management and maintenance problems t hat wouldn’t be attractive to an affordable housing operator. It could also lead to higher housing costs, including service charges, above what would be considered affordable.

119 The applicant states that the availability of sites for off-site prov ision is limited given that the area is undergoing extensive regeneration and that due to the land price this is not always a cost effective delivery method. Furthermore, sites have both already been secured and allocated for development, or else construct ion has started. To find alternative sites at this advanced stage of the process would lead to delay and risk to delivering the project. As such, given the lack of an alternative delivery site a payment in lieu is justified.

120 Officers are satisfied that the proposal maximises the amount of provision on-site given the design of the scheme and that at this late stage of the process it would lead to lengthy delays to find alternative sites. Furthermore, the shortfall is relatively small (i.e. 47 habitable rooms) and therefore a payment towards delivering affordable housing elsewhere in the borough would be a more practical option in these very exceptional circumstances.

121 The proposed development would be built in phases. To ensure the affordable hou sing is delivery is phased in line with the market units the delivery the following phasing is proposed:

a) Block A would be delivered as the first phase and so the 56 rented units will be completed prior to occupation of 50 market units:

b) The 35 intermediate units would be completed prior to occupation of 100 market units;

c) The first 50% of the in lieu payment would be paid prior to occupation of 100 market units or at practical completion of Block B, whichever is the sooner; and

d) The final 50% of the in lieu payment would be paid prior to occupation of 150 market units or at practical completion of Block C, whichever is the sooner.

The applicant is committed to delivering the affordable rent accommodation within two years from imple mentation of the planning permission. The delivery of the affordable housing, including rent levels, will be secured by legal agreement.

Conclusion 122 Although a mutually accepted position on viability matters has not been reached, 35% affordable housing is now proposed with majority of the provision on-site. Officers are satisfied that the sequential approach has been followed and, under the circumstanc es, a payment in lieu is accepted for the shortfall of 47 habitable rooms on site. Both the London Plan and local plan policy allow for such a payment where it has been demonstrated that on-site and off-site provision is not feasible. As such, the proposal accords with policy. It is disappointing that the affordable housing offer doesn’t provide more family units, but the overall 35% quantum of provision is strongly supported. In this respect the scheme would make a significant contribution towards deliveri ng much needed affordable homes in the borough. Furthermore, the applicant is committed to delivering the majority of the affordable units within the first phase of development. The scheme is therefore considered acceptable in terms of affordable housing provision.

Quality of residential accommodation

123 Saved policy 4.2 of the Southwark Plan asserts that planning permission will be granted provided the proposal achieves good quality living conditions, and includes high standards of accessibility, priv acy and outlook, natural light, ventilation, space, safety and security, and protection from pollution. This policy is reinforced by the Residential Design Standards SPD (2012). Section 2.2 of the SPD sets out the criteria required to be met for high density schemes which include:

• Significantly exceed minimum floorspace standards (both flats and rooms) • Provide for bulk storage • Include a predominance of dual aspect units in the development • Exceed the minimum ceiling height of 2.3 metres required by the Building Regulations • Have natural light and ventilation in kitchens and bathrooms • Exceed amenity space standards • Meet good sunlight and daylight standards • Have excellent accessibility within dwellings including meeting Lifetime Homes standards • Minimise corridor lengths by having an increased number of cores • Minimise noise nuisance in flat developments by stacking floors so that bedrooms are above bedrooms, lounges are above lounges etc. • Obtain Secured by Design certification • Have exceptional environmental performance that exceeds the standards set out in the Sustainable Design and Construction Supplementary Planning Document. This will include de signing an energy efficient development, using long lasting building materials and reducing water consumption. • Maximise the potential of the site as demonstrated in the applicant’s Design and Access Statement. • Make a positive contribution to local context, character and communities, including contributing to the streetscape.

Internal Flat Sizes 124 In terms of floorspace, the proposed units meet the minimum requirements with regard total floor area which is demonstrated below:

Unit type SPD (sqm) Min proposed Max proposed Studio 36 38.1 39.4 1 bed 50 50 72.6 2 bed (3 person) 61 63.5 2 bed (4 person) 70 145 3 bed 86 88.4 99.3

125 Whilst in some instances generous floor areas are provided, many of the units either meet or are only marginally above the minimum requirements as is demonstrated in the above table. The internal layout of units is appropriate with individual room sizes meeting or exceeding minimum standards as outlined within the SPD. All of the proposed studi o units, and one 1 bedroom flat, have been amended during the application process to provide a more appropriate internal layout.

126 Habitable rooms have a minimum floor to ceiling height of 2.5m, thus exceeding the minimum 2.3m building control requirement.

127 Bathrooms have been positioned internally in the apartment layouts whilst generally kitchens are open plan and part of combined living/dining space. The affordable 3 bed dwellings have been designed with separate kitchen dining rooms with open able windows. Whilst it would be desirable to locate bathrooms on external walls to achieve direct natural ventilation it is recognised that this is often not a practical use of space.

128 Space has been allocated for residential bulk storage within each of the 336 residential units and additional bulk storage areas are provided within the basement totalling 250sqm of space.

Impact of proposed development on amenity of adjoining occupiers and surrounding area

Aspect and Outlook 129 All new developm ents should maximise the amount of dual aspect flats in order to ensure improved outlook and opportunities for cross-ventilation. North facing single aspect flats should be avoided.

130 Officers would expect schemes seeking to achieve exemplary design t o provide a predominance of dual aspect units. The applicants have stated in their documentation that 211 units would be dual aspect. However Officers assessing the scheme have concluded that there are only 162 true dual aspect units across the scheme whic h equates to a 48.2% provision.

131 Officers consider a true dual aspect unit to have outlook from at least 2 elevations being perpendicular (90degrees) to each other or parallel and facing in opposite directions. Those units located on the west and eas t elevations of the tower, have windows set at just a 38 degree angle, and are therefore not considered to be true dual aspect.

132 Furthermore the development provides 14 north facing single aspect units proposed on the north elevation of Block C.

Overshadowing 133 A Permanent Overshadowing Assessment has been undertaken with regard to the communal amenity areas across the site to establish the extent to which they are in permanent shadow. This assessment has included the roof tops of Blocks A, B2 , B3, B4, in the courtyard and in the main plaza. Overshadowing has a significant impact on how residents will interact with and enjoy their amenity space, as well as for the detailed landscape design considerations such as the planting specifications.

134 The areas located on the tops of Blocks A, B3 and B4 receive at least 2 hours of sunlight on the 21 st March and far exceeds the 50% recommended by the BRE. The area on the roof top of Block B2 falls short of the recommendation with just 23.4% of the area seeing at least 2 hours of sunlight on the 21 st March, however the assessment has established that the vast majority of the area will see hours of sunlight just below the recommended 2 hours and during the summer months the area will see up to 8 hours of sunlight. The courtyard will again fall just short of the recommendation at 48.72% receiving 2 or more hours of sunlight.

135 The main plaza will fall short of the BRE recommended 2 or more hours of sunlight over 50% of the area on the 21 st March, with only 32.85% of the area achieving this standard. The arrangement and massing of those buildings surrounding the plaza, and most particularly the position, height and depth of the tower results in a large proportion of the plaza being in almost permanent shadow.

Privacy and Overlooking 136 The Residential Design Standards SPD states that in order to prevent problems of overlooking, loss of privacy and disturbance, new developments should achieve:

- A minimum distance of 12m at the front of a building and any elevation that fronts onto a highway; - A minimum distance of 21m at the rear of a building. These distances should be achieved both for flats within the new development site as well as between the proposed scheme and surrounding dwellings.

137 Facing windows of habitable rooms are experienced in a number of instances across the development. Between the southern elevation of Block A and the northern elevation of Block B1 the separation gap is reduced to 6.6m. Those windows on the northern elevation of Block B1 however are secondary windows and can therefore be obscured glazed to restrict the potential for direct overlooking occurring. This can be secured by the imposition of an appropriate condition.

138 Between Blocks B1 and B3 at their closest points separation distances range between 9.6m and 11.6 metres. Whilst between Blocks B2 and C distances are reduced to 8.4m in areas. Unlike in the previous situation these windows are not secondary.

139 The close proximity of facing habitable windows in these situations is likely to result in those units experiencing mutual overlooking which is a regrettable situation which cannot be resolved through the use of obscured glazing. Whilst it is acknowledged that in urban locations there can be a degree of flexibility in separation distances, Officers consider that these distances do not present an ideal situation and that at those points noted above, units are uncomfortably close.

Sunlight and Daylight 140 An internal daylight and sunlight re port has been undertaken which has assessed all proposed habitable rooms within the development. This has been prepared in accordance with the Building Research Establishment (BRE) guidelines and methodology for the measurement and assessment of daylight and sunlight within proposed buildings.

141 All habitable rooms have been assessed for Average Daylight Factor (ADF), No Sky Line (NSL) and Room Depth Criterion (RDC). The results show that 95.6% of all rooms tested comply with the BRE’s recommendations for ADF and 92.8% of all rooms achieving the minimum recommended levels of NSL. All rooms have been designed in accordance with the RDC where this is applicable.

142 Where rooms fail to achieve recommended standards these either fall just below those standards and any shortfall is therefore not considered to be perceptible by the human eye, or rooms are generous in size leading these rooms to achieve lower levels, or they are bedrooms where the associated living areas are well lit.

143 A further room achieving levels of daylight below that recommended would be a 7 th floor north facing studio within block C. Whilst the shortfall is not large, it should be noted that such north facing units do not benefit from direct sunlight. The single aspect north f acing units within this block will require supplementation with artificial light and look over the public plaza, which in itself does not benefit from good levels of light.

Amenity Space 144 Paragraph 3.2 of the Residential Design Standards SPD advise s that developments should as a minimum meet and seek to exceed the following standards for private amenity space:

− 50m² of communal space per development; − For units containing 3 or more bedrooms, 10sqm of private amenity space; − For units containing 2 or less bedrooms, ideally 10sqm of private amenity space, and where this is not possible the remaining amount should be added to the communal amenity space requirement.

145 Therefore the development providing 336 residential units should make provision for 3410sqm of amenity space being calculated on the basis of 10sqm per unit and 50sqm of communal space. The proposed development provides 2906.4sqm of private amenity space in the form of terraces, balconies or winter gardens with all units having access to an area of private space of at least 5sqm.

146 The applicant states that 3186sqm of communal amenity space is provided, however this calculation includes the business courtyard, public plaza, mews access route and child play sp ace. All of which Officers do not considered constitute areas of residential communal amenity space.

147 Officers calculate that in ad dition to those areas of private amenity space a series of roof top communal gardens, to Blocks A, B and B2/3, totalling 923sqm would be provided. This will provide a valuable amenity source for residents in the form of raised grass lawns, sun decks, seat ing, pergolas and soft landscaping. This takes the total area of amenity space provision to 3829.4sqm exceeding the required total provision by 419.4sqm. As well as the private and communal amenity spaces, residents can benefit from the new public square ‘the main plaza’ set within the centre of the scheme.

148 In terms of areas therefore the proposed development meets the required provision for private and communal amenity space as outlined within the SPD.

149 However, officers have concerns about the availability of those areas of amenity space to all residents within the development. Block C fronting St Georges Circus sees a concentration of the larger 3 bedroomed units with a total of 30 being provided within this block. Of those 30 units, 4 do not make provision for a single usable area of amenity space. This results from unusual shaped balconies which narrow in areas creating pinch points that can’t be accessed. Therefore whilst the total area of balcony/terrace exceeds standards, the usable area is considered to fall below 10sqm with either 7.9sqm or 8sqm provided for these units.

150 Of most concern is that within this block, where we see a concentration of family units, there is no access to any area of communal amenity space or child pl ay space, all of which are situated on the roof areas of the other blocks. Therefore, not only are some family units considered to fall short of private amenity space provision, they also do not have access to those areas of communal amenity or designated child play space within the development.

Child Play Space 151 The communal gardens will provide a total of 245sqm of dedicated play space for 0-5 years which will combine a selection of naturalistic play elements and bespoke sculptural fixtures. These will include play huts, balance beams, wobble dishes, boulders and stepping logs.

152 Whilst the provision of child play space within the dev elopment is welcomed it only accounts for 29.6% of the required 826sqm which should be provided based on the calculated child yield within the development. This is a significant shortfall and whilst the other areas of communal amenity space will also be available to children this does not compensate for the lack of designated play facilities within the development.

153 Taking into account the failure of some large family units to meet minimum private amenity standards and the 70.4% shortfall of playspace provided, the development falls significantly short of providing the exemplary standard of accommodation sought in this respect.

Conclusion on residential quality 154 The proposed development provides accommodation that in the majority is considered to be of a satisfactory standard with some units falling short of minimum expected levels of residential quality. The development cannot be said to be of an exemplary standard of design for the following reasons:

− The development does not significant ly exceed minimum floorspace standards for flat and room sizes and in many instances it provides accommodation that only just meets minimum requirements. Whilst some larger units exceed those standards, this cannot be said of the development as a whole.

− Distances between facing habitable rooms of units do not meet minimum separation standards as established within the Residential Design Standards SPD.

− There is not a predominance of dual aspect units across the development with only 48.2% being true dual aspect, of the remaining single aspect units 14 are north facing units.

− A high proportion of units comply with the BRE's recommendations with regard to sunlight and daylight and the proposed roof terraces on Blocks A and B would achieve good leve ls of direct sunlight. The roof terrace to Block B4 and the public plaza however would experience poor levels of light.

− The range of facilities offered would in the majority meet the resident's needs for amenity space. However 30 family sized 3 bedro omed units would have restricted access to areas of communal amenity space and play space, and 4 of these units are considered by officers to fail to meet minimum areas of private amenity space.

− Insufficient provision of child play space has been made with a 70.4% shortfall.

155 For those reasons as noted above the development is not considered to be of an exemplary standard of design as referred to in Core Strategy policy SP5(4) and as defined by section 2.2 of the Residential Design Standards SPD (2 012). Consideration of environmental performance and the developments contribution to local context, character and communities, including contributing to the streetscape, are discussed below.

Impacts on neighbouring residential amenity

156 Strategic Policy 13 of the Core Strategy sets high environmental standards and requires developments to avoid amenity and environmental problems that affect how we enjoy the environment. Saved Policy 3.2 of the Southwark Plan states that planning permissio n for development will not be granted where it would cause a loss of amenity, including disturbance from noise, to present and future occupiers in the surrounding area or on the application site. Furthermore, there is a requirement in Saved Policy 3.1 to e nsure that development proposals will not cause material adverse effects on the environment and quality of life.

157 A development of the size and scale proposed will clearly have potential significant impacts on the amenities and quality of life of occupiers of properties both adjoining and in the vicinity of the site. The proposal has required an EIA in order to ascert ain the likely associated environmental impacts and how these impacts can be mitigated. The accompanying ES and ES Addendum deals with the substantive issues raised by local residents. An assessment then needs to be made as to whether the residual impact s, following mitigation, would amount to such significant harm as to justify the refusal of planning permission.

Outlook and privacy of neighbouring properties 158 In the interests of preventing overlooking and protecting the amenity of existing resid ents, paragraph 2.8 of the residential design standards SPD states that a minimum separation distance of 12m should be secured at the front of the building and any elevation which fronts onto a highway. The SPD states that where the minimum distances cann ot be met, the applicants must provide justification through the Design and Access Statement.

159 Those existing residents in closest proximity are located to the east within Blazeley House and to the south east on the opposite side of Libra ry Street. Between Block B2/3 and Blazeley House a gap of 17m is maintained across pedestrian and vehicle access routes. This is considered sufficient to ensure existing residents are not unduly affected through loss of privacy or overlooking. To the so uth across Library Street a gap of 16m is maintained and is therefore in excess of recommended minimum distances.

160 To the north of the site between Block A and Blazeley Hous e the separation gap is reduced to just 6.8m between the northernmost section of Blazeley House and the first floor residential roof terrace proposed on the rear elevation of Block A. This has the potential to result in conflict between the users of the a menity area and the occupiers of those residential units at ground, first and second floor levels within the northernmost party of Blazeley House. It is therefore recommended that the imposition of a suitable condition requiring the installation of a priv acy screen to this terrace be included on any permission given.

161 In all other areas the distances as outlined within the SPD are exceeded. Subject to the above mentioned condition the development is not considered to unduly adversely affect the privacy of existing residential neighbours.

Daylight Impacts 162 An assessment of the likely significant impacts of the development on daylight and sunlight is contained in the ES and in the ES Addendum. Local concerns have been raised that the developmen t will have a negative effect on light and shading. The impacts on levels of daylight received by neighbouring properties have been assessed in line with best practice guidance produced by the Building Research Establishment (BRE). The report prepared by GIA, which forms part of the ES, uses two methods to assess the impact of the proposed development on neighbours: the Vertical Sky Component (VSC) test and the No Sky Line (NSL) or Daylight Distribution analysis.

163 The VSC test considers the angle of visible sky that falls on a window taking account of local obstructions. The BRE sets out that a 27% VSC indicates a good level of daylight. Further, the guidance advises that if a proposed development results in the VSC of neighbouring buildings falling by more than 20% this would result in a noticeable impact, with a breakdown as follows:

0-20% Negligible 20-29.99% Minor 30-39.99% Moderate 40% + Major

The VSC analysis only applies to habitable rooms.

164 This is supplemented by the NSL o r Daylight Distribution method, a simple test that considers the proportion of a room from which the sky is visible. Again, if a 20% reduction occurs then this would indicate a noticeable impact as a result of the development.

165 The report considers the impact on the following neighbours: − 1 Mclaren House (student accommodation) − 115 Blackfriars Road (hostel accommodation) − Blocks A-B, C, R & S Peabody Square − 1-27 Tadworth House − 1-32 Markstone House − 1-32 Bazeley House − 42 Davidge Street − E&C Early Housing 2 nd Block, Library Street − E&C Early Housing, Library Street.

A table of those properties tested and results can be seen below:

Property No. of No. No. with No. with No. with % of windows retaining minor moderate major rooms tested at least adverse adverse adverse failing to 27% VSC impact of impact of impact of meet NSL or at least up to between over 40% BRE 80% of 29.99% 30%- reduction guidelines their reduction 39.99% in VSC baseline in VSC reduction value in VSC 1 Mclaren 219 37 115 51 10 44% House 115 53 11 20 14 20 47% Blackfriar s Road Blocks 58 7 13 22 16 78% A - B Peabody Square Block C 8 - 8 - - 100% Peabody Square Block R 24 22 2 - - 25% Peabody Square Block S 30 30 - - - 10% Peabody Square Block T 35 35 - - - 0% Peabody Square 1-27 73 64 7 2 - 0% Tadworth House 1-32 139 48 50 15 26 12% Markston e House 1-32 144 8 11 36 89 50% Bazeley House 42 23 23 - - - 0% Davidge Street Property No. of No. No. with No. with No. with % of windows retaining minor moderate major rooms tested at least adverse adverse adverse failing to 27% VSC impact of impact of impact of meet NSL or at least up to between over 40% BRE 80% of 29.99% 30%- reduction guidelines their reduction 39.99% in VSC baseline in VSC reduction value in VSC E&C 32 32 2 - - 9% Early Housing 2nd Block, Library Street E&C 107 59 17 20 11 13% Early Housing, Library Street

1 Mclaren House and 115 Blackfriars Road 166 In considering those impacts as outlined within the table above, regard needs to be had to the nature of some of the residential properties being affected. 1 Mclaren House is made up of student accommodation and the transitory nature of the student accommodation should be taken into account. Residents will only be living in this accommodation on a tempo rary basis and officers consider that this influences the nature of the impact on these properties.

167 A similar situation exists at 115 Blackfriars Road, which provides hostel accommodation and as such is again a transient use. The mate rial weight attached to those impacts identified within both 1 Mclaren House and 115 Blackfriars Road is considered to be less significant than they would be if they were to be experienced by permanent residents.

Conclusion on Daylight 168 As is demonstrated above the daylight assessment undertaken demonstrates that there will be a marked loss of light experienced to a high proportion of surrounding residential occupiers and Officers consider this to be a regrettable consequence of the development. Of particular concern is the loss of light to Block C Peabody Square, Blazeley and Markstone House and the E&C Early Housing.

169 For the units affected, the level of daylight they receive would be particularly poor with some window s in Blazeley House experiencing a 100% reduction in VSC and within E&C Early Housing some windows will experience a 92.31% reduction. It should be noted however these figures should be understood as representing a worst case scenario when the sky is over cast and that in reality, reflections of light from other surfaces will result in daylight entering these properties. It is also noted that, whilst the proposed development is the factor that causes this reduction, the articulation of many of these proper ties is a factor that determines existing low levels of light received by some of these units. In particular this is the case within Markstone and Blazeley Houses where the overhanging roofs and projecting balconies reduce the level of light received.

170 Blazeley House also currently benefits from outlook over unusually low scale buildings at close proximity being within the development site. As such, the windows in this building obtain a disproportionally high level of unimpeded daylight in the existi ng situation. 171 All of the dwellings within Blazeley and Markstone Houses are dual aspect receiving light from more than one source. Therefore whilst the impacts on some rooms within these properties are regrettable, they could be considered less signi ficant in the context of the overall development.

172 With regard to the remaining properties tested there will be only minor adverse impacts experienced by Blocks C, R and S Peabody Square and E&C Early Years 2nd Block, whilst Block T Peabody Square and 42 Davidge Street will retain good levels of daylight.

173 It is acknowledged that any degree of redevelopment of the application site is likely to result in the loss of light to some of the surrounding residential properties which currently benefit from an underdeveloped adjacent piece of land. In the context of this highly urbanised situation achieving the recommended BRE standards is always likely to be a challenge and therefore some degree of flexibility is required when considering whether impact is acceptable.

174 Notwithstanding this however it should be acknowledged that there will be a marked loss of daylight to residential properties within Blocks A&B Peabody Square, Blazeley and Markstone House and the E&C Early Housing Block, and that this is a direct result of the scale, massing and positioning of the proposed buildings.

Sunlight Impacts 175 The impact of the scheme on sunlight to neighbouring properties has been assessed using the Annual Probable Sunlight Hours (APSH) test. The test follows the same methodology that is outlined above for VSC, with guidance advising that if a reduction in sunlight is 20% or less of its original value then the retained sunlight received is adequate. Only rooms with windows facing within 90 degrees of due south are assessed. The orientati on of neighbouring buildings means that this assessment relates to a smaller number of properties than the daylight assessment.

176 A table of those properties tested and results can be seen below:

Property No. No. of rooms No. of rooms Percentage of rooms achieving dropping rooms assessed recommended below dropping below BRE levels recommended recommended BRE levels BRE levels

McLaren House 102 64 38 37% Block T Peabody 8 4 4 50% Square Block S Peabody 10 5 5 50% Square Block R Peabody 8 5 3 62.5% Square Tadworth House 41 23 18 44% Markstone House 89 30 59 66% Blazeley House 92 7 85 92% 42 Davidge 6 6 0 0 Street E&C Early 6 6 0 0 Housing 2 nd Block, Library Street

Property No. No. of rooms No. of rooms Percentage of rooms achieving dropping rooms assessed recommended below dropping below BRE levels recommended recommended BRE levels BRE levels

E&C Early 27 3 24 89% Housing, Library Street

177 Within Blocks S and T Peabody Square, 6 of those rooms tested would receive a 100% reduction in winter sunlight levels. Meaning that at no point in the day would they now receive direct sunlight during the winter.

178 This marked reduction in sunlight levels is seen across the surrounding properties, with those in Peabody Square, Markstone House, Blazeley House and the Elephant and Castle Early Housing particularly affected. This has resulted from a combination of the close pr oximity of some blocks to adjacent existing properties, but also from the transient overshadowing experienced as a result of the tower element. This is discussed further below.

Transient Overshadowing 179 Modelling has been undertaken to show the posi tion and movement of temporary shadows that are created at different times of the day and year (transient overshadowing) as a result of the proposed tower element of the development. Due to the slim form of the tower, the shadow produced is also slim in n ature and will move throughout the day, thereby never leaving an area in shade for a significant amount of time.

180 However the closer you get to the tower the longer this transient shadow takes to move. This has resulted in many of the adjacent properties on the opposite side of Blackfriars Road seeing a marked reduction in sunlight and this can be seen i n particular within Peabody Square.

181 During the early morning these properties will be in shadow cast from the lower Blocks A, B and C, as would be expected in any form of development which was to follow established building heights along Blackfriars Road. As these shadows then move away allowing light to penetrate onto Blackfriars Road, the transient shadow from the tower then moves across the face of those effected buildings, meaning that all morning sunlight i s removed from the rooms of those dwellings. By the time the transient shadow moves the potential for receiving any sunlight has been lost.

182 A similar situation is then experienced to the east of the development site with the towers transient shadow blocking early afternoon light. By the time the towers shadow moves the shadow created by the lower blocks then moves across casting the majority of the west face of Blazeley and Markstone Houses in shadow.

183 The impact of the development in terms of transient overshadowing in a wider context is considered to be minor in nature due to the quick moving nature of the shadow cast. However its impact on properties in close proximity is marked and it should be noted that it is these dwellings which will al so experience a reduction in daylight as examined above.

Overshadowing 184 Neighbouring amenity areas have been assessed to establish the extent to which overshadowing will occur as a result of the proposed development. This has included the amenity areas for Peabody Square, the amenity area between Blazeley House and Markstone House; and the amenity area behind the Duke of Clarence.

