planning report D&P/4158/02 9 April 2018 Camden Goods Yard in the London Borough of Camden planning application no. 2017/3847/P

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

The proposal Redevelopment of the petrol filling station site to provide a 6 storey building comprising a replacement petrol filling station, retail and office uses. Redevelopment of the main supermarket site to include the erection of seven buildings ranging in height up to 14 storeys accommodating up to 573 residential units together with a supermarket, retail, offices and workshops, and a community centre.

The applicant The applicant is Safeway Stores Ltd and BDW Trading Ltd, the architect is Allies & Morrison.

Key dates Pre-application: 13 December 2016 Stage 1 report: 23 August 2017 Council’s committee meeting: 23 November 2017

Strategic issues summary Principle of development: The principle of the redevelopment of this underutilised site for residential-led mixed uses is strongly supported. Full details of the affordable workspace package has been secured within the section 106 agreement. Affordable housing: The proposed 39% provision of affordable housing by habitable room (40% with grant) is fully supported. An early implementation review has been secured within the section 106 in accordance with the requirements of the ‘Fast Track Route’ in the Mayor’s Affordable Housing and Viability SPG and Policy H6 of the draft London Plan. Transport: All issues have been resolved and the necessary conditions and obligations secured.

Outstanding issues relating to urban design, inclusive design, noise, climate change and drainage and air quality have been resolved.

The Council’s decision In this instance, Camden Council has resolved to grant planning permission.

Recommendation That Camden Council be advised that the Mayor is content for it to determine the case itself, subject to any action that the Secretary of State may take, and does not therefore wish to direct refusal.

page 1 Context

1 On 14 July 2017 the Mayor of London received documents from Camden Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. This was referred to the Mayor under Category 1A, 1B and 1C of the Schedule to the Order 2008:

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

• 1B “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings outside Central London and with a total floorspace of more than 15,000 square metres.”

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

2 On 23 August 2017 the Mayor considered planning report D&P/4158/01, and subsequently advised Camden Council that the application did not comply with the London Plan, for the reasons set out in paragraph 76 of the above-mentioned report; but that the possible remedies set out in the report could address these deficiencies. A copy of the above-mentioned report is attached. The essentials of the case with regard to the proposal, the site, case history, strategic planning issues and relevant policies and guidance are as set out therein, unless otherwise stated in this report.

3 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (as amended) has been taken into account in the consideration of this case.

4 On 23 November 2017 Camden Council planning committee resolved to grant planning permission subject to conditions, obligations and informatives and also subject to any referral and/or direction made by the Mayor of London and/or any referral to the Secretary of State. On 5 March 2018 Camden Council advised the Mayor of this decision and section 106 negotiations have taken place since. Under the provisions of Article 5 of the Town & Country Planning (Mayor of London) Order 2008 the Mayor may allow the draft decision to proceed unchanged or direct Camden Council under Article 6 to refuse the application. The Mayor has until 9 April 2018 to notify Camden Council of his decision and to issue any direction.

5 The decision on this case and the reasons will be made available on the GLA’s website www.london.gov.uk.

Consultation stage issues summary

6 At the consultation stage, Camden Council was advised that the application did not comply with the London Plan, for the reasons set out below. The resolution of these issues could, nevertheless, lead to the application becoming compliant with the London Plan.

• Principle of development: Full details of the affordable workspace must be agreed and secured in the s106 agreement. • Affordable housing: The proposed 39% provision of affordable housing by habitable room is supported as a starting point; however, the applicant must fully investigate the provision of grant funding (and any other available public subsidy) in accordance with London Plan Policy 3.12 and the Affordable Housing and Viability SPG and an early stage review also needs to be included within the s106.

page 2 • Urban design: Blank frontages to servicing areas and its relationship with the public realm need to be addressed; the design of Block E1 in respect of the ground floor and the provision of shared amenity space should be reconsidered; reconfiguring the ramp to Block F is required; and amendments are required to reduce the sense of enclosure in certain parts of the development. • Inclusive design: Concerns regarding the shared spaces will need to be addressed; the sizes of public lifts confirmed; the design of stepped and ramp access routes; the proportion of disabled bays provided; the provision of a ‘changing places toilet’; upgrading some of the lifts to fire evacuation lifts; and comments regarding wheelchair accessible units addressed. • Noise: The noise and vibration assessment should be revised in consultation with nearby entertainment/ cultural venues so that the sufficiency of the acoustic and vibration mitigation measures can be verified in line with the ‘agent of change’ principle. The revised assessment must be provided prior to Stage 2. • Climate change and drainage: The energy strategy does not fully accord with London Plan Policies 5.2 and 5.9. Further information regarding overheating, the site-wide network and renewable energy is required. The final agreed energy strategy should be appropriately secured by the Council, along with S106 obligations for off-site mitigation. Any drainage attenuation tanks proposed should be designed to also provide benefit during lower order storm events by utilising the Method 2 tank design.

• Air quality: The air quality assessment is incomplete. Further information is required to fully assess the air quality impact. Consideration should be given to providing hydrogen refuelling within the replacement petrol filling station.

• Transport: The proposed access on Chalk Farm Road must be revised to ensure it is suitable for bus operations and traffic signals; the car parking proposed for the temporary supermarket during construction exceeds London Plan standards; a S106 contribution to public realm works and a new entrance at Camden Town station should be secured; comprehensive travel, deliveries and servicing and car and cycle parking management plans, and two-stage construction logistics plan should be secured by condition. Update

7 Since the consultation stage, GLA officers have engaged in joint discussions with Camden Council, the applicant team, and Transport for London (TfL) officers with a view to addressing the above matters. Accordingly, the response to the various issues raised at consultation stage on this application are considered under the corresponding sections below. Furthermore, as part of Camden Council’s decision on the case, various planning conditions and obligations have been proposed to address the above concerns and to ensure that the development is acceptable in strategic planning terms.

8 Revisions and clarifications to the development were submitted to the Council in September 2017. This further information was accompanied by a letter of assessment relating to the Environmental Assessment, providing clarification with regard to the environmental implications of the amended proposed development in respect of the original Environmental Statement. The amended proposals relate to both the main site and the Petrol Filling Station. However, there were no amendments to the area schedule or unit or tenure mix. Strategic planning policy and guidance update

9 The following draft policy and guidance is now a material consideration:

page 3 • Draft revised National Planning Policy Framework 2018; • Draft London Plan 2017. Principle of development

10 The principle of the proposed high density residential-led mixed use redevelopment of the site was strongly supported at consultation stage by virtue of its location within a Major Town Centre and in accordance with London Plan Policy 2.15 and policies GG2 and SD6 of the draft London Plan. However, further details were requested as to the package of benefits on offer in respect of the affordable workspace provision (reduced rental levels/ flexible leases etc.) and details as to how this would be secured.

