Shell Centre, 2-4 York Road, London, SE1 7NA

Site address Shell Centre, 2-4 York Road, London, SE1 7NA

Ward Bishop’s

Proposal s 12/04708/FUL: Part demolition of Shell Centre comprising Hungerford, York and Chicheley wings, upper level walkway, removal of raised podium deck, associated structures and associated site clearance to enable a mixed use development of 8 buildings ranging from 5 to 37 storeys in height and 4 basement levels to provide up to 218,147m2 of floorspace (GIA), comprising offices (B1), residential (C3) (up to 877 units), retail (A1-A5), leisure (D2) and community/leisure uses (D1/D2), parking and servicing space, hard and soft landscaping together with the provision of a new public square, highway and landscaping works to Belvedere Road, Chicheley Street and York Road, modifications to York Road Underground station, 2 link bridges from new buildings to the existing Shell Centre Tower, reconfiguration of York Road footbridge if retained, creation of new vehicular access and other associated works. 12/04699/FUL: Application for external alterations to the retained Shell centre Tower to integrate it with the redevelopment works, to include recladding exposed elements of the building façade. 12/04701/LB: Application for Listed Building Consent for the dismantling, removal, storage and re-siting on-site of the existing Grade II listed Franta Belsky fountain. 12/04702/CON: Application for the part demolition of the existing Shell Centre comprising the wings of Hungerford, York and Chicheley, removal of the upper level pedestrian link bridge that runs through the Shell Centre and removal of raised podium deck and associated structures. Application types and Two Full Planning Permission applications Application Reference 12/04708/FUL , 12/04699/FUL

Listed Building Consent Application 12/04701/LB

Conservation Area Consent Application (Demolition) 12/04702/CON

Case officer details Name: Gavin Chinniah Tel: 020 7926 1257 Email: [email protected]

Applicant Sean Bashforth Braeburn Estates Limited Partnership and Shell International Petroleum Company Limited

Agent Quod

Approved plans and Drawing Numbers Rev No. documents 11016 _C645_B2_P_B3_002 01 11016 _C645_B2_P_B1M_002 01 11016 _C645_B2_P_B1_002 01 11016 _C645_B2_P_B2_002 01 11016_B1_P_00_C645_001 00 11016_B1_P_01_C645_001 00 11016_B1_P_02_C645_001 00 11016_B1_P_03_C645_001 00 11016_B1_P_04_C645_001 00 11016_B1_P_05_C645_001 00 11016_B1_P_06_C645_001 00 11016_B1_P_07_C645_001 00 11016_B1_P_08_C645_001 00 11016_B1_P_09_C645_001 00 11016_B1_P_10_C645_001 00 11016_B1_P_11_C645_001 00 11016_B1_P_RF_C645_001 00 11016_B1_E_E_C645_001 00 11016_B1_E_N_C645_001 00 11016_B1_E_S_C645_001 00 11016_B1_E_W_C645_001 00 2104_C645_B2_P_00_001 00 2104_C645_B2_P_04_001 00 2104_C645_B2_P_08_001 00 2104_C645_B2_P_12_001 00 2104_C645_B2_P_16_001 00 2104_C645_B2_E_N_001 00 2104_C645_B2_E_S_001 00 403_ B3_P_00_C645_501 01 403_ B3_P_00_C645_502 01 403_ B3_P_02_C645_501 01 403_ B3_P_08_C645_501 01 403_ B3_P_14_C645_501 01 403_ B3_P_20_C645_501 01 403_ B3_P_26_C645_501 01 403_ B3_P_29_C645_501 01 403_ B3_E_N_C645_501 01 403_ B3_E_N_C645_502 01 403_ B3_E_S_C645_501 01 403_ B3_E_S_C645_502 01 11016 B4A_P_00_C645_001 01 11016 B4A_P_33_C645_001 01 11016 B4A_E_AL_C645_001 01 11016 B4B_P_00_C645_001 01

11016 B4B_P_17_C645_001 01 11016 B4B_E_AL_C645_001 01 453_B5_P_00_C645_001 00 453_B5_P_02_C645_002 00 453_B5_P_12_C645_003 00 453_B5_E_EN_C645_002 00 453_B5_E_WS_C645_001 00 12013 B6+7_P_00_05_C645_001 00 12013 B6+7_P_06_13_C645_001 00 12013 B6+7_P_14_Roof_C645_001 00 12013 B6+7_P_E_N+S_C645_001 00 12013 B6+7_P_E_E+W_C645_001 00 11016 MP_P_00_C645_001 01 11016 MP_P_01_C645_001 01 11016 MP_P_00_C645_002 01 11016 MP_P_01_C645_002 01 11016_B0_P_00_G710_001 01 11016_B0_P_00_G710_002 01 11016_B0_P_RF_G710_001 01 11016_B0_P_RF_G710_002 01 11016_B0_P_00_G710_012 01 11016_B0_P_00_G710_013 01 10073_03A - 00 10073_03B - 00 10073_003A 01 10073_003B 01 MP_P_00_JA12_001 00 MP_P_01_JA12_001 00 MP_P_TY_JA12_001 00 MP_P_RF_JA12_001 00 MP_P_B1_JA12_001 00 MP_P_B1M_JA12_001 00 MP_P_B2_JA12_001 00 MP_P_B3_JA12_001 00 MP_E_E_JA12_001 00 MP_E_N_JA12_001 00 MP_E_S_JA12_001 00 MP_E_W_JA12_001 00 MP_S_AA_JA12_001 00 MP_S_BB_JA12_09 00 MP_P_00_JA12_002 00 MP_P_01_JA12_002 00 MP_P_TY_JA12_002 00 MP_P_RF_JA12_002 00 MP_P_B1M_JA12_002 00 MP_P_B1_JA12_002 00 MP_P_B2_JA12_002 00 MP_P_B3_JA12_002 00 MP_E_E_JA12_002 00 MP_E_N_JA12_002 00 MP_E_S_JA12_002 00

MP_E_W_JA12_002 00 11016 ST_P_00_C645_001 00 11016 ST_P_00_JA12_001 00 11016 ST_E_N_C645_001 00 11016 ST_E_E_C645_001 00 11016 ST_E_S_C645_001 00 11016 ST_E_W_C645_001 00 11016 MP_P_00_C645_003 00 11016 MP_P_00_C645_004 00

Associated Document Numbers:

BE1.a APPLICATION FORMS BE1.b DRAWINGS FOR APPROVAL BE1.c DRAWINGS FOR INFORMATION BE1.01 PLANNING BE2.01 STATEMENT BE3.01 STATEMENT OF BE4.01 DEVELOPER CONTRIBUTIONS BE1.02.1 DESIGN AND ACCESS BE2.02 STATEMENT BE3.02.1 VOLUME 1: CONTEXT, BE4.02 MASTERPLAN AND DESIGN PROCESS BE1. DESIGN AND ACCESS 02.2 STATEMENT VOLUME 2: BUILDING 1 BE1. DESIGN AND ACCESS 02.3 STATEMENT VOLUME 3: BUILDING 2 BE1. DESIGN AND ACCESS 02.4 STATEMENT VOLUME 4: BUILDING 3 BE1. DESIGN AND ACCESS 02.5 STATEMENT VOLUME 5: BUILDING 4A & 4B BE1. DESIGN AND ACCESS 02.6 STATEMENT VOLUME 6: BUILDING 5 BE1. DESIGN AND ACCESS 02.7 STATEMENT VOLUME 7: BUILDINGS

6 & 7 BE1.02.8 DESIGN AND ACCESS STATEMENT VOLUME 8: BASEMENT BE1. DESIGN AND ACCESS 02.9 STATEMENT VOLUME BE3.02.2 9: SHELL TOWER BE1. DESIGN AND ACCESS 02.10 STATEMENT VOLUME 10: LANDSCAPING AND PUBLIC REALM STRATEGY BE1. 03 ENVIRONMENTAL STATEMENT - VOLUME I : MAIN DOCUMENT BE1.03.1 ENVIRONMENTAL STATEMENT - VOLUME II : TOWNSCAPE AND VISUAL IMPACT ASSESSMENT BE1.03.2 ENVIRONMENTAL STATEMENT - VOLUME II : TOWNSCAPE AND VISUAL IMPACT ASSESSMENT

APPENDIX 7 – VIEWS FOR ON-SITE ASSESSMENT BE1.03.3 ENVIRONMENTAL STATEMENT - VOLUME III : TECHNICAL APPENDICES 1 of 2 BE1.03.4 APPENDIX A – Informal and Formal Scoping Report and Opinion BE1.03.5 APPENDIX B – Transport Assessment BE1.03.6 APPENDIX C – Wind Microclimate Technical Report BE1.03.7 ENVIRONMENTAL STATEMENT - VOLUME III : TECHNICAL APPENDICES 2 of 2

BE1.03.8 APPENDIX D – Daylight, Sunlight, Overshadowing, Light Spillage & Solar Glare Technical Reports BE1.03.9 APPENDIX E – Flood Risk Assessment BE1.03.1 APPENDIX F – Ground 0 Contamination Desk Study & Preliminary Risk Assessment Report BE1.03.1 APPENDIX G – 1 Environmental Noise Survey Report & Train Induced Vibration Report BE1.03.1 APPENDIX H – Phase 1 2 Habitat Survey BE1.03.1 APPENDIX I – Heritage 3 Statement BE1.03.1 APPENDIX J – Aviation 4 report BE1.04 ENVIRONMENTAL STATEMENT - NON TECHNICAL SUMMARY BE1.05 TRANSPORT ASSESSMENT BE1.06.1 FRAMEWORK TRAVEL PLAN BE1. RESIDENTIAL TRAVEL 06.2 PLAN BE1.07 STATEMENT OF COMMUNITY INVOLVEMENT BE1.07.1 STATEMENT OF COMMUNITY INVOLVEMENT – APPENDIX DOCUMENT BE1.08 SUSTAINABILITY ASSESSMENT BE1.9 ENERGY STRATEGY BE1.10 HERITAGE STATEMENT BE2.03 BE4.03 BE1.11 SITE WASTE STRATEGY

BE1.12 AFFORDABLE HOUSING STATEMENT BE1.13 RETAIL REPORT BE1.14 REGENERATION AND SUSTAINABLE COMMUNITIES STATEMENT BE1.15 ESTATE MANAGEMENT STRATEGY BE1.16 INTERNAL DAYLIGHT AND SUNLIGHT REPORT BE1.17.1 INTERNAL DAYLIGHT AND SUNLIGHT REPORT – TECHNICAL APPENDIX 1 BE1.17.2 INTERNAL DAYLIGHT AND SUNLIGHT REPORT – TECHNICAL APPENDIX 2 BE1.17.3 INTERNAL DAYLIGHT AND SUNLIGHT REPORT – TECHNICAL APPENDIX 3 BE1.18 Aboricultural Development Statement and Tree Survey

BE2.a APPLICATION FORMS BE2.b DRAWINGS

BE3.a APPLICATION FORMS BE3.b DRAWINGS

BE4.a APPLICATION FORMS BE4.b DRAWINGS

Recommendation(s) Grant planning permission, Listed Building Consent and Conservation Area Consent (Demolition) subject to Section 106 Agreement, conditions, Stage 2 Referral to the GLA and The Secretary of State (SoS).

Report Review

Department(s) or Organisation(s) Date Date Comments consulted response summarised in received paragraph Governance & Democracy (legal) 08.05.2013 09.05.2013 Within Report

Consultation

Department(s) or Organisation(s) Consulted Date response Comments ? (y/n) received summarise d in report? (y/n) Inter nal Building Control Y Private Sector Housing Y Early Years Development Childcare Y Housing Association Section 106 Y Housing Public Health, Animal Welfare, Pest Y Control Noise Pollution Team Y 27.01.2013 Y Arboricultural Officer Y 01.04.2013 Y Lambeth Cyclists Y Lambeth Environmental Consortium Y Planning Policy Y Various Y discussions on the application Sports Y Performance, Strategy and Y 26.02.2013 Y Regeneration Regeneration Partnership Officer Y Various Y discussions on the application Streetcare Y Y Transport and Highways Y 15.02.2013 Y Implementation Team Y Various Y discussions on the application Regulatory Services Entertainment Y 09.01.2013 Licensing Regulatory Services – Food Safety Y Regulatory Services – Noise Pollution Y Regulatory Services – Health and Y Safety Housing Y Various Y discussions on the application Library Leisure Services Manager Y Parks and Open Spaces Y Conservation and Design Y Various Y discussions on the application Urban Design Y Various Y For advice on how to make further written submissions or to register to speak on this item, please contact Governance & Democracy by emailing [email protected] or telephoning 020 7926 2170. Information is also available on the Lambeth website www.lambeth.gov.uk/democracy

discussions on the application Private Sector Housing Y Various Y discussions on the application Ambulance Services Y Health and Safety Department Y Lambeth Arts Y Lambeth Crime Prevention Unit Y Various Y discussions on the application

External Friends of Hatfield Green Y Friends of Jubilee Gardens Y Friends of Archbishop’s Park Y Waterloo Quarter BID Y 01.02.2013 Y Ashmole Tenants Association Y Coin Street Community Builders Y Cleaver Square Residents Association Y Heart of Kennington Residents Y Association Hatch Row Housing Co-operative Y Lambeth Towers and Lambeth Road Y TA Manor of Kennington Residents Y Association Matheson Lang Munroe Tenants Y Association Pearman Street Residents Association Y Whitegift Estate Tenants Association Y EDF Energy Y Metropolitan Police Service Y LFCD Authority Y Fire Brigade Y Transport for London Land Use Y 07.02.2013 Y Planning Team Ancients Monuments Society Y Aerodrome and Air Traffic Standards Y Division Council for British Archaeology Y Cinema and Theatre Association Y Design for London Y Natural England Y 10.04.2013 Y The Garden History Society Y Highways Agency Y London Ecology Unit Y LPAC Y For advice on how to make further written submissions or to register to speak on this item, please contact Governance & Democracy by emailing [email protected] or telephoning 020 7926 2170. Information is also available on the Lambeth website www.lambeth.gov.uk/democracy

National Air Traffic Safeguarding Office Y Off Route Airspace 5 Y Society for Protection Ancient Y Buildings Sport England Y Y Sustrans Y Traffic Director for London Y London Borough of Wandsworth Y Y Corporation of London Y 07.02.2013 Y Commission For Architecture and the Y 27.02.2013 Y Built Environment (CABE) London Underground Infrastructure Y 02.05.2013 Y Protection Port of London Authority Y Y Jubilee Walkway Trust Y Whitehouse Residents and Owners Y 05.03.2013 Y Association South Bank Board Y 06.03.2013 Y South Bank Management Company Y Ltd Twentieth Century Society Y 18.01.2013 Y Association of Waterloo Groups Y Traffic Director for London Y Greater London Authority Y 07.02.2013 Y Kennington Oval and Vauxhall Forum Y Lambeth Estates Residents Y Association South Bank Employers Groups Y 25.02.2013 Y Waterloo Community Development Y Group Kennington Association Y English Heritage Y 12.02.2013 Y English Heritage – Archaeology Y 21.02.2013 Y TFL Road Network Development Y Y City of Westminster Y 13.03.2013 Y London Borough of Southwark Y 28.12.2013 Y London Borough of Camden Y 14.01.2013 Y Environment Agency Y 16.01.2013 Y Network Rail Y 06.05.2013 Y Victorian Society Y The Georgian Group Y Development Control Department Y Check Date Y Thames Water The Westminster Society Y County Hall Residents Association Y 02.03.2013 Y Coin Street Community Builders Y Ambulance Services Y National Air Traffic Safeguarding Y 03.01.2013 Y For advice on how to make further written submissions or to register to speak on this item, please contact Governance & Democracy by emailing [email protected] or telephoning 020 7926 2170. Information is also available on the Lambeth website www.lambeth.gov.uk/democracy

Southern Gas Networks Southern Gas Y 31.01.2013 Y Sewers Major Development – Thames Y 16.04.2013 Y Water Theatres Trust Y 07.03.2013 Y

Background Documents Case File (this can be accessed via the Planning Advice Desk, Telephone 020 7926 1180)

For advice on how to make further written submissions or to register to speak on this item, please contact Governance & Democracy by emailing [email protected] or telephoning 020 7926 2170. Information is also available on the Lambeth website www.lambeth.gov.uk/democracy

Executive Summary

This application relates to the redevelopment of the site between Belvedere Road, York Road and Chicheley Street popularly referred to, given the continued occupation by Shell Petroleum since the 1960s, as the Shell Centre.

Four associated applications dealing with Planning, Conservation Area Consent and Listed Building Consent are in front of the authority for consideration.

Consent is sought for redevelopment of the site, with the retention of the Shell Centre Tower that fronts Belvedere Road, and the South Bank. It would involve the erection of eight new buildings, rising from five up to 37-storeys. The development would deliver additional office accommodation to the site, alongside retail and leisure floor space securing jobs for the Borough. It would introduce residential development to the site, deliver both on and off-site affordable housing and capture future value of the site under a review mechanism. It would result in a true ‘mixed use’ development whilst facilitating the retention of Shell Petroleum who would act as an anchor. This secures certainty to the delivery of the scheme and in turn offers impetus for development objectives of the wider Waterloo Area by their continued commitment to be located here.

The development seeks to respond to the objectives for the site as set out within policy, at both a local, regional and national level. The site is required to contribute to both strategic and local needs, being an Opportunity Site situated within the Central Activities Zone as designated within the London Plan and the development would enable the area to play a fuller role in London’s economy.

The report presents the development in detail, setting out the planning issues together with the representations received in response to the application. The planning merits of the scheme are justified given the proposals response to the context of the site, both in terms of its urban setting and the wider policy objectives that underlies its position within Waterloo. Consequently, when brought together, Officers are able to recommend the application for approval subject to Conditions and the completion of a Section 106 Legal Agreement securing a package of mitigation to the impact of development and additional regeneration benefits.

The site is situated within a historic setting, both a Conservation Area, in the setting of adjacent Listed Buildings and the World Heritage Site of the Houses of Westminster on the north bank of the Thames.

Given the above, the proposed demolition at the site gives rise to the need for Conservation Area Consent. The aspirations for the site necessitate demolition to achieve a development as equal to that proposed which can achieve significant public benefit to the immediate area, as well as to the Borough and to secure London as a ‘World Class Place’. The demolition would see the loss of existing structures at the site, for which the Centre as a whole is considered to make a positive contribution to the Conservation Area. However, it is considered by officers that whilst the loss would result in harm, this harm would be less than substantial harm. The public benefits of the scheme far outweigh the impact that would result in their loss, and for which the redevelopment of the site would enhance the character and appearance of the Conservation Area.

In this respect, one of the principle issues is the design, heritage and impact on views; here both Westminster Council (WC) and English Heritage (EH) raise objection. Whilst the development would result in harm, this harm would be less than substantial harm and as a consequence, the tests anticipated by EH and WC to justify the harm are not relevant.

Currently, whilst the buildings provide a positive contribution to the setting of the Conservation Area and the Shell Centre Tower is occupied, the site is a poor neighbour in the absence of active frontage, lack of permeability and gives no contribution towards the strategic role of the CAZ. The proposal is brought forward from an overarching Master plan approach commissioned by the Applicant. The Master plan provided overarching principles for development of the site, securing a holistic vision of the site that similarly does not stifle the expertise of individual architects in bringing forward individuality to the different buildings across the site, improving the immediate public realm around the site and providing routes through to give improve permeability between Waterloo Station and the South Bank. This has ensured complementary proposals across an ‘urban block’ under signal ownership, giving due regard to its dialogue with its neighbours, both internal to the proposal and external to the site. The form of development, set out within the Master plan, follows good townscape principles, stepping up towards the station and providing a marker to this key nodal point within the station. Local Conservation Areas and the key view within the World Heritage Site are uncompromised. In respect of the latter, the proposal does not compete with the internationally iconic feature of the Queen Elizabeth Tower.

The GLA give broad support to the schemes design, and CABE have endorsed the principles of the Master plan approach to set the threshold from which the proposed development has thus evolved.

A second key consideration is the impact of the viability of the scheme on its ability to be policy compliant. In this respect it is the capability of the scheme to deliver the maximum reasonable quantum of affordable housing that needs consideration. The application has been subject to the submission of a financial viability assessment, verified by BNP Paribas on behalf of the authority. The viability of the scheme is challenging but the provision of twenty per cent affordable housing is considered to engage with the policy requirements in this respect, alongside the imposition of a review mechanism which would see a capped contribution of £24, 480,000.00 payable to the authority, based on a calculation of the equivalent additional affordable housing required to allow the 40% policy target to be achieved over the on and off-site residential component.

It is inevitable given the objectives sought to be delivered at the site that an impact would result. Notwithstanding, the impact is fully addressed by the imposition of conditions and wide range of S106 obligations securing benefits for the wider Waterloo community as well as the Borough as a whole. It would ensure Lambeth residents can play a greater role in London’s economy through a package of local labour, construction and end use employment at the development which local people will be able to access. It would secure the authorities role in achieving the economic aspirations for London as anticipated by the Central Activity Zone designation for the site. In this respect, the implementation of the development would give rise to not only additional

jobs in the Borough but also contribute towards strategic objectives for London in its promotion as a World City.

Overall, officers recommend the proposal for approval.

1 Summary of Main Issues

1.1 The main issues involved in this application are:

• Principle of development; • The acceptability of the scheme in terms of the increase in office floor space (Use Class B1); • The acceptability of the introduction of residential units (Use Class C3) on the site; • The provision of affordable housing associated with the development; • The provision of retail uses within the development; • The acceptability of the proposed space standards for the residential units together with private amenity space; • The public realm improvements associated with the scheme; • The regeneration benefits the proposal provides within the Waterloo area; • The demolition of the existing building along with the high-level footbridge on York Road. • The acceptability of a tall buildings on the site; • The impact the proposed design, massing, scale and bulk would have on the visual amenity of the area • The impact the development would have on the South Bank, Waterloo and South Bank conservation areas; • The impact the development would have on the setting of various heritage assets in close proximity of the development; • The impact the development would have on safeguarded views such as The Palace of Westminster World Heritage Site and Blue Bridge in St James’ Park. • The impact the development would have in terms or residential amenity such daylight, sunlight, sense of enclosure and privacy; • The environmental and cumulative impact the proposed development has within the built environment; • The acceptability of the highway proposals; • The proposed connection of the development to the South Bank; • The acceptability of the development in terms of sustainability and carbon emissions from the proposed scheme and • The Section 106 Contributions associated with the scheme.

2 Site Desc ription and Surrounding Area

2.1 The application site is approximately 3.5 hectares (ha) in area and roughly rectangular in shape. The application site includes part of York Road to the east of the Shell Centre, Chicheley Street to the south and part of Belvedere Road to the west. The northern boundary is formed by a railway viaduct that continues to Hungerford Bridge.

2.2 The existing site is used by Shell Petroleum PLC as its UK headquarters and comprises office (Use Class B1) and ancillary accommodation. The Shell Centre includes the Shell Tower which is 28-storeys in height and

adjoining wings which are ten storeys in height. The wings are known as “Hungerford”, “York” and “Chicheley”. The Hungerford wings lies to the north of the Tower, the York wing lies to the east and the Chicheley wing abuts the base of the Tower on its south side. The tower is currently occupied by Shell Petroleum. A bank branch is also located at ground floor level at the corner of York wing and Hungerford wing.

2.3 The main entrance to the Shell Centre is located at the base of the Shell Tower, facing Belvedere Road. The York wing incorporates an entrance to Waterloo Underground Station at ground level. The courtyard formed by the Shell Tower and wings, contains a Grade II Listed bronze fountain designed by Franta Belsky.

2.4 A raised podium is located to the south of the Shell Tower and Chicheley wing. The basement extends under the Shell Tower and wings and include four level car park comprising 320 spaces, private facilities for Shell staff (including a swimming pool, sports hall and former theatre) and plant equipment. Existing vehicular access to the site is from York Road, Belvedere Road and Chicheley Street.

2.5 Surroundings and Locality

2.6 A railway viaduct lies directly to the north of the site. Sutton Walk passes underneath the viaduct from the site to Concert Hall Approach. This leads towards the Royal Festival Hall (Grade 1 Listed) and under the South Bank complex as well as the Whitehouse apartments located to the north of the viaduct. The Whitehouse apartments’ building previously formed part of the Shell Centre and was known as the Shell ‘Downstream’ site, before being converted into residential use.

2.7 To the west of the site Belvedere Road and beyond the River Thames lies Jubilee Gardens. Jubilee Gardens is designated Metropolitan Open Land (MOL), which has been recently landscaped. This MOL designation extends to the north across Hungerford car park adjacent to the north of Jubilee Gardens. Between the car park and the railway viaduct is the service road for the Royal Festival Hall.

2.8 To the south of Jubilee Gardens and along the riverside, lies the London Eye, with the County Hall complex and the North Block located to the south of the Shell Centre podium part of the site. It comprises predominately residential accommodation with commercial uses on the ground floor.

2.9 On the opposite side of York Road from the site is Elizabeth House. Elizabeth House is a three linked 1960’s buildings which are 16, 10 and 7 storeys in height. The building is currently being used for office accommodation on the upper floors with retail uses at ground level along York Road.

2.10 The site lies adjacent to the Waterloo Station which acts as a major transport hub for national rail, bus and underground services. The Waterloo International Terminal (WIT) is located beyond Elizabeth House on the east

side of York Road. The Bakerloo underground line runs below the existing Shell Centre basement east to west. The Northern Line runs below the eastern part of the site, northwest to southeast.

2.11 The site is situated within the wider Central Activity Zone (CAZ) for which the shopping area at Lower Marsh is located to the southeast of Waterloo Station and is identified as being a district local centre. The majority of the site, up to the median strip on York Road, is located within the South Bank Conservation Area. A number of further conservation areas are located within the wider Waterloo area which includes Lambeth Palace, Waterloo and Roupell Street.

2.12 The Shell Centre Tower is locally listed and in addition to the Franta Belsky Fountain and Royal Festival Hall a number of other listed buildings are located within 0.5km of the site, which include the following:

• Main Block of County Hall (Grade II*) • Royal National Theatre (Grade II*) • Waterloo and Westminster Bridges (Grade II*) • Church of St. John with All Saints (Grade II*) • Victory Arch, Waterloo Station (Grade II) • General Lying-In- Hospital (Grade II)

2.13 In addition, the Westminster World Heritage Site (WWHS) is located across the River Thames to the southwest of the site, which is made up of Big Ben and the Houses of Parliament.

3 Planning History

3.1 Planning permission was granted at appeal on the part demolition of existing structures (including the elevated pedestrian walkway and stairs down to Belvedere Road), change of use of the ground, lower ground and basement levels and provision of additional floorspace to provide shops (Class A1); professional and financial services (Class A2); cafes and restaurants (Class A3) to incorporate sitting out areas; leisure uses (Class D2); and offices (Class B1), together with the construction of office building for B1 offices and Class A purposes on the podium of the Shell Centre (Appeal Reference: APP/N5660/A/03/1111998, LBL Reference: 01/02543/FUL).

3.2 Conservation Area Consent (demolition) was granted at appeal for the demolition of part of existing structures at the existing Shell Centre, including reconfiguration of the basement and ground floor levels, removal of upper level pedestrian link and bridge through Shell Centre and across Belvedere Road, and removal of raised podium deck and associated structures (Appeal Reference: APP/N5660/E/1111997, LBL Reference: 01/02571/CON).

3.3 Listed Building Consent was granted at appeal for works for dismantling and removal of a Grade II listed Franta Belsky fountain from existing Shell courtyard , the temporary safe storage and re-siting of the fountain to new location (Appeal Reference: APP/N5660/E/03/1111996, LBL Reference: 01/02572/LB).

3.4 The site lies within the Palace of Westminster, Westminster Abbey and St Margaret’s Church which were inscribed as a cultural World Heritage Site in 1987. The designation of this group makes them one of 851 buildings and sites worldwide considered to have ‘outstanding universal value’ and to be part of the world’s cultural and natural heritage. The west side of the Thames from the site lies within White Hall, Savoy, Strand, Westminster Abbey and Parliament Square Conservation Areas.

4 Proposal

This section of the report discusses the proposals submitted by the applicant in turn by application reference:

4.1 The main planning application (12 /4708/FUL) is for the following:

Part demolition of Shell Centre comprising Hungerford, York and Chicheley wings, upper level walkway, removal of raised podium deck, associated structures and associated site clearance to enable a mixed use development of 8 buildings ranging from 5 to 37 storeys in height and 4 basement levels to provide up to 218,147m2 of floorspace (GIA), comprising offices (B1), residential (C3) (up to 877 units), retail (A1-A5), leisure (D2) and community/leisure uses (D1/D2), parking and servicing space, hard and soft landscaping together with the provision of a new public square, highway and landscaping works to Belvedere Road, Chicheley Street and York Road, modifications to York Road Underground station, 2 link bridges from new buildings to the existing Shell Centre Tower, reconfiguration of York Road footbridge if retained, creation of new vehicular access and other associated works.

4.2 Breakdown of uses and floorspace:

• Residential (Use Class C3): up to 110,198sqm • Office (Use Class B1): 76,043sqm • Retail (Use Classes A1-A5) up to 5,986sqm • Leisure and Community: 2,557sqm • London Underground ticket hall: 330sqm • Basement/ Servicing: 23,037sqm • Total: up to 218,147sqm

4.3 Building Uses and Typology:

• Buildings 1 and 2: Office (B1) and retail (A1-A5) • Buildings 3, 4a, 4b, 5, 6 and 7: Residential (C3) and Retail (A1-A5) • Basement: Retail (A1-A5), Leisure and Community (D1/D2)

4.4 Mix of residential units:

The application proposes a total of 877 residential units. There would be a total of 779 private units onsite, with the remaining units (98) split between affordable rent (extra-care) (52 units) and intermediate (46).

4.5 Basement Level:

The redevelopment proposes a mezzanine plus three levels of basement. The basement would provide all the servicing, parking and storage associated with the development. Vehicle access would be via Chicheley Street. The basement levels would span the entire width of the development.

4.6 The application proposes a total of eight new buildings following parameters set out within a master plan commissioned by the applicant to address the objectives of the site within the wider area. Building 1 would front both onto York Road and Chicheley Road, this building has already been pre-let to Shell International Petroleum. The use of this building would be mainly office accommodation (Use Class B1). The building would be part 12, part 11, part 9, part 8 and part 5 storeys in height. This building would be 61.62m at the highest point and would have a floorspace of approximately 32,446sqm, including associated plant, whilst the ground floor accommodates 1,671sqm of retail floor space. The floor plan of the building has been influenced to accommodate trading floors for Shell. A covered walkway is propos ed between buildings 1, 2 and the existing Shell Tower. Building would incorporate bridges at floors 3 and 8 that link to the Shell Tower. The proposed links into the Shell Tower have been submitted under a separate application (12/04699/FUL).

4.7 The ground floor of this building would comprise of an office lobby and retail function which would face onto York Road and the main north-south route passing through the site. The proposed façade of building 1 consists of three solid framed elements which step up in height to the north, separated by further glazed elements. The solid frame is constructed from reconstituted stone with recessed metal framed glazing. Between the stoned framed bays, a series of bronze fins at regular intervals would be installed. Roof terraces have been proposed at floors 5, 8 and 9, which would be used ancillary to the office use. Roof planting would be installed at roof level.

4.8 Building 2:

This building would front York Road to the north of Building1 at a height of 84.5m and provide 37,445sqm (GIA), of which 36,619sqm would be office (Use Class B1) floorspace, from floors 1 to 16. A total of 826sqm would be used for retail floorspace, facing onto York Road and the public square. The office accommodation would be accessed from York Road.

4.9 The proposed facades of the building would have a glass treatment. The design and access statement states “high quality glass, metal panels and detailing creates an elegant envelope that enhance the building form”. The application proposes a series of winter gardens and a roof terrace at floor 16.

4.10 Building 3:

This would also be facing York Road, to the north of Building 2. It would stand to a height of 109.50m, 32 storeys, and occupies the northeast corner with the Shell Centre masterplan. The ground floor of the building would incorporate an upgraded ticket office and entrance lobby to the existing London Underground Station from York Road. The ground floor area would also accommodate two retail units, a retail service core and three residential cores. The application proposes above ground floor level, three residential tenures, affordable rent (Extra Care), intermediate rent and private tenure from the 1 st to the 28 th floor. This building proposes two scenarios, firstly the footbridge remaining and secondly the footbridge being demolished. In both events the retail offer would be different:

• With Bridge: 590sqm • Without Bridge: 467sqm

4.11 There would be a total of 52 affordable rent units (extra-care) and 46 intermediate units. The extra care apartments are designed with needs of older people in mind and enabling the provision of varying levels of care and 24hour support on-site. All the units would be provided as or adapted to wheelchair accessible units. All have wet rooms in place of standard bathrooms with some of the units potentially including adjustable kitchen worktops within the units, and provided with level access to a balcony or winter garden for provision of private amenity space.

4.12 The remaining units within this building would be private, totalling 203 residential units. A total of 10% units would be wheelchair accessible (20 units). All these units would have level access to one or two balconies/ winter gardens for provision of private amenity space.

4.13 The application proposes an option to retain the high-level footbridge, subject to the determination of the Elizabeth House scheme. However, if the footbridge remains, the applicant has states the stairs into the site would be reconfigured at the western end to run parallel with building 3, with the installation of a new passenger lift and high-level balustrades.

4.14 The proposed building would have a stone precast appearance. Strong vertical piers are integrated into the building. There would be a series of ‘pop out bay windows and winter gardens’ along with a series of flush balconies.

4.15 Buildings 4A and 4B:

The proposed buildings 4A and 4B occupy the northern part of the proposed masterplan for the site. Building 4A would be erected to 126.94m in height, 35 floors. The ground floor would be accommodated by retail floorspace (807sqm) and would accommodate a total of 212 residential units on the upper floors (private tenure). Building 4B would be erected to 104.54m in height, 30 floors. The ground incorporates retail space (150sqm), with the remaining upper floors accommodated by 158 residential units (private tenure).

4.16 The two buildings would provide amenity space through balconies and winter gardens. The proposed appearance of the two buildings would provide a rigid structure, with the installation of rigid frames. The horizontal spandrels divide the frame into four floors per group, which assist in breaking down the scale of the towers. The proposed materials used would be drawn from the neighbouring existing buildings such as the Shell Tower and the Royal Festival Hall. The frames would be of reconstituted stone, whereas the cladding infill bays would be a combination of anodised bronze panels and frames with clear glass panels.

4.17 Building 5:

The proposed building would be located on the north western corner of the site, parallel with Belvedere Road to the west. Building 5 would be erected to a height of 56.38m, 15 floors. This building would provide a total of 108 residential units. At ground and mezzanine level, retail use would accommodate this space (1335sqm).

4.18 The proposed appearance of the building would have a ‘carved’ nature. There would a solid stone material proposed throughout the elevation. The proposed materials are in response to the materials in existence along the South Bank.

4.19 Buildings 6 and 7:

These two buildings are situated towards the south western corner of the master plan site and would be erected to a height of 75.97m (building 6, 21 floors) and 43.48m (building 7, 11 floors). Building 6 would provide a total of 67 private residential units, along with building 7 providing a further 31 private residential units. The ground floor element of building 7 would provide 403sqm of retail floorspace. Whilst building 6 would provide 66sqm. It should be noted that these two buildings would be linked.

4.20 The ground floor element of the building would be clad in a palette of precast stone and bronze materials, which would relate to the existing buildings on the South Bank, such as the Shell Tower and Royal Festival Hall. The base of the buildings is defined by a double storey expression of the stone frames to provide a civic scale which characterises the stone buildings on the River Thames. The upper floors would be expressed with large glazed areas, with minimal frames. There would be stoned framing throughout the building as well on the upper floors.

4.21 The applicant has submitted three further applications which are as follows:

4.22 (12/04699/FUL) : A further full planning application has been submitted for external alterations to the retained Shell Centre Tower, which would facilitate the integration of the building within the development.

4.23 This application would involve the re-cladding of the exposed facades following the demolition of the attached wings to the tower. This would be made good to match the existing appearance of the building.

4.24 The applicant has stated that the existing Shell Centre Tower would continue to be occupied by Shell, who would also take occupation of Building 1, it would be necessary to have more than one physical link to allow the company to work efficiently within the two buildings. New links would be created at the 4 th and 10 th floors of the Shell Tower, which would link into Building 1. These links would incorporate glazing steel sidewall truss structures will be used to support the bridge roof and floor level framing to existing beams and connections at the Shell Tower end of the bridges.

4.25 (12/04702/CON) : The application would involve the part demolition of the existing Shell Centre comprising the wings of Hungerford, York and Chicheley. Furthermore, the application would involve the removal of the upper level pedestrian link bridge that runs through the Shell Centre and removal of the raised podium deck and associate structures.

4.26 The applicant has submitted two options in relation to the high-level footbridge, “with” and “without”, this is dependent on the Elizabeth House scheme coming forward, which would propose the demolition of the whole bridge. If the high-level bridge remained the retail floorspace to building 3 would increase slightly. This is as a result of the inclusion of a lift which would adjoin the footbridge

4.27 (12/04701/LB) : Listed Building consent has been applied for as the scheme would involve the removal and relocation of a fountain (Grade II Listed), which was created by a Czech sculptor Franta Belsky. This would be incorporated in a new location between buildings 4B and 5, adjacent to the railway viaduct.

4.28 Public Realm:

The development proposes extensive public realm improvements as part of the scheme. The main emphasis given for the public realm improvements by the applicant is to address a series of key principles which involve:

(i) Creating and establishing an image and identity; (ii) Creating an attraction and destination for people; (iii) Offering a series of amenities; and (iv) Creating a design which is flexible to suit current and future demands including the creation of routes through the site to link up Waterloo Station with the South Bank.

The proposed redevelopment of the Shell Centre proposes over 1ha of public realm within the boundary of the site. There would be an overall increase of 0.3ha over the existing open areas on the site. It should be noted that all these areas would be accessible to the general public and future residents of the site, where as currently pedestrian can only pass over the Shell Centre podium.

The proposed development would create routes throughout the development, increasing the permeability through the development by

pedestrians. This would facilitate links between Waterloo Station, the South Bank and the wider Waterloo Area.

The next few paragraphs describe the proposed public realm improvements.