185 The BRE Guidelines suggests that on the 21 st March, at least 50% of an existing amenity area should receive at least two hours of sunlight or retain 0.8 times (20%) its former valu e. If these guidelines are not met than the loss of sunlight is likely to be noticeable.

186 The assessments undertaken have demonstrated that all of the tested amenity areas will be BRE compliant, with at least 50% of the area receiving at least two ho urs of sunlight on the 21 st March. The impact to existing amenity areas surrounding the site are therefore considered to be negligible.

Noise and Vibration 187 The ES assesses the likely significant noise and vibration impacts of the de velopment. Noise surveys have been carried out to establish the baseline noise environment across the site and to determine background noise levels at nearby sensitive receptors. An Acoustic Report Addendum was submitted during the course of the applicatio n to take account of comments raised by the council’s Environmental Protection Team who requested noise monitoring to be undertaken to the east of Erlang House on Library Street to take account of potential noise bleed from both Blackfriars Road and Borough Road. It was agreed with officers that additional noise monitoring at the rail depot site to the south-west of St. George’s Circus was not required.

188 The survey results show that road traffic on Blackfriars Road and Borough Road was the dominant noise source. There was no reported evidence of ambient vibration due to road traffic or other sources.

189 The ES anticipates demolition and construction works would take approxima tely 3.5 years and be built in phases. The ES identifies the potential for nearby receptors to experience moderate to major adverse noise and vibration impacts during the demolition and construction phase of the development. Mitigation in the form of a Con struction Environmental Management Plan will be required to reduce impacts and this will need to be approved by the LPA (in consultation with TfL) prior to works commencing on site. With mitigation in place, the residual impact would be reduced to minor or negligible impacts at surrounding receptors, with the exception of receptors closest to the development site (specifically existing residents of Muro Court, Bazeley Court, NHS Medical Building, and new residents of the development given that it would be b uilt on a phased basis) where moderate adverse impacts are predicted. These impacts would relate to specific periods during the construction process and therefore are short-term and temporary in nature. This is considered acceptable in order to enable development.

190 Once operational, there are no residual adverse impacts pr edicted in relation to noise and vibration. Plant associated with the development will be conditioned to ensure adequate insulation that will prevent noise breakout. Conditions are also recommended to ensure that internal ambient noise levels within the pr oposed development will meet the council's standards so there would long-term residual impacts from road traffic noise for future residents would be negligible. Hours of servicing the commercial / retail elements of the scheme would be restricted to protec t the amenities of neighbouring existing residents as well as future occupiers of the development.

Impact of adjoining and nearby uses on occupiers and users of proposed development

191 The proposed uses are compatible with those already existing in the locality. There are no uses in the area that would adversely impact future occupiers of the development, the character of which is entirely in keeping with existing uses in the area.

Transport issues

192 Core Strategy Strategic Policy 2 encour ages walking, cycling and the use of public transport rather than travel by car. Saved Policy 5.1 of the Southwark Plan states that major developments generating a significant number of trips should be located near transport nodes. Saved Policy 5.2 advises that planning permission will be granted for development unless there is an adverse impact on transport networks; and/or adequate provision has not been made for servicing, circulation and access; and /or consideration has not been given to impacts of the development on the bus priority network and the Transport for London (TfL) road network.

193 An assessment of the likely significant environmental impacts of the development on transport is included within the ES. A Framework Travel Plan and S ervice Management Plan have also been submitted. A Technical Transport Note (P750-019) Addendum was submitted during the course of the application to address comments raised by the GLA in the Stage I Report and from Southwark’s Transport Planning Team.

194 The application site has excellent levels of public transport accessibility which is reflected in the PTAL rating of 6b which is the highest possible level. Blackfriars Road forms part of the Transport for London Road Network (TLRN) where Transport for London (TfL) is the Highway Authority.

195 A number of local concerns have been raised in respect of transport matters. The concerns relate to increased traffic flows; excessive car parking; servicing and access on Bl ackfriars Road will cause problems for safety of pedestrians and cyclists and disruption to buses; and bins storage on Library Street is un-neighbourly.

Vehicle trip movements 196 The existing buildings on site were formerly used for offi ce purposes. The site is largely vacant but could be brought back into office use without the need for planning permission. The ES has therefore taken the baseline condition to be the existing buildings at their potential capacity (i.e. using current offic e floor space) to predict trip generation. The ES estimates that the development is likely to result in a net increase of 7 two-way vehicle movements in the AM peak and a reduction of 9 two-way movements in the PM peak when compared with the existing offic e use. The ES concludes that the resultant additional trips can be readily accommodated by the local transport network and therefore the residual impact on the highway network is negligible.

197 Officers are satisfied with the assessment undertaken and agree that there is unlikely to be any material impact on the highway in terms trip generation. Officers further note that the existing site has capacity for approximately 60 vehicles within a car p ark accessed from Library Street. The proposed development includes basement car parking for 79 vehicles. The proposed uplift of 19 vehicles would have a negligible impact on the highway network.

198 In addition, £1,697,216 has been secure d as a strategic transport contribution to increase the capacity of transport provision in the borough. As noted earlier, the site straddles two opportunity areas with the southern portion of the site (approximately 46% of site area) within the Elephant an d Castle OA. For major schemes within the Elephant and Castle, the S106 standard charge for strategic transport contributions is replaced with a strategic transport tariff to contribute towards the Elephant and Castle northern roundabout improvement and No rthern Line ticket hall expansions projects. In accordance with the charges set out in the Elephant and Castle SPD, £1,593,592 has been secured based on the proportion of the site within the Elephant and Castle OA and a further S106 strategic transport su m of £103,624 (S106 standard charge) is secured in respect of the remaining part of the site to be put towards enhancement of transport provision elsewhere in the borough.

199 London Underground (LU) advise that the site is situated close to undergroun d tunnels and infrastructure and therefore a condition is recommended to secure further details of foundations and basements to ensure there will be no impact on existing LU infrastructure.

Impacts on the bus network 200 The development will result in an increase in the population in the area, which in turn will increase the number of journeys undertaken on the local bus routes. The Transport Assessment (included within the ES) and Technical Note Addendum conclude that add itional bus services will not be required to mitigate demand from the development. However, TfL consider that additional public transport capacity will be required and that the additional demand from the development will have a cumulative impact on the sur rounding network. In particular, bus routes 45 and 63 that directly serve the development are already close to capacity and new trips generated by the development will push peak hour bus usage over capacity. TfL have requested a contribution of £75,000 per annum over 5 years (total £375,000) to fund an additional service to be provided on one of these routes in the AM peak.

201 The applicant considers that this sum is not proportionate or justifiable given the predicted low impact of the development onto existing services. Instead, £176,250 is offered based on a predicted level of bus impact to be approximately 47% of that identified by TfL. The agreed monies, and mechanism and triggers for payment will need to be secured through the S106 legal agreement. Discussions on this matter are on-going and it is anticipated that the final contribution will be confirmed in time for Planning Committee.

Pedestrian and cycle movements 202 Blackfriars Road is a busy cyclist route to and from the City . As part of TfL’s Blackfriars Road urban realm improvement project, a segregated two-way north-south cycle route is planned adjacent to the northbound carriageway which would ultimately form a new Cycle Superhighway (CSH) connecting Elephant and Castle with Kings Cross. Associated improvements to pedestrian crossings and public realm are planned which will return Blackfriars Road into an attractive boulevard. TfL advise that works on the Blackfriars Road project is d ue to commence Spring 2015. The proposed development will therefore benefit from the planned improved cycle facilities and enhanced public realm.

203 As part of this development proposal, it is proposed to re-surface and landscape the footways outside of the proposed development, along Blackfriars Road and Library Street. TfL have requested (by letter dated 6 November 2014) the upgrade of an existing bus shelter outside the site as part of the works along Blackfriars Road. The applicant does not agree to this as existing bus stops will be relocated as part of the wider regeneration of Blackfriars Road. This matter has yet to be resolved and Members will be updated at Planning Committee.

204 TfL further wish to secure the option for funding to be paid to them to complete the enhancement works outside the site in the event that the TfL project works coincides with the build out of the development. As yet an ap propriate level of funding has not been agreed between the applicant and TfL but the final agreed sum will need to be included in the S106 legal agreement. 205 TfL also request a condition to prevent occupation of the development until the adjacent footwa y works are complete, however the applicant is unwilling to accept such a condition due to the phased nature of construction. The applicant advises that the resurfacing works will be completed at the same time as each building phase and therefore a signifi cant proportion of the development, including associated resurfacing, would be complete and unable to be occupied until the entire development was constructed, which is anticipated to be late 2018. Alternatively, the applicant suggests an appropriately wor ded condition to allow occupation once the adjacent highway works to each phase is complete. Officers consider this to be an acceptable approach as it would still ensure that the relevant public realm works are complete prior to occupation of each block.

206 The proposed development will not remove land from the Blackfriars Road footway, other than to provide an inset loading bay. Footway widths adjacent to the site are very wide and, even with the loading bay, the footways would retain suffi cient width (circa. 4m as it passes the bay) to deliver a ‘boulevard feel’ to the road. The proposed loading bay will need to be constructed to accord with TfL’s public realm improvements and should provide a flush surface with the footway so that it can e asily accommodate pedestrians when not being used for servicing. As TfL are the Highway Authority for Blackfriars Road and St. George’s Circus any modification to the footway and/or street furniture needs to be agreed with them via a S278 Agreement.

207 The proposal also shows the widening of the western footway on Library Street and the introductio n of an inset loading bay. To accommodate this, the applicant will need to dedicate some land to Southwark Highway Authority as public highway. The palette of materials to be used for the re-surfacing works need to accord with the council’s specifications.

208 Immediately adjacent to the site on Library Street there are 6 pay-and-display bays outside the proposed development on the western side of Library Street. It is proposed to relocate these bays to the eastern side of the r oad to facilitate servicing of the development from Library Street. Highway officers have raised no in principle objections to this, providing that this doesn’t lead to the loss of on-street parking bays. The applicant will need to enter into a S278 Agreement with Southwark Highway Authority for the works on Library Street.

Cycle docking station 209 A request was originally made in the GLA Stage I Report to secure obligations towards site identification and funding of a n additional cycle hire docking station (with a minimum of 30 docking points) either on or in the vicinity of the site. TfL has since amended their position, and now request £100,000 to be secured to extend the existing docking station on Webb er Street by a further 14 docking points. An additional £30,000 would also be required for traffic management costs associated with the closure of Webber Street. The applicant has agreed to the requested £100,000 contribution towards cycle hir e expansion but does not agree to the capped £30,000 for the Webber Street closure. Members will be updated of further progress on this matter at Planning Committee.

Access 210 Pedestrian access to the development is at ground level from a number of building cores. Officers note that a number of doors to the ground floor commercial units open outwards onto public highway and obstruct pedestrian movement. All doors on the ground floor should open inwards. A condition is recommended to ensu re that no door opens out onto public space.

211 Vehicular and cycle access to the basement car park would be from Blackfriars Road, utilising the existing crossover. The access point would lead to an internal ramp that at the entrance is j ust wide enough for cars to pass but then reduces to one car width. A one-way traffic light system would be in operation to hold vehicles whilst another is using the one-way length of the ramp. A dedicated cycle path and signal system will be installed for cyclists to enter/exit the basement which will ensure that cyclists will travel independently and not with vehicles to ensure there is no conflict between users.

Car parking 212 The original submission proposed 79 parking spaces in the basement. This has since been revised to 77 parking spaces as two spaces are now dedicated for small deliveries and maintenance vehicles. The 77 parking spaces equate to a car parking ratio of 0.23 spaces per residential unit. Of the 77 spaces, 34 are proposed to be blue badge spaces. No car parking is proposed for the retail or commercial uses which is welcome.

213 Since the site is within the CAZ and its high PTAL rating the development would normally be expected to be ‘car-free’ (aside from blue badge spaces) in accordance with Saved Policy 5.6 of the Southwark Plan. A number of objections have been received stating that the level of on-site car parking is excessive.

214 The applicant justi fies the additional car parking by reasons of viability and meeting expected demand from residents. Furthermore, that the level proposed is consistent with that granted on other schemes in equally accessible locations. The 43 general spaces are proposed to be made available for the private units within the development.

215 Officers acknowledge that the level of parking is broadly consistent with o ther consented schemes in the vicinity but, given that each application is assessed on its own merits, the extent of general needs parking fails to accord with policy 5.6. It has however been adequately demonstrated that the amount of parking would not hav e an adverse impact on the local highway network. As such, officers consider a reason for refusal on this basis could not be substantiated and on balance the proposed level of parking is acceptable. The car parking should be prioritised for the larger 3-be droom family units. 20% of the car parking spaces will be provided with electric vehicle charging points (ECVP) with 80% passive provision. This level of ECVP provision is considered acceptable.

216 A Car Parking Management Plan (CMP) has been requeste d by TfL which details how the standard, ECVP, and disabled parking will be allocated and managed. Officers strongly advise that the general needs car parking should be prioritised for the larger 3-bedroom family units. The CMP will be secured by legal agr eement, and include a mechanism for monitoring and review of provision.

217 There are three car club bays (with provision for four cars) located within a 10 minute walk of the site, on Keyworth Street, Pocock Street, and Offord Street. The applicant ha s agreed to provide three years’ free car club membership for the first occupants of each residential unit to discourage car use which is welcome. Car club obligations will be secured by legal agreement.

218 A condition will be required on any grant of permission to ensure that future residents within the development (aside from blue badge holders) are excluded from eligibility for on-street parking permits within the CPZ.

Cycle parking 219 662 residential cycle spaces are proposed at basement level made up of semi-vertical cycle racks which exceeds the minimum amount of required parking. At ground floor level, 38 dedicated cycle parking spaces will be provided for the office and retail elements within secured and covered spaces. A further 8 residen tial visitor spaces and 47 retail/commercial visitor spaces will also be provided at various locations across the site. All the cycle parking at grade will be in the form of Sheffield stands. The overall level of cycle parking provision (total 755 spa ces) is considered acceptable.

220 Transport officers have however raised a concern that a number of the cycle stores appear difficult to access, the routes being rather convoluted, and requiring up to four doors to be opened before reaching a store. It would be preferable for a more direct and simplified route to be provided to access the basement stores (including possibility of utilising the lifts to the basement). Final details of the access arrangements, including dimension of lifts, to the internal basement storage areas should be reserved by condition.

221 A shower and changing facility is proposed for the Class B1 commercial element of the scheme. It is a concern that provision could not have been extended to include the retail element in order to f urther encourage the use of cycling as a sustainable means of travel.

Refuse and servicing

Residential deliveries 222 Deliveries to the residential units would take place on-street from the proposed inset loading bays at Blackfriars Road and Library Street. It was originally proposed that longer dwell vehicles (such as residential / commercial removals, site maintenance/repair vehicles), could cross the footway on Blackfriars Road and access the s ite Between Blocks A and B1. Officers were concerned that this could result in an unsafe environment for pedestrians. Accordingly, the servicing strategy has been revised so that servicing would just take place from the two loading bays. Maintenance and sm aller deliveries can access the basement car park where two parking spaces have now been allocated for such vehicles.

Residential refuse collection 223 There are seven internal refuse stores distributed across the site to serve the uses within each o f the blocks. Two external ‘holding areas’ are proposed at ground floor level within the demise of the site. ‘Holding Area 1’ is located to the north part of the site between Blocks A and B1, ‘Holding Area 2’ is located to the east of Block C, adjacent to Library Street. An on-site management strategy would be in place for the collection of residential refuse whereby bins from the internal refuse stores would be taken to the holdings areas on collection day. The location of these holding areas will ensure that the council’s standard of a maximum 10m ‘drag distance’ between refuse vehicle and collection point can be achieved.

224 Highway officers have raised a concern about the bin holding area proposed on Library Street , in that it would have a negative impact on the public realm and would render the footway unusable by pedestrians on bin collection days. The Technical Note Addendum confirms that the holding area is within the application site redline boundary, so the ex isting public highway would not be reduced. Alternative locations have been considered but when considering impact on the new public square (‘ Library Square’) and distances to the loading bays it has not been possible to relocate the holding area.

225 The size of the holding area has however been reduced from circa 22 bins to 11 bins with the other 11 bins relocated to Holding Area 1 served from Blackfriars Road. A minimum footway width of 3.2m would be maintained when the holding area is bei ng used. The waiting times for the refuse vehicles on Library Street would also be reduced by as a result of the smaller holding area. 226 Officers do not normally favourably consider external bin collection points and that bins should be collected from i nternal storage areas wherever possible. However, in this instance, none of the bin storage areas would meet the maximum 10m drag distance. Furthermore, the location of the bin stores has to be balanced with the need to provide active uses along the principal frontages, including flanking Library Square. Public realm improvements are proposed to Library Street including new street tree planting which will represent an overall improvement to the streetscape. On balance, this aspect of the scheme is considered acceptable.

Retail / office deliveries and refuse collection 227 Servicing for the retail units would take place principally from the loading bay on Blackfriars Road, with smaller deliveries from the Library Street loading bay. The majority of deliveries for the office element would be undertaken from Library Street, with larger deliveries from Blackfriars Road. Refuse collection for the office and retail element would be undertaken by a private contractor.

228 Officers are satisfied that the delivery and servicing arrangements are acceptable, subject to a final SMP being submitted for approval, in consultation with TfL who wish to ensure that delivery times (particular ly refuse collection) do not adversely impact the TLRN.

Travel Plan 229 The submitted Framework Travel Plan is considered to be of good quality. A final Travel Plan covering each element of the scheme will be required. This should include a commitmen t for monitoring of targets at 1, 3 and 5 years post first occupation. Commitment to update the Travel Plan following each survey, and commitment to measures identified in the Travel Plan should also be provided.

Demolition and construction impacts 230 A Construction Environmental Management Plan will be in place to minimise the impacts associated with construction traffic. The plan will include vehicle access, timing of movements and traffic routeing to ensure impacts on the highway are minimised as fa r as possible. All associated impacts would be short term and temporary in nature.

Conclusion on transport matters 231 In summary, the proposed development is considered acceptable in terms of transport matters. However, there are a number of issues th at have not been agreed with TfL which will need to be resolved prior to determination of the application.

Design issues, including impact on townscape views and heritage assets

Policy context 232 The NPPF stresses the importance of good design and states in Paragraph 56 that “Good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making better places for people.”

233 Chapter 7 of the London Plan deals with design related matters. In particular, Policy 7.1 sets out the design principles required for new development and Policy 7.6 requires that architecture should make a positive contribution to the public realm, streetscape and cityscape. Policy 7.8 asserts that development affecting heritage assets and their settings should conserve their significance by being sympathetic in their form, scale, materials and architectural detail.

234 The relevant Southwa rk design and conservation policies include Strategic Policy 12 of the Core Strategy and Saved Policies 3.12, 3.13, 3.16, 3.18 and 3.20 of the Southwark Plan. These policies require the highest possible standards of design for buildings and public spaces. The principles of good urban design must be taken into account in all developments, including height, scale and massing of buildings, consideration of the local context, including historic environment, its character, and townscape strategic and local views.

235 A large number of design related local objections have been raised in respect of the proposed development, including the height of the tower. This includes representations from local residents’ groups, including The Albert Association, The St. George’s Circus Group and The Georgian Group. The principal concerns are:

− the proposal is contrary to the requirements of London Plan and Southwark tall building policies; and − the proposal will have a harmful impact on the setting of St. Geor ge’s Circus Conservation Area and nearby listed buildings.

236 Officers note that the City of Westminster and Lambeth Council have raised no objections to the proposed development.

Loss of existing buildings 237 The proposed buildings on site are of poor quality and make a limited contribution to local townscape interest. Local representations received are generally supportive of the principle of redeveloping the site and consider the regeneration of the southern end of Blackfriars Road to be long overdue. The council’s Conservation Area Advisory Panel (CAAG) has however raised a concern about the loss of Erlang House, which the Panel consider to be a “fine 1960s building”. Whilst this concern is noted , Erlang House is not a designated listed building and is not considered to be a positive contributor to the conservation area. Its loss, from a design perspective, is not resisted.

Immediate site context 238 The southern portion of the site directly adjoins St. George’s Circus, a historically important example of Georgian planning at the core of the St. George’s Conservation Area. Its historical significance results primarily from the layout of the roads surrounding the Obelisk at the cen tre of the Circus and the curved facade of the Duke of Clarence former public house, the only original building remaining in the composition. As noted earlier, this building has recently been converted into the LSBU Enterprise Centre. The vision of the Bla ckfriars Road SPD identifies an aspiration for St. George’s Circus to be marked as an active node:

“There will be a range of building heights along Blackfriars Road, with the tallest buildings at the north end of the road, signifying the gateway to Central London and the gateway to Southwark. There will also be taller buildings at the important locations of Southwark tube station and at the southern end of Blackfriars Road towards St. George’s Circus. Development will be of exceptional design and will enhance the local character, sustaining and enhancing the historic environment.” (Pg. 9)

239 The Grade II* listed Obelisk at the centre of the Circus was originally erected here in 1771 to form a landmark and visual focus for travellers approaching from all directions. Although it was subsequently removed, it was returned to the Circus in 1998. At the centre of a busy traffic island, its setting is currently isolated and hostile, but the redevelopment of the application site and regeneration of the wider Blackfriars Road area present opportunities to address and improve accessibility.

240 The Duke of Clarence former public house remains in place, forming the eastern enclosure of the Circus. The rail depot building of circa. 1908, with its two storey brick frontage, forms the southern enclosure of the Circus at No. 1 Lond on Road. This is considered to be a key unlisted building, identified as contributing positively to the St. George’s Circus Conservation Area. The redevelopment of the application site presents the opportunity to complete the enclosure of the Circ us, thereby enhancing the conservation area.

Site layout 241 The proposed site layout responds positively to the specific opportunities and constraints presented by the existing urban grain and development patterns in the area. In particular, officers welcome the proposal to reinstate the north-eastern quadrant of St. George’s Circus with the concave elevation proposed for Block C. The form of this building is considered to be in keeping with the original 1809 design of the Circus and to respond well to its Grade II listed neighbour, the Duke of Clarence former public house.

242 The proposed layout would also reinforce the significance of Blackfriars Road and contribute to its reinstatement as the “handsome avenue” originally envisaged by its Georgian designers. This would be achieved by the a lignment of Blocks A, B1, B2 (Tower) and C fronting onto Blackfriars Road, together creating a consistent urban enclosure along the southern portion of the road.

243 In accordance with the Blackfriars Road SPD, the tower element (Block B2) would not be located on the Circus itself, as this would detract from the historical significance of this urban set piece. Rather it would be sited some distance to the north, marking the ‘start’ of Blackfriars Road.

244 Towards the eastern boundary of the site, the proposal responds more appropriately to the finer urban grain and more local character of the existing buildings and streets. As detailed below, the height scale and massing of the buildings (Block B3/4) in this part of the site would be reduced, and a new north-south link, ‘Blackfriars Mews’, connecting Blackfriars Road with Library Street would be created. As a response to the urban conditions of the site and surroundings, this is considered appropriate.

245 The site layout will enhance the setting of the Grade II* listed Obelisk and the St George’s Circus conservation area. It would also contribute to the enclosure of the Circus as an urban event, reinforcing its sense of place. It complements its hi storic setting preserving and enhancing the architectural and historic significance of the listed building and its setting and preserving and enhancing the character and appearance of the conservation area and its setting. This is something that Erlang Hou se fails to do given that it is so far set back from the Circus and of an incongruous form.

Townscape and active frontages 246 As a general approach to the site, it is proposed to introduce a “mixed urban plinth” around the base of each building. Archi tecturally this would be differentiated from the residential architecture above, which would create a sense of human scale from the perspective of the pedestrian, as well as ground the buildings and define the non- residential uses. Opportunities for “spill-out” external seating have also been explored which would further contribute to the activity and animation of the street frontages. It would however be important to restrict the spill out spaces to those areas where the footway / public realm is sufficiently generous.

247 A strong combination of residential lobbies and commercial uses is proposed along the main road frontages. This contrasts with other schemes where residential entrances are often tucked away from the main routes and would result in vibrancy and activity at various times of the day along these primary routes.

248 In contrast, the dedicated B1 office uses would be positioned at the quieter eastern side of the site either fronting onto the internal co urtyard or new Blackfriars Mews. This cluster arrangement has been proposed in order to foster a sense of community amongst the SME occupiers. Although this approach has some merit, these units could suffer from the lack of a clear or prominent commercial address. This arrangement would also mean that the SMEs wouldn’t necessarily benefit from the footfall generated by the retail units on the main routes to the west and south. As noted earlier, there are units within the scheme located along the main fronta ges which could be taken up for either Class B1 office or Class A retail uses depending on demand. Officers consider it preferable for at least some of these spaces to be utilised as office space wherever possible in order to extend the Class B1 employment offer and give it some prominence.

Height, scale and massing across the development 249 Under SPD 5 (Building Heights) of the Blackfriars Road SPD, it is stated that:

“We will ensure development contributes positively and helps to regenerate and transform Blackfriars Road by requiring development to be of an appropriate scale of height and by encouraging tall buildings at the key gateways and junctions. Development should reinforce the civic character of Blackfriars Road... Generally the heights will be taller along the main routes, with appropriate heights of up to 30 metres, depending on the local context. Heights off of the main routes will generally be lower.”

250 Two of the three existing buildings on the site (Hill House and Erlang House) are over 30m in height (being 34m and 30.4m respectively). As such, they establish a significant sense of mass on the site, not just as a consequence of their height but also their large footprints and commercial floor to ceiling heights.