11 The applicant has been in discussions with a local affordable workspace provider with a proven track record, however, the negotiations are currently at an early stage. A planning obligation has been secured in the draft section 106 agreement requiring the submission of an affordable workspace plan which requires the applicant to: confirm details of an affordable workspace provider that the space will be transferred to at a peppercorn rent, the workspace to be fitted out to a reasonable standard, restrict occupation to small and medium sized enterprises, secure 50% of the affordable workspace to be provided to tenants free of charge and the remaining floorspace at no more than 50% of market rate. This is supported. Affordable housing

12 At the consultation stage, 39% affordable housing by habitable room (32% by unit) was proposed with at least 30% is to be provided as London Affordable Rent, 30% as intermediate rent and the remaining 40% was confirmed as been agreed with the Borough to be provided as (roughly) 30% London Affordable Rent and 10% intermediate rent. This was confirmed as offering a ‘Fast Track Route’ compliant tenure split under the provisions of the Mayor’s Affordable Housing and Viability SPG and Policy H6 and H7 of the draft London Plan. Following the Council’s resolution to grant permission, GLA officers have secured the affordability of all the intermediate rented units in line with the requirements of the Mayor’s SPG, Policy H7 of the draft London Plan and the London Plan Annual Monitoring Report, and will be affordable to households on incomes of up to £60,000.

13 In order to confirm full compliance with the ‘Fast Track Route’, the applicant was required to fully investigate the potential for Mayoral grant funding (and any other available public subsidy) and secure the necessary early stage review mechanism within the section 106 agreement. In this regard, the applicant has engaged with GLA officers and has confirmed that the scheme could increase affordable housing delivery to 40% should GLA programme funding be available under the developer-led route of the Mayor’s Affordable Housing and Viability SPG. In accordance with the Mayor’s SPG, suitable provisions have been included within the draft section 106 agreement securing both the baseline level of affordable housing in addition to the with grant scenario. An early stage viability review has also been secured by planning obligation. On this basis the affordable housing offer is in accordance with the London Plan, draft London Plan and the Mayor’s Affordable Housing and Viability SPG. Urban design

14 The revisions that were undertaken subsequent to the stage one report, provide more detail on the public realm along Stephenson Street, address concerns raised in relation to prioritising pedestrian routes into the site. The sub-station has also been moved to a less prominent location on the north-eastern ground floor frontage of Block B which serves to further activate this facade. The provision of climbing plants and material detailing adds visual interest to these elevations and addresses concerns raised in relation to active frontages to Blocks A and E1. Furthermore, the high

page 4 quality of public realm and extent of active frontages across the scheme as a whole serves to outweigh these concerns.

15 In addition to the above, the applicant has confirmed that the public spaces along Roundhouse Way and Makers Yard will achieve acceptable levels of sunlight. Inclusive design

16 All outstanding issues in respect of inclusive design have now been addressed. Whilst a ‘changing places toilet’ is not proposed, the supermarket will provide accessible toilets open to the public during operational hours, and furthermore, a unisex pop-up toilet will be provided on the approach to the site from Chalk Farm Road, which will become operational at night. In combination, the public toilet provision broadly meets the provisions of draft London Plan Policy S6. Full details of the design of the public realm and landscaping has been conditioned and satisfactorily addresses those issues previously raised in respect of the design of steps and shared spaces. The location and type of seating is now indicated on the approved landscaping plans and submission of level plans are secured under the section 106 agreement as required.

17 The number of disabled parking spaces for the residential element has remained unchanged at 20 spaces, which falls short of the London Plan minimum standard of one space per accessible unit, however, this does meet the draft London Plan minimum standard for one bay per 3 per cent of the accessible dwellings. Officers note that the car parking management and travel plans secured within the section 106 agreement provide for this to be increased in the future, and given the improved access to step-free bus services from within the redeveloped site, and the step free access at Camden Town station, this level of provision is acceptable in this instance. The concierge service will assist with the evacuation of disabled persons in the event of a fire; and the proportion of wheelchair accessible/ adaptable units is broadly in line with London Plan and draft London Plan requirements and is secured by condition. Noise

18 It was reported at consultation stage that the submitted noise and vibration assessment did not provide sufficient comfort that the impact of the numerous existing cultural venues in the vicinity of the site had been fully taken account of in establishing the baseline acoustic environment contrary to the ‘Agent of Change’ principles as defined within the draft Cultural and Night-Time Economy SPG. As such, confirmation was requested that the noise surveys undertaken were representative of the nearby venue’s noisiest events and mitigation applied as necessary.

19 Subsequently, a noise assessment addendum was produced by the applicant which confirmed that the assessment was suitably robust and provided an appropriate assessment baseline. In addition, the Council have proposed two noise conditions including the requirement for a post completion assessment in addition to securing an ‘Agent of Change’ section 106 obligation. It is considered that these mechanisms will ensure the appropriate safeguarding of the nearby existing cultural and night time entertainment venues and are therefore general in accordance with the provisions of the draft Cultural and Night-Time Economy SPG and Policy D12 of the draft London Plan.

Climate change and drainage

20 The carbon savings meet the minimum targets contained within Policy 5.2 of the London Plan. Clarification has been provided in relation to overheating, the use of active cooling, connection to the district heating network, the site heat network and renewable energy provision has been provided in full to the GLA. As requested at the consultation stage, a carbon offset contribution of £718,860 has been

page 5 secured in the section 106 agreement and the application is now in compliance with energy policies of the London Plan and draft London Plan. Air quality

21 At the consultation stage, the air quality neutral assessment was deemed incomplete, and additional information was requested to enable the appropriate assessment of the impact of the energy centre, in addition to details of mitigation measures to address emissions from the basement car park. The applicant has since submitted further information and made revisions to the air quality strategy in order to overcome the issues raised. Due to the omission of CHPs the concerns raised in respect of the impact of the energy centre are no longer relevant. The air quality neutral assessment has also been revised and is now deemed acceptable. In respect of the emissions from the basement car park, consideration of the ventilation strategy is required as part of the car parking management plan which is secured by planning obligation. Officers would encourage future dialogue with the applicant in relation to the provision of zero emission vehicle refuelling as part of the replacement petrol filling station.

Transport

22 Following concerns regarding the proposed level of retail car parking at the consultation stage; however, the provision for the temporary store has since been reduced to 66 spaces including 6 disabled parking spaces, which meets London Plan standards. The car parking for the permanent replacement store will initially exceed these standards by 48 spaces. Nevertheless, the section 106 agreement requires the developer to reduce car parking to a London Plan compliant amount of 252 spaces, whilst retaining adequate Blue Badge parking. The applicant is also required to investigate further reductions within 3 years of opening, or a bond of £1m will be payable to Camden Council, to be used for sustainable transport. The redevelopment of the site will therefore result in an eventual reduction of at least 173 retail car parking spaces. This planning obligation is supported by a set of robust travel plan and car parking management measures also secured in the section 106 agreement, including marketing to promote walking and cycling; strict limits to car parking time; validation of customer car parking by supermarket staff; and CCTV enforcement with fines. Electric vehicle charging provision in accordance with the London Plan standards has also been secured.

23 The new car park will be underground, freeing up the current surface provision for new housing and high quality public realm in line with the Mayor’s and TfL’s new Good Growth and Healthy Streets approaches. A financial contribution of £1.85m to Camden Council has also been secured to fund improvements to local pedestrian and cycling links, enhancing access to local public transport stops and stations, and to encourage active travel by improving key points of severance and permeability around the site, in addition to funding for three new Legible London signs, which is welcomed.

24 Further traffic modelling to assess the potential for delays to bus journey times due to the new vehicular access proposed into the site from Chalk Farm Road has also been undertaken. This has revealed minor delays to some services which would be offset by a much improved bus passenger arrival experience. Stops will be closer to the store entrance in a new public plaza and the proposed arrival area has been designed to meet TfL Buses’ operational needs. The section 106 agreement secures the land and rights for this new infrastructure and its delivery as part of the development.