4.29 Belvedere Road:

This would create a raised crossing point, enhancing links between Jubilee Gardens and the Shell Centre. There would be areas for taxi drop offs along with maintenance and manage for coach drop offs. There would be the retention of planting and the installation of high-quality stone setts across the crossing and drop off areas.

4.30 Chicheley Street:

The applicant proposes improvements on this street which would involve the increase in the street width, bays would be inserted. There would be opportunities for tree planting. Vehicular routes delineated using coloured asphalt and stone paving used for pedestrian routes.

4.31 York Road:

The proposal would widen the crossing at the northern end of York Road by Sutton Walk, to create a level crossing for pedestrians. Similarly the southern crossing by Chicheley Street would also become wider. The median strip would remain as existing, however, this area would be occupied through the planting of trees, flush with the ground to allow informal pedestrian crossing across York Road to be maintained.

4.32 The surfaces of York Road would be retained as asphalt. The proposed crossings would be stone setts to ensure there is a consistency with Belvedere Road and Chicheley Street.

4.33 Arrival Public Square and Sutton Walk:

A new access would be created towards Sutton Walk, which would provide an improved pedestrian access from Waterloo station. Trees would be planted and this area would be stone paved.

4.34 Public Square:

The public square would be located centrally within the development. The perimeter of this space would be activated with ground floor uses and entrances to the residential units on the upper floors of the buildings. The square itself would be paved with an intricate high quality paving ‘carpet’. A water feature is proposed which would be positioned off centre within the square. The feature would be flexible, whereby the water can be switched off to this area, allowing other events and uses to be hosted across this space.

4.35 Groups of trees and planting strips are proposed across this area to soften

the space and add seasonal interest. The area would be effectively used as an area for relaxation and reflection along with the movement of pedestrians through the site.

4.36 Railway Viaducts:

A pedestrian route is proposed alongside the railway viaduct and would be resurfaced with high quality paving to enhance permeability of a new pedestrian route. The scheme offers future potential to increase the public realm in this area by the alteration or demolition of the viaduct ‘spur’ building although this is not part of this application. In addition, subject to agreement with Network Rail, there is the potential to open up the archways to the viaduct which would provide activity to both sides of the proposed pedestrian thoroughfare here.

4.37 Routes through the Master Plan:

There would be a grouping of trees and green gardens which would be positioned between Buildings 1 and 6, Building 4A and 4B and 5, to create enjoyable, green pocket spaces.

4.38 The character of the street between Buildings 1, 6 and 7 is proposed to be a woodland garden. The character of the spaces between Buildings 4A, 4B and 5 would be informal in appearance, ‘traditional’ gardens. The north west/ south east street would be maintained as clutter free routes, which are paved with stone to create direct movement into and through the site. The street located between the Shell Tower and Building 6 and 7 would act as a shared space, likely to be flush with the road giving priority to the pedestrian.

4.39 There would be a ‘woodland garden’, which would create areas of informal green pockets of landscape. Sculptural gardens would be developed which would be used by residents and the general public. A winter garden would be created between buildings 1 and 2.

4.40 Roofs:

The proposed development would incorporate a range of living green and brown roofs and provide roof terraces across the site. Green roofs are proposed on buildings 2, 3, 4B, 5 and 7. Brown roofs are proposed on buildings 4A and 6. Roof terraces are proposed buildings 1 and 2, which have the opportunities to provide space for the office workers and residents. These areas would have spaces for planting, seating and lawn areas, range of extensive and intensive living green roofs and private roof terraces are proposed across the masterplan.

Extensive green roofs are proposed which would potential support smaller plant species (e.g. Sedum and grasses

4.41 Play Space:

Play facilities would not be segregated and fenced off, instead areas would

be pocketed across the site to invite play. This would include distinctive focus points such as informal play equipment set in engaging landscaping, open space and facilities for informal play. Different age groups would be able to make use of the spaces through varying activities at different times of the day. The table below sets out the play standards (sqm) associated with the development:

Age Profile Number of Spaced Proposed Children Required Provision Under 5 Years 40 400 On-site (in part) 5-11 Years 18 180 Off site 12+ Years 10 100 Off-site Total 68 680

4.42 Access, Parking and Servi cing:

The development proposes new pedestrian routes that are aligned to key desire lines, enabling pedestrians for example to exit Waterloo Station and walk through the site to the London Eye, Westminster bridge and the South Bank. The development would provide a new level crossing points across York Road, Belvedere and Chicheley Street to create new connections through the site and into Jubilee Gardens. The creation of new streets, improving permeability across the site.

4.43 A total of 270 car parking spaces would be provided, which would be accommodated within the levels of the development. A total of 20% of car parking spaces are proposed to be fitted with electric charging points. In addition to these, two car club spaces are proposed on the eastern side of Belvedere Road. The development would also provide a total of 50 motorcycle spaces. Vehicles would be strictly controlled in terms of their access to and movement around the site, entering the basement via a ramp off Chicheley Street.

4.44 The development has been designed to be fully accessible to the mobility impaired and 10% of the proposed residential units have parking designed to disabled standards. In addition 10% of all commercial parking is designed in accordance with the London Plan.

4.45 The proposed cycle parking would be accommodated within the basement levels, accessible to residents. Access would be via lift core within each residential building. Office and retail employees would access the commercial cycle parking via two dedicated lifts and a staircase positioned at ground floor within building 1.

4.46 The development provides all servicing, waste collection and storage to take place below ground, within the basement. There would be no servicing or

waste collection from street as part of the redevelopment proposals. All service vehicles would access a basement loading bay via a ramp from Chicheley Street. The ramp is situated within the building 1 footprint. The entrance and exist routes would be suitable to accommodate service and waste vehicles up to 10m in length.

4.47 Waste Management:

Refuse collection is divided into commercial and residential streams. Residential waste would be collected by Lambeth, while the commercial waste would be under private contract. Residential waste would be split into three waste streams: recyclable, non-recyclable and organic, which are collected via gravity chute system located in the access corridors at each floor level. A vacuum based waste collection system is being proposed, which would comprise of waste pipes serving each of the residential buildings with waste access points at each floor level. The pipes from each of the buildings would be interconnected and routed to a central waste collection point for the development. The pipes are maintained under vacuum which ‘transports’ the waste to the central collection point.

4.48 A total of 74 euro bins would be required to store all residential waste based on an un-compacted residential waste strategy. This would be stored within the basement. Furthermore two compactors would be installed for recyclable and non-recyclable waste streams in the loading bays. Commercial waste would be segregated into general waste, dry mixed waste and glass.

4.49 Energy Strategy , Sustainability, BREEAM and Code for Sustainable Homes:

4.50 A central Energy Centre would be provided comprising gas-fired boiler and Central Heat Pump (CHP) plant, water cooled chiller plant and heat rejection planted located at roof level of building 3. A primary heating circuit would circulate water to the boilers and CHP plant, and secondary heating circuits would circulate low temperature hot water (LTHW) heating to each building via a site wide heating network.

4.51 Plant would generally be located at basement and roof levels with vertical connectivity via the main central core of each building.

5 Consultations and Responses

5.1 Braeburn Estates Limited Partnership and Shell International Petroleum have undertaken extensive public consultation with various stakeholders and the local community prior and post submission of the proposed scheme to the London Borough of Lambeth. The applicant has compiled a comprehensive document produced by the public relations company ‘Soundings’ on the consultation stages for the application.

5.2 The applicant has stated that mail-outs; website updates; leaflet drops; Shell Centre dialogue hotline calls; exhibitions; workshops; consultation base;

hoardings and adverts were the methods used to carryout consultation for the scheme. A single ‘hub’ on the York Road entrance side of the Shell site has been used for public displays.

5.3 Lambeth Planning carried out the following consultation:

A total of 22 site notices were displayed on the 28.12.2012. A press advert was published on the 28.12.2012. A number of drop-in events were arranged by the applicant and where officers of the Councils Planning and Transport department were present. The application went out for reconsultation following the applicant amending the scheme on the 9 th April 2013, with a further press advert published on the 12.04.2013. A further 10 site notices were displayed.

Internal consultation

The following section of the report presents the responses received from colleagues across the Council, and for which the detail of comments is presented within the planning assessment section.

5.4 Building Control: Comments received raising no objection.

5.5 Private Sector Housing: No representations received.

5.6 Early Years Development Childcare: No representations received.

5.7 Housing Association Section 106 Housing: No representations received.

5.8 Public Health, Animal Welfare, Pest Control: No representations received.

5.9 Arboricultural Officer: Comments received raising no objection, subject to condition being imposed.

5.10 Lambeth Cyclists: No representations received.

5.11 Lambeth Environmental Consortium: No representations received.

5.12 Renewable Energy Project Officer: No representations received.

5.13 Lambeth Sports: No representations received.

5.14 Performance, Strategy and Regeneration: Comments received raising no objection subject to conditions being imposed.

5.15 Streetcare: Comments received raising no objection subject to condition being imposed.

5.16 Transport and Highways: Comments received raising no objection subject to conditions being imposed and Section 106 Contributions being secured to mitigate the impact of the development in the Waterloo area.

5.17 Implementation Team: Comments received raising no objection.

5.18 Regulatory Services Entertainment Licensing: Comments received raising no objection.

5.19 Regulatory Services – Food Safety: Comments received raising no objection subject to conditions.

5.20 Regulatory Services – Noise Pollution: Comments received raising no objection subject to conditions being imposed, safeguarding residential amenity.

5.21 Regulatory Services – Health and Safety: No representations received.

5.22 Housing: Comments received raising no objection.

5.23 Library Leisure Services Manager: No representations received.

5.24 Parks and Open Spaces: Comments received raising no objection.

5.25 Conservation and Design: Comments received broadly in support of the proposed development.

5.26 Private Sector Housing: No representations received.

5.27 Ambulance Services: No representations received.

5.28 Health and Safety Department: No representations received.

5.29 Lambeth Arts: No representations received.

5.30 Lambeth Crime Prevention Unit: Comments received raising no objection to the proposed development subject to conditions being imposed.

External Consultation

5.31 The following section of the report presents the responses received from external bodies. Any concerns raised are addressed within the planning assessment section of the report.

5.32 Friends of Hatfield Green: No representations received.

5.33 Friends of Jubilee Gardens: No representations received.

5.34 Friends of Archbishop’s Park: No representations received.

5.35 Waterloo Quarter BID:

Comments received in support of the application

The proposed Shell Centre development would be an exciting new addition to the area that will help raise its profile as a great place to do business. The proposed increase in permeability is strongly supported through the site and the improved access this will bring from the riverside into the heart of the Waterloo area. These key west-east walking routes have been inaccessible for too long and the development has the potential to overcome some of the blockages to pedestrian movement caused by the current site layout and surrounding public realm. This is a key aspiration of Waterloo Quarter BID and we would expect to see this trend continued in future developments in the surrounding area, including the development of the station itself.

It is considered essential that established local venues and retailers are given the opportunity to benefit from the greatly increased customer base that the development will bring. There are major challenges to pedestrian movement in Waterloo caused by the physical barrier of the station and this will still remain an issue when the site is developed. In light of this, we welcome the developer’s willingness to consider how significant new worker and resident population on the site could be drawn out into the surrounding area, in particular that to the east of the station, for the benefit of local businesses. We would urge continued efforts to facilitate this through appropriate promotions that integrate the new development within the wider offer of the are as a whole.

5.36 Ashmole Tenants Association: No representations received.

5.37 Coin Street Community Builders: No representations received.

5.38 Cleaver Square Residents Association No representations received.

5.39 Heart of Kennington Residents Association: No representations received.

5.40 Hatch Row Housing Co-operative: No representations received.

5.41 Lambeth Towers and Lambeth Road TA: No representations received.

5.42 Manor of Kennington Residents Association: No representations received.

5.43 Matheson Lang Munroe Tenants Association: No representations received.

5.44 Pearman Street Residents Association: No representations received.

5.45 Whitegift Estate Tenants Association: No representations received.

5.46 EDF Energy: No representations received.

5.47 Metropolitan Police Service: On-going discussion with the applicant.

5.48 LFCD Authority: No representations received.

5.49 Fire Brigade: No representation received.

5.50 Transport for London Land Use Planning Team:

5.51 Ancients Monuments Society: No representations received.

5.52 Aerodrome and Air Traffic Standards Division: No representations received.

5.53 Council for British Archaeology: No representations received.

5.54 Cinema and Theatre Association: No representations received.

5.55 Design for London: No representations made.

5.56 Natural England: Comments received raising no objection to the proposal.

5.57 The Garden History Society: No representations received.

5.58 Highways Agency: No representations received.

5.59 London Ecology Unit: No representations received.

5.60 LPAC: No representations received.

5.61 National Air Traffic Safeguarding Office: Comments received raised

5.62 Off Route Airspace 5: No representations received.

5.63 Society for Protection Ancient Buildings: No representations received.

5.64 Sport England: Comments received raising no objection to the scheme.

5.65 Sustrans: No representations received.

5.66 Traffic Director for London: No representation received.

5.67 London Borough of Wandsworth: Comments received wishing not to make an observation.

5.68 Corporation of London: Comments received wishing not to make an observation.

5.69 Commission For Architecture and the Built Environment (CABE):

Comments received generally in support of the proposed development, however, some concerns were raised, which are listed below:

• Given the density development and the large number of people crossing the site on their way from Waterloo Station to the South Bank Centre and the river, the scheme requires a clear public space strategy to offer relief and to become a pleasant piece of the city. We are pleased to see a new public space at the heart of the proposal. However, we feel that two

aspects of the public space strategy should be revisited. In our view, the site organisation could be further improved to enable straightforward movement across the site. We question the presence of the large number trees, particularly the trees under the canopy, and encourage the design team to strengthen the east-west routes and to revisit the different zones of the square in terms of their use and type of activity • Secondly we think that the bottle neck situation between the railway arches and building 4A is unfortunate, creating an extremely narrow passageway. Every effort should be made to move the colonnade away from the railway structure which obstructs the route to the Southbank or to remove the railways structure which obstructs the route to the South Bank or to remove the railway structure, an to provide a more generous space that will be able to accommodate the large number of pedestrians. • We also think that the pavement along York Road could perhaps cause problems in terms of the large number of office workers accessing building 1. The buildings along York Road could benefit from more animated frontages to create a pleasant pedestrian experience along this busy road. We urge the design team to consider the introduction of the colonnades which would provide a protected space, particularly when taking into account climate change adaptation and appropriate sun shading measures. Given the potential redevelopment of adjacent site and the removal of the pedestrian bridge from Waterloo Station, the proposal ahs to be flexible enough to respond to different scenarios and changing parameters. The area in front of building 4A needs to provide a successful public space that is both able to work on its own and conjunction with Victory Square as part of Elizabeth House. • We welcome the composition of the buildings around the retained Shell Tower and the family relationship between them. We suggest, however, recessing how the Tower could be more integrated into the scheme in terms of use and accessibility. Taking design cues from the existing buildings and the limited pallet of materials across the site is accomplished elevational treatments. The success of the structure will depend on high quality materials and detailing. Given its prominent location on the river the site has to always immaculate and age and whether gracefully. To preserve this quality throughout construction, we urge the client to continue using the same design teams. • A project of this scale in single ownership has the potential to become exemplar in terms of sustainability and environmental strategies and we do not think that the scheme has yet achieved this. We urge the client and design team to think in more detail about climate change and adaption in terms of the building orientation and shading and we also think that the number of single aspect flats could be reduced.

5.70 London Underground Infrastructure Protection:

Comments received raising no objection to the proposal subject the detailed design of the London Underground Station being secured.

5.71 Port of London Authority:

Comments received raising objection to the proposed development on the

following grounds:

• The targets set for river services are disappointing given the London Plan’s target of a 50% increase in passengers and freight transported on the Blue Ribbon Network from 2011-2021. It is of note that since the application was submitted the Mayor has published a River Action Plan which sets a target to increase passenger journeys on the Thames to 12 million a year by 2020 and to maximise its potential for river travel. The plan refers to working with developers to identify opportunities to enhance existing piers; and working with developers to maximise the integration of existing piers with the development and local transport network. Against this background the target of 60 in and 55 out by “other modes” (which includes river transport) seems very low out of a total of 23, 002 in and 21, 651 proposed trips.

• Consideration should be given to the use of the river for the transport of construction materials to and waste materials from the development site. A condition should be placed on any grant of planning permission requiring the applicant to investigate maximising the use of the river in this way.

5.72 Jubilee Walkway Trust: No representations received.

5.73 Whitehouse Residents and Owners Association:

Comments received raising objections to the proposed development, which are listed below:

• Flawed Consultation Process

We wish to register our complete dissatisfaction with the consultation exercise run by a company called Soundings which is cited in the Planning Statement. Many members of WHORA attended numerous meetings and found the consultation process biased from the outset in favour of a preconceived idea of what the site would look like. There was no meaningful engagement with the local community, and we wish to disassociate ourselves from any suggestion by the Applicant that we support their proposals. Much of the consultation was with people who were just passing through the area and had no connection with the local community. Our views were not taken into account.

• Conservation Area

There are no 'exceptional reasons' to demolish the existing Wing building. The Wing building compliments the 'downstream' building of the original Shell complex, now the Whitehouse residential block and that rhythm should be maintained. The Applicant proposes to replace the Wing building with a dense cluster of towers which will be used for apartments, offices, retail and restaurants. All these uses can easily be accommodated in a refurbished Wing building. Indeed, the Whitehouse Apartments are proof of this. The nationally listed Franta Belsky fountain statue relocation had strict conditions

imposed on the Belvedere Court consent including limiting storage for a max of three years and another possible 6 years hidden away is not acceptable.

• Gross Overdevelopment in a Conservation Area Close to a World Heritage Site

The dense cluster of towers crammed behind the Shell Tower will create a closed in feel, and the Tower will lose its identity amongst these taller buildings. The sense of history of the Shell Centre will be lost forever. The area will become just another high rise nonentity with little regard to its position on the South Bank. Open areas in conservation areas are also protected but the existing square to the north of the Tower will be hemmed in by the proposed tall building with minimum space between. Little sunlight will penetrate through and it will not be a quality 'open space' for people to relax and walk through. We deserve better in this wonderful location on the South Bank. The proposed new square to the north of the Tower, which will be sunless and windswept for the majority of the day, is no improvement to the EXISTING square already there.

5.74 South Bank Centre:

Comments received, supporting the proposed scheme:

• In offering our support in principle for the Shell Centre scheme, we have sought assurances from Braeburn that they will work with us to address a number of issues set out below and which we would like to draw to Lambeth Council’s and GLA’s attention.

Sutton Walk Cultural Gateway

• Sutton Walk is the gateway to the cultural quarter with over 60% of visitors arriving through this route. This is likely to increase further when the Elizabeth House scheme is implemented which would provide a significantly improved exit from Waterloo Station via Victory Arch.

• We therefore sought assurances from Braeburn that there would be improvements to Sutton Walk as part of their scheme and that these improvements would be to no lesser standard of finish than other areas of the development site. We also sought recognition of the importance of this pedestrian route to our cultural venues and site. Braeburn has assured us that, through agreement with Network Rail they will make further improvements as a key part of the Cultural and Place Making Strategy. We welcome this assurance and request that Lambeth Council make this a specific requirement for the grant of planning permission.

Servicing Access

• We discussed Braeburn’s servicing assumptions given their landscaping proposals for Chicheley Street and Belvedere Road and whether these would be compatible with the Cultural Quarter’s current and future service vehicle movements. Our venues and facilities require continuous

servicing from a range of vehicles with a major dependence on HGVs for the delivery of sets, orchestra equipment, live relays from the auditoria, summer festival infrastructure and other temporary interventions.

• The continued ability of our servicing traffic (both volume and scale of vehicles) to continue to use Chicheley Street and Belvedere Road during the period of construction, and once the development is completed, is of critical importance to the sustainability of the cultural quarter.

• Braeburn has explained their proposals in more detail which include improvements to vehicular access to the cultural venues and site along Chicheley Street through removal of obstructions including the pedestrian refuge, taxi rank and bus stop. Improvements to Belvedere Road would include removal of the raised tables and the existing Shell service yard exit point opposite the Southbank Centre service lane along Hungerford Bridge.

• We welcome these improvements and request that Lambeth Council make continuity of servicing access via Chicheley Street and Belvedere Road, (both during and after construction) a specific requirement for the grant of planning permission.

• We have a wider and more general concern around routes through and around the Shell Centre site, access routes and legibility to the new underground entrance, key pedestrian routes such as those crossing York Road and via Sutton Walk, and the impact of Braeburn’s proposals for Chicheley Street and Belvedere Road on pedestrian use and traffic flows, particularly in relation to the intense servicing needs of our three cultural organisations.

• Given this, our view is that all transport and movement issues need much greater input from neighbouring stakeholders than has hitherto been the case and we ask Lambeth Council and Braeburn to ensure that this happens. We therefore ask that the conditions/obligations are explicit and that any S106 or S278 agreements or any other provisions related to the matters we have raised are to be the subject of detailed discussion involving Braeburn, Lambeth Council and adjacent major landowners and users of the adjoining public spaces, including our three organisations.

5.75 South Bank Management Company Ltd: No representations received.

5.76 Twentieth Century Society:

Comments received raising objections to the proposed development

• The planning policy framework for the Shell Centre site is complex and to a degree contradictory. Thus recent and emerging policies (the Waterloo Opportunity Area Planning Framework 2007, the LDF Core Strategy 2011 and the Draft Waterloo SPD 2012) indicate that redevelopment by taller buildings may be appropriate on the site, but statutory considerations and

long-established policies (Section s 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, the LVMF and related Directions, and saved Policy 41(iii) of the Lambeth UDP 2007) indicate that the preservation of important views and the preservation or enhancement of the character or appearance of the conservation area and the setting of the several nearby listed buildings are required. Thus it cannot be claimed that there is clear policy support for these proposals. • Thus the open space creation expected by the Draft SPD as the trade-off of accepting tall buildings on the site does not appear to exist, at any rate not in any useable form. • The ‘cluster of towers’ proposed at the northern end of the site is formed principally by Buildings 3, 4A and 4B which are 31, 37 and 30 storeys high respectively. This assembly is virtually identical to the ‘Three Sisters’ proposal of 2008” • But the present applications would be even more prominent than the ‘Three Sisters’ in views from Westminster and the Thames because they would be closer to the river and with no screening due to the foreground of the MOL of Jubilee Gardens. • The effect of the whole development proposals on the setting of the listed buildings of County Hall, the Royal Festival Hall, the Royal National Theatre, Waterloo Bridge and Victory Arch would be catastrophic due to the wall of development it would present. Though the buildings are separated from one another they are to be built so close together and close to the Shell Tower that there would be few if any glimpses of sky between them. • Even the lower buildings proposed at the southern end of the site (Buildings 1, 2, 6 and 7) would be between 11 and 21 storeys high, apart from the southern end of Building 1 at 5 storeys. They would thus substantially increase the relatively low profile of the skyline when seen from the north bank of the Thames, which is presently around 7-8 storeys, and build up the river frontage of the site to a line of tall buildings. The landmark nature of the Shell Tower would disappear, despite the building itself being retained. • The design principle in the Draft SPD, of buildings on the site stepping down from Waterloo Station towards the river, would not be achieved because the permission for the 29 storey building on Elizabeth House means that the proposed buildings on the Shell site would instead step up to 37 storeys at Building 4A, 31 storeys at Building 3 and 30 storeys at Building 4B. At the southern end of the site, Building 6 adjacent to County Hall and Jubilee Gardens and close to the London Eye would be 21 storeys high, thus increasing building height from Building 1 which is adjacent to York Road and would be of 5-12 storeys. • It is highly questionable whether the density and height of the proposed redevelopment would enable views through to the London Eye from York Road to be retained, as required by the design principles of the Draft SPD. At present the podium site remains clear (albeit with the benefit of the 2004 permission for a 10 storey development) and allows such views. The placing of Buildings 1, 6 and 7 on this site with heights of 5-12 storeys, 21 storeys and 11 storeys is thus a loss compared to the permitted scheme, not a benefit. • However, the analysis by Donald Insall and Partners in December 2010

concluded that the exterior of the building makes a positive contribution to the conservation area, as does the Council’s 2007 Conservation Area Statement, both of which documents appraise the buildings by current, not historic, criteria. • The austere and regular form of the wing buildings and the high quality of materials on all elevations are restrained and yet of the best of their time. Given that it was built in the first phase of the aftermath of post-war austerity, and bearing in mind its scale, the complex is worthy of a more finessed and balanced appraisal than is given by the Heritage Statement. • Because of the less than balanced nature of the appraisal of this undesignated heritage asset and the conclusions the proposals fail to preserve or enhance the character or appearance of the South Bank Conservation Area. The scheme would result in a substantial loss of character due to the extensive demolition of a very significant complex, the compromising of the important landmark of the tower (and of its recent companion the London Eye), by failing to respect the 20th century character of the area and by infilling a significant space forming the backdrop to the Jubilee Gardens MOL with a cluster of tall buildings having none of the quality of finish of the Shell Centre and nearby buildings.

5.77 Association of Waterloo Groups: No representations received.

5.78 Traffic Director for London: No representations received.

5.79 Greater London Authority:

Comments received in relation to the proposed development stating that the application is broadly acceptable in strategic policy terms, however, further, information and/ or clarification as detailed below is required before it can be confirmed that the proposal is in full accordance/ complies with the London Plan:

• The principle of the housing on this site is acceptable, however, the affordable housing offer is still subject of negotiation and verification in order to ensure the maximum reasonable amount is being proposed in accordance with the London Plan Policy 3.12. • There are some detailed design aspects to buildings 4A and 4B ground floor elevations where further discussion is required. • Further detailed discussions on a number of issues, and in particular the London Underground entrance, are required before it can be considered that the application is in compliance with the transport policies of the London Plan.

5.80 Kennington Oval and Vauxhall Forum: No representations received.

5.81 Lambeth Estates Residents Association: No representations received.

5.82 South Bank Employers Groups:

Comments received in relation to the proposed development are listed

below:

• The proposed permeability and public realm improvements are welcomed. • We believe that there is a need for more detailed consideration of the implications of some of these proposals for neighbouring stakeholders. • Heritage issues should not be given undue weight, but should be balanced against the overall economic and community benefits which developments give rise to. • In our assessment the impact of the proposals will have no effect on the ability to appreciate the Outstanding Universal Value of the World Heritage Site which is the key consideration. • Nor do we believe that the visibility of the development in the view from the St James Park Bridge will cause harm. • The figures set out in the application for additional jobs from the development and the potential for economic benefit to the area from local spend by new employees and residents. We also welcome the new retail in the scheme. • We welcome the investment Braeburn have made to the South London Procurement Network and as operators of the Waterloo Job Shop we look forward to working with the developers on job brokerage to prepare for the opportunities created by the development. • Braeburn Estates has contributed to feasibility work on the proposed South Bank Decentralised Energy Network (and the contribution is to be taken account by Lambeth in the Section 106 Package). • Our view is that investment in the South Bank public realm should be the highest priority for Section 106 resources and should have priority over other Section 106 obligations set out in the Councils planning policies.

5.83 Waterloo Community Development Group:

Comments received which are listed below:

Consultation:

Congratulations should be given to the developers for their extensive consultation prior to submitting the application. There have been many events held by them at the Shell Centre and beyond over a nine month period, in addition to attending and presenting the proposals at the public meetings that we arrange. WCDG were engaged in supporting the consultation process at an early stage, focusing on principles before the emergence of a master plan.

Retaining Shell PLC on site:

There is strong support for retaining Shell’s UK HQ in Waterloo: they are generally a good neighbour and positive presence in Lambeth, as well as providing several thousand jobs directly and indirectly. There is therefore acknowledgement of the driver for redevelopment of new large trading floors, and the implications of this in terms of the need to create new

buildings on the site.

The current buildings:

The site has traditionally been seen as bleak, hostile and windswept by local residents, and in need to active frontages at ground floor as well as interventions to improve the microclimate. We therefore supported some elements of the 2004 scheme which addressed these issues. The three major positives of the current site are (i) a recognition of the appropriateness of the current tower in terms of quality, scale, height, and presence; (ii) the open spaces, particularly the podium site, which affords magnificent views of the river and Eye and provides the only decent view of the northbank from the hinterland road (York Rd, Stamford Street, Lambeth Palace Rd) between Lambeth Bridge and Bernie Spain Gardens, as well as the courtyard; (iii) the pedestrian public realm which affords numerous routes through and around the site.

Mix of uses:

There is strong support for a mix of uses to be introduced onto the site, breaking down the monolithic uses of large sites which has been considered a problem by local people for 40 years. There are many benefits to having a mixed use site, including the ability to create more active frontages and spaces which are lived in throughout the 7 days of the week, not simply working hours. The introduction of residential is supported, provided it includes sufficient affordable housing on site, as is the introduction of a relatively modest quantum of A-class uses, and additional offices to provide a range of other tenants. There is support for a reduction in car parking, regret at the loss of the basement swimming pool and theatre, and an aspiration that some other uses emerge in the final mix, such as community uses or other commercial uses.

Conservation Area:

There has been some concern that the approach of the applicant has not been sufficiently sensitive to the requirements which are entailed by the Conservation Area status, to consider ways of re-using the current buildings and minimizing the interventions on the site. It has been suggested that the 2004 approval provides for an additional building on the podium site with suitably large footplates to accommodate the trading floors required by Shell, and that the wings have proven that they lend themselves to conversion to residential by the Shell Upstream/ White House conversion in the 1990s. The applicant is therefore invited to explain why this approach – which would retain most of the existing buildings including the wings, and would better respect the Conservation Area – has not been taken.

The most consistent theme coming through the application from the beginning has been concern at the height, bulk, scale and density of the development.

Heights:

There is a strong view that the existing tower should remain the tallest on the site and the focal point of the development, and concern that this is being undermined by ‘height creep’ which has seen some of the proposed buildings increase by 20% over the height of the tower. There are concerns about the impact of a number of tall buildings close together on the site in terms of shadowing of the public spaces and footpaths between the buildings, impact on daylight and sunlight on the White House and County Hall, the impact on the microclimate, and impact on local and strategic views and various Conservation Areas (Roupell CA, Waterloo CA, South Bank CA), with the proposed buildings out of scale and keeping with the ‘groundscrapers’, houses and medium height buildings in those areas.

Loss of open space:

The application proposes a loss of a large amount of open space at the podium and courtyard, which amounts to over 7,000m2. The podium site was considered an open space of community value by the Secretary of State in his 2004 decision, albeit its loss was justified by the purported benefits of that scheme. Lambeth planning policy precludes loss of open space, with the minimum requirement that any loss is made up for with new open space. The proposed new open space is entirely insufficient for this purpose, as well as there being doubts as to its attractiveness given the tall buildings surrounding it and the lack of direct light it will enjoy. We have consistently encouraged the applicants to seek an arrangement with Southbank Centre to bring about the extension of Jubilee Gardens across the disgraceful Hungerford Car Park, but as yet this has not been achieved. This is an opportunity to finally remove the car park, an aspiration held by Lambeth and the local community since at least 1974. This is possible because the Southbank Centre have finally acknowledged that it is extremely unlikely that the BFI will relocate here and they have no other arts building uses for the site.

In our view the application as it stands is a departure with regard to open space and it needs to urgently be addressed.

Public Realm:

There is the very strongest concern about the minimal amount of pavement space provided in York Rd in particular. The 2m wide footpath is wholly inadequate and will appear extremely intimidating with tall buildings right up to the curtilage of the site. The current plans would force people to walk in the road at peak times. This is simply not acceptable.

There are also concerns that the proposed crossing points on York Rd do not sufficiently match the desire lines created by the proposals and by the arrangement of buildings approved for Elizabeth House.

Servicing:

There have been concerns about the servicing of the site, which sees the number of ingresses onto the site reduced from 5 to 1. It is difficult to believe that this will not place considerable burden on Chicheley Street, with traffic back-ups at peak hours. This could have a serious impact on the residents opposite the site at that point, as well as effectively undermining the attempt to create an attractive boulevard along Chicheley Street.

Community Uses/ arts uses:

There are no specific community uses proposed in the application, although there is a small basement space offered for community uses. The creation of a new generic community space is not appropriate, and we would rather see the public benefit captured in a considerable sum of s106 for a community hub/ library.

At the moment the identity of the development seems unformed, and a strong community or commercial/ arts use could help address that. For example a boutique cinema, an underground skateboarding rink or ice rink, or relocation of the Poetry Library from the Festival Hall would help create a unique identity for the site and would enrich the mix of uses to create a critical mass of activities more likely to prove commercially sustainable. The attractive mix offered at Brunswick Square provides a fitting model.

Affordable housing/ Sheltered housing:

There is very strong support for on-site affordable housing, although housing off site and nearby maybe acceptable, depending on the site. The proposal to have specialist residential accommodation for older people is extremely welcome and supported.

Density:

Many of the concerns raised are indicative of an over-development of the site. We are unaware of any site in London which has such a large amount of development on such a relatively tight site, and would be grateful of examples which may being comfort on this matter.

5.84 Kennington Association: No representations received.

5.85 English Heritage:

A letter of objection has been raised towards the proposed development, these are summarised below:

• The proposed development would be of a scale, mass and form that significantly detracts rather than adds to the picturesque qualities of the view. It would compete with the tower of the Foreign office, diminishing the clarity of its built form. • In the language of the NPPF, the development would thus cause

substantial harm to the setting of the Grade I Park and the Grade I Foreign and Commonwealth Office. • Reservations have been raised towards the impact of the proposals on the setting of Horse Guards from the Guards Memorial and the setting of the Elizabeth Tower in views from Parliament Square. However, the strongest concerns relate to the effect of the proposed development on the view from St James’ Park. • The current design is not a sustainable solution required by the principles of the NPPF. The proposed application could be redesigned to achieve the twin objectives of regeneration of this business quarter whilst conserving heritage assets of the highest importance. • For these reasons, English Heritage considers that the proposals are not sustainable development and therefore fail to comply with national and local planning policy. In particular, it is recommended that the proposed residential towers on the North-East corner of the site be reduced in height to eliminate them from the view from St James’ Park. If necessary, the residential development omitted from this area from this area and accommodated elsewhere on the site, such as through additional floors on building 5. • It is acknowledged that there are public benefits associated with the development; however, these do not outweigh the harm to the historic environment.

5.86 English Heritage – Archaeology: Comments received raising no objection subject to condition being imposed.

5.87 TFL Road Network Development:

Comments received raising no objection proposal subject to the detailed design of the London Underground being secured.

5.88 City of Westminster:

Comments received raising objection to the proposed development, which are listed below:

• The proposed development by reason of the its height and bulk will harm the setting and outstanding universal value (OUV) of the Palace of Westminster and Westminster Abbey including St Margret’s World Heritage Site. • The proposed development by reason of its height and bulk will adversely affect a number of important views from the City of Westminster. These include the London View Management Framework views from St James Park (view 26A.1), Waterloo Bridge (view 15A.2), Westminster Bridge (view 18.B1), Victoria Embankment between Waterloo and Westminster Bridge (view 20B.1) and together with a number of metropolitan and local views. • The proposed development by reason of its height and bulk will harm the setting of a number of listed buildings including the Palace of Westminster, Royal Festival Hall, National Theatre, County Hall Horse Guards and the Foreign Commonwealth Office are particularly serious

and unacceptable. • The proposed development by reason of its height and bulk will harm the setting of a number of Westminster conservation areas, including those of Westminster Abbey and Parliament Square, Whitehall, Savoy and Strand.

5.89 London Borough of Southwark: Comments received wishing not to make an observation.

5.90 London Borough of Camden: Comments received wishing not to make an observation.

5.91 Environment Agency: Comments received raising no objection to the proposal subject to conditions.

5.92 Network Rail:

A letter has been received stating that they are unable to support this application in its current form for the following reasons listed below:

• The development is contrary to accepted policy, there are no proposals within the scheme to help improve the station, which is already the busiest rail station in the UK. • The application fails to properly identify and mitigate against the impacts of the proposals on the future safe and efficient operation of the station. • In addition Network Rail understands there are many different financial demands on developers who bring forward large scale mixed use schemes on prime sites in Central London. • Notwithstanding this point, it is extremely disappointing that the applicant has not seen fit to support a key local and strategic objective to improve a strategically important railway station that will help the local area and strategic objectives to improve a strategically important railway station that will also help the local area. • The transport assessment which supports the application concludes that the proposal does not result in any significant impacts which would warrant the need for any mitigation works. The assessment relies upon the 2008 dataset used for the WDA study for demand figures for Waterloo and Waterloo East Stations. Whilst is not contested that these figures provide an accurate representation in 2008, it is questioned as to whether these figures provide and accurate representation of the current situation and therefore whether they can be used effectively to understand the impact of the application. • The figures are five years old and we believe significant changes have taken place in time since, which significantly increase passenger figures. Therefore, we are due to carry out a study later this year to assess the situation at the station so we have a better idea as to how the station is currently performing, and better understand what improvements works will be required in future. • Network Rail fully accepts Lambeth Council’s policy that an acceptable level of affordable housing is required from such a large mixed use scheme in an expensive World Class City. It is also with merit that

Lambeth and the GLA seek to include the regeneration of Hungerford Car Park within any scheme, which will compliment the popular Jubilee Gardens. • Furthermore, we understand that Transport for London, is willing to accept a new £7m York Road London Underground ticket hall, which the applicant wants to provide as it allows them to develop another tower above to drive out more financial gain. • All the above are worthy contributions but they will not help deliver any station or interchange capacity improvements. They will not reduce congestion with the existing Waterloo Station, underground or bus connections, and they will not provide any new station facilities for passengers or local users. Furthermore, no contributions are being made to improve access to and from the station and to aid station permeability. • The Shell site benefits from excellent transport link, which is one of the main features promoting its development. It central location will help significantly with the sale of the residential units and the delivery of the mixed use scheme, however, it is necessary to ensure that the station is able to meet the needs of both the current and future users of the station and supports schemes such as this. • It is worth noting that the developers behind Elizabeth House proposal engaged with Network Rail throughout the planning application process and fully understood the need to improve the environment around the station and access/egress for the benefit of all concerned. • It was agreed as part of this scheme that a Section 106 contribution of £5.5m to station improvements would be made. In addition they are providing a new Victory Arch Square which will improve public accessibility to the station. • The applicant has been speaking with Network Rail regularly, but with specific focus on commercial uses rather than looking at the potential impacts of the development on the station and the possible need of any station improvements. • If Lambeth allow this development to proceed without any financial contribution to help improve Waterloo Station than a once in a lifetime opportunity will be missed. The redevelopment of Kings Cross and St Pancreas has shown what regeneration can created in the local area by providing a modern fit for purpose railway station. We hope that a similar success can be delivered at Waterloo. • We hope that Lambeth Council will support our joint aspirations by requiring the applicant to make a substantial Section 106 contribution or by ensuring that the Community Infrastructure monies levied on the scheme are ring fenced for the future redevelopment works at Waterloo Station.