251 In line with SPD 5 (Building Heights) of the SPD, which suggests “buildings of up to 30m along Blackfriars Road between Southwark tube station and St. George’s Circus”, the proposed buildings fronting onto Blackfriars Road would be up to 10 storeys in height. Towards the northern end of the site, the buildings would have a consistent datum line expressed at 9 storeys. This would create th e top of Block A (with the exception of rooftop plant) and form a shoulder on the adjacent building, Block B1, above which there would be one additional storey of accommodation set back approximately 1m from the street edge. Whilst this is not a particular ly large setback, it would break up the mass of Block B1 and ensure consistency with Block A. Although much of the tower element (Block B2) of the scheme would be brought to ground, along the Blackfriars Road frontage it too would appear to emerge out of a 9- storey shoulder height, thus continuing the consistent urban enclosure along this section of the road. Given the generous width of Blackfriars Road, this would result in an enclosure ratio (height to width) of approximately 1:1 . This is considered appropriate for such an important urban thoroughfare.

252 The massing of the Blackfriars Road frontage would be broken down further by the articulation of a double height plinth or base to all of the buildings and the s imilar, but varied, elevations proposed for each block.

253 The southernmost element is Block C, one arm of which would also contribute to the enclosure of Blackfriars Road. This building would be 7 storeys in height with a set bac k top eighth storey. It would therefore be lower than the buildings to the north in recognition of the significance of the Circus and the original buildings that remain around its enclosure. As a result, the height scale and massing of this building is con sidered to be sympathetic to the historic context of the site whilst mediating between the various scales of the existing townscape and the other proposed new buildings on site. The top storey would be made up of a distinctive undulating form that would ‘c rown’ the building and celebrate it as an urban feature at an important node.

254 In response to the finer urban grain on the eastern side of the site, the building heights of Block 3/4 to the rear would reduce to 5 storeys. This is considered appropria te to respond to the height of the existing adjacent buildings along Library Street and Milcote Street as well as providing a suitable degree of enclosure to Blackfriars Mews, without over-enclosing it.

255 The Block B2 tower w ould comprise 25 residential floors above a double height base. It would have a roof terrace within the ‘crown’ proposed at the very top. The tower element of the scheme is discussed further below.

Architectural design and quality 256 The fabric propo sed for each of the buildings is of a very high quality, designed to ensure that each facade works at the urban building, and dwelling scale simultaneously. Each block would have a distinct material palette but there would be common elements across the sch eme to avoid visual disarray. The predominant facing material would be brick, of different tones and textures, enhanced by precast concrete elements, including lintels, cills, horizontal banding and copings to provide visual richness. The application of th ese facade materials across each of the buildings would create a balance between the vertical brick piers and the horizontal concrete banding.

257 The defining architectural reference for Blocks A, B1 and B2 (i.e. those that front onto and enclose Blackfriars Road) is the historic London warehouse; specifically the way in which these buildings used fine architectural detailing and variety of textures to elegantly break down their large mass and rational order.

258 Block A would be finished in bronze and green bricks. The Blackfriars Road elevation would be elaborately detailed with a white and green glazed brick base, toothed white glazed brick articulation around the window reveals, and decorative brick motifs o n the vertical brick piers. The sides and rear would be simpler, in response to the existing hierarchy of streets and spaces.

259 Block B1 would be finished in a mixture of gold and brown bricks with the B2 tower element and Blocks 3 / 4 (on the Library Street / Milcote Street) differentiated in mixed grey. The grey would give a calm frame to the new open space to the rear (the “Creative Courtyard”), whilst the brown and gold would contribute to the urban frontage along Blackfriars Road. Continuous piers of either white glazed or dark grey bricks and spandrel panels of faceted dark grey glazed brick would articulate the tower. Although all the tower elevations would be largely the same, the narrower southern and nort hern elevations would feature a concentration of white bricks to give a slight emphasis and enhance the presence of the tower on the skyline and celebrate the setting of the obelisk. The tower element of the scheme is discussed further below.

260 Block A and Blocks B1 and B2 (tower) would all include faceted brickwork which would create a common texture along Blackfriars Road and lift the visual interest of the scheme through the resultant changing light and shadows. In contrast, Blocks B3 and B4 behind would feature much simpler, crisp detailing and smooth brickwork.

261 Block C would present an appropriately formal, civic elevation to the Circus. It would be finished in sand and grey toned brick. The top storey would be set back and finished in white glazed brick to lighten its appearance. Similar to Blocks B1 and B2, Block C would also feature thin, precast concrete lintels over the windows which would be set back one b rick depth. Strong horizontal precast concrete banding is also proposed which, along with the framed windows, would echo the architecture of the Duke of Clarence as well as compliment the Georgian layout of the Circus.

262 The double height base of each building would be expressed by dark, smooth bricks at the lowest level which would create a robust, urban plinth with white glazed brick on the upper level which would lighten the pedestrian experience and provide clear definition. The balance between the two levels and the ways in which they are detailed would vary from block to block in order to create a familial expression but one that responds to the character of the rest of the building and its role in the masterplan. 263 White glazed brick would be used across each of the buildings to articulate the window openings and parapets. This would lighten the facades and soften the otherwise very rational and ordered window arrangements. No projecting balconies would be used along the formal, urban Blackfriars Road and St. George’s Circus elevations. Instead, enclosed winter gardens are proposed that would be expressed in the same manner as the other fenestration, thus maintaining the rational, consistent order of the street frontage an d creating an appropriate grandeur and civic presence. Winter gardens would also ensure that the amenities of these spaces would be protected from the heavily trafficked routes. Projecting balconies would be limited to the rear elevations and the buildings to the east of the site (Block3/4) which are intended to be less formal and more domestic in character. This is considered to be an appropriate response to the existing urban pattern.

264 Across all of the buildings, the window and doorframes would be a bronze coloured metal but a subtly different shade would be used for each building to match the varying tones and textures of the brickwork. Subtle visual enrichment of this nature is welcomed. Other metalwork across the scheme, including balustrades and ventilation grilles, would create a common pattern based on formal Georgian designs. This is acceptable in principle as an interesting way of celebrating the historic significance of the site and further lifting the appearance of the buildings. A conditio n requiring detailed drawings and a sample of the proposed metalwork and patterning should be imposed on any grant of permission to ensure that the proposed metalwork is of sufficient quality.

265 As described above, the building fabric and proposed arc hitectural detailing will be essential to the success and quality of the scheme. Officers consider these are matters that can be reserved by condition to ensure that the detailing, especially around openings and parapets, and the wall finishes are of the h ighest quality and that they retain the high quality visual richness proposed. The choice of facing materials is also important in this sensitive historic context, particularly on the Block B2 tower given its visibility and proximity to the Circus. A condi tion requiring material sample panels to be viewed on site and a 1:1 mock-up of the tower frontage will be required should planning permission be granted. The samples will need to show the chosen facing materials in relation to each other, for example the specific bronze tone for the window and doorframes shown with the relevant brick tone.

266 In summary, officers consider the building fabric and proposed architectural detailing to be of exceptionally high quality. It is therefore important that this is not lost as the project is taken forward. The varying tones and textures across the otherwise highly ordered and rational facades would ensure visual richness, whilst remaining calm and urban in character. The main urban elevations of Blackfriars Road and St. George’s Circus would be the most formal and detailed whereas the level of detail and variation would be toned down on the quieter eastern side of the site. As a result, officers con sider that the proposal would enhance the quality of the existing townscape in the area, and embody a creative, high quality design solution that is appropriate in its context and one that would enhance the historic environment.

Tall buildings 267 The Block B2 tower element of the development rises to 27 storeys (including double height ground floor) or 96.5m AOD. It would also have a roof terrace within a ‘crown’ proposed at the very top.

268 London Plan Policy 7.7 sets out the policy in relation t o location and design of tall buildings. This states, amongst other requirements, that tall and large buildings should generally be limited to sites in the CAZ, opportunity areas or town centres. It also states that tall and large buildings should not have an unacceptably harmful impact on their surroundings.

269 The site is located within all these defined areas and therefore can be considered to meet the broad locational criteria specified in the policy. The GLA Stage I report considers that the scheme satisfies the requirements of Policy 7.7 through the implementation of well-defined and high quality public realm, alongside a clear demonstration of a high quality of architecture, materiality and detailing. Furthermore, the height and massing strategy i s generally supported and raises no strategic issues. London Plan policy 7.7 says:

270 Tall and large buildings should: a generally be limited to sites in the Central Activity Zone, opportunity areas, areas of intensification or town centres that have good access to public transport b only be considered in areas whose character would not be affected adversely by the scale, mass or bulk of a tall or large building c relate well to the form, proportion, composition, scale and character of surrounding buildings, urban grain and public realm (including landscape features), particularly at street level; d individually or as a grou p, improve the legibility of an area, by emphasising a point of civic or visual significance where appropriate, and enhance the skyline and image of London e incorporate the highest standards of architecture and materials, including sustainable design and construction practices f have ground floor activities that provide a positive relationship to the surrounding streets g contribute to improving the permeability of the site and wider area, where possible h incorporate publicly accessible areas on the upper floors, where appropriate i make a significant contribution to local regeneration.

271 The proposal accords with this London Plan policy insofa r as it is located in the CAZ with good access to public transport; has been designed to complement its urban and historic context, avoiding any harm to heritage assets and their settings; significantly improves the streetscene and permeability of the St G eorge’s Circus area, the Blackfriars Road, and Library Street; introduces an appropriately designed ‘landmark’ at this confluence of important routes; is of exemplary quality of design; and will make a significant contribution to local regeneration.

272 In terms of local policy requirements, Strategic Policy 12 of the Core Strategy requires tall buildings to be of an exemplary standard of design and to make a positive contribution to regenerating areas and creating unique places. The policy identifies locations where tall buildings could go which are London Bridge, the northern end of Blackfriars Road, Elephant and Castle and action area cores. Supporting paragraphs 5.114 and 5.115 advise that these locations are the fo cus for tall buildings because in the wrong locations they can be overbearing and out of character. The Core Strategy identifies areas that are not very built up, do not have good public transport access, are covered by conservation areas or have other her itage asset implications as not appropriate for tall buildings.

273 Strategic Policy 12 also establishes that tall buildings need very good access to public transport to s upport high levels of occupation. In other areas tall buildings are not appropriate because they are not very built up, do not have good public transport access, would be harmful to conservation areas or have other heritage asset implications.

274 The a pplication site has excellent access to public transport, benefitting from a PTAL rating of 6b and to that extent is well placed to support high density living. Indeed, the CAZ and opportunity areas are considered to be growth areas where large-scale, higher density development will be prioritised to contribute towards London’s need for housing, commercial and other development. Notably, Saved Policy 3.20 of the Southwark Plan asserts that planning permission may be granted for buildings that are significantly taller than their surroundings, or have a significant impact on the skyline providing they are in highly accessible locations and are within the CAZ (particularly opportunity areas); the site’s location clearly accords with this aspect of the policy.

275 Officers acknowledge that the tower would be significantly taller than any other building in the vicinity (the other building of height in the area is the H10 Hotel at 14 storeys) but that in itself doesn’t necessarily mean it is inapprop riate, harmful or would look out of place. Again, the fact that part of the site is within a conservation area and close to a number of listed buildings doesn’t necessarily render the site unsuitable for tall buildings. Rather the NPPF requires the LPA to assess any harm that it may cause to the significance of these heritage assets and to weigh that against the public benefits of the proposal.

276 That the Core Strategy identifies locations in the borough where tall buildings could go doesn’ t preclude them being considered appropriate elsewhere. The policy merely highlights where tall buildings could go given their sustainable locations and that these areas already contain a number of taller buildings. All tall building proposals, irrespectiv e of whether they are within one of the suggested Core Strategy locations or not, must be assessed against a number of design-led criteria set out in Saved Policy 3.20 as well as other environmental considerations, such as overshadowing and impact on the micro-climate, in order to determine their acceptability.

277 An assessment of the proposal against Policy 3.20 design criteria is set out below. Environmental implications of the tower are dealt with elsewhere in the relevant sections of the report.

(i) Makes a positive contribution to the landscape 278 Contributions to landscape and the public realm are an important part of any propo sal for a tall building. Proposals should not only create an appropriately scaled setting for the tower, allowing the tower to ‘land’ appropriately, but also exploit the benefits that can arise from expanding vertically in this way, by freeing up more publ ic space at grade in dense urban locations.

279 The proposed layout would set the new urban blocks, including the tower, within a high quality, connected landscape scheme made up of the following three new spaces at grade:

− Library Square (987 sqm): a public square at the base of the tower with a new east-west connection through the site; − Creative Courtyard (521 sqm): a new amenity space enclosed by the business units in Block B3/B4 for occupiers of the development; − Blackfriars Mews (171 sqm): a ‘mews-style’ route through the development connecting Library Street and Blackfriars Road.

280 The treatment of the spaces varies according to their intended uses. Library Square would provide a new focal destination point for existing and future residents and visitors to sit and enjoy as well as pass through. Indicative plans show that it would include public benches integrated with new tree planting, climbing wall plants, a water feature built into the rear facade of Block C to address this space, and decorative lighting. It would also open up a generous space into which the tower would ‘land’. The Creative Courtyard and Blackfriars Mews would provide open spaces and circulation space for occupiers of the development and its visitors with residential lobbies and business unit entrances opening directly onto these spaces. Treatments would include high quality hard surfacing, raised planters which will also provide informal seating, and new tree planting.

281 The applicant considers that these three new spaces constitute new public realm offering residents, office workers and passers-by the opportunity to sit and relax. Officers agree that Library Square would offer a new public square and public route through the site connecting Library Street and Blackfriars Road. However, access to the Creative Courtyard and Blackfriars Mews would be restricted. They would therefore offer addi tional amenity and permeability for future residents and office workers of the development, but don’t constitute spaces that are publically accessible at all times. In principle, there is no objection to the provision of a mix of public, communal and priva te spaces on a site, on the understanding that each will be clearly defined and the transitions between them sensitively resolved. This balance between each needs to be agreed with the applicant and it is recommended that a condition requiring landscape la yout plans, including detail section drawings of boundary details and features should be imposed.

282 Moreover, they don’t create new pedestrian desire lines that would encourage public movement through the site, other than for users of the development Officers are of the opinion that these spaces would appear private for the development and should be treated as such.

283 Notwithstanding that officers haven’t yet reached agreement with the applicant on the extent of public realm that would be delivere d, collectively the three open spaces would create a high quality setting for the new buildings, including the tower, and the new public square would offer significant public benefits. They would also introduce a new east-west connection through the site, enhancing local connectivity and permeability. The new public spaces on the site are considered to make a welcome and substantial positive contribution to the landscape and public realm on the site, the quality of the local streetscape, and extent of ‘urba n greening’, particularly when compared with the impermeable, poor quality buildings and spaces in the existing condition.

284 In addition, public realm improvements, including resurfacing and associated landscaping, are proposed along the Blackfriars Road, St. George’s Circus and Library Street frontages. TfL is currently developing scheme to improve pedestrian crossings, the public realm, and cycle provision along Blackfriars Road. As such, the proposed works on the application site will make a welcome contribution to TfL’s Blackfriars Road project, further contributing to the public benefit of the proposals. Details of the works will need to be secured by legal agreement, including the applicant entering into a S278 Agreement with TfL as highway authority for Blackfriars Road.

(ii) Is located at a point of landmark significance 285 For the purposes of Policy 3.20, the Southwark Plan defines a ‘point of landmark significance’ as “where a number of important routes converge, where there is a concentration of activity and which is or will be the focus of views from several directions.” 286 SPD 5 of the Blackfriars Road SPD advises that:

“Tall buildings will be encouraged in important locations, where they reinforce the character and function of this main route into Central London. These landmarks will highlight the importance of Blackfriars Road as a gateway to Southwark and create new focal points at main transport junctions along Blackfriars Road to Elephant and Castle.”

287 The SPD advises a range of heights to be provided along Blackfriars Road, with the tallest at the northern end but also taller buildings at important locations at Southwark tube station and at St. George’s Circus (Para. 1.17). With specific reference to the application site, SPD 5 goes on to say:

“A tall building, of a height of up to 70 metres could provide a focal point at the southern end of Blackfriars Road. Tall buildings must be set back from the Circus and should sustain, enhance or better reveal heritage assets and their settings, particularly at St. George’s Circus Conservation Area and the Grade 2* listed obelisk.”

288 In accordance with the Policy 3.20 and the SPD, the siting of the tower is considered to be at a point of landmark significance, marking not just St. George’ s Circus (a key junction within Southwark, connecting a number of key arterial routes), but also the start of Blackfriars Road, a key route into Central London. This strategic node links Blackfriars Bridge, Lambeth Bridge, Westminster Bridge, London Bridge and Elephant and Castle and as a result the tower would become an urban marker at both district and city scale.

289 Furthermore, the tower would not be located on the Circus itself, but would be set back along Blackfriars Road in order to respect the sensitivity of the existing heritage assets.

290 It is noted that the tower proposed is approximately 97m in height (approxim ately 93m above street level) and therefore taller than the 70m advised in the Blackfriars Road SPD. However, when a tower of 70m in height was tested during the design process, it resulted in a building of uncomfortable proportions that did not allow for a slender expression but appeared rather squat. It was therefore agreed that, whilst the main bulk of the building could should to approximately 70m, a sculptural ‘crown’ should extend beyond this to stretch the perception of verticality and elegance. As a result, at approximately 70m above street level, the facades are set back and above this datum the architectural expression changes to introduce ‘pinnacles’. At the upper level, residential amenity spaces would be provided within the crown, including terr aces and a communal room. Not only does this allow residents to enjoy the views on offer from this height, but architecturally it allows the termination of the building to appear lighter as it meets the sky. The design of the ‘crown’ is discussed in further detail below.

291 Furthermore, it is also important to consider the way in which the height of this building would be perceived from street level, particularly along the primary route of Blackfriars Road. As described above, at street level along Blackfriars Road the tower would be read as emerging from a 9 storey base, creating consistency and coherence within the wider street scene and not allowing the tower to dominate the public realm. The tower would rise 19 storeys above this datum, including the 27 residential floors and upper level of residential amenity spaces.

(iii) Is of the highest architectural standard 292 As with the other buildings proposed for the application site, the quality of materials and detailed design proposed for the tower is of a very high standard. The tower has been designed with a hexagonal plan form, intended to ensure a slender tower and to reduce its visual impact from all viewing angles. This form also allows the tower to be aligned with Blackfriars Road whilst simultaneously addressing St. George’s Circus to the south and the new public space proposed to the east.

293 In contrast to other buildings proposed within the development, the tower would have an almost uniform architectural treatment to all of its facades. On initial view, officers were concerned that, as a result of the hexagonal plan form, such an approa ch may not allow for the most slender expression, particularly on the wider eastern and western facades. However, following discussion with the applicant’s design team, further detailed design has been worked up to emphasise the vertical proportions of the se elevations and subsequently alleviate officer’s concerns. This detail has been submitted for consideration as part of the Addendum package. In brief, the revised detail design introduces full brick width window reveals in white glazed brick running up t he height of the main body of the building. This nuanced and thoughtful consideration of the elevation would ensure a strong sense of verticality without losing the layered and textured approach to the elevations or the reading of the entire building as a uniform landmark. The proposed building is considered to be of the highest architectural standard.

(iv) Relates well to its surroundings, particularly at street level 294 The Tower has been designed in a manner that is clearly related to the architectu ral language and proposed townscape and massing of the Blackfriars Road elevation, yet has its own distinct character. A careful balance is proposed between the 9 storey shoulder height along Blackfriars Road (as described above), the tall element that emerges above it and the importance of ‘grounding’ the other elevations of the tower, particularly where it relates to the new ‘Library Square’.

295 As a result of this sensitive design approach, it is considered that the tower would both contribute to the enclosure of Blackfriars Road and also be perceived as a distinct landmark element defining the new public square at its base. The inclusion of large, open retail frontages and a concierge facility at th e base of the tower would ground the building within the square and help animate the pedestrian street environment along Blackfriars Road.

296 In compliance with the SPD, the Tower would not be located on the Circus itself, but set back along Blackfriars Road in order to respect the sensitivity of the existing heritage assets. As such, it relates very well to its surroundings, partic ularly at street level.

(v) Contributes positively to the London skyline as a whole consolidating a cluster w within that skyline or providing a key focus within views 297 The application site lies in the Wider Setting Consultation Area of the Protecte d Vista of the Palace of Westminster in Townscape View 23A.1 from the Serpentine Bridge in Hyde Park, as identified defined in the London View Management Framework (LVMF) SPG 2012 which relates to the management of important London views. The proposed deve lopment would also be potentially visible in a number of London Panoramas.

298 The potential impact on townscape and views has been considered in a Townscape, Visual and Built Heritage Assessment (TVBHA) which forms Volume II of the ES. This details the long-term impact of the proposed development on 21 viewing positions (agreed with the Local Planning Authority) as well as three views of London-wide significance. Two of the later are identified views in the London View Management Framework: Townscape Vi ew 23A from the Serpentine Bridge to Westminster; and Townscape View 27B Parliament Square to the Palace of Westminster. A further 11 unverified views were also tested to ensure that where it was predicted that the impact(s) of the proposal would be neglig ible, this was indeed the case. The proposal has also been considered in relation to its cumulative impact along with other tall buildings, including other significant consented development, on the London skyline

299 In order to ensure that the tower makes a positive contribution to the London skyline, the upper levels have been designed as a sculptural, well articulated feature. The tower top would feature a series of steps in its massing in order to reduce its profil e and provide a number of communal terraces for residents. On top of this would be a ‘crown’ made up of a series of white glazed brick ‘pinnacles’ which would extend directly from the vertical piers expressed throughout the main body of the building. This would create a distinctive and striking silhouette at the top of the building and provide enclosure at rooftop terrace level. This approach is welcomed as it would ensure that the silhouette of the tower contributes positively to the London skyline and it would enhance the vertical proportions of the design.

300 The views of city-wide importance assessed in the TVBHA, including those from the LVMF, show the proposal to have a minimal impact, very much subordinate to heritage assets including Hyde Park, th e Serpentine and the Palace of Westminster World Heritage Site.

301 During the course of the application, Historic Royal Palaces (HRP) sought confirmation that the proposed development would not be visible from the Tower of London World Heritage Site. An additional view looking south-west from within the Tower towards the development site was therefore submitted as part of the Addendum package which confirmed that the development would not be visible and as such there would be no impact on the setting of the World Heritage Site. HRP has advised they have no further comment.

302 In the 21 views of district wide significance, the proposal has a range of impacts varying from very minor to very significant. In many of the views, the high quality nature of the proposal would integrate well with the existing layered and highly articulated urban setting. The most significant impacts are described and assessed below.

303 From Borough Road, at the junction with Keyworth Street, the proposal is considered to represent an enhancement to the existing townscape and setting of the St George’s circus Conservation Area as Block C would redefine the western end of Borough Road providing a better sense of enclosure and responding more appropriately to the urban development patterns. The tower would have a major impact on this view, with the wider eastern elevation highly visible. As set out above, following co ncerns expressed by Officers during the course of this application that the wider elevations would benefit from a greater sense of verticality, the detailed design of the window reveals has been revised and a new approach submitted for consideration as par t of the Addendum package. The stronger sense of verticality that this would achieve would substantially benefit this view, resulting in a more slender expression.

304 From London Road, at the junction with Garden Road, the tower would be particularly visible. However, thanks to its hexagonal plan form, it is the narrower southern elevation that is visible from this position. This is a particularly successful elevation, in which the tower is expressed as a slender vertical landmark, and it will be enhanc ed even further by the enhancements required by condition to the design of the ‘crown’

305 The beneficial impact of the proposal on views from St. George’s Circus is demonstrated by the verified view from London Road at the junction with the Circus. From this point, Block C would clearly enhance the view, and therefore the setting of the conservation area and neighbouring listed buildings, by reinstating the north eastern quadrant of the Circus. The tower would be set back from the Circus, allowing the he ritage assets to retain the primary foreground focus of the view. It would be read as a high quality, slender urban landmark signifying the ‘start’ of Blackfriars Road. The views from Lambeth Road, between St. George’s Road and the Circus and Westminster B ridge Road at the junction with Waterloo Road also demonstrate this beneficial impact.

306 Similarly, the beneficial impacts of improving the Blackfriars Road frontage and sense of enclosure along this primary route are shown in the view taken from the junction with Webber Street looking towards the Circus. It is noted that the wider western elevation of the tower is visible from this point. As with the eastern elevation, this will benefit substantially from the enhanced detail design submitted as part o f the Addendum package. In view of the above, it is considered that the proposal contributes positively to the London skyline as a whole consolidating a cluster within that skyline or providing a key focus within views.

307 The GLA Stage I Report particularly noted that the tower remains subservient to the emerging cluster of taller buildings (up to 52 storeys) at the northern end of Blackfriars Road.

308 In summary, officers consider that the proposal meets the location criteria in terms of siting of a tall building and, as demonstrated above, it fully accords with the design-led requirements of Saved Policy 3.20.

CABE/English Heritage Guidance on Tall Buildings 309 The CABE and EH set out the criteria for tall buildings and state that: Applicants seeking planning permission for tall buildings should ensure therefore that the following criteria are fully addressed:

4.1.1 The relationship to context, including natural topography, scale, height, urban grain, streetscape and built form, open spaces, rivers and waterways, important views, prospects and panoramas, and the effect on the skyline.