25 The Council has secured £365,000 to fund the new vehicular access into the site from Chalk Farm Road and TfL will also approve the detailed design prior to implementation to ensure it is suitable for cyclists, bus operations and traffic signals. A financial contribution of £200,000 and safeguarded land has been secured for a new Cycle Hire docking station. In addition to the above, site-wide deliveries and servicing and construction logistics plans have been secured in the section 106 agreement with monitoring contributions for effective delivery.

page 6 Draft section 106 agreement

26 Further to the heads of terms set out within Camden Council’s committee report, and subsequent GLA and TfL discussions with the applicant and Camden Council planning officers, the Section 106 agreement will secure the following key provisions:

Community Infrastructure Levy:

• On site provision of 39% affordable housing (184 units); • Early stage review mechanism; • Provision of affordable workspace; • Agent of Change obligation to safeguard nearby cultural and entertainment venues; • A bond to limit the number of car parking spaces afforded to the supermarket; • £1,852,800 contribution towards local pedestrian and environmental improvements; • Legible London signage; • Cycle hire scheme – safeguard land and installation/ maintenance costs; • £718,860 carbon offset contribution; • Pop-up toilet and maintenance costs; • Community toilet scheme; • Local employment, skills and local supply plan and contribution of £315,778 • Farm Management Plan Response to consultation

27 Consultation letters were sent to properties in the vicinity of the site; in addition, 50 site notices were displayed in and around the perimeter of the site as well as in the local area. In total, 90 consultation responses were received from residents/ individuals, groups and businesses.

28 Formal re-consultation took place in October following receipt of revisions, which attracted a smaller number of consultation responses.

29 The following statutory consultation responses were received:

Secretary of State

• No response received

Environment Agency

• No comment

Natural England

• No comment

MET police

• Advise that the applicant continues to engage with the Design-Out-Crime Officers throughout the project.

page 7 HS2

• Requests detailed design and construction method statements to demonstrate that if the development is constructed concurrent with HS2 then HS2 construction would not be impeded.

Historic England

• HE welcomes the redevelopment of the site which currently detracts from this part of Camden Town. The height of the tallest elements has impacts on surrounding heritage assets but the harm is less than substantial and could be outweighed by public benefits.

Historic England – GLAAS

• Recommends a programme of archaeological investigation be carried out in accordance with an appropriate condition.

Canal and River Trust

• Consideration needs to be given to the potential impact of the development on views towards the Regent’s Canal.

UK Power Networks

• Contact with UKPN needs to be made regarding the potential relocation of the existing substation.

Thames Water

• Various comments made in respect of the drainage strategy, groundwater, foul water and sewers. Various conditions recommended.

30 Objections were raised by local residents, local interest groups, landowners and businesses as summarised below:

Land use • Overdevelopment of site; • A greater proportion of social and affordable housing would be desirable; • There is insufficient affordable offices and SME workspace; • A variety of retail uses should be provided; • There are too many smaller sized units; • Affordable/social housing must not be reduced.

Design – height, density, layout and access • Does not accord with Camden Goods Yard Framework; • The scheme is too high and dense and will impact local character, heritage and daylight/sunlight/privacy; • Impact of scheme on daylight and sunlight to adjacent residential; • Object to architecture and design; • The Grenfell fire has demonstrated that buildings on this scale are not appropriate for community development; • Proposals should be more permeable with green routes and wider streets; • Not clear how visitors, disabled users, emergency vehicles and deliveries would gain access to all parts of the scheme;

page 8 • Access to the development will be difficult in case of fire; • Access to the site for cyclists is inadequate and unsafe;

Transport • Concerns over additional traffic generation and vehicular pollution, compounded by temporary closer of the Petrol Filling Station; • Cumulative traffic impact not considered; • Increased car parking pressure; • The visuals produced of the scheme are misrepresented and tactically chosen; • Increased impact on Chalk Farm tube station; • Too much supermarket car parking; • No provision seems to have been made for car clubs, taxi or local delivery vehicles for the supermarket; • Inadequate access from Oval Road; • Concerned about additional pedestrian traffic around the area and along the towpath; • Insufficient cycle parking;

Heritage • Views down Haverstock Hill, up Chalk Farm Road, from Camden Lock, from Oval Road and from the Primrose Hill Conservation Area would be damaged; • Harm to the setting of the listed Interchange; • The high-rise blocks will be visible from Regent’s Park which is a Grade I listed; • Significant lowering of the ground level has not been at all clearly shown on the plans;

Impact on amenity • Impact on local residents in terms of noise, pollution, and traffic during construction should be mitigated; • Concerned over utilities capacity; • The impact of the scheme on daylight/ sunlight and privacy to adjacent residential; • Microclimate impacts; • Noise assessment must consider and protect nearby entertainment venues and Agents of Change principles applied; • Impact of the scheme on air quality.

Other • Object to the number of trees being felled; • Overshadowing will hinder the growth of green spaces; • The design of the public realm will encourage anti-social behaviour; and • Considerable strain would be put on existing schools, health facilities and shops. • Issues raised with quality of submission and consultation process

31 Having considered the responses to the local consultation process, Camden Council has proposed various planning obligations and conditions in response to the issues raised. Having had regard to these, GLA officers are satisfied that the statutory and non-statutory comments on this application do not raise any material planning issues of strategic importance that have not already been considered in this report, or consultation stage report D&P/4158/01.

page 9 Article 7: Direction that the Mayor is to be the local planning authority

32 Under Article 7 of the Order the Mayor could take over this application provided the policy tests set out in that Article are met. In this instance, the Council has resolved to grant permission with conditions and a planning obligation, which satisfactorily addresses the matters raised at Stage 1, therefore there is no sound planning reason for the Mayor to take over this application. Legal considerations

33 Under the arrangements set out in Article 5 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor has the power under Article 6 to direct the local planning authority to refuse permission for a planning application referred to him under Article 4 of the Order. He also has the power to issue a direction under Article 7 that he is to act as the local planning authority for the purpose of determining the application and any connected application. The Mayor may also leave the decision to the local authority. In directing refusal the Mayor must have regard to the matters set out in Article 6(2) of the Order, including the principal purposes of the Greater London Authority, the effect on health and sustainable development, national policies and international obligations, regional planning guidance, and the use of the River Thames. The Mayor may direct refusal if he considers that to grant permission would be contrary to good strategic planning in Greater London. If he decides to direct refusal, the Mayor must set out his reasons, and the local planning authority must issue these with the refusal notice. If the Mayor decides to direct that he is to be the local planning authority, he must have regard to the matters set out in Article 7(3) and set out his reasons in the direction. Financial considerations

34 Should the Mayor direct refusal, he would be the principal party at any subsequent appeal hearing or public inquiry. Government Planning Practice Guidance emphasises that parties usually pay their own expenses arising from an appeal.

35 Following an inquiry caused by a direction to refuse, costs may be awarded against the Mayor if he has either directed refusal unreasonably; handled a referral from a planning authority unreasonably; or behaved unreasonably during the appeal. A major factor in deciding whether the Mayor has acted unreasonably will be the extent to which he has taken account of established planning policy.