5.93 Victorian Society: No representations received.

5.94 The Georgian Group: No representations received.

5.95 Development Control Department Thames Water: Comments received raising no objection subject to conditions.

5.96 The Westminster Society: No representations received.

5.97 County Hall Residents Association:

Comments received raising objection to the application for the following reasons:

Several complaints have been received by CHORA in respect of the deadline imposed to residents and owners to review the Shell redevelopment plans. As previously brought to the attention of planning officer, many residents and owners were frustrated with the timing of the application being submitted immediately before a religious holiday when many residents were away, no doubt deliberately timed to reduce the time available to residents to review the necessary documents.

The consultation process appears to have been more of a “communication” than “consultation” as the concerns raised by residents and owners that were repeatedly brought to the attention of the developers have been ignored.

Concerns are raised towards the public safety surrounding the South Bank area, specifically safety on York Road, Chicheley Street and Belvedere Road. Due to the presence of Shell in the area it is essential that discrete and proportionate counter-terrorism measures are an essential approach to the design of buildings and the spaces between them.

The residents and owners of County Hall request that an assessment of human health risk is undertaken for the construction activities associated with the proposed redevelopment specifically for County Hall and that the results are discussed with CHORA. The assessment will need to take into consideration exposure of nearby residents to fine particular matter and emission associated with construction activities.

5.98 Coin Street Community Builders: No representation received.

5.99 Ambulance Services: No representations received.

5.100 National Air Traffic Safeguarding:

Comments received raising observations in relation to the proposed development which are listed below:

The only issue that I would like to expand upon is that associated with the potential need for cranes used during the construction phase to be equipped with aviation warning light and the aviation notification of such cranes.

Lighting .

As already advised:

• In the UK, the need for aviation obstruction lighting on ‘tall’ structures

depends in the first instance upon any particular structure’s location in relationship to an aerodrome. If the structure constitutes an ‘aerodrome obstruction’ it is the aerodrome operator that with review the lighting requirement. For civil aerodromes, they will, in general terms, follow the requirements of CAP 168 – Licensing of Aerodromes. This document can be downloaded from the Civil Aviation CAA website at www.caa .co.uk/docs/33/CAP168.PDF – Chapter 4 (12.8) refers to obstacle lighting. • Away from aerodromes Article 219 of the UK Air Navigation Order applies. This Article requires that for en-route obstructions (ie away from aerodromes) lighting only becomes legally mandated for structures of a height of 150m or more. However, structures of lesser high might need aviation obstruction lighting if, by virtue of their location and nature, they are considered a significant navigational hazard. Routinely, structures less than 150m high and away from the immediate vicinity of an aerodrome are not routinely lit for civil aviation purposes. • Cranes, whether in situ temporarily or long term are captured by the points heighted above. Note that if a crane is located on top of another structure, it is the overall height (structure + crane) than is relevant. If any crane extends to a height of 150m or more there is a mandated requirement for such cranes to be equipped with light; the default specification is that detailed in Article 219. Whilst not a mandatory requirement, I would recommend that any crane of a height of 91.4m (300ft) is equipped with aviation warning lighting.

5.101 Southern Gas Networks Southern Gas: Comments received raising no objection to the proposal subject to save digging measures being undertaken by the developer.

5.102 Sewers Major Development – Thames Water:

Comments have been received raising concerns that the existing sewage and water supply system has the inability to deal with the extent of the proposed development. However conditions should be attached to mitigate against this.

5.103 London Duck Tours:

Comments received raising objection to the proposed development:

• Coach parking and related management is a serious and controversial issue within the Southbank. SBEG of which LDT is a full member, has discussed options at length these last 3 years. There is no recourse for those who have problems with inconsiderate coach parking and after 5pm the London Eye stops policing their allocated bays which compounds the issues.

• The proposed amount of car parking spaces designed within the scheme for the new for residents is excessive. The Public transport accessibility level rating of the Southbank is at 6b, which is the highest possible. Given that fact. The Proposals are unreasonable for the area.

It will encourage and permit additional unnecessary congestion and pollution by choice. There are quality public alternatives available. Some of the proposed underground spaces could be assigned to coach parking, thus addressing a serious need in Lambeth.

• The proposed use of high-quality materials are supported, however concern is raised towards the maintenance and upkeep of the public realm

• Any arguments or assumptions proposed in a) that the coaches would not be suitable due to heights of vehicles are flawed. The Proposal’s own assessments already make it clear that waste removal lorries will utilise the area. These are much less manoeuvrable vehicles and of similar height.

• These flawed traffic flow calculations need to be recalculated and the results reconsidered and adjustments made to the scheme before any future progress can be made.

• The Proposals state a wish to use high quality building materials on Belvedere road and Chicheley Street. This is to be lauded. Nevertheless, it lacks one fundamental ingredient; Chicheley Street and Belvedere Road are owned by Lambeth. Under the present legal process in the longer term the Council is responsible for maintaining the quality of the surfaces. Given the massive pressures on Lambeth already and from our practical experience, reinforced by the SBEG documentary evidence, we foresee a position where the Council will be unable to meet the on-going maintenance costs. Whilst LDT would like to re-iterate it is in full support of the principal of high quality materials for the area, all on-going maintenance should as a condition of planning approval remain the responsibility of the developers.

• A shared space as designed can and will create problems for Lambeth parking enforcement. The permanent removal of this curb can pose consequences for Lambeth parking enforcement if not handled correctly.

• Rogue parking is a serious issue within the area of this proposed development. If maintenance levels drop or the materials used exacerbate the wear of markings, the enforcement officer may not be able to issue notices. To date road safety with Chicheley Street has been materially jeopardised and LDT has the documentary evidence to prove it! Rogue parking is already a major issue; anything that hinders enforcement is not welcome.

• The Proposals make very little reference to service connections to the Proposals, given the large amount of road works which this area has already suffered. Planning cannot be considered constructively without the evidence.

• The Proposals state moving the RV1 bus stands from Chicheley Street on the northern side, but keeping them on the southern side. This ludicrous suggestion unduly restricts traffic, when the Proposals are

trying to in fact relieve it. Furthermore the southern lane of Chicheley Street serves as a delivery lane for vehicle intensive buildings e.g. the National Theatre. If the proposals are trying to reduce pressures on Chicheley Street, a piecemeal solution is not the strategy; either fully remove buses from Chicheley Street or do not do it at all. LDT, calling upon its bitter experience to date, suggested consolidating the southern RV1 bus stand with Bus Stop F “County Hall” on York Road. It saves the Council the cost of maintaining a bus stop and frees Chicheley Street completely of buses, increasing flow. Regretfully, this suggestion was either made too late to be included within the submission, or ignored, but the developer acknowledged this to be a great idea when LDT suggested it.

• LDT is concerned by the double turning right areas for the service entrance for the following reasons: § It increases the number of places for traffic can be held up. § In the case of a barrier failure, there is a reduced length of road that needs to fill up with cars before impacting York road (see point 6b). This is amply demonstrated by the shortcomings at County Hall § It does not seem necessary, especially taken in the context of rationalising Chicheley Street.

• LDT’s solution has been proposed but ignored by the developers and not referred to in this submission. LDT feels that the lower turn right should be removed and all vehicles undertake the screening vehicle route to the service entrance, providing more time for traffic issues caused by barrier failures to be fixed without impacting York road. Also there is an assumption in this design that residents parking would not be a security risk. This is not necessarily true.

• The current proposals have a significant impact on LDT’s operations. In the current form it is proposed that all of LDT’s bus stands are removed. A replacement option has not been proposed. LDT legally cannot trade without such bus stands and we look forward to in depth discussions with Lambeth and the developers on providing 40+ meters of bus stands within their modified proposals.

• That buildings 5, 6 and 7 having only residential and A3/A4 is closing off potential positive options for the area. A3/A4 is strongly represented in the area with County Hall, the Southbank Centre, the Royal Festival Hall, and Coin Street/Oxo tower. All offer A3/A4. An extra bar or restaurant is, in our opinion unnecessary. The proposition being proposed of creating high-end restaurants is unlikely to be sustainable given the composition of those using the Southbank.

• The LDT view outlined under No 1 above is reinforced by the existing evidence of Slug and Lettuce and All Bar One. Having bars below residential buildings of that proposed creates undue tension. The Slug and Lettuce have an outside area which they currently rent, but are prevented from using due to noise restriction orders arising from

pressure created by local residents. Even though The Proposals have restricted balconies to higher floors, noise always travels. Residents will be unable to have full enjoyment.

• Drunken behaviour also causes problems, even though no spill out is proposed for buildings 5, 6 and 7. If a pub/bar is the lessee, patrons will end up outside its doors, next to residential entrances. This will, by definition, cause unnecessary problems for residents wishing to access their building. Crime is also unnaturally high in this area despite the efforts of the local community, The Southbank Employers Group (SPEG) and the Police; allowing more nightlife is likely to exacerbate the very crimes the Southbank is historically famous for e.g. pick-pocketing.

• LDT is keen to employ locally housed personnel. This cannot be achieved without a significant increase in the ratio of affordable housing. LDT costs increase significantly by employing labour from outside the borough. LDT is worried about the numbers of social/affordable housing being provided by the development. 96 units out of a total of 778 appears a low ratio for this development. It implies a 12% bare minimum at the expense of the local low paid community. LDT’s own experience of a local work force demonstrates it can and does produce numerous benefits for smaller and medium enterprise companies: lower staff turnover, lower training costs and a better attention to the local needs/quality of service. For any proposal, which states that it wants to create a community atmosphere and a full working relationship with the area local people must be able to live there. The affordable housing ratio needs to be materially increased. 5.104 The Theatre Trust:

A letter has been receive raising objection to the proposal which are listed below:

• No comments are made on the proposed scheme. • However, regret the complete loss of the Cecil Beaton-designed theatre as an important cultural resource. • The Trust believes that the theatre should be incorporated within the development. • We would suggest that a Needs and Impact Assessment be required by the local authority form the developer in order to establish whether a performance facility is surplus to cultural and community requirements within the catchment area. There is no reason to believe that it could not be adapted into a small venue for community benefit. • Should consent be granted for the application, we suggest that recording and salvaging conditions be attached to the permission prior to the commencement of the works.

Neighbours

The following section presents the responses received from neighbouring occupiers of the site.

5.105 A total of 67 objections, 10 letters of support and a further four letters of comment neither objecting nor supporting the applic ation were received. Enclosed with the consultation letter was a consultation document providing further detail on the proposals. Drop-in sessions were advertised for members of the public to speak with Council officers on the proposals. In addition, separate evening meetings were arranged with and for the residents at County Hall and Whitehouse Apartments respectively. The following table presents the objections received in respect of the application, with a response given to each in turn (and for which the Planning assessment later in the report provides a fuller consideration of the scheme as a whole). Some grounds of objection received are not planning reasons for refusal, such as the impact on house prices.

No. of Letters sent No. of Objections No. in support Comments A total of 6693 67 10 4 consultation letters were sent out for the four applications to local residents.

Objections: Council’s Response:

• The height of the proposed buildings and This site is designated as an the density is excessive for the site and Opportunity Area by the GLA will result in an overwhelming eyesore on where tall buildings are permitted the South Bank adjacent to the London to facilitate growth in the area. In Eye, a highly desirable location to attract this instance the proposal for a tourists to London. range of tall buildings would be • Views across from north of the river acceptable. Whilst it is accepted would be massively restricted by the that the development would slightly development, with the jumble of large exceed the density range of 650- structures. 1,100hrha (proposed development • The developer’s proposal is far too dense being approximately 1,419hrha), at the Hungerford viaduct end; buildings given that the site is centrally 3, 4a and 4b in combination with located and has high public Elizabeth House would create a massive transport accessibility (PTAL) of 6B block of uninspired architecture. and is within the CAZ, Waterloo • The architecture being proposed is Opportunity area and the reminiscent of the high rise council contribution that the scheme is blocks of the 1960’s. making to place shaping in Waterloo, the proposed density is appropriate, reinforced by a high quality design approach born out of a masterplan for the site, endorsing a complementary palette of materials for the wider area and

brought forward by a number of renowned architects and giving.

• Taking into account the recently granted The proposed development would Elizabeth House, this will cause gross be providing a centrally located over-development in this area, leaving no square which would be accessible spaces in the area other than Jubilee to the general public, office Gardens. workers and residents. The • There is a loss of public realm space on redevelopment proposal proposes the site which is unacceptable. The site over 1ha of public realm space lies in an area where there is deficiency within the boundary of the site, in the amount of public space. which is an increase of approximately 0.3ha over the existing open area on the site. It should be noted that the existing Shell Centre layout only provides a route through the site, with very little, if any visual amenity. The proposed increase responds to the Waterloo Area SPD, which states that additional open space and amenity space is needed generally across the Waterloo Area. In this instance the scheme would comply. Its impact would also be addressed by the provision of S106 monies towards open space.

• The footprint of building 6 on the corner This area is currently occupied by of Chicheley Street and Belvedere Road a raised podium and as such is shown to encroach further into there is no existing ‘building line’. Chicheley Street end. The building lines between buildings 1 and 7 have been proposed to provide a visual interest along this particular section of Chicheley Street, and fall within the cartilage of the site.

• The Royal Festival Hall – The impact of Officers consider the proposed the proposed development on the setting development sits comfortably with of this Grade I listed building was seen the mid 20th century aspirations for as highly detrimental. Views showing the the redevelopment of this area. current situation were tabled, and it was The replacement of the clear that the extra built mass would be monotonous wings of the Shell extremely harmful and objectionable. Building with more distinctive • South Bank (including the National buildings, of a high quality of Theatre) - The theatre together with architecture would not harm the Waterloo Bridge are Grade II* listed significance of the RFH, but rather structures. The setting of these important would place it within a lively and Twentieth Century icons would be evolving townscape symbolic of adversely affected and inhibit the views present aspirations for the

from the Thames and along the river also regeneration of the wider Waterloo the views of the World Heritage site at area. Officers consider within Westminster these views the development would have minimal impact because of the orientation, distances and contrasting form of the listed buildings in relation to the proposal. Furthermore, there would be minimal impact to the World Heritage Site at Parliament Square.

• The height of the two buildings facing The applicant has submitted a Jubilee Gardens are far too high at this Townscape and Visual Impact location as these will be able to be seen Assessment (TVIA) as part of the from Parliament, which would potentially development. Building 1 would impact on views. only appear very slightly within the LVMF views 27A.1 and 27A.2, however, the potential effects of the intrusions within these views would not have a cumulative impact. Officers acknowledge that the development would still be viewed in close proximity to the Big Ben Tower, but this would only be present when you move away from the fixed point of view that requires consideration under the LVMF. Buildings 5, 6 and 7 which face onto Jubilee won’t be sent from Parliament Square.

• The proposed development by reason of These two link assessment point its height and bulk will harm the setting views 27A.1 and 27A.2 are located and outstanding universal value (OUV) of on the pedestrian island in the the Palace of Westminster and south-west corner of the square Westminster Abbey including St between the UK Supreme Court Margret’s World Heritage Site. and Westminster Abbey. From this location the northern parts of the Palace of Westminster are seen clearly in context with St Margret’s Church and Westminster Abbey. Within these two views the proposal would comply with the visual guidance in that the development would be set away from the Houses of Parliament next to Portcullis House. This would allow sufficient sky to be maintained around the Clock Tower to preserve the OUV of the

World Heritage Site. It should be noted that a very small part of the proposed roof to building 1 would appear within this view towards the right hand side of Portcullis House. However, the overall impact would be neutral. Officers raised no objection to this.

• The proposed development by reason of The development would appear in its height and bulk will adversely affect a many views designated as part of number of important views from the City the LVMF. Overall, it is considered of Westminster. These include the that the development would have London View Management Framework the most impact within the view views from St James Park (view 26A.1), from St James’s Park. However, Waterloo Bridge (view 15A.2), The proposed towers of buildings Westminster Bridge (view 18.B1), 4A and 4B would be seen to the Victoria Embankment between Waterloo left of the Foreign Commonwealth and Westminster Bridge (view 20B.1) Office (FCO) tower, however and together with a number of framed by the London Eye and metropolitan and local views. with The Shard to the right. The proposed buildings appear as part of the existing group of buildings to the right of Duck Island, and as noted by the applicant, do not dominate or compete with existing buildings. The stone tracery and distance between the buildings helps to differentiate them having a minor adverse impact. However, given the number of buildings which have come forward within this view and are in the pipeline, the sympathetic presence of this building would be supported by officers. It is noted that this position is supported by the GLA also.

• The proposed development by reason of Officers have assessed the its height and bulk will harm the setting of proposed impact of the a number of listed buildings including the development within the built Palace of Westminster, Royal Festival environment and it considered on Hall, National Theatre, County Hall Horse balance the development would Guards and the Foreign Commonwealth not be detrimental to the adjoining Office are particularly serious and building within the Conservation unacceptable. Area and the surrounding areas.

• The proposed development by reason of The development has been its height and bulk will harm the setting of assessed within these views and a number of Westminster conservation officers considered that the

areas, including those of Westminster scheme would have a neutral Abbey and Parliament Square, Whitehall, presence in these views. In this Savoy and Strand. instance no objection is raised.

• These buildings would detrimentally The applicant has submitted impact on residents of the County Hall daylight and sunlight assessment residents block causing light to be which has assessed the adjoining blocked out. County Hall residents block. Officers acknowledge that there would be an impact in relation to the adjoining building, however, consideration should be given towards the overarching regenerative benefits of the scheme to the Waterloo area and the London city.

• There is no justification for the demolition Notwithstanding the policy context of buildings within a conservation area. for the site which gives support to the principle of development and in turn therefore demolition to parts of the site, Conservation Area designations do not give immunity to the demolition of buildings, but the loss of historical fabric has to weighed in terms of the significance of the loss. The tests for the application are whether the public benefits outweigh the harm that would result in the loss of the perimeter blocks and associated structure s. As presented below under the planning considerations section, the proposed public benefit that would be delivered by the development far outweigh the impact.

• Why can’t the remaining buildings which Officers acknowledge the change are to be demolished on the site be in use of similar downstream river retained and modernised like the Shell buildings into residential use, Tower? however the site is identified for • The loss of the low-level wings destroys mixed use development as well the architectural integrity and continuity seeing the maximisation of of the original Shell Centre complex site. development to make best use of • Similar downstream buildings such as such inner-urban sites. The Shell Whitehouse Apartments have been Centre complex was bespoke to converted into high class apartments, its occupier, and Shell are why can this not be achieved on the committed to remain at the site existing site? within new accommodation whilst

• The Shell Centre is locally listed. The retaining the most recognisable of demolition of the wings appears to be the sites existing architecture. implausible given that the main tower will The demolition will be carefully be preserved as part of the development. controlled by condition and work to make good those parts of the tower will be carried out through re-use of some of the demolition material.

• Given consent under Elizabeth House Conditions would be imposed scheme to remove pedestrian bridge, controlling traffic impact from the there will be traffic congestion and demolition of the buildings if both pedestrian problems, in particular developments came forward at pedestrians crossing York Road stopping the same time. Furthermore, the traffic. demolition of the high-level bridge would be phased, once adequate mechanisms have been provided, to mitigate against the loss. New and improved pedestrian crossings would be installed at the north-eastern end of the site (by Sutton Walk) as well as a wider crossing close to the Chicheley Street/York Road junction. These measures have been assessed alongside projected pedestrian and vehicle movement in the area to ensure the developments are suitability mitigated and no undue impact to the movement of traffic (including pedestrian) is affected.

• The consultation undertaken by the The applicant has undertaken developer has been flawed. They have extensive consultation with the requested feedback from local residents local community which has been but taken into account none of their presented through Soundings. comments and made no adjustments to Officers have attended various their intensive development of this site. meetings with the local community where the applicant has been present and on the whole recognise that an acceptable level of consultation has been carried out. It is acknowledged that not everyone will consider their comments or objections have been addressed by the applicants in their pre-application consultation with residents, but that others will see that some have. The sites location and underlying policy designations

establishes in principle support for high density development which it is recognised will not be welcome by all but that nevertheless directly responds to the aspirations for the site in its role for this World City.

• Inconsistency between the buildings in The proposed development would terms of the designs creates a “hotch result in a range of building styles potch” effect and is totally out of scale but all of which respond to with the key adjacent buildings such as common principles to achieve Royal Festival Hall. harmony with the local typology. In this way the buildings pick up on the predominate palette of materials in the immediate area and seek to complement rather than compete with the Iconic architecture found along the South Bank. Indeed, the scale of development steps up away from the River, ensuring the existing Shell Centre Tower predominates in views from the River and that the scale of development creeps up towards the higher rise development approved at Elizabeth House.

• Building 5 will cause a major loss of light Officers have acknowledged the for residents in adjacent buildings and findings within the report and substantially diminish the usefulness of accept that there would be an the amenity areas such as the roof impact to the existing residential gardens at 9 Belvedere Road. units adjoining the site but given the area is designated as an opportunity area designated by the GLA and that dense urban development is envisaged on the site, the proposed loss of daylight to these properties in the rounds would be acceptable. Furthermore, given the regenerative benefits which the scheme delivers not to only the Waterloo area but the wider London city, refusing the scheme on this basis would not warranted.

• York Road will become a canyon, taking Whilst it is acknowledged that the into the account the already approved extent of development along York Elizabeth House scheme. Road could be perceived as a

canyon-like character, the layout of the buildings along with the number of links between them would break up this appearance, which would facilitate routes and permeability that connect the sites to the wider area. Furthermore it should be noted that the designation of the site as being a opportunity area allows growth to be achieved through the erection of tall buildings. The pedestrian experience will be equivalent to the City and there will be no unacceptable micro-climate conditions to discourage the form of development proposed.

• Buildings 6 and 7 should be reduced in The proposed heights of buildings height to the same height as the river 6 and 7 would be erected between facing apartments as possible. 11-21 stories in height. The proposed buildings would step down from the Shell Tower towards the height of the North Block County Hall. Given that the scheme has taken in consideration the relationship between the existing and proposed buildings on the site, officers raise no objection to this form of development in this location.

• The extra pedestrian traffic resulting from Whilst it is acknowledged that the closure of the podium route will make it scheme would build over the much busier and increase the danger for existing podium area as part of pedestrians. In this instance there the development, the proposed should be considerable widening of the development would be providing footpath along Chicheley Street. many routes through the site, which would funnel pedestrians through from York Road towards the South Bank, in this instance no objection is raised. Furthermore, the widening of Chicheley Street would aid pedestrian flow and safety from York Road towards the South Bank.

• The proposed application would affect Officers have acknowledged the the natural sunlight/ daylight of findings within the report and apartments (County Hall North Block) accept that there would be an impact to the existing residential units adjoining the site but given the area is designated as an opportunity area designated by the GLA and that dense urban development is envisaged on the site, the proposed loss of daylight to these properties in the rounds would be acceptable. Furthermore, given the regenerative benefits which the scheme delivers not to only the Waterloo area but the wider London city, refusing the scheme on this basis would not be warranted.

• The design aesthetically would be The suitability of the density of unacceptable given that the closely development is discussed below packed tall buildings is out of keeping (see section 7.12). Whilst the with the rest of the area. design of buildings has involved a • The proposed development would range of architects, the ground impede permeability and accessibility. plane is designed by the same • The proposed new access ways through specialist landscape architects the site do not meet the needs of with renowned experience across pedestrians of the local area. London and elsewhere in similar • The proposed public realm works are urban settings. The proposal has cluttered and by virtue of the different been designed alongside existing architects and design do not provide a and emerging pedestrian and realm that is co-ordinated either within other movement in the immediate the proposals or with the local area, with clear routes and spaces conservation area and locally-listed to be created, which is currently buildings. not being utilised by the existing site. This would significantly improve the public realm of the area and quality of open space within the site. Furthermore, the proposed routes would improve permeability and pedestrian linkages which would in effect improve and enhance access from Waterloo Station to the river. The current site creates a barrier from Waterloo Station, York Road and the river. The proposed approach would improve the current situation.

• The South Bank is a global world class The existing site is currently in centre of excellence which should be office use. No arts or culture uses enhanced and maintained. This are present on the site. The development fails to do this. proposed introduction of a mixed use development would provide a range of uses, creating a vibrant and diverse environment which would enhance the setting of the South Bank.

• The South Bank has a unique With the exception of Building 2, architectural style that has not been whose glazed treatment would reflected in the designs proposed, in emphasises its non-domestic conflict with the principles of the function, the proposed buildings conservation area. on the site would be constructed with an element of Portland stone which would maintain the character and appearance of the buildings on the South Bank. Given the nature of high rise development proposed for the site, the predominance of materials found in the immediate area to be used at the site is welcomed by officers.

• There is no supermarket of significant The proposed development would size, putting pressure on the existing be providing a total of 3,728sqm facilities in the area. of retail space. The submitted ‘Retail Report’ states that these units would provide amenities to meet the everyday needs of the local community, office and visitor population. These uses would be broken up into individual retail units within the development. However, the proposed units would be provided on the basis of safeguarding and promoting the role of Lower Marsh/ The Cut as a CAZ frontage, where specialist types of retailing i.e. supermarkets would be located. Notwithstanding, there is no exclusion from the scheme design to the delivery of a ‘local’ scale convenience store.

• The planned demolition would cause A condition has been imposed to significant noise and dust disruption to this effect which would control any the neighbouring properties, which have demolition works which would

already suffered over the past few impact on the ongoing operation months through existing construction of buildings along York Road. activity at other neighbouring sites. Furthermore, several conditions relating to construction management of the development has been imposed and this would control any traffic management along York Road. Notwithstanding, the planning regime is not permitted to duplicate the powers given to environmental health or building control who also have powers to govern these effects.

• The proposed development would Officers have acknowledged the overshadow the Whitehouse Apartments. findings within daylight and sunlight report (please refer to section 10.22) and accept that there would be an impact to the existing residential units at County Hall North Block, but given the area is an opportunity area designated by the GLA and that dense urban development is envisaged on the site, the proposed loss of daylight to these properties in the rounds would be acceptable. Furthermore, given the regenerative benefits which the scheme delivers not to only the Waterloo area but the wider London city, it not so substantive as to merit refusing the application.

• The proposed development would give This is discussed in the planning rise to wind issues within the local area. assessment section in more Would the possible wind mitigation detail. The Square is considered measures be sufficient? to provide new public open space suited to its inner urban location.

• The proposed Chicheley Street The submitted ES has assessed appearance will not be a reality given the all these raised objections to the service entrance placed there, application. This has been contributing to extra pollution, noise independently assessed by levels and congestion, plus the extra Bowyer Planning on behalf of the danger posed to pedestrian/ or by LPA and they have concluded that pedestrians. adequate mitigation measures have been taken into consideration within the development to minimise such

impact. Deliveries and servicing will be strictly monitored and improvements to the presentation of Chicheley Street will assist in the prioritisation of the pedestrian.

• The proposed South Bank is a vibrant Officers acknowledge that there community unable to cope with a small would be a significant uplift of town as seen at Canary Wharf where a development on the site in the new town was created. form of retail, housing and employment which would impact on the local infrastructure and services. However, officers have secured a range of mitigation measures which would be imposed via the Section 106 Agreement to directly address this impact. The scale of development is not comparable to, nor is it proposed to be, of a Canary Wharf scale.

• There has been no co-ordination The extent of co-ordination between Elizabeth House and the Shell between different landowners Centre development. cannot always be achieved and given that the schemes have come forward within different timeframes, this perceived task is not always achievable. Notwithstanding, the scale of development does correspond with that established for Elizabeth House, the scheme takes into consideration the timing of development of Elizabeth House (should the pedestrian bridge be present or not) and the public realm is embedded also. Similarly, consideration has been given to the mitigation package achieved at the Elizabeth House site and how the impacts of development for Shell are similarly required. It would be incorrect for it to be viewed that the development has been proposed independently of the Elizabeth House scheme, if indeed the Elizabeth House scheme was not proposed to respond directly to the Shell scheme that was

submitted after the formers resolution for approval.

• The potential construction of Elizabeth Several conditions relating to House, Doon Street and the Shell Centre construction management of the development would potentially bring the development has been imposed flow of traffic in the local area to a halt. and this would control any traffic management along York Road. A co-ordinated approach across the different developments is to be encouraged and secured through the establishment of a group for the immediate area. All emerging development in the area would be required to hold membership.

• The proposed affordable package would The proposed development would not be affordable to key workers. A provide a minimum of 20% further creation of a violently overpriced affordable housing. This would be ghetto for the wealthy who will not form a in the form of affordable rent residential community but set up another (extra care), intermediate units desert of little visited pied a tiers and offsite provision providing further affordable re nted units. • The proposed level of affordable housing Officers fully support the proposed is nothing short than a disgrace given the level and type of affordable density and number of units being housing being incorporated within proposed as part of the development. the development both onsite and offsite recognising the challenge • The lack of affordable housing does not of delivery on an inner urban site bode well in creating balanced and mixed in this particular location where communities. the financial viability of such delivery has been tested. • The ongoing discussion in relation to Secured by way of a S106 offsite affordable housing, will the agreement, the scheme is applicant ever deliver these affordable considered to deliver the homes in the area. maximum reasonable amount of affordable housing in accordance with the policy. Mixed and balanced communities are not only delivered through the provision of residential accommodation, and the provision of a range of mixes contributes towards achieving such aspirations also.

• There will be no contribution towards the The development would secure a local community. contribution of £1,000,000.00 towards community facilities. In addition, in the instance that the community unit on site is not

occupied, that the developer provides an equivalent financial contribution of £300,000.00 The above is considered reasonable and commensurate to the scale of development proposed. It is in addition to contributions towards health and education that addresses the increased demand derived from the scale of the development.

• A condition should be imposed restricting Hours of construction work, the hours of demolition. including demolition, are covered by Building Regulation.

• The development would give rise to Building 7 would be erected at a overlooking towards the North Block of distance of 25m from the North County Hall Apartments. Block, County Hall. Given the • The proposed terraces facing the North urban central location of the Block of County Hall will give rise to development and given the built up overlooking. environment of the area, the proposed distance is considered to be generous. Officers consider on this basis that the scheme would not give rise to direct overlooking and loss of privacy to this existing residential building.

• Sufficient measures/ conditions should The removal of asbestos is be imposed for the removal of the governed by separate regulation asbestos as local residents should be and is not controlled by the protected. Planning regime. Notwithstanding, a demolition and construction plan will be required to be submitted ahead of works commencing that would need to address such matters.

• The application does not locate exactly The proposed two duck tour where the two duck tour spaces will be spaces would be relocated from located. Chicheley Street onto Belvedere Road which is supported by officers.

• Discrete and proportionate counter This has been secured within the terrorism measures are an essential Section 106 Agreement. approach to the design of buildings and spaces between them.

• The proposed development would be a

security issue and a possible terrorist target; the surrounding amenity of the surrounding sites impaired.

• The presumption to locate the servicing Concerns have been raised during yard opposite a residential block is totally the pre-application stage in relation unacceptable and would severely impact to the proposed new delivery on the amenity of local residents. entrance into the site; historically the principle vehicular access point for staff to the basement car park. Officers have acknowledged these concerns but due to the restriction of York Road being a red route and other roads adjoining being utilised by the development, Chicheley Street would be the safest and most acceptable access point into the site. All servicing would be carried out in the basement, which would minimise impact to residential amenity. Furthermore a service management plan would be imposed to ensure that the access operates in an efficient manner. The TRIP rates in this respect have been tested, and no detriment is envisaged.

• Removing on-street parking bays would The applicant would be re- have an adverse traffic impact along providing the off-street parking Chicheley Street. elsewhere on Chicheley Street and Belvedere Road. In this instance no objection is raised.

• The daily congestion at the junction of The submitted TA has been Chicheley Street and Belvedere Road assessed by officers and it is would cause traffic to back-up to York considered that adequate Road. Furthermore, with the new information has been submitted to proposal, vehicles will fail to execute right alleviate concerns in relation to hand turn from Chicheley Street into the traffic impact along York Road at proposed new service yard. the junction of Chicheley Street. Furthermore, adequate provision and signage would be visible which would facilitate right hand turns into the site. A servicing management plan would be imposed which would restrict impact and congestion towards the junction of Belvedere Road and Chicheley Street.

• Strong restrictions through conditions Conditions are recommended should be imposed for open times of the imposing restrictions to the restaurants and bars. opening and closing times of the various retail, restaurants and night time activity uses within the development. This would protect the amenity of both surrounding and proposed residents in the area.

• There is no proposal for creative The development being proposed industries as part of the development. would be a truly mixed use development. However, whilst the extent of uses which the development could provide is restricted there is no in principle objection to the accommodation of the creative industry within the commercial element. Furthermore, the public art regime for the area will require engagement with the creative industry.

• The urban design of the public realm This is discussed in the planning would lack any sun and daylight, windy, assessment section in more detail. oppressive and cluttered. The proposed The Square is considered to central square would be hemmed in. provide new public open space suited to its inner urban location.

• The backdrop of the Eye would be lost by The proposed development has the proposed development. been assessed in regard to the built environment surrounding the • The proposed development would block site. It is considered on balance the whole view of Jubilee Gardens and given the public benefits of the the Thames. development, along with the high- quality design of the buildings, the scheme would provide a development which would integrate into the existing surrounding and would no result in having an impact to existing buildings in the vicinity nor a barrier. Whilst it is recognised that the view of the London Eye would be reduced from York Road, an appreciation of its form would be had down Chicheley Street whereby the proposed development and that at County Hall would frame the central axis upon which it turns.

• The open space provision for 798 units The development provides would be insufficient given that this area adequate amenity provision and would be used by the office this is explained further under the accommodation. design section. • Inadequate provision of children playspace within development.

• The proposed development should be The development is proposed as car free development. The development car free and promotes sustainable does not promote sustainable transport transport measures with modes. contribution towards Boris bikes, on-site cycle storage, improved permeability alongside the sites high public transport accessibility rating level. Whilst the proposed parking provision would be slightly higher than the parking ratio as set out in the London Plan. However, given the scale of the development, the level is considered to be acceptable.

• The proposed sports hall, swimming pool The existing uses currently on the should be retained through the deletion site has been utilised of the proposed car parking in the predominately by officers workers basement. of Shell Petroleum. The applicant would be required to contribute money towards the provision of a leisure facility to other schemes in the immediate area, in particular a swimming pool proposed within the Doon Street development.

• The proposed development reduces the In total 69,065sqm GIA of amount of office accommodation on the commercial (B1) floorspace is site. proposed above ground, a net increase on site by 24,372sqm. Additionally, a further circa 35,000sqm GIA of commercial (B1) floorspace is provided in the existing Shell Tower and will be retained as part of the redevelopment proposals. In this instance there would be no shortfall.

• The additional population created by the The development site would bring development requires further community many benefits to the local spaces to be created through libraries, community such as jobs, housing, childcare facilities, fitness facilities. The public realm improvements around current development destroys this. Waterloo Station and considerable

uplift and employment floorspace. The proposed development would also provide Section 106 contributions to the local area to address the additional residential and working population. All these benefits are considered to be a positive to the local community.

• The new residential units achieve the Officers have acknowledged the minimum recommended daylight levels; findings within the daylight and just over half of the residential units sunlight report and accept that receive acceptable sunlight. The there would be an impact to the development would also create a sense existing residential units adjoining of enclosure by the buildings on the site. the site but given the area is designated as an opportunity area by the GLA and that dense urban development is envisaged on the site, the proposed loss of daylight to these properties in the rounds wo uld be acceptable. Furthermore, given the regenerative benefits which the scheme delivers not to only the Waterloo area but the wider London city, refusing the scheme on this basis would not warranted.

• The air quality surrounding the site would Air quality impacts from the be affected by the number of proposed development have been developments being proposed in the assessed in combination with local area. known development in the pipeline and it is considered that the scheme would not cause harm to existing and proposed residents within the area.

• The proposed development would give This has been independently rise to solar glare to trains, which is assessed as part of the positively dangerous. Environmental Statement. Whilst it is acknowledged that there would be an impact from buildings on the western elevation a condition has been imposed requesting that the glazing is fitted with reflected glass, minimising the impact and of which such would not have a detrimental effect.

• The development fails to provide The development would provide adequate children space within the play space for under 5 years development. onsite. The remaining age group categories would be provided through existing facilities such as Jubilee Gardens which lies directly to the west of the site, and Archbishop’s Park which lies within 400 metres of the site. This is supported by officers.

• The public benefits are less then the All schemes are to be considered permitted Elizabeth House scheme. on their own merits, rather than compared with others. The development site would bring many benefits to the local community such as jobs, a far greater number of residential units (and in turn higher number of affordable housing units), public realm improvements improving routes between Waterloo Station and the South Bank and a considerable uplift in employment floorspace. The proposed development would also provide Section 106 contributions to the local area commensurate with the scale of development.

• The development does not address the The development provides delivery of Hungerford Car Park as an adequate amenity provision extension to Jubilee Gardens. This might commensurate with the scale of be secured through the Section 106 the proposal as discussed below Agreement. under the design section. Nonetheless, the delivery of Hungerford Car Park has been discussed with the applicant and officers continue to work with them and the landowner to see the objectives for the site as an extension to Jubilee Gardens brought forward in the future.

• The area east of the viaduct urgently Objectives for the Waterloo area needs work to ensure that is are set out within the Waterloo complements the exciting developments SPD. This part of Waterloo is of Elizabeth House and the Shell Centre. sought for improved public realm St John’s Churchyard should be more provision. The Shell Centre site integrated into the public space provision. however is not found to result in harm to St Johns Church and

movement between the station, the South Bank and Lower Marsh are envisaged to be likely for which related mitigation contributions are sought by way of S106.

• The targets set for river services are It should be noted that occupiers of disappointing given the London Plan’s the Shell Centre site would be target of a 50% increase in passengers encouraged to travel to the site and freight transported on the Blue using sustainable modes Ribbon Network from 2011-2021. It is of supported by robust Residential note that since the application was and Workplace Travel Plans. submitted the Mayor has published a These Travel Plans would serve to River Action Plan which sets a target to promote the use of river services increase passenger journeys on the and set a number of measures and Thames to 12 million a year by 2020 and targets against which the use of to maximise its potential for river travel. river services by Shell Centre The plan refers to working with users can be monitored. developers to identify opportunities to enhance existing piers; and working with developers to maximise the integration of existing piers with the development and local transport network. Against this background the target of 60 in and 55 out by “other modes” (which includes river transport) seems very low out of a total of 23, 002 in and 21, 651 proposed trips.