310 The proposal has been considered by officers in its urban and historic context, its natural setting and topography as well the wider context of London as a world city and found to meet this requirement both in its contribution to the local and wider skyline and the way it meets the ground.

4.1.2 The effect on the historic context, including the need to ensure that the proposal will preserve and/or enhance historic buildings, sites, landscapes and skylines.

311 The impact of the proposal on local and wider historic assets i ncluding World heritage Sites, listed buildings, conservation areas, ancient scheduled monuments, registered parks and gardens and hidden archaeology has been considered in detail and found that it avoids any harm to the historic context.

4.1.3 The effect on world heritage sites.

312 The information submitted with the application demonstrates that proposal will not be visible from within or around the London’s World Heritage Sites at the Palace of Westminster and the Tower of London.

4.1.4 The relationship to transport infrastructure.

313 The proposal is located in a highly accessible location within Southwark close to two Underground Stations, and will contribute to the delivery of improvements to the local transport infrastructure.

4.1.5 The architectural quality of the building.

314 As outlined above, the architectural quality of the tall building is unquestioned by the council. It is considered to be of exemplary quality of design meeting and exceeding all the adopted design standards and making a substantial positive contribution to the immediate and wider historic setting.

4.1.6 The sustainable design and construction of the proposal.

315 Officers are satisfied that the proposed energy strategy adequately adheres to the Mayor’s Energy Hierarchy although the predicted carbon savings fall some way short of the minimum London Plan 40% carbon savings required.

4.1.7 The credibility of the design, both technically and financially.

316 The design has been prepared by a highly experienced architect’s practice and applicant with a solid track record in delivering world-class a rchitecture across the UK and in Southwark. The technical or financial credibility of the design is not questioned.

4.1.8 The contribution to public space and facilities, both internal and external. 4.1.9 The effect on the local environment. 4.1.10 The contribution made to the permeability of a site and the wider area.

317 The proposal includes a landscape scheme and extension of the public realm into and across the site introducing new permeability across the site and three new publicly accessible spaces which will offer residents, office workers and passers-by the opportunity to sit and relax. As outlined above this is considered to be a substantial contribution to the landscape.

318 The effect on the local environment has been tested by the applica nt and found to be acceptable. The council is satisfied that details of the treatment of the public spaces and the landscape can be reserved by condition and will enable the creation of a well designed environment and a usable public space.

4.1.11 The provision of a well-designed environment, both internal and external.

319 The standard of accommodation provided including the quality of the residential and public spaces is exemplary meeting and exceeding the council’s standards and will contribute posi tively to the quality of life of residents and visitors alike. Spaces are designed with function, fitness for purpose and amenity in mind and work well within an elegant design.

320 Accordingly, this proposal is considered to meet the criteria set out in the CABE / EH guidance on tall buildings

Impact on character and setting of a listed building and/or conservation area

321 A large number of representations have been received concerning the impact of the proposal on local heritage assets.

322 Paragraph 132 of the NPPF states that “when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be.” Paragraphs 133 – 135 further state that when a proposed development would result in harm to the significance of a designated heritage asset, this harm should be assessed as ‘substantial’ or ‘less than substantial’ and subsequently weighed against the public benefits of the proposal. 323 The southern portion of the site falls within the St. George’s Circus Conservation Area. Development on the site could also affect the setting of a number of other conservation areas, including King’s Bench, West Square, and Elliot’s Row.

324 There are no listed buildings on the development site itself but the proposal has the potential to impact upon a number of listed buildings in the area. Those closest to the application site include:

• The Obelisk at the centre of St. George’s Circus (Grade II*) • St. George the Martyr Library (Grade II) • The Duke of Clarence Public House – the only remaining original building element enclosing the Circus (Grade II) • Nos. 109-112 Borough Road – the former Presbyterian Chapel (Grade II) • Nos. 2-14 London Road (Grade II) • Nos. 113-119 Borough Road (Grade II) • Nos. 123-131 London Road (Grade II) • The Peabody Estate on Blackfriars Road • Roman Catholic cathedral of St George on Lambeth Road • Archbishop's House and Cathedral House at 150 St George's Road – junction with Westminster Bridge Road • 4-48 Gladstone Street • 3-11 Gladstone Street • 13-55 Gladstone Street • 2-18 Colnbrook Street • Colnbrook Street Schools • Former Church of St Jude on St George's Road

325 There are also a number of unlisted buildings that are identified in the St. George’s Circus Conservation Area as making a positive contribution to the surrounding townscape, including:

• Nos. 13-16 Borough Road • Baker Street and Waterloo Railway Depot • Nos 2-14 London Road.

326 The heritage significance of the St. George’s Circus Conservation Area is primarily generated by the Georgian design and layout of the circus itself and its relationship to the ‘handsome avenue’ of Blackfriars Road (as well as the other ‘arms’ that emanate from it, including Borough Road and London Road). The proposed scheme would enhance this significance by reinstating the curved facade of the north-eastern quadrant of the Circus, thus improving its enclosure and integrity as an urban event, and enhancing the setting of the Obelisk. The proposed architectural treatment of Block C would further contribute to this by paying due regard to the Geo rgian character of the circus and the setting of the Duke of Clarence pub whilst being clearly distinguishable as a contemporary intervention.

327 The heritage significance of Blackfriars Road in relation to the conservation area and its setting would be enhanced by the increased sense of enclosure and definition that the proposals would create along it, thus returning it to a ‘handsome avenue’. The tower would also contribute to this by creating a landmark presence at the ‘start’ of Blackfriars Road, without diluting the significance of the circus or detracting from its visual presence. The quality of the built fabric and architectural articulation p roposed also ensure that the new development would contribute beneficially to the setting of the conservation area.

328 The tower would sit just to the north of St. George’s Circus Conservation Area, set back from the Circus so as to not compromise the articulation of the curved facade and integrity of the Georgian layout. However, it would have a major impact on its setting as well as the setting of other nearby conservation areas. For example, the proposed development would be visible from the West Squ are Conservation Area, along Westminster Bridge Road and Lambeth Road and a number of other locations. That said, it is considered that the high quality nature of the proposals, including the tower, would not result in harm to these conservation areas, but it could indeed have beneficial impacts, particularly following the revised detailed design of the tower and the enhancements to the ‘crown’ to be required by condition.

329 The historic significance of the Grade II* listed Obelisk as a clearly visible landmark at the focal point of the Circus would be maintained by the proposed development, and indeed enhanced by the curved frontage of Block C. The relationship between the Obelisk and the Duke of Clarence Pub (the sole remaining original building on th e Circus) would also be maintained. The proposed B2 tower would be visible from the Obelisk and its setting, but it is not considered that it would be harmful to its heritage significance. As a landmark, the influence of the Obelisk is restricted to a loca l scale whereas the proposed tower would be a landmark at a district and even City-wide scale. It is therefore considered that the two could exist harmoniously as urban markers.

330 The Duke of Clarence Pub forms the eastern enclosure of the Circus. By r einstating the enclosure of the north-eastern quadrant, it is considered that Block C would enhance its setting. The proposed tower would be visible from the setting of the Duke of Clarence, but given its high architectural quality (particularly following revisions to detailed design and further enhancements to be required by condition) it is not considered that it would cause harm to its heritage significance.

331 The St George the Martyr Library is located to the south east of the application site. It is Grade II listed, designed in an Art Nouveau style in red brick and terracotta with a pitched, tiled roof. Its heritage significance is informed by its association with John Passmore Edwards (Victorian philanthropist) and its substantially intact elevat ions. It also has group value when considered together with the other buildings in the vicinity of St George’s Circus. Block C would be located immediately to the west of the library and would enhance its setting by repairing the continuity and definition of the western end of Borough Road and the St George’s Circus frontage. The tower would also be visible in relation to the library, but given the high architectural quality proposed it is not considered that it could cause harm to its heritage significance.

332 The setting of listed buildings on the other arms of the Circus, including Borough Road and London Road, would also be enhanced by the proposed reinstatement of the circus enclosure. The tower would be visible to various degrees but, as discussed above, given its high architectural quality and potential to act as an elegant vertical landmark, with the public benefit of a new open space at its base, it is not considered that it would cause harm to the heritage significance.

333 Officers therefore conclude that the scheme would have many beneficial impacts on the significance of St. George’s Circus Conservation Area and the setting of other surrounding conservation areas and listed buildings. Although the proposed tower woul d be a highly visible intervention from the settings of many of the surrounding heritage assets, it is important to note that visibility does not automatically equate to harm. As a result of the high quality architectural and urban design qualities of the proposals, it is indeed considered that the proposals would have a beneficial impact.

334 English Heritage (EH) has confirmed their support of the principle of redevelopment of the site, particularly noting the poor quality of the existing buildings whi ch detract from the setting of nearby listed buildings and St. George’s Circus Conservation Area. They consider the proposed principal building (Block C) fronting the north east quadrant of the Circus to be an appropriate response to the context of the ori ginal designated late C18 urban intervention that created the formal axis of Blackfriars Road. In addition, the new building is well designed and of the right scale, and will enhance the character and appearance of the conservation area.

335 English Her itage does however raise concerns over the B2 tower which would be in the immediate backdrop to the conservation area. They say that tall buildings, by their nature, can have far reaching impacts on the wider context and on the settings of designated herit age assets. In addition, the tall building dominates the setting of the Grade II listed St. George the Martyr Library (Borough Road). In their view, the proposal causes some (less than substantial) harm to the setting of nearby designated heritage assets a nd they have requested that the council weighs this harm against the public benefits of the proposal.

336 English Heritage does however raise concerns over the B2 tower which would be in the immediate backdrop to the conservation area. They say that ta ll buildings, by their nature, can have far reaching impacts on the wider context and on the settings of designated heritage assets. In addition, the tall building dominates the setting of the Grade II listed St. George the Martyr Library (Borough Road). I n their view, the proposal causes some (less than substantial) harm to the setting of nearby designated heritage assets and they have requested that the council weighs this harm against the public benefits of the proposal.

337 As noted above, officers conclude that, as a result of the high quality of the architectural and urban design qualities of the scheme, it would not result in harm to the heritage significance of any of the surrounding designated assets. The proposal therefore accords with the poli cies in the London Plan, the Core Strategy and the saved policies in the Southwark Plan in relation to heritage assets and will conserve their significance. Indeed, it is considered that the enhancements resulting from the replacement of the incongruous ex isting buildings on the site, the reinstatement of the concave elevation to the circus, the sense of enclosure proposed along Blackfriars Road and the elegant design of the tower and a vertical landmark structure, the scheme would have many beneficial impa cts. Furthermore, the scheme is considered to have other public benefits beyond the enhancements to the surrounding townscape, including the delivery of a new public square at the base of the tower and a new east-west connection across the site.

338 The Planning (Listed Buildings and Conservation Areas) Act 1990 imposes statutory duties on LPAs in sections 66 to ensure that any development shall have special regard to: the desirability of preserving the heritage asset or its setting; and in section 72 th e desirability of preserving or enhancing the character or appearance of designated conservation areas. Officers are satisfied that this proposal achieves these key statutory objectives.

Design Review Panel 339 An earlier iteration of the scheme propos ed for the application site was reviewed by Southwark's Design Review Panel on 8 April 2013. Although the Panel agreed that the context of the site, at the focus of a number of views and of significance in the wider urban context, does not preclude a landm ark building in this location, they did express some concern that the architectural approach and positioning of the tower required further refinement. In particular, they were keen to ensure that the tower had an appropriate setting; that it made a proport ionate contribution to the public realm; and that it distinguished itself sufficiently from the other buildings on the site.

340 The Panel considered that a successful tower in this location should be visible from St George’s Circus, but set back suffici ently to create its own setting at the southern end of the Blackfriars Road whilst respecting the adjacent conservation area and listed buildings. They stressed that it should be accompanied by an appropriate public space on the site itself, and that this site should be of a generous size, proportionate to the scale of development. They stated that the scheme should not devolve responsibility for providing the public space to a wider than normal public footway or a space nearby.

341 The Panel focussed on a mid height building of 16-storeys that no longer forms part of the scheme. This building was proposed to mediate between the mid-range podium blocks and the 30-storey tower. They felt that, whilst it may be necessary to mediate between the prevailing 7-8 storey scale of the Blackfriars Road and taller elements on the site, the approach to scale was too monolithic and unified and that each tall element needed to distinguish itself sufficiently and articulate its setting appropriately. They expressed conce rn that the taller elements were articulated as larger versions of the warehouse style blocks they had proposed for the rest of the site.

342 The Panel recognised that the listed buildings on London Road and the St George’s Circus Conservation Area are s ensitive contextual aspects of this scheme and expressed some concern that the impact on the settings of these assets had not yet been fully explored. They requested rendered views of the proposal demonstrating how the proposed development affects the sett ing of these sensitive historic assets and to justify the impact on the setting of the listed buildings and the conservation area. These have now been provided in the TVBHA discussed above.

Impacts from demolition and construction 343 The likely signif icant impacts on townscape character and visual amenity would vary according to the nature of the demolition and construction works over time. Demolition and construction activities would have the greatest visual impact in the areas adjoining the site, inc luding the setting of built heritage assets and would reduce the further away from the site. Impacts would be short to medium term and temporary in nature.

344 Visual adverse impacts of short to medium-term prior to the completion of the development are inevitable on a scheme of this size and scale. However, it is considered that given their nature and duration the adverse impacts are acceptable in order to secure the comprehensive redevelopment of the site, thus contributing towards the wider regeneratio n of Blackfriars Road and cause no harm to the significance of the heritage assets or their settings.

Ecology and biodiversity

345 Saved Policy 3.28 of the Southwark Plan requires that biodiversity is taken into account in all planning applications a nd encourages the inclusion of features which enhance biodiversity. It also states that developments will not be permitted which would damage the nature conservation value of Sites of Importance for Nature Conservation and local nature reserves and/or dama ge habitats or priority species. The proposal has no such effect. Strategic Policy 11 concerning open spaces and wildlife requires new development to avoid harming protected and priority plants and animals to help improve and create habitat. Section 40(1) of the Natural Environment and Rural Communities Act 2006 provides that: “ (1) Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity.”

346 The council’s Ecology Officer has reviewed the Ecology chapter within the ES and considers the assessment to be acceptable. The site currently has a low ecological value when considering the footprint of the existing buildings, the extent of hardstanding and intensively managed amenity landscape being present on the site. The proposed development has the potential to enhance biodiversity with the inclusion of features such as biodiverse living roofs and green walls which are beneficial for wild life. Opportunities for providing bird, bat, and bug boxes will be made across the site, situated in trees at grade and amongst shrubs and timber pergolas at roof level. The retention of 10 street trees is particularly welcome.

347 Natural England has advised that the proposal is unlikely to affect any statutorily protected sites or landscapes.

348 Officers recommend that conditions should be attached to any grant of permission to secure biodiversity enhancement.

Landscape and impact on trees

349 The proposed landscaping is of high quality resulting in an improved public realm and positive contribution to amenity. This is achieved using a variety of generously proportioned new landscaped public and semi-private open spaces at ground floor level. The most prominent of these spaces is the un-gated public central courtyard, ‘Library Square’ connecting Blackfriars Road eastwards to Library Street. Design features include new tree planting to create a grove of new trees, raised planters, green walls, a glazed brick wall water feature and seating. The use of water is especially welcome.

350 Further amenity spaces for occupiers of the development will be provided in the form of communal roof gardens which include a variety of multi-functional spaces such as door step play for the under 5 year olds, raised grass lawns, sun decks, and timber pergolas planted with climbing plants to provide shelter. The Block B2 tower will incorporate an external events space with viewing deck and seating for residents of the development.

351 Ten of thirteen existing trees are proposed to be retained. The three trees to be removed are relatively young trees and are located within the southern portion of the site. The 10 trees to be retained are off-site street trees along the Blackfriars Road / St. George’s Circus frontages. Six new trees are proposed along Library Street as well as additional tree planting along Blackfriars Road to enhance the ‘boulevard’ setting of th e street. Details of the tree planting on TfL routes will need to be submitted for approval in consultation with TfL as highway authority. Should it not be technically feasible to provide the proposed street trees in the locations shown on the submitted la ndscaping plan then these will be required to be provided elsewhere on the highway. Officers recommend that this can be satisfactorily dealt with by condition.

352 The council’s Urban Forester has advised that the details submitted show a high quality l andscape strategy for the development but appropriate detailed design details for hard and soft landscaping, including areas of new public realm, will be required in order to ensure the quality of landscaping aspired to. In particular, the applicant will need to demonstrate sufficient soil volumes to sustain trees within raised planters and above podiums.

353 A local resident has raised a query concerning the retention of two mature London Plane trees, one on the corner of St. George’s Circus and Boroug h Road and the other located in Tadworth House, adjacent the northern site boundary. The proposal includes the retention of all highway trees (as shown on the landscape plans) fronting the site. An Arboricultural Method Statement detailing the measures fo r protection of existing trees during construction will be secured by condition. The tree to the rear of Tadworth House is not affected by the proposed development.

Wind (microclimate)

354 Buildings that are taller than their surroundings may deflect wind pressure from higher levels down towards street level. Strong winds may occur as the pressure escapes around corners and through openings. The degree to which this is important depends on details of both building shapes, in the context of their surroundings, and the relative direction of the prevailing winds.

355 The ES has assessed the implica tions of the proposed development on wind conditions within and immediately surrounding the site. Current (baseline) conditions on the site reflect wind conditions that are broadly in keeping with other parts of Central London. Once buildings on site have been demolished there will be the potential for wind to blow openly across the site thereby increasing wind exposure on and immediately adjoining the site. However, an increase in local windiness is unlikely to create conditions that are unsuitable for a w orking construction site or adjacent pedestrian thoroughfares. Furthermore, wind conditions would gradually adjust towards the conditions of the completed development as construction proceeds. The residual impact during demolition and construction is there fore predicted to be negligible.

356 In terms of the completed development, wind tunnel testing was carried out in relation to the proposed development massing with the existing surrounding buildings. The development has been designed to reduce wind spe eds and make locations suitable for their intended use (i.e. sitting, standing, and walking). In particular, proposed hard and soft landscaping would provide varied forms of shelter in the form of tree and/or hedge planting in ground floor amenity areas, p ublic open space as well as on roof top terraces. Additional mitigation in the form of full-height solid screens would be required to the B2 roof terraces (Level 25).

357 The results of the assessment show that the overall residual impact on wind condit ions around the site are expected to range from negligible to moderately beneficial in that wind conditions would be similar to or slightly less windy at most locations around the site as compared to the existing scenario. Officers are satisfied with the E S assessment subject to the proposed landscape and screen mitigation measures being secured by condition.

Air quality

358 The majority of the borough, including the application site, is within an Air Qual ity Management Zone due the significant presence of traffic generated pollutants. As a result, developments are required to take account of any impacts upon air pollution as a result of, and during construction of, a proposed development. An Air Quality Assessment has been prepared and submitted as part of the ES.

359 There are potential adverse impacts upon local air quality during the construction phase, particularly from dust generation and additional construction traffic vehicle movements. However, these would be temporary in nature and can be mitigated as far as possible through measures secured as part of the Construction Environmental Management Plan. During this phase it is not expected that that the volume of construction traffic from this devel opment, or combined with other construction sites, would have a significant adverse impact upon local air quality when compared with existing traffic flows in the area.

360 Once complete, the development is predicted to result in an insignificant chang e in vehicle movements when considering the current parking levels on site. Furthermore, a Travel Plan will be provided to reduce future car dependency and promote more sustainable means of travel. The development will incorporate a Combined Heat and Power (CHP) system and gas boilers but the ES advises that the impact of emissions from the plant upon local air quality to existing and future sensitive receptors is predicted to be negligible.

361 Mitigation measures to reduce exposure of future residents of the development to poor air quality intake will be required. These include the use Mechanical Ventilation with Heat Recovery (MHVR) systems for the residential units and the underground car park will also require effective ventilation.

362 The Enviro nmental Protection Team are satisfied with the submitted details but recommend full details and specification of the proposed mechanical ventilation and CHP system, including management plan, should be secured by condition.

Electronic interference

363 Developments which include tall buildings have the potential to disrupt TV reception (digital terrestrial and satellite format) as the buildings can block the signals. The ES includes an assessment of the proposed development upon potential impacts to TV reception.

364 The ES identifies that during construction the use of temporary equipment such as cranes and scaffolding would give rise to short-term minor adverse impacts to TV reception due to the possible reduction in signal. Cable services may also be affected but this can be mitigated by obtaining cable route information from service providers.

365 During the operational phase, the development would cast a shadow from the Crystal Palace transmitter extending 0.65km from the site in a north-west di rection. 22 properties with TV aerial installations are located within this shadow and are likely to be adversely affected and mitigation required. For dwellings without a satellite dish, measures could include increasing the height of existing aerials and /or providing a non-subscription satellite service. Mitigation measures for loss of satellite TV services will include increasing the height of dishes or relocating them to outside the predicted shadow area. With mitigation measures in place, long-term res idual impacts to TV (including digital and satellite) are predicted to be negligible.

366 Arqiva, who are responsible for providing the BBC and ITVs transmission network, have raised no in principle objection to the proposal but clarify that this doesn’ t mean there will be no potential problems with interference.

367 Officers are satisfied with the assessment undertaken and are of the view that likely significant effects are identified and assessed. Officers recommend that obligations are included in the legal agreement to require appropriate surveys to be carried out before and after development to assess the impacts, and the implementation of mitigation measures to rectify any problems that occur.

Archaeological matters

368 Policy 3.19 of the So uthwark Plan requires an archaeological assessment and evaluation to be submitted for planning applications affecting sites within Archaeological Priority Zones (APZs). The application site is not within an APZ but the applicant has undertaken a desk based assessment to provide baseline data for the archaeological chapter within the ES.

369 The site investigation works undertaken have been observed by an archaeologist to clarify the interpretation of the desk-based assessment. The ES considers that the s ite has a low archaeological potential due to the demolition of post-medieval and modern buildings and the construction of the current buildings on site, including basement. The council’s Archaeological Officer agrees that there is limited potential for ar chaeological remains to be present on site and therefore recommends that no further archaeological work is required.

370 Overall, the residual impacts of the proposed development both during demolition, construction and when operational are considered to have a negligible impact on archaeological remains.

Ground conditions and contamination

371 The RSA Geotechnics Ltd Phase 1 Desk Study Report forms part of the ES. The purpose of the report is to establish the potential for significant ground conta mination to exist at the site and the likely risk posed to a range of sensitive receptors such as humans, aquifers and flora. In terms of ground water resources, the site is located over a secondary aquifer. The study concludes that there is potential for underlying contamination sources to be present although the potential for significant contamination is low. Officers are satisfied that likely significant effects have been identified and assessed.

372 A site investigation and detailed risk assessment w ill need to be undertaken prior to construction to determine the level of contamination (if any) and whether remediation measures will be required and, if necessary, followed by a validation report. All demolition and construction works will be carried out in accordance with a Construction Environmental Management Plan which will include measures to minimise potential harmful impacts. With these measures in place, the likely residual impacts both during construction and to future occupiers of the site would be insignificant or negligible.

373 The council’s Environmental Protection Team and the Environment Agency are satisfied with the submitted details, subject to conditions requiring further details of potential site contamination and appropriate remediation.

Water resources and flood risk

374 Strategic Policy 13 of the Core Strategy allows development to occur in the protected Thames flood zone as long as it is designed to be safe and resilient to flooding and meets the Exceptions Test for new devel opment in flood risk areas. The policy also requires major development to reduce surface water run-off by at least 50%.

375 The ES (which includes a site specific Flood Risk Assessment) considers the likely impacts of the development on flood risk, grou ndwater levels and surface water drainage. The site is located within Flood Zone 3a defined as having a high probability of flooding with a greater than 0.5% chance of flooding in any given year due to the proximity of the tidal River Thames. However, the site is in an area which benefits from Thames tidal flood defences.

376 The ES states that during the construction phase there could be potential for flood risk and disturbance to groundwater and contaminated land. However, no significant impacts to wat er resources are expected providing that the mitigation measures specified within the ES, including Environmental Management Plan, are in place. Once operational, measures such as SUDS (Sustainable Urban Drainage Systems) and green roofs would be incorpora ted into the development. In addition, the residential accommodation would be above ground floor level and will be protected from flooding even in the unlikely event of the river defences being breached. Officers are satisfied that likely significant effe cts have been assessed and that it has been demonstrated that the development can be made safe through the measures detailed in the submitted assessment.

377 The Environment Agency raises no objections to the proposal, subject to conditions requiring th e submission of a surface water drainage scheme and that the flood mitigation measures specified in the Flood Risk Assessment are secured. The residual impacts of the development are therefore considered to be negligible.

378 A significant part of Southw ark is within Flood Zone 3. There are no sites of this size that are at a lower risk of flooding for some distance. The application site is designated as a potential development site in the Blackfriars Road SPD and the development of brownfield sites, part icularly within Opportunity Areas, is encouraged to maximise the efficient use of land. The proposal would incorporate hard and soft landscaping as well as green and brown roofs which will attenuate surface water run off from the site and thereby contribut e towards a potential reduction in flood risk. The submitted assessment details proposed measures to ensure that future occupants would be safe in the event of a flood. Furthermore, the proposal would have social, economic and environmental benefits that a re considered to outweigh any risk from flooding. Officers therefore consider that the proposal meets the required Exceptions Test.