36 Should the Mayor take over the application he would be responsible for holding a representation hearing and negotiating any planning obligation. He would also be responsible for determining any reserved matters applications (unless he directs the council to do so) and determining any approval of details (unless the council agrees to do so). Conclusion

37 The strategic issues raised at consultation stage regarding affordable workspace, affordable housing, urban design, inclusive design, noise, climate change and drainage, air quality and transport have been satisfactorily addressed, and appropriate planning conditions and obligations have been secured. As such the application complies with the London Plan, and there are no sound reasons for the Mayor to intervene in this case.

page 10

for further information, contact GLA Planning: Juliemma McLoughlin, Chief Planner 020 7983 4271 email [email protected] Jonathan Finch, Case Officer 020 7983 4799 email [email protected]

page 11

planning report D&P/4158/01 23 August 2017 Camden Goods Yard in the London Borough of Camden

planning application no. 2017/3847/P

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

The proposal Redevelopment of the petrol filling station site to provide a six-storey building comprising a petrol filling station, flexible retail floorspace and offices. Redevelopment of the main supermarket site to include the erection of seven buildings ranging in height up to 14 storeys accommodating up to 573 homes together with a foodstore, flexible retail, offices and workshops, community centre together with landscaping and associated works.

The applicant The applicant is Safeway Stores Ltd and BDW Trading Ltd, the architect is Allies & Morrison.

Strategic issues Principle of development: The principle of the redevelopment of this underutilised site for residential-led mixed uses is strongly supported. Full details of the affordable workspace must be agreed and secured (paragraphs 17 to 20). Affordable housing: The proposed 39% provision of affordable housing by habitable room is supported as a starting point; however, the applicant must fully investigate the provision of grant funding (and any other available public subsidy). An early stage review is also required (paragraphs 22 to 27). Urban design: The proposals are generally acceptable subject to revisions to address blank frontages, the sense of enclosure, the ramp to Block F and the design of Block E1, particularly in respect to the ground floor and the provision of amenity space (paragraph 33 to 49). Transport: The proposed access on Chalk Farm Road must be revised to ensure it is suitable for bus operations and traffic signals; the car parking proposed for the temporary supermarket exceeds London Plan standards; a S106 contribution towards the Camden Town station public realm works should be secured; travel, deliveries and servicing and car and cycle parking management plans, and two-stage construction logistics plan should be secured by condition (paragraph 59 to 72).

Outstanding issues relating to inclusive design, noise, climate change and drainage and air quality also need to be addressed. Recommendation That Camden Council be advised that the application does not yet comply with the London Plan, for the reasons set out in paragraph 76 of this report; but that the possible remedies set out in that paragraph could address these deficiencies.

page 1 Context

1 On 14 July 2017, the Mayor of London received documents from Camden Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008, the Mayor has until 25 August 2017 to provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 1A and 1C of the Schedule to the 2008 Order: • 1A “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats.” • 1C “Development which comprises or includes the erection of a building (c) more than 30 metres high and is outside the City of London.”

3 Once Camden Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

4 The environmental information for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (as amended) has been taken into account in the consideration of this case.

5 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description

6 The application site comprises three parcels of land situated to the rear of the Stables Market within Camden Town Centre and is made up of the double height Chalk Farm Morrisons food store and car park (main site), the associated petrol filling station fronting Chalk Farm Road (PFS site) and a small area of access road below a railway bridge. The combined site area amounts to approximately 3.3 hectares and also includes areas currently used by buses for layovers.

7 The main site is bounded by the West Coast mainline railway line to the south west and the northern line to the north east, the Stables Market beyond the northern line and social housing to the south at Gibleys Yard and to the north at Juniper Crescent. The PFS site is bound by Chalk Farm road to the north, railway lines to the south and the access road the east and west.

8 The main site is elevated by approximately six metres above Chalk Farm Road and has limited access other than the main vehicular access from Juniper Crescent and a level pedestrian access from Oval Road/Gibleys Yard to the south east. To the north-east corner there is a pedestrian access point via lift and stairs to the Stable Market, although it is understood that the applicant only has rights to the top 0.4 metres of land in this area and the covenants stipulate that it can only be used for parking or landscaping. Due to the level changes, limited access and situation between railways lines, the site is considered relatively isolated from the wider town centre.

page 2 9 There are no listed buildings within the application boundary; however, the site is adjacent to a number of conservation areas. The Regents Canal Conservation Area effectively wraps the northern, eastern and southern boundaries of the main site and incorporates the PFS site. There are a number of listed buildings within this conservation area in close proximity to the site, namely the Roundhouse and Camden Incline Winding Engine House (Grade II*), the Stables Market, the Interchange Warehouse and Gibleys Warehouse (Grade II). The Primrose Hill Conservation Area lies to the south-west beyond the West Coast mainline railway and beyond Chalk Farm Road to the north is the Harmwood Street Conservation Area and to the north-west is the Eton Conservation Area. The viewing corridor of protected London Panorama 2A.2 from Parliament Hill summit to the Palace of Westminster also traverses approximately half of the application site, where the London View Management Framework indicates that building heights should not exceed approximately 84 metres AOD.

10 With regards to policy designations the application site is located within a major town centre. In addition, the Camden Goods Yard Planning Framework, which covers the application site as well as a number of adjoining sites, was recently adopted by Camden (July 2017). The site itself is specifically identified for redevelopment to provide a new mixed-use neighbourhood that, in summary, builds upon and adds to the special character of the area including a significant number of homes, a mix of commercial space that adds to the diversity and vitality of Camden Town centre including the re-provision of the foodstore and a mix of other uses suitable to the areas’ status as a ‘sensitive frontage’. Proposals for the site should improve its connectivity with surrounding neighbourhoods; provide high quality entrance from Chalk Farm road, high quality public realm and new attractive and legible pedestrian and cycle routes that address level changes.

Details of the proposal

11 The proposals involve the redevelopment of the PFS site to include the erection of a new building of up to six storeys creating 11,243 sq.m. to accommodate a replacement petrol filling station and kiosk at ground floor (rear) with small retail units fronting Chalk Farm Road, and offices above. The eastern portion of the building will accommodate restaurant/ cafe uses and a winter garden above within a glazed, winged enclosure which will rise a storey above the main building. The petrol station site will be redeveloped first and will house the replacement foodstore for a temporary period of 30 months, whilst the remainder of the site is under development. Following this, the temporary foodstore will be relocated to its permanent home on the main site.

12 The main supermarket site is to be redeveloped to provide seven development blocks ranging in height up to 14 storeys accommodating up to 573 homes, including affordable housing, together with up to 28,345 sq.m. GEA non-residential floorspace. The non-residential component will comprise the permanent replacement foodstore which will be located at the middle of the site at lower ground floor (Block B), in broadly the same location as the existing foodstore with associated car parking for the store also provided at lower ground floor level. The upper floors of Block B will accommodate offices, workshops and residential at part ground and over the top three floors, a roof level food and plant growing/production facility including small scale brewing and distilling; with associated ancillary office, storage, education, training, cafe and restaurant activities. Block A and F, to the north/ west of the site will broadly accommodate a mixture of workspace, offices and retail at lower levels and residential above. Block A is 14 storeys, the tallest block in the scheme. Blocks D and E are almost entirely residential and extend across the southern boundary of the site. Block D also accommodates a community centre at ground floor. These are generally lower rise than the rest of the proposed development, with the exception of Block E1, which is 11 storeys. Block C, to the east of the site is up to 10 storeys in height and accommodates workspace and retail use at ground floor and residential on upper floors.