• Consideration should be given to the use The applicants are committed to of the river for the transport of minimising the impact of the construction materials to and waste demolition and construction works materials from the development site. A upon local residents and condition should be placed on any grant businesses. The potential to use of planning permission requiring the the river for the transport of applicant to investigate maximising the construction and waste materials use of the river in this way. will be considered upon appointment of the contractor but will be dependent upon the impact of local businesses, residents and the existing public realm along the South Bank. The Shell Centre site does not have direct river-front access and therefore any river- borne construction deliveries of materials or removal of waste requires unloading and access arrangements by HGV which would need to be compatible with the high pedestrian footfall in the area.

• As the fountain is currently sited in a Officers have advised that the broad courtyard with low buildings relocation of the fountain should be immediately surrounding, it therefore found in a place where it would be appears taller than the structures able to be re-commissioned as a adjoining. However, its new location water feature and thus enjoyed in would find it trapped between Building 5 the original manner imagined by and Building 4b with the railway the artist when the piece was embankment adjacent. The Committee created. The listed building thought this less than satisfactory and application proposes the piece to were of the opinion that a totally different be placed in the public space location would be more appropriate – between buildings 4a and 5. This perhaps linked to the South Bank/Royal location is off-set to the north side Festival Hall. Taking into consideration of the main square but adjoining the foregoing the present proposal was the new pedestrian route which deemed undesirable and objectionable. skirts the railway viaduct. In this respect the piece would be highly visible and thus would contribute to the quality of the public realm. In this instance no objection is raised.

5.106 The comments of support received are summarised as follows:

- Proposals look excellent, redevelopment overdue. - This will see an exciting future for Waterloo bringing a vibrancy to the area. - Development would have a significant positive benefit on local business and the residential community. More jobs, new homes and new business in the area shall be a fantastic opportunity. - Tall buildings proposed are ok compared to other skyscrapers proposed on other stretches of the South Bank, and if anything would make the area fir in better with the surrounding area. - Commitment to affordable housing, long term commitment to public realm improvements and gathering of local suppliers and businesses in their supply chain marks a shift in attitude towards SMEs.

6 Planning Policy

The following section of the report sets out all pertinent National, regional and local policy that relates to the application site which are considered further under the ‘Planning Assessment’ section of the report below.

National Guidance

6.1 On 27th March 2012, the Government published the National Planning Policy Framework (NPPF). This document had the immediate effect of replacing various documents including, amongst other documents, PPS1, PPS3, PPS4, PPS5, PPS12, PPG13, PPG17 and Circular 05/2005: Planning Obligations.

6.2 The NPPF sets out the Government’s planning policies for England and how these are expected to be applied. It reinforces the Development Plan led system and does not change the statutory status of the development plan as the starting point for decision making. The NPPF states that the National Planning Policy Framework must be taken into account in the preparation of local and neighbourhood plans, and is a material consideration in planning decisions. Moreover, it sets out that in assessing and determining development proposals, local planning authorities should apply the presumption in favour of sustainable development.

6.3 The applicant’s planning consultants have submitted a statement confirming how this application meets the aspirations of the NPPF.

The London Plan 2011

6.4 The London Plan was published in July 2011 and replaces the previous versions which were adopted in February 2004 and updated in February 2008. The London Plan is the Mayor’s development strategy for Greater London and provides strategic planning guidance for development and use of land and buildings within the London region.

6.5 The London Plan is the overall strategic plan for London, and it sets out a fully integrated economic, environmental, transport and social framework for the development of the capital over the next 20-25 years. It forms part of the development plan for Greater London. All Borough plan policies are required to be in general conformity with the London Plan policies

6.6 The following policies of the London Plan (2011) are relevant:

Policy 1.1 Delivering the strategic vision and objectives for London 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 3.1 Ensuring equal life chances for all Policy 3.2 Improving health and addressing health inequalities Policy 3.8 Housing choice Policy 3.16 Protection and enhancement of social infrastructure Policy 4.1 Developing London’s economy Policy 4.2 Offices Policy 4.3 Mixed use development and offices 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 5.8 Innovative energy technologies 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 5.14 Water quality and wastewater infrastructure Policy 5.15 Water use and supplies Policy 5.16 Waste self-sufficiency Policy 5.21 Contaminated land Policy 6.1 Strategic approach Policy 6.2 Providing public transport capacity and safeguarding land for transport Policy 6.3 Assessing effects of development on transport capacity Policy 6.4 Enhancing London’s transport connectivity Policy 6.5 Funding Crossrail and other strategically important transport infrastructure Policy 6.7 Better streets and surface transport 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 Designing out crime 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 7.10 World Heritage Sites Policy 7.11 London View Management Framework Policy 7.12 Implementing the London View Management Framework Policy 7.14 Improving air quality Policy 7.15 Reducing noise and enhancing soundscapes Policy 7.18 Protecting local open space and addressing local deficiency Policy 7.19 Biodiversity and access to nature Policy 7.29 The River Thames Policy 8.2 Planning obligations Policy 8.3 Community Infrastructure Levy

6.7 Lambeth’s Local Development Framework Core Strategy. The Core Strategy was adopted by the council on 19 January 2011.

The following policies are considered to be of relevance to the assessment of this application:

Policy S1 – Delivering the Vision and Objectives Policy S2 – Housing Policy S3 – Economic Development

Policy S4 – Transport Policy S5 – Open Space Policy S6 – Flood Risk Policy S7 – Sustainable Design and Construction Policy S8 – Sustainable Waste Management Policy S9 – Quality of the Built Environment Policy S10 – Planning Obligations Policy PN1 – Waterloo

6.8 London Borough of Lambeth Unitary Development Plan (2007): ‘Policies saved beyond 5 August 2010 and not superseded by the LDF Core Strategy January 2011’

The following policies are considered to be of relevance to the assessment of this application:

Policy 7 Protection of Residential Amenity; Policy 9 Transport Impact; Policy 14 Parking and Traffic Restraint; Policy 19 Active Frontage Uses; Policy 21 Location and Loss of Offices Policy 23 Protection and Location of Other Employment Uses; Policy 26 Community Facilities; Policy 29 The Evening and Late Night Economy, Food and Drink and Amusement Centre Uses; Policy 30 Arts and Culture; Policy 31 Streets, Character and Layout; Policy 32 Community Safety/Designing Out Crime; Policy 33 Building Scale and Design; Policy 35 Sustainable Design and Construction; Policy 37 Shopfronts and Advertisements; Policy 38 Design in Existing Residential/Mixed Use Areas; Policy 39 Streetscape, Landscape and Public Realm Design; Policy 40 Tall Buildings; Policy 41 Views; Policy 43 The River Thames Policy Area – Urban Design; Policy 45 Listed Buildings; Policy 47 Conservation Areas; Policy 50 Open Space and Sports Facilities; and

6.9 Regional Guidance:

• London Plan Housing SPG • London Plan Providing for Children and Young People’s Play and Informal Recreation • London Plan World Heritage Sites SPG • London Plan London View Management Framework (LVMF) SPG • London Plan Sustainable Design and Construction SPG • London Plan Mayoral Community Infrastructure Levy (CIL) SPG • London Plan Cross-Rail SPG • London Plan Planning and Access for Disabled People: a good practice

guide (ODPM) • London Plan the Mayors Ambient Noise Strategy • London Waterloo Opportunity Planning Framework (OAPF) • British Research Establishment (BRE) Handbook Site Layout Planning for Daylight and Sunlight 2011: A Guide to Good Practice.

6.10 Local Guidance:

The council has adopted the following Supplementary Planning Documents, which are relevant:

• SPD: Safer Built Environments • SPD: Housing Development and House Conversions • SPD: Sustainable Design and Construction • SPD: S106 Planning Obligations • The Waterloo SPD (Adopted April 2013)

6.11 The Council’s ‘Waste & Recycling Storage and Collection Requirements: Guidance for Architects and Developers’ (2006) is also relevant.

6.12 Lambeth Older Person Housing Strategy (2012)

Employment and Office Accommodation

7.1 The site is located within the Central Activities Zone (CAZ), Thames Policy Area and Waterloo Opportunity Area as designated by the London Plan (LP). Under the London Borough of Lambeth’s Core Strategy Policy PN1 Waterloo, the site falls within the ‘Railway’ character area of Waterloo. It is also subject to the saved Major Development Opportunity 92 (MDO92) in the ‘Lambeth UDP 2007: Saved Policies’. This thread of policy gives the site a strategic role within London, and for which Lambeth is tasked to contribute and ensure London’s offer as a ‘World Class Place’ is maintained.

7.2 London Plan Policy 2.10 anticipates the delivery of a mix of local and strategic uses to secure the globally iconic core of one of the Works most attractive and competitive business locations. London Plan Policy 2.13 relates to Opportunity Areas. It states that, taking account of other policies, developments will be expected to maximise residential and non-residential densities and to contain mixed uses; and that, given their scale, they are likely to give rise to substantial planning obligations. The Waterloo Opportunity Area (WOA) is identified as having an indicative employment capacity of 15,000 jobs and is expected to accommodate a minimum of 1,500 additional homes between 2001 and 2026.

7.3 Core Strategy Policy PN1 sets out the council’s vision and approach for Waterloo, reflecting the London Plan Opportunity Area Planning Framework. Furthermore, the vision at a local level is drawn out within the Waterloo SPD where the opportunities of the Shell Centre site to contribute upon the wider area objectives are stated. Policy PN1 states that the council will support sustainable development for jobs and homes in line with London Plan targets and maximise the area’s potential for the full range of Central

London and Town Centre activities. This aligns with national policy presumptions for sustainable development. A broad range of uses is supported within Waterloo in order to achieve this vision and Waterloo is identified as a major location for offices as well as a mixed residential area with appropriate supporting community, service and shopping facilities.

7.4 Core Strategy Strategic Policy S3 (f) supports the location of, and investment in, major office developments (over 1,000 m2) in the CAZ and WAO. Section (d) of the policy supports the vitality and viability of Lambeth’s hierarchy of major, district and local centres, including the WAO, for retail, service, leisure, recreation and other appropriate uses, whilst maintaining the predominant retail function of primary shopping areas in the WAO (Lower Marsh). Saved UDP Policy 21 provides guidance on the requirements for large scale office development, particularly in relation to impacts on public transport capacity and securing benefits for local communities.

7.5 The application would provide new additional commercial (B1) accommodation for Shell Petroleum in Building 1 which would be physically linked into the retained Shell Tower through upper level bridges (both buildings would be utilised to provide the European Head Quarters for Shell Petroleum). The retention of Shell at the site highlights the role of the site as being part of the economic core of a World City. Indeed, the retention extends Shells long-term commitment to the area and gives certainty to the delivery of the scheme whereby it is understood to be a condition between the parties that this part of the scheme commence almost immediately upon consent being secured. The reality of the development being implemented here will secure an impetus to other development sites neighbouring the site and in the wider Waterloo Area which in turn secures delivery upon its targets as anticipated by virtue of its designation in the CAZ. A further speculative commercial building is proposed providing flexible floor plate accommodation in building 2. In total 111,029sqm GIA of commercial (B1) floorspace is proposed above ground, a net increase on site by 28,434sqm.

7.6 The total employment on the Shell Centre site following implementation of the proposed development would be 6,165 jobs. The employment generated by the proposed commercial (office and retail (introduced below) would be 4,465 jobs. Taking to in consideration the existing employment capacity of the wings (2,490 jobs) this equate to a total uplift in 1,975 net additional jobs.

7.7 Officers have sought to achieve a wider package of public benefit to build on the initial work between the applicant and the authority in setting up the ‘South London Procurement Network’. A contribution towards the setting up of and ongoing (time limited) maintenance of a Job Brokerage would be secured. In addition, as well as securing construction jobs for targeted employment in the local area, a strategy to secure jobs, interview support training and other employment entry initiatives would be secured. Canary Wharf Group, party to the joint venture under which the application is submitted, has an excellent track record in this respect where it operates in other boroughs within London. Such requirements would be a lasting

outcome from the development setting a benchmark against which other development would be anticipated to contribute.

Employment and Office Ac commodation

7.8 The site is located within the Central Activities Zone (CAZ), Thames Policy Area and Waterloo Opportunity Area as designated by the London Plan (LP). Under the London Borough of Lambeth’s Core Strategy Policy PN1 Waterloo, the site falls within the ‘Railway’ character area of Waterloo. It is also subject to the saved Major Development Opportunity 92 (MDO92) in the ‘Lambeth UDP 2007: Saved Policies’. This thread of policy gives the site a strategic role within London, and for which Lambeth is tasked to contribute and ensure Londons offer as a ‘World Class Place’ is maintained.

Housing

7.9 The principle of introducing housing on the site receives support across the suite of policy hierarchy from a local to national level. London Plan Policy 3.3 seeks to increase London’s supply of housing including affordable and sets Lambeth a minimum ten year target of 11,950 new homes. The Waterloo SPD reminds applicants that the target for Waterloo under the London Plan is 1900 homes by 2031.

7.10 Policy S2 of the Core Strategy commits the Council to the provision of at least 7,700 net additional dwellings across the borough between 2010/11 and 2016/17 in line with London Plan targets and a further 8,800 more homes by 2024/25, subject to London Plan targets for this period. Both local and regional policy sets out that developments should provide a mix of housing sizes and types to meet the needs of different sections of the community. With a scheme of this nature, at least 50 per cent of housing should be affordable where public subsidy is available or 40 per cent without public subsidy, subject to housing priorities. Furthermore, there is an expectation that the mix of affordable housing should be 70 per cent Social Rented and 30 per cent Intermediate housing.

7.11 The proposal would deliver 877 residential units in a variety of tenures. This would provide a significant contribution towards the strategic housing targets set for the Borough, optimising the potential of the site. The proposed site is located within a ‘Central’ setting in respect of supported density ratios according to public transport accessibility levels (PTALS). Higher densities are sought where access and public transport is greatest. The site has a PTAL rating of 6B (excellent public transport). Under the above designation a density range of 650-1,100hrha is anticipated.

The development proposes a total of 2,199 habitable rooms. The density of the development would therefore be 1,419hr/ha and 566u/hr. Officers acknowledge that the proposed density would exceed the figures set out in the London Plan, however, the policy states it is not appropriate to apply this mechanistically. Its density ranges for particular types of location are broad, enabling account to be taken of other factors relevant to optimising potential including local context and design. Higher density resulting for the provision

of a higher number of smaller households is encouraged for areas higher PTAL ratings. Overall taking into consideration the high rise nature of development, the location of the development in close proximity to a major transport interchange, the proposed residential densities are appropriate for this urban location and are not considered to result in the overdevelopment of the site whereby the scheme is designated to accord with all pertinent residential standards.

7.12 Of the 877 units proposed, 779 would be private, and the remaining 98 would be affordable.

7.13 The following table outlines the mix of the private units:

Unit Buildin Buildin Buildin Buildin Buildin Buildin Tota Type g 3 g 4A g 4B g 5 g 6 g 7 l Studio 37 48 30 0 0 0 115 One 78 68 52 31 16 8 253 Bed Two 76 76 55 48 31 16 302 Bed Three 12 19 15 26 19 6 97 Bed Four 0 1 6 3 1 1 12 Bed Total 203 212 158 108 67 31 779

7.14 Given the dense urban capacity anticipated by the policy context for the site, the predominance of smaller units is considered acceptable; the principle to this has been introduced above. It supports aspects of London’s world city role by meeting a recognised need for high quality residential units suitable to the accommodation needs of international business and those working in the CAZ. The proposed room flat sizes and overall flat layouts have been assessed against the SPD for Housing Development and House Conversions and are compliant.

Affordable Housing

7.15 Policy within the London Plan sets out a strategic priority for the delivery of affordable housing, requiring boroughs to seek the maximum reasonable amount of affordable housing when negotiating on individual private residential and mixed-use schemes. Policy S2, part c, specifies at least 50% of housing should be affordable where public subsidy is available or 40% without public subsidy, subject to housing priorities and, where relevant to independently validated evidence of viability. At a local level, it is anticipated, having regard to the likelihood of availability of public subsidy, that forty per cent will be the minimum provision, subject to viability. Policy 16 of the UDP sets out that a range of unit sizes of affordable housing should be provided, having regard to local circumstances, site characteristics and the aims of the borough’s annual housing strategy. It goes on to set out the presumption that affordable housing should be

provided on site. Policies further state that there should be tenure mix of 70% socially rented units and 30% intermediate. The Waterloo SPD sets out the authorities’ commitment to maintain a vibrant, mixed community in Waterloo. Where applicable, it states that S106 agreements shall capture any uplift in values during the lifetime of development to maximise the delivery of affordable units on or off site

7.16 Out of the up to 877 proposed residential units, 96 would be affordable, as set out below:

Unit Type Affordable Intermediate Total Rents (Extra Units Care) One Bed 46 24 70 Two Bed 6 22 28 Total (Tenure 52 (53%) 46 (47%) 98 Split)

The proposed tenures would be extra care (affordable rent) and intermediate units.

7.17 This equates to a total on-site provision of twelve per cent affordable housing. It should be noted that this twelve per cent includes a ‘phantom’ 7 units as one floor of the affordable rent provision will provide communal and specialist facilities (ie. treatment rooms) specifically required to support the delivery of the extra care facility. This floor has been designed to allow the 7 units to be reinstated at a point in time in the future if appropriate. It is considered appropriate to reflect these ‘phantom’ units in reporting the on site delivery of affordable housing.

7.18 Policy 16 of the UDP sets out that a range of unit sizes of affordable housing should be provided, having regard to local circumstances, site characteristics and the aims of the borough’s annual housing strategy. It goes on to set out the presumption that affordable housing should be provided on site. Policies further state that there should be tenure mix of 70% socially rented units and 30% intermediate. Notwithstanding that the principle of off-site affordable housing needs substantiating further, the proposed quantum of affordable housing has required the submission of a financial viability appraisal to demonstrate that the proposal delivers the ‘maximum reasonable’ amount of affordable housing. The report submitted has been independently assessed on behalf of the Planning Authority by BNP Paribas (BNPP) together with input from Gardiner and Theobold in respect of the costs plan, both of whom are experts in their respective areas.

7.19 BNPs assessment provides a critique to the methodology adopted on the viability of the development, the assumptions adopted by the application and hwy alterative assumptions have been promoted together with results of the appraisal and conclusions drawn from it.

7.20 In respect of the methodology, the appraisal includes a benchmarked ‘current use value’ which derives from an assumption that the extant

‘Belvedere’ consent be delivered. Given that this has been implemented, this approach is considered acceptable and is consistent in the approach taken on such appraisals in similar circumstances. Indeed, whilst the retention of Shell gives certainty to the delivery of the scheme, in return they require a reasonable return in respect of a land receipt inorder to be suitably incentivised to ‘release’ the site for development, and thus realise the sites potential to contribute towards both strategic and local functions within the CAZ. The approach taken therefore is whether a reasonable level of developer return is achieved, and in this respect that suited to lengthy timescale projects is used. A return of twenty per cent is considered comparable with other developments in the Borough and across London.

7.21 Overall, the viability is deemed ‘challenging’, particularly given that the appraisal makes no account for the delivery (cost) of off-site affordable housing, nor Section 106 payments. As a consequence, BNP advise that over the life of the planning application and construction period the pr ospects for improvement in the economics of the development are good. Consequently, in the absence of achieving the forty per cent policy target, and to meet with the spirit of delivering the ‘maximum reasonable’ amount of affordable housing, a review mechanism that re-considers the viability at an appropriate future point in the development period is recommended by BNP.

7.22 Given the quantum of affordable housing proposed is greater than that which is accounted for within the appraisal, it is considered that as submitted a more than reasonable maximum amount of affordable housing is proposed, but that given improvements to the housing market as widely reported in the media, and too that the overarching aim of affordable housing policy is to secure the reasonable amount, the policy context is considered to support the recommendations from BNP to secure a review mechanism. First, the details of the proposed affordable housing provision shall be discussed.

7.23 The greater proportion of affordable housing proposed for the site would be a form of Affordable Rent, promoted as Extra Care Housing. The Council’s Older Person’s Housing Strategy (2012) has identified the need of the Borough’s elderly population:

• There is a shortage of c.250 homes for elderly in 2012, increasing to 379 homes by 2031. • There are insufficient new scheme in the pipeline to address the shortage identified. • The nature, type and size of the Councils existing specialist elderly housing fails to meet the needs of elderly residents. • There are shortfalls in the quality of the existing elderly accommodation stock – heavy investment is required within this field.

7.24 The application would deliver a total of 52 extra care units on site within building 3 of the development of which 46 would be one bed and six would be two bed units. The approach to design has ensured that the units are self-contained, easy to run and manage, are capable of accommodating individuals of different care needs and offering flexible care packages to

older Lambeth residents. They fall within the C3 use classification.

7.25 The units would be individual homes, each with their own front door, accessed from a self-contained core and within a safe and secure building. The proposed accommodation has given regard to the Housing Learning and Improvement Networkstandards and other guidance such as the Housing our Ageing Population: Panel for Innovation (HAPPI) panel report, which is supported by officers. Furthermore, the type of units would surpass the dwelling space standards in the Mayor’s Housing SPG (2012). The only difference from the normal residential and the extra care units would be age restricted occupation as Affordable Rent only. They would be let to eligible older households and provide enhanced communal facilities and ancillary space, required to deliver care and support.

7.26 The proposed tenants would live independently but would have access to care and support at varying levels of personal care and support would be provided from the staff and physical resources based on site. The range of facilities would include communal living, dining spaces and activity areas, exemplar winter gardens, a therapy hub and ancillary space, enabling the provision of on-site care and support. The first floor has been designed to accommodate the communal/ shared facilities.

7.27 The residents of the affordable rent home would be responsible for paying rent and accommodation related service charges in the usual way for affordable housing. The properties would be rented using Affordable Rent agreements. The rent level range for a one bed unit would be £130 (lower limit) up to £184 (upper limit). The rent level range for a two bed unit would £150 (lower limit) up to £241 (upper limit).

7.28 Officers have assessed the affordability levels for the extra care units and raised no objection to the rent levels. The applicant recognises the challenge associated with service charge provisions to income levels for older peoples and is therefore keenly aware of the need to specifically focus on careful management and control of estate service charges which a Registered Provider will be able to manage through setting of rents having regard to service charge levels. This would be secured through Section 106 Agreement with the applicant and will reflect the terms of the Tenancy Strategy.

7.29 In summary officers support the proposed form extra care units on site at affordable rent levels as there is a required need in the Borough for which the development would contribute homes with flexibility to ensure longevity to meeting the changing needs of the elderly population.

7.30 The remainder of on-site affordable housing units would be intermediate rent homes. The 46 units would be in the form of 1 and 2 bedroom units. This would be provided to the market as discounted market rents which are affordable to incomes within the affordability thresholds set out in the London Plan (£18,000 - £61,400) and meet identified local needs, rather than shared ownership.

7.31 The Strategic Housing Assessment for the South West of London identifies a shortfall of around 6,500 intermediate units across the sub-region, of which 90% are for one and two bed properties. Intermediate rent is low cost rented housing, where rent are typically set 20-30% lower than private market rent level. The units would be let to on an Assured Shorthold Tenancy basis, as directed by the Homes and Communities Agency (HCA), managed by a Registered Provider (RP) providing greater security of tenure and high quality affordable accommodation. The managing RP would work with Lambeth and Homebuy Agent, First Steps, to ensure that all the units are allocated in accordance with Lambeth’s priority groups for intermediate housing.

7.32 The benefits of intermediate rent units would be as follows:

• Overcoming the barrier to entry often associated with shared ownership typically, a deposit equivalent to a month’s rent is required for intermediate rent (c.£1,050 - £1,200 for a 1 bed and c£1,400 for a 2 bed) in comparison to shared ownership where a deposit of at least 10% of the equity share purchased is required (equating to at least £13,750 for a 1 bed and £23,100 for a 2 bed). • Accessible to a wide range of households on moderate incomes. • Flexibility to respond to changing prices and individual circumstance of eligible applicants, ensuring affordability of units for future eligible households, not only at first lets but for subsequent lettings. • Allocated to eligible Lambeth residents who cannot afford to buy a home of their own outright and who would not be given high priority for social rent or affordable rent.

7.33 To demonstrate the potential range of affordability of the proposed 1 and 2 bedroom homes to be provided at the Shell Centre, the following assumptions have been applied:

• A net income cap of 40% i.e. ensuring that the total housing costs do not exceed more than 40% of a households net income;

• A monthly market rent of £1,500 for a 1 bed and £2,000 for a 2 bed (exclusive of service charge);

• Service charge assumptions by reference to the average service charges in London from the Association of Residential Managing Agents (ARMA). These are currently between £1,800 and £2,000 per annum and each end of this range has been tested within the eligible income ranges.

7.34 It will be subject to nomination agreements, the ability of the RP to fix the rent dependent on the level income that is achieved by a tenant. The following tables show the intermediate levels of rent changeable in accordance with a range of household incomes. For instance someone on £30,405 have a rent of £600 per month for a 1 bed apartment.

1 Bedroom Intermediate Rent Unit (Figure 3):

2 Bedroom Intermediate Rent Unit (Figure 4):

7.35 The applicant has considered alternative intermediate units in the form of shared ownership, however, this was not considered further given the inaccessibility of deposit requirements and due to the scheme not achieving affordability levels for different income thresholds. This is demonstrated in the two tables below for either a 25% or 50% share in the units:

1 Bedroom Shared Ownership (Figure 5):

2 Bedroom Shared Ownership (Figure 6):

7.36 Figures 5 and 6 illustrate that shared ownership units would target higher income earners which would not benefit a varied range of individual on lower incomes and would not comply with the income household for affordable

housing. The minimum incomes targeted are at least £58,732 for a one bedroom and a minimum of £94,535 for a two bed, thereby significantly exceeding the Mayor’s current maximum income threshold of £66,000. The intermediate rent option would deliver ‘better value’ units which would cater for different housing needs in the borough on a lower income. Consequently, the intermediate rent model is welcomed as an alternative approach towards delivering affordable units.

7.37 Whilst the principle of off-site affordable housing does not meet the policy context, and notwithstanding development viability, the provision of additional affordable units onsite would not be equal to the quantum that could be deliverable off-site. Such a proposition has been supported at neighbouring sites given development constraints, and in this respect the principle would directly engage with the London plans expectation for the maximisation of housing output. Consequently, officers have no in principle objection to off-site affordable housing in this instance.

7.38 The applicants have worked diligently with officers to consider suitable sites, within a defined proximity to the site. Discussions evolved around:

(i) Identify potential opportunities to deliver additional affordable housing locally of a type, tenure and affordability that focuses on meeting local needs, in particular affordable rent and larger family units; (ii) To create the opportunity deliver affordable housing early; and (iii) To deliver 20% affordable housing overall.

7.39 The Ethelred Nursery site, on Lollard Street is identified as the preferred location for delivering a mix of affordable housing, with the greatest potential number of new homes, the highest certainty of delivery and significant other community benefits included improved public realm and provision of new nursery facilities. It is within a mile of the application site and would potentially provide up to 101 residential units as a whole.

7.40 The different delivery options are still being explored but the applicants have committed to being responsible for the construction of the new homes and leaving the Council the flexibility to select a delivery model to suit its wider objectives; for example the completed units could be transferred back to the Council to be retained as Council housing in their ownership and benefit from the income; an element of homes could be included for sale to raise funding to invest in other housing initiatives; or the homes could be transferred to a Registered Provider and a capital receipt received by the Council. A total of 101 units would be created, where a total of 78 units would be created as part of the Shell Centre offsite provision. The remaining 23 units would be the balance.

7.41 Lambeth Housing officers support the proposals submitted by the applicant. The proposed off-site affordable housing units should be of family accommodation and should comply with the Lambeth affordable rent model principles. This would be secured as part of the Section 106 Agreement. In relation to the intermediate housing, comments were raised in relation to the affordability of the units given the area. However, after assessing the

current development in accordance with the GLA’s affordability level, they would comfortable fit within the middle of the range. Consequently, the proposed tenure, mix and quantum of affordable housing is supported.

7.42 As referred above, however, policy expectations are to secure the maximum reasonable quantum of affordable housing, and capture value from the development. Authorities are encouraged to secure commuted payments where developments are phased. This has been a point of disagreement between the parties, whereby given the need to build out the proposed basement, it is being argued by the applicant that the development is not phased. Officers are of the view, however, that where the development would bring forward eight separate buildings, albeit with a shared basement, over the course of 6 years plus, the scheme meets the exact criteria for which commuted payments are anticipated and for which the GLA lends its support also. Whilst such a proposition should not vetter the applicants profit margin to incentivise commencement of development, so it is reasonable for the Authority to secure a proportionate quantum of uplift to be paid as a commuted sum equivalent to meeting a value of forty per cent affordable housing from both the development and that equal to the 70 units proposed off-site. In order to capture the true value from the development, but also incentivise the developer to complete the development, the review would be sought to occur at the point where 70% of residential units have been ‘sold’. The capped value has been calculated on the basis of the provision of 40% affordable housing across both the on and off-site housing to be equivalent to a total sum of £24,480,000.00.

7.43 The proposed development has been designed to Lifetime Home standards and 10% of dwellings would be designed to be easily adaptable to meet the needs of a wheelchair user.

7.44 Proposed Standard of Accommodation to future residents

The submitted daylight and sunlight report which has been submitted as part of the ES has assessed the proposed daylight levels within the proposed residential units. The Vertical Sky Component (VSC), Average Daylight Factors (ADF) and No Sky Line (NSL) were calculated. The assessment concluded that a large proportion of the rooms within the flats of the new development itself (27.4%) that would not meet the minimum daylighting recommendations. However, BRE gives guidance in that where there is shortfall in daylight levels, this could be mitigated against by using electric lighting. Furthermore, given the urban dense location and the extent of the development on the site, shortfalls in daylight levels to proposed units cannot be avoided. In this instance officers raise no objection to the proposed shortfalls.

7.45 The proposed minimum distance between the residential units on the site would be 15m. There would be some perceived overlooking between the units within the development, however, where there is direct overlooking, the proposed distances between the buildings would be sufficient given the urban context. In this instance no objection is raised.

7.46 The proposed residential units would have there own private amenity space. This would be in the form of balconies and projecting winter gardens. The majority of the balconies within the development would comply with space standards set out in the SPD for Housing Development and House Conversions. However, where the shortfall may arise, this can be utilised by making use of the public square within the development.

7.47 Children’s Playspace

The applicant has submitted a playspace strategy which is set out in volume 10 of the design and access statement. Policy 3.6 of the London Plan sets out the requirement for new housing developments to include provision of children’s playspace and informal recreation. Provision should be based on the number of children living in the new development and should be appropriate for the age profile of the population. The GLA SPG “Providing for Children and Young People’s Play and Informal Recreation” states that the minimum benchmark for new residential developments should be 10sqm per child. The playspace needs to be suitable for various age groups of children and young people.

7.48 The proposed development would be providing a range of play space facilities within the development and the surrounding areas in close proximity of the application site. Play facilities would not be segregated and fenced off, instead, playful offers would be threaded throughout the scheme. This would include distinctive focus points such as informal play equipment set in engaging landscaping, open space and facilities for informal play. Different age groups would be able to make use of the spaces through varying activities at different times of the day. The table below sets out the play standards (sqm) associated with the development:

Age Profile Number of Spaced Proposed Children Required Provision Under 5 Years 40 400 On-site (in part) 5-11 Years 18 180 Off site 12+ Years 10 100 Off-site Total 68 680

The development would provide play space for under 5 years onsite. The remaining age group categories would be provided through existing facilities such as Jubilee Gardens which lies directly to the west of the site, and Archbishop’s Park which lies within 400 metres of the site. The guidance sets a benchmark of 10sqm of useable child playspace to be provided per child, with under-5 child playspace provided on-site. The redevelopments proposals would include approximately 719sqm of communal gardens and 2,106sqm of public ream and the applicant is proposing informal playable space in these spaces, with older children being created for through existing facilities, such as Jubilee Gardens, with financial contributions being offered to improve them.

Retail Uses

7.49 The application proposes approximately 5,957sqm of A1-A5 floorspace.. The applicant has submitted a ‘Retail Report’ produced by Roger Tym and Partners. It states that the main target market for the retail (shops, food and drink), leisure and other related uses area would be:

• Shell Employees; • Office tenants of building 2; • Residential occupiers within the proposed flats; • Workers and residents from the surrounding area; and • Visitors to the area

7.50 The report states that “both local residents and workers have expressed the need for local retail and for a much better range of cafes, restaurants and bars. The applicants are concerned to ensure that the development offers new facilities to complement and not threaten the trades and retailers of the local area, particularly Lower Marsh”.

7.51 The proposed retail uses would be located at ground floor levels for buildings 1, 3, 4A, 4B, 5, 6 and 7. The square is designed to provide an alternative and complimentary space to local facilities that the South Bank has to offer including bars and restaurants, parks, the promenade along the river, the London Eye and the South Bank Centre. The cafes, restaurant and bars that are proposed at the ground floor of the buildings around the square would spill out into the square in the form of outside seating which will create a vibrant place to relax.

7.52 The proposed tenant mix would potentially include chemist, newsagent, dry cleaners and a quality food st ore along with a range of bars and restaurants. There are two main categories: smaller units of 50sqm; 150sqm and larger units of 500sqm. The smaller units would be accommodated with coffee shops, lunch options or a ‘meal to take home’ tenants. Whilst the larger units would be accommodate by supermarket chains ‘local’.

7.53 The NPPF also requires applications for retail development outside of town centre, which are not in accordance with an up-to-date Local Plan, to be accompanied by an is over a proportionate, locally set floorspace threshold, or a default threshold of 2,500sqm. An impact assessment should include:

• Assessment of the impact of the proposal on existing, committed and planed public and private investment in a centre or centres in the catchment area of the proposal; • Assessment of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area, up to 5 years from the time the application is made.

7.54 London Plan Policy 2.10 ‘Central Activities Zone (CAZ) – Strategic Priorities’ and Policy 2.11 ‘Central Activities Zone – Strategic Functions’ set out a number priorities/functions that are relevant to the CAZ. In terms of retail the relevant priorities/functions are:

• To support and improve the retail offer for residents, workers and visitors; • To identify, enhance and expand retail capacity to meet strategic and local need and focus this on the CAZ frontages.

7.55 Lower Marsh and The Cut are designated as CAZ frontages in the London Plan, which are defined as mixed use areas usually with predominant retail frontage. Therefore, the retail capacity is enhancing and expanding open the existing offer to meet strategic and local need. It is recognised that this will add to the number of jobs in the area also.

7.56 However, compared with that proposed with the extant Belvedere permission that proposed an area of 9,500sqm of A1 floorspace including a food store, the current proposal would be providing 5,957sqm, which is considerably less. This demonstrates the intention behind the retail offer to enhance rather than compete with the localised provision. The applicant has assessed the minimal impact of the uses would have with the existing town centres such as Lower March and the Cut.

7.57 The impact test states that there would be limited, if any overlap between the floorspace being proposed at the application site and the existing function of Lower Marsh and The Cute. The profile of the proposed development would be materially different and is targeted to take advantage of the new spending generated by the development. Additionally, the food store provided would enhance consumer choice in the area which is an aspiration of the Waterloo SPD. In this instance the impact of development would have a negligible and more offset by the wider economic benefits provided.

7.58 Due to the provision of the retail uses within the development, conditions would be imposed restricting the opening and closing times of the units. This would mitigate potential impact to residential units within the proposed development and also adjoining.

7.59 Overall at all levels the planning policy supports the additional retail proposed as part of the scheme. Additional retail uses in the Waterloo opportunity area are supported by the London Plan, the Saved UDP and the Core Strategy. The principle of retail on the Site has also already been established by the implemented Belvedere Court scheme, which the UDP states will be a material consideration when determining future planning applications. The Core Strategy also supports retail use on the Site, as it will provide active frontages and meet local needs. The proposed basis and rational for the level of the retail offer is supported by officers recognising the benefits for the area and its combination in creating a truly mixed use development.

7.60 Other Uses

In addition to the residential, office and retail uses, the redevelopment proposes leisure and community uses equating to 2,557sqm of D1/D2 (community/ leisure) as well as space capable of accommodating

replacement police facilities. A £1million contribution towards a swimming pool offsite, which has been earmarked for the Doon Street development would be secured through the Section 106 also. Officers welcome the proposed community uses within the development.

7.61 Policy 30: ‘Arts and Culture’ of the Saved UDP protects theatres, stating that planning permission will not be given for a change of use of buildings built at theatres to a non-theatre use. Furthermore, the development would remove the existing swimming pool and sports hall facilities which currently exist in the basement. These are however, all private and used solely by Shell employees, albeit Shell have allowed external groups to use them periodically.

7.62 The Theatres Trust have raised objection to the loss of the theatre from the existing site and have stated that the space could be incorporated within the scheme and marketed properly to potential users of theatres, which would be more sustainable. Whilst officers acknowledge it is an aspiration of the trust for the retention of the theatre, it should be noted that this space was not used for public viewing and this was reiterated within the Secretary of State (SoS) report for the Belvedere scheme, where the Inspector stated this also. Evidence given at the time indicated it was principally as a facility for Shell employees and business purposes.

7.63 Conclusion:

The proposed development would be providing a range of uses which would provide regenerative benefits to the local area and the wider London city. These are summarised below:

• There would be substantial increase in employment floorspace which would provide an increase in jobs to the area. • The legacy of the scheme provides a basis for future apprenticeship, skills to be acquired and jobs to be created from the development for the local community. • The introduction of residential units on the site would provide a significant uplift in the housing supply for the Borough. Furthermore, the proposed housing unit would also help the Borough to meet its strategic housing targets • The application would deliver 20% affordable housing in the form of onsite units equating to 12% (extra-care and intermediate units), with the remaining units equating to 8% provided offsite at a site named Ethelred Housing Estate. • The proposed retail uses in the scheme will enhance and complement the existing offer found in the area and help to provide for local retail needs.