Socio-economic implications

380 The NPPF sets out the government’s commitment to deliv ering sustainable development. The social and economic dimension of sustainable development can be broken down into four themes:

- Building a strong, competitive economy; - Ensuring the vitality of town centres; - Delivering a wide choice of high quality; and - Promoting healthy communities.

381 Policies in the London Plan, Southwark Plan and Core Strategy support the strategy for sustainable growth in London and specifically the Bankside, Borough and London Bridge and Elephant and Castle as opportunity areas for growth.

Building a strong competitive economy 382 The estimated demolition and construction period is 3.5 years. The ES advises that the development would support approximately 176 full time equivalent construction jobs per year. The completed development will contribute new long-term employment opportuni ties through the creation of an additional 223 jobs (taking into account the reduction of 105 artists that currently work on site). In addition, the gross expenditure of future residents on site is estimated to be £15 million annually and whilst this may not all be spent in the Blackfriars Road area, it can be expected that a high proportion of spending will be in Southwark. The significance of both the creation of new jobs and additional local spending is considered to be minor beneficial in the ES.

Ensuring the vitality of town centres 383 The proposal supports the creation of new retail provision thereby significantly increasing the amount of active retail frontage in the area, particularly compared with the curre nt situation where no active frontage is provided on site. The proposed retail offer would contribute towards the provision of a mix of new town centre uses which will increase activity and strengthen the appeal of the area as envisaged by the Core Strateg y and Blackfriars Road SPD. Again, the ES predicts this to have a minor beneficial long-term impact on the area.

Delivering a wide choice of high quality homes 384 The proposed development would provide 336 new homes on site of varying size of which 1 5% would be larger family sized homes. 30% of the homes (or 91 units) would be affordable with an additional £4.7m payment to be made towards funding affordable housing elsewhere in the borough. The proposal would make an important contribution to housing supply in the area, including the achievement of local and regional housing targets such that the ES concludes that the 336 new homes would have a moderate beneficial impact on housing provision in the borough.

Promoting healthy communities 385 There are seven GP surgeries within 1km of the development site (within Southwark and Lambeth). The proposed development will increase the demand on GP surgeries but the ES advises that Southwark has fewer people per GP than the national average and therefore the long-term impact on health provision would be negligible. The development would provide new areas of open amenity space, play space, and landscaped public realm which will have minor beneficial effects on the provision of recreational opportunities for existing and future local residents which in turn would generate associated health benefits. This is particularly welcome as the site is within an identified area of open space deficiency. S106 contributions will also be secured to mitigate the impacts of increased demand on local infrastructure such as health and education provision.

Conclusion 386 Officers agree with the conclusions of the ES and consider that the socio-economic impacts arising from the development are overall likely to be positive. The development would support the town centre by providing high quality new retail space, generate additional jobs in the borough, both during construction and operational phases, and the provision of new homes would make an important contribution towards meeting the requirement for much needed homes in the borough. The creation of new open amenity areas and high quality linking public realm through the site will encourage activity and movement, thus enhancing the attractiveness and appeal of the area. The proposal is therefore considered acceptable and the overall regenerative benefits arising from the scheme are welcome.

Equalities

387 Section 149 of the Equality Act 2011 provides that the council must, in the exercise of its functions, have due regard to the need to:

a) eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under this Act: b) advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it; and c) foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

It should be noted that the Blackfriars Road SPD was supported by an equality impact assessment.

388 The ES includes assessment of the associated Socio-Economic impacts arising from the development. Overall, there is considered to be a positive benefit on all groups as a result of the development. The impacts arising from the demolition and construction phase have been ident ified earlier in the report. During demolition and construction there are no specific equalities impacts in that all potentially adverse construction impacts would be evenly distributed and as such do not disadvantage any particular group. There are minor beneficial impacts arising for unemployed people due to the number of potential construction jobs.

389 It is considered that the proposed scheme would long-term beneficial impacts providing job opportunities, new public spaces, and a significant number of new homes. No significant adverse impacts that would affect specific groups of particular characteristics have been identified.

390 The completed development would broadly have a positive impact on all the target groups. It is acknowledged that the d evelopment would result in the displacement of 105 artists currently on site but there will be a net gain of 223 jobs which will be a positive impact for local unemployed people. The provision of high quality flexible business units will result in a long-term beneficial impact for new and existing businesses. New housing, including affordable homes, will be built on site, contributing towards achieving a mixed community. The housing would also include wheelchair units and to be built to Lifetime Homes stand ard which will have a positive impact for those with a disability. The improved physical environment, including new linking public realm, will ensure greater accessibility and movement through the site which will benefit all groups. As such the proposal wi ll have a positive impact on terms of equalities.

391 Officers therefore consider that the proposed scheme and the wider regeneration of the area brought about by the development, which aims to deliver a mixed and balanced community, is compatible with its equalities duties and will have some beneficial impact on protected groups, the advancement of equality of opportunity and the fostering of good relations between persons who share a relevant protected characteristic and persons who do not share it.

Planning obligations (S.106 undertaking or agreement)

392 Regulation 122 of the Community Infrastructure Levy (CIL) 2010 Regulations came into force on 6 April 2010. Regulation 122 provides that a planning obligation may only constitute a reason for granting planning permission for a development , if the obligation meets all of the following tests:

• necessary to make the development acceptable in planning terms; • directly related to the development; and • fairly and reasonably related in scale and kind to the development.

393 The above tests are echoed in Para. 204 of the NPPF and planning obligations are requirements of Policy 8.2 of the London Plan and Saved Policy 2.5 of the Southwark Plan to provide mitigation for the impacts of a develop ment. These are reinforced by the S106 Planning Obligations SPD which details the type of development that qualifies for planning obligations. Strategic Policy 14 of the Core Strategy states that planning obligations will be sought to reduce or mitigate the impacts of a development.

394 The following table sets out what the applicant has agreed to provide in order to mitigate the impacts of the development.

Planning obligation Amount of planning Amount of planning gain calculated by gain agreed by applicant toolkit (£) (£) Education 492,988 492,988 Employment in the 25,477 25,477 development Employment during 287,148 287,148 construction Employment during 21,733 21,733 construction management fee Public open space 122,795 122,795

Planning obligation Amount of planning Amount of planning gain calculated by gain agreed by applicant toolkit (£) (£) Child play equipment 45,200 45,200 Sports development 299,657 299,657 Transport strategic * 191,897 at 54% = 1,697,216 103,624 1,593,592 at 46% E&C Tariff Total = 1,697,216 Transport site specific 193,920 193,920 Public realm 277,920 277,920 Health 391,826 391,826 Community facilities 54,764 54,764 Sub Total 3,910,654 3,910,654 Admin charge (2% first 69,106.50 69,106.50 £3m / 1% remaining) TOTAL 3,979,760.50 3,979,760.50

* 54% of the site is within Bankside, Borough and London Bridge OA / 46% of the site is within Elephant and Castle OA where the strategic transport contribution has been replaced with a strategic transport tariff to part-fund improvements at the Northern Line ticket hall at Elephant and Castle which are required to underpin the regeneration of the area.

395 The applicant wishes to include an option in the legal agreement to allow provision of their own Employment Workplace Co-ordinator and required appren ticeship training. The Employment during Construction payment would only be payable in the event the applicant elected not to provide their own WPC or else fall short of the council’s employment training targets. Officers consider this acceptable.

396 The public realm and transport site specific contributions would be used to fund the improvement works along the Blackfriars Road frontage. The applicant intends to undertake these works which are predicted to cost far in excess of the £471,840 toolkit gene rated contribution (being £277,920 + £193,920). A default payment will be included in the legal agreement In the event the works are carried out by TfL.

397 The applicant is providing sufficient contributions which are in l ine with the toolkit contained within the S106 SPD. Officers consider that the planning obligations sought meet NPPF guidance and satisfy the requirements of regulation 122(2) of the Community Infrastructure Levy Regulations 2010. The contributions would b e spent on delivering new school places as a result of the development, job creation during construction and in the final development, improvements to open spaces, sports facilities and children’s play areas within the vicinity, improvements to increase th e capacity of transport provision across the borough and specifically at the Northern Line Ticket Hall at the Elephant and Caste, improvements to the public realm, new health facilities and improvements to community facilities.

398 The S106 also includes provisions for

- 91 affordable housing units on-site as well as £4.7m in-lieu payment and phasing of delivery. - Construction Environmental Management Plan - £375,000 towards additional bus capacity* - Bus shelter improvements* - £100,000 towards cycle hire expansion - Car Parking Management Plan - Funding of 3 years free car club membership - £77,156 towards Green Fund

*At the time of this report, these contributions were the subject of on-going negotiations. The outcome will be reported in the addendum report .

399 In addition, the applicant is proposing to erect temporary pub lic artwork on the northern gable wall of Block A, which is on the party wall adjoining Tadworth House. The gable would be visible until Tadworth House is redeveloped. Obligations will be required concerning the commissioning and production of this artwork . The applicant envisages this being organised as a local community competition.

400 The S106 planning obligations are considered necessary to mitigate the impacts of the development, they are directly related to the development and are proportionate to its size and scale. The S106 planning obligations are therefore considered acceptable.

401 In the event that the legal agreement has not been signed by 28 February 2015 it is recommended that the Head of Development Management be authorised to refuse permission, if appropriate, for the following reason:

402 The proposal, by failing to provide for appropriate planning obligations secured through the completion of a S106 agreement, fails to ensure adequate provision of affordable housing and mitigation a gainst the adverse impacts of the development through projects or contributions in accordance with saved policy 2.5 'Planning Obligations' of the Southwark Plan (2007), strategic policy 14 'Delivery and Implementation' of the Core Strategy (2011), policy 8.2 'Planning obligations' of the London Plan (2013) and the Planning Obligations SPD (2007).

Sustainable development implications

403 The NPPF sets out that pla nning has a key role to play in meeting the challenge of climate change through securing radical reductions in greenhouse emissions, through providing resilience to climate change and by supporting the delivery of renewable and low carbon energy.

404 Lo ndon Plan Policy 5.2 stipulates that in order to make the fullest contribution to minimising carbon dioxide emissions, developments should employ the following energy hierarchy: Be lean (use less energy), Be clean (supply energy efficiently), Be green (use renewable energy). Prior to October 2013, the policy had a minimum target for reduction in carbon dioxide emissions of 25% on Part L1A 2010 Building Regulations. From October 2013, the minimum policy target has increased to 40% carbon savings with the red uction to be calculated in respect of regulated emissions only. Policy 5.7 states that for major developments, this should incorporate the use of on-site renewable energy generation, where feasible.

405 Core Strategy Strategic Policy 13 establishes a series of targets for sustainable design and construction and for on-site renewable energy technologies. The policy requires major development to achieve 44% saving in carbon dioxide emissions on 2006 Building Regulations. However, this requirement has been superseded by the London Plan energy policies which reference 2010 Building Regulations and so 40% on 2010 Building Regulations is the relevant target for assessing major new developments. Strategic Policy 13 further requires 20% carbon reduction from on-site renewable sources.

406 A Sustainability Assessment has been submitted which includes an Energy Report setting out the proposed energy strategy for the development. Indicative BREAM and Code for Sustainable Homes Pre-assessments have also been prepa red for the commercial and residential components of the scheme. The anticipated energy savings are predicted relative to both 2006 and 2010 Building Regulations.

Be Lean 407 Passive design measures will be incorporated within the building fabric to improve its thermal performance. Other features include low energy lighting and mechanical ventilation system with heat recovery (MVHR) in the residential units. These measures are predicted to save 17.5 tonnes of carbon dioxide annually which is a 3% savi ng from a baseline 2010 Building Regulations compliant building. Officers consider the 3% saving to be very low for a new-build scheme.

Be Clean 408 A gas fired Combined Heat and Power (CHP) unit is proposed to provide the domestic hot water load as w ell as a proportion of the space heating for the development. The unit would be located in a dedicated basement plant room in addition to gas boilers and other necessary plant. This will result in a reduction in regulated carbon dioxide emissions of 147 tonnes per year or 25.24% saving from a 2010 baseline.

409 It is advised that provision will be made in the basement plant room for future connection to a district heating network. Officers welcome this and recommend a condition to ensure the development is future proofed for connection to a District Heat Network should one become available in the area.

Be Green 410 An analysis of available renewable technologies has been undertaken to supplement the above savings, as per the requirements of the Lo ndon Plan. Options including solar thermal panels, wind turbines, biomass heating and heat pumps were considered and discounted. Photovoltaic (PV) panels are identified as the most appropriate renewable technology to be incorporated on-site. Various locati ons were considered but Blocks A, B2 and B3 were discounted due to potential overshadowing and the need to provide roof-top amenity spaces. The only viable roof space for PV panels is on Blocks B1 and C. The energy strategy states that the PV panels could deliver a further saving of 12.53 tonnes per annum, an additional 3% from the 2010 baseline.

411 Officers welcome the inclusion of PV panels. Although the potential 3% carbon saving achieved falls significantly short of the 20% Core Strategy target, it is acknowledged that there are constraints to the amount of available roof space that could be utilised. As such, the amount of carbon savings from renewable technologies is acceptable.

412 Cumulatively, the ‘Lean’, ‘Clean’ and ‘Green’ measures allow f or an estimated total saving of 177.04 tonnes of carbon dioxide per annum which equates to a 30.4% overall saving.

413 Officers are satisfied that the proposed energy strategy adequately adheres to the Mayor’s Energy Hierarchy but the predicted carbon s avings fall some way short of the minimum London Plan 40% carbon savings required. For a new development of this size and scale, such a shortfall is regrettable and the scheme fails to accord with policy in this respect. The GLA have advised that additiona l measures in the energy efficiency step of the hierarchy should be considered to help achieve further carbon reductions. No further information has been submitted to address this matter.

414 Policy 5.2 of the London Plan asserts that in cases where it has been demonstrated that specific targets cannot be fully achieved on-site, any shortfall may be provided off- site or through a cash in lieu contribution to the borough to be spent on securing delivery of carbon savings elsewhere. Accordingly, and in the absence of any proposed revisions to the energy strategy, officers consider that the shortfall in carbon savings should be off-set by a payment into the borough’s ‘Green Fund’ and the applicant has confirmed agreement.

415 The council’ s draft S106 Planning Obligations and Community Infrastructure Levy contains details of the borough’s Green Fund, including figures for calculating the shortfall sum – charged at £1,380 per tonne of carbon dioxide. The shortfall is carbon savings is 55.91 tonnes per year and so the payment would be £77,156.

416 The submitted BREEAM pre-assessment for the commercial element of the scheme predicts a credit score of 71.92% which equates to an ‘Excellent’ rating. The Code for Sustainable Homes pre-assessment gives a predicted score of 71.99%, equating to ‘Level 4’. These predicted scores meet the minimum targets set out in Strategic Policy 13 and are acceptable. A condition will be required to secure the submission of post- completion assessments to ensure the scheme meets the targets anticipated at this stage.

417 As noted earlier in the report, the scheme would also deliver a number of sustainable measures including rain water run-off attenuation provided by attenuation tanks and green roofs, inclusion of sustainable urban drainage (SuDS), and provision of electric car charging points.

418 Overall, officers consider it very disappointing that the required on-site carbon savings would not be achieved, particularly when considering the policy targets are expressed as a minimum. However, taking all matters into consideration and the wider regenerative benefits that would be delivered by the scheme, on balance the proposal is acceptable.

Other matters

Mayoral CIL

Community Infrastructure Levy (CIL) 419 Section 70(2)(b) of the Town and Country Planning Act 1990 provides that when dealing with a planning application the Council shall have regard to local finance considerations so far as material to the application. The term ‘ local finance consideration’ is defined in section 70(4) and includes sums that a relevant authority has received, or will or could receive, in payment of Community Infrastructure Levy. The requirement for payment of the Mayoral CIL is therefore a material consideration. The weight to be attached to that material consideration is to be determined by the decision maker. The Mayoral CIL is required to contribute towards strategic transport investments of benefit to London as a whole, primarily Crossrail.

420 In Southwark, the Mayoral CIL was established at a rate of £35 per sqm of new development, although this is an index linked payment. The following floorspace is CIL:

Residential (C3) – XXX Retail (A1-A4) – 1,200 sqm GIA Office (B1) – 2,502 sqm GIA Office / Retail (A1-A4 / B1) – 528 sqm GIA

Period of consent 421 In orde r to ensure early delivery of the regenerative benefits of the scheme, including affordable housing and new jobs, officers recommend a shorter timeframe of 18 months for implementation of the development is secured by condition, rather than the standard 3 year timeframe.

Conclusion on planning issues

422 The application site has been identified as a development site to facilitate the wider regeneration of the Blackfriars Road area. The site is within a location where high density new mixed use develop ment is encouraged. The proposal would replace three vacant / under-used buildings that make a poor contribution to the local streetscape. As such the principle of development is supported.

423 The proposed land uses are hi ghly appropriate in this location. The proposal will deliver 336 new homes, including 35% affordable housing (of which 30% would be on- site) which is particularly positive. The phasing of the scheme will ensure that the affordable housing element will be d elivered at an early stage. The proposal will result in a significant loss of business floorspace which has been considered very carefully and the proposal is considered to meet the exceptions test set out in Saved Policy 1.4 of the Southwark Plan. The sch eme provides active new retail frontages, new public realm and landscaping enhancements which would also benefit the wider area.

424 At 1,232 habitable rooms per hectare the density of the scheme is higher than that normally expected for the area, 1,10 0 habitable rooms per hectare. Whilst the proposal would deliver a reasonable standard of residential accommodation, the quality is not considered to be exemplary. The proposal also falls short of the required minimum carbon dioxide savings but the applica nt has agreed to make a payment to the council’s Green Fund.

425 The proposal includes a tall building which has been considered carefully against the requirements of the London Plan and local design policies. Whilst the southern end of Blackfriars Road is not expressly listed in the Core Strategy as a location for a tall building, this doesn’t necessarily preclude it. All tall buildings, irrespective of location, must be assessed against the requirements of Saved Policy 3.20. Accordingly, this assessmen t has been undertaken and it is concluded that the proposal adequately meets the specified Policy 3.20 design criteria. Although the proposal would be visible from a number of vantage points, this doesn’t cause harm. Overall, the scheme is considered to be of high design and architectural quality and would not result in harm to the heritage significance of any of the surrounding heritage assets. Indeed, the scheme would have a beneficial impact to townscape views, and would have other public benefits, such as the delivery of a new public square and east-west connection through the site. This is considered a landmark location at the southernmost end of the Blackfriars Road boulevard and a unique site with adequate space for the wider public benefits necessary to warrant a tall building and is not likely to establish a precedent in the area.

426 It is recognised that the development of this size and scale, including its demolition and construction, has the potential for significant environmental impacts and t herefore an Environmental Statement has been submitted. In arriving at their recommendation, officers had full regard to the Environmental Statement, further information and other information and all submissions relating to considerations contained in this Statement. This includes an assessment of possible alternative options and why these were not feasible as well as an assessment of the cumulative impacts of this and other nearby developments. Following mitigation measures, there are likely to be some adv erse impacts association with the demolition and construction phases but these impacts would be short term. The development would however result in long term adverse impacts to the daylight and sunlight of a number of properties closest to the site. Whilst any resultant adverse impact to neighbouring properties is regrettable, the impacts would not amount to such significant harm that would justify the refusal of planning permission on those grounds.

427 Other policies have also been considered but, as s et out in the report, no impacts and/or conflicts with planning policy have been identified that couldn’t adequately be dealt with by planning obligation or condition. The development would fall short on a number of matters but when considered against the overall regenerative benefits of the scheme to the Blackfriars Road area this proposal is, on balance, considered to comply with the development plan when considered as a whole, and to be acceptable. Having regard to all the policies considered and any oth er material planning considerations it is recommended that planning permission is granted subject to conditions and the completion of a legal agreement.

Community impact statement

428 In line with the Council's Community Impact Statement the impact of this application has been assessed as part of the application process with regard to local people in respect of their age, disability, faith/religion, gender, race and ethnicity and sexual orientation. Consultation with the community has been undertaken a s part of the application process. The impact on local people is set out above.

429 A Statement of Community Involvement has been submitted which details the public consultation and engagement process undertaken by the applicant prior to submission of th e planning application. Public engagement included a series of meetings with key stakeholders, a public exhibition on 22 and 23 May 2014, set up of a dedicated project website and contact ‘hotline’ as well as attendance at various community events.

430 The proposal was presented to the Design Review Panel (DRP) on 8 April 2013. A summary of the Panel’s comments are provided at Paragraph X and in Appendix 2.

Consultations

431 Details of consultation and any re-consultation undertaken in respect of this application are set out in Appendix 1.

Consultation replies

Details of consultation responses received are set out in Appendix 2.

Summary of consultation responses

Objections 432 − Height and scale of proposal − Architectural detail and quality − Poor internal layout − Loss of office space − A greater level of residential / retail space should be provided − Lack of affordable housing − Residential amenities / environmental concerns − Loss of daylight and sunlight to neighbouring residential properties and overshadowing − Loss of views, outlook and privacy − Impacts on highway network − Trees and landscaping − Increased pressure on local schools, medical centres and other infrastructure − Flood risk

Neighbours and local groups

433 Representations to the scheme have been received from The St. George’s Circus Group; The Albert Association, BDP on behalf of London South Bank University; and occupiers of the following properties: Gladstone Street; The C ut; Milcote Street; Oswin Street; Nelson Square; Webber Street: Webber Row; Colnbrook Street; and West Square

Height and scale of proposal − Conflict with Section 7.7 and 7.8 of the London Plan, Saved Policy 3.18 of the Southwark Plan in terms of the harmful impact on the setting of heritage assets − Conflict with Saved Policy 3.20 of the Southwark Plan in that the tall building is not located at a point of landmark significance, a negative contribution to landscape, and detrimental effect to adjacent listed buildings and conservation areas. − Conflict with Core Strategy, Strategic Policy 12 in terms of locations that could accommodate tall buildings − Blackfriars Road SPD – the Core Strategy does not authorise the preparation of an SPD, the proposal fails to conform to the SPD − Would appear incongruous and out of character with scale of surrounding buildings − No precedent for a building of this scale in the area − Already too many skyscrapers dominating previously humane landscapes − Lack of clarity over how tall the building would be, including to the top of roof plant − Proposal is contrary to the council’s Pre-Application Advice Le tter issued 19 June 2013

Architectural detail / floor plans − Out of keeping with / fails to complement the Georgian architecture and historic nature of the area − Materials are not contextual with adjacent older buildings − Balconies appear to be constructed of metal panels which will reflect light and cause blinding reflection to neighbouring properties − Architectural design is not of sufficient quality commensurate with the site − Potential poor internal spaces due to oddly shaped layouts

Land use / principle of redevelopment − Regeneration of southern end of Blackfriars Road is broadly supported − Loss of office space − A greater level of residential / retail space should be provided − Provision of active frontages welcome

Affordable housing − Lack of affordable housing

Residential amenities / environmental concerns − Loss of daylight and sunlight to neighbouring residential properties, including LSBU student accommodation − Overshadowing to the rear courtyard of LSBU Clarence Centre and incorrect plans used for the ES assessment − Loss of views, outlook and privacy − Rubbish bins will block pedestrian footway and adversely impact on amenity of surrounding properties − The open space will attract drinkers, making it unpleasant and breed anti-social behaviour − Public space would be sunless and potential windy − Loss of TV reception − Rights to Light matters Impacts on highway network − Pedestrian, cycle and pedestrian safety on Blackfriars Road − Disruption to bus services with large service and maintenance vehicles in the loading areas − Increased traffic congestion and pollution − Excessive amount of basement car parking − Servicing strategy is flawed − Traffic modelling undertaken is incorrect

Trees and landscaping − Two mature plane trees should be retained − Doesn’t add much greenery to the area

Impact on local infrastructure − Increased pressure on local schools, medical centres and other infrastructure − Flood risk

434 Support Three letters of support received: − Welcome replacement of derelict office buildings − Tower is elegant and well designed − Appropriate location for a tall building − Attempts to balance the architecture of Clarence Pub is appreciated − Welcome provision of affordable housing − Area lacks decent restaurants and shops − CIL / S106 payments will enhance local infrastructure

Internal services

Local Economy Team 435 The type of commercial space being reprovided is appropriate for the area and market. The clustering potential with LSBU is positive. H owever, the overall reduction of employment floorspace is unacceptable. The quantum of B class floorspace ought to be increased from what is proposed. The draft S106 Planning Obligations/CIL SPD deals with loss of employment floorspace and any schemes whic h reduce the existing employment floorspace on sites located in protected employment locations should make a contribution to mitigate the loss of B1 floorspace. A sum of £354,000 should be sought based on the quantum of floorspace to be lost.

Environmental Protection Team 436 Additional noise monitoring on Library Street and at the railway depot, south-west of the Circus was requested (Follow-up email to confirm that railway depot noise monitoring was not necessary due to the dominance of road traffic n oise). Further information required on any kitchen extract cooking system to ensure odours are filtered and dispersed before A3 / A3 uses commence. Strongly recommended that space is accommodated for extract flue ducting to pass up to roof level as low lev el discharge will not be acceptable. Section 10.49 of the ES advises that Southwark’s construction noise level is too stringent. The applicant is advised that this standard will be applied. A number of conditions are recommended concerning internal noise; plant noise; servicing of commercial units; ventilation; CHP specification; kitchen extract ventilation; lighting; site contamination and remediation; and Construction Environmental Management Plan.

Re-consultation Additional monitoring undertaken as requested and proposed façade glazing specification are satisfactory. The noise information is acceptable. The aforementioned conditions remain valid.