page 3 13 A new road junction will be provided to the site together with the creation of new streets and squares within the development itself; hard and soft landscaping and play space is proposed together with public cycle parking, a cycle hire facility adjacent to the entrance to the main site and other associated works, including the removal of the existing surface level car parking and retaining walls, road junction alterations. Case history

14 On 13 December 2016, a pre-application meeting was held at City Hall with the applicant, where principle of development was discussed including detailed matters relating to housing and affordable housing, urban design and transport. Strategic planning issues and relevant policies and guidance

15 The relevant issues and corresponding policies are as follows:

• Principle of development London Plan; Town Centres SPG • Housing and affordable housing London Plan; Housing SPG; Housing Strategy; Shaping Neighbourhoods: Play and Informal Recreation SPG; Shaping Neighbourhoods: Character and Context SPG; Affordable Housing and Viability SPG; Shaping Neighbourhoods: Play and Informal Recreation SPG • Urban design London Plan; Shaping Neighbourhoods: Character and Context SPG; Housing SPG; London View Management Framework • Inclusive design London Plan; Accessible London: achieving an inclusive environment SPG • Noise London Plan; draft Culture and the Night-time Economy SPG • Climate change and drainage London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy • Air quality London Plan; Control of Dust and Emissions SPG; Sustainable Design and Construction SPG; • Transport London Plan; the Mayor’s Transport Strategy; Mayoral Community Infrastructure Levy; Crossrail SPG; Mayor’s draft Transport Strategy

16 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is the Camden Core Strategy (2010); the Camden Development Policies (2010); the 2016 London Plan (Consolidated with Alterations since 2011).

17 The following are also relevant material considerations: • The National Planning Policy Framework, Technical Guide to the National Planning Policy Framework and National Planning Practice Guidance. • The Camden Goods Yard Planning Framework (2017).

page 4 Principle of development

18 The site is located within Camden Town Centre, which is identified as a ‘Major Town Centre’ in the London Plan. In this regard, London Plan policy 2.15 promotes London’s network of town centres as the main foci for development outside of the Central Activities Zone for commercial development and intensification, including residential development. Such development is therefore expected to sustain and enhance the vitality and viability of the centre; accommodate economic and/or housing growth; support and enhance the competitiveness, quality and diversity of town centre retail, leisure, employment, arts and cultural, promote access by public transport, walking and cycling; promote safety, security and lifetime neighbourhoods; contribute to an enhanced environment including urban greening and public realm; and reduce delivery servicing and road user conflict.

19 In this regard, the proposals seek to provide a high density residential-led mixed use scheme in a town centre location on a site which is currently significantly underutilised. The proposals will re-provide the existing foodstore and petrol station as well as providing flexible retail floorspace, offices, workshops and a small community centre. The proposals will also contribute significantly to the Borough’s annual housing targets (64%). Efforts have been made to connect this somewhat isolated site to the surrounding area as much as possible. New routes and public spaces have been created taking into account of the level changes across the site. Therefore, the proposed mix of uses are appropriate to the site’s town centre location, reflect the strategic aspirations of London Plan Policies 2.15 and 4.7 and is therefore strongly supported.

Retail

20 The existing superstore and associated parking will be re-provided within the scheme at lower ground floor level of Block B, thereby maximising the availability of land at ground floor level for development. Flexible retail uses are to be introduced along the Chalk Farm Road frontage (1,243 sq. m.) within the replacement petrol filling station block, which is strongly supported, particularly as it would create a more active, pedestrian friendly frontage in this location. A further 787 sq. m. of small, flexible retail units is proposed across the main site at ground floor level which will promote activity within the site during the daytime and into the early evenings. The inclusion of smaller shops suitable for small or independent retailers will serve to further strengthen the retail offer and attractiveness of the destination in line with London Plan Policy 4.9.

Offices and workshops

21 The proposals would deliver 13,546 sq.m. of office floorspace. It is anticipated that approximately 1,184 full time equivalent jobs would be created as a result of introducing the total mix of commercial floorspace to the site, including approximately 869 jobs in relation to the office element. In addition, 465 sq.m. of office floorspace will be provided as affordable, as endorsed by the Town Centre SPG, and is therefore strongly supported. Light industrial (B1c) workshops also form part of the commercial offer, although these are proposed to be offered at a market rate. These workshops are intended to be utilised by creative industries in the area as promoted by local policy. Overall, the commercial offer is strongly supported. However, further details are required as to the package of benefits on offer in respect of the affordable workspace provision (reduced rental levels/ flexible leases etc.). These benefits should be secured within the s106.

page 5 Housing

22 The proposed development would deliver 573 residential units with the following mix:

Market Affordable Intermediate Sub-totals (% Rent mix)

Studio 62 0 0 62 (10.8%)

1 bed 140 23 46 209 (36.5%)

2 bed 146 29 36 211 (36.8%)

3 bed 41 42 0 83 (14.5%)

4 bed 0 8 0 8 (1.4%)

Totals 389 102 (18%) 82 (14%) 573 (100%)

Affordable housing

23 London Plan Policy 3.12 seeks the maximum reasonable amount of affordable housing to be provided. The Mayor’s Affordable Housing and Viability SPG establishes a minimum pan- London threshold level of 35% affordable housing (without grant) with a strategic target of 50%. Under the ‘Fast Track Route’, as set out within the Affordable Housing and Viability SPG, a viability assessment of the scheme does not need be provided at application stage and a late stage review is negated if the affordable housing offer is at least 35% by habitable room; meets the SPG’s requirements in respect of tenure split; and meets all of the other relevant policy requirements and obligations.

24 In this regard, the application proposes 39% affordable housing by habitable room (32% by unit) with a 62:48 affordable rent:intermediate split. In line with the Affordable Housing and Viability SPG at least 30% is to be provided as social rent, 30% as intermediate products and the 40% has been agreed with the Borough to be provided as (roughly) 30% social rent and 10% intermediate and therefore fully accords with the ‘Fast Track Route’. In addition, both Camden Policy H3 and London Plan policy 3.11 require affordable housing should be provided on a 60:40 ratio of social to intermediate (albeit Camden calculate affordable housing on a floorspace basis). The affordable rent units will be let at London Affordable Rent rates in accordance with the Mayor’s SPG. The rents payable on the intermediate units will be based on the following breakdown:

• All one bedroom intermediate rent units will be affordable to households earning £40,000 per annum. A weekly rent of £215 including service charges is proposed, equivalent to circa £932 per month.

• For the two bedroom intermediate units it is proposed that 50% of units are affordable to households earning £50,000 per annum, with 50% affordable to those earning £55,000 per annum, resulting in weekly rents of £269.23 to £296.15 per week including service charges. This equates to circa £1,167 – £1,283 per month.

25 The London Living Rent (LLR) levels for the Camden Town ward are £1,111 and £1,234 for one and two bed apartments respectively. Therefore, the proposed rental levels are broadly in accordance with the Mayor’s London Living Rent and are therefore supported.

page 6 26 Whilst the provision of a threshold 35% affordable housing offer (before public subsidy) is supported as a starting point, applicants are required to work with the Mayor, Local Planning Authorities and Registered Providers to ensure that the provision of affordable housing is maximised from all sources. The applicant must therefore fully investigate the potential for Mayoral grant funding (and any other available public subsidy) with a view to further increasing affordable housing delivery within the scheme. Evidence that the applicants have explored this opportunity must be supplied to the GLA prior to Stage 2.