8 Conservation an d Design

8.1 The scheme design has been introduced above, within the proposals section, whereby the scheme would be built over eight new buildings along with alterations to the main Shell Centre Tower. It has evolved through

extensive pre-application discussions with officers, together with presentations to English Heritage, CABE and the GLA. The design approach has evolved around a masterplan by Squire and Partners, with a number of esteemed architects taking forward explored context parameters including KPF, Stanmore Williams, Patel Taylor and Grid Architects.

Overview of development:

8.2 The massing of development has been carefully considered in light of the nature of development surrounding the site, the character and appearance of the South Bank Conservation Area and the aspiration for a cluster of tall buildings in the Waterloo Opportunity Area. Indeed, due to the sites central location and adjacency to other potential redevelopment sites, it represents an important strategic node for the regeneration of Waterloo. Development of the site offers the impetus for the redevelopment of the surrounding area, including Waterloo Station, to commence.

8.3 This has set the benchmark for the scale of development proposed, in terms of height, mass and plan scale, allows it to be read as a macro and micro level. The taller elements take the form of slender towers and are clustered towards the north-east corner of the site, away from the river edge by Jubilee Gardens and County Hall, and close to the main entrance to Waterloo Station. The tallest element of the proposed development rises taller than the existing Shell Centre Tower but responds to the recently resolved Elizabeth House redevelopment scheme, that would deliver an up to 29-storey building. The varied height of the new buildings provides visual interest on the skyline and expresses the plan form of the scheme. This is particularly evident in views from the north bank of the Thames, with the taller elements seen to the east, set behind the existing Shell Centre Tower. The proposed buildings on either side of the latter are between 14-21storeys tall, ensuring the Shell Centre Tower remains the dominant element in these views as it has since the 1960’s.

8.4 The new buildings on Belvedere Road continue the building line of the Shell Centre Tower and provide a built edge and enhanced sense of enclosure to the road. The proposed buildings would address the existence of Jubilee Gardens and the River Thames positively. Furthermore, this part of Belvedere Road would be improved by the introduction of passive surveillance from the new residential units in Buildings 5, 6 and 7, so too the corner with Chicheley Street.

8.5 To the east, there would be four further buildings erected along York Road, which would be separated by pedestrian routes. These would serve to enhance the townscape quality of this busy street and promote the eastern edge of the South Bank Conservation Area. Pedestrian movement south along York Road would be encouraged through the introduction of active uses here. The Master Plan approach of the development results in an harmonious group of buildings which respond to each other, and enhances the setting of the Shell Centre Tower.

Tall Buildings

8.6 Along with the prior permission for the site, the acceptance of the tall buildings in the immediate area (Doon Street and Elizabeth House opposite on the east side of York Road) there is a policy context that supports the provision of tall buildings for the site. Indeed, the site has been home to tall buildings, with the Shell Centre Tower having been the UKS tallest building when first constructed. The principle of tall buildings for the site is consequently well established.

8.7 English Heritage and CABE have published ‘Guidance on Tall Buildings’ providing twelve criteria’s by which tall buildings should be considered and assessed. These are considered in respect of the proposed scheme as follows:

• Relation to context Notwithstanding the existing presence at the site of a ‘tall building’ the underlying policy context encourages the delivery of tall buildings to the site. The rationale stepping the height up towards the northeast corner secures a dialogue with the development to come forward across the road at Elizabeth House and adds to the visual interest present across the wider London Skyline. The design responds to the immediate urban townscape, without seeking to compete with local Conservation Areas, nor Listed Buildings and does not impact upon the World Heritage Setting of the Houses of Parliament. Furthermore, to the ground plane it seeks to promote permeability from Waterloo towards the South Bank as anticipated by the Waterloo SPD.

• The effect on the historic context This is discussed below under 8.4.

• The effect on World Heritage Sites This is discussed below under 8.53

• The relationship to transport infrastructure The site achieves the highest possible PTAL rating of 6b and as such accords with the London Plan policy for the provision of tall buildings. The development would improve the public realm from the station through varying routes on York Road towards the South Bank and beyond. Section 106 monies are to be sought to improve the local public realm, cycle network and pedestrian footpaths leading to and from the site.

• The architectural quality of building CABE supports the applicant’s approach in terms of built form and design detailing, which has been discussed in detail above.

• The sustainable design and construction Sustainability has been embedded to the design evolution, and the applicants have given support for local aspiration to see the delivery of a district heat network. The facade design of the buildings and distribution

of solid to void ratio is mindful of passive control of heating the buildings and general solar gain issues. The commercial buildings are proposed to achieve BREEAM Excellent scores. The development would reduce carbon emissions by 31% which would exceed the London Plan standard of 25%.

• The credibility of the design The design has progressed following extensive discussions with the Council officers, GLA and presentation to CABE. The architects are well respected for their portfolio of work, both in Britain and internationally. As part of the recommendations of the S106 agreement, they shall all be maintained throughout the detailed construction drawing stage together with a 1:1 sample of the facades to be provided for review as part of the discharge of conditions to secure the design quality.

• The contribution of public space and facilities The scheme would benefit and improve the existing public realm surrounding the site. The improvements would also enable a greater permeability and accessibility from York Road towards the South Bank, which is currently hindered by the current buildings on the site. This discussed in more detail below under the 8.70 section.

• The effect on the local environment The applicant has submitted an Environmental Statement to assess the proposal impact on the environment which is discussed below in this report. Overall, the development is envisaged to result in no unacceptable impact subject to appropriate mitigation secured by condition.

• The contribution to permeability This is discussed in more detail below but the development would create new access routes through the site providing greater permeability towards the South Bank and immediate context as well as improved legibility of the site itself.

• The provision of a well-designed environment This is discussed further within the design section.

8.8 CABE were consulted on the proposed development and they support the composition of the buildings around the retained Shell Tower and the ‘family’ relationship between them. English Heritage has raised concern on views in relation to tall buildings which is covered under section 8.53.

Detailed Design and treatment

8.9 The Waterloo OAPF, states that the northern element to York Road should be the focus for tall buildings, given this the proposed tower element would deliver the cluster of taller buildings at Waterloo. Within the views identified in the London Viewing Management Framework (LVMF), the majority of the lower elements of the towers would not generally be visible; however buildings 1, 4A and 4B would be visible from within a number of LVMF views

and from other locations across central London. There are a number of towers in Waterloo generally and the proposed tower will stand next to the Shell Centre tower. In this instance officers would not object to the proposed towers in this location. Furthermore the proposed scheme would accord to the ‘Guidance of Tall Buildings’.

8.10 The application proposes a total of eight new buildings, these are assessed in turn below:

Building 1 would front both onto York Road and Chicheley Road, this building has already been pre-let to Shell International Petroleum. The floor plan of the building has been influenced to accommodate trading floors for Shell. A covered walkway is proposed between buildings 1, 2 and the existing Shell Tower. Building would incorporate bridges at floors 3 and 8 that link to the Shell Tower. The proposed bridges/links have been submitted under a separate application (12/04699/FUL).

Building 1 would be the lowest building on the site. The large rectilinear office building would be formed by three major volumes stepping up in height towards the north. The three volume which are ‘linked; would effectively break up the elevational bulk of this building. The overall height step backwards and increases in height due to the existing height of the County Hall North Block along Chicheley Street. The proposed building in terms of its overall scale, bulk and massing would be acceptable given the existing heights of buildings in the vicinity and as this building would effectively step away from the County Hall Block, the impact of this building would be minimal.

8.11 The ground floor of this building would comprise of an office lobby and retail function which would face onto York Road and the main north-south route passing through the site. The proposed façade of building 1 consists of three solid framed elements which step up in height to the north, separated by further glazed elements. The solid frame is constructed from reconstituted stone with recessed metal framed glazing. Between the stoned framed bays, a series of bronze fins at regular intervals would be installed. Roof terraces have been proposed at floors 5, 8 and 9, which would be used ancillary to the office use. Roof planting would be installed at roof level. The proposed palette of the materials being proposed would be sympathetic to the existing buildings in the area and as such would not impact on the character and appearance of the South Bank Conservation Area.

8.12 Building 2:

This office accommodation would be accessed from York Road. The proposed facades of the building would have a glass treatment. The design and access statement states “high quality glass, metal panels and detailing creates an elegant envelope that enhance the building form”. The application proposes a series of winter gardens and a roof terrace at floor 16. The overall height would continue to increase, stepping up from building 1. Building 2 would be a glass structure and would be a continuation in the overall height of the building on the site. The proposed height is supported

in this location given the designation of the development on the site within the Waterloo OAPF. Furthermore, the applicant has used a high quality architectural firm to design this building, which is sleek in design and would be glassy in appearance. The proposed appearance would make a positive contrast to the remaining buildings on the site and given the proposed glassy design of the north building of Elizabeth House (members have granted resolution for planning permission), building 2 would make a positive contribution and this is supported by officers.

8.13 Building 3:

This building occupies the northeast corner with the Shell Centre masterplan. The ground floor of the building would incorporate an upgraded ticket office and entrance lobby to the existing London Underground Station from York Road. The ground floor area would also accommodate two retail units, a retail service core and three residential cores. The application proposes above ground floor level, three residential tenures, affordable rent (Extra Care), intermediate rent and private tenure from the 1 st to the 28 th floor.

8.14 The proposed building would have a stone precast appearance. Strong vertical piers are integrated into the building. There would be a series of ‘pop out bay windows and winter gardens’ along with a series of flush balconies. The proposed height of the development would increase further. The proposed elevational treatment would be installed with a series of projecting bays, adding visual interest, which would be utilised as winter gardens for the proposed residential units. The proposed stone precast appearance would provide a visual presence from the materials in existence within the South Bank Conservation. Again the high quality detailing, materials and appearance is supported by officers and would provide an invaluable addition to the existing site.

8.15 The application proposes an option to retain the high-level footbridge, subject to the determination of the Elizabeth House scheme. However, if the footbridge remains, the applicant has states the stairs into the site would be reconfigured at the western end to run parallel with building 3, with the installation of a new passenger lift and high-level balustrades.

8.16 Buildings 4A and 4B:

The proposed buildings 4A and 4B occupy the northern part of the proposed masterplan for the site. The two buildings would provide outside amenity space through balconies and winter gardens. The proposed appearance of the two buildings would provide a rigid structure, with the installation of rigid frames. The horizontal spandrels divide the frame into four floors per group, which assist in breaking down the scale of the towers. The proposed materials used would be drawn from the neighbouring existing buildings such as the Shell Tower and the Royal Festival Hall. The expressed framed would be reconstituted stone, whereas the cladding infill bays would be a combination of anodised bronze panels and frames with clear glass panels.

8.17 Building 4A would be the tallest building on the site, whilst building 4B would step down towards building 5. The overall bulk, height and massing of the buildings given the recent resolution to grant the Elizabeth House scheme, which proposed a 29-storey tower, the height of building 4A within the proposed location is supported by officers. Furthermore, the stepping down of the building 4B towards building 5, enables the development to take into consideration the overall bulk and massing on the site as well as the existing buildings along the South Bank. The proposed materials being proposed of Portland stone would integrate the development further within this location and the wider South Bank Conservation Area.

8.18 Building 5:

The proposed building would be located on the north western corner of the site, parallel with Belvedere Road to the west. The proposed appearance of the building would have a ‘carved’ nature. There would a solid stone material proposed throughout the elevation. The proposed materials are in response to the materials in existence along the South Bank.

8.19 This building would be lower in height to buildings 4A and 4B taking into consideration the bulk, height and massing of buildings along the South Bank which face onto the River Thames. The proposed ‘stone effect’ building has taken into consideration the palette of materials on the South Bank and the wider South Bank Conservation Area. This is supported by officers.

8.20 Buildin gs 6 and 7:

These two buildings are situated towards the south western corner of the master plan site. The ground floor element of the building would be clad in a palette of pre-cast stone and bronze materials, which would relate the existing buildings on the South Bank, such as the Shell Tower and Royal Festival Hall. The base of the buildings is defined by a double storey expression of the stone frames to provide a civic scale which characterises the stone buildings on the River Thames. The upper floors would be expressed with large glazed areas, with minimal frames. There would be stoned framing throughout the building as well on the upper floors.

8.21 These two buildings would be shortest buildings on the site, given the presence of the existing height of development at County Hall North Block. The proposed materials would further promote and enhance the materials being used in the locality and this is supported by officers.

8.22 Summary of buildings:

The scheme is of a high quality. Although designed as part of a larger masterplan that has taken into consideration the proposals for Elizabeth House, the individual scheme architects have been given the scope within the overall masterplan discipline to produce buildings of distinct character, tha t reflect their uses and add a richness and texture to the overall scheme. As a composition, the buildings sit well with the Shell Tower, which

maintains its primacy in the group when viewed across the river. The buildings on the immediate river frontage are lower than the Shell building, and whilst the residential buildings behind it are as tall or taller, in perspective views they do not dominate or compete with the Shell Tower. The majority of the new buildings have a grid structure expressed in a stone that echoes the treatment of the original Shell Centre and the buildings on the South Bank. The grid treatment gives the group a unity, whilst the variations in the way the grid is expressed on the individual blocks avoids this becoming monotonous or overbearing.

8.29 Full Planning Application – Link Bridges between Shell Tower and proposed Building 1 (12/04699/FUL)

8.30 A further full planning application has been submitted for external alterations to the retained Shell Centre Tower, which would facilitate the integration of the building within the development.

8.31 This application would involve the re-cladding of the exposed facades following the demolition of the attached wings to the tower. This would be made good to match existing appearance of the building.

8.32 The applicant has stated as the existing tower would be occupied by Shell, but would also inhabit the proposed Building 1, it necessary to have more than one physical link to allow the company to work efficiently within the two buildings. New links would be created at the 4 th and 10 th floors of the Shell Tower, which would link into Building 1. These links would be lightweight and glassy in appearance. Steel sidewall truss structures will be used to support the bridge roof and floor level framing to existing beams and connections at the Shell Tower end of the bridges.

8.33 The proposed bridges would 15m between building 1 and the existing Shell Tower. The proposed link structures would be lightweight in appearance and given the extent of development on the site, the introduction of link bridges between these two buildings would not be detrimental to the visual appearance of the two buildings. Furthermore, given the functionality and rational for the link bridges, no objectio n is raised to the proposed structures. Conditions have been imposed relating to the materials and proposed attachment details to the Shell Tower.

Heritage matters 8.34 National policy within the NPPF sets out the criteria by which development that affects heritage assets must be judged. Heritage assets are ‘buildings, monuments, sites, places, areas or landscapes identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest’. They include designated heritage assets, being a World Heritage site, listed building or Conservation Area as well as assets identified by local authorities (including locally listed buildings). Authorities are reminded to take account of:

• the desirability of sustaining and enhancing the significance of heritage

assets and putting them to viable uses consistent with their conservation; • the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and • the desirability of new development making a positive contribution to local character and distinctiveness.

8.35 Great weight is to be given to the conservation of a designated heritage asset. ‘The more important the asset, the greater the weight should be’. Significance can be harmed or loss not just from alteration or destruction of the asset, but from development within its setting. Where proposed development leads to substantial harm to or total loss of significance of a designated heritage asset, planning authorities are encouraged to refuse consent unless it can be demonstrated that the substantial harm or loss is necessary to achieve the substantial public benefits that outweighs that harm or loss, or where all of the following apply:

• the nature of the heritage asset prevents all reasonable uses of the site; and • no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation; and • conservation by grant-funding or some form of charitable or public ownership is demonstrably not possible; and • the harm or loss is outweighed by the benefit of bringing the site back into.

8.36 Where development leads to less than substantial harm, the harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.

8.37 Shell Tower (Existing)

The Shell Centre Tower, which is part of the locally listed Shell complex, would remain as part of the development. The only changes being made to the Shell Tower related to the resurfacing of the exposed walls, following demolition of the wing building. Furthermore, there would be a series of link bridges attached from the proposed building 1 to the tower at varying heights. The applicant has submitted a further planning application, taking into consideration these minor changes. Officers consider these changes to be minor to the external appearance of the building and no would result in no harm to this non-designated heritage asset. Instead, the development would secure its occupation by its intended end user and retain its prominence on the South Bank.

8.38 Conservation Area Consent – Demolition of Lower Wing Buildings (12/04702/CON)

The proposed conservation area consent involves the demolition of part of the structures at the existing Shell Centre, including the Hungerford, York and Chicheley wings, removal of upper level pedestrian link and bridge through the Shell Centre and across Belvedere Road, and the removal of the raised podium deck and associated structures. This involves the

demolition of the built elements on the site and other the Tower, which is excluded from the planning application and conservation area consent applications.

8.39 The test here is whether or not the existing structures make a positive contribution to the existing South Bank Conservation Area. The English Heritage document ‘Understanding Place: Conservation Area Designation, Appraisal and Management’ (2011), suggests a number of questions to assess the value of an unlisted building to the significance of a conservation area. This document considers certain characteristics that could provide the basis for considering if a building may make a positive contribution to the special interest of a conservation area i.e. significance, subject to consideration of whether or not these values have been compromised.

8.40 The applicant has concluded that the proposed demolition of the lower wing of the up-stream parts is of little architectural merit, and does not contribute positively to the townscape or character of the surrounding area. Notwithstanding, the existing development as a whole is considered to make a positive contribution to the Conservation Area.

8.41 Officers have assessed the proposed rational for the demolition of the lower wings within the heritage statement. It is considered that the loss of the podium, perimeter block and courtyard would result in harm to the historic interest, however this would not be substantial harm. Consequently, the tests as to whether this harm is acceptable is to be weighed against the public benefits the development would deliver such as the uplift in employment floorspace, retail uses, housing, improved permeability and accessibility through the site from the station towards the South Bank. In this instance the proposed loss of the historic fabric of the site would be acceptable where the weight of the cumulated public benefits that are presented in more detail within the body of this report far outweigh this impact.

8.42 Listed Building Consent (12/04701/LB)

A bronze fountain/ sculpture (c1959-63) by Franta Belsky currently occupies a portion of land in the courtyard of the Upstream block, which is Grade II Listed. Consent has been previously granted to move the sculpture to a less suitable location off the footway by the vehicular entrance to the main site at York Road.

8.43 Officers have advised that the relocation of the fountain should be found in a place where it would be able to be re-commissioned as a water feature and thus enjoyed in the original manner imagined by the artist when the piece was created. The listed building application proposes the piece to be placed in the public space between buildings 4a and 5. This location is off-set to the north side of the main square but adjoining the new pedestrian route which skirts the railway viaduct. In this respect the piece would be highly visible and thus would contribute to the qualit y of the public realm. Conditions are recommended to deal with the temporary storage and eventual redisplay, including the materials of the basin, pool and water

supply. These are set out within the recommendation for this associated Listed Building application.

8.44 Impact on Conservation Areas

8.45 The proposed development is located within the South Bank Conservation Area and has a role in the setting of both the Waterloo and Roupell Street Conservation Areas.

8.46 South Bank Conservation Area

The Conservation Area has an associated character statement complied by the authority. Within it, it is stated that:

“The demolition and redevelopment of features that do not make a positive contribution to the character or appearance of the conservation area is welcome. There is a presumption in favor of retaining buildings and features that make a positive contribution to the area ” (para 3.17) and

“New buildings, where appropriate, should be of high architectural quality, preserve or enhance the established character and appearance of the conservation area, and respect the setting of listed buildings” (para 3.18) .

8.47 The proposed Master Plan for the Site will integrate the Site more effectively with its surroundings knitting the sit into the wider urban grain in Waterloo and thereby contributing to the popularity and intensity of use seen along the riverside. In order to achieve this from a public realm and ground plane perspective the development would:

• Create new areas of public realm with a distinctive sense of place; • Enhance connectivity between the SBCA and Waterloo Station and York Road; and • Generate activity that is complementary to the cultural and leisure uses along the river front.

8.48 Facing the river, the proposed buildings between 14 and 21 storeys tall, ensure the Shell Centre Tower remains the dominant element in these views giving a richness to the townscape between old and new architecture. The new buildings on Belvedere Road continue the building line of the Shell Centre Tower and provide a built edge and enhanced sense of enclosure to the road. They address Jubilee Gardens and the River Thames positively. The area as a whole will benefit from additional passive surveillance from the new residential accommodation. The provision of a built edge to the north side of Chicheley Street would similarly enhance the sense of enclosure along this road. Overall, the development would enhance the character and appearance of the South Bank Conservation Area.

8.49 Waterloo Conservation Area:

Within the Waterloo Conservation Area the development would be visible in townscape views along Stamford Street. The proposed residential towers

would rise up above the listed terraces. However, when viewed in combination with the development at Elizabeth House, it is considered that a neutral impact would be generated upon the Conservation Area. Giving consideration to the designation of Waterloo as an opportunity area, officers are of the view that development of this scale and nature would be acceptable at the proposed height, scale, bulk and design without resulting in harm to the Conservation Area The development would assist to terminate views along Stamford Street towards the end of street, done so by the corner of building 4B that would be visible, and giving definition to the boundaries at the junction of the various Conservation Areas.

8.50 Roupell Street Conservation Area: The proposed development would potentially impact on three main streets within the Conservation Area which are Roupell Street, Whittlesey Street and Theed Street. These can all be considered in combination with the Elizabeth House scheme, which would predominately mask the Shell development. Yet, it would not ‘hide’ views of the proposed development from the CA in its entirety. Building 4A would be seen, but its slender form would contribute a neutral impact on this conservation area. Of course, given the low-rise domestic scale that predominates in this Conservation Area, any development which responds to the policy aspirations for tall buildings at the application site would result in some visibility within the Conservation area. Yet, the buildings that, in addition to 4a should Elizabeth House not come forward, between the dense urban development befitting to the CAZs strategic role within London acting as the backdrop to more local, typical residential neighbourhoods in London. Such townscape juxtapositions are found elsewhere in the City without and offer interest to the skyline.

8.51 Impact on Listed Buildings:

The proposed development would be in the setting of several listed buildings which are located along the South Bank. UDP Policy 40 protects the backdrops, settings, and important views of buildings and conservation areas. Furthermore, policy 45 states that Development which adversely affects the setting of a listed building, or significant views of a listed building, will be refused. The setting of a heritage asset (introduced above) is defined by national policy as the ‘ surroundings in which a heritage asset is experienced ’. Its extent is not fixed and may change as the asset and its surrounding evolve. Furthermore elements of the setting may make a positive or negative contribution to the significance of an asset. In respect of listed buildings that are designated heritage assets which require consideration against national policy given the proposed development, these include the Royal National Theatre, Royal Festival Hall, County Hall, Victory Arch, Church of St John with All Saints and Waterloo Bridge. Each are considered in turn:

8.52 Royal National Theatre (RNT) and Royal Festival Hall (RFH):

The proposed development sits comfortably with the mid 20th century aspirations for the redevelopment of this former industrial backwater. The

replacement of the monotonous wings of the Shell Building with more distinctive buildings, of a high quality of architecture would not harm the significance of the RFH, but rather would place it within a lively and evolving townscape symbolic of present aspirations for the regeneration of the wider Waterloo area. Officers consider within these views the development would because of the orientation, distances and contrasting form of the listed buildings in relation to the proposal, would result in no harm to their setting is are compliant with policy aspirations

8.53 County Hall (CH):

The Proposed Development, set back behind Jubilee Gardens, will not impact on CH’s ‘premier’ position closer to the water’s edge. CH will maintain a presence evocative of its former civic use (now housed in the modern City Hall building further east along the river) which remains evident in its grand riverfront elevation. When visible in views of CH, the Proposed Development will be seen in conjunction with the existing Shell Centre Tower and to the east of the London Eye. The roofline of County Hall would be interrupted in oblique views but these are only really experienced in a kinetic manner while crossing Waterloo Bridge from west to east and again there would be sufficient distance between the two forms. The Albert Embankment would not be harmed. Furthermore, there would be no impact on the former General Lying In Hospital, York Road or on St John’s Church, Waterloo Road. Consequently, the proposed development is not considered to result in harm to the setting of the Listed Building.

8.54 Victory Arch, Waterloo Station

The Grade II Listed Victory Arch which is currently shielded by the existing Elizabeth House building would face the development on the opposite side of York Road. Given, the recent resolution to grant planning permission for the redevelopment of Elizabeth House which canter lever over the arch, officers considered the proposed Shell Centre development would be seen as an addition to the evolving urban landscape in this location and not harm any element of the setting that contributes to the significance of this listed building.

8.55 Church of St John with All Saints

The church is located on a busy road and close to large scale 19th and early 20th century development. As a result it does not command a dominant presence in the townscape by virtue of its size (particularly in views from the south and west) but rather draws attention to itself by its detailed design and its churchyard setting. The proposed development would be seen as an addition to the evolving urban landscape in this location and not harm any element of setting that contributes to the significance of this listed building.

8.56 Waterloo Bridge:

In the views from Waterloo Bridge the introduction of three slender and distinct elements beyond the roof form of the RFH (albeit taller than the

existing building here), rather than a single large form, will provide a backdrop of high quality. High quality new development visible behind the RFH would not lessen the importance of its waterside location, or the contribution of this to its significance. The development would build upon the urban layers of the city as viewed kinetically along Waterloo Bridge, and as such no harm to the setting to the Bridge is considered to result.

8.57 Overall, the development is not considered to result in any undue harm to the setting of Listed Buildings in the vicinity of the site and would add to the varied townscape and history of London’s cityscape.

World Heritage Sites

8.58 World Heritage Sites are recognised to be at the top end of the spectrum in terms of ‘asset’ importance’.

8.59 The NPPF states that local planning authorities should look for opportunities for new development within Conservation Areas and World Heritage Sites and within the setting of heritage assets to enhance or better reveal their significance. Paragraph 137 goes on to say ‘ Proposals that preserve those elements of the setting that make a positive contribution to or better reveal the significance of the asset should be treated favourably’, recognising that not all elements of a World Heritage Site (or Conservation area) will contribute to its significance.

8.60 The development is located near to the South Bank, which is an important component within the setting of the World Heritage site. It is approximately 800m away from the WH site. The protection of the site is governed by English Heritage on behalf of UNESCO. Notwithstanding, its significance is recognised at both a local and regional level. Policy S9 of the Core Strategy states that the Council will improve and maintain the quality of the built environment by interalia, ‘Protecting Strategic Views, including those that affect the outstanding universal value (OUV) and setting of the Westminster World Heritage Site. The London Plan anticipates development to not cause an adverse impact on World Heritage Sites or their setting (including any buffer zone). In particular, it should not compromise a viewer’s ability to appreciate it Outstanding Universal Value (OUV). In accordance with the GLA’s ‘London Heritage Sites – Guidance of settings SPPG (2012), the applicant has demonstrated a clear understanding of the OUV of Westminster World Heritage Site (WWHS), assessed the contribution of the setting of the WWHS to its OUV and assessed the proposals impact on the WWHS and its OUV.

8.61 The applicant has assessed the application in accordance with the strategic views set out in the London Viewing Management Framework (LVMF). The ‘London View Management Framework Revised Supplementary Planning Guidance’ (‘LVMF’) is designed to provide further clarity and guidance on the London Plan’s policies for the management of these views. LVMF views affected by the Proposed Development are considered as part of the submitted ‘Townscape and Visual Impact Assessment’ (TVIA). The LVMF SPG identifies London panoramas, linear views, river prospects and

townscape views, with 27 views in total. The proposed development would not be located in any Protected Vistas as identified within the LVMF SPG, but would be visible within some London Panoramas, river prospects and townscape views such as: Alexandra Palace, Parliament Hill, Primrose Hill, Serpentine, St James Park, Lambeth Bridge, Parliament Square, Westminster Bridge, Westminster Pier, Victoria Embankment, Hungerford Footbridge, Embankment Gardens, Waterloo Bridge, Southwark Bridge and Blackfriars Bridge.

8.62 In terms of the panoramas, officers consider that development minor impact within these views as it is seen as part of the developing cluster of taller buildings in the Waterloo Opportunity Area. The strategic views in which the proposal is likely to have the most impact are from St James Park (26) and in respect of the World Heritage Site, Parliament Square (27A.1 and 27A.1). The applicant has submitted a TVIA for the development, taking into account these two strategic views.

Parliament Square

8.63 There are two link assessment point views 27A.1 and 27A.2 located on the pedestrian island in the south-west corner of the square between the UK Supreme Court and Westminster Abbey. From this location the northern parts of the Palace of Westminster are seen clearly in context with St Margret’s Church and Westminster Abbey. Within these two views the proposal would comply with the visual guidance in that the development would be set away from the Houses of Parliament next to Portcullis House. This would allow sufficient sky to be maintained around the Clock Tower to preserve the OUV of the World Heritage Site. It should be noted that a very small part of the proposed roof to building 1 would appear within this view towards the right hand side of Portcullis House. However, this is considered to result in a neutral impact to the WHS and would maintain the OUV without detriment to its setting. Indeed, English Heritage note that its present, but raise no specific objection in this respect. It is noted that Westminster’s City Council object, but that the comparative ‘peak’ of proposed development in views from the Square should be considered alongside the recent decision by the Secretary of State at Elizabeth House where no harm was considered to result.

St James Park

8.64 The second strategic view where the proposed development would appear is St James Park (26A within the LVMF SPG). The viewing location is on the east side of the footbridge across the lake. The view derives its particular character from the high quality landscaped setting of St James’s Park. The foreground and middle ground are dominated by the lake and surrounding mature parkland. The LVMF SPG states that no development is expected in the foreground. The middle ground landscape needs to be managed to maintain its dominance in the view. Indeed, “ the juxtaposition of the landscaped elements in the foreground and middle ground, and the two groups of important civic buildings, including Horse Guards and Whitehall Court to the left, and the Foreign and Commonwealth Office, as well as the

London Eye and the Shell Centre to the right, enable the viewer to appreciate that this is an historic parkland in an important city location ” and as a consequence development in the back ground of this view should not dominate, overpower or compete with either of the existing two groups of built form or landscape elements between and either side of them.

8.65 The existing Shell Centre Tower appears behind the tower of the Foreign and Commonwealth Office (FCO), on both sides of the latter: to the left it is less than half the apparent height of the FCO tower; and to the right it is below the bold decorative relief and cornice to the FCO tower’s parapet. It is seen within the circumference of the London Eye. The proposed towers of buildings 4A and 4B would be seen to the left of the FCO tower, however framed by the London Eye and with The Shard to the right. The proposed buildings appear as part of the existing group of buildings to the right of Duck Island, and as noted by the applicant, do not dominate or compete with existing buildings. The stone framework and distance between the buildings helps to differentiate them. This at the most can only be considered to have a minor adverse impact. However, given the number of buildings which have come forward within this view and are in the pipeline, the sympathetic presence of this building would be supported by officers. English Heritage has objected to the presence of these towers within these views, this is discussed further below.

8.66 Response to English Heritage Comments

8.67 English Heritage have raised objection to the proposed development which have been summarised under section 5 above.

8.68 The applicant has carried out a detailed assessment of the St James’s Park view within the TVIA. English Heritage within their comments state that the scale, mass and form of the proposed development significantly detracts rather than adds to the picturesque qualities of this strategic view should not be allowed. Furthermore, it should not compete with the tower of the FCO. The LVMF guidance states that development in the background of this view should be of a scale, mass and form that does not dominate, overpower or compete with either of the existing two groups of built form or the landscape elements between and either side of them. However the guidance does not state that there should be no development in the background behind the silhouette of the buildings seen in this view – it clearly envisages the possibility of such development being acceptable.

8.69 The inclusion of the upper floor on buildings 4A and 4B of the proposed development in this view would not remove the picturesque qualities, would simply add another layer of interest and enhance the awareness of the wider city which is currently evolving, which can be appreciated from the St James Park view. It would not affect the viewers ability to appreciate that this historic parkland is an important city location. The arrangement of the built form on the site of the proposed development and the stepping up in height to the north-east is a logical response to the main sites constraints, not least views from the WHHS. The proposed development would not result in any single building commanding a focus, but would add a further architectural

layer within the London skyline. The upper parts are seen in conjunction with the FCO building, framed by the London Eye, and the Shard to the right. They would appear as part of this existing group of buildings to the right of Duck Island and would not dominate or compete with existing buildings.

8.70 It should be noted also the GLA who are the authors of the LVMF have raised no concerns in respect of view 26A. They state the development has been designed to ensure it minimises LVMF impact on St James’s Park views. The views analysis demonstrates that the Shell Centre Tower retains its prominence and that the proposed architecture contributes positively to the skyline, as a development in itself and when combined with the Elizabeth House proposal.

8.71 Reservations have been raised by English Heritage towards the impact of the proposals on the setting of Horse Guards from the Guards Memorial and the setting of the Elizabeth Tower in views from Parliament Square. The visibility of a small layer of the development proposal would an additional layer of history for this view, the background and skyline of which include noticeable 20 th Century elements, notably the London Eye.

8.72 Officers acknowledge that the development would still be viewed in some views from Parliament Square, but this would only be present when you move away from the fixed point of view that requires consideration under the LVMF. Indeed, it should be noted that views of the towers as you move through this gap would become more oblique, reducing the visual prominence of the clock faces on Big Ben and is representative of the transient way townscape is both ‘read’ and ‘explored’. You would have to actively move through the gap to ‘discover’ the singular point where and when Big Ben appears at its least articulate. The appearance of the two tallest towers would not (and is not) appreciated statically. Indeed, predominately the viewers eye would be drawn towards the upper part of the tower, and its Clock Face. In terms of competition, it is indeed shown in the submitted views that as the other landmark site in the immediate area, the London Eye would be the only other point of intrigue in these views to distract from Big Ben itself.

8.73 English Heritage have acknowledged that there are public benefits associated with the development, however, they consider that these do not outweigh the harm to the historic environment. Officers take a different view in the assessment of the development as a whole. The proposal would help to deliver a range of public benefits, including significantly contributing to the regeneration of the Waterloo Opportunity Area, which would facilitate and improve permeability and functioning of the area. Whilst is acknowledged that the applicant could proceed with the extant planning permission relating to the Belvedere Road scheme, it is considered that the scheme would not provide the improved accessibility/ permeability from York Road towards the South Bank; considerable uplift in housing in the area which would add to the existing housing stock, which is of strategic importance for Lambeth; provision of both onsite and offsite affordable housing; increase in employment generating floorspace; increase and improved public realm

provision; retail provision on the site. Whilst the majority of these impacts would be felt within the immediate Waterloo area, the benefits that the scheme brings in terms of contributing to London’s World City role, with a landmark building and public realm that improves links to cultural areas of the South Bank also help to improve and enhance the setting of the World Heritage Site as well. Having regard to the above and weighing these against the less than substantial harm, the substantial public benefits of the proposal would help to deliver and enhance the setting of the World Heritage Site and far outweigh this harm.

8.74 It is accepted by officers that the proposed scheme would have an impact within the local area of Waterloo and some strategic views which have been assessed within the report. However, the aspirations of the site and the certainty of deliverability will give impetus to the regeneration of the wider area and secure the Opportunity Areas role within the CAZ for which it currently under achieves on its potential

8.75 Public Realm

Overview:

The detailed design of the public realm works have been addressed within the proposals section. The redevelopment of this site provides significant opportunities to resolve some key public realm issues that existing in Waterloo, which suffers a lack of permeability and legibility. The proposed Elizabeth House scheme would see the removal of the existing elevated public walkway that runs across York Road, through the site, thereby bringing pedestrians from Waterloo Station to ground level as quickly as possible and providing step free access, which is otherwise absent. The Shell proposals have been designed to incorporate these changes on the application side of the road, which is strongly supported by the GLA. The scheme also considers an alternative scenario, should the walkway not be removed and drawing are provided for this showing the footbridge remaining, thereby enabling the development to proceed in either of the two scenarios. This is logical and the alternative plans are acceptable, noting the inclusion of a lift within the alternative, which is otherwise absent at present.

8.76 The current site creates a barrier of movement between the station and the river, and the applicant has sought to provide legible routes through the site, responding to desire lines and linking with the Elizabeth House proposals. In relation to crossings at York Road, the position of the southern crossing is still fixed, and continued dialogue would be expected as both this and the Elizabeth House scheme progress. Key to this is maintaining the desire lines from the new opening between the proposed new Elizabeth House buildings, which would provide a direct and step-free link from Waterloo Station, to the South Bank and beyond.

8.77 The applicant’s aspirations for Chicheley Street and Belvedere Road in terms of providing shared surfaces and resolving the current issues regarding servicing and coach parking are welcomed by officers. The layout

proposed would mean that Chicheley Street would become an important route from the station via the proposed Elizabeth House scheme towards the South Bank. The detailed design of this route will be expected to address the fact that a range of users, including TfL buses, Duck Tours, coaches, servicing vehicles and pedestrians will be sharing this space. The applicant are proposing significant Section 106 contributions for the delivery of these shared areas, which have been addressed within the heads of terms.

8.78 The applicant notes the desire to turn the Shell Centre around so that it has a frontage on to the newly re-designed Jubilee Gardens. This is welcomed.

8.79 The new route along the southern edge of the railway viaduct is welcomed in terms of providing links to the South Bank and views and links to the river and Charing Cross Station beyond from the newly created Victory Arch Square. The intention to open up the arches so that there is dual frontage to the space and to Concert Hall Approach is welcomed. Arrangements with respect to servicing and deliveries would need to be clarified so as to ensure that neither this nor Concert Hall Approach revert to a service lane.

8.80 Spaces between buildings:

In terms of the building layouts and spaces between buildings, the proposed masterplan shows a range of public and semi-private spaces and routes through the site. The spaces between the buildings are reasonably tight, and with 877 residential units a commensurate amount of commercial space, as visitors to the South Bank from Waterloo Station, there would be intensive use of these spaces. The spaces within the masterplan have all been carefully considered in terms of the uses that open onto them, the way people move through them, and the way the landscaping defines them, and crucially their fit and interface with Jubilee Gardens and the South Bank, with nowhere in the site far from the open aspect to and across the River Thames. Overall the routes through the buildings, and the scale, layout and function of the spaces have been well considered and would deliver a step change in the quality of the public realm in this key strategic location.

8.81 Character of Public Square:

The proposed public square is located at the heart of the masterplan and has a series of open pedestrian routes that feed into it from the north, south, east and west. It is framed by a mix of residential and office buildings with active retail uses at the ground floor this area would create a lively environment which will entice the public into the space to either enjoy the activities and entertainment that will be provided there or to pass through on the way to their final destination.