Ecology Officer 437 The site has low ecological value with the bu ildings, hard standing and intensively managed amenity landscape being present on site. The proposal has potential to enhance biodiversity and includes features beneficial for wildlife. Recommend conditions regarding provision of green roofs and walls, bir d and bat boxes, ecological management plan and monitoring.

Highways Team 438 Advise that all works to existing streets and spaces to be designed and constructed to an adoptable standard, irrespective of whether it is proposed to offer them for adopti on. Applicant will need to enter into a S278 Agreement for works to existing adopted highway. The application site is within the ‘Town Centre’ and ‘Heritage’ Specification Area and the proposed street palette for the public realm should reflect this design ation. Concerns raised about the provision of a service access across the proposed loading bay on Blackfriars Road. This may have a detrimental impact on the road network. Doors to some ground floor units open outwards onto the public highway and will obst ruct pedestrian movement. A detailed survey is required to ensure that the proposed trees on Library Street are able to be planted on the footway. The trunk centre of the proposed trees should be a minimum 4.5m from building facades. No loss of existing pay-and-display bays on Library Street will be acceptable. The proposed bin holding area on Library Street will render the footway unusable by pedestrians on collection days.

Statutory and non-statutory organisations

English Heritage 439 Support the principle of redevelopment. Existing poor quality buildings detract from the setting of nearby listed buildings and St. George’s Circus Conservation Area. The principle building fronting the north-east quadrant of St. George’s Circus is an appr opriate response. The building is well designed, of the right scale, and will enhance the character and appearance of the conservation area.

Concerns raised over the tall building. In addition to having an impact on the setting of the conservation area, it dominates the setting of the Grade II listed St. George the Martyr Library. The proposals cause some harm to the setting of nearby designated heritage assets, and the council should weigh this harm against the public benefits of the proposal before reaching a decision.

Historic Royal Palaces 440 Request an additional view, looking south-west from within the Tower of London, over the roof of the Queens House, towards the development site in order to confirm that the top of the tower will not be visible.

Reconsultation – confirm that the view modelled demonstrates that the tower will not be visible from within the Inner Ward of the Tower of London.

Natural England 441 Statutory nature conservation sites – no objection. The proposal is unlikely to affect any statutorily protected sites or landscapes.

Greater London Authority 442 In general the proposal complies with land use principle, housing and affordable housing, urban design, housing quali ty, strategic views, world heritage site, inclusive access, blue ribbon network, climate change and transport. Further discussion is however needed on the following points prior to referring back to the Mayor: - Affordable housing: Further discussion req uired in response to the findings of an independently led review of the financial viability assessment, to ensure the maximum reasonable amount of affordable is achieved.

- Energy: The energy hierarchy has been broadly followed. Sufficient information has been provided to understand the proposal as a whole. Further revisions are required before the proposal can be considered acceptable.

- Transport: Travel Plan, car club contribution, delivery service plan, construction logistics plan, and car parking man agement plan should be secured by condition or as part of a legal agreement. The developer will be required to enter into a S278 Agreement with TfL for the Blackfriars Road improvements, or provide appropriate financial contribution for the works. Appropri ate financial contributions should also be secured towards the E&C northern roundabout improvement and Northern Line ticket hall expansion projects, cycle hire expansion, and bus service capacity enhancements.

London Underground 443 No objection in principle but there are a number of potential constraints on the redevelopment of a site situated close to underground tunnels and infrastructure. Request a condition to secure submission of detailed design and method statements for foundat ions and basement and ground floors to demonstrate that there would be no detrimental impact on LU infrastructure.

Network Rail 444 No observations.

Transport for London 445 Request S106 financial contributions in terms of funding cycle hire expansion and additional bus service capacity. Conditions / obligations recommended in respect of Delivery and Service Plan, restricting occupation until public realm works are undertaken, car parking management plan, and travel plan. A S278 Agreement will be required for any works proposed on the TLRN. ‘Yorkstone Paving’ should be used for the resurfacing works to tie in with the materials used for the wider Blackfriars Road project, and there must be no removal of vegetation as a result of the works.

Arqiva 446 No objections are raised. Arqiva is responsible for providing the BBC and ITVs transmission network and can only address the integrity of their broadcast networks. Ariqiva only check whether a proposal might detrimentally affect their ability to continue broadcasting signals from the site and do not check whether there might be interference with the reception of those signals once transmitted from their site to individual proper ties. Arqiva’s closest microwave passes approximately 75m to the east of the development.

BAA 447 Confirm they have no safeguarding objections.

Environment Agency 448 No objection, subject to securing con ditions requiring submission of further details concerning flood risk, surface water drainage scheme, site contamination and remediation, and foundation design.

Thames Water 449 Waste – no comments to make. Water – no objections, subject to a condition to secure the submission of a piling method statement. The existing water supply infrastructure has insufficient capacity to meet the additional demands of the proposed development. Request a condition to secure the submission of impact studies of the exi sting water supply infrastructure to determine the magnitude of any additional capacity required.

City of Westminster 450 Does not wish to comment.

London Borough of Lambeth 451 Raises no objections.

Conservation Area Advisory Group 452 Disappointed about the loss of Erlang House. Opposed to a tall building in this location because it was not identified for tall buildings in the Core Strategy, it is not a transport node and is surrounded by listed buildings and heritage assets. Could set a precedent for further tall buildings along the length of Blackfriars Road. Lack of enough external space to support the proposed number of residents.

Quality of materials and detailing high but concerned that, given the scale of development , it could appear repetitive and monotonous. Reinstatement of one quadrant of the Circus is welcome, but Building C is not of sufficient quality. The Circus needs more public realm and landscape enhancements. The proposal doesn’t positively engage with the listed Library. Frontages would not be active or lively enough.

Design Review Panel 453 Comments incorporated into report.

Human rights implications

454 This pl anning application engages certain human rights under the Human Rights Act 2008 (the HRA). The HRA prohibits unlawful interference by public bodies with conventions rights. The term ’engage’ simply means that human rights may be affected or relevant.

455 This application has the legitimate aim of demolishing the existing buildings on site and redeveloping to provide a high density, mixed use development comprising residential, business and retail uses. The rights potentially engaged by this application, i ncluding the right to a fair trial (Article 6) and the right to respect for private and family life (Article 8) and the protection of property (Article 1 of the First Protocol) are not considered to be unlawfully interfered with by this proposal.

BACKGROUND DOCUMENTS

Background Papers Held At Contact Site history file: TP/1390-133 Southwark Council Planning enquiries telephone: Chief Executive's 020 7525 5403 Application file: 14/AP/1862 Department Planning enquiries email: 160 Tooley Street [email protected] Southwark Local Development London Case officer telephone: Framework and Development SE1 2QH 020-7525-5349 Plan Documents Council website: www.southwark.gov.uk

APPENDICES

No. Title Appendix 1 Consultation undertaken Appendix 2 Consultation responses received Appendix 3 Recommendation

AUDIT TRAIL

Lead Officer Gary Rice, Head of Development Management Report Author Simon Bevan Version Final Dated 9 December 2014 Key Decision No CONSULTATION WITH OTHER OFFICERS / DIRECTORATES / CABINET MEMBER Officer Title Comments Sought Comments Included Strategic Director of Finance and No No Corporate Services Strategic Director of Environment and Yes Yes Leisure Strategic Director of Housing and Yes Yes Community Services Director of Regeneration Yes Yes Date final report sent to Constitutional Team 10 December 2014

APPENDIX 1

Consultation Undertaken

Site notice date: 04/07/2014

Press notice date: 30/10/2014

Case officer site visit date: n/a

Neighbour consultation letters sent: 03/07/2014

Internal services consulted:

Archaeology Officer Design and Conservation Team Ecology Officer Elephant and Castle Special Projects Environmental Protection Team [Noise / Air Quality / Land Contamination / Ventilation] Highway Development Management Housing Regeneration Initiatives Local Economy Team Planning Policy Public Realm - Asset Management Public Realm - Project Design Team Surface Water Flood Management Team Transport Planning Team Urban Forester Waste Management

Statutory and non-statutory organisations consulted:

Arqiva - digital communications BAA City of London City of Westminster Dept. for Communities & Local Government [Referrals under T&CP (Consultation)(England) Direction 2009 -for London only- as per Annex B of Chief Planner's letter 10 March 2011 - see details on Xdrive] EDF Energy English Heritage Environment Agency Greater London Authority Historic Royal Palaces, HM Tower of London London Borough of Lambeth London City Airport London Fire & Emergency Planning Authority London Underground Limited Metropolitan Police Service Natural England - London Region & South East Region Network Rail (Planning) Thames Water - Development Planning The Georgian Group The Royal Parks Transport for London (referable & non-referable app notifications and pre-apps)

Neighbour and local groups consulted:

33 Gladstone Street London SE1 6EY Apartment 2 46 Webber Street SE1 8QW Via Email x Apartment 3 46 Webber Street SE1 8QW 28 Gladstone Street London SE1 6EY Unit D 46 Webber Street SE1 8QW Suite 2 45-46 Lower Marsh SE1 7RG Apartment 1 46 Webber Street SE1 8QW 33 Gladstone Street London SE1 6EY 13 Library Street London SE1 0FJ 14a Baylis Road Waterloo SE1 7AA Flat 31 Muro Court SE1 0FH Flat 32 Muro Court SE1 0FH Flat 29 Muro Court SE1 0FH Flat 30 Muro Court SE1 0FH Flat 15 Bridgehouse Court SE1 8HW Flat 33 Muro Court SE1 0FH Flat 16 Bridgehouse Court SE1 8HW 9 Library Street London SE1 0FJ Flat 13 Bridgehouse Court SE1 8HW 11 Library Street London SE1 0FJ Flat 14 Bridgehouse Court SE1 8HW Flat 34 Muro Court SE1 0FH Flat 17 Bridgehouse Court SE1 8HW 7 Library Street SE1 0FJ Flat 20 Bridgehouse Court SE1 8HW Flat 103 Wellington Lodge SE1 8RQ Flat 21 Bridgehouse Court SE1 8HW Flat 104 Wellington Lodge SE1 8RQ Flat 18 Bridgehouse Court SE1 8HW Flat 101 Wellington Lodge SE1 8RQ Flat 19 Bridgehouse Court SE1 8HW Flat 102 Wellington Lodge SE1 8RQ Flat 12 Bridgehouse Court SE1 8HW Flat 105 Wellington Lodge SE1 8RQ Flat 5 Bridgehouse Court SE1 8HW Flat 203 Wellington Lodge SE1 8RQ Flat 6 Bridgehouse Court SE1 8HW Flat 204 Wellington Lodge SE1 8RQ Flat 3 Bridgehouse Court SE1 8HW Flat 201 Wellington Lodge SE1 8RQ Flat 4 Bridgehouse Court SE1 8HW Flat 202 Wellington Lodge SE1 8RQ Flat 7 Bridgehouse Court SE1 8HW Flat 3 Wellington Lodge SE1 8RQ Flat 10 Bridgehouse Court SE1 8HW Apartment 6 46 Webber Street SE1 8QW Flat 11 Bridgehouse Court SE1 8HW Apartment 7 46 Webber Street SE1 8QW Flat 8 Bridgehouse Court SE1 8HW Apartment 4 46 Webber Street SE1 8QW Flat 9 Bridgehouse Court SE1 8HW Apartment 5 46 Webber Street SE1 8QW Block T Flat 8 Peabody Square SE1 8HS Apartment 8 46 Webber Street SE1 8QW Block T Flat 9 Peabody Square SE1 8HS Flat 1 Wellington Lodge SE1 8RQ Block T Flat 5 Peabody Square SE1 8HS Flat 2 Wellington Lodge SE1 8RQ Block T Flat 6 Peabody Square SE1 8HS Apartment 9 46 Webber Street SE1 8QW Block T Flat 10 Peabody Square SE1 8HS Garden Flat 12 London Road SE1 6JZ Block T Flat 14 Peabody Square SE1 8HS Flat 28 Muro Court SE1 0FH Block S Flat 2 Peabody Square SE1 8HT Flat 2 Muro Court SE1 0FH Block T Flat 11 Peabody Square SE1 8HS Flat 3 Muro Court SE1 0FH Block T Flat 12 Peabody Square SE1 8HS Ground Floor Flat 8 London Road SE1 6JZ Block T Flat 4 Peabody Square SE1 8HS Flat 1 Muro Court SE1 0FH Flat 24 Bridgehouse Court SE1 8HW Flat 4 Muro Court SE1 0FH Flat 25 Bridgehouse Court SE1 8HW Flat 7 Muro Court SE1 0FH Flat 22 Bridgehouse Court SE1 8HW Flat 8 Muro Court SE1 0FH Flat 23 Bridgehouse Court SE1 8HW Flat 5 Muro Court SE1 0FH Flat 26 Bridgehouse Court SE1 8HW Flat 6 Muro Court SE1 0FH Block T Flat 2 Peabody Square SE1 8HS Living Accommodation Flowers Of The Forest SE1 7QX Block T Flat 3 Peabody Square SE1 8HS Basement And Ground Floor 52-58 Lancaster Street SE1 0RY Flat 27 Bridgehouse Court SE1 8HW First Floor 52-58 Lancaster Street SE1 0RY Flat 28 Bridgehouse Court SE1 8HW Tenants Hall Overy House Webber Row Estate SE1 8QX Flat 2 Bridgehouse Court SE1 8HW Unit 4 109-115 Blackfriars Road SE1 8HW Block T Flat 1 Peabody Square SE1 8HS Flat 4d 3 London Road SE1 6JZ Block S Flat 1 Peabody Square SE1 8HT Living Accommodation 30 Borough Road SE1 0AJ Flat 8 Mawdley House Webber Row Estate SE1 8XQ Living Accommodation 108 Blackfriars Road SE1 8HW Flat 9 Mawdley House Webber Row Estate SE1 8XQ Flat Above 6 London Road SE1 6JZ Block A Flat 1 Peabody Square SE1 8HU Block S Ground Floor Office Peabody Square SE1 8HU Block D Flat 1 Peabody Square SE1 8HZ Flat 21 Muro Court SE1 0FH Block O Flat 1 Peabody Square SE1 8JA Flat 22 Muro Court SE1 0FH Block B Flat 1 Peabody Square SE1 8HX Flat 19 Muro Court SE1 0FH Block C Flat 1 Peabody Square SE1 8HY Flat 20 Muro Court SE1 0FH Flat 7 Mawdley House Webber Row Estate SE1 8XQ Flat 23 Muro Court SE1 0FH Flat 19 Mawdley House Webber Row Estate SE1 8XQ Flat 26 Muro Court SE1 0FH Flat 2 Mawdley House Webber Row Estate SE1 8XQ Flat 27 Muro Court SE1 0FH Flat 17 Mawdley House Webber Row Estate SE1 8XQ Flat 24 Muro Court SE1 0FH Flat 18 Mawdley House Webber Row Estate SE1 8XQ Flat 25 Muro Court SE1 0FH Flat 20 Mawdley House Webber Row Estate SE1 8XQ Flat 18 Muro Court SE1 0FH Flat 5 Mawdley House Webber Row Estate SE1 8XQ Flat 11 Muro Court SE1 0FH Flat 6 Mawdley House Webber Row Estate SE1 8XQ Flat 12 Muro Court SE1 0FH Flat 3 Mawdley House Webber Row Estate SE1 8XQ Flat 9 Muro Court SE1 0FH Flat 4 Mawdley House Webber Row Estate SE1 8XQ Flat 10 Muro Court SE1 0FH Block M Flat 1 Peabody Square SE1 8JP Flat 13 Muro Court SE1 0FH Block F Flat 1 Peabody Square SE1 8JQ Flat 16 Muro Court SE1 0FH Block I Flat 1 Peabody Square SE1 8JL Flat 17 Muro Court SE1 0FH Block J Flat 1 Peabody Square SE1 8JN Flat 14 Muro Court SE1 0FH Block N Flat 1 Peabody Square SE1 8JR Flat 15 Muro Court SE1 0FH 39 Webber Street London SE1 8QW South Bank University 103 Borough Road SE1 0AA Flat 1 Bridgehouse Court SE1 8HW 29 Borough Road London SE1 0AJ Block K Flat 1 Peabody Square SE1 8JW Unit 2 160 Blackfriars Road SE1 8EZ 37 Webber Street London SE1 8QW Unit 3 160 Blackfriars Road SE1 8EZ Block H Flat 1 Peabody Square SE1 8JJ Flat 1 Murphy House Borough Road Estate SE1 0AH Block U Flat 3 Peabody Square SE1 8JB Flat 12 Murphy House Borough Road Estate SE1 0AH Block U Flat 4 Peabody Square SE1 8JB Flat 13 Murphy House Borough Road Estate SE1 0AH Block U Flat 1 Peabody Square SE1 8JB Flat 10 Murphy House Borough Road Estate SE1 0AH Block U Flat 2 Peabody Square SE1 8JB Flat 11 Murphy House Borough Road Estate SE1 0AH Block P Flat 1 Peabody Square SE1 8JD Unit 1 160 Blackfriars Road SE1 8EZ Block E Flat 1 Peabody Square SE1 8JG Clarence Centre For Enterprise And Innovation 6 St Georges Circus SE1 6LF Block G Flat 1 Peabody Square SE1 8JH 13-16 Borough Road London SE1 0AA Block Q Flat 1 Peabody Square SE1 8JE Unit A Bell House SE1 0RF Block R Flat 1 Peabody Square SE1 8JF Room 101 Northcott House SE1 8JU Block O Flat 5 Peabody Square SE1 8JA 123 London Road London SE1 6LF Block O Flat 6 Peabody Square SE1 8JA 126 London Road London SE1 6LF Block O Flat 3 Peabody Square SE1 8JA 130 London Road London SE1 6LF Block O Flat 4 Peabody Square SE1 8JA 124 London Road London SE1 6LF Block O Flat 7 Peabody Square SE1 8JA 125 London Road London SE1 6LF Block O Flat 11 Peabody Square SE1 8JA Flat 3 Murphy House Borough Road Estate SE1 0AH Block P Flat 2 Peabody Square SE1 8JD Flat 4 Murphy House Borough Road Estate SE1 0AH Block O Flat 8 Peabody Square SE1 8JA Flat 23 Murphy House Borough Road Estate SE1 0AH Block O Flat 9 Peabody Square SE1 8JA Flat 24 Murphy House Borough Road Estate SE1 0AH Block O Flat 2 Peabody Square SE1 8JA Flat 5 Murphy House Borough Road Estate SE1 0AH Block D Flat 5 Peabody Square SE1 8HZ Flat 8 Murphy House Borough Road Estate SE1 0AH Block D Flat 6 Peabody Square SE1 8HZ Flat 9 Murphy House Borough Road Estate SE1 0AH Block D Flat 3 Peabody Square SE1 8HZ Flat 6 Murphy House Borough Road Estate SE1 0AH Block D Flat 4 Peabody Square SE1 8HZ Flat 7 Murphy House Borough Road Estate SE1 0AH Block D Flat 7 Peabody Square SE1 8HZ Flat 22 Murphy House Borough Road Estate SE1 0AH Block D Flat 10 Peabody Square SE1 8HZ Flat 16 Murphy House Borough Road Estate SE1 0AH Block D Flat 11 Peabody Square SE1 8HZ Flat 17 Murphy House Borough Road Estate SE1 0AH Block D Flat 8 Peabody Square SE1 8HZ Flat 14 Murphy House Borough Road Estate SE1 0AH Block D Flat 9 Peabody Square SE1 8HZ Flat 15 Murphy House Borough Road Estate SE1 0AH Block Q Flat 5 Peabody Square SE1 8JE Flat 18 Murphy House Borough Road Estate SE1 0AH Block Q Flat 6 Peabody Square SE1 8JE Flat 20 Murphy House Borough Road Estate SE1 0AH Block Q Flat 3 Peabody Square SE1 8JE Flat 21 Murphy House Borough Road Estate SE1 0AH Block Q Flat 4 Peabody Square SE1 8JE Flat 19 Murphy House Borough Road Estate SE1 0AH Block Q Flat 7 Peabody Square SE1 8JE Flat 2 Murphy House Borough Road Estate SE1 0AH Block Q Flat 10 Peabody Square SE1 8JE 8 Bell House 57 Webber Street SE1 0RF Block Q Flat 11 Peabody Square SE1 8JE Flat 502 Wellington Lodge SE1 8RQ Block Q Flat 8 Peabody Square SE1 8JE Flat 503 Wellington Lodge SE1 8RQ Block Q Flat 9 Peabody Square SE1 8JE Flat 405 Wellington Lodge SE1 8RQ Block Q Flat 2 Peabody Square SE1 8JE Flat 501 Wellington Lodge SE1 8RQ Block P Flat 5 Peabody Square SE1 8JD Flat 504 Wellington Lodge SE1 8RQ Block P Flat 6 Peabody Square SE1 8JD Flat 602 Wellington Lodge SE1 8RQ Block P Flat 3 Peabody Square SE1 8JD Flat 603 Wellington Lodge SE1 8RQ Block P Flat 4 Peabody Square SE1 8JD Flat 505 Wellington Lodge SE1 8RQ Block P Flat 7 Peabody Square SE1 8JD Flat 601 Wellington Lodge SE1 8RQ Block P Flat 10 Peabody Square SE1 8JD Flat 404 Wellington Lodge SE1 8RQ Block P Flat 11 Peabody Square SE1 8JD Flat 302 Wellington Lodge SE1 8RQ Block P Flat 8 Peabody Square SE1 8JD Flat 303 Wellington Lodge SE1 8RQ Block P Flat 9 Peabody Square SE1 8JD Flat 205 Wellington Lodge SE1 8RQ Block D Flat 2 Peabody Square SE1 8HZ Flat 301 Wellington Lodge SE1 8RQ Block A Flat 4 Peabody Square SE1 8HU Flat 304 Wellington Lodge SE1 8RQ Block A Flat 5 Peabody Square SE1 8HU Flat 402 Wellington Lodge SE1 8RQ Block A Flat 2 Peabody Square SE1 8HU Flat 403 Wellington Lodge SE1 8RQ Block A Flat 3 Peabody Square SE1 8HU Flat 305 Wellington Lodge SE1 8RQ Block A Flat 6 Peabody Square SE1 8HU Flat 401 Wellington Lodge SE1 8RQ Block A Flat 9 Peabody Square SE1 8HU 1 Bell House 57 Webber Street SE1 0RF Block A Flat 10 Peabody Square SE1 8HU 2 Bell House 57 Webber Street SE1 0RF Block A Flat 7 Peabody Square SE1 8HU Room 410 Northcott House SE1 8JU Block A Flat 8 Peabody Square SE1 8HU Room 311 Northcott House SE1 8JU Block S Flat 12 Peabody Square SE1 8HT 3 Bell House 57 Webber Street SE1 0RF Block S Flat 5 Peabody Square SE1 8HT 6 Bell House 57 Webber Street SE1 0RF Block S Flat 6 Peabody Square SE1 8HT 7 Bell House 57 Webber Street SE1 0RF Block S Flat 3 Peabody Square SE1 8HT 4 Bell House 57 Webber Street SE1 0RF Block S Flat 4 Peabody Square SE1 8HT 5 Bell House 57 Webber Street SE1 0RF Block S Flat 7 Peabody Square SE1 8HT Room 308 Northcott House SE1 8JU Block S Flat 10 Peabody Square SE1 8HT Flat 701 Wellington Lodge SE1 8RQ Block S Flat 11 Peabody Square SE1 8HT Flat 702 Wellington Lodge SE1 8RQ Block S Flat 8 Peabody Square SE1 8HT Flat 604 Wellington Lodge SE1 8RQ Block S Flat 9 Peabody Square SE1 8HT Flat 605 Wellington Lodge SE1 8RQ Block C Flat 5 Peabody Square SE1 8HY Room 304 Northcott House SE1 8JU Block C Flat 6 Peabody Square SE1 8HY Room 209 Northcott House SE1 8JU Block C Flat 3 Peabody Square SE1 8HY Room 400 Northcott House SE1 8JU Block C Flat 4 Peabody Square SE1 8HY Room 310 Northcott House SE1 8JU Block C Flat 7 Peabody Square SE1 8HY Room 402 Northcott House SE1 8JU Block C Flat 10 Peabody Square SE1 8HY Room 40 32 Borough Road SE1 0AJ Block C Flat 11 Peabody Square SE1 8HY Room 41 32 Borough Road SE1 0AJ Block C Flat 8 Peabody Square SE1 8HY Room 39 32 Borough Road SE1 0AJ Block C Flat 9 Peabody Square SE1 8HY Room 4 32 Borough Road SE1 0AJ Block C Flat 2 Peabody Square SE1 8HY Room 42 32 Borough Road SE1 0AJ Block B Flat 4 Peabody Square SE1 8HX Room 45 32 Borough Road SE1 0AJ Block B Flat 5 Peabody Square SE1 8HX Room 46 32 Borough Road SE1 0AJ Block B Flat 2 Peabody Square SE1 8HX Room 43 32 Borough Road SE1 0AJ Block B Flat 3 Peabody Square SE1 8HX Room 44 32 Borough Road SE1 0AJ Block B Flat 6 Peabody Square SE1 8HX Room 38 32 Borough Road SE1 0AJ Block B Flat 9 Peabody Square SE1 8HX Room 31 32 Borough Road SE1 0AJ Block B Flat 10 Peabody Square SE1 8HX Room 32 32 Borough Road SE1 0AJ Block B Flat 7 Peabody Square SE1 8HX Room 3 32 Borough Road SE1 0AJ Block B Flat 8 Peabody Square SE1 8HX Room 30 32 Borough Road SE1 0AJ Flat 3 7 Westminster Bridge Road SE1 7XP Room 33 32 Borough Road SE1 0AJ Flat 4 7 Westminster Bridge Road SE1 7XP Room 36 32 Borough Road SE1 0AJ Flat 1 7 Westminster Bridge Road SE1 7XP Room 37 32 Borough Road SE1 0AJ Flat 2 7 Westminster Bridge Road SE1 7XP Room 34 32 Borough Road SE1 0AJ Flat 5 7 Westminster Bridge Road SE1 7XP Room 35 32 Borough Road SE1 0AJ Flat 8 7 Westminster Bridge Road SE1 7XP Room 58 32 Borough Road SE1 0AJ Flat 9 7 Westminster Bridge Road SE1 7XP Room 59 32 Borough Road SE1 0AJ Flat 6 7 Westminster Bridge Road SE1 7XP Room 56 32 Borough Road SE1 0AJ Flat 7 7 Westminster Bridge Road SE1 7XP Room 57 32 Borough Road SE1 0AJ Basement Flat 6 London Road SE1 6JZ Room 6 32 Borough Road SE1 0AJ Flat 15 6 Lambeth Road SE1 6HT Room 62 32 Borough Road SE1 0AJ Flat 16 6 Lambeth Road SE1 6HT Room 63 32 Borough Road SE1 0AJ 9 London Road London SE1 6JZ Room 60 32 Borough Road SE1 0AJ St Georges Cathedral Primary School 33 Westminster Room 61 32 Borough Road SE1 0AJ Bridge Road SE1 7JB 12 London Road London SE1 6JZ Room 55 32 Borough Road SE1 0AJ 13 London Road London SE1 6JZ Room 49 32 Borough Road SE1 0AJ 225 Waterloo Road London SE1 8XH Room 5 32 Borough Road SE1 0AJ 227-229 Waterloo Road London SE1 8XH Room 47 32 Borough Road SE1 0AJ 219 Waterloo Road London SE1 8XH Room 48 32 Borough Road SE1 0AJ 221 Waterloo Road London SE1 8XH Room 50 32 Borough Road SE1 0AJ 233 Waterloo Road London SE1 8XH Room 53 32 Borough Road SE1 0AJ Flat 1 Dauncy House Webber Row Estate SE1 8QS Room 54 32 Borough Road SE1 0AJ Flat 10 Dauncy House Webber Row Estate SE1 8QS Room 51 32 Borough Road SE1 0AJ Flat 1 235 Waterloo Road SE1 8XH Room 52 32 Borough Road SE1 0AJ Flat 1 Kynaston House SE1 8XH Room 29 32 Borough Road SE1 0AJ 217 Waterloo Road London SE1 8XH Room 11 32 Borough Road SE1 0AJ Flat 12 7 Westminster Bridge Road SE1 7XP Room 110 32 Borough Road SE1 0AJ Flat 13 7 Westminster Bridge Road SE1 7XP Room 108 32 Borough Road SE1 0AJ Flat 10 7 Westminster Bridge Road SE1 7XP Room 109 32 Borough Road SE1 0AJ Flat 11 7 Westminster Bridge Road SE1 7XP Room 111 32 Borough Road SE1 0AJ Flat 14 7 Westminster Bridge Road SE1 7XP Room 114 32 Borough Road SE1 0AJ 266 Waterloo Road London SE1 8RQ Room 115 32 Borough Road SE1 0AJ 215 Waterloo Road London SE1 8XH Room 112 32 Borough Road SE1 0AJ Flat 16 7 Westminster Bridge Road SE1 7XP Room 113 32 Borough Road SE1 0AJ The Crown 108 Blackfriars Road SE1 8HW Room 107 32 Borough Road SE1 0AJ Flat 14 6 Lambeth Road SE1 6HT Room 100 32 Borough Road SE1 0AJ 15 London Road London SE1 6JZ Room 101 32 Borough Road SE1 0AJ 6 London Road London SE1 6JZ Room 1 32 Borough Road SE1 0AJ 11 London Road London SE1 6JZ Room 10 32 Borough Road SE1 0AJ 14 London Road London SE1 6JZ Room 102 32 Borough Road SE1 0AJ 7 London Road London SE1 6JZ Room 105 32 Borough Road SE1 0AJ 132 London Road London SE1 6LF Room 106 32 Borough Road SE1 0AJ 10 London Road London SE1 6JZ Room 103 32 Borough Road SE1 0AJ 40 Gladstone Street London SE1 6EY Room 104 32 Borough Road SE1 0AJ 42 Gladstone Street London SE1 6EY Room 22 32 Borough Road SE1 0AJ 38 Gladstone Street London SE1 6EY Room 23 32 Borough Road SE1 0AJ 4 Gladstone Street London SE1 6EY Room 20 32 Borough Road SE1 0AJ 44 Gladstone Street London SE1 6EY Room 21 32 Borough Road SE1 0AJ 6 Gladstone Street London SE1 6EY Room 24 32 Borough Road SE1 0AJ 8 Gladstone Street London SE1 6EY Room 27 32 Borough Road SE1 0AJ 46 Gladstone Street London SE1 6EY Room 28 32 Borough Road SE1 0AJ 48 Gladstone Street London SE1 6EY Room 25 32 Borough Road SE1 0AJ Flat 7 6 Lambeth Road SE1 6HT Room 26 32 Borough Road SE1 0AJ Flat 8 6 Lambeth Road SE1 6HT Room 2 32 Borough Road SE1 0AJ Flat 5 6 Lambeth Road SE1 6HT Room 13 32 Borough Road SE1 0AJ Flat 6 6 Lambeth Road SE1 6HT Room 14 32 Borough Road SE1 0AJ Flat 9 6 Lambeth Road SE1 6HT Room 116 32 Borough Road SE1 0AJ Flat 12 6 Lambeth Road SE1 6HT Room 12 32 Borough Road SE1 0AJ Flat 13 6 Lambeth Road SE1 6HT Room 15 32 Borough Road SE1 0AJ Flat 10 6 Lambeth Road SE1 6HT Room 18 32 Borough Road SE1 0AJ Flat 11 6 Lambeth Road SE1 6HT Room 19 32 Borough Road SE1 0AJ Flat 4 6 Lambeth Road SE1 6HT Room 16 32 Borough Road SE1 0AJ 4-5 London Road London SE1 6JZ Room 17 32 Borough Road SE1 0AJ 131 London Road London SE1 6LF Flat 3 12 London Road SE1 6JZ 20 Gladstone Street London SE1 6EY 14 The Priory Webber Street SE1 0RQ 2-3 London Road London SE1 6JZ Flat 1 12 London Road SE1 6JZ 7a St Georges Circus London SE1 6HS Flat 2 12 London Road SE1 6JZ Flat 2 6 Lambeth Road SE1 6HT 15 The Priory Webber Street SE1 0RQ Flat 3 6 Lambeth Road SE1 6HT Unit 1 262 Waterloo Road SE1 8RQ 7b-7c St Georges Circus London SE1 6HS Unit 2 262 Waterloo Road SE1 8RQ Flat 1 6 Lambeth Road SE1 6HT Unit 1 And Unit 2 109-115 Blackfriars Road SE1 8HW Flat 16 Overy House Webber Row Estate SE1 8QX Unit 3 109-115 Blackfriars Road SE1 8HW Flat 17 Overy House Webber Row Estate SE1 8QX Second Floor Rooms 202 202b And 204 5-5a Westminster Bridge Road SE1 7XW Flat 14 Overy House Webber Row Estate SE1 8QX Flat 8 7-13 King James Street SE1 0RU Flat 15 Overy House Webber Row Estate SE1 8QX Flat 9 7-13 King James Street SE1 0RU Flat 18 Overy House Webber Row Estate SE1 8QX Flat 12 7-13 King James Street SE1 0RU Flat 20 Overy House Webber Row Estate SE1 8QX Flat 13 7-13 King James Street SE1 0RU Flat 21 Overy House Webber Row Estate SE1 8QX Flat 1 8 London Road SE1 6JZ Flat 19 Overy House Webber Row Estate SE1 8QX Part Basement And Ground Floor 5-5a Westminster Bridge Road SE1 7XW Flat 2 Overy House Webber Row Estate SE1 8QX First Floor Room 102 5-5a Westminster Bridge Road SE1 7XW Flat 13 Overy House Webber Row Estate SE1 8QX Flat 2 8 London Road SE1 6JZ Flat 8 Algar House Webber Row Estate SE1 8QT Flat 3 8 London Road SE1 6JZ Flat 9 Algar House Webber Row Estate SE1 8QT Flat 11 Polychrome Court SE1 8XH Flat 6 Algar House Webber Row Estate SE1 8QT Flat 12 Polychrome Court SE1 8XH Flat 7 Algar House Webber Row Estate SE1 8QT Flat 6 Polychrome Court SE1 8XH Centre For Language In Primary Education Webber Flat 10 Polychrome Court SE1 8XH Street SE1 8QW Flat 11 Overy House Webber Row Estate SE1 8QX Flat 7 Polychrome Court SE1 8XH Flat 12 Overy House Webber Row Estate SE1 8QX Ro 43 Webber Street SE1 0RF Flat 1 Overy House Webber Row Estate SE1 8QX Flat 4e 3 London Road SE1 6JZ Flat 10 Overy House Webber Row Estate SE1 8QX Flat 8 Polychrome Court SE1 8XH Flat 10 Mawdley House Webber Row Estate SE1 8XQ Flat 9 Polychrome Court SE1 8XH Flat 11 Mawdley House Webber Row Estate SE1 8XQ Flat 5 Polychrome Court SE1 8XH Flat 9 Overy House Webber Row Estate SE1 8QX David Barker Hostel 115a Blackfriars Road SE1 8HW Flat 1 Mawdley House Webber Row Estate SE1 8XQ Schoolkeepers Flat St Georges Cathedral Primary School SE1 6HU Flat 12 Mawdley House Webber Row Estate SE1 8XQ 1a The Priory Webber Street SE1 0RQ Flat 15 Mawdley House Webber Row Estate SE1 8XQ 46b Gladstone Street London SE1 6EY Flat 16 Mawdley House Webber Row Estate SE1 8XQ 2 Gladstone Street London SE1 6EY Flat 13 Mawdley House Webber Row Estate SE1 8XQ Flat 3 Polychrome Court SE1 8XH Flat 14 Mawdley House Webber Row Estate SE1 8XQ Flat 4 Polychrome Court SE1 8XH Flat 8 Overy House Webber Row Estate SE1 8QX Flat 1 Polychrome Court SE1 8XH Flat 24 Overy House Webber Row Estate SE1 8QX Flat 2 Polychrome Court SE1 8XH Flat 25 Overy House Webber Row Estate SE1 8QX Flat 11 7-13 King James Street SE1 0RU Flat 22 Overy House Webber Row Estate SE1 8QX Room 75 32 Borough Road SE1 0AJ Flat 23 Overy House Webber Row Estate SE1 8QX Room 76 32 Borough Road SE1 0AJ Flat 3 Overy House Webber Row Estate SE1 8QX Room 73 32 Borough Road SE1 0AJ Flat 6 Overy House Webber Row Estate SE1 8QX Room 74 32 Borough Road SE1 0AJ Flat 7 Overy House Webber Row Estate SE1 8QX Room 77 32 Borough Road SE1 0AJ Flat 4 Overy House Webber Row Estate SE1 8QX Room 8 32 Borough Road SE1 0AJ Flat 5 Overy House Webber Row Estate SE1 8QX Room 80 32 Borough Road SE1 0AJ Flat 5 Algar House Webber Row Estate SE1 8QT Room 78 32 Borough Road SE1 0AJ Flat 4 Dauncy House Webber Row Estate SE1 8QS Room 79 32 Borough Road SE1 0AJ Flat 5 Dauncy House Webber Row Estate SE1 8QS Room 72 32 Borough Road SE1 0AJ Flat 20 Dauncy House Webber Row Estate SE1 8QS Room 66 32 Borough Road SE1 0AJ Flat 3 Dauncy House Webber Row Estate SE1 8QS Room 67 32 Borough Road SE1 0AJ Flat 6 Dauncy House Webber Row Estate SE1 8QS Room 64 32 Borough Road SE1 0AJ Flat 9 Dauncy House Webber Row Estate SE1 8QS Room 65 32 Borough Road SE1 0AJ Flat 1 Algar House Webber Row Estate SE1 8QT Room 68 32 Borough Road SE1 0AJ Flat 7 Dauncy House Webber Row Estate SE1 8QS Room 70 32 Borough Road SE1 0AJ Flat 8 Dauncy House Webber Row Estate SE1 8QS Room 71 32 Borough Road SE1 0AJ Flat 2 Dauncy House Webber Row Estate SE1 8QS Room 69 32 Borough Road SE1 0AJ Flat 13 Dauncy House Webber Row Estate SE1 8QS Room 7 32 Borough Road SE1 0AJ Flat 14 Dauncy House Webber Row Estate SE1 8QS Room 93 32 Borough Road SE1 0AJ Flat 11 Dauncy House Webber Row Estate SE1 8QS Room 94 32 Borough Road SE1 0AJ Flat 12 Dauncy House Webber Row Estate SE1 8QS Room 90 32 Borough Road SE1 0AJ Flat 15 Dauncy House Webber Row Estate SE1 8QS Room 92 32 Borough Road SE1 0AJ Flat 18 Dauncy House Webber Row Estate SE1 8QS Room 95 32 Borough Road SE1 0AJ Flat 19 Dauncy House Webber Row Estate SE1 8QS Room 99 32 Borough Road SE1 0AJ Flat 16 Dauncy House Webber Row Estate SE1 8QS Flat 10 7-13 King James Street SE1 0RU Flat 17 Dauncy House Webber Row Estate SE1 8QS Room 96 32 Borough Road SE1 0AJ Flat 21 Algar House Webber Row Estate SE1 8QT Room 97 32 Borough Road SE1 0AJ Flat 22 Algar House Webber Row Estate SE1 8QT Room 9 32 Borough Road SE1 0AJ Flat 2 Algar House Webber Row Estate SE1 8QT Room 83 32 Borough Road SE1 0AJ Flat 20 Algar House Webber Row Estate SE1 8QT Room 84 32 Borough Road SE1 0AJ Flat 23 Algar House Webber Row Estate SE1 8QT Room 81 32 Borough Road SE1 0AJ Flat 3 Algar House Webber Row Estate SE1 8QT Room 82 32 Borough Road SE1 0AJ Flat 4 Algar House Webber Row Estate SE1 8QT Room 85 32 Borough Road SE1 0AJ Flat 24 Algar House Webber Row Estate SE1 8QT Room 88 32 Borough Road SE1 0AJ Flat 25 Algar House Webber Row Estate SE1 8QT Room 89 32 Borough Road SE1 0AJ Flat 19 Algar House Webber Row Estate SE1 8QT Room 86 32 Borough Road SE1 0AJ Flat 12 Algar House Webber Row Estate SE1 8QT Room 87 32 Borough Road SE1 0AJ Flat 13 Algar House Webber Row Estate SE1 8QT Flat A 33 Borough Road SE1 0AJ Flat 10 Algar House Webber Row Estate SE1 8QT Flat B 33 Borough Road SE1 0AJ Flat 11 Algar House Webber Row Estate SE1 8QT Flat N 31 Borough Road SE1 0AJ Flat 14 Algar House Webber Row Estate SE1 8QT Flat P 31 Borough Road SE1 0AJ Flat 17 Algar House Webber Row Estate SE1 8QT Flat C 33 Borough Road SE1 0AJ Flat 18 Algar House Webber Row Estate SE1 8QT Flat F 33 Borough Road SE1 0AJ Flat 15 Algar House Webber Row Estate SE1 8QT Flat G 33 Borough Road SE1 0AJ Flat 16 Algar House Webber Row Estate SE1 8QT Flat D 33 Borough Road SE1 0AJ Flat C 67 Lancaster Street SE1 0RZ Flat E 33 Borough Road SE1 0AJ Flat C 42 Davidge Street SE1 0RR Flat M 31 Borough Road SE1 0AJ Flat B 67 Lancaster Street SE1 0RZ Flat E 31 Borough Road SE1 0AJ Flat B 42 Davidge Street SE1 0RR Flat F 31 Borough Road SE1 0AJ Flat D 67 Lancaster Street SE1 0RZ Flat C 31 Borough Road SE1 0AJ Flat F 67 Lancaster Street SE1 0RZ Flat D 31 Borough Road SE1 0AJ Flat G 67 Lancaster Street SE1 0RZ Flat G 31 Borough Road SE1 0AJ Flat D 42 Davidge Street SE1 0RR Flat K 31 Borough Road SE1 0AJ Flat E 67 Lancaster Street SE1 0RZ Flat L 31 Borough Road SE1 0AJ Flat A 42 Davidge Street SE1 0RR Flat H 31 Borough Road SE1 0AJ Flat 4a 3 London Road SE1 6JZ Flat J 31 Borough Road SE1 0AJ Flat 4b 3 London Road SE1 6JZ Flat 7 Mathieson Court SE1 0SA Flat 3b 3 London Road SE1 6JZ Flat 8 Mathieson Court SE1 0SA Flat 3c 3 London Road SE1 6JZ Flat 5 Mathieson Court SE1 0SA Flat 4c 3 London Road SE1 6JZ Flat 6 Mathieson Court SE1 0SA Flat 5c 5 London Road SE1 6JZ Flat 9 Mathieson Court SE1 0SA Flat A 67 Lancaster Street SE1 0RZ Flat 12 Mathieson Court SE1 0SA Flat 5a 5 London Road SE1 6JZ Flat 13 Mathieson Court SE1 0SA Flat 5b 5 London Road SE1 6JZ Flat 10 Mathieson Court SE1 0SA Flat 2 Hunter House SE1 0AG Flat 11 Mathieson Court SE1 0SA 2 Delarch House Webber Row Estate Webber Row SE1 Flat 4 Mathieson Court SE1 0SA 8QU Flat 1 Hunter House SE1 0AG Flat K 33 Borough Road SE1 0AJ 1 Delarch House Webber Row Estate Webber Row SE1 Flat L 33 Borough Road SE1 0AJ 8QU Flat 3 Hunter House SE1 0AG Flat H 33 Borough Road SE1 0AJ 4 Delarch House Webber Row Estate Webber Row SE1 Flat J 33 Borough Road SE1 0AJ 8QU Flat 5 Hunter House SE1 0AG Flat M 33 Borough Road SE1 0AJ 3 Delarch House Webber Row Estate Webber Row SE1 Flat 2 Mathieson Court SE1 0SA 8QU Flat 4 Hunter House SE1 0AG Flat 3 Mathieson Court SE1 0SA Second Floor And Third Floor Flat 13 London Road SE1 Flat N 33 Borough Road SE1 0AJ 3TW Flat K 67 Lancaster Street SE1 0RZ Flat P 33 Borough Road SE1 0AJ Flat L 67 Lancaster Street SE1 0RZ Flat B 31 Borough Road SE1 0AJ Flat H 67 Lancaster Street SE1 0RZ Flat 9 Bazeley House SE1 0RN Flat J 67 Lancaster Street SE1 0RZ Flat 10 Bazeley House SE1 0RN Flat M 67 Lancaster Street SE1 0RZ Flat 7 Bazeley House SE1 0RN Flat Q 67 Lancaster Street SE1 0RZ Flat 8 Bazeley House SE1 0RN Flat R 67 Lancaster Street SE1 0RZ Flat 11 Bazeley House SE1 0RN Flat N 67 Lancaster Street SE1 0RZ Flat 14 Bazeley House SE1 0RN Flat P 67 Lancaster Street SE1 0RZ Flat 15 Bazeley House SE1 0RN Flat 3a 3 London Road SE1 6JZ Flat 12 Bazeley House SE1 0RN Flat 10 264 Waterloo Road SE1 8RP Flat 13 Bazeley House SE1 0RN Suite 203 And 204 154-156 Blackfriars Road SE1 8EN Flat 6 Bazeley House SE1 0RN Flat 8 264 Waterloo Road SE1 8RP 8 The Priory Webber Street SE1 0RQ Flat 9 264 Waterloo Road SE1 8RP 9 The Priory Webber Street SE1 0RQ Suite 308 154-156 Blackfriars Road SE1 8EN 6 The Priory Webber Street SE1 0RQ Block E Flat 11 Peabody Square SE1 8JG 7 The Priory Webber Street SE1 0RQ Flat 11 264 Waterloo Road SE1 8RP Flat 1 Bazeley House SE1 0RN Suite 112 To 133 154-156 Blackfriars Road SE1 8EN Flat 4 Bazeley House SE1 0RN Northcott House 259 Waterloo Road SE1 8JU Flat 5 Bazeley House SE1 0RN Flat 7 264 Waterloo Road SE1 8RP Flat 2 Bazeley House SE1 0RN Flat 7 Kynaston House SE1 8XH Flat 3 Bazeley House SE1 0RN Flat 1 264 Waterloo Road SE1 8RP Flat 28 Bazeley House SE1 0RN Flat 5 Kynaston House SE1 8XH Flat 29 Bazeley House SE1 0RN Flat 6 Kynaston House SE1 8XH Flat 26 Bazeley House SE1 0RN Flat 2 264 Waterloo Road SE1 8RP Flat 27 Bazeley House SE1 0RN Flat 5 264 Waterloo Road SE1 8RP Flat 30 Bazeley House SE1 0RN Flat 6 264 Waterloo Road SE1 8RP Milcote House Milcote Street SE1 0RX Flat 3 264 Waterloo Road SE1 8RP Flat A 31 Borough Road SE1 0AJ Flat 4 264 Waterloo Road SE1 8RP Flat 31 Bazeley House SE1 0RN First Floor And Second Floor Flat 16a London Road Flat 32 Bazeley House SE1 0RN SE1 6JZ First Floor Flat 13 London Road SE1 6JZ Flat 25 Bazeley House SE1 0RN First Floor And Second Floor Flat 15 London Road SE1 Flat 18 Bazeley House SE1 0RN 6JZ First Floor And Second Floor Flat 15a London Road Flat 19 Bazeley House SE1 0RN SE1 6JZ First Floor Flat 8 London Road SE1 6JZ Flat 16 Bazeley House SE1 0RN Flat 2b 3 London Road SE1 6JZ Flat 17 Bazeley House SE1 0RN Flat 2c 3 London Road SE1 6JZ Flat 20 Bazeley House SE1 0RN Flat 15 7 Westminster Bridge Road SE1 7XP Flat 23 Bazeley House SE1 0RN Flat 2a 3 London Road SE1 6JZ Flat 24 Bazeley House SE1 0RN Professors Flat Mclaren House SE1 0AP Flat 21 Bazeley House SE1 0RN 239 Waterloo Road London SE1 8XH Flat 22 Bazeley House SE1 0RN Flat 12 264 Waterloo Road SE1 8RP Gateway Training Centre 66 Lancaster Street SE1 0RZ 9a London Road London SE1 6JZ 32 Borough Road London SE1 0AJ Assistant Hall Managers Flat Mclaren House SE1 0AP Flat 31 Hugh Astor Court SE1 0DD Hall Managers Flat Mclaren House SE1 0AP Flat 32 Hugh Astor Court SE1 0DD 9b London Road London SE1 6JZ Flat 1 7-13 King James Street SE1 0RU Flowers Of The Forest 14-18a Westminster Bridge Road Flat 4 7-13 King James Street SE1 0RU SE1 7QX Childrens Play Centre Tadworth House Lancaster Flat 5 7-13 King James Street SE1 0RU Estate SE1 0RH Ground Floor And First Floor 1-3 Westminster Bridge Flat 2 7-13 King James Street SE1 0RU Road SE1 7PL Ground Floor 119-122 London Road SE1 6LF Flat 3 7-13 King James Street SE1 0RU First Floor 119-122 London Road SE1 6LF Flat 30 Hugh Astor Court SE1 0DD Second Floor 1-3 Westminster Bridge Road SE1 7PL Flat 23 Hugh Astor Court SE1 0DD First Floor Rooms 101 And 114 To 117 5-5a Flat 24 Hugh Astor Court SE1 0DD Westminster Bridge Road SE1 7XW First Floor Room 106 5-5a Westminster Bridge Road Flat 21 Hugh Astor Court SE1 0DD SE1 7XW Part Ground Floor And Third Floor 1-3 Westminster Flat 22 Hugh Astor Court SE1 0DD Bridge Road SE1 7PL Part Basement 5-5a Westminster Bridge Road SE1 Flat 25 Hugh Astor Court SE1 0DD 7XW Ground Floor 15 London Road SE1 6JZ Flat 28 Hugh Astor Court SE1 0DD Unit 5 109-115 Blackfriars Road SE1 8HW Flat 29 Hugh Astor Court SE1 0DD Hill House 133-150 Blackfriars Road SE1 8DB Flat 26 Hugh Astor Court SE1 0DD Flat 29 Hunter House SE1 0AG Flat 27 Hugh Astor Court SE1 0DD Flat 30 Hunter House SE1 0AG 22 Gladstone Street London SE1 6EY 156 Blackfriars Road London SE1 8EN 24 Gladstone Street London SE1 6EY Endsleigh Insurance Student Union Shopping Mall SE1 16 Gladstone Street London SE1 6EY 6NG Neighbourhood Housing Office Library Street SE1 0RN 18 Gladstone Street London SE1 6EY Ground Floor 32 Borough Road SE1 0AJ 26 Gladstone Street London SE1 6EY Campus Travel Student Union Shopping Mall SE1 6NG 32 Gladstone Street London SE1 6EY 67 Lancaster Street London SE1 0RZ 34 Gladstone Street London SE1 6EY First Floor Rooms 110 And 113 5-5a Westminster 28 Gladstone Street London SE1 6EY Bridge Road SE1 7XW Second Floor Rooms 202a 203 206 209 And 210 5-5a 30 Gladstone Street London SE1 6EY Westminster Bridge Road SE1 7XW First Floor Room 107 5-5a Westminster Bridge Road 14 Gladstone Street London SE1 6EY SE1 7XW First Floor Room 109 5-5a Westminster Bridge Road 30 Borough Road London SE1 0AJ SE1 7XW Second Floor Room 205 5-5a Westminster Bridge Road 60 Lancaster Street London SE1 0RY SE1 7XW Fourth Floor 5-5a Westminster Bridge Road SE1 7XW Flat 6 7-13 King James Street SE1 0RU Third Floor Rooms 304 And 307 To 309 5-5a Mclaren House 1 St Georges Circus SE1 0AP Westminster Bridge Road SE1 7XW Third Floor Rooms 301 And 310 To 313 5-5a 43 Webber Street London SE1 0RF Westminster Bridge Road SE1 7XW Flat 28 Hunter House SE1 0AG 10 Gladstone Street London SE1 6EY 11 Delarch House Webber Row Estate Webber Row 12 Gladstone Street London SE1 6EY SE1 8QU Flat 12 Hunter House SE1 0AG 7-12 Borough Road London SE1 0AN 10 Delarch House Webber Row Estate Webber Row 44-50 Lancaster Street London SE1 0SJ SE1 8QU Flat 11 Hunter House SE1 0AG Flat 19 Hugh Astor Court SE1 0DD 12 Delarch House Webber Row Estate Webber Row Flat 26 Mathieson Court SE1 0SA SE1 8QU Flat 14 Hunter House SE1 0AG Flat 27 Mathieson Court SE1 0SA 14 Delarch House Webber Row Estate Webber Row Flat 24 Mathieson Court SE1 0SA SE1 8QU Flat 13 Hunter House SE1 0AG Flat 25 Mathieson Court SE1 0SA 13 Delarch House Webber Row Estate Webber Row Flat 28 Mathieson Court SE1 0SA SE1 8QU Flat 10 Hunter House SE1 0AG Flat 31 Mathieson Court SE1 0SA 6 Delarch House Webber Row Estate Webber Row SE1 Flat 32 Mathieson Court SE1 0SA 8QU Flat 7 Hunter House SE1 0AG Flat 29 Mathieson Court SE1 0SA 5 Delarch House Webber Row Estate Webber Row SE1 Flat 30 Mathieson Court SE1 0SA 8QU Flat 6 Hunter House SE1 0AG Flat 23 Mathieson Court SE1 0SA 7 Delarch House Webber Row Estate Webber Row SE1 Flat 16 Mathieson Court SE1 0SA 8QU Flat 9 Hunter House SE1 0AG Flat 17 Mathieson Court SE1 0SA 9 Delarch House Webber Row Estate Webber Row SE1 Flat 14 Mathieson Court SE1 0SA 8QU Flat 8 Hunter House SE1 0AG Flat 15 Mathieson Court SE1 0SA 8 Delarch House Webber Row Estate Webber Row SE1 Flat 18 Mathieson Court SE1 0SA 8QU Flat 21 Hunter House SE1 0AG Flat 21 Mathieson Court SE1 0SA Flat 22 Hunter House SE1 0AG Flat 22 Mathieson Court SE1 0SA Flat 20 Hunter House SE1 0AG Flat 19 Mathieson Court SE1 0SA 20 Delarch House Webber Row Estate Webber Row Flat 20 Mathieson Court SE1 0SA SE1 8QU Flat 23 Hunter House SE1 0AG Flat 12 Hugh Astor Court SE1 0BP Flat 26 Hunter House SE1 0AG Flat 13 Hugh Astor Court SE1 0BP Flat 27 Hunter House SE1 0AG Flat 10 Hugh Astor Court SE1 0BP Flat 24 Hunter House SE1 0AG Flat 11 Hugh Astor Court SE1 0BP Flat 25 Hunter House SE1 0AG Flat 14 Hugh Astor Court SE1 0BP 19 Delarch House Webber Row Estate Webber Row Flat 17 Hugh Astor Court SE1 0BP SE1 8QU Flat 16 Hunter House SE1 0AG Flat 18 Hugh Astor Court SE1 0BP 16 Delarch House Webber Row Estate Webber Row Flat 15 Hugh Astor Court SE1 0BP SE1 8QU Flat 15 Hunter House SE1 0AG Flat 16 Hugh Astor Court SE1 0BP 15 Delarch House Webber Row Estate Webber Row Flat 9 Hugh Astor Court SE1 0BP SE1 8QU Flat 17 Hunter House SE1 0AG Flat 2 Hugh Astor Court SE1 0BP 18 Delarch House Webber Row Estate Webber Row Flat 3 Hugh Astor Court SE1 0BP SE1 8QU Flat 19 Hunter House SE1 0AG Flat 20 Hugh Astor Court SE1 0DD 17 Delarch House Webber Row Estate Webber Row Flat 1 Hugh Astor Court SE1 0BP SE1 8QU Flat 18 Hunter House SE1 0AG Flat 4 Hugh Astor Court SE1 0BP Block I Flat 14 Peabody Square SE1 8JL Flat 7 Hugh Astor Court SE1 0BP Block J Flat 2 Peabody Square SE1 8JN Flat 8 Hugh Astor Court SE1 0BP Block I Flat 12 Peabody Square SE1 8JL Flat 5 Hugh Astor Court SE1 0BP Block I Flat 13 Peabody Square SE1 8JL Flat 6 Hugh Astor Court SE1 0BP Block J Flat 3 Peabody Square SE1 8JN Flat 6 Brookwood House Lancaster Estate SE1 0RJ Block J Flat 6 Peabody Square SE1 8JN Flat 7 Brookwood House Lancaster Estate SE1 0RJ Block J Flat 7 Peabody Square SE1 8JN Flat 4 Brookwood House Lancaster Estate SE1 0RJ Block J Flat 4 Peabody Square SE1 8JN Flat 5 Brookwood House Lancaster Estate SE1 0RJ Block J Flat 5 Peabody Square SE1 8JN Flat 8 Brookwood House Lancaster Estate SE1 0RJ Block I Flat 11 Peabody Square SE1 8JL Flat 10 Markstone House SE1 0RL Block I Flat 4 Peabody Square SE1 8JL Flat 11 Markstone House SE1 0RL Block I Flat 5 Peabody Square SE1 8JL Flat 9 Brookwood House Lancaster Estate SE1 0RJ Block I Flat 2 Peabody Square SE1 8JL Flat 1 Markstone House SE1 0RL Block I Flat 3 Peabody Square SE1 8JL Flat 3 Brookwood House Lancaster Estate SE1 0RJ Block I Flat 6 Peabody Square SE1 8JL Flat 19 Brookwood House Lancaster Estate SE1 0RJ Block I Flat 9 Peabody Square SE1 8JL Flat 2 Brookwood House Lancaster Estate SE1 0RJ Block I Flat 10 Peabody Square SE1 8JL Flat 17 Brookwood House Lancaster Estate SE1 0RJ Block I Flat 7 Peabody Square SE1 8JL Flat 18 Brookwood House Lancaster Estate SE1 0RJ Block I Flat 8 Peabody Square SE1 8JL Flat 20 Brookwood House Lancaster Estate SE1 0RJ Block M Flat 10 Peabody Square SE1 8JP Flat 23 Brookwood House Lancaster Estate SE1 0RJ Block M Flat 11 Peabody Square SE1 8JP Flat 24 Brookwood House Lancaster Estate SE1 0RJ Block M Flat 8 Peabody Square SE1 8JP Flat 21 Brookwood House Lancaster Estate SE1 0RJ Block M Flat 9 Peabody Square SE1 8JP Flat 22 Brookwood House Lancaster Estate SE1 0RJ Block F Flat 2 Peabody Square SE1 8JQ Flat 23 Markstone House SE1 0RL Block F Flat 5 Peabody Square SE1 8JQ Flat 24 Markstone House SE1 0RL Block F Flat 6 Peabody Square SE1 8JQ Flat 21 Markstone House SE1 0RL Block F Flat 3 Peabody Square SE1 8JQ Flat 22 Markstone House SE1 0RL Block F Flat 4 Peabody Square SE1 8JQ Flat 25 Markstone House SE1 0RL Block M Flat 7 Peabody Square SE1 8JP Flat 28 Markstone House SE1 0RL Block J Flat 10 Peabody Square SE1 8JN Flat 29 Markstone House SE1 0RL Block J Flat 11 Peabody Square SE1 8JN Flat 26 Markstone House SE1 0RL Block J Flat 8 Peabody Square SE1 8JN Flat 27 Markstone House SE1 0RL Block J Flat 9 Peabody Square SE1 8JN Flat 20 Markstone House SE1 0RL Block M Flat 2 Peabody Square SE1 8JP Flat 14 Markstone House SE1 0RL Block M Flat 5 Peabody Square SE1 8JP Flat 15 Markstone House SE1 0RL Block M Flat 6 Peabody Square SE1 8JP Flat 12 Markstone House SE1 0RL Block M Flat 3 Peabody Square SE1 8JP Flat 13 Markstone House SE1 0RL Block M Flat 4 Peabody Square SE1 8JP Flat 16 Markstone House SE1 0RL Block H Flat 11 Peabody Square SE1 8JJ Flat 19 Markstone House SE1 0RL Block E Flat 4 Peabody Square SE1 8JG Flat 2 Markstone House SE1 0RL Block E Flat 5 Peabody Square SE1 8JG Flat 17 Markstone House SE1 0RL Block E Flat 2 Peabody Square SE1 8JG Flat 18 Markstone House SE1 0RL Block E Flat 3 Peabody Square SE1 8JG Flat 16 Brookwood House Lancaster Estate SE1 0RJ Block E Flat 6 Peabody Square SE1 8JG Flat 17 Tadworth House Lancaster Estate SE1 0RH Block E Flat 9 Peabody Square SE1 8JG Flat 18 Tadworth House Lancaster Estate SE1 0RH Block E Flat 10 Peabody Square SE1 8JG Flat 15 Tadworth House Lancaster Estate SE1 0RH Block E Flat 7 Peabody Square SE1 8JG Flat 16 Tadworth House Lancaster Estate SE1 0RH Block E Flat 8 Peabody Square SE1 8JG Flat 19 Tadworth House Lancaster Estate SE1 0RH Block R Flat 11 Peabody Square SE1 8JF Flat 21 Tadworth House Lancaster Estate SE1 0RH Block R Flat 4 Peabody Square SE1 8JF Flat 22 Tadworth House Lancaster Estate SE1 0RH Block R Flat 5 Peabody Square SE1 8JF Flat 2 Tadworth House Lancaster Estate SE1 0RH Block R Flat 2 Peabody Square SE1 8JF Flat 20 Tadworth House Lancaster Estate SE1 0RH Block R Flat 3 Peabody Square SE1 8JF Flat 14 Tadworth House Lancaster Estate SE1 0RH Block R Flat 6 Peabody Square SE1 8JF 3 Gardiner House Borough Road Estate Borough Road SE1 0AQ Block R Flat 9 Peabody Square SE1 8JF 4 Gardiner House Borough Road Estate Borough Road SE1 0AQ Block R Flat 10 Peabody Square SE1 8JF 1 Gardiner House Borough Road Estate Borough Road SE1 0AQ Block R Flat 7 Peabody Square SE1 8JF 2 Gardiner House Borough Road Estate Borough Road SE1 0AQ Block R Flat 8 Peabody Square SE1 8JF Flat 1 Tadworth House Lancaster Estate SE1 0RH Block H Flat 4 Peabody Square SE1 8JJ Flat 12 Tadworth House Lancaster Estate SE1 0RH Block H Flat 5 Peabody Square SE1 8JJ Flat 13 Tadworth House Lancaster Estate SE1 0RH Block H Flat 2 Peabody Square SE1 8JJ Flat 10 Tadworth House Lancaster Estate SE1 0RH Block H Flat 3 Peabody Square SE1 8JJ Flat 11 Tadworth House Lancaster Estate SE1 0RH Block H Flat 6 Peabody Square SE1 8JJ Flat 1 Brookwood House Lancaster Estate SE1 0RJ Block H Flat 9 Peabody Square SE1 8JJ Flat 10 Brookwood House Lancaster Estate SE1 0RJ Block H Flat 10 Peabody Square SE1 8JJ Flat 8 Tadworth House Lancaster Estate SE1 0RH Block H Flat 7 Peabody Square SE1 8JJ Flat 9 Tadworth House Lancaster Estate SE1 0RH Block H Flat 8 Peabody Square SE1 8JJ Flat 11 Brookwood House Lancaster Estate SE1 0RJ Block G Flat 11 Peabody Square SE1 8JH Flat 14 Brookwood House Lancaster Estate SE1 0RJ Block G Flat 4 Peabody Square SE1 8JH Flat 15 Brookwood House Lancaster Estate SE1 0RJ Block G Flat 5 Peabody Square SE1 8JH Flat 12 Brookwood House Lancaster Estate SE1 0RJ Block G Flat 2 Peabody Square SE1 8JH Flat 13 Brookwood House Lancaster Estate SE1 0RJ Block G Flat 3 Peabody Square SE1 8JH Flat 7 Tadworth House Lancaster Estate SE1 0RH Block G Flat 6 Peabody Square SE1 8JH Flat 25 Tadworth House Lancaster Estate SE1 0RH Block G Flat 9 Peabody Square SE1 8JH Flat 26 Tadworth House Lancaster Estate SE1 0RH Block G Flat 10 Peabody Square SE1 8JH Flat 23 Tadworth House Lancaster Estate SE1 0RH Block G Flat 7 Peabody Square SE1 8JH Flat 24 Tadworth House Lancaster Estate SE1 0RH Block G Flat 8 Peabody Square SE1 8JH Flat 27 Tadworth House Lancaster Estate SE1 0RH Suite 107 154-156 Blackfriars Road SE1 8EN Flat 5 Tadworth House Lancaster Estate SE1 0RH Suite 106 154-156 Blackfriars Road SE1 8EN Flat 6 Tadworth House Lancaster Estate SE1 0RH Suite G02 154-156 Blackfriars Road SE1 8EN Flat 3 Tadworth House Lancaster Estate SE1 0RH Suite 109 154-156 Blackfriars Road SE1 8EN Flat 4 Tadworth House Lancaster Estate SE1 0RH Suite 105 154-156 Blackfriars Road SE1 8EN Flat 16 Albury Buildings SE1 0SB Suite 206 154-156 Blackfriars Road SE1 8EN Flat 17 Albury Buildings SE1 0SB Suite G07 154-156 Blackfriars Road SE1 8EN Flat 14 Albury Buildings SE1 0SB Suite 104 154-156 Blackfriars Road SE1 8EN Flat 15 Albury Buildings SE1 0SB Suite 208 154-156 Blackfriars Road SE1 8EN Flat 18 Albury Buildings SE1 0SB Suite 201 154-156 Blackfriars Road SE1 8EN Flat 20 Albury Buildings SE1 0SB 284-302 Waterloo Road London SE1 8RQ Flat 21 Albury Buildings SE1 0SB Suite 301 154-156 Blackfriars Road SE1 8EN Flat 19 Albury Buildings SE1 0SB Block D Estate Office Peabody Square SE1 8HZ Flat 2 Albury Buildings SE1 0SB Suite 306 154-156 Blackfriars Road SE1 8EN Flat 13 Albury Buildings SE1 0SB 231 Waterloo Road London SE1 8XH Flat 8 Lingfield House Lancaster Estate SE1 0RW Suite 210 154-156 Blackfriars Road SE1 8EN Flat 9 Lingfield House Lancaster Estate SE1 0RW Suite 303 To 307 154-156 Blackfriars Road SE1 8EN Flat 6 Lingfield House Lancaster Estate SE1 0RW Suite 213 154-156 Blackfriars Road SE1 8EN Flat 7 Lingfield House Lancaster Estate SE1 0RW Suite 309 154-156 Blackfriars Road SE1 8EN Flat 1 Mathieson Court SE1 0SA Flat 4 235 Waterloo Road SE1 8XH Flat 11 Albury Buildings SE1 0SB Flat 2 237 Waterloo Road SE1 8XH Flat 12 Albury Buildings SE1 0SB Flat 2 235 Waterloo Road SE1 8XH Flat 1 Albury Buildings SE1 0SB Flat 3 235 Waterloo Road SE1 8XH Flat 10 Albury Buildings SE1 0SB Flat 3 237 Waterloo Road SE1 8XH 11 The Priory Webber Street SE1 0RQ Flat 3 Kynaston House SE1 8XH 12 The Priory Webber Street SE1 0RQ Flat 4 Kynaston House SE1 8XH 1 The Priory Webber Street SE1 0RQ Flat 4 237 Waterloo Road SE1 8XH 10 The Priory Webber Street SE1 0RQ Flat 2 Kynaston House SE1 8XH 13 The Priory Webber Street SE1 0RQ Suite 305 154-156 Blackfriars Road SE1 8EN 4 The Priory Webber Street SE1 0RQ Suite G03 And G04 154-156 Blackfriars Road SE1 8EN 5 The Priory Webber Street SE1 0RQ Suite 101 154-156 Blackfriars Road SE1 8EN 2 The Priory Webber Street SE1 0RQ Health Centre 151-153 Blackfriars Road SE1 8EL 3 The Priory Webber Street SE1 0RQ Suite 200b 154-156 Blackfriars Road SE1 8EN Flat 9 Albury Buildings SE1 0SB Suite 108 154-156 Blackfriars Road SE1 8EN Flat 24 Albury Buildings SE1 0SB Suite 113 154-156 Blackfriars Road SE1 8EN Flat 3 Albury Buildings SE1 0SB Suite 212 154-156 Blackfriars Road SE1 8EN Flat 22 Albury Buildings SE1 0SB Suite 200a 154-156 Blackfriars Road SE1 8EN Flat 23 Albury Buildings SE1 0SB Flat 1 237 Waterloo Road SE1 8XH Flat 4 Albury Buildings SE1 0SB Erlang House 128 Blackfriars Road SE1 8EQ Flat 7 Albury Buildings SE1 0SB Block N Flat 9 Peabody Square SE1 8JR Flat 8 Albury Buildings SE1 0SB Block N Flat 10 Peabody Square SE1 8JR Flat 5 Albury Buildings SE1 0SB Block N Flat 7 Peabody Square SE1 8JR Flat 6 Albury Buildings SE1 0SB Block N Flat 8 Peabody Square SE1 8JR Flat 5 Lingfield House Lancaster Estate SE1 0RW Block N Flat 11 Peabody Square SE1 8JR Flat 11 Lingfield House Lancaster Estate SE1 0RW Block K Flat 4 Peabody Square SE1 8JW Flat 12 Lingfield House Lancaster Estate SE1 0RW Block K Flat 5 Peabody Square SE1 8JW Flat 1 Lingfield House Lancaster Estate SE1 0RW Block K Flat 2 Peabody Square SE1 8JW Flat 10 Lingfield House Lancaster Estate SE1 0RW Block K Flat 3 Peabody Square SE1 8JW Flat 13 Lingfield House Lancaster Estate SE1 0RW Block N Flat 6 Peabody Square SE1 8JR Flat 16 Lingfield House Lancaster Estate SE1 0RW Block F Flat 9 Peabody Square SE1 8JQ Flat 17 Lingfield House Lancaster Estate SE1 0RW Block F Flat 10 Peabody Square SE1 8JQ Flat 14 Lingfield House Lancaster Estate SE1 0RW Block F Flat 7 Peabody Square SE1 8JQ Flat 15 Lingfield House Lancaster Estate SE1 0RW Block F Flat 8 Peabody Square SE1 8JQ Flat 9 Markstone House SE1 0RL Block F Flat 11 Peabody Square SE1 8JQ Flat 31 Markstone House SE1 0RL Block N Flat 4 Peabody Square SE1 8JR Flat 32 Markstone House SE1 0RL Block N Flat 5 Peabody Square SE1 8JR Flat 3 Markstone House SE1 0RL Block N Flat 2 Peabody Square SE1 8JR Flat 30 Markstone House SE1 0RL Block N Flat 3 Peabody Square SE1 8JR Flat 4 Markstone House SE1 0RL Suite 110 154-156 Blackfriars Road SE1 8EN Flat 7 Markstone House SE1 0RL Suite G05 154-156 Blackfriars Road SE1 8EN Flat 8 Markstone House SE1 0RL Suite 311 154-156 Blackfriars Road SE1 8EN Flat 5 Markstone House SE1 0RL Suite 304 154-156 Blackfriars Road SE1 8EN Flat 6 Markstone House SE1 0RL Suite G06 154-156 Blackfriars Road SE1 8EN Flat 29 Lingfield House Lancaster Estate SE1 0RW 223 Waterloo Road London SE1 8XH Flat 3 Lingfield House Lancaster Estate SE1 0RW Suite 209 154-156 Blackfriars Road SE1 8EN Flat 27 Lingfield House Lancaster Estate SE1 0RW Suite 111 154-156 Blackfriars Road SE1 8EN Flat 28 Lingfield House Lancaster Estate SE1 0RW 154-156 Blackfriars Road London SE1 8EN Flat 30 Lingfield House Lancaster Estate SE1 0RW Block K Flat 8 Peabody Square SE1 8JW Flat 33 Lingfield House Lancaster Estate SE1 0RW Block K Flat 9 Peabody Square SE1 8JW Flat 4 Lingfield House Lancaster Estate SE1 0RW Block K Flat 6 Peabody Square SE1 8JW Flat 31 Lingfield House Lancaster Estate SE1 0RW Block K Flat 7 Peabody Square SE1 8JW Flat 32 Lingfield House Lancaster Estate SE1 0RW Block K Flat 10 Peabody Square SE1 8JW Flat 26 Lingfield House Lancaster Estate SE1 0RW Suite 103 154-156 Blackfriars Road SE1 8EN Flat 2 Lingfield House Lancaster Estate SE1 0RW Suite 207 154-156 Blackfriars Road SE1 8EN Flat 20 Lingfield House Lancaster Estate SE1 0RW Block K Flat 11 Peabody Square SE1 8JW Flat 18 Lingfield House Lancaster Estate SE1 0RW Suite 102 154-156 Blackfriars Road SE1 8EN Flat 19 Lingfield House Lancaster Estate SE1 0RW 36 Gladstone Street London SE1 6EY Flat 21 Lingfield House Lancaster Estate SE1 0RW Unit A 46 Webber Street SE1 8QW Flat 24 Lingfield House Lancaster Estate SE1 0RW Unit B 46 Webber Street SE1 8QW Flat 25 Lingfield House Lancaster Estate SE1 0RW 15 Library Street SE1 0FJ Flat 22 Lingfield House Lancaster Estate SE1 0RW 17 Library Street London SE1 0FJ Flat 23 Lingfield House Lancaster Estate SE1 0RW Unit C 46 Webber Street SE1 8QW 3 Metropolis 1 Oswin Street SE11 4TF Email X