27 On the basis that the scheme meets the minimum 35% threshold of the Affordable Housing and Viability SPG, the requirement for a late stage affordable housing review mechanism is negated. However, in line with the Affordable Housing and Viability SPG (and as an incentive for timely delivery), the Section 106 agreement will need to include provision for an early viability review mechanism – to be triggered if an agreed level of progress on implementation has not been made within two years of any planning permission.

28 The early stage review mechanism clause will need to be built into the associated s106 agreement. A draft of the s106 must be provided to the GLA for review as soon as one is made available; to ensure that the review mechanism has been applied as required by the Affordable Housing and Viability SPG.

Residential density

29 The site has a Public Transport Accessibility Level (PTAL) of 6b (on a scale where 6b is the highest). The density matrix contained in table 3.2 and policy 3.4 of the London Plan suggests a density 650 to 1,100 habitable rooms per hectare (hr/ha) or 215-405 units per hectare. The proposed scheme has a density of 323 units per hectare 864 hr/ha and therefore sits comfortably between the London Plan range. In light of the good levels of residential quality achieved, the overall design of the proposal, and give the provision of play and amenity space, the density is acceptable.

Residential quality

30 All of the units meet the nationally described space standard and the majority of units (90%) are provided with private amenity space in the form of balconies or terraces in accordance with the provisions of the Mayor’s Housing SPG. In the instances where they are not, the internal floor area has been increased relative to the shortfall recorded against the minimum internal space standard requirement. The provision of external private amenity space has been dictated by the proximity to existing residential and the need to protect amenity and privacy and it is mainly the smaller studio units which are affected. In light of this, and given the relatively limited proportion of units affected, the proposals are considered acceptable.

31 The majority of proposed units are dual aspect with most blocks incorporating 70% or more dual aspect units. However, in blocks F and B only 51% and 57% of units respectively are dual aspect, which is significantly lower. However, it is acknowledged that the applicant has explored the use of decked access and duplex units to increase these levels and there are limited opportunities available beyond this to increase this proportion further. Therefore, in this instance these proportions are considered acceptable subject to the applicant addressing the concerns raised in respect of the ground floor frontages. Please see the urban design section of this report for further details.

Children’s play space

32 London Plan Policy 3.6 ‘Children and Young People’s Play and Informal Recreation Facilities’ seeks to ensure that development proposals provide access to inclusive, accessible and

page 7 safe spaces, offering high-quality play and informal recreation opportunities. The Mayor’s Play and Informal Recreation SPG (September 2012) sets out the GLA’s requirements for the design of playspace within schemes. The associated playspace calculator identifies the requirement for playspace for this scheme as being 1,765 sq.m (41% for under 5s, 35% for 5-11s and 24% for the 12+ age group). Camden Council’s Amenity CPG6 supplementary planning guidance (figure 5) identifies considerably lower requirements for children’s playspace, although the Council have revised this requirement based on local need up to 540 sq.m.

33 A total of 1,129 sq.m. of on-site children’s playspace is proposed this represents an under-provision of 636 sq.m against the Mayors SPG requirement. Notwithstanding this, a significant amount of both amenity open space (7,257 sq.m.) and natural green space (3,434 sq.m.) is proposed to be provided within the scheme which, when combined, is in excess of the Council’s open space requirements. On the basis that this open space is defendable and fully accessible, the overall quantum of amenity space to be provided across the site more than makes up for the relatively small deficiency in playspace against the Mayor’s SPG requirement. Urban design

Layout

34 The scheme's layout is generally well thought out and has evolved positively through pre- application input and design review to create a logical arrangement of blocks and sequence of well- defined public realm.

35 The intention to enable future connections to the established and emerging street network (while also addressing significant level changes) is welcomed and the scheme gives potential to create new and enhanced routes along the railway edge via 'Engine House Way' and into the Stables Market via 'Interchange Yard'. Notwithstanding this, in the interim period, Stephenson Street is the sole point of entry into the site from Chalk Farm Road for all servicing, pedestrians and bus access. It is therefore important that the application secures safe and clearly delineated pedestrian access (including maximised pavement widths and pedestrian crossings) towards the proposed 'Goods Yard' public square and the wider scheme. Particular attention should be given to the delivery and servicing route towards the supermarket's basement loading bay, which crosses the 'Goods Yard' public square.

36 The blocks are generally designed to achieve high levels of active commercial and residential frontage to the majority of public facing edges, which is welcomed. Some concern is however raised in relation to the north-east corner of Block B, the western frontage of Block A and the south-east corner of block E1, where vehicular access/servicing and blank frontages are at risk of having a detrimental impact on the public realm. These portions of Blocks B and E in particular both form key points of arrival into the site and as such should be designed to engage more positively with the public realm as far as is feasible.

37 Block E1 will effectively be turning its back onto the route into the site from the south via Gilbeys Yard and options for relocating the escape stair and better-utilising the car park area to the rear for residential amenity space should be considered.

38 The run of duplex units along the 'Engine House Way' frontage of Block F is welcomed and has potential to create a strong residential mews character. Block A's ramp access to basement parking disrupts this, and options for wrapping the edge of the ramp with additional commercial/workspace must therefore be explored.

page 8 39 The arrangement of blocks across the remainder of the masterplan is supported and the scheme makes good use of existing site levels and podiums to contain the majority of servicing and refuse/cycle storage.

Form/massing

40 The proposal responds appropriately to the predominant scale of the surrounding townscape, including local heritage assets (Interchange building, St Mark's Church and Roundhouse) by mediating in scale across the site. The heights of blocks are also restricted through the centre of the site by the London View Management Framework viewing corridor. Taller buildings are positioned towards the northern end of the site and are positioned to address key spaces within the public realm. This approach is broadly supported; however, the applicant should consider the comments above relating to the ground levels of the western portion of Block A and Block E1, to ensure that the bases of these taller buildings are fully resolved.

41 The applicant has undertaken a thorough townscape and views analysis which indicates that the form and heights distribution will have no significant impact on the character of neighbouring conservation areas and it is noted that the massing has been amended to ensure that the settings of key views are preserved.

42 The intention to optimise housing and employment densities in this town centre location is supported, there are however a number of instances where distances between blocks are limited, creating a strong sense of enclosure at ground level. The heights/width ratios of 'Roundhouse Way' and 'Makers Yard' in particular are likely to create an overbearing effect on the public realm and the applicant should therefore demonstrate how the form/massing of blocks has been designed to optimise sunlight penetration and minimise overshadowing onto the public realm.

Heritage

43 The proposals involve the redevelopment of a site within the setting of listed buildings and Conservation Areas. Under S66 and S72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 special regard must be had to the preservation of the listed buildings and their settings and special attention must be paid to the desirability of preserving or enhancing the character or appearance of a Conservation Area.

44 The NPPF states that when considering the impact of a proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation, and the more important the asset, the greater the weight should be. Significance is the value of the heritage asset because of its heritage interest, which may be archaeological, architectural, artistic or historic, and may derive from a heritage asset’s physical presence or its setting. Where a proposed development will lead to ‘substantial harm’ to or total loss of the significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss. In line with London Plan Policy 7.8, the NPPF states that where a development will lead to ‘less than substantial harm’, the harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.