8.82 The square is designed to provide an alternative and complimentary space to local facilities that the South Bank has to offer including bars and restaurants, parks, the promenade along the river, the London Eye and the South Bank Centre. The cafes, restaurant and bars that are proposed at the ground floor of the buildings around the square will spill out into the square

in the form of outside seating which will create a vibrant place to relax.

8.83 The square would be populated by carefully selected soft landscaping including planters and trees, public art features, seating, fountains and occasional cultural entertainment events which all add to the pleasant experience of the space. The proposed use of light coloured paving and the combination of glass and light coloured materials on the buildings around the square, combined with the open nature of the pedestrian routes that feed into the square ensures that it receives adequate light and as such a comfortable climate to spend time in.

8.84 Movements through the Public Square:

The public square is a highly permeable space and would accommodate the pedestrian footfall from Waterloo Station through to the London Eye, Westminster Bridge, Hungerford Bridge and Jubilee Gardens. The square is reinforced by the views into and through the space from York Road, which have been carefully planned to reinforce a sense of permeability, yet offer sufficient enclosure to define it as a square in its own right. Consequently there are clear views into and out of the space from all sides, to the south and Chicheley Street, to the west and Jubilee Gardens, to the north over the viaduct and towards the White House beyond, and back towards Waterloo Station.

8.85 Materials:

The proposed materials would contribute to a high quality space. There is a simple and limited palette of complimentary materials to be implemented with simple coordinated details. The aim is to create a cohesive, coordinated palette of hard landscaped materials which are durable and easy to maintain. There is an emphasis on natural materials, such as York stone and granite within the public square and surrounding streets and stone setts used on trafficked drop off areas and crossings, to create a pleasant pedestrian environment. Coloured asphalt is proposed on the surrounding carriageways such as Belvedere Road and Chicheley. The detailed design of the materials have been secured via conditions. However, officers support the principle of the materials being used within the development.

8.86 The public square is proposed to be paved with an intricate high quality paving ‘carpet’ that is exclusive from the rest of the public realm paving palette. The square will include a defined paving frame around the edge of the square for the retail units to spill out onto, with a central high quality paving grid. The paving will be developed based on the following principles:

• Visually interesting ‘carpet’ that gives a high quality presence and is exclusive from the rest of the public realm paving palette

• Defined paving frame around the edge of the Public Square for the retail units to spill out onto

• Opportunity to involve an artist to make reference to the history of the

Site, including the Festival of Britain

8.87 Street Furniture and Lighting:

The proposed development would provide bin facilities, cycle stands and signage within the proposed development. The palette would be expanded to include a number of complimentary and bespoke items which would fit in with the design and would be coordinated with the art strategy. The security elements would also be treated as street furniture within the development. A comfortable level of light would ensure that the Shell Centre is safe and welcoming for visitors, residence and commuters. These would be provided by incorporating lights in trees and installing large up lighting.

8.88 Response to CABE

CABE have acknowledged that given the density of the development and the large number of people crossing the site on their way from Waterloo Station to the South Bank Centre and the river, the scheme requires a clear public space strategy to offer relief. The applicant has revised the scheme by repositioning the planting and benches within the square and throughout the site to more suitable locations which would provide a more accessible route for pedestrian through the development towards the South Bank.

8.89 Concerns were raised towards the bottle neck situation between the railway arches and building 4A, which would create an extremely narrow passageway and as a result the colonnades should move away from the railway structure, which currently obstructs the route to the South Bank. This would facilitate a larger number of pedestrians to accommodate this area. The submitted pedestrian data has been reviewed and it is considered that adequate space would be provided, to allow pedestrians to pass through this area. Furthermore, it is an aspiration of the applicant to remove the spur within this area, which would improve the environment further.

8.90 It was suggested that the pavement along York Road could perhaps cause problems in terms of the large number of office workers accessing building 1. As a result the buildings along York Road could benefit from more animated frontages to create a pleasant pedestrian experience along this busy road. Given the potential redevelopment of adjacent site and the removal of the pedestrian bridge from Waterloo Station, the proposal has to be flexible enough to respond to different scenarios and changing parameters. The area in front of building 4A needs to provide a successful public space that is both able to work on its own and conjunction with Victory Square as part of Elizabeth House. Again the applicant has submitted adequate data which has been assessed and as a result the extra flow of pedestrians/ workers would not give rise nor impact on the usability of York Road.

8.91 It was raised that there should be a better relationship between the Shell Tower and the proposed buildings on the site. The proposed buildings would provide a scheme which would integrate the Shell tower on the site and as result this would not impact on the identity of this building. The

design cues could be taken from the existing buildings and the limited pallet of materials across the site is accomplished elevational treatments. This would depend on the high quality materials and detailing. To preserve this quality throughout construction the same design teams should be used. Officers have requested that the architects are retained throughout the construction and delivery stages of the application. This has been secured through the Section 106 Agreement.

8.92 A project of this scale in single ownership has the potential to become exemplar in terms of sustainability and environmental strategies and we do not think that the scheme has yet achieved this. The design team should consider in more detail the climate change and adaption in terms of the building orientation and shading and the number of single aspect flats which could be reduced. Overall the development would exceed sustainability standards as set out in the London Plan, and whilst it is acknowledged that some of the flats are single aspect, it is unavoidable given the urban location of the development.

9 Residential Amenity

Potential impact on the amenity of residents

9.1 This is mainly dealt within sections 10.2 to 10.6 below given the nature of development and necessary Environmental Assessment. Notwithstanding, the following matters are considered in turn:

Sunlight/Daylight

The impact of development in this regard is considered in detail below under the Environmental Assessment section including details and response to the comments received from adjoining residents

Overlooking/Loss of Pr ivacy/sense of enclosure

9.2 Overlooking – Privacy:

The nearest residential properties to the proposed development would be County Hall North Block and Whitehouse Apartments. The existing County Hall North Block would be impacted the most by Building 1 (office) and 7 (residential). Building 1 would be positioned approximately 25m in distance. This building would be stepped, starting at its lowest point of 5-storeys rising up to 12 storeys. It is considered that there would be some perceived overlooking between the proposed office accommodation and existing residential units of this building. However, the distance exceeds the Councils standards of residential to non-residential gaps between buildings.

9.3 Building 7 would be erected at a distance of 25m from the North Block, County Hall. Given the urban central location of the development and given the built up environment of the area, the proposed distance is considered to be generous. Officers consider on this basis that the scheme would not give rise to direct overlooking and loss of privacy to this existing residential

building, nor would prospective residents experience unacceptable overlooking. .

9.4 Whitehouse apartments would be most affected by buildings 4A and 4B, though the buildings here would be at distance of between approximately 50- 55m. This is far in excess of standard gaps between urban streets, where the proposed pedestrian route to the north boundary, railway viaduct and Concert Hall Approach accommodates this spatial gap. Given the urban location of the area, more than sufficient distance between existing and proposed buildings, and no harm is envisaged.

9.5 Proposed Development at Elizabeth House:

Both buildings 3 and 4A would be the nearest proposed residential buildings to the recent Elizabeth House scheme which granted resolution for permission by members. However, the proposed distance between the sites would be between 25m to 30m in distance. Officers consider that this distance would be sufficient given the urban location of the development.

9.6 Sense of Enclosure:

The County Hall North Block would be most affected by the proposed Shell Centre development. Buildings 1 and 7 would be erected at a distance of 25m. It should be acknowledged that the Belvedere scheme which has been implemented would be erected in a similar location and was accepted at appeal. Given the urban location of the development and the extant permission, officers consider that there would be sufficient distance from this residential block. Given the regenerative benefits of the scheme, the application is considered to be acceptable further.

Environmental Impact

9.7 The applicant has submitted an Environmental Statement (ES) as part of their submission for the planning application. In accordance with the relevant regulations the ES considers a number of topics during demolition, site preparation, construction and subsequent occupation. In line with legislation and best practise requirements direct, indirect, cumulative, short, medium, long-term, permanent, temporary, beneficial and adverse effects are considered where applicable. As amendments to the application were submitted, the applicant updated the ES where applicable. The ES was compiled by URS on behalf of the applicant and independently verified by the LPA’s consultant Bowyer Planning and in turn their own appointed consultants together with officers of the Council. Some further information was provided for the purpose of clarification but no information was additional in respect of the regulations requiring reconsultation.

9.8 Daylight, Sunlight and Overshadowing

Daylight, sunlight and overshadowing assessment has been undertaken with reference to the British Research Establishment Guidelines: ‘Site Layout Planning for Daylight and Sunlight, A Guide to Good Practise’. This is widely

referenced by planning authorities nationally as a benchmark against which to assess the likely impact of development on these matters. The BRE guidance recognises the use of electric lighting within commercial property and is concerned more specifically with residential amenity appreciating the higher dependence by the latter upon natural lighting. Similarly, BRE guidance points to consideration of open space and gardens in considering Overshadowing. The guide is just that though, and it is advised in the Guide that its standards should be administered flexibly mindful of site context whereby it is a guide used for both rural and urban development where existing conditions vary. The BRE advise that it should not be mandatorily applied, it is not policy.

9.9 The daylight, and where appropriate sunlight, conditions for each surrounding property have been assessed by the applicant for the following surrounding properties which are listed below:

• The Whitehouse Apartments, Belvedere Road; • 75 York Road; • County Hall, Belvedere Road (Northern Elevation); • County Hall, Belvedere Road (Courtyard); and • County Hall, Belvedere Road (East Block);

The scope of properties is considered extensive to capture all properties where an impact could be experienced.

9.10 The BRE guidelines provide a series of tests for daylight and sunlight assessment, acknowledging that in some circumstances, such as that of a dense urban environment as found with the application site, some allowances beyond the limits may be considered reasonable. The BRE Guidelines provide two principle methods for assessing daylight to existing residential accommodation:

• The Vertical Sky Component (VSC) method; and • The No Sky Line (NSL)

9.11 VSC is a quantified measurement of the amount of skylight falling on a vertical wall or window. This is the ratio of the direct sky luminance falling on a vertical wall at the reference point for the simultaneous horizontal luminance under an unobstructed sky. The ‘standard overcast sky’ is used and the ratio is usually expressed as a percentage, for which the guideline threshold is 27%. The maximum value is almost 40% for a completely unobstructed vertical wall. But the VSC test is only a spot test, and there are other methods (such as the NSL) which demonstrate the receipt of light within a room.

9.12 The NSL method is a measure of the distribution of daylight at the 'working plane' within a room, i.e. a point 0.85m above the floor in houses. It provides an indication of daylight distribution within a room. If a significant area of the working plane lies beyond the NSL (i.e. it receives no direct sky light) then the distribution of daylight in the room would be poor and supplementary electric lighting may be required. The working plane is

plotted for main rooms, including living rooms, dining rooms and kitchens. Bedrooms are also analysed although they are considered less important in terms of the amount of daylight received. The BRE Guidelines state that if the area of a room that does receive direct sky light is reduced to less than 0.8 times its former value, then this would be noticeable to occupants

9.13 The impact of development on daylight has been assessed as follows:

The Whitehouse Apartments:

A total of 285 windows were analysed for VSC, of which 92 do not meet the BRE guidelines in the existing condition. Of these, 76 do not meet the BRE guidelines by having a loss of VSC greater than 20% of the existing value following development. Twenty of those windows would however see a 20- 29% loss, which given the inner urban context and underlying policy presumption for high rise development, is considered marginal. There are, though, 56 windows (20% of those assessed), that would see a loss greater than 40% which would lead to a noticeable loss in daylight. When considered alongside the NSL test, 155 rooms of 205, i.e. 75% of those rooms assessed, would retain BRE complaint levels of daylight. There would be 44 rooms (20%) where whilst not all their respective windows would meet with the guideline VSC levels, they would comply with the NSL test, and therefore be BRE compliant. Consequently, this leaves 6 rooms, i.e. three per cent of the 205 rooms tested, where both the VSC and NSL BRE targets would be exceeded. It is understood that these 6 rooms involve 3 kitchens and 3 bedrooms. In all instances over half the rooms would receive direct skylight when taking the NSL test into consideration, and two of the rooms have VSC levels below the VSC standard in the existing condition.

9.14 There is inevitability to be some impact generated by development on one neighbouring property to another. Whilst residential amenity is protected by policy, at the same time this is not a protection to retain the existing condition for residents, the result of which would be no development at all. Indeed, there is an expectation set out in policy for development of a scale equivalent to that proposed for which an impact will result. Overall, the impact to the Whitehouse relates principally to six rooms (all serving different floors, and not the same unit) out of the 205 assessed, an impact to 3 per cent of the surveyed rooms. Whilst the impact to those rooms would be moderate to major adverse, this needs to be considered alongside the urban context of the site, the quantum of rooms that do meet the standards and the presumption in favour of development at the site given its Opportunity Area designation within the CAZ. Consequently, the impact is considered to not be so substantial as to merit refusal of the application whereby the development will address the objectives for the site, to deliver mixed use development, improve permeability in the immediate area, generate an uplift in jobs and deliver housing units towards meeting the Boroughs housing targets.

9.15 County Hall:

The submitted ES has split the assessment of this building into three main

sections which are as follows: northern elevation, courtyard and east block. The northern elevation is directly to the south of the site on the other side of Chicheley Street. Currently the southern part of the site features very little in the way of buildings or obstruction. The BRE guide acknowledges that the urban environment may accommodate ‘unnaturally’ low rise development in otherwise central locations. In such instances the guide promotes the testing of a ‘mirror image’ of the neighbouring ‘build’ to set out a reasonable, and fair, benchmark against which the impact of development should be judged. In addition, the baseline can also be considered against the previous consent, the ‘Belvedere’ scheme.

9.16 Against the baseline, 175 windows were analysed, and of those 153 would meet the VSC target threshold in respect of a the existing ‘mirrored’ condition to the northern County Hall elevation. In the proposed condition, this would be reduced to 71 windows that meet the VSC levels under the BRE guidance. Nonetheless, of the 104 that do not, 40% just exceed the target level, with a percentile loss of between 20 and 29%. This is considered reasonable whereby the scale of development anticipated is going to result in an impact, and whereby the change in actual daylight to individual units would only just be perceptible. Twenty per cent of the assessed windows would have a greater loss, 13 windows having a loss of over 40%, 20% more than the BRE target threshold. When the NSL is taken into consideration, 78% of the rooms would meet the BRE threshold. Overall, 29 rooms would see a breach in both the threshold for the NSL and VSC. This relates to 12 living rooms and 17 bedrooms located over first, second, third, fourth and fifth floors. Ten windows serving eight of the 29 rooms do not meet the guideline VSC level in the baseline condition, for which these rooms consequently see the greatest percentage change. All but one room would receive over fifty per cent direct skylight at the working plan. Whilst this shows that there will be an impact, again this impact must be considered alongside the likelihood of an impact from development given the aspirations for the application site. As with the Whitehouse Apartments, the assessment of the proposed development illustrates that there will be an impact, but that the impact will not be felt to all residential units, and is commensurate with the scale of development required to achieve the aspirations for development anticipated by the sites Opportunity Area designation within the CAZ and reflects the inner urban context of the site.

9.17 County Hall – Court Yard:

Given the orientation of the Courtyard with the development, it is unsurprising that of the 64 windows of 54 rooms modelled, the proposed development would result in no breach to the BRE thresholds in respect of the VSC and NSL, and as such there would be a negligible impact from development in this respect.

9.18 County Hall – East Block:

Similarly to the courtyard, all windows and rooms analysed on the east block would meet the BRE guidelines for VSC and NSL and therefore the assessed impact of development in this respect is considered to be

negligible.

9.19 There is a third method of daylight assessment, the Average Daylight Factor (ADF), though used most commonly as a method for calculating daylight to proposed residential properties. The ADF assesses both the quality and distribution of light within a room served by windows/doors – it takes account of the VSC value, size and number of windows of a room, the rooms expected function and even the colour the room is painted (making it a more accessible method for proposed development). The recommended ADF value is dependent upon the use of the room in question. The BRE Guidelines suggest a bedroom should have an ADF of 1%, a living room 1.5% and an open plan living space incorporating a kitchen and standalone kitchens 2%. If a given room meets its relevant criteria, then it will be regarded as having adequate daylight.

9.20 Elizabeth House proposals:

The applicant has assessed the proposed development at Elizabeth House which was granted resolution for planning permission by members (November 2012). The dwellings here would be located in the north building at floors 14 to 28. The ADF methodology was used for assessment which is appropriate since these dwellings are not yet built. The modelling has taken into account the average reflectance of the room surfaces based on ‘fairly light-coloured rooms’. The calculations show that 197 of the modelled 206 rooms would meet the recommended ADF values. All nine that do not are combined kitchen/living/dining rooms, which although miss the recommended 2% threshold, achieve greater than the 1.5% recommended for living rooms. When considered alongside the expectations for both the Elizabeth House and Shell Centre sites situated within an Opportunity Area of the CAZ, the impact of development where the two developments would come together are considered moderate given this urban context.

Sunlight

9.21 The BRE also provides guidance thresholds for the Annual Probable Sunlight Hours (APSH) to windows, appropriate only for those windows that face within 90 degrees of due south given the path of the sun. The point at the centre of the window on the outside face should be used as the reference point. The BRE states that if the window reference point can receive more than one quarter of APSH including at least 5% of annual probable sunlight hours during winter months then the room should receive adequate sunlight. Sunlight may be adversely affected if less sunlight is received and is less than 0.8 times the former value.

9.22 Of those windows assessed as facing 90 degrees south, only those at Whitehouse Apartments are affected. Here, 215, or 85%, of the surveyed windows are compliant with the BRE thresholds. The remaining 39 of the 254 windows assessed do not comply, 20 of which are bedrooms and the remainder living rooms. Notwithstanding that Bedrooms are considered of lesser importance by the BRE, only three of these windows would not meet annual probable sunlight hours but would meet with the winter sunlight criteria. Similarly, of the living room windows, 2 would not comply with the

annual sunlight criteria, falling just short of the 25% benchmark, at 21% and 22% respectively. Of course, the sun is lower in the sky during winter months, and so in dense urban areas the likelihood of achieving the BRE guidance is more difficult than for lower urban areas. As with daylight, there is an expectation for redevelopment of the site whereby the existing condition has allowed for a standard of amenity that is not representative of being neighbour to a opportunity site within the CAZ. Indeed, when considered in combination with the Elizabeth House scheme, the number of effected windows increases by fifteen to 54. Seven of these do not meet the annual or winter annual probable sunlight hours guidelines, with the remainder missing the winter guideline target only. This cumulative impact reflects the development capacity that is sought by the Opportunity Area designation for the site and for which the impact of development would not give way to such detriment as to merit refusing the application.

Overshadowing:

9.23 The BRE guide gives guidance upon the impact of development on gardens and open space where large scale development is proposed. For such space to appear adequately sunlit throughout the year, at least half of a garden or amenity area should receive at least two hours of sunlight on 21 st March. If as a result of new development on existing garden or amenity areas, the above criteria is not met, and the area which can receive two hours of sun on 21 st March is less than 0.8 times its former value, then the loss of sunlight is likely to be noticeable. If a detailed calculation cannot be carried out, it is recommended that the centre of the area should receive at least two hours of sunlight on 21 st March.

9.24 Three groups of existing open spaces were scoped for analysis in the ES. These are the large Jubilee Gardens (two areas analysed), the rear to the Royal Festival (one area) and the Whitehouse apartments’ gardens (three areas). The results for sunlight show that at least 50% of all of these areas would receive at least 2 hours of sun on 21 st March with the proposed development in place. The impact would therefore be negligible to minor adverse and would not affect the attraction of the surrounding spaces to be used as external amenity, be it private or public. Indeed at Jubilee Gardens, there is no shadow after midday, as occurs in the existing condition.

9.25 Consideration has also been had of the proposed development, providing a public and arrival square. Whilst on the 21 st June only 43.7% of the area would receive at least 2 hours of sun, the space needs to be considered in light of its intended end use, a public square with spill out cafes together with providing access routes from Waterloo towards the South Bank. Given the likely transience of the space throughout the year, and with sun to be received in lunchtime hours throughout the summer months, the overshadowing here is not considered to be unusual for such inner urban environments. The layering of massing is supported in spite of that culminating in some shadowing of the proposed public space. Indeed, given the nature of the intended space, it is envisaged that there would be no less animation were it to exceed the guideline thresholds in the receipt of light.

Light Spillage:

9.26 Light pollution is normally an issue caused by inappropriate external lighting, for example floodlighting, illuminated signage, external amenity lighting or roadway lighting that causes unwanted light to neighbouring areas and properties or upwards into the sky. However, and as common on many developments, the external lighting strategy has not been fully defined. Consequently, this ha s not been incorporated into the assessment. Nonetheless, the principal of external light fixtures is acceptable and conditions can control the level of light seepage to a level appropriate to the residential context.

9.27 Consequently, the assessment has only included light spill from interior lighting within the proposed buildings. The assessment has concluded that there could be potential light spillage from two facades in the new development, to building 3 and building 6/7, which is predicted to be outside the guidelines, but this could be mitigated at the detailed design stage by design of interior lighting, provision of blinds and lighting controls. A condition is recommended to this effect. Furthermore, a condition has been imposed requesting a review of the applicant’s Construct Environment Management Plan to avoid light pollution at the construction and demolition stages. Overall, no adverse impact is envisaged in respect of light spillage.

Solar Glare:

9.28 The ES has considered solar glare to ten view points on roads and railway lines. The assessment in the solar glare appendix of impacts to these points, ranging from negligible to moderate adverse, is reasonable. However, the ES itself ignores the moderate adverse impacts and suggests that mitigation be limited to the areas of sun visors by drivers. The applicant should consider whether the limited areas of glazing causing the moderate adverse impacts could be fitted with low reflectance glass to reduce the glare caused by reflections. A condition has been imposed requesting that the western elevations of the development are fitted with reflecting glass, minimising impact to pedestrians and drivers from this viewpoints.

Overlooking – Privacy:

9.29 The nearest residential properties to the proposed development would be County Hall North Block and Whitehouse Apartments. The existing County Hall North Block would be impacted the most by Building 1 (office) and 7 (residential). Building 1 would be positioned approximately 25m in distance. This building would be stepped, starting at its lowest point of 5-storeys rising up to 12 storeys. It is considered that there would be some perceived overlooking between the proposed office accommodation and existing residential units of this building. However, it is considered that the use of the building would not be used in 24 hour operation as residential unit and only used during business hours, officers raise no objection on this basis. The proposed distance would increase as the building steps further away northwards. Furthermore, the proposed distance of the 5-storey part of the being 25m is considered to be adequate considering the urban central

location of the development.

9.30 Building 7 would be erected at a distance of 25m from the North Block, County Hall. Given the urban central location of the development and given the built up environment of the area, the proposed distance is considered to be generous. Officers consider on this basis that the scheme would not give rise to direct overlooking and loss of privacy to this existing residential building.

9.31 Whitehouse apartments would be most affected by buildings 4A and 4B which would be at distance of between approximately 50-55m. Officers consider that there would be sufficient distance away from this existing residential building. Only one façade (elevation facing the railway line) would be affected by the development, however, the remaining elevations, would have oblique views from these proposed buildings. Furthermore, given the urban location of the area, sufficient distance is given and as such no objection is raised.

Proposed Development at Elizabeth House:

9.32 Both buildings 3 and 4A would be the nearest proposed residential buildings to the recent Elizabeth House scheme which granted resolution for permission by members. However, the proposed distance would between 25m to 30m in distance. Officers consider that this distance would be sufficient given the urban location of the development. No objection is raised.

Sense of Enclosure:

9.33 The County Hall North Block would be most affected by the proposed Shell Centre development. Buildings 1 and 7 would be erected at a distance of 25m. It should be acknowledged that the Belvedere scheme which has been implemented would be erected in a similar location and was accepted at appeal. Given the urban location of the development and the extant permission, officers consider that there would be sufficient distance from this residential block. Given the regenerative benefits of the scheme, the application is considered to be acceptable further.

Wind

9.34 The applicant carried out Wind tunnel testing to assess the likely effect of wind upon pedestrian experience from the proposal, classified in accordance with the Lawson Criteria (LC). The LC is popularly referenced as a guiding principle, with six levels of activity, measured in the Beaufort scale for wind on land, itself with twelve force levels from ‘Calm’ to ‘Hurricane’. It enables an assessment of the expected conditions within and around the proposal site and thereby highlight potential for mitigation where excesses in comfort levels are anticipated from the modeling results.

9.35 Six configurations of the site were modelled:

1. Existing site (baseline) with existing surround 2. Fully demolished/cleared site (Shell Tower retained) 3. The redevelopment proposals (including footbridge over York Road) with existing surrounds 4. The redevelopment proposals (excluding the footbridge, over York Road) with existing surrounds 5. The redevelopment proposals with the other development schemes; and 6. The redevelopment proposals with the other development schemes and the Elizabeth House proposals massing.

Other modeling was carried out to demonstrate effectiveness of different mitigation measures.

9.36 Results for both summer and winter months have been provided. This is because some pedestrian activities defined by the Lawson Comfort Criteria need to be met during the windiest seasons whereas others, primarily due to seating and amenity are dependent upon the summertime conditions. The LCs upper threshold for wind tolerances is measured up to 6 on the beaufort scale, but during the windiest season, winds can be strong enough to significantly disrupt pedestrian activities.

9.37 Baseline conditions are commonly taken from the UK meteorological office. Overall 168 locations were modelled within and around the site. The existing condition is one of relative calm, with all test locations suitable for sitting, standing or leisure walking during the windiest season. The windiest locations during the winter months were found next to the London Eye, within Jubilee Gardens, areas to the west of the site and on the west side of York Road adjacent to Elizabeth House and Waterloo Station; all have exposure to prevailing winds.

9.38 The completed development was modeled both with and without the pedestrian bridge across York Road. Broadly, the surround of the site is similar to the baseline condition, suitable for a range of sitting, standing and leisure walking. There were windier conditions relative to the baseline reported along either side of the York Road pavement adjacent to County Hall. However, the results show that the effect would be suitable to the anticipated use, where leisure walking/standing conditions are expected compared with standing/sitting conditions are present under the baseline position. Whilst this will result in a long term minor adverse impact, it is envisaged that the change would have no impact on the comfortably passing through this pedestrian space.

9.39 There would be calmer conditions experienced to the east side of the footbridge and at the south-western corner of Elizabeth House, suitable for standing and sitting respectively compared with the existing conditions for leisure walking and standing. The removal of the pedestrian bridge would assist further in calming the local condition at the base of the pedestrian footbridge on the east side of York Road.

9.40 In the summer months, the local area would see no impact to make the environment unsuitable for its intended use, and indeed some parts would see calming by one category.

9.41 Within the site the conditions that would result from the development would be suitable for standing at ground level, with windier leisure walking conditions at building corners and to the base of the tallest buildings. Overall, the conditions would be suitable for the intended use during the year, with thoroughfares suitable for their desired use throughout the year with the exception of the a part of the passageway between the railway viaduct and building 5. Here a screen is recommended as mitigation. With this in place the area is suited to leisure walking in winter and standing in summer months. Given its intended use as a pedestrian thoroughfare where the mitigation measures are put in place they are considered to address any impact and would give way to a microclimate typical of such urban environments with high-rise development.

9.42 All entranceways are suitable for such use with the exception of a secondary entrance to the southern retail unit within Building 5. Given that this is a secondary entrance and adjacent to a pedestrian thoroughfare it is considered acceptable that is found to provide for leisure walking.

9.43 In a cleared site context with surrounding buildings, the location of the proposed public square to the interior of the site appears to provide more comfortable ground conditions, than others. The public square under proposed conditions would result in sitting and standing conditions during summer months. Mitigation would be required to address those areas where a standing rather than sitting condition for which the latter is anticipated as the end use is achieved.

9.44 The other areas of open space proposed within the site including at the foot of building 4a, balconies and roof terraces would be suited to standing/sitting conditions with mitigation would improve upon the se conditions.

9.45 Overall, the methodology employed for the wind is robust and meets with industry best practise. A number of mitigation measures have been tested which appear to have resulted in the required calming of local wind conditions making various locations suitable for their intended pedestrian activities and pertinent conditions are recommended to secure these. While there would be some impact, be it negligible or minor beneficial, given the inaccessibility of much the site currently the importance of the results is their comfort range with the intended use. Similarly, small improvements for the immediate surrounding would be an improvement directly resulting from the development over the existing condition. The impacts are no dissimilar to those found within inner urban environments and for which the site is earmarked as an opportunity area within the CAZ that encourages the scale of development proposed.

9.46 Water Resources and Flooding:

This chapter has been prepared by URS on behalf of the application and

identifies the key water resources and likely significant effects, direct and indirect, of the redevelopment on these resources. These considerations have been made in the context of existing site conditions, demolition and construction works and once the development is complete. The mitigation measures are addressed and any residual effects are indentified.

9.47 A desk review and consultation with external parties has identified the key water resource receptors within close proximity to the redevelopment proposals. The proposals highlight that the scheme would have an effect upon the water resources during the construction and operation of the site.

9.48 The impact of the development during the construction of the site is considered to be negligible, provided that the following mitigation measures are implemented for each source of impact which include:

• If contamination is traced, then work will cease until the contamination is effectively treated. • Adequate mechanisms would be used to depose of residual construction waste from the development. • The use of water re-use and saving measures such as rainwater harvesting system, implementation of staff-based initiatives and use of recycled water systems for wheel washers, which would reduce the wastewater generation during the construction phase.

9.49 The operation of the development would have a negligible impact on the water resource receptors but the following mitigation measures would be used to reduce this impact:

• Reducing the likelihood of leaks and spills by the creation of emergency spillage response plan. • Installation of a drainage network and use of appropriate waterproofing protection during construction. • Reducing flood risk by managing surface water up to 100 years plus climate change return period. This would be brought forward by the implementation of attenuation tanks which allow for a 65-70% reduction in the current drainage rate. Furthermore, there would be the inclusion of green roofs and rainwater harvesting.

9.50 Within the completed development there would be water saving fixture and fittings incorporated within the site to meet best practice targets and reduce water demand for the site. This would be in the form of low flush volume for toilets, restricted shower outlets and wash hand basins, sanitary water shut off systems and the use of limited fill baths, which would effectively reduce water demand in the area.

9.51 The assessment concludes that the development would have a long-term negligible impact on the water infrastructure and is not likely to give rise to significant environmental effects associated with water resources and flood risk. The submitted information has been assessed by the Environment Agency and whilst the development is sited within ‘Flood Zone 3’, which is deemed to be ‘high-risk’ whereby the residential properties would be

classified as ‘more vulnerable’, and indeed the community proposals are also sensitive, they have no explicit concerns. A condition is recommended requesting that details of surface drainage scheme for the site, based on sustainable drainage principles are submitted for assessment.

9.52 Thames Water raised concerns that the existing water infrastructure would not be able to cope with the introduction of the proposed development, but this could be mitigated through a condition requesting a drainage strategy being submitted prior to the implementation of the scheme, detailing on and offsite drainage works. A condition has been imposed to this effect. Overall officers are satisfied that the mitigation measures set out in the ES would outweigh the impact the development may have in local area on the existing water infrastructure.

9.53 Ground Conditions:

This chapter has been prepared by Ove Arup and Partners (Arup). The main aim of this chapter is for the assessment to the potential for land contamination and the associated risks/ likely effects to human health and the environment from the redevelopment proposals.

9.54 The desk based assessment and review of existing ground investigation data for the site suggest there is a potential for contamination at the site, although the contamination which has been assessed would be limited and unlikely to require specific remediation before or during demolition and construction. The assessment concludes that during both the demolition and construction stage there would be limited impact and where there would be potential impact adequate mitigation measures such as dust control, ground investigation and risk assessment and various pre-construct ion assessment such as piling risk and unexploded ordnance (UXO) strategy (assesses potential for land contamination) is used. As a result there would be no significant environmental effects associated with ground conditions.

9.55 This part of the development has been assessed by Bowyer Planning on behalf of the LPA. Overall, conclusions, mitigation measures and recommendations made within the ground conditions chapter of the ES for the Shell Centre Site is justified. Bowyer Planning has requested that a condition is imposed in relation to risks associated with potential contamination of the site.

9.56 Air Quality: As with the majority of London, the site lies within an Air Quality Management Area. This chapter of the ES consider the effect associated with additional road traffic and heating plant emissions attributed to the redevelopment proposals once operational. It also considers the potential emissions from construction plant and dust generation during the demolition and construction works. Consideration is given to the intended end use of the site and whether the design proposals adequately avoids causing air quality issues on the site.

9.57 WSP Consulting reviewed the impacts modelled in the ES. Together with the mitigation proposed by the applicant, WSP have advised that a communication strategy with Environmental Health should be secured for during the monitoring period associated with construction, which was absent within the applicants submission of proposed measures. Whilst the impact during the demolition and construction phase is found to be minor adverse, these are temporary impacts and would not result in lasting detriment. Indeed, this phase would be required, subject to conditions, to comply with a Demolition and Construction management plan to include details of, but not exclusively, site planning, construction traffic performance and management, and site activities. This would seek to mitigate against any likely impact to the surrounding area.

9.58 Overall, the review of the chapter concludes that the air quality impacts are satisfactorily modelled for the purposes of planning decision making. For the completed development, together with others in the immediate vicinity, a negligible impact to local air quality levels is envisaged.

9.59 Ecology:

The ecology chapter of the ES was reviewed by the ‘Ecology Consultancy’. The chapter assessed the likely effect of development on ecology and nature conservation resulting from the demolition, construction and operational phases of the development. It considered the legal and planning context, gave a description of the assessment methodology and significance criteria, the baseline conditions, the evaluation of the ecological receptors, and the likely significant effects and mitigation measures.

9.60 The assessment of the envisaged impact provided by the Ecology Consultancy raised criticism on the methodology carried out by the applicant for the bird and bat surveys but which has no effect on the anticipated impact. There are no protected or notable species found within the site, nor would it support those found recorded within 2km of the site (such as bats and falcons). Overall, the impact is at worst expected to be negligible and best have a minor beneficial impact given the intended provision of bird and bat boxes to the site along with bio diverse landscaping. All birds are protected by virtue of the Wildlife and Countryside Act 1981. A condition has been imposed which proposes when demolition of the site should be carried out to safeguard any subsequent breeding at the site.

9.61 The Ecology Consultancy has advised that “planning guidance makes it clear that applications should not be determined without all the necessary survey data in respect of protected and BAP spe cies being considered.” Following further clarification from the consultants involved, the Ecology Consultancy have confirmed that “whilst we are critical of the methodology for the bat and bird surveys, overall given the nature of the Shell Centre and its urban location our view is that the ES is sufficiently robust.”

9.62 Bower Planning concluded that the information is robust to assess and judge the ES assessment in respect of ecology.

9.63 Noise and Vibration:

The submitted ES has assessed the likely significant effects of the redevelopment proposal with regard to noise and vibration throughout the demolition and construction stage. This has been assessed by Hann Tucker Associates on behalf of the applicant. The report has taken into consideration the impact the development would have during demolition, construction and completion of the development.

9.64 The prediction of noise and vibration levels anticipated during the demolition and construction programme has been carried out based on the methodology contained within the British Standard 5228; this provides guidance on the assessment of noise and vibration impacts development, together with the assumptions of the working practices likely to be employed during the demolition and construction works.

9.65 The Department of Environment (DoE) Advisory Leaflet (AL) 72 (1976) ‘Noise Control’ on Building Sites, gives advice on the maximum levels of construction site noise at residential location during daytime hours based on levels associated with speech interference. This publication states that during daytime hours (08:00 hours to 18:00 hours) the LAeq noise level at the building façade should not exceed

• 75dBA in urban areas near to main roads in heavy industrial areas; or • 70dBA in rural suburban and urban areas away from main road traffic and industrial noise.

The assessment for the demolition phase states that the noise impact would have a minor to moderate adverse impact. During the construction stage, due to the metres of piling and substructure operations required, these are likely to cause short or medium effects for local periods of moderate to major adverse significance. This would not be exceptional thought for a development of this scale and would be temporary and intermittent throughout the course of the development.

9.66 The construction vehicles would have the potential to generate noise, the estimated number of vehicles would represent a very small proportion of the day to day road traffic movements in the surrounding streets and as a result this would have a negligible effect.

9.67 Consideration is also had to the lifetime of the development and impacts for prospective occupations in relation to noise and vibration. Various sources of disturbance could arise given the inner urban location of the site, such as road traffic noise. This would result in a negligible impact. The redevelopment would incorporate items of fixed plant which would have the potential to generate noise, especially when operating at night when background noise levels are at their lowest. A large amount of mechanical plant would be incorporated into the shared basement with intake and discharge louvers at street level. Intermediate plant rooms are proposed within building 1 and 2 and rooftop plant is proposed for all buildings. The rooftop planning would comprise air handling equipment on all, heat rejection

units on buildings 1, 2, and 3 and emergency standby generators on buildings 2 and 3. Again, this would give rise to a negligible to moderate impact when considering modern cooling needs etc.

9.68 There could be potential noise and vibration issues which may impact upon the residential units in buildings 4A, 4B and 5 due to these buildings being erected in close proximity to the railway line. A condition has been imposed, requesting that windows are installed with thickened glass to mitigate any noise impact to these residential units with no significant impact anticipated whereby such mitigation will address any impact for which the relationship of a railway and residential use in this respect is not uncommon of an inner urban context.

9.69 The proposed shops, restaurants, cafes and drinking establishment within the development proposal would generally be serviced via the service yards within the shared basement. The noise generated from servicing activities would therefore be dominated by associated traffic movements but actual delivery activities. However, this noise would be masked by the basement. Servicing would not take place during night-time hours. It is considered that the high-levels of daytime traffic would mask the majority of the individual noise events from servicing and produce an effect of negligible significance for all noise sensitive receptors. Conditions are recommended in relation to delivery and servicing, which would mitigate impact to the adjoining residential blocks especially County Hall North Block which is opposite the site.

9.70 The proposed retail units within the redevelopment proposals may comprise of cafés, restaurants and drinking establishment, but the list would not include night clubs. Such uses may have the potential to generate noise although the likely significant effects are unlikely to be greater than of negligible significance as the sound insulation afforded by the proposed facades would be more than sufficient for most uses. Overall the noise and vibration impact assessment of the development has been assessed and officers consider that the information which has been submitted would be sufficient and result in mitigating impact to the existing and future occupants of the residential units. However, conditions as listed above would mitigate any negligible impact that may arise.