Re-consultation: 23/10/2014

APPENDIX 2

Consultation Responses Received

Internal services

Ecology Officer Environmental Protection Team [Noise / Air Quality / Land Contamination / Ventilation] Highway Development Management Surface Water Flood Management Team

Statutory and non-statutory organisations

Arqiva - digital communications BAA City of Westminster Dept. for Communities & Local Government [Referrals under T&CP (Consultation)(England) Direction 2009 -for London only- as per Annex B of Chief Planner's letter 10 March 2011 - see details on Xdrive] English Heritage Environment Agency Greater London Authority Historic Royal Palaces, HM Tower of London London Borough of Lambeth Natural England - London Region & South East Region Network Rail (Planning) Thames Water - Development Planning The Georgian Group Transport for London (referable & non-referable app notifications and pre-apps)

Neighbours and local groups

Bdp 16 Brewhouse Yard EC1V 4LJ By Email, Flat 20, 59 Waterloo Mansions SE1 0RD By Email Flat 15 SE1 0RH By Email Flat 26 SE1 0RN By Email Flat 78 SE1 0LT By Email 15 Gladstone Street SE1 6EY By Email 23 Gladstone Street SE1 6EY By Email 46 Gladstone Street SE1 6EY By Email 6 Colnbrook SE1 6EZ Email X Email representation Flat 12 Murphy House Borough Road Estate SE1 0AH Flat 17 59 Waterloo Mansions SE1 0RD Flat 20 Markstone House SE1 0RL Flat 20 Muro Court SE1 0FH Flat 22 Muro Court SE1 0FH Flat 5 Markstone House SE1 0RL 14 Overy House Webber Row SE1 8QX 15 Gladstone Street London SE1 6EY 18 Conbrook Street London SE1 6EZ 18 Gladstone Street London SE1 6EY 28 Gladstone Street London SE1 6EY 28 Muro Court Milcote Street SE1 0FH 30 Gladstone Street London SE1 6EY 33 Styles House Hatfields SE1 8DF 4 Dauncy House Webber Row SE1 8QS 41 West Square London SE11 4SP 45 Styles House The Cut SE1 8DF 5 Colnbrook Street London SE1 6EZ