45 London Plan Policy 7.8 states that “development should identify, value, conserve, re-use and incorporate heritage assets” and refers to the importance of preserving London’s historic character by “the careful protection and adaptive use of heritage buildings and their settings” and that “heritage assets such as conservation areas make a significant contribution to the local character, and should be protected from inappropriate development.

page 9 46 The assessment highlights two instances where the development will result in significant change to the setting of the Primrose Hill Conservation Area; and the special historic interest of Regent's Park. GLA officers are satisfied that while the setting of these heritage assets, in particular, will be altered, the significant benefits of the scheme such as: increased permeability; the delivery of a significant quantum of housing; and the creation of high quality public realm, would outweigh any harm caused.

47 In more local views, the scheme is designed to respond positively to the industrial heritage of the area and the simple and refined appearance of larger blocks will appear as a backdrop and largely recessive in local townscape views.

Residential layouts

48 The mix of typologies and distribution of cores creates efficient residential layouts and a high quality residential environment. The majority of cores and access corridors are designed to be naturally lit and ventilated and deck access is used to avoid north facing single aspects while allowing the proportion of dual aspect to be maximised.

49 The podium courtyards and amenity spaces of Blocks A, B, C and F are generously sized and orientated to receive good levels of sunlight penetration. Block E1 would however benefit from similarly defined shared amenity space given the scale of this block. This could be achieved by removing/relocating its rear car parking area and extending the amenity space of Block E2.

Architecture

50 The varied and well-considered architectural response to the site and its surroundings is strongly supported and has potential to create a high standard of place-making. As commented above, Block E1 is the least successful building in terms of its relationship with the lower-rise and the more contextual Blocks D and E2. The applicant is encouraged to consider how this block might be reconfigured/refined to provide an improved entrance into the site and improved response to the scale and proportions of Block E2. Inclusive design

51 In general, the scheme is considered well-planned from an inclusive access perspective. However, a number of detailed comments/ queries have been raised in respect of the design of the shared spaces; public lift sizes and thresholds; design of external steps; the provisions of a ‘changing places toilet’; disabled parking bays; the provision of fire evacuation lifts; and wheelchair accessible/adaptable units. These comments have been sent in full to both the applicant and the Council and should be addressed in full prior to Stage 2. Noise

52 The development is in close proximity to a number of significant noise sources including the railway track, road traffic, as well as a number of night time economy and culture businesses. These include Camden Market, Proud Camden, the Roundhouse and three of London’s 94 Grassroots Music Venues, as defined in the Mayor’s Rescue Plan for Grassroots Music Venues. These are The Assembly, The Monarch and Spiritual Caipirinha Bar. Under the provisions of London Plan Policy 7.15, development proposals should seek to manage noise by mitigating and minimising the existing and potential adverse impacts of noise on, from, within, as a result of, or in the vicinity of new development without placing unreasonable restrictions on development or adding unduly to the costs and administrative burdens on existing businesses.

page 10 53 Building on this, and in response to the recent closure of a number of high profile entertainment venues across London, the draft Cultural and Night-Time Economy SPG establishes the ‘Agent of Change’ principle, which puts the onus on the person or business responsible for the change as carrying the responsibility for managing the impact of the change. This means that a residential development to be built near a live music venue, for example, would have to pay for soundproofing. Responsibility for noise management is therefore placed on the ‘agent of the change’.

54 In this regard, whilst the Noise and Vibration Impact Assessment submitted with the application acknowledges the fact that there is a high concentration of entertainment venues in the vicinity of the site; as it stands the noise surveys undertaken do not provide sufficient comfort that the impact of the nearby venue’s noisiest events has been fully considered and addressed. Therefore, the Noise and Vibration Assessment should be revised in consultation with nearby entertainment/ cultural venues to agree appropriate noise survey times and locations in order to accurately record the impact so that the sufficiency of the acoustic and vibration mitigation measures can be verified. In carrying out the assessment, regard should be had to the Professional Practice Guidance on Planning & Noise (ProPG) produced by The Association of Noise Consultants (ANC), the Institute of Acoustics (IOA) and the Chartered Institute of Environmental Health (CIEH) in particular. The revised assessment must be provided prior to Stage 2. Climate change

55 Based on the energy assessment submitted, an on-site reduction of 238 tonnes of CO2 per year in regulated emissions is expected for the domestic buildings, compared to a 2013 Building Regulations compliant development, equivalent to an overall saving of 39%. The domestic buildings are required to meet the zero-carbon target and the applicant should therefore ensure that the remaining regulated CO2 emissions are met through a contribution to the Council’s offset fund. The carbon dioxide emissions and savings for the non-domestic uses currently achieve an on-site reduction of 165 tonnes of CO2 per year in regulated emissions equivalent to an overall saving of 31%, the savings therefore fall short of the 35% target and the applicant should therefore commit to a contribution to the carbon offset fund equivalent to the shortfall. Further information regarding overheating, the use of active cooling, connection to the district heat network, the site heat network, and renewable energy has been requested from the applicant which is required before it can be confirmed that the application meets London Plan requirements.

Drainage

56 The Flood Risk Assessment states that the development will aim to reduce surface water discharge by at least 50%. The residual surface water will be discharged to the local combined sewer network. Whilst there is likely to be some further opportunity for sustainable drainage, the approach proposed would represent the minimum acceptable approach to implementing London Plan Policy 5:13 (Sustainable Drainage). Any attenuation tanks proposed should be designed to also provide benefit during lower order storm events by utilising Method 2 tank design. Further details have been sent direct to the applicant and Council. Air quality

57 London Plan Policy 7.14 requires an Air Quality Neutral Assessment to be undertaken in relation to transport emissions and building emissions. Developments should be at least air quality neutral and minimise exposure to poor air quality.

page 11 58 The reduction in car parking spaces, and the consequent reduction in vehicle movements is welcomed. However, the air quality assessments currently do not provide sufficient information to understand the expected impact of the energy centre, and the air quality neutral assessment is incomplete, the full details of which have provided direct to the applicant.

59 There is a significant opportunity with the re-provision of the petrol filling station to provide support for zero emission vehicle re-fuelling, including hydrogen and electric vehicles in line with Policy 6 within the Mayor’s draft Transport Strategy and Policy 4.3.2 in the draft London Environment Strategy which encourage the take up of ultra-low and zero emission technologies to make sure London’s entire transport system is zero emission by 2050 to further reduce levels of pollution and achieve WHO air quality guidelines. Hydrogen refuelling can be provided at standard pumps alongside fossil fuels, and the opportunity to incorporate the necessary infrastructure during the redevelopment should be taken. Similarly provision of rapid electric charging at hub sites, either in the petrol station forecourt or within the supermarket car park can be done more cheaply and effectively if incorporated at the design stage. This busy refuelling station is an ideal location to design in these future services and should therefore incorporate this facility. Transport

60 The site has a Public Transport Accessibility Level (PTAL) of 6b, the highest possible on a scale of 1a – 6b. It is split into two by a railway line. The southern part, on Juniper Crescent, a private road, is a Morrison’s supermarket and car park whilst the petrol station to the north, fronts onto Chalk Farm Road, a borough highway. Vehicle access to the development site, including for buses, currently takes place from both Chalk Farm Road and Juniper Crescent.

61 The nearest part of the Strategic Road Network is approximately 1km away (Kentish Town Road) and the nearest part of the Transport for London Road Network (TLRN) is approximately 0.6 km away (Camden High Street).

62 An existing bus stand and turning area on site serves two bus routes. Another stand adjacent to the petrol station is used periodically for rail replacement services. Five additional bus routes stop within walking distance on Chalk Farm Road and Maiden Road. Camden Town (London Underground), Chalk Farm (London Underground) and Kentish Town West (London Overground) are all also within walking distance of the site.