9.71 Electronic Interference :

This chapter in the ES presents the findings of an assessment of the likely significant effects to digital and terrestrial and satellite television (TV) reception associated with the redevelopment proposals. Consideration has also been given to the likely significant effects on radio reception, mobile telephone signals, wireless networks and emergency service communications. This document has been prepared by Tom Paxton, a specialist electronic interference consultant.

9.72 A desk based study was undertaken to ascertain what forms of broadcasting would be at risk of adverse effects as a result of the redevelopment proposals and where there these would occur. It was identified that both

terrestrial TV and satellite TV reception could be at risk. An on-site survey was conducted to identify any at-risk dwellings within the predicted shadow areas. The predicted shadow from the Crystal Palace transmitter could potentially be affected by the development. However, mitigation measures such as upgrading the existing aerials by increasing their height and/or gain, or providing a non-subscription satellite service that is supplied by either the BBC and ITV (Freesat) or by ‘Sky’ for a one-off cost would alleviate this. In this instance, no impact is envisaged where conditions are recommended for future monitoring post development.

9.73 Demolition and Construction:

This chapter of the ES describes the likely programme of demolition and construction works and the key activities that will be undertaken on the site in relation to the redevelopment proposals. This chapter has been prepared by Canary Wharf Contractors Limited.

9.74 It is expected that the total duration of the work for the entire redevelopment proposals would be approximately 68 months. In general terms it is anticipated that the site opening and working hours are as follows:

• Monday to Friday – 07.00 to 19.00; and • Saturday 07.00 to 13.00

Actual building work hours are controlled under Building control regulations. All works and ancillary operations which would have a measurable increase ambient noise levels shall only be carried out between the hours of 08.00 to 18.00 Monday to Friday and 08.00 to 13.00 on Saturday. Works and ancillary operations which will not see a measurable increase over ambient noise levels may be carried out between the hours of 07.00 to 08.00 and 18.00 to 19.00 Monday to Friday and on Saturdays from 07.00 to 08.00. These are designated as ‘quiet’ working hours on site.

9.75 Hoardings would be erected around the site, for which it is recommended that a condition secure a rolling programme of work with local groups/schools/artists and be maintained throughout the construction period to improve the presentation of the hoarding line.

9.76 A ‘Clean Site’ policy would be established and actively managed by the principal contractor. Building materials containing asbestos would be fully assessed in advance of any demolition works (this has been discussed above under ‘Ground works’. A full access Type Asbestos Survey would be carried out by a suitable accredited specialist. The proposal would limit dust impact from demolition through effectively demolishing structures on the site. Conditions have been imposed to this effect.

9.77 Officers have assessed the submitted demolition and construction chapter. The details submitted present no unusual circumstances for such a development.

9.78 Socio -Economic:

This chapter assesses the likely significant socio-economic effects of the redevelopment proposals. This chapter has been prepared by Quod. Consideration is given to the likely effects of the redevelopment proposals on housing, employment, local expenditure and the demand for community facilities. This has been assessed during both the demolition, construction and completion stages of the development.

9.79 The likely significant effects of the redevelopment proposals during the demolition and construction phase include demolition and construction employment and training. It is estimated that an average of 700 construction workers per month would be required on-site for six years. This has been assessed as a temporary beneficial effect of minor significance at the local and district level. These jobs would be fed through the authorities brokerage and ensure Lambeth residents can play a greater role in London’s economy.

9.80 The likely significant effects of the completed and occupied redevelopment proposals on the demand for housing, demand for affordable housing, and employment are assessed as beneficial effects of major significance at the local and district level. The likely significant effect of the provision of high quality public realm is assessed as a major beneficial effect at the local level.

9.81 It is estimated that up to 1,560 people would live within the new residential units, generating a demand for up to 45 primary school places, 30 secondary school places, less than one General Practice Doctors for which financial contributions would be secured by way of Section 106 agreement. Up to 750 m2 of playspace is required. In addition to playspace provided on site, a contribution towards these facilities would be provided. With mitigation measures in place, the residual effect of the redevelopment proposals on these facilities is assessed as negligible at the local, district and regional levels.

9.82 The new residential and working population is anticipated to generate up to £9.7 million and £5.9 million respectively in annual spending, a large proportion of which could be captured locally. This is assessed as a moderate beneficial effect at the local level. The new residential population and increase in employees is anticipated to generate increased activity on- site and in the surrounding area. Combined with improved public realm, this is assessed as having a beneficial effect of minor significance on crime and public safety at the local level.

9.83 Overall, officers welcome the socio-economic benefits of the scheme which deliver a substantial package of benefits for Waterloo and the Borough, in addition to the contribution that is consequently made to the strategic functionality of the site within the CAZ as has been discussed above.

9.84 Residual Effect Assessment

This chapter in the submitted ES summarises the residual effects of the redevelopment proposals. Residual effects are defined as those effects that remain following the implementation of mitigation measures. Mitigation

measures relate to the demolition and construction, and operational phases of the redevelopment proposals. This chapter has been written by URS.

9.85 The assessment concludes that throughout the demolition and construction phase a number of potential adverse effects are anticipated. These specifically relate to construction noise, dust, and temporary effects to the setting of the heritage assets. In order to mitigate against these effects, a condition would be imposed in relation to Construction Environmental Management Plan (CEMP). This would address all relevant environmental issues; including control limits to noise and vibration, waste management, air emissions and dust controls, hours of working and neighbour liaison. However, it should be noted here that demolition and construction phase also generates beneficial effects relating to construction employment and training.

9.86 The ES has demonstrated that the scheme would provide a number of beneficial effects. These include provision of residential housing to meet housing targets; employment creation on-site and for the wider economy; provision of open space; and improved safety and reduced fear of crime.

9.87 Furthermore, BREEAM levels of ‘Excellent’ for the office development and ‘Very Good’ for the retail development would be targeted and the residential elements would target Code for Sustainable Homes Level 4.

9.88 Officers acknowledge that there would be a loss of both daylight and sunlight to the adjoining properties. However, given the overarching regenerative benefits of the scheme which would make a contribution to both Waterloo and the wider London city area, refusing the scheme would not be warranted. In this instance the submitted ES and supporting information addresses this potential loss.

9.89 The redevelopment proposals are assessed as appropriate in terms of local, regional and national policies and on balance, it is considered that the development responds to the environmental considerations appropriately.

9.90 Effects Interactions and Cumulative Effects Assessment:

This part of the submitted ES has assessed:

• The combined effect of individual effects, for example noise, airborne duct or traffic effect 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 effect.

This has been written by URS on behalf of the applicant.

9.91 From the assessment of the potential combined cumulative effects, it can be seen that there is potential for both adverse and beneficial combined cumulative effects. As highlighted previously the adverse cumulative effects

occur throughout the demolition and construction and phase of development proposals. As a result the combined cumulative effects have the potential to have an effect upon:

• Existing residential properties adjacent to/ in proximity to the site; • Existing commercial properties and local businesses adjacent to/ in proximity to the site; • Pedestrian, cyclists and road users at the site and its surrounding area; and • Nearby open space

9.92 However, the mitigation measures which have been described within the ES would reduce the potential nuisance factors on these receptors. In this instance the proposed development would provide overall a beneficial cumulative effect in the Waterloo area and the wider London city.

9.93 Conclusion

It is considered that all of the potential impacts on residential amenity have been fully addressed and neither not considered to be a matter of concern or have been fully mitigated through the detail of the scheme or the proposed conditions.

10 Sustainability and Renewable Energy

10.1 Policies 5.1 and 5.2 of the London Plan sets out a minimum target reduction for carbon dioxide emissions in buildings up until 2013 of 25% over the Target Emission Rates outlined in the national Building Regulations. Developments should follow the following energy hierarchy:

1 Be lean: use less energy; 2 Be clean: supply energy efficiently; 3 Be green: use renewable energy

10.2 Policy S7 of the Core Strategy ensures that future development, including construction of the public realm, highways and other physical infrastructure, achieves the highest standards of sustainable design. The policy further states that major developments should achieve a reduction in carbon dioxide emissions in line with London Plan targets through energy efficient design, decentralised heat, cooling and power systems and on-site renewable energy generation and requiring all other development to achieve maximum feasible reduction in carbon dioxide emissions through these measures.

10.3 The applicant has followed the energy hierarchy and is proposing to reduce the carbon emissions by 31%, thus exceeding the London Plan requirement. A total of 20% savings would be achieved from energy efficiency measures and 14% savings from combined heat and power plant, which will provide the lead source of heat for the site wide energy network. A small amount of photovoltaic panels (393sqm) would provide a further 1% savings.

10.4 The applicant has identified the planned South Bank district heating network

(DHN) as a future point of connectivity. The energy strategy indicates that it would be possible, as local air quality requirement have restricted the exhaust emission allowed on site to serve the South Bank DHN from the Shell Centre site at this time. Nevertheless, the applicant should continue to prioritise connecting to the South Bank network and should investigate measures to overcome the air quality restraints and allow the energy centre to host the South Bank DHN energy plant.

10.5 The applicant has submitted a sustainability statement, which includes assessment against the GLA’s standards and includes a Code for Sustainable Homes and BREEAM pre-assessment. The applicant states that it is intended that all homes meet Code for Sustainable Homes Level 4 and ‘Excellent’ for the office space, and complies with all of the relevant London Plan policies and the Mayor’s SPG.

10.6 The documents also set out a number of techniques proposed to reduce energy consumption and cut carbon emission, using high performance building fabric, shading systems, low energy lighting, energy efficient appliances, metering, high-levels insulation, and by maximising natural sunlight and solar gain. Sustainable urban drainage is proposed in the form of grey water/ rainwater harvesting and surface water attenuation tanks, and 3,360sqm of green/ brown roof would also be provided with together with the planting proposed would contribute towards urban greening in the CAZ which otherwise been absent in this vicinity for may years. This has been secured via conditions.

11 Refuse and Recycling

11.1 This Site Waste Strategy report has been prepared by the Waste Team at AECOM to support these applications.

11.2 Refuse collection is divided into commercial and residential streams. Residential waste would be collected by Lambeth, while the commercial waste would be under private contract. Residential waste would be split into three waste streams: recyclable, non-recyclable and organic, which are collected via gravity chute system located in the access corridors at each floor level. A vacuum based waste collection system also being proposed.

11.3 A total of 74 euro bins would be required to store all residential waste based on an un-compacted residential waste strategy. This would be stored within the basement. Furthermore two compactors would be installed for recyclable and non-recyclable waste streams in the loading bays. Commercial waste would be segregated into general waste, dry mixed waste and glass.

11.4 Officers have assessed the proposed waste provision for both the commercial and residential units. No objections have been raised subject to condition being imposed in relation to waste management

12 Transportation and Accessibility

12.1 Policy S4 of the Core Strategy aims to achieve and contribute towards sustainable pattern of development within the borough; seeking improvement for better connectivity, quality and capacity in public transport; working in partnership with TfL, Network Rail and other public transport providers and supporting the plans and programmes for improvements to public transport infrastructure and services in the borough, including the transport hubs at Waterloo; requiring developments to comply with the maximum car parking standards in the London Plan and reflect the public transport accessibility of the development and to include provision for cycle parking, motor-cycle parking in appropriate location and car clubs wherever possible; promoting walking and cycling, including through improvements to existing provision in and around development for cycling, cycle parking, public realm and transport and highway infrastructure.

12.2 Policy 6.1 of the London plan aims to encourage patterns and nodes of development that reduce the need to travel, especially by car; seeking to improve the capacity and accessibility of public transport, walking and cycling, particularly in areas of greatest demand; supporting development that generates high levels of trips at locations with high public accessibility; improving interchange between different forms of transport, particularly around major rail and Underground stations, especially where this will enhance connectivity in outer London.

12.3 The site has a PTAL score of 6b, which is the highest possible score on the PTAL scale and is considered ‘excellent’, and is therefore considered appropriate for high density mixed use development. The site is located on the eastern side of the A3200 York Road which is a red route forming part of the TLRN. The site is bound to the north by railway tracks heading into Waterloo East station, to the south by Chicheley Street and the west by Belvedere Road which are borough roads. However, to the south of the site Belvedere Road is gated between Chicheley Street and Westminster Bridge Road where it is a private road.

12.4 Car Parking and Cycle Storage Facilities

Basement Car Park

The application proposes a total of 270 car parking spaces, a reduction from the existing 320 parking spaces. Of these, 239 would be allocated to residential, 30 to office use and 1 to retail. The proposed level of residential car parking equates to ratio of 0.27. This is marginally above the 0.2 ratio that officers generally consider to be acceptable in locations such as this but in considering the scale of development and potential transport impacts the proposed level is considered to be acceptable in this case. Indeed, though marginal to the scheme as a whole, the provision of residential car parking delivers value to the scheme against which the authority can secure additional affordable units as discussed above. The 2011 census shows that car ownership and car use for work purposes has reduced over the last 10 years and therefore the provision of 30 spaces is considered to be appropriate. The development would be secured as “permit free” such that residents would not be allowed to purchase on-street parking permits.

Commercial parking would be for operational use only, and no individual occupier would be allowed parking in excess of the London Plan parking standards. This would be controlled through a S106 agreement. Of the residential parking 33% would be accessible spaces, and 10% of the office parking would be accessible spaces. A total 20% of car parking spaces would be fitted with electric charging points and a further 20% passive provision would also be made available for future conversion. 50 motorcycle parking spaces are also proposed within the car park.

12.5 Car Club

The applicant proposes to fund a car club at the site which is welcomed by officers. A package of free membership’s equivalent to the number of apartments is also to be provided and this would be secured through the s106 agreement.

12.67 Cycle Hire Bikes

The proposal includes the relocation of the existing Barclays Cycle Hire docking station on the eastern footway of Belvedere Road next to the loading bay exit, to the opposite side of Belvedere Road. This is acceptable in principle but is likely to require the relocation of a number of street trees and / or lamp columns. All costs associated with the relocation would be covered by the Section 106. The final location would be secured as part of the public realm proposals, and may not be in the position shown for reasons set out in the public realm section of this report below.

12.7 Officers have been in discussion with the applicant about the number and location of visitor cycle parking facilities to be provided. It is recommended that the details of this are secured by condition to ensure that an appropriate number of stands are provided, and that the location of these stands is acceptable bearing in mind the likely high level of use. The proposed cycle hire bikes approach is supported by TfL also. The number of cycle parking spaces proposed within the site to accommodate all the uses within the site meets London Plan standards. However, officers are recommending that the details of the cycle parking are reserved by condition to ensure that amendments to the layout can be secured. This includes reducing the size of cycle stores, and will ensure that the types of cycle stand proposed are acceptable.

12.8 Traffic Impacts

The applicant has undertaken traffic surveys to support the application. However, both officers and local residents raised concerns that these were not undertaken at peak tourist times and would not, therefore, show the worst case scenario in terms of the potential impact of the development. The applicant therefore undertook additional traffic surveys, at a time agreed with local residents, to supplement the original surveys. They have also factored in additional tourist traffic as measured in a coach survey undertaken in June 2012.

12.9 Officers are satisfied, that although the original surveys were not undertaken at the most appropriate time of the year to capture tourist related traffic, the likely impact of the development would be acceptable. The additional surveys (taken during school holiday period) show little difference in the level of background traffic and it is not expected that this would vary significantly during the summer. What would change, is the number of coaches visiting the area but surveys undertaken by the applicant show that these do not significantly affect peak times. Consequently, overall transport Officers (and TfL) are satisfied that there would be no adverse impacts on the local road network as a result of the proposed development.

12.10 Trip Generation and Modal Split

Officers (and TfL) are satisfied that the assessment of traffic generation (using TRAVL, or Trip Rate Assessment Valid for London, which is a multi- modal trip generation database for use in London trip generation database) is acceptable and that there would be no adverse impacts as a result of the proposed land uses and level of parking. This is subject to agreement of the Service Management Plan as set out below. A sense check using 2011 Census data has been provided in this section to confirm that the TRAVL data used in the TA was representative.

The table below demonstrates that the difference between the split used in the TA, and that derived from the most recent Census for the local resident population is minor and not considered to be of significance.

Difference between TRAVL Bishops Ward TRAVL Census and Census Underground 17.9% 24.2% -6.3% National Rail 17.5% 8.2% 9.3% Bus/Coach 19.8% 19.5% 0.3% Taxi 0.5% 0.6% -0.1% Car Driver 8.3% 7.5% 0.8% Car Passenger 0.9% 0.5% 0.4% Motorcycle 2.1% 0.8% 1.3% Pedal Cycle 4.6% 6.8% -2.2% Walk 28.4% 31.0% -2.6% Other 0.0% 0.8% -0.8% Total 100.0% 100.0%

12.11 Vehicular Acces s

The Shell Centre currently has a number of vehicular access points. There is entry to the service yard on York Road adjacent to the railway viaduct with an exit onto Belvedere Road, two accesses (entry and exit) to the car park on Chicheley Street, and 2 delivery accesses (entry and exit) to Belvedere Road for smaller delivery vehicles. The existing vehicular access and egress ramps on Chicheley Street would be removed and replaced by a single vehicular access point for the whole site to access both the new basement service yard, and all car parking associated with the development (incorporating one crossover providing direct access to the basement and

one providing access to a security loop). The security loop is security screening area located off the carriageway, where vehicles which are not pre-authorised will be checked before entering the basement.

12.12 The only other vehicular access to the site proposed is an internal VIP pick- up / drop-off facility positioned between Building 1 and the Shell Tower, for exclusive use by Shell and accessed from Belvedere Road. Emergency vehicles would access the internal area of the site from Belvedere Road via this pick-up / drop off facility, or between Buildings 3 and 4A which would be controlled by rising bollards. Internal routes would be unobstructed to allow direct access to fire entry points and risers. At the ramp access on Chicheley Street secure entry facilities would be provided by way of a barrier controlled rejection facility at the ramp entrance. Residents’ private cars would use a key card / fob entry system to access the ramp directly from Chicheley Street, while service vehicles and vehicular couriers would be required to use a ‘rejection’ entry loop, and once cleared would then be allowed to enter the basement. The entry loop would appear to accommodate up to 2 x 10m large goods vehicles (LGVs), and would allow refuse vehicles to re-join the carriageway in a forward gear.

12.13 The applicant has provided information explaining why they chose Chicheley Street as the best location for vehicular access, and why other options were discounted. One of the key principles of the development is to improve pedestrian access from Waterloo Station and York Road to the river and this therefore limits the potential location of the access. One of the main benefits of the proposed development is to open up a new link through the site along the railway viaduct to Belvedere Road. This would provide a new direct route between the Victory Arch entrance to Waterloo Station and the upstream Golden Jubilee Bridge, although this would rely on an extension to Jubilee Gardens to complete the link. Currently, the route to and from this bridge is difficult and this route would provide significantly improved permeability. Officers agree that the current access location on York Road does not, therefore, provide the best option to serve the new development.

12.14 Other locations on York Road are restricted by the location of the Underground station, the Shell Tower, proximity to the junction with Chicheley Street, and impacts on the location of pedestrian routes and public realm. TfL is not supportive of this option because of the implications it would have for traffic flow on York Road, which is part of the Transport for London Road Network.

12.15 It is not considered appropriate for the access to be located on Belvedere Road. This road provides access to Jubilee Gardens, the London Eye and the Southbank Centre and generates a significant amount of pedestrian movements including tourist groups currently. A new vehicular access, therefore, would increase the amount of traffic on this road and impact on the proposals to create significantly improved public realm, as befits the location, as well as being able to accommodate all of the on-street bays that are required. It would also lead to more traffic using the junction of Chicheley Street with Belvedere Road which could lead to additional queuing on Chicheley Street due to the location of the access to the County Hall service

areas at this point.

12.16 It is considered, therefore, that after taking into account these other factors, Chicheley Street is the best available location for the car park and servicing access but this would be subject to the implementation of appropriate management measures to minimise its impact. Transport officers have had several meetings with the applicant to ensure that the proposed access location is acceptable, bearing in mind its proximity to County Hall north block. Meetings have also been held with residents to understand their concerns. Residents highlighted existing problems on Chicheley Street and are concerned over the potential for additional noise and queuing associated with the proposals.

12.17 As a result of requests made by officers, and in order to overcome concerns about the potential impact on traffic flow and safety on Chicheley Street, the applicant has provided additional information regarding how the access would operate. At the request of officers, the applicant’s analysis has included signal capacity and queue modelling exercises to illustrate how the secure entry loop would operate. It is important to note that the applicant has assessed the impact of the access under both a managed and unmanaged scenario to understand the worst case scenario. This demonstrates that in the worst case scenario, adequate capacity would be provided and this would be improved when the Service Management Plan is introduced.

12.18 An integral part of the planning application is a Service Management Plan to ensure that the access operates in an efficient manner. The applicant has provided a draft Plan which outlines the principles of the servicing management strategy, including the principles of vehicle registration, the delivery booking system, some detail on the applicants past experience, and restrictions on the size of vehicles. The Plan would cover retail, residential and office deliveries, including couriers. This would be secured by condition. A key principle of the Plan would be the ability to pre-authorise as many vehicles as possible so that they do not have to use the security loop. An assessment of traffic generation by the applicant, including additional analysis on the operation of the security loop and a worst case capacity assessment of the ramp and loop security screening area, which indicates that there would not be an adverse impact on the capacity of Chicheley Street at its junction with York Road. Officers are satisfied that this would be supported by TfL.

12.19 Existing Problem s on Chicheley Street

In response to concerns raised by residents, the applicant has provided additional information on the existing operation of Chicheley Street, in particular the occurrence of queuing from County Hall and the taxi rank at the western end of the street. Video surveys were undertaken in November 2012 which have been analysed by the applicant.

• County Hall servicing access - The applicant has advised that the video survey results demonstrate that during the surveyed period queues did not stretch back as far as the proposed Shell Centre access, and only

during one five minute period did queues of more than four vehicles occur.

• Taxi Rank Location – the applicant suggests that moving the existing taxi rank away from the junction would “reduce the activity of taxis directly in front of the County Hall servicing access and increase the space available for other road users throughout Chicheley Street / Belvedere Road junction”. Officers agree with this assessment and it is proposed that the taxi rank is relocated outside the Shell Centre Tower on Belvedere Road. However, the means to prevent taxis from dropping off in the existing location, which is likely to remain popular given its location next to several major tourist attractions, would need to be explored as part of the public realm proposals.

As a result of the survey results officers are satisfied that there is unlikely to be a significant impact on the Shell Centre access. The relocation of the taxi rank, and removal of the central island on Chicheley Street (which will allow vehicles to pass any queuing traffic) would also assist the situation.

12.20 Public Transport

Transport Officers (and TfL) are satisfied with the analysis of the baseline position and impact of the proposed development on local public transport networks.

The proposed reorientation of the London Underground station entrance on the western side of York Road is welcomed as an improvement on the existing facility. The final details would need to be agreed with TfL which requires an improvement on the existing facility. This is agreed in principle but the details need to be agreed prior to the commencement of construction. There would be improved pedestrian connection to Waterloo Station through the improvement of the pedestrian crossing at Victory Arch.

12.21 Highway and Public Realm Works

The application proposes significant changes to the public realm around the site. Indicative plans have been provided and would be secured through the Section106 Agreement and a Section278 agreement (Highways Act 1980). However, whilst officers are satisfied with these proposals, the details need to be finalised prior to construction. All comments below, therefore, are based on the indicative plans which could change subject to detailed assessment by the council as Highway Authority. The final location of all on- street bays would also be subject to a separate statutory consultation although the applicant has demonstrated that all existing on-street bays can be accommodated as part of the application proposals. However, it may not be possible (or desirable) to retain all bays in their current locations.

12.22 The proposed use of high quality materials means that there would be an increased maintenance responsibility. Therefore, an agreement is required between the council and the developer, to ensure that the latter would be responsible for funding all additional maintenance costs.

12.23 York Road

In combination with the neighbouring Elizabeth House development, the proposals include amendments to York Road. The Elizabeth House proposals would widen the eastern footway of York Road and remove the existing pedestrian footbridge, and two Shell Centre layouts have been have been designed to accommodate either scenario of the footbridge removal or retention. The Shell Centre proposals retain the width of the existing western footway and the raised median strip would also be retained and planted with trees, to retain informal crossing provision for pedestrians. This has been agreed by TfL. Improvements to the pedestrian crossings on York Road at Chicheley Street and Victory Arch are proposed, and raised crossing facilities would be provided at both locations.

12.24 Chicheley Street

The Chicheley Street carriageway would be narrowed, providing wider footways, and trees planted to improve the quality of the pedestrian environment. The applicant states that the security loop would be sensitively incorporated into the public realm without significant detriment to the footway width on the northern side of Chicheley Street. The original plans included central hatching along Chicheley Street to guide vehicles into the security loop. However, as a result of concerns about the impact on cycle safety this has been amended to show standard centre line markings. The existing central island at the junction with Belvedere Road is also shown to be removed. Chicheley Street would retain a kerb between the footway and carriageway although it is proposed that higher quality materials would be used to resurface both the carriageway and footways.

12.25 Belvedere Road

On Belvedere Road between the junction with Chicheley Street and the railway viaduct a shared surface treatment is proposed, with wider footways. Clearly defined pedestrian crossing spaces are also proposed on Belvedere Road either side of the Shell Centre Tower and near the London Eye to tie in with key pedestrian desire lines. These improvements in at-grade pedestrian crossing facilities are welcomed. It is proposed that this section of Belvedere Road becomes a shared surface with no (or minimal) distinction between the carriageway and footways. High quality materials are proposed which would lead to a significant improvement in the public realm in this important location and would prioritise pedestrians over other traffic. These proposals are supported in principle but would be subject to detailed design and agreement by the council as highway authority, primarily to ensure that highway safety is not compromised.

12.26 On -street Parking an d Coach Bays

Following discussions between Transport Officers and the applicant the proposals would re-provide at least the same level of on-street parking / waiting space as the existing highway layout, with a net increase of some

50m of coach / parking bays shown on Chicheley Street / Belvedere Road. Given the growing need for coach parking in this area TfL has asked that the number of coach bays should be maximised. The plans show the existing London Duck Tours (LDT) bus stand removed from Chicheley Road and it is proposed that this is relocated to Belvedere Road with no loss of capacity. The London Eye currently manages the existing coach parking very effectively and a similar level of management will be required in future. A Coach Management Strategy has been imposed, which should build on the principles of the London Eye approach, and include liaison with neighbouring developments such as the London Eye.

12.27 Taxi Rank

It is proposed to relocate the existing taxi rank to outside the Shell Tower. The removal of the rank from the existing location is welcomed to reduce movements at the Belvedere Road / Chicheley St junction, which also serves as a waiting area for vehicles waiting to clear security at the County Hall service yard, and the private section of Belvedere Road. However, it does not take into account the level of use of the rank where 3-4 taxis are often seen queuing. Therefore, officers advise that the capacity of the rank should be increased to at least 3 taxis, and this can easily be accommodated in the proposed plans. TfL’s Taxi Rank & Interchange Management have also suggested a second ‘feeder rank’ in the vicinity to accommodate waiting taxis. Concern is also raised that taxis would continue to drop-off at the existing location, given the popularity of the London Eye and County Hall attractions, thus affecting the operation of the junction. Therefore, the public realm proposals should include means to discourage this happening.

12.28 Bus Stop Relocation

The proposals include the relocation of both RV1 bus stops, the Chicheley Street northbound RV1 stop moving slightly closer to the junction with Belvedere Road, and the southbound bus stop relocated from Chicheley Street to Belvedere Road. TfL Buses have not raised any concerns over the proposed arrangement. The existing bus stand on Belvedere Road would also need to be re-provided.

12.29 Pedestrian Routes

In addition to the improved at-grade pedestrian crossing facilities in the vicinity, other improvements to public realm include significantly enhancing pedestrian linkages through the site from York Road to Belvedere Road, including a new link to the south of the railway viaduct which would provide a significantly improved route to the southern Golden Jubilee footbridge, and the provision of a new public square, all of which are welcomed.

12.30 There are currently 3 pedestrian routes through the Shell Centre from York Road to Belvedere Road although 2 of these are currently closed to the public. The 2 closed routes are at ground level through the courtyard and at first floor level on the bridge link to Waterloo Station. The latter still provides

access to York Road and to the Shell Centre itself for staff. However, the route through the site to Belvedere Road is closed. The third route is across the podium deck above the car park.

12.31 The layout of the proposed development provides a number of new routes through the site. There would be a new route along the southern side of the railway viaduct linking Victory Arch, via an improved pedestrian crossing on York Road, to Belvedere Road. This provides the opportunity for a much improved link to the upstream Golden Jubilee Bridge over the river, especially if at a future date the existing Hungerford car park is incorporated into Jubilee Gardens.

12.32 There would be 2 routes to the north and south of Building 3 linking York Road to the new square and then through to Belvedere Road. These routes would also provide improved access to the London Underground York Road ticket hall. There would also be also a third route through the site to the south of Building 2. Finally, it is proposed to widen the footway on Chicheley Street along the southern boundary of the site to a minimum of 4m. The applicant has assessed of all of these routes, using the relevant TfL guidance, to ensure that they would be wide enough to accommodate predicted flows. The assessment confirms that pedestrian levels of comfort are very good. The public realm works to York Road ensures that the routes are co-ordinated with a redeveloped Elizabeth House to provide improved access to Waterloo Station. An option has also been produced that retains the current footbridge over York Road.

12.33 Wayfinding

The redevelopment proposals provide an opportunity to incorporate enhanced pedestrian wayfinding through the Legible London programme. The Section 106 Agreement has secured this provision.

12.34 Travel Plan

Framework and Residential Travel Plans have been included within the submission, which have been initially assessed using the Attribute tool. The Plans are considered appropriate and have been secured via the Section 106 Agreement, along with measures such as cycle vouchers and Car Club membership.

12.35 Construction

The applicant confirms that York Road provides the main construction access point which is welcomed. The Construction Management Plan would include a commitment to consult with neighbouring developments on the construction programme and protection of pedestrian routes for example, and include review mechanisms. Pedestrian routes to and from Waterloo Station to the South Bank needs to be maintained during the construction period. The applicant has been advised to liaise with Network Rail in this respect.

12.36 Other access points on Chicheley Street and Belvedere Road would be used at various times during the construction period but officers do not consider these to be appropriate to be used for long periods of time by large vehicles. The developer’s contractor would be required to provide measures to ensure that highway safety is not compromised and this would need to be scrutinised in detail given the nature of this area and the number of tourists it attracts. Construction would not be allowed to commence until the LPA is satisfied that a very robust construction management plan has been proposed by the applicant. This would be rigorously enforced and the contractor will be expected to constantly review the plan, in association with the LPA and other affected parties to ensure that construction impacts are minimised and the area remains as safe as possible for all users.

12.37 Given that this will be only one of a number of developments under construction in this area at the same time a contribution should be sought via S106 towards a Lambeth Highways construction supervisory position (funded jointly by neighbouring developments). This has been secured.

Response to Network Rail

12.38 Network Rail (NR) has raised an objection to the proposed application. The substance of this objection relates to the application failing to ‘properly identify and mitigate against the impacts of the proposals on the future safe and efficient operation of the station’. However, NR gives no indication of the impact they consider would derive from the development upon the capacity provision at Waterloo Station. Any contributions sought to mitigate the impact of development are required to conform with the NPPF, and be 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.

12.39 The TA submitted with the application identifies that the development would not impact significantly upon existing passenger numbers making use of the services to and from Waterloo (and Waterloo East). Indeed, the combined effect upon the station with the Elizabeth House scheme is a 1.3% increase in passenger numbers at the AM peak (0800-0900 hours) and 0.3% in the PM peak (1700-1800 hours). This is before 10-car train upgrades, which could be in place ahead of the first occupation of development (anticipated as 4 years following commencement of work). NR are critical of the assessment made based upon a 2008 dataset used for TfLs Waterloo Data Analysis (WDA) study for demand figures for Waterloo and Waterloo East Stations. The figures, as being accurate for 2008, are not contested by NR, however, the accuracy of their representation in the current condition is queried.

12.40 The TA confirms that following a request from TfL (ahead of submission of the application at the same time NR were consulted to scope out the baseline conditions that should be used within the assessment), that the baseline data contained within a draft version of the WDA dated June 2012 be used in the assessment of public transport effects. Whilst NR advise that they are due to carry out a study later in 2013 upon current capacity at the

station, the approach promoted by TfL using the most recent data from 2012, not 2008, is appropriate. NR have been encouraged throughout the application process to provide details on the impact they consider the development would give rise to, but for which the modelling of the scheme against the most recent and up-to-date data illustrates it would not. It is entirely unreasonable for development to await NRs own study where assessment of the impacts has been made in regard to up-to-date data contrary to the impression promoted by NR.

12.41 NR suggest that the development, unlike the Elizabeth House scheme, would not improve access to and from the station to aid station permeability. At the same time NR recognise that there are competing demands in the area, and as such it should be acknowledged that new development can not be tasked to overcome all existing issues but, as set out above, be required to address its own impact. The Elizabeth House scheme contributed significantly towards improvements that Waterloo Station, and in respect of the viability of the scheme this came ahead as a priority to other contributions that could have been captured. The Shell development is not divorced from its local area. It is unreasonable to suggest that it will not help improve access to and from the station and aid permeability. The scheme responds to the objectives for improved permeability across Waterloo, responding to the improvements promoted within the Elizabeth House scheme and correspondingly providing for an improved public realm across York Road, and at its northern most pedestrian crossing. Routes through the site have been presented above and address the objectives for improved legibility in the area.

12.42 Whilst the objections from NR are noted, the development is not modelled to result in any significant negative impact upon Waterloo Station. It also contributes to public realm improvements including increased permeability in the area and has a dialogue with the adjacent Elizabeth House scheme which does have a more immediate relationship to the station (and as a result the resolution to grant planning permission for that scheme included specific obligations to account for the close interface with the Station).

12.43 Overall, the development would deliver permanent changes to the public realm and as a consequence the movement around the site. In particular, improvements would be made to the permeability across the site. The proposed development would see a reduction in the parking capacity at the site from the existing position, and whilst the provision would be in excess of the preferred ratio, this is marginal given the scale of development. The scheme would result in no impact upon existing capacity demands to the local Bus Network nor is it modelled on Waterloo Station. Servicing and deliveries to the site will be closely managed, and improvements to Chicheley Street, Belvedere Road and York Road will be achieved. In respect of the former, this is to prioritise the pedestrian experience, and to the latter will be directly responsive to the proposals for Elizabeth House. Given the excellent PTAL rating for the site, the development is considered to result in no undue impact with respect to transport matters where relevant conditions and section 106 contributions are secured.

Response to the GLA

12.44 The GLA are in support of the principle of the housing for the development, however, it was noted that the affordable housing offer is still subject of negotiation. The assessment of the viability to the scheme has been tested by the Councils independent consultants, and it is found that the scheme economics are challenging. Whilst the development would deliver affordable housing both on and off site, a Review Mechanism is also secured under the S106 package to capture the delivery of monies for additional affordable housing where improvements to the viability arise.

12.45 Throughout the detailed design of buildings 4A and 4B, comments were raised to the overall location and positioning of these buildings. Officers consider that the proposed locations of these building would make a positive contribution as it would integrate the development into the wider surroundings. Furthermore, the proposed ground floor areas would be animated with ground floor uses, integrating the use of the development further.

13 S106, CIL, Impact Upon Local Infra structure, and Benefits for the Wider Community

13.1 The Community Infrastructure Levy Regulations 2010 explicitly set out that planning permission should only be granted subject to completion of a planning obligation where the obligation meets all of the following tests. A planning obligation should be: (i) necessary to make the development acceptable in planning terms; (ii) directly related to the development; and (iii) fairly and reasonably related in scale and kind to the development.

13.2 Policy S10 of the Core Strategy sets out the circumstances in which planning obligations will be expected from developers. In particular it sets out that planning obligations will be sought to mitigate the direct impact of development, secure its implementation, control phasing where necessary, and to secure and contribute to the delivery of infrastructure made necessary by the development - subject to the particular circumstances of the development in question and the nature and extent of impact and needs created.

13.3 With specific regard to Waterloo, Policy PN1 of the Core Strategy sets out that the council will ensure that development is linked with the wider area and that it secures benefits for the wider community through contributions to necessary social and physical infrastructure needs arising from development in particular for public transport, education and other community facilities and securing employment and training opportunities to address issues of worklessness in the borough and the setting up of a local project bank in order to mitigate the impacts of development.

13.4 On 1st April 2012, the Mayor’s Community Infrastructure Levy (CIL) came into effect across London to secure funding for Crossrail. The application development would be subject to a CIL charge, based on £35 per sq m on all new net floorspace based on Gross Internal Area. This floorspace figure

applies to the retail, B1 office, residential, basement, and plant areas. At the time of writing further information and clarification is awaited from Sainsbury’s on these floorspace figures.

Section 106 Heads of Terms

13.5 Affordable Housing

• The developer shall submit a planning application for the construction of no less than 70 affordable units at the Ethelred Estate, which to the best of its knowledge shall be valid at the point of receipt, no later than 3 months following the final resolution for approval. • The developer shall secure the provision of 70 affordable units on land at the Ethelred Estate. • The developer shall secure the provision of 98 units on site as affordable housing with Building 3. No less than 52 units shall be provided as Affordable Rent (Extra Care) and no less than 46 shall be provided as Intermediate Rent, all with affordable service costs. • Not more than 50% of any one of the open market residential blocks (4a, 4b,5, 6 or 7) shall be occupied until the 98 on site units have been completed and the developer has entered into and exchange an agreed for sale or an agreement for lease of the affordable units with a registered provider. • No residential block shall be occupied until the completion and transfer of the off=site affordable housing has been provided. • A review of the scheme GDV generated by the entire development at a point equal to 70% of unit sales, to provide a financial contribution that is equivalent to the additional affordable housing required to meet the 40% policy target.

13.6 Public Realm, Transport and Highways

• Highways and/or external public realm improvements to York Road, Chicheley Street, Sutton Walk and Belvedere Road (estimated value of £9,300,000.00). • Payment by the landowner/developer towards provision of 60 Boris Bikes (circa £230,000.00) • Payment by the landowner/developer of £200,000.00 towards Milk Passage • Payment by the landowner/developer of £400,000.00 towards Imax roundabout • No business or residential parking permits • Strategy to promote and provide connectivity in area for the existing National Cycle Network • Car club membership for a period of five years to be provided at nil cost to all residential occupiers, and the provision of no less than 2 spaces on-site in perpetuity. • Works to LUL Ticket Hall to Building 3 (estimated value of £6,250,000.00). • Payment by the landowner/developer of a revenues contribution of

£117,277.68 (with an annual figure of £60,000.00 to be paid per annum for ten years from the date of the decision) • Travel Plan Contribution - £1,000.00 • Payment by the development of £150,000.00 towards the provision of trees on York Road and associated servicing works. • Landscaping completion program • Improved waterloo signage including no less than £30,000.00 contribution for legible London panels. • Developer to use Reasonable endeavours towards the delivery op opening the arches to the south elevation of Railway Viaduct, including program of temporary enhancements. • Removal /temporary closure of pedestrian footbridge and related works to Victory Arch if necessary. • Waterloo Maintenance Group • Estate management plan to be submitted to contain details of: • 24/7 unrestricted public access through site, • cleaning and maintenance plan • security management plan

13.7 Social and Community Infrastructure contribution

• Payment by the landowner/developer of a Health contribution of £927,239.00 • Payment by the landowner/developer of an education contribution of £2,005,981.00 • Payment by the landowner/developer of a community facilities contribution of £1,000,000.00 • Community facility on-site or equivalent contribution of no less than £300,000.00 to be paid by the developer toward community infrastructure. • Re-provision of police facility including temporary on-site accommodation during construction unless otherwise agreed in consultation with the Metropolitan Police

13.8 Architect, Open space, Public Art and Play space

• Retention of Squire and Partners as architect during construction of the entire development, including Building 1, 4a and 4 b or alternative architectural firm as to be advised in writing. • Retention of KPF as architect during construction of Building 2 or alternative architectural firm as to be advised in writing. • Retention of Patel Taylor as architect during construction of Building 3 or alternative architectural firm as to be advised in writing. • Retention of Stanton Williams as architect during construction of Building 5 or alternative architectural firm as to be advised in writing. • Retention of Grid as architect during construction of Building 6 and 7 or

alternative architectural firm as to be advised in writing. • Retention of landscape Architects Townsend or alternative landscape architectural firm as to be advised in writing • Payment by the landowner/developer of £162,678.00 towards Children and young people play space • Payment by the landowner/developer of £1,010,098.75 towards Open Space • Public art strategy for the site • Development period terrorism protection plan • Payment of £1,000,000.00 to provision of swimming pool off-site. 13.9 Construction

• Payment by the landowner/developer of a Local Labour in construction contribution of £650,000.00 • Onsite operatives to include 15% as local labour. • Onsite operatives to include 5% (10% stretch target) as local apprentices to then be tracked (where off-site) and in any case until completion of certified apprenticeships • Developer to continue to maintain the South London Procurement Network up to two years post first occupation or until 31.12.2019 whichever is earlier or as may otherwise be agreed in writing with the Authority. • Developer to employ on-site workplace co-ordinator during the course of the construction period (including responsibility for Employment and Skills Plan in line with CITB or other industry standards and in consultation with Lambeth Working. • On-site training facility. • Considerate Contractor Scheme – the applicant to carry out all works in keeping with the National Considerate Contractor Scheme • Neighbourhood co-ordination group to be set up, to meet bi-monthly, the members of which are to be agreed in advance with the Local Planning Authority and minutes to be circulated by the developer to all those involved. • Undertaking of an interference study in relation to TV and radio reception • Waterloo construction co-ordination strategy

13.10 Jobs during development life

• Completed development Economic Strategy to be agreed with LBL including: - Employment strategy, including engagement with brokerage services and encouraging tenants to advertise jobs through local means ahead of the open market and with a target for local component of retail employment to be a minimum of 20%.

- Approach to retail and leisure to include details of how the applicants will engage with local partners to maximise the benefits of the retail in Shell as part of the wider Waterloo/South Bank area including where appropriate temporary displays/pop-ups/art installations and benefits and engagement with Waterloo Quarter BID (or any successor), SBEG, other major developments and Lower Marsh traders. - Details of Shell PLC engagement with Lambeth to maximise local benefits from CSR activities, including education and training. • Payment by the landowner/developer of a Lambeth Job Brokerage contribution of £500,000.00 • Payment by the landowner/developer of a ten year sponsorship from first occupation toward the Lambeth Job Brokerage equal to £50,000.00 per annum. • No less than 10x Two week work experience programme for local residents aged 15 to 18 years old. Details to be provided how local schools will be actively engaged.

13.11 Energy and Sustainability

• Site wide district heat network, with connection to neighbouring sites, and future proofing for wider area provision. 13.12 Other

• Council Fee

14 Conclusion

14.1 The redevelopment proposals would provide a truly mixed use scheme comprising office, residential, retail, leisure and community leisure uses.

14.2 The housing proposed would help boost the housing supply within the borough. The proposal would provide both on-site and off-site affordable housing which would benefit different housing needs and as a result this would contribute towards the objectives of delivering mixed and balance communities.

14.3 The proposed office floor space would contribute to job targets within the Waterloo area and address the role Lambeth has to play within the Central Activities Zone. There would be over 6,000 jobs available at the site. The redevelopment proposals would also enable Shell to consolidate its activities and base its European Headquarters in Waterloo giving certainty to the implementation of the application and impetus to regeneration of neighbouring sites.

14.4 The design of the redevelopment proposals has responded to comments made during pre-application discussions and the quality of the design would add to the overall quality of the area in the long term and create a new part of London to live, work and visit. The evolution of the design from an

overarching masterplan lends uniformity to the scheme, whilst achieving individuality to the character of each building. Whilst it is acknowledged that the redevelopment proposals have also been sensitively designed having regard to the surrounding heritage assets and strategic views, some harm will result but that harm is less than substantial and far outweighed by the public benefits that would be achieved.

14.5 The improvements to pedestrian routes around the site and the proposed pedestrian routes through it ensure that the redevelopment proposals integrate well with the surrounding streets and converging public realm improvements around Waterloo Station. The public realm, especially the proposed public square, has been designed to be adaptable to different activities. The redevelopment proposals are legible and the masterplan creates gateways, focal points and landmarks to help people find their way.

14.6 Whilst there are some transport and environmental impacts from the scheme, there is an inevitability in this respect, and the impact is considered to be negligible and in all other cases overcome by the imposition of conditions.

14.7 The redevelopment proposals enable significant regeneration benefits to be provided, with up to 877 new homes and a contribution of £9.7 million in additional household and £5.9 million employee spend to the local economy. A multi-million pound investment would also be provided through section 106 contributions in the local area including open space, sports and leisure provision, education, health, community facilities and transport.

14.8 Overall, the proposal has engaged with the aspirations for the site across the thread of policy hierarchies, and is recommended for approval.

15 Recommendation

15.1 Grant conditional planning permission subject to a Section106 Agreement and Stage 2 Referral to the GLA and The Secretary of State (SoS).

16 Summary of Reasons

16.1 In deciding to grant planning permission, the Council has had regard to the relevant policies of the Development Plan and all other relevant material considerations. Having weighed the merits of the proposal in the context of these issues, it is considered that planning permission should be granted subject to the conditions listed below. In reaching this decision the following policies were relevant:

16.2 Core Strategy Policies S1, S2, S3, S4, S5, S6, S7, S8, S9, S10 and PN1; Saved UDP Policies 7, 9,14, 19, 21, 23, 26, 29, 30, 31, 32, 33, 35, 37, 38, 39, 40, 41, 43, 45, 46, 47 and 50. The application also complies with the following SPD’s: Waterloo Area; Housing Development and House Conversions; Safer Built Environments; Sustainable Design and Construction; S106 Planning Obligation

17 Recommended Conditions

Full Application Reference - 12/04708/FUL

1. The development to which this permission relates must be begun not later than the expiration of three years beginning from the date of this decision notice.

Reason: To comply with Section 91(1) (a) of the Town and Country Planning Act 1990.

2. The development hereby permitted shall be carried out in accordance with the approved plans listed in Schedule x of this decision notice, other than where those details are altered pursuant to the requirements of the conditions of this planning permission. For the avoidance of doubt, Schedule x forms part of this condition.

Reason: Otherwise than as set out in the decision and conditions, it is necessary that the development be carried out in accordance with the approved plans for the avoidance of doubt and in the interests of proper planning

3. The first component of the development (excluding demolition) shall comprise Building 1 and Basement works as defined on drawings 11016 MP_P_AL_C645_002 Rev 00, 11016 _C645_B2_P_B1_002 Rev 01, 11016 _C645_B2_P_B1M_002 Rev 01, 11016 _C645_B2_P_B2_002 Rev 01 and 11016 _C645_B2_P_B3_002 Rev 01. Prior to the commencement of the remainder of the development, a Construction Sequencing Plan shall be submitted to the local planning authority for approval. The Construction Sequencing Plan shall include details of the sequence of the construction of the proposed buildings, landscaping and any works to the York Road Footbridge (as shown on drawings 11016 MP_P_AL_C645_002 Rev 00, 11016_B0_P_00_G710_001 Rev 01 and 11016_B0_P_00_G710_002 Rev 01). There shall be no variations to the approved Construction Sequencing Plan save where this is approved in writing by the Local Planning Authority.

Reason: To ensure that the development sequencing and provision of detailed design information occurs in a satisfactory order.

Environmental Mitigation

4. Before any demolition commences full details of the proposed demolition methodology, in the form of a Method of Demolition Statement, shall be submitted to and approved in writing by the local planning authority. The developer will be working with other developers in the area to minimise demolition impacts. The Method of Demolition Statement shall include details regarding: consultation with neighbours regarding the timing and coordination of works; the

notification of neighbours with regard to specific works; advance notification of road closures; details regarding parking, deliveries, and storage; details regarding dust mitigation; details of measures to prevent the deposit of mud and debris on the public highway; and other measures to mitigate the impact of demolition upon the amenity of the area and the function and safety of the highway network. Demolition shall not begin until provision has been made to accommodate all site operatives', visitors' and vehicles’ loading, off- loading, parking and turning within the site or otherwise during the demolition period in accordance with the approved details. The details of the approved Method of Demolition Statement must be implemented and complied with for the duration of the demolition process. These details shall be submitted to and approved in writing by the Local Planning Authority prior to the commencement of demolition. The details of the approved Method of Construction Statement must be implemented and complied with for the duration of the construction process.

Reason: To minimise danger and inconvenience to highway users. (Policy 9 of the Saved Unitary Development Plan and Policy S4 of the Core Strategy)

5. Before any development commences (other than demolition) full details of the proposed construction methodology, in the form of a Method of Construction Statement, shall be submitted to and approved in writing by the local planning authority. The developer will be working with other developers in the area to minimise construction impacts. The Method of Construction Statement shall include details regarding: consultation with neighbours regarding the timing and coordination of works; the notification of neighbours with regard to specific works; advance notification of road closures; details regarding parking, deliveries, and storage; details regarding dust mitigation; details of measures to prevent the deposit of mud and debris on the public highway; and other measures to mitigate the impact of construction upon the amenity of the area and the function and safety of the highway network. The development shall not begin until provision has been made to accommodate all site operatives', visitors' and construction vehicles’ loading, off-loading, parking and turning within the site or otherwise during the construction period in accordance with the approved details. These details shall be submitted to and approved in writing by the Local Planning Authority prior to the commencement of demolition. The details of the approved Method of Construction Statement must be implemented and complied with for the duration of the construction process.

Reason: To minimise danger and inconvenience to highway users. (Policy 9 of the Saved Unitary Development Plan and Policy S4 of the Core Strategy)

6. The development hereby permitted shall not be commenced (other than demolition) until a detailed Design and Method Statement for all

of the foundations, basement and ground floor structures, or for any other structures below ground level, including piling (temporary and permanent), has been submitted to and approved in writing by the local planning authority with prior consultation with London Underground.

a) provide details on all structures referred to above to be used in the construction of the development; b) demonstrate how the development works would accommodate the location of the existing London Underground structures and tunnels; c) demonstrate how the development works would accommodate ground movement arising from the construction thereof; and d) set out the proposed mitigation for the effects of noise and vibration arising from the adjoining operations within the structures and tunnels.

Thereafter all structures and works shall be implemented in accordance with the Design and Method Statement hereby approved. set out in the approved Design and Method Statement shall be completed, in their entirety, as part of the relevant part of the development and before any part of the building hereby permitted is occupied.

Reason: To ensure that the development does not impact on existing London Underground transport infrastructure, in accordance with London Plan policy 3C.4.

7. Demolition works should be undertaken outside of the bird nesting season (generally accepted as being between March and July inclusive). If this is not possible, all the trees, scrub and buildings should be searched for the presence of nesting birds. If any are found the nests should be protected until such time as the young have fledged and left the nest. These protection details should be submitted to and approved in writing by the Local Planning Authority prior to the implementation of the relevant part of the development.

Reason: In the interest of preserving ecology on the development site in accordance with policy 7.19 of the London Plan.

Design

8. Notwithstanding the details shown on the drawings hereby approved, full particulars of item ‘a’ below shall be submitted to and approved by the Local Planning Authority in writing prior to commencement of development (other than demolition) unless non material changes are otherwise agreed in writing by the Local Planning Authority. The development shall not be carried out otherwise than in accordance with the details thus approved.

a. A sample of external materials;

b Notwithstanding the details shown on the drawings hereby approved full particulars of items a-h below (where relevant) shall be submitted to and approved by the Local Planning Authority in writing prior to commencement of development (other than demolition) of each building; the basement; and public realm (as shown on drawings 11016 MP_P_AL_C645_002 Rev 00, 11016 _C645_B2_P_B1_002 Rev 01, 11016 _C645_B2_P_B1M_002 Rev 01, 11016 _C645_B2_P_B2_002 Rev 01, 11016 _C645_B2_P_B3_002 Rev 01 and 11016_B0_P_00_G710_001 Rev 01 and 11016_B0_P_00_G710_002 Rev 01) unless non material changes are otherwise agreed in writing by the Local Planning Authority. The development shall not be carried out otherwise than in accordance with the details thus approved.

c. Mock up panels of typical elevation window bays;

d. Façade design and detailing at 1:20 and 1:5 scale to include (where relevant) details of the precast concrete, reveal depth, glass, mullion, transom, fins and their supporting structure, opening windows (or equivalent), the integration of the façade cleaning rails and any external louvers, illustrating the different conditions over the building;

e. Location and dimension details of all external pillars;

f. Details of building soffits;

g. Full ground and first floor detailed elevation drawings of the buildings including details of entrance doors, canopies, fire escapes and service doors;

h. Details of basement ventilation strategy.

i. Finishing details to all external pillars

j. Details of louvers, PV panels, façade cleaning equipment, plant and machinery and other excrescences at roof level (including screening).

Reason: To ensure that the external appearance of the building is satisfactory and does not detract from the character and visual amenity of the area along with setting of the adjoining conservation and listed buildings in accordance with policies 31, 33, 40, 45 and 47 of the Saved Unitary Development Plan along with policy S9 of the Core Strategy.

10. A detailed signage/advertisement strategy shall be submitted to and approved in writing by the Local Planning Authority prior to commencement of all works above ground of the relevant building (as shown on drawing 11016 MP_P_AL_C645_002 Rev 00). All

signage/advertisement to be affixed to the building to be in accordance with the approved strategy unless otherwise agreed in writing by the Local Planning Authority.

Reason: To ensure that the appearance of the development is satisfactory and does not detract from the character and visual amenity of the area (Policies 33 and 37 and 47 of the Saved Unitary Development Plan and Policy S9 of the Core Strategy).

11. Prior to the commencement of any relevant lighting works, full details of a lighting strategy for any lighting to be affixed to the relevant building shall be submitted to and approved in writing by the local planning authority. The approved lighting shall be installed before the relevant building is first occupied, or in accordance with an agreed implementation strategy, and retained thereafter for the duration of the development in accordance with the approved details.

Reason: To ensure that satisfactory attention is given to detailed design, to security and community safety and to providing acceptable living environments for future residents of the development (Policy 7, 32 and 33 of Lambeth’s Unitary Development Plan and Policies S2, S9 and PN1 of Lambeth’s Core Strategy).

12. No plumbing or pipes, other than rainwater pipes, shall be fixed to the external faces of buildings or associated structures.

Reason: To ensure an appropriate standard of design (Policy 33 Lambeth’s Unitary Development Plan and Policy S9 and PN1 of Lambeth’s Core Strategy).

13. A landscaping scheme, including hard and soft landscaping, street furniture and lighting not affixed to buildings, illustrated on detailed drawings shall be submitted to and approved by the Local Planning Authority, in writing, prior to completion to shell and core of any Building as shown on drawing 11016 MP_P_AL_C645_002 Rev 00. Soft landscaping details to include the planting of trees and shrubs showing species, type of stock, numbers of trees and shrubs to be included and showing areas to be grass seeded or turfed, planter profiles; all hard landscaping including all ground surfaces, seating, lighting of all external public areas, refuse disposal points, designated smoking areas, secure and covered cycle stands, bollards, vehicle crossovers/access points, any ramps or stairs plus wheel chair access together with finished ground levels and site wide topographical levels; all landscaping in accordance with the approved scheme, and approved, shall be carried out in accordance with a timescale to be agreed in writing with the Local Planning Authority, and shall be maintained to the satisfaction of the Local Planning Authority for a period of ten years, such maintenance to include the replacement of any plants/trees that die, or are severely damaged, seriously diseased, or removed, upkeep of ground surfaces and hard landscaping features as well as cleaning schedule to include removal

of graffiti/chewing gum.

Reason: To provide a high environmental standard in the interest of the site and wider area (Policies 31, 33, 39 of the Saved Unitary Development Plan and Policy S9 of the Core Strategy).

14. Details of the dismantling / removal, storage and reinstatement, within the application site of the following artefacts and art works shall be submitted to and approved in writing by the Local Planning Authority prior to the commencement of development for the following:

a. The Motor Cyclist Statue (presently in the courtyard); b. Aumonier’s ‘sphere’ (presently on belvedere Road) c. The two carved Portland stone shells (presently flanking the high level footbridge entrance on York Road) d. The bronze Shell cartouche (presently marking the secondary entrance to Belvedere Road ) e. The shell embellished lead-work (presently on the Chicheley Street podium canopies)

Reason - in order to preserve the special interest o the locally listed site and character and appearance of the conservation area in accordance with policies 46 and 47 of the Saved Unitary Development Plan.

15. The theatre interior and the interior of the swimming pool shall be recorded (photographically and with measured drawings) prior to dismantling; the records made being deposited in the London Historic Monuments Record and attempts shall be made to secure the salvage and re-use (on or off site) of their decorative elements. Preferably these should be first offered to relevant archives, museums (or similar) before disposal on the open market.

Trees

16. No trees other than those identified to be removed in the approved document Arboricultural Development Statement (CBA 10073 V3) prepared by CBA Trees dated March 2013, shall be felled, pruned, uprooted, damaged or otherwise disturbed without the prior written agreement of the Local Planning Authority.

Reason: To ensure the retention of, and avoid damage to, the retained trees on the site which represent an important visual amenity to the locality (Policies 31, 33, 38 and 39 of the Unitary Development Plan: Policies saved beyond 5th August 2010 and not superseded by the Local Development Framework Core Strategy January 2011 and

Policies S1 and S9 of the Local Development Framework Core Strategy (January 2011)).

17. All tree protection measures, including all arboricultural method statements, as set out in the Approved Document Arboricultural Development Statement (CBA 10073 V3) prepared by CBA Trees dated March 2013 shall be strictly adhered to and implemented before the commencement of any part of the development hereby approved. The tree protection measures and arboricultural method statements shall remain effective and in place for the duration of the construction of the development, and only be dismantled or removed during construction following the written agreement of the Local Planning Authority.

18. All arboricultural site monitoring, site supervision and subsequent recording keeping of all tree protection measures shall be carried out in strict accordance with the approved details as contained in Approved Document Arboricultural Development Statement (CBA 10073 V3) prepared by CBA Trees dated March 2013 .

19. A drawing showing the confirmed route of all service and drainage routes outside of all retained tree root protection areas (BS5837:2012) shall be submitted to and approved in a timescale to be agreed in writing with the Local Planning authority . The development shall thereafter be implemented in strict accordance with the approved details.

Residenti al Amenity

20. Prior to commencement of building works above ground, full details of sound insulation for the residential units which shall show how the building has been designed to meet the following standards, shall be submitted to and approved in writing by the local planning authority:

for living rooms, 35 dB(A) LAeq 16 hour between 0700 and 2300 hours; for bedrooms, 30 dB(A) LAeq 8 hour between 2300 and 0700 hours; and 45 dB(A) max for any individual noise event (measured with F time weighting) between 2300 and 0700 hrs

The development shall be carried out in accordance with the approved details.

Reason: To ensure that no nuisance or disturbance is caused to the detriment of the amenities of future occupiers (Policy 7 of the Saved Unitary Development Plan and policy 7.15 of the London Plan).

21. There shall be no amplified sound, speech or music (excluding voice alarm systems for fire alarm and evacuation purposes) used in connection with the commercial premises hereby approved which is audible above background noise levels when measured outside the nearest residential property.

Reason: To safeguard the amenities of future residential occupiers and the surrounding area (Policies 7 and 29 of Lambeth’s Unitary Development Plan and policy 7.15 of the London Plan).

22. Prior to commencement of relevant works to each building as shown on drawing 11016 MP_P_AL_C645_002 Rev 00 and relevant works to the basement as shown on drawings 11016 _C645_B2_P_B1_002 Rev 01, 11016 _C645_B2_P_B1M_002 Rev 01, 11016 _C645_B2_P_B2_002 Rev 01 and 11016 _C645_B2_P_B3_002 Rev 01 , full details of internal and external plant equipment and trunking, including building services plant, ventilation and filtration equipment and commercial kitchen exhaust ducting / ventilation to terminate at roof level, shall be submitted to and approved in writing by the local planning authority. All flues, ducting and other equipment shall be installed in accordance with the approved details prior to the use commencing on site and shall thereafter be maintained in accordance with the manufacturers’ instructions.

Reason: To ensure that no nuisance or disturbance is caused to the detriment of the amenities of future residential occupiers or of the area generally (Policy 7 and 29 of Lambeth’s Unitary Development Plan and Policy S2 and PN1 of Lambeth’s Core Strategy and 7.15 of the London Plan).

23. Noise from any mechanical equipment or building services plant shall not exceed the background noise level when measured outside the window of the nearest noise sensitive or residential premises, when measured as a L90 dB(A) 1 hour.

Reason: To protect the amenities of future residential occupiers and the surrounding area (Policies 7 and 29 of Lambeth’s Unitary Development Plan and policy 7.15 of the London Plan).

Public Safety

24. Prior to commencement of works above ground to each building as shown on drawing 11016 MP_P_AL_C645_002 Rev 00 and public realm works as shown on drawings 11016_B0_P_00_G710_001 Rev 01 and 11016_B0_P_00_G710_002 Rev 01, a crime prevention strategy shall be submitted to and approved in writing by the Local Planning Authority in consultation with the Police. The strategy shall demonstrate how the development makes reasonable endeavours to meet 'Secured by Design' standards and shall include details on the following:

Secured by Design physical protection measures to be incorporated in both the commercial and residential units.

1.) External & Courtyard communal lighting be to BS 5489 2.) Full audio-visual access control measures are incorporated to all units. 3.) Monitored Alarm facilities should be provided to the commercial units. 4.) CCTV is recommended at the entrance and around the exterior of the site 5.) Plant rooms to be lockable with robust security rated doors 6.) Bin stores to be lockable 7.) Cycle stores to be lockable 8.) Security rated doors and windows for each unit 9.) Good lighting to achieve a minimum of 0.25 uniformity

Reason: To ensure that satisfactory attention is given to security and community safety (Policy 32 of the Saved Unitary Development Plan).

25. Prior to first occupation of the development an Evacuation Plan for safe access from the basement levels of the development to an upper level and a detailed flood warning system is to be submitted to and approved in writing by the local planning authority. The development shall be operated in accordance with the plan thereafter.

Reason: To reduce the risk to people using the basement levels in case of flooding due to breach or overtopping of the Thames tidal flood defences (Policy S6 of Lambeth’s Core Strategy).

Highways, Access and Parking

26. A Delivery and Servicing Management Plan shall be submitted to and approved in writing by the local planning authority prior to use of the development. The Plan shall require that no deliveries to the basement for the B1 or A1-A5 uses hereby approved shall be taken to, or dispatched from, the site between the hours of 0700 and 1000 or 1600 and 1900 Mondays to Saturdays, unless non material changes are otherwise agreed in writing by the Local Planning Authority. The measures approved in the Plan shall be implemented prior to the relevant uses commencing and shall be so maintained for the duration of the relevant uses.

Reason: To ensure that the delivery arrangements to the building as a whole are appropriate, to limit the effects of the increase in travel movements and to prevent deliveries during peak periods and in order to maintain the free flow of traffic on the adjoining highway. (Policies 9 and 33 of Lambeth’s Unitary Development Plan and Policies S2 and S4 of Lambeth’s Core Strategy).

27. A Delivery and Servicing Management Plan shall be submitted to and approved in writing by the local planning authority prior to use of the development. The Plan shall require details on vehicles would deliver to the site other than to the basement between the hours of 0700 and 1000 or 1600 and 1900 Mondays to Saturdays, unless non material changes are otherwise agreed in writing by the Local Planning Authority. The measures approved in the Plan shall be implemented prior to the relevant uses commencing and shall be so maintained for the duration of the relevant uses.

28. Prior to commencement of development (other than demolition) full details outlining the scheme parking for the office, retail and residential accommodation, garaging, manoeuvring, and the loading and unloading of vehicles shall be submitted to and approved in writing by the local planning authority and be laid out in accordance with the approved details prior to the occupation of the development hereby permitted and that area shall not thereafter be used for any other purpose, or obstructed in any way.

Reason: To enable vehicles to draw off, park and turn clear of the highway to minimise danger, obstruction and inconvenience to users of the adjoining highway (Policies 9 and 14 of Lambeth’s Unitary Development Plan and Policy S4 of Lambeth’s Core Strategy).

29. No part of the individual buildings hereby permitted shall be occupied

or used until the provision for cycle parking for that building shown on the application drawings has been implemented in full and the cycle parking shall thereafter be retained solely for its designated, as shown on drawings 11016 _C645_B2_P_B1_002 Rev 01, 11016 _C645_B2_P_B1M_002 Rev 01, 11016 _C645_B2_P_B2_002 Rev 01 and 11016 _C645_B2_P_B3_002 Rev 01.

Reason: To ensure adequate cycle parking is available on site and to promote sustainable modes of transport. (Policies 9 and 14 of Lambeth’s Unitary Development Plan and Policy S4 of Lambeth’s Core Strategy).

30. No doors or gates (other than for means of escape) shall be erected in a way that enables them to be opened over or across the adjoining footways, carriageways and public rights of way.

Reason: In the interests of public safety and to prevent obstruction of the public highway. (Policies 9 and 14 of Lambeth’s Unitary Development Plan and Policy S4 of Lambeth’s Core Strategy).

Water, Drainage and Waste

31. No development (other than demolition) shall commence on site until such time as impact studies pertaining to the existing water supply infrastructure have been submitted to and approved in writing by the local planning authority. The studies should determine the magnitude of any new additional capacity required in the system, a suitable connection point and measures for overcoming impact on the water supply infrastructure. The development shall be implemented in accordance with details approved in writing by the local planning authority.

Reason: To ensure that the water supply infrastructure has sufficient capacity to cope with additional demand generated by the development (Policy S6 of the Core Strategy).

32. Development shall not commence (other than demolition) until a drainage strategy, detailing any on and/ or off-site drainage works, has been submitted to and approved in writing by the local planning authority. The development shall thereafter be constructed in accordance with the approved details.

Reason: To ensure that sufficient capacity is made available to cope with the new development; and in order to avoid adverse environmental impact upon the community (Policy S6 of Lambeth’s Core Strategy).

33. The development hereby permitted shall only be operated in accordance with a Waste Management Strategy to be submitted and approved in writing by the local planning authority prior to the use of the development commencing.

Reason: To ensure that adequate provision is made for the storage of refuse and the provision of recycling facilities on the site and in the interests of the amenities of the area. (Policies 9 and 33 of Lambeth’s Unitary Development Plan and Policies S8 and S9 of Lambeth’s Core Strategy).

34. The development permitted by this planning permission shall only be carried out in accordance with the approved Flood Risk Assessment (FRA) by Waterman Transport and Development Ltd (dated April 2012) and the following mitigation measures detailed within the FRA:

Provision of on site surface water runoff attenuation of 495 cubic meters Finished floor levels are set no lower than 4.11m above Ordnance Datum (AOD)

The mitigation measures shall be fully implemented prior to occupation and subsequently in accordance with the timing/phasing arrangements embodied within the scheme, or within any other period as may subsequently be agreed, in writing, by the Local Planning Authority.

Reasons: To prevent flooding by ensuring the satisfactory storage of/disposal of surface water from the site; to reduce the risk of flooding to the proposed development and future occupants. To ensure that sufficient capacity is made available to cope with the new development; and in order to avoid adverse environmental impact upon the community (Policy S6 of Lambeth’s Core Strategy).

35. Prior to the commencement of development approved by this planning permission (or such other date or stage in development as may be agreed in writing with the Local Planning Authority), the following components of a scheme to deal with the risks associated with contamination of the site shall each be submitted to and approved, in writing, by the Local Planning Authority:

A desktop study, site investigation scheme and intrusive investigation, based on the above report, to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site. The desk study will identify all previous site uses, potential contaminants associated with those uses, a conceptual model of the site indicating sources, pathways and receptors and any potentially unacceptable risks arising from contamination at the site. The site investigation scheme will provide information for an assessment of the risk to all receptors that may be affected, including those off site. The risk assessment will assess the degree and nature of any contamination on site and to assess the risks posed by any contamination to human health, controlled waters and the wider environment; The results of the site investigation and detailed risk assessment referred to in (1) and, based on these, an options appraisal and

remediation strategy giving full details of the remediation measures required and how they are to be undertaken; A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in the remediation strategy in (2) are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action

Any changes to these components require the express consent of the Local Planning Authority. The scheme shall be implemented as approved and any required remediation works completed prior to the commencement of development (other than demolition).

Reason: For the protection of Controlled Waters. The site is located over a Secondary Aquifer and it is understood that the site may be affected by historic contamination from past activities and current conditions. To ensure that sufficient capacity is made available to cope with the new development; and in order to avoid adverse environmental impact upon the community. To remove the risk of contaminated land in the interests of the safety of residents and visitors (Policy 7.13 of the London Plan and Policy S6 of Lambeth’s Core Strategy).

36. If, during development, contamination not previously identified is found to be present at the site then no further development (unless otherwise agreed in writing with the Local Planning Authority) shall be carried out on that part of the site until the developer has submitted, and obtained written approval from the Local Planning Authority for, a remediation strategy detailing how this unsuspected contamination shall be dealt with. The remediation strategy shall be implemented as approved and reported to the satisfaction of the Local Planning Authority.

Reason: Given the history of the site, there is a potential for unexpected contamination to be identified during ground works, particularly during basement ground works. We should be consulted should any significant contamination be identified that could present an unacceptable risk to Controlled Waters. To ensure that sufficient capacity is made available to cope with the new development; and in order to avoid adverse environmental impact upon the community (Policy S6 of Lambeth’s Core Strategy).

37. Prior to occupation of the development, a verification report demonstrating completion of the works set out in the approved remediation strategy and the effectiveness of the remediation shall be submitted to and approved, in writing, by the Local Planning Authority. The report shall include results of sampling and monitoring carried out in accordance with the approved verification plan to demonstrate that the site remediation criteria have been met. It shall also include any plan (a ‘long-term monitoring and maintenance plan’) for longer-term monitoring of pollutant linkages, maintenance and

arrangements for contingency action, as identified in the verification plan, if appropriate, and for the reporting of this to the Local Planning Authority. Any long-term monitoring and maintenance plan shall be implemented as approved.

Reason: Should remediation be deemed necessary, the applicant should demonstrate that any remedial measures have been undertaken as agreed and the environmental risks have been satisfactorily managed so that the site is deemed suitable for use. To ensure that sufficient capacity is made available to cope with the new development; and in order to avoid adverse environmental impact upon the community (Policy S6 of Lambeth’s Core Strategy).

38. Piling or any other foundation designs using penetrative methods shall not be permitted other than with the express written consent of the Local Planning Authority in consultation with the Environment Agency, which may be given for those parts of the site where it has been demonstrated that there is no resultant unacceptable risk to groundwater. The development shall be carried out in accordance with the approved details.

Reason: The developer should be aware of the potential risks associated with the use of piling where contamination is an issue. Piling or other penetrative methods of foundation design on contaminated sites can potentially result in unacceptable risks to underlying groundwater. We recommend that where soil contamination is present, a risk assessment is carried out in accordance with our guidance 'Piling into Contaminated Sites'. We will not permit piling activities on parts of a site where an unacceptable risk is posed to Controlled Waters. To ensure that sufficient capacity is made available to cope with the new development; and in order to avoid adverse environmental impact upon the community (Policy S6 of Lambeth’s Core Strategy).

39. Whilst the principles and installation of sustainable drainage schemes are to be encouraged, no infiltration of surface water drainage into the ground is permitted other than with the express written consent of the Local Planning Authority, which may be given for those parts of the site where it has been demonstrated that there is no resultant unacceptable risk to Controlled Waters. The development shall be carried out in accordance with the approval details.

Reason: Infiltrating water has the potential to cause remobilisation of contaminants present in shallow soil/made ground which could ultimately cause pollution of groundwater. To ensure that sufficient capacity is made available to cope with the new development; and in order to avoid adverse environmental impact upon the community (Policy S6 of Lambeth’s Core Strategy).

Hours and control of use

40. The A4 use hereby permitted shall only be carried out between the hours of 1100 to 2300 hours Monday to Wednesday, 1100 to 2400 hours Thursday to Saturday and 1000 to 2200 hours on Sundays and Public Holidays. All patrons are to have left the premises within an hour of closing.

Reason: To ensure that the use operates in a satisfactory manner and does not unduly disturb adjoining occupiers or prejudice local amenity generally.

41. The A3 use hereby permitted shall only be carried out between the hours of 0630 to 2300 hours Monday to Wednesday, 0630 to 2400 hours Thursday to Saturday and 1000 to 2200 hours on Sundays and Public Holidays. All patrons are to have left the premises within an hour of closing.

Reason: To ensure that the use operates in a satisfactory manner and does not unduly disturb adjoining occupiers or prejudice local amenity generally.

42. The A1, and A2 use hereby permitted shall only be carried out between the hours of 0630 to 2200 hours Monday to Friday, 0800 to 2200 hours Saturday and 1000 to 1800 on Sundays and Public Holidays.

Reason: To ensure that the use operates in a satisfactory manner and does not unduly disturb adjoining occupiers or prejudice local amenity generally in accordance with policy 7 of the Saved Unitary Development Plan.

43. The A5 use hereby permitted shall only be carried out between the hours of 0730 to 2000 hours Monday to Friday, 0800 to 2000 hours Saturday and 1000 to 1800 on Sundays and Public Holidays.

44. Restriction on quantum/size of A5 units

45. The Class A2 use hereby approved shall not be operated as a betting office and shall only be used for all other purposes include in the Class A2 use of the Schedule of the Town and Country Planning (Use Classes) Order 1987 (as amended) or in any provision equivalent to that Class in any statutory instrument revoking or re-enacting that Order.

Reason: The authority has had special regard to the circumstances of

this use and Council policy and considers unrestricted A2 use would be unacceptable.

46. The class D2 use hereby approved shall not be operated other than as a gym and for no other purpose included in Class D2 use of the Schedule of the town and Country Planning (Use Classes) Order 1987 (as amended) or in any provision equivalent to that Class in any statutory instrument revoking or re-enacting that Order

Reason: In order to limit the flow of pedestrian and vehicular traffic that could be generated by the uses to the premises and to ensure that parking on the highway is contained to a minimum level, in the interests of road safety generally and avoidance of obstruction of the highway in accordance with policy 7, 14 and 33 of the Saved Unitary Development Plan.

Sustainability

47. Prior to first occupation of the each relevant building(s) as shown on drawing 11016 MP_P_AL_C645_002 Rev 00 evidence (e.g. photographs, installation contracts and as-built certificates under the Standard Assessment Procedure and National Calculation Method) should be submitted to the Local Planning Authority and approved in writing to show that the development has been constructed in accordance with the approved energy strategy.

Reason: To ensure that the development has an acceptable level of sustainability (Policy 35 of the London Borough of Lambeth Unitary Development Plan (2007): Policies saved beyond 5 August 2010 and not superseded by the LDF Core Strategy January 2011, and Policies S7 and S9 of the London Borough of Lambeth Core Strategy (January 2011)).

48. Full details demonstrating how the approved scheme has been designed to allow for the future connection to any neighbouring heating and cooling system shall be submitted to and approved in writing by the Local Planning Authority. Evidence that the approved scheme has been implemented shall be submitted to and approved by the Local Planning Authority prior to the issue of a certificate of practical completion (of the final building). The development shall be carried out in accordance with the approved design details and no alterations shall take place without the prior written consent of the Local Planning Authority.

49. Full details of an extensive green roof which shall be compliant with GRO Green Roof Code 2011 shall be submitted to and approved in writing by the Local Planning Authority prior to the implementation of the relevant part of the development hereby approved. The green roof submission must provide/comprise of the following information:

Biodiversity based with extensive/semi-intensive soils substrate which is commercial brick-based aggregate or equivalent with a varied substrate depth of 80 -150mm planted with 50% locally native herbs/wildflowers in addition to sedum, include additional features such as areas of bare shingle, areas of sand for burrowing invertebrates and individual logs or log piles. An ecological management and maintenance plan including the landscape features and a cross section of the roof.

The development shall be carried out strictly in accordance with the details approved, shall be maintained as such thereafter and no alterations to the approved scheme shall be permitted without the prior written consent of the Local Planning Authority. Evidence that the green roof has been installed in accordance with the details above should be submitted to and approved by the local planning authority prior to first occupation of each relevant building.

50. Within three months of work (excluding demolition) starting on site a design stage assessment report prepared by an accredited Code for Sustainable Homes assessor and a summary score sheets under the Code for Sustainable Homes (or such equivalent standard that replaces this) shall be submitted for approval in writing by the Local Planning Authority to show that a Level 4 rating shall be achieved on the residential portions of the site. This report shall be submitted to BRE and upon receipt a BRE Design Stage certificate certifying the development achieves a level 4 shall also be submitted to the local planning authority for approval.