63 The nearest strategic cycle route, Cycle Superhighway 11, is currently under construction. It is located approximately 0.5 km away at Regent’s Park. The nearest Cycle Hire docking stations are within walking distance at Castlehaven Road and Arlington Road.

64 As noted in Camden Council’s recently adopted Camden Goods Yard SPD, permeability through the site is currently very poor, and would benefit from improved walking and cycling connections with the wider area.

Trip generation

65 The trip generation associated with the proposed development is unlikely to result in a severe negative impact on London’s strategic highways, public transport, walking and cycling networks, subject to the detailed issues raised below being addressed.

66 A proposed new highway arrangement for the main vehicular site access at Chalk Farm Road and Juniper Crescent is required. However, the current proposal for this junction would increase average driver delays on Chalk Farm Road by up to 28 seconds, affecting six bus services. This is unacceptable. A joint TfL/Council corridor study is underway to assess and

page 12 propose improvements to junctions and signals along Chalk Farm Road and Primrose Hill, to improve conditions for pedestrians and cyclists. Prior to determination, the Transport Assessment (TA) should be updated to take account of the corridor study and specifically estimate and mitigate against the potential bus delay which would result from the development proposals. Subsequently TfL should approve the detailed design of all highway works to ensure that new arrangements are suitable for bus operations and for signalling changes approvals. This should all be secured in any permission.

67 The existing supermarket has 425 car parking spaces which would be reduced to 300 spaces, including 15 Blue Badge / carer spaces. Although a further reduction would be justified given the high PTAL, general provision is within London Plan standards and on balance is acceptable. Permission for 61 car parking spaces at a temporary supermarket on the petrol filling station during construction of the wider development is also being sought. This exceeds maximum London Plan standards by 13 spaces and should be reduced.

68 The new homes and all other land uses on site would be car-free except for 20 Blue Badge spaces. The provision of Blue Badge parking needs further detailed consideration in light of the significant under-provision against London Plan requirements for 57 spaces. This should include a managed approach to allocation. A Car Parking Management Plan should therefore also be secured by condition.

69 Local bus services are likely to be able to cope with additional demand generated by the development, subject to resolution of the potential delays on Chalk Farm Road. The bus stopping and standing arrangement proposed within the site is also satisfactory, subject to the grant of appropriate property rights, drivers’ access to a toilet or dedicated facilities, and suitable re-provision of the rail replacement bus standing.

70 The development may generate up to 272 new London underground (LU) trips in the AM peak. However, Camden Town station currently suffers from crowding and congestion with operational controls being enforced on a regular basis and is more likely to be used by the development than Chalk Farm as it is closer to central London. TfL is therefore delivering a £200 million upgrade to the station largely funded from the current Business Plan which is expected to be completed at a similar time to the development. There is a shortfall of approximately £1 million for necessary changes to the public realm and pedestrian wayfinding at and around the new entrance on Buck Street, which would serve the development. Additionally, improvements are required to the walking and cycling route between the site and the station. The Council should therefore secure a S106 contribution from the applicant for both sets of works to mitigate the development’s impact.

71 Many locations within the site have a Pedestrian Environment Review System (PERS) audit score of zero (out of 5) due to narrow footways, dropped kerbs and a lack of tactile elements for the visually impaired. These parts of the scheme should therefore be redesigned in line with the Mayor’s new focus on delivering healthy streets for London.

72 The framework Travel Plan requires some amendments. The full Travel Plan should be secured by condition/s106 obligation and should promote active and public transport. TfL would support the Council requesting free Cycle Hire memberships for all new residents and wayfinding signage from the applicant. Increased use of Chalk Farm and Kentish Town stations rather than Camden Town should also be promoted, especially for north bound and east-west trips.

73 The submitted framework Deliveries and Servicing Plan (DSP) is broadly acceptable. A full Deliveries and Servicing Plan should also be secured by condition. A freight consolidation centre within the development should be considered, to minimise vehicle journeys, improve the

page 13 reliability and efficiency of deliveries, and reduce local congestion. Both the DSP and Travel Plan should include measures to encourage the use of cargo bikes by customers and suppliers of the new supermarket. In addition, a two-stage Construction Logistics Plan (CLP) condition should be attached to any consent, to ensure production of an outline CLP prior to appointment of a principal contractor, and a detailed CLP prior to commencement. Local planning authority’s position

74 Camden Council planning officers are supportive of the scheme in principle and are currently targeting a planning committee in October. Legal considerations

75 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008, the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application. There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments.

Financial considerations

76 There are no financial considerations at this stage. Conclusion

77 London Plan policies on employment, housing, urban design and heritage, inclusive design, noise, climate change and drainage, air quality and transport are relevant to this application. The application does not comply with the London Plan, but the resolution of the below issues could lead to the application becoming compliant with the London Plan:

• Principle of development: Full details of the affordable workspace must be agreed and secured in the s106 agreement. • Affordable housing: The proposed 39% provision of affordable housing by habitable room is supported as a starting point; however, the applicant must fully investigate the provision of grant funding (and any other available public subsidy) in accordance with London Plan Policy 3.12 and the Affordable Housing and Viability SPG and an early stage review also needs to be included within the s106. • Urban design: Blank frontages to servicing areas and its relationship with the public realm need to be addressed; the design of Block E1 in respect of the ground floor and the provision of shared amenity space should be reconsidered; reconfiguring the ramp to Block F is required; and amendments are required to reduce the sense of enclosure in certain parts of the development. • Inclusive design: Concerns regarding the shared spaces will need to be addressed; the sizes of public lifts confirmed; the design of stepped and ramp access routes; the

page 14 proportion of disabled bays provided; the provision of a ‘changing places toilet’; upgrading some of the lifts to fire evacuation lifts; and comments regarding wheelchair accessible units addressed. • Noise: The Noise and Vibration Assessment should be revised in consultation with nearby entertainment/ cultural venues so that the sufficiency of the acoustic and vibration mitigation measures can be verified in line with the ‘agent of change’ principle. The revised assessment must be provided prior to Stage 2. • Climate change and drainage: The energy strategy does not fully accord with London Plan Policies 5.2 and 5.9. Further information regarding overheating, the site-wide network and renewable energy is required. The final agreed energy strategy should be appropriately secured by the Council, along with S106 obligations for off-site mitigation. Any drainage attenuation tanks proposed should be designed to also provide benefit during lower order storm events by utilising the Method 2 tank design.

• Air quality: The air quality assessment is incomplete. Further information is required to fully assess the air quality impact. Consideration should be given to providing hydrogen refuelling within the replacement petrol filling station.

• Transport: The proposed access on Chalk Farm Road must be revised to ensure it is suitable for bus operations and traffic signals; the car parking proposed for the temporary supermarket during construction exceeds London Plan standards; a S106 contribution to public realm works and a new entrance at Camden Town station should be secured; comprehensive travel, deliveries and servicing and car and cycle parking management plans, and two-stage construction logistics plan should be secured by condition.

for further information contact GLA Planning Unit, Development & Projects Team: Sarah Considine, Senior Manager – Development and Projects 020 7983 5751 email [email protected] Shelley Gould, Strategic Planning Manager 020 7983 4803 email [email protected] Hannah Thomas, Senior Strategic Planner (case officer) 020 7983 4281 email [email protected]